Incitec Ammonium Nitrate Facility

The companies track record and the proximity of the site to Humans should stop this project before it gets started. It is unthinkable that the project has got to this stage, the people of Stockton and the greater Newcastle are will not let this go ahead. The compensation that the people are already owed due to this poorly run factory will only be multiplied if this project even looks like happening.

This proposal is not only outrageous and intellectually unbelievable, but it flies in the face of everything that people hold dear, ie. their personal safety and the right to feel protected in their own environment.

This explosives plant will be dangerously close to our City and environs, and right next door to a proven pollution hazard.

This is autocracy at its worst, and this policy MUST BE REJECTED. Any sane person cannot allow this proposal to succeed.

I currently live in Stockton and intend to retire sometime in the next 5 years. I have to put up with the coal dust that finds its way inside the house and settles almost every where upstairs and all over the outside of my house. We also have to contend with the ever growing problem of Orica on our door step. Having Incitec Pivot build another plant of similar nature again on our door step is totally irresponsible. There has to be a far safer place to build such a plant if in deed one is required. One would think there is enough output from Orica to satisfy the requirements of mining and the like. Orica has a bad reputation in Stockton and Mayfield areas without another company adding to the mix. It is about time someone stood up and told these conglomerates that enough is enough. I am sure and certain that I am not the only person who has this point of view. I personally don't care who reads this statement or where it is published as I firmly believe I won't be the only resident to voice an opinion on this matter.

I am writing to object to the proposed chemical manufacturing plant on Kooragang Island (application number SSD-4986).

I am opposed as this plant represents a serious risk to myself, my family and my community. I understand the incitec plant will be built next to the orica plant which has a terrible public safety record.

I am deeply concerned that an explosion could result in the destruction of my home and community and that my children, husband friends and other residents of stockton could be killed in such an explosion.

I am also concerned about air, water and soil pollution.

I am lastly concerned about the effect on housing prices.

I believe residents in Stockton are entitled to the same environmental protections as every other Australian citizen. I find it incredulous that a fertilizer manufacturer would from the outset try to duck out of its environmental requirements even before they start as evidenced by the attempt to re zone Stockton as an industrial / residential transition zone.

Incitec I believe are setting up to compete with orica and as such will be competing on price. Therefore there will be every incentive for them to cut costs on order to get the business. This is a bad start and has significant potential for harm Ro my area, my kids and my life. This I wholeheartedly object to the incited development proposal. Incidentally I have no objection to oricas proposals which seem to be far more safety conscious and not so business profit driven to the exclusion of my safety.

Sincerely.

I believe this submission should not go ahead as it provides an unacceptable risk to the residents of Stockton and Seaside Fern Bay.

I object this application because:

1. It is too close to homes and families (less than 1km from my home) - I fear for my own and my families safety due to the risk of explosion from storing 30,000 of ammonium nitrate. I experience anxiety at the thought of this application becoming a reality.

2. The increase in danger and risk of injury of transporting ammonium nitrate solution by trucks to Warkworth. This will create extra truck transport on the already congested Kooragang Island road and Hunter Valley roads from coal trucks.

3. The health and wellbeing of local fauna, flora and our waterways due to the production of ammonium nitrate and the waste products it would create.

I am not confident that the site would be managed safely as other industries nearby have been deceitful in their safety and accountability records.

I have lived in Stockton and Fern Bay for 56 years and have not been as fearful for the future of our local area ever before.

It is not just Stockton but the future of the suburbs in a 5-10 km radius from this proposed site that would be affected if an explosion occurs.

It is not acceptable for a site such as this to be built near homes and families.

UNACCEPTABLE RISK.

Based on the information I have to date:

Already we have large quantities of Ammonia Nitrate stored on a neighbouring site (Orica facility) which has the potential to kill and injure people within a 5km plus radius.

If this development was to be approved we are further adding to the risk of a large scale disaster.

The information I have is that these risks are real and there are examples of ammonia nitrate based disasters on record. Note, the quatities involved in historic disasters are nothing like the quantum's being proposed to be stored on Kooragang Island.

There is no evidence that these risks can be manage to the extent they are acceptable.

I am objecting to Incitec's proposed amonnium nitrate plant on Kooragang Island. If this plant goes ahead it will have the capacity to store thousands of tonnes of amonnium nitrate. Together with its proposed neighbor, Orica (which has a very bad public safety record) the two plants will hold enough ammonium nitrate to cause an explosion that some experts have estimated up to 75% of the size of the atomic bomb dropped on Hiroshima during World War Two.
Please prevent this from happening.

I strongly object to the Incitec Ammonium Nitrate Manufacturing Facility project SSD-4986 on Kooragang Island.
To have 2 plants producing ammonium nitrate side by side less than 1 kilometre from a residential area surely can not be best practice. This would present an unacceptable risk of expolsion to all residents of not only Stockton but suburbs within at least a 20 kilometre radius of Kooragang.
As a Stockton resident I am already impacted by 24 hour noise levels and any additional noise would be unacceptable.
This proposed plant would add to the already increasing levels of pollution; being dust, emissions and nitrogen oxides further adding to the range of escalating medical ailments in surrounding communities.
Risk of further pollution of the Hunter River estuary which is an internationally recognised protected wetland is again unacceptable.
I also feel there has been inadequate community consultation. Many residents in Stockton, Carrington, Tighes Hill, Mayfield and indeed many other potentially affected suburbs have not been given enough correct information on this potential project, leaving many in the dark.
Surely it's time that Corporations consider the negative effects on real people and the environment and realise that these issues are more important in the long term than financial gain. Australia is a big country! If this plant has to be built, it should be built a safe distance away from residential communities.

Please find submission attached

Susanna Scurry
54 Douglas St
Stockton 2295

Monday, October 22

As a resident of Stockton please accept this submission of objection regarding Incitec Pivot's proposed ammonium nitrate plant on Kooragang Island (SSD-4986).

Newcastle and the suburbs that surround the Port are demanding responsible planning decisions and the very thought of two ammonium nitrate plants, operating side-by-side just 800 from residents is insulting.

As a grandmother with grandkids who also live in Stockton, I strongly believe the proposal creates an unacceptable risk to me and my family and Incitec's Environmental Impact Statement does not address relevant concerns of explosive risk, noise, air and water pollution and possible impacts to house values.
After reviewing the EIS and attending public forums in the community, the main concerns I have are:

Potential for explosion
Incitec's EIS fails to adequately address my concern around the potential risks of storing 21,500 tons of ammonium nitrate (maximum storage capacity combining Orica and Incitec).

The blast contours in Incitec's EIS do not even reach Stockton, yet it's well known an ammonia nitrate explosion involving 300 tons of ammonium nitrate in Toulouse, France, killed 33 and injured thousands within a 5km radius in 2001.
I am aware that ammonium nitrate is an oxidising agent, not an explosive, however, it can be turned into an explosive both quickly and easily by shock waves, foreign matter, heat and pressure.

Whilst the risk of explosion is small, the impact of an explosion would be catastrophic and despite slogans in Incitec's EIS of "world's best practice' accidents do occur, take for instance Orica's Hexavalent Chromium leak in 2011.

One of the fundamental responsibilities of any Government is the welfare and protection of people and this proposal undermines the safety of around 50,000 residents within a 5km radius.

Government should note that if Incitec proceeds there is enough explosive power on Kooragang Island to match the Hiroshima atomic bomb (Hiroshima used 18,000 tons of TNT which is comparable to the 21,000 tons proposed by Incitec and Orica's current capacity).

The Department of Planning must also acknowledge that the South Australian Government is trying to shift Incitec's storage of AN in Port Adelaide due to explosion risk for residents, which is outlined by a SA WorkCover report. Such a massive concentration of ammonium nitrate storage with 800 m of residents is not acceptable to the communities that surround the proposal.

Air Pollution

What kind of environment are we creating when Stockton residents already deal with excessive coal dust and nitrous oxides from Orica;s plant.

Now we're expected to welcome another chemical plant that will worsening our air quality with dust and NOx gas which are detrimental to respiratory health, especially among the
young and elderly.

Nowhere in the world will you have such a high concentration of NOx gases with two large scale ammonium nitrate plants, operating so close to residents.

The cumulative air test present in IPL EIS are insufficient and fail to take in the present air pollution levels that residents experience.

Noise Pollution

Industrial noise, especially night-time noise is already a major concern which impacts my family directly. Incitec's EIS noise monitoring of the site was conducted when Orica's ammonia plant was not even in operation and proved that Orica is not meeting acceptable noise levels.

Furthermore, Incitec in their EIS, argue that "it is appropriate to relax the recommended levels for suburban areas by 5db".
Here are some extracts taken from different sections of Incitec's EIS on Noise.

"As the existing level of industrial noise exceeds noise amenity criteria recommended by the EPA's Industrial Noise Policy (INP) by a significant margin, alternate operational noise criteria has been nominated for the Project.

"Whilst the appropriate zoning in Stockton is recognised as
suburban, considering the adjoining industrial zoning it must be noted that a suburban/industrial interface exists. The Industrial Noise Policy, does not provide recommended industrial noise levels for suburban/industrial interfaces and therefore it is considered appropriate to relax the recommended levels for suburban areas by 5db.

"Given that IPL and Orica are the only two operators that could materially influence industrial noise, it's is proposed the adjacent sites assume an equal responsibility in achieving the nominated levels."

As a resident personally affected by noise from Orica and PWCS, I find the assertion of Stockton being an `interface' suburb offensive and the idea for government to `relax' noise limits completely absurd.

How can industry be trusted when Orica are well above night-time noise limits and Incitec are requesting special considerations?

Inadequate consultation

Many residents from Stockton, Carrington, Tighes Hill and Mayfield have been left in the dark on this project. Letter drops and one information session two months after the Orica disaster is not proper consultation for a project of such magnitude and widespread impacts.

Incitec's own `community perception' survey conducted in April 2012, identified less than a third of residents were unaware of the Project. Another example of poor consultation is residents that live within the outer rim of a 5 km radius have been excluded in any communication material. Suburbs such as Cooks Hill, Newcastle West and East, The Hill and Hamilton South have received no information regarding the proposal.

Now, Incitec has declared a two year delay in making any decision on the Project. This may please IPL's investors; however it prolongs resident uncertainty, stymies local investment and provides Incitec with an extended period to lobby Government ministers.

The amount of community consultation over a twelve month period does not match the enormity of the Project and its impacts on residents.

Impacting house prices

Incitec's EIS fails to address my concern that a second ammonium nitrate plant may impact the value of our two properties. We've already been unsuccessful in our attempts to sell one property this year and if Incitec's development is approved, the risk profile for Stockton will increase and it's highly likely that the value of properties may decrease. Downward pressure on properties would be a direct result from fewer new families moving into areas like Stockton and a reputational stigma for suburbs closest to two ammonium nitrate plants.

Incitec's EIS does not acknowledge this issue, nor does it address who would be responsible if property values were lowered by their Project.


Polluting the hunter river

It's deeply concerning that Incitec will be handed yet "another license to pollute" the Hunter River. If Incitec truly want to build a world-class plant then their EIS should reflect a plant with no effluent into the Hunter River. The river is an important recreational estuary for thousands of fisherman, not to mention that Kooragang is an international regonised RAMSAR wetland.

Excessive industrial development with a licenses to pollute the river close to a RAMSAR area is not common sense planning, nor does it position the Hunter River in a positive light to tourists.


As a submission maker, I can confirm that I have not made a political donation totaling $1000 or more in the past 2 years.
Yours Sincerely,

Susanna Scurry
54 Douglas St
Stockton 2295

Although the risk of explosion is low I believe the location is too close to residential suburbs particularly Stockton where I reside with my family.

To Whom it may Concern,

I am writing to express my objection to the proposed ammonium nitrate plant on Kooragang Island by Incitec Pivot. I live in Stockton with my family; we have a house here and my children attend the local school. We are concerned about the proposed development for a number of reasons, particularly the impact that construction and operation of the plant will have on the local community and our family.

It is realistic to expect there will be an increase in pollution of the air and water around the facility and port, an increase in noise and traffic through Kooragang Island, and damage to the local roads. Those will be clearly noticeable, but the hidden costs associated with the operation of such a large plant near residential communities are far more worrying. There is the risk of catastrophic explosion, chemical leakage, and the devaluation of surrounding land, including Stockton.

Having read the Environmental Impact Statement, our concerns have not been abated at all. The risk of explosion is still very real and completely unacceptable, considering the potential devastation it could cause. We have already been exposed to several chemical leaks from the neighbouring Orica plants, due to their disregard of the government's safety standards, and are not prepared to have to deal with any similar incidents from a new facility. The increase in pollution - air, water and noise - is also undeniable and simply not appropriate for an industrial facility so close to residential communities which were established many decades ago.

The people here in Stockton have already been severely affected by the industrial operations in Kooragang Island. The monitoring of current pollution-levels has been inadequate and therefore the basis for any increase is unsubstantiated.

Nicholas Hall - Planner
Mining and Industry Projects
Dept. of Planning and Infrastructure
GPO Box 39
SYDNEY 2001
[email protected]



Date 28/10/2012
Dear Sir/Madam
As a resident of Mayfield please accept this submission of objection regarding Incitec Pivot's proposed ammonium nitrate plant on Kooragang Island (SSD-4986).
In my opinion the proposal creates an unacceptable risk to nearby residents and Incitec's Environmental Impact Statement does not address my concerns of explosive risk, noise, air and water pollution and possible impacts to house values.
Newcastle and the suburbs that surround the Port are demanding responsible planning decisions and the thought of two ammonium nitrate plants, operating side-by-side just 800 meters from residents is a planning disaster.
I do not accept that Newcastle Port, its present infrastructure and industrial focus is in the best interest of Newcastle and the Hunter Region. The potential for Port facilities to be left as a series of stranded assets in the foreseeable future is real and will be of significant cost to the community and our region
Incitec has suspended its feasibility study on the development of the project (Sept 2012 ASX Announcement) deferring the decision on whether to proceed with the development for at least two years. In the meantime, however, it is our understanding that they wish to have the development proposal approved so that if and when the proponents (or possible new owners) are ready to proceed with the proposal they can avoid the need to address the cumulative impacts on the local community and the environment that are continually compounding in the absence of a Port Master Plan.
The direct impacts from Incitec's proposal for me and my family include:
* High safety and hazard risk , including road transportation to the coal mines and from the Port of Newcastle as well as the Hunter regional road network
* Increase in 24 hour noise levels
* Air quality impacts
* Impacts on the internationally listed Ramsar wetlands
* Groundwater impacts
I am aware that ammonium nitrate is an oxidising agent, not an explosive, however, it can be turned into an explosive both quickly and easily by shock waves, foreign matter, heat and pressure. Whilst the risk of explosion is small, the impact of an explosion would be catastrophic and despite slogans in Incitec's EIS of "world's best practice' accidents do occur, take for instance Orica's Hexavalent Chromium leak in 2011.
One of the fundamental responsibilities of any Government is the welfare and protection of people and this proposal undermines the safety of around 50,000 residents within a 5km radius. Government should note that if Incitec proceeds there is enough explosive power on Kooragang Island to match the Hiroshima atomic bomb (Hiroshima used 18,000 tons of TNT which is comparable to the 21,000 tons proposed by Incitec and Orica's current capacity).

The Department of Planning must also acknowledge that the South Australian Government is trying to shift Incitec's storage of AN in Port Adelaide due to explosion risk for residents, which is outlined by a SA WorkCover report. Such a massive concentration of ammonium nitrate storage with 800 m of residents is not acceptable to the communities that surround the proposal.

Air Pollution
I'm deeply concerned that Incitec's plant will only add to already deteriorating air quality. residents experience high levels of coal dust from PWCS and NCIG, diesel particulates from industry and nitrous oxides from Orica's plant.
Two large scale ammonium nitrate plants, operating so close to residents creates an especially high concentration of NOx gases that are detrimental to respiratory health, especially the young and elderly.
Orica's expansion and Port Waratah Coal Services' T4 proposal, further impacts future air-quality and Incitec's Air Quality tests does little to abate my concerns regarding air pollution.

Noise Pollution

Industrial noise, especially night-time noise is already a major concern which impacts me. Incitec's EIS noise monitoring of the site was conducted when Orica's ammonia plant was not even in operation and proved that Orica is not meeting acceptable noise levels.
Furthermore, Incitec in their EIS, argue that "it is appropriate to relax the recommended levels for suburban areas by 5db".
Here are some extracts taken from different sections of Incitec's EIS on Noise.
"As the existing level of industrial noise exceeds noise amenity criteria recommended by the EPA's Industrial Noise Policy (INP) by a significant margin, alternate operational noise criteria has been nominated for the Project.
"Whilst the appropriate zoning in Stockton is recognised as suburban, considering the adjoining industrial zoning it must be noted that a suburban/industrial interface exists. The Industrial Noise Policy, does not provide recommended industrial noise levels for suburban/industrial interfaces and therefore it is considered appropriate to relax the recommended levels for suburban areas by 5db.
"Given that IPL and Orica are the only two operators that could materially influence industrial noise, it's is proposed the adjacent sites assume an equal responsibility in achieving the nominated levels."
As a resident personally affected by noise from Orica and PWCS, I find the assertion of Stockton being an `interface' suburb offensive and the idea for government to `relax' noise limits completely absurd.
How can industry be trusted when Orica are well above night-time noise limits and Incitec are requesting special considerations?

Inadequate consultation

Many residents from Stockton, Carrington, Tighes Hill and Mayfield have been left in the dark on this project. Letter drops and one information session two months after the Orica disaster is not proper consultation for a project of such magnitude and widespread impacts.

Incitec's own `community perception' survey conducted in April 2012, identified less than a third of residents were unaware of the Project. Another example of poor consultation is residents that live within the outer rim of a 5 km radius have been excluded in any communication material. Suburbs such as Cooks Hill, Newcastle West and East, The Hill and Hamilton South have received no information regarding the proposal.

Now, Incitec has declared a two year delay in making any decision on the Project. This may please IPL's investors; however it prolongs resident uncertainty, stymies local investment and provides Incitec with an extended period to lobby Government ministers.

Impacting house prices

Incitec's EIS fails to address my concern that a second ammonium nitrate plant may impact house prices. If Incitec's development is approved, the risk profile increases for all suburbs close to Kooragang and it's highly likely that the value of properties may decrease. Downward pressure on properties would be a direct result from fewer new families moving into areas like Stockton and a reputational stigma for suburbs closest to two ammonium nitrate plants.

Incitec's EIS does not acknowledge this issue, nor does it address who would be responsible if property values were lowered by their Project.

Traffic Impacts
Traffic is already a major problem as a result of industrial activity on Kooragang Island. Incitec's EIS does nothing to mitigate future traffic problems during construction and its operational phase.

In addition to congestion, the extra diesel truck movements will add to dangerous carcinogenic fine particles and nitrous oxides levels.
Employment and economic impacts in Newcastle and Lower Hunter
If operational, Incitec's plant will employ just 60 people, many of whom will be transfers from the company's Mooranbah ammonium nitrate plant. Considering the risk and impacts the plant brings to tens of thousands of people, 60 jobs are not commensurate with the more obvious and insidious impacts the plant will bring.
Furthermore, Incitec have stated that rising construction costs and a failing coal price has forced a two year delay in making a decision on this Project. These outside economic forces impact the viability and longevity of the plant and should be included in EIS.
Polluting the hunter river
As a keen fisherman and swimmer, it's concerning that Incitec will be handed yet "another license to pollute" the Hunter River. If Incitec truly want to build a world-class plant then their EIS should reflect a plant with no effluent into the Hunter River. The river is an important recreational estuary for thousands of fisherman, not to mention that Kooragang is an international regonised RAMSAR wetland.
Excessive industrial development with a licenses to pollute the river close to a RAMSAR area is not common sense planning, nor does it position the Hunter River in a positive light to tourists.



As a submission maker, I can confirm that I have not made a political donation totaling $1000 or more in the past 2 years.
Yours Sincerely,
Claire Charles
Andrew Parker
April Parker
36 Crebert st
Mayfield
2304

As a resident of Stockton please accept this submission of objection regarding Incitec Pivot's proposed ammonium nitrate plant on Kooragang Island (SSD-4986).
In my opinion the proposal creates an unacceptable risk to nearby residents and Incitec's Environmental Impact Statement does not address my concerns of explosive risk, noise, air and water pollution and possible impacts to house values.

Newcastle and the suburbs that surround the Port are demanding responsible planning decisions and the mere thought of two ammonium nitrate plants, operating side-by-side just 800 from residents is a planning disaster.
The direct impacts from Incitec's proposal for me and my family include:

Potential for explosion

Incitec's EIS fails to adequately address my concern around the potential risks of storing 21,500 tons of ammonium nitrate (maximum storage capacity combining Orica and Incitec). The blast contours in Incitec's EIS do not even reach Stockton, yet it's well known an ammonia nitrate explosion involving 300 tons of ammonium nitrate in Toulouse, France, killed 33 and injured thousands within a 5km radius in 2001.

I am aware that ammonium nitrate is an oxidising agent, not an explosive, however, it can be turned into an explosive both quickly and easily by shock waves, foreign matter, heat and pressure. Whilst the risk of explosion is small, the impact of an explosion would be catastrophic and despite slogans in Incitec's EIS of "world's best practice' accidents do occur, take for instance Orica's Hexavalent Chromium leak in 2011.

One of the fundamental responsibilities of any Government is the welfare and protection of people and this proposal undermines the safety of around 50,000 residents within a 5km radius. Government should note that if Incitec proceeds there is enough explosive power on Kooragang Island to match the Hiroshima atomic bomb (Hiroshima used 18,000 tons of TNT which is comparable to the 21,000 tons proposed by Incitec and Orica's current capacity).

Ammonium Nitrate has brisance potential and secondary explosion potential and with the surrounding land uses to the proposed development including significant petroleum storage this type of risk is unacceptable.

It is understood that a draft Kooragang Island emergency Plan has been development for review by an expert panel. This plan has no consideration for the evacuation or emergency management of Stockton because of the difficulty to evacuated the peninsular, therefore increasing the risk profile with such a development should not be allowed. It is noted that on New Year Eve every year it takes approximately 3 hours for the traffic to subside across Stockton at a time when everyone is trying to leave via the only transport route, during an emergency such a situation would be catastrophic.

The Department of Planning must also acknowledge that the South Australian Government is trying to shift Incitec's storage of AN in Port Adelaide due to explosion risk for residents, which is outlined by a SA WorkCover report. Such a massive concentration of ammonium nitrate storage with 800 m of residents is not acceptable to the communities that surround the proposal.

Air Pollution

As young parent with two small children, I'm deeply concerned that Incitec's plant will only add to already deteriorating air quality. Stockton residents experience high levels of coal dust from PWCS and NCIG, diesel particulates from industry and nitrous oxides from Orica's plant.

Two large scale ammonium nitrate plants, operating so close to residents creates an especially high concentration of NOx gases that are detrimental to respiratory health, especially the young and elderly.

Orica's expansion and Port Waratah Coal Services' T4 proposal, further impacts future air-quality and Incitec's Air Quality tests does little to abate my concerns regarding air pollution.

Noise Pollution

Industrial noise, especially night-time noise is already a major concern which impacts me. Incitec's EIS noise monitoring of the site was conducted when Orica's ammonia plant was not even in operation and proved that Orica is not meeting acceptable noise levels.

Furthermore, Incitec in their EIS, argue that "it is appropriate to relax the recommended levels for suburban areas by 5db".
Here are some extracts taken from different sections of Incitec's EIS on Noise.

"As the existing level of industrial noise exceeds noise amenity criteria recommended by the EPA's Industrial Noise Policy (INP) by a significant margin, alternate operational noise criteria has been nominated for the Project.

"Whilst the appropriate zoning in Stockton is recognised as suburban, considering the adjoining industrial zoning it must be noted that a suburban/industrial interface exists. The Industrial Noise Policy, does not provide recommended industrial noise levels for suburban/industrial interfaces and therefore it is considered appropriate to relax the recommended levels for suburban areas by 5db.

"Given that IPL and Orica are the only two operators that could materially influence industrial noise, it's is proposed the adjacent sites assume an equal responsibility in achieving the nominated levels."

As a resident personally affected by noise from Orica and PWCS, I find the assertion of Stockton being an `interface' suburb offensive and the idea for government to `relax' noise limits completely absurd.

How can industry be trusted when Orica are well above night-time noise limits and Incitec are requesting special considerations?

Inadequate consultation

Many residents from Stockton, Carrington, Tighes Hill and Mayfield have been left in the dark on this project. Letter drops and one information session two months after the Orica disaster is not proper consultation for a project of such magnitude and widespread impacts.

Incitec's own `community perception' survey conducted in April 2012, identified less than a third of residents were unaware of the Project. Another example of poor consultation is residents that live within the outer rim of a 5 km radius have been excluded in any communication material. Suburbs such as Cooks Hill, Newcastle West and East, The Hill and Hamilton South have received no information regarding the proposal.

Now, Incitec has declared a two year delay in making any decision on the Project. This may please IPL's investors; however it prolongs resident uncertainty, stymies local investment and provides Incitec with an extended period to lobby Government ministers.

Impacting house prices

Incitec's EIS fails to address my concern that a second ammonium nitrate plant may impact house prices. If Incitec's development is approved, the risk profile increases for all suburbs close to Kooragang and it's highly likely that the value of properties may decrease. Downward pressure on properties would be a direct result from fewer new families moving into areas like Stockton and a reputational stigma for suburbs closest to two ammonium nitrate plants.

Incitec's EIS does not acknowledge this issue, nor does it address who would be responsible if property values were lowered by their Project.

Traffic Impacts

Traffic is already a major problem as a result of industrial activity on Kooragang Island. Incitec's EIS does nothing to mitigate future traffic problems during construction and its operational phase.

In addition to congestion, the extra diesel truck movements will add to dangerous carcinogenic fine particles and nitrous oxides levels.

Employment and economic impacts in Newcastle and Lower Hunter

If operational, Incitec's plant will employ just 60 people, many of whom will be transfers from the company's Mooranbah ammonium nitrate plant. Considering the risk and impacts the plant brings to tens of thousands of people, 60 jobs are not commensurate with the more obvious and insidious impacts the plant will bring.

Furthermore, Incitec have stated that rising construction costs and a failing coal price has forced a two year delay in making a decision on this Project. These outside economic forces impact the viability and longevity of the plant and should be included in EIS.

Polluting the hunter river

As a keen fisherman and swimmer, it's concerning that Incitec will be handed yet "another license to pollute" the Hunter River. If Incitec truly want to build a world-class plant then their EIS should reflect a plant with no effluent into the Hunter River. The river is an important recreational estuary for thousands of fisherman, not to mention that Kooragang is an international recgonised RAMSAR wetland.

Excessive industrial development with licenses to pollute the river close to a RAMSAR area is not common sense planning, nor does it position the Hunter River in a positive light to tourists.

Please find attached my submission.

1.The proposed plant should not be in the at risk perimeter of the 6th biggest city populous.
2.Urban lifestyle does not sustain and survive with the industrial cumulative impact of 21 thousand tonnes of ammonium nitrate and THE EPA could not handle the cummulative impact under the world standards of cumulative impact
3.the examples of explosion experienced across the world at other sites; shows such a development puts our population at risk of incident and death
4. inadequate portauthority, NSW Government & big industry to improve port infrastructure. Neglect at this level
will ensure Incitec will continue to contribute to Newcastle port inefficiency. There is no Port Plan,No transport, No rail, noadequate dust noise and water monitoring plan
that offers strategy to affect old licenses and licences that are breached.
higher pollution risks, deaths on roads and ships anchored off shore in a ques- result in INCITECS Proposal being unacceptable


Newcastle

SUBMISSION re: development proposal Incitec Ammonium Nitrate Manufacturing Facility Project,SSD-9986Heron Road, Kooragang Island
I wish to submit my OBJECTION to the Incitec Pivot proposal.

INTRODUCTION
Newcastle Port does not have a Strategic Plan for its future development
This needs to be addressed before any new plants or expansions go ahead. If you make the wrong decision & choose to approve this application then you have helped lock the Port into a continuation of its presently bad situation for decades to come. Highly dangerous & toxic plants & no diversification, when King Coal busts & we are already seeing the likely hood of this then our Port collapses as most projects on the port are coal related.
Incitec has stated that they will not proceed with the development for at least 2 years, so then the proposed approval/disapproval should not happen until they are ready to use the approval. I expect & forever hopeful that within the next 2 years we will have better planning & environmental laws that will be better at protecting the community than what we currently have.
Before the development proposal is approved, the state government has the responsibility of deciding whether the development is in the best interest of the community. I list a number of the major issues that I consider have not been adequately addressed by the proponents.

CUMULATIVE IMPACTS
The EIS fails to address the Director General's directive regarding cumulative impacts of the proposal.
Cumulative impacts are some of my greatest concerns & my greatest frustration. Who is supposed to be taking this into account? Certainly none of the organisations on the Port do & continually state it is not their problem. Well it may not be theirs, but & I must ask why isn't it, because certainly it is the communities. We have to live with it.
There is an inadequate regulatory framework to address disclosure and accounting for dealing with environmental risk and performance of the project within the context of the Port location and its proximity to residential areas and the Newcastle CBD.
The proposal is set to see the emergence of ongoing environmental issues including, but not limited to
* High safety and hazard risk to citizens, including road transportation to the coal mines and from the Port of Newcastle as well as the Hunter regional road network
* Increase in 24 hour noise levels. I personally have complained to the EPA on about 4 separate occasions & could do this almost daily with the noise that is coming from, I believe Orica.
The community is already experiencing excessive noise from Kooragang Island in Stockton. The current night time noise levels are above the amenity criteria acceptable level 40 dB for suburban environments as outlined in the NSW Industrial Noise Policy. The current levels at night are 49 to 51dB. The Incitec plant will further increase noise levels and this is totally unacceptable to the community.
What is more disturbing is the fact that they have called for an increase in the allowable noise levels in regard to their project. This is insulting and totally unacceptable to the community and contrary to the NSW Industrial Noise Policy. This cannot be allowed. Why should my life be interrupted 24/7.
* Air quality impacts
The Incitec plant will increase the air pollution levels in surrounding suburbs in a number of ways including:
* Release of very fine particles (PM 10 and PM2.5) of ammonium nitrate from the Prill tower including particles dangerous to the health of the community.
* Release of toxic nitrogen dioxide from:
o The nitric acid plant. These emissions are dangerous to the health of surrounding communities
o Large releases of nitrogen dioxide from an ammonium nitrate fire or explosion
* Release of toxic ammonia gas from:
o Fugitive emissions from the huge (30,000 t) ammonium storage tank
o Fugitive emissions form unloading operations from ships and tankers
o Leaks from pipework and connections
o Large release from a damaged pipeline of damaged storage tank and destroyed storage tank from AN explosion brisance, earthquake, aircraft accident, truck accident and malicious damage
o Large release of ammonia from an ammonium nitrate fire or explosion
As well the plant will release a large amount of greenhouse gas N20 which is 310 worse than carbon dioxide as a greenhouse gas.
Already PM10 levels monitored only every 6 days at the Orica monitoring station at Stockton are experiencing exceedances of the NEPM standard of 50 ug/m3 in the last 12 months and there have been a significant increase in PM10 particles since 2010 when the NCIG coal stockpiles where constructed on Kooragang Island. The continuous monitoring of PM10 particles would very likely have shown many more exceedances and it is highly likely PM 2.5 particles have regularly exceeded the target level of 25 ug/m3.
The air quality assessment in the EIS neglected to assess and model PM 2.5. While this is not a NEPM standard yet it is likely to be in the near future and a target level has been set at 25 ug/m3. Due to the dangerous nature of PM 2.5 particles and the fact that there is no safe level with increasing health issue with rising MP 2.5 levels PM 2.5 particle dispersion modelling and contours should be developed for this project as part of the EIS. It is likely PM 2.5 particles are already exceeding the target level at Stockton and a reduction in particles is required rather than another project increasing the level of dangerous fine particles in communities.

* Impacts on the internationally listed Ramsar wetlands
The cumulative impacts upon these wetlands are already at levels that should not be accepted, don't allow an increase
* Groundwater impacts & impacts on the Hunter River.
Until this or any new proposal can stop pollution going into our Hunter River or the groundwater then they should not get approval. I expect a closed loop system or the proposal should not be approved.
* Traffic impacts. If you are currently trying to cross the Island between 6am - 9am or 3pm - 6pm, then I don't need to explain the traffic impacts. At anytime between these `peak hours' you could take up to an hour what should take about 5 mins. The extension of the 2 lanes has improved this but obviously this will deteriorate over time.
* Explosives impacts. The EIS fails to adequately address the community concern of the potential risks of storing 21,500 tonnes of ammonium nitrate (maximum storage capacity combining Orica and Incitec). This shows such a lack of thought by the Planning Department if you allow this to go ahead. I mean really 2 AN plants next to each other with just in front of them 2 tanks with ethanol, next to Incitec is vacant land but it is believed to be the proposed LNG plant if that goes ahead & then next to that Hifert (fertiliser plant). If one goes they will all go & Newcastle along with them.

It is a failure of the assessment process for this proposal to be considered in isolation of existing potentially hazardous industries that already exist at the Port.
COMMUNITY CONSULTATION
I believe that Incitec has carried out insufficient community consultation and it has chosen to ignore public feedback regarding their proposal. Their own survey carried out in April 2012 stated that more than 2/3 of the respondents were unaware of their proposal
The proponent's state that (p45 EIS) "The acceptability of the risk will ultimately depend on the value of the potentially affected area or system to the local community and wider society". So does this mean that if the decision is for this project to go ahead the Planning Dpt has decided that the risk to 50,000 people is less important than the mines having explosives & Incitec making a good profit?
Also, the potential impact of the proposed plant extends well beyond Stockton, Mayfield and Carrington. Residential areas such as Cooks Hill, Newcastle East, Honeysuckle and Newcastle`s CBD have not received any project material. Much of Newcastle is still unaware of this proposal.
It seems to me that they are so scared of community consultation that when a proposal went to Newcastle Council for them to do a public briefing along with Stockton & Mayfield representatives, they sent a letter attacking the communities request. Even Orica (given after all their disasters), PWCS & Dart did public briefings.
LOCATION
Incitec's proposal is simply in the wrong location.
The proposed facility is to be located on Kooragang Island adjacent to the Orica plant (which has leaked arsenic into the Hunter River and spread hexavalent chromium and ammonium onto the surrounding suburbs), the Marstel Fuel Storage at Mayfield and the approved Manildra ethanol storage facility.
The blast contours in Incitec's EIS do not reach Stockton (800 metres away), despite the fact an ammonia nitrate explosion involving 300 tonnes of ammonia nitrate in Toulouse, France killed 33 people and injured 14,000 people within a 5km radius. As I live in Stockton I have had the unpleasant reality of an industry not informing me that they poured pollution all over me because they didn't think it had left their site. I don't ever want this to happen again. If they haven't got the right blast contours in their EIS then how can I possibly have any faith that if an accident/incident occurs they will do the right thing & notify me immediately.
Possible Explosion
Ammonium nitrate can explode under a range of conditions including fire, shock and contact with contaminants. There have been many accidental explosions worldwide despite precautions being taken to avoid explosions. Explosions involving even smaller quantities of ammonium nitrate, such as in the Toulouse explosion involving 300 tonnes in 2001, resulted in many injuries and damage to buildings up to 5 km from the plant.

The South Australian Government is currently negotiating to shift Incitec's storage in Port Adelaide due to explosion risk for nearby residents near the storage as outlined in a SA WorkCover report. Such a massive concentration of ammonium nitrate storage on Kooragang Island within 800 m of residents and 3 kilometres from Newcastle's CBD is unheard of worldwide and is unacceptable to the communities surrounding Kooragang Island.
Ammonia
Communities have been exposed already to low levels of ammonia from the Orica plant and two people were sent to hospital last year as a result of an ammonia leak from the ammonia storage tank at the Orica plant. This large transfer and storage of ammonia at the proposed Incitec plant adds to the cumulative effect of ammonia release from the Orica plant.
A number of years ago there was also a leak from Incitec, from memory when Orica & Incitec where still the same company. This time the leak went over Stockton Centre which is a large residential for people with disabilities. Two staff members collapsed, fortunately no clients where affected as many have serious respiratory conditions the Ammonia leak could have been lethal for them.
Damage to the 30,000 t ammonia storage that could release its contents would be catastrophic for communities surrounding Kooragang Island depending on the wind direction and strength and has the potential to cause severe injuries and death. Such a failure could be caused by an earthquake, accident involving the tank or pipelines to and from the tank, a plane crash and explosion of ammonium nitrate with tank failure due to the pressure wave. Explosion overpressure has the potential to destroy tanks located close to an explosion which in this case would release a massive amount of ammonia.
This failure mode of the 30,000 t ammonia tank should have been assessed in the EIS as a worst case scenarios and air quality modeling undertaken on this scenario to understand the effect on surrounding communities in such a failure mode. This has not been undertaken in the EIS and the injuries and possible deaths from this scenario are unknown due to this omission.


Emergency Response Plan
The draft Kooragang Island Plan for emergencies does not include Stockton in the emergency evacuation procedures it is understood most likely due to the difficult of an evacuation being on a peninsular with one road in and out. Considering the possible emergency scenarios at Incitec andOrica ammonium nitrate plants this is a major concern for the Stockton community.

Conclusion
So in conclusion. The reasons why I am against this proposal are:
* Nothing new & no expansion should happen until we have properly investigated the cumulative impacts on the Port, the local environment & the people who live around it.
* Diversification of the Port. We need to have a more diversified Port. Everyone goes on about the economics & yet we are being dug a great big hole. When King Coal dies we the whole of the Hunter will be in trouble. Let's get some industries on the Port that are not related to coal.
* Closed loop system. No new or expansions should be allowed unless they have a closed loop system. No more pollution, we should be decreasing not increasing. This includes noise pollution.
* This proposal is in the wrong location. It is not safe to have it so close to the community as well as other lethal facilities
* The risk of an explosion while not high if it occurred would be catastrophic. Much of Newcastle would be seriously affected.
Yours
Cathy Burgess
9 Hereford St Stockton 2295
[email protected]
0249201528

I am objecting to Incitec Pivot's proposed ammonium nitrate plant on Kooragang Island.
My primary objection is the unacceptable risk that storing a large quantity of ammonium nitrate so close to densely populated areas poses. Although the liklihood of an industrial accident or terrorist attack on the plant may be low, the amount of ammonium nitrate stored at the plant and the neighbouring Orica facility has the potential to cause a massive explosion flattening many Newcastle suburbs including the CBD - putting thousands of lives at risk. A terrorist operation with this outcome would change the very fabric of Australian society - a risk I would have thought would be unacceptable in our current security environment. Surely the security apparatus required to properly mitigate this risk means it would be more cost effective and certainly safer to locate the facility in a less population dense area.
Other concerns I have with Incitec's proposal are its's potential to cause air and noise pollution. As a resident of Stockton, a medical student and a mother I am concerned with the increasing concentrations of NOx gases that will result from another ammonium nitrate plant. These gases are detremental to respiratory health and hence should be confined to less populous areas.
Also detremental to health is sleep deprivation and general stress caused by excess noise. I am very concerned with the tone of Incitec's proposal relating to noise pollution particularly in Stockton. Stockton is a residential suburb, therefore residents deserve to be protected by residential zoning policies relating to noise pollution. I find it completely unacceptable that Incitec believes these policies can be relaxed simply becasue Stockton is close to an industrial area. Surely the policies are there to protect just such suburbs - the ones that need to be protected from excessive industrial noise are logically going to be those closest to industry. Incitec's proposal seems to show contempt for this idea and have little regard for the health and wellbeing of nearby communities.