Incitec Ammonium Nitrate Facility

Submission on behalf of Newcastle Port Corporation

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


28/10/2012
Dear Sir/Madam
As a resident of Stockton please accept this submission of objection regarding Incitec Pivot's proposed ammonium nitrate plant on Kooragang Island (SSD-4986).
I previously lived on the Central Coast when Ashland Chemicals (an American Company) tried to build a chemical plant in 1989 at Berkeley Vale. The Community was horrified that a government would allow a chemical plant to be built so close to an area were people live and in a sensitive environment. Fortunately commonsense prevailed not greed and the promise of job vacancies that are always trotted out but don't amount to much in the long run. The area now has clean industry providing stable employment and the rural and aquatic environments are enjoyed by many locals and visitors alike.
Newcastle has so much to offer. It does not need to become a dirty and dangerous industrial area where international companies can make profits at the expense of locals' health, safety and future family finances.
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).

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 a newly retired resident living here fulltime now rather than part time and one who enjoys the outdoors 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. The amount of coal dust and other pollution (including noise) has increased and is certainly more noticeable when one is home all day. 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. (There is at least a curfew in Sydney which give airport residents some reprieve at night!)

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,
Julie Cook
Julie Cook
49 Monmouth St Stockton

Dear Sir/Madam

As a resident of Sydney 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 surrounding residents 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).

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. 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."
Local residents 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
I am concerned 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,
Catherine Woolnough

There are numerous concerns with Incitec Pivots proposal to build an ammonium nitrate plant on Kooragang Island.

Those that I am personally concerned about include:

1. Any increase in industrial noise, particularly at night. Already there is a problem with audible noise disturbing the sleep of Stockton residents. The idea of relaxing this further is dangerous as impaired sleep affects our ability to function, and in the case of my household and many others, to learn and work. It is counter intuitive to suggest that because already the noise limit in a residential zone is exceeded that it should be further exceeded! It is a residential zone and every effort by industry should be made to comply with that noise limit, not breach it further.

2. Negative impact on house prices. Initially, when I told people that we had bought property in Stockton people were enthusiastic and positive about the changes in Newcastle and the move away from reliance on heavy industry that has occurred in the last 15 - 20years. After the Orica chemical leaks last year I actually had colleagues 'zapping' me and calling me radioactive due to our address, and commiserating with our perceived financial loss as a result of our investment. With the announcement of further development by Incitec Pivot and the massive distrust in the wake of Orica, I have been subjected to a further round of insults and commiserations at our loss. It is devastating because Newcastle and Stockton has the potential to grow in a really positive way, and yet this proposal is a step away from that potential and off putting to so many people who had approached and expressed interest in relocating themselves.

There are people who are interested in Newcastle because of cheaper overheads compared to running a business in Sydney and are looking to set up businesses here. I have a family member who has set up a small business and is employing 3 people full time, and adding to the community of Carrington in a positive way. Incitec Pivot is offering only 60 full time positions at sch a massive cost is not an attractive employment opportunity. Encourage other forms of business that are less detrimental to the residents of Newcastle - and have a chance of creating work for locals too, not a specialized few!

3. Traffic on Kooragang Island is already a nightmare at peak hour. There is no adequate proposal to expand infrastructure to accommodate the already over burdened area. It is not acceptable to continue this practice of government to allow development without appropriate compensation to infrastructure.

4. Further pollution of the Hunter River. Again, yet another step in the wrong direction. Any changes to levels of pollution allowed should be in the form of reducing pollution. Then there is the extraordinary danger of a chemical like ammonium nitrate, and again the lack of trust we have in the companies manufacturing it to manage the risk. With a second plant, the concern is even greater.

5. Lack of any real benefit at all to Newcastle and great harm to neighbouring suburbs.

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



28/10/12
Dear Sir/Madam
As a resident of Stockton for the past 12 years, 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 impost on the quality of life because of various issues that are not addressed in Incitec's EIS. My main concerns are the additional noise, the extra traffic the fact that we have to live with a knowledge that even though the chances are remote, a devastating explosion is still a possibility. In addition, the possibility of further air pollution, water pollution point to le impacts on air to nearby residents and Incitec's Environmental Impact Statement do the fact that if this facility is still required for the mining industry it should be located in a sparsely populated area.
The possibility that two ammonium nitrate plants could be adjacent to each other and only 800 from residents is a worrying proposition and potentially a planning disaster.
The direct impacts from Incitec's proposal for me are:
Air Pollution
The advent of the expansion of the coal loaders has already impacted on the amout of coal dust we seem to be receiving. The cumulative impact of the development and more is likely to impact on my future health. It may be concindence but this year despite a flu injection I had the worst chest infection in my life. Further emissions of nitrous oxides from the proposed development on top of the nitrous oxides we already receive is just another cumulative impact. I think with the impacts we already have that residents are justified in demanding that air filters be fitted to their homes by those causing the air pollution and also contribute to the annual running costs.

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?
Incitec have already indicated that noise will be an issue. If development was to be allowed then Incitec should pay for the fitting of noise reduction technology such as wall insulation and special glass to houses most affected.
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 just 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.


Impacting house prices

The recent Orica pollution breaches has already impacted on the reputation of Stockton as a desirable place to live. 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 falling 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.
Given that Incitec has announced that they will not proceed with the development of a plant for the immediate future it seems unwise to grant approval for the plant at this stage but rather review it at the time when they wish to proceed. By the time Incitec wish to proceed, other issues may in fact be relevant.
Polluting the Hunter river
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,

Brian Davies,

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



27/10/2012
Dear Sir/Madam
As a resident of Stockton please accept this submission of objection regarding Incitec Pivot's proposed ammonium nitrate plant on Kooragang Island (SSD-4986). After attended a number of community forums and reading about this proposal, I am appalled and "gobsmacked" at the mercenary lengths big business will go, to make a buck. Taking ridiculous risk with human life, not to mention the environment or the aesthetics of the city of Newcastle.
"Do you not watch the world news, look at the disaster's that weren't likely or supposed to happen, but they did. Have you not heard of "harm minimization". I't not rocket science boys and girls! Read on - Some very dedicated member's of our community have outlined simply and clearly in this well written letter the effects of this proposal. I couldn't express it any better myself.
It is clear to me that this 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).

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 a resident and a parent, 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 recognized 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,
Margaret Punch.
17 Church Street
Stockton, 2295.
N.S.W.

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



29 October 2012
Dear Sir/Madam
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 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 propect 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).

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. 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.
Industry cannot 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 ill informed about 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 concerns 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,

Michael Punch
17 Church Street, Stockton, 2295.

Please find attached

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

As a young mother who moved to Stockton to raise a family, I believe 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.

See attached.

see attached.

see attached.

see attached.

Please see file attachment

Incitec Submission

Brian Kelly

28 October 2012.

Nicholas Hall
Planner
Mining and Industry Projects
Department of Planning and Infrastructure
GPO Box 39
Sydney NSW 2001 Via Email [email protected]


Dear Mr Hall,
Re Incitec Pivot's ("Incitec") proposed ammonium nitrate/nitric acid manufacturing facility at Kooragang Island (SSD - 4986)

I am a resident of Newcastle. I live at ________.

Let me say at the outset that I am at a complete loss to understand how any company could boldly ask a planning authority to approve such a manufacturing facility in such a location in 2012.

In 2012, the proposed manufacturing plant's proximity to residential areas alone should make it fanciful.

The fact that there is already an identical plant next door does not change that argument. Put simply, in 2012, the Orica plant shouldn't be where it is either. It survives there because of history. Government allowed it to be built. We are stuck with it. It doesn't follow that if we have one dinosaur we should have two.

When Orica had their `issues' in August 2011 and the possible dangers crystallised for me (and many other people I spoke to) I stood and wondered how it could be that such a plant could still exist so close to residential areas.

The answer as to why the Orica plant is there on Kooragang Island of course harks back a different era when, I respectfully submit, planning authorities were not as interested or as thorough as they are now and the general public were not as empowered or advised. Also, the environment was not as well respected. Much damage has been done. The words Union Carbide and Sydney Harbour spring to mind. It just wouldn't happen today.

In August 2011 it was stated by many people in the government and the press and indeed by members of the public that such a manufacturing plant (Orica) would never be approved in such a location "these days."

People from other parts of NSW scoff at the residents of Newcastle when they protest at the impact of the industry on their lives (such as noise and pollution). It has been a catch cry often heard, "The resident s of Stockton knew it was there when they moved there. They should stop whingeing." Well when I moved to Stockton there were not TWO plants manufacturing ammonium nitrate and nitric acid 800 metres across the water storing over 20,000 tons of ammonium nitrate.

If this plant is built, it will be imposed on the city and community against their will. It will introduce a very significant variable to our lives that we didn't count on. To whom do I look for the resultant decrease in the value of my house?

The one good thing to come out of this EIS is to identify that Orica is unable to meet their noise requirements.

I am also at a loss to understand how it is that Incitec want a relaxation of 5db for recommended noise levels for residential areas.

I understand that decibels are measured on a logarithmic scale. Increasing something by 3db is doubling it! Think about that. A 5db relaxation of recommended levels is an extraordinary request. Its boldness is breathtaking. One can only wonder at the ethics of a person who works within a process that considers it acceptable to suggest it is appropriate to relax the recommended levels for suburban areas by 5db.

I understand that ammonium nitrate is not an explosive in itself. However, exactly how it is made into an explosive is well known to many. Including terrorist organisations! Terrorism wasn't even on the horizon when Orica obtained their approval in the 1960's when the Orica plant was built.

Not even all parts of the EIS are released to the public - with bodies receiving some parts of the EIS because of security/terrorism issues. This is an amazing situation in itself. It makes the approval process a no-brainer.

I ask that you please stand back and take a proper look at this project. Even a cursory glance will show that it is an ill-fitting proposal. Don't be part of the process that inflicts more stupidity on the next generation. Don't be that person who actually approved a manufacturing plant against common sense and in a situation/position where it doesn't fit.

There is no sensible argument as to why the ammonium nitrate used in the Hunter Valley mines must be made in the Hunter Valley. The coal mines of the Hunter Valley use much equipment made throughout the world. Why is it that ammonium nitrate must be made locally. Incitec no doubt intend to export the ammonium nitrate made at Kooragang Island to other places in the world. So what is the need to make it here?

I am not a person that would be considered `anti-development'. NSW needs jobs. NSW does not need the 60 ongoing jobs running an ammonium nitrate/nitric acid manufacturing plant AT THAT LOCATION. There are many other places where it could go that are well away. The noise pollution and explosion problems will not present a constant danger to the public if the manufacturing plant is built in an isolated location.

If I can be of any further assistance please don't hesitate to contact me on ________.

Yours faithfully

Brian Kelly

Brian Kelly


28 October 2012.

Nicholas Hall
Planner
Mining and Industry Projects
Department of Planning and Infrastructure
GPO Box 39
Sydney NSW 2001 Via Email [email protected]


Dear Mr Hall,
Re Incitec Pivot's ("Incitec") proposed ammonium nitrate/nitric acid manufacturing facility at Kooragang Island (SSD - 4986)

I am a resident of Newcastle. I live at _________.

Let me say at the outset that I am at a complete loss to understand how any company could boldly ask a planning authority to approve such a manufacturing facility in such a location in 2012.

In 2012, the proposed manufacturing plant's proximity to residential areas alone should make it fanciful.

The fact that there is already an identical plant next door does not change that argument. Put simply, in 2012, the Orica plant shouldn't be where it is either. It survives there because of history. Government allowed it to be built. We are stuck with it. It doesn't follow that if we have one dinosaur we should have two.

When Orica had their `issues' in August 2011 and the possible dangers crystallised for me (and many other people I spoke to) I stood and wondered how it could be that such a plant could still exist so close to residential areas.

The answer as to why the Orica plant is there on Kooragang Island of course harks back a different era when, I respectfully submit, planning authorities were not as interested or as thorough as they are now and the general public were not as empowered or advised. Also, the environment was not as well respected. Much damage has been done. The words Union Carbide and Sydney Harbour spring to mind. It just wouldn't happen today.

In August 2011 it was stated by many people in the government and the press and indeed by members of the public that such a manufacturing plant (Orica) would never be approved in such a location "these days."

People from other parts of NSW scoff at the residents of Newcastle when they protest at the impact of the industry on their lives (such as noise and pollution). It has been a catch cry often heard, "The resident s of Stockton knew it was there when they moved there. They should stop whingeing." Well when I moved to Stockton there were not TWO plants manufacturing ammonium nitrate and nitric acid 800 metres across the water storing over 20,000 tons of ammonium nitrate.

If this plant is built, it will be imposed on the city and community against their will. It will introduce a very significant variable to our lives that we didn't count on. To whom do I look for the resultant decrease in the value of my house?

The one good thing to come out of this EIS is to identify that Orica is unable to meet their noise requirements.

I am also at a loss to understand how it is that Incitec want a relaxation of 5db for recommended noise levels for residential areas.

I understand that decibels are measured on a logarithmic scale. Increasing something by 3db is doubling it! Think about that. A 5db relaxation of recommended levels is an extraordinary request. Its boldness is breathtaking. One can only wonder at the ethics of a person who works within a process that considers it acceptable to suggest it is appropriate to relax the recommended levels for suburban areas by 5db.

I understand that ammonium nitrate is not an explosive in itself. However, exactly how it is made into an explosive is well known to many. Including terrorist organisations! Terrorism wasn't even on the horizon when Orica obtained their approval in the 1960's when the Orica plant was built.

Not even all parts of the EIS are released to the public - with bodies receiving some parts of the EIS because of security/terrorism issues. This is an amazing situation in itself. It makes the approval process a no-brainer.

I ask that you please stand back and take a proper look at this project. Even a cursory glance will show that it is an ill-fitting proposal. Don't be part of the process that inflicts more stupidity on the next generation. Don't be that person who actually approved a manufacturing plant against common sense and in a situation/position where it doesn't fit.

There is no sensible argument as to why the ammonium nitrate used in the Hunter Valley mines must be made in the Hunter Valley. The coal mines of the Hunter Valley use much equipment made throughout the world. Why is it that ammonium nitrate must be made locally. Incitec no doubt intend to export the ammonium nitrate made at Kooragang Island to other places in the world. So what is the need to make it here?

I am not a person that would be considered `anti-development'. NSW needs jobs. NSW does not need the 60 ongoing jobs running an ammonium nitrate/nitric acid manufacturing plant AT THAT LOCATION. There are many other places where it could go that are well away. The noise pollution and explosion problems will not present a constant danger to the public if the manufacturing plant is built in an isolated location.

If I can be of any further assistance please don't hesitate to contact me on ________.

Yours faithfully

Brian Kelly

Please find the attached letter which outlines my concerns for both safety of both my family and my neighbours.

I would like to see a comparison of the project to the other two potential sites, to determine which site would have the lease environmental and community impact.