Manildra - Port Kembla Bulk Liquid Terminal

Neighbourhood Forum 7 has been agitating over a long period of time for changes to the traffic rules applying to Northcliffe Drive with a view to diverting all large truck movements to Five Islands Road.
For information, 1) Northcliffe Drive runs from Kembla Grange to Warrawong and almost exclusively passes through residential suburbs, 2) There are a significant number of residential frontages to Northcliffe Drive in Berkeley, Lake Heights and Warrawong and vehicle access to each of the abovementioned residential properties is directly on to and off Northcliffe Drive, 3) A footpath runs parallel to Northcliffe Drive for most of its length, 4) A traffic lighted pedestrian crossing is located at the intersection of Bristol/Sussex Streets and Northcliffe Drive, 5) Two Schools - Lake Illawarra High and Lake Heights Primary School - have boundaries adjoining Northcliffe Drive. School buses drop off and pick up students attending Lake Illawarra Sport High from a bus stop located on Northcliffe Drive. Parents drop off and pick up students (on foot and in vehicles) attending Lake Heights Primary School at its Northcliffe Drive entrance. School buses drop off and pick up students attending Lake Heights Primary School from bus stops located on the northern and southern sides of Northcliffe Drive, 6) A safety crossing is located at the location of the Lake Heights Primary School Northcliffe Drive entrance.
The Forum Concerns are:- 1) Noise pollution arising from a general increase in traffic volumes is a concern. There is a particular concern regarding noise pollution arising from increased heavy vehicle (Trucks with dog trailers, B Doubles and Semi Trailers) traffic movements on Northcliffe Drive. The use of exhaust brakes by heavy vehicles is exacerbating this concern, 2) There are concerns related to air pollutant emissions arising from a general increase in Northcliffe Drive traffic volumes, particularly emissions from heavy vehicles (Trucks with dog trailers, B Doubles and Semi Trailers), and the negative impact that this has on human health, 3) Heavy vehicle (Trucks with dog trailers, B Doubles and Semi Trailers) movements are resulting in increased levels of dust and vibration. The weight of the heavy vehicles (Trucks with dog trailers, B Doubles and Semi Trailers) may be contributing to road subsidence at a number of sites along the length of Northcliffe Drive e.g. in front of 83 and 368 Northcliffe Drive Lake Heights. There is a concern that the weight of these vehicles and the associated vibration may be negatively impacting on sewerage and water services along the length of Northcliffe Drive, 4) Having in mind the information provided above, the negative impact of increased traffic volumes on Public Safety in terms of the potential for motor vehicle accidents involving pedestrians, cyclists, school students and vehicles entering and exiting residences cannot be overstated, 5) There is an over arching concern that Northcliffe Drive is beginning to be used as a primary heavy transport link whereas this was not previously the case.
It is an issue of grave concern that Manildra is proposing to use A-Double tankers and for such tankers to use Northcliffe Drive as an approved route. These are very large trucks, 35 metres in length, that are appreciably longer than B-Double and Semi Trailer trucks. Approval of Manildra's proposal will exacerbate the pedestrian and vehicle safety concerns that NF7 has previously raised.
Planning and Environment is urged to specify the routes that trucks must use and specifically prohibit the use of Northcliffe Drive.
Regards
Peter Maywald
Convenor - Neighbourhood Forum 7

Please see submission attached.

I object to the proposal in it's current form, and would like to see improvements made. I object to the reliance on the road network for transport when there is a rail network available from the departure point to the port-side destination. Furthermore it is inappropriate to rely on Option 2 as mapped in Figure 4 – Routes from Shellharbour to the Terminal of the Transport Study, as it involves sending heavy vehicles across the Windang Bridge. The Windang Bridge is built on fiction pylons that have suffered from significant movement over the last few years due to the entrance entrainment. Daily tidal flows cause significant erosion and sand movement around the pylons, and have required rock armoring. There has been noticeable movement in the road surface, and this would be further exacerbated numerous heavy movements. A longterm solution to tidal erosion in the entrance, and stability of the Windang Bridge are still being investigated. Please make approval conditional on using the train network to move the freight, or at least Option 1 along Five Islands Road.

While there are some sensible environmental provisions, the consideration of greenhouse gas emissions is insufficient. As Wollongong City Council has declared, we are in a climate emergency and it is important to reduce our greenhouse gases wherever possible. Please ensure there are emission reduction strategies implemented such as solar panels on the buildings for use on-site, with excess electricity stored on-site in batteries or delivered to the grid, and that the facility uses 100% Green Power. Furthermore it's important to face a ship to shore power facility, not only to reduce greenhouse emissions, but also to reduce the use of heavy fuel oil and marine diesel oil and its associated particulate pollution, atmospheric sulfur and other emissions. The social impact assessment has failed to consider the impact of burning heavy marine oil on air quality while the vessels are in port, where electric alternatives could be easily added at the outset.

I am concerned that waste has been inappropriately represented in response to the Green Port checklist - "Waste generation will be minimal, we utilise local council waste disposal bins." Which bins are these? Will the proponent be dumping commercial rubbish in the public bins on MM Beach? Kerbside collection of council bins are for residential properties as part of the waste levy within rates. It is my understanding that the facility will need to procure the services of a commercial waste contractor (which may also have a council contract for kerbside collection), or transport waste directly to a commercial waste transfer station or the Council's Whytes Gully waste and resource recovery park.

I am dissappointed that the "Development Perspectives" fails to include the bi-directional cycleway that is adjacent to this property. Also the on-site parking looks like it is only for cars, and does not include bicycles. Being located next to a train station, adjacent to a cycle-path, there should be provisions for staff or visitors to cycle to the facility. However the Green Port checklist does make a positive commitment to "cyclist paths and facilities including secure storage, showers and change facilities". There are also bicycle undercover requirements in the Development Control Plan, however these are not readily evident in the design.

It is completely inappropriate to even suggest one of the trucking routes would be via Windang on an already congested road. Logistics should be occurring by rail. Adding trucking movements to this road will negatively impact the community. If trucks are used they should only be permitted to access the freeway via Five Islands Road. However with recent upgrades to the rail line between Bomaderry and the Illawarra, why are Manildra not utilizing rail?
The community consultation on this project has been poor and overstated in the planning documents. Manildra did not attend NHF7 which i am a member, or engage with them in a meaningful way.
I am also concerned about the accumulation of volatile industries at the Port and potential risk to the community if a major incident were to occur. My children attend Port Kembla Public School nearby. I would be more reassured if the Land Use Safety Study had been completed and made public before this project was given any approvals.

Please see the attachments. Including one on moving ethanol by rail in the USA and Canada.

Road transport is an option. However, given the recent $40 million upgrade of the South Coast line south of Kiama, the rail link to Manildra’s facility at Bomaderry, and the rail tracks near the proposed methanol facility at Port Kembla, the use of rail should be required to given further consideration by the proponent.

Further factors favouring the use of rail are an improvement in road safety, the high external costs of road freight, and the reduction in emissions resulting from the use of rail, as opposed to road.

If, however, road transport is to be used, strict conditions should be imposed such as those sought by Wollongong City Council’s Neighbourhood Forum 5 and 7.

These include designated routes, hours of operation, payment of a levy on the proponent for Council and State Road upgrades and repairs, and Manildra to undertake and transparently publish the results of traffic surveys at regular intervals with a view to confirming the traffic projections provided in the application.

There is also a case for all trucks accessing Ports located near urban areas, including Port Kembla, to be required to meet the current emission standards that are standard in Europe (Euro-VI Stage-C).

Submission is attached.
Please withhold my address and telephone number.

Refer attached NF5 submission

Please see the attachment.

Transport for NSW has spent $40m to upgrade the Kiama Bomaderry railway line. Why then is Transport For NSW supporting the use of road transport (as per their letter to Dept of Planning informing SEARS).

I refer to the extract below which is self explanatory:

Australian-owned agribusiness Manildra Group, who employ 1,000 people and send their homegrown products to every continent, will benefit from the rail line upgrade.

“The track upgrade to 25-tonne axle loading between Berry to Bomaderry and the tunnels between Kiama and Berry allows our company to operate heavier and longer rail services through the network,” Manildra Group National Transport and Logistics" Manager Mark Ownes said.

“This ultimately means we can meet both our current and future growth targets for both inbound raw materials to our Bomaderry facility and for our export freight to the Port of Botany to meet the export market, which benefits both regional employment and the NSW trade and economy."

Manildra may not want to use tankers on rail wagons, but for decades, milk tankers moved up and down the South Coast line.

It appears that there is no reason to not use rail to transport the product to Port Kembla.
If rail is not used it may be that Manildra should look at repaying the NSW taxpayer $40 million for the cost of rail improvements which appear to have been completed solely for the benefit of manildra.

See attached

Manildra-Port Kembla_Environmental Impact Statement_D. I refer you to section 6 (pages 62-72), “Consultation and stakeholder engagement”.

Manildra have claimed in this section that consultation with Neighbourhood Forum 5 . Neighbourhood forum 7 , project neighbours and landowners near the project has occurred.
This has NOT occurred as NHF5 and NHF7 are not aware of any approaches having been made by Manildra during this process.

The Claimed engagement method was:
Project overview
Advertising
Website update
Online survey
Online workshop
The method of engagement is ineffective as it is purely electronic and the community was (by all accounts) unaware that this may have been happening. There has been no personal contact made to the members of the community during this process (apart from the surprise briefing given to the members of PKHEG 12 months ago)

The following Scope of engagement claims to inform and advise the community. This is false. There is total ignorance to this proposal in the community - apart from the those businesses who were approached.
6.1.1 Scope of Engagement
This chapter covers community and stakeholder engagement carried out during the Environmental Impact
Assessment of the Proposal. The scope of this engagement covered:
• To inform the community of the overall proposal to build and operate a beverage grade ethanol storage and
handling facility on Foreshore Road at Port Kembla;
• To advise affected stakeholders of the overall proposal and its possible impacts during construction and
operation; and
• To advise stakeholders on how they may obtain further information or communicate concerns, complaints or
suggestions.

This section (below) states that property owners in postcodes 2540,2541 and 2505 and community and interest groups are stakeholders and as such the community should have been made aware that the process had begun and there was opportunity for engagement.
Community stakeholders include:
• Port owners, managers, and users;
• Impacted and nearby property owners (postcodes 2540, 2541 and 2505);
• Community and interest groups;
• Aboriginal groups;
• Businesses and industry;
• All levels of government;
• Utilities;
• Emergency services; and
• Media

The table below confirms what the Port Kembla Pollution Committee, Community members of PKHEG and NH5 and NH7 are claiming. That there has been no community engagement as evidenced by the fact that only one person RSVP'd and no one turned up to the briefing. The reason - No one knew about it. The RSVP could also be viewed as a stage as this community would have turned up if it knew something was happening.
Table 9: Stakeholder Meetings and Presentations
DATE STAKEHOLDER/ BRIEFING EVENT TOPICS
26 April 2022 Online Community workshop 1 RSVP but no attendees

The community could be forgiven for thinking that this whole process has been deceptive.

There needs to be comprehensive reparations to this process and comprehensive community consultation should be engaged.

A suggestion has been made to impose a trucking movement tax on all new truck movements in Port Kembla . ie new development in Port Kembla, to compensate for road damage, to assist with up grades and repairs.
This should be implemented immediately.
This is not considered to be too onerous as the proponents stand to make substantial profits from using Port Kembla Roads.
If a road tax is found to be too difficult to implement then a substantial annual contribution should be made back to the community of Port Kembla and surrounding suburbs for infrastructure repairs, community rebuilding, regeneration and other community projects.

It has been brought to our attention that the residents that reside along Shellharbour Road in the suburbs of Primbee, Windang, Lake South, Warilla, Blackbutt, Shellharbour, Flinders and Dunmore have not been advised of the Development Proposal; yet they will be severly inpacted by the increase in truck movements along their doorstep.
This submissions process should be halted until those suburbs have been notified of the intended increase in truck movements through their suburbs.

According to the traffic survey detailed in the DA the proposal will add an extra 4400 B Double (and larger) Truck movements onto Foreshore Road, annually.
Foreshore road already suffers with 365,000 truck movements annually form Morgan cement.
The trucks that currently use Foreshore road are not B double vehicles for good reason. There is a level crossing at the junction of Foreshore Road and Old Port Road and this immediately turns into a very small roundabout with a bus stop on the opposite side.
Buses cannot successfully negotiate this roundabout without mounting the roundabout itself.
Any B double using this roundabout will illegally cross onto the roundabout.
This intersection is already a very dangerous intersection especially when combined with the boat trailer traffic that use the boat ramp located a short distance along Foreshore road.
B double trucks would not be able to make a legal turn into Foreshore Road from the North end of Old Port Road as the driver would need to take an exceptionally wide turn across the roundabout to allow entry to Foreshore Road and across the level crossing on Foreshore Road without passing onto the wrong side of the road.
To enter Foreshore Road via Downies bridge Port Kembla (ie from Darcy Road) would involve the trailer passing over the centre of the roundabout. Similarly if a departing truck turned from Foreshore Road toward Darcy road it would have to take an exceptionally wide turn over the roundabout centre , passing onto the wrong side of the road to make the turn.
Both of which would be illegal turns.
B double trucks would not be able to traverse Downies Bridge legally as the entry road in both directions is a sharp bend and the Bridge is exceptionally slender. Currently trucks have to use both side of the road to move across the bridge.
Please note that Downies bridge was built for horses and carts not trucks. Each and every truck that uses Downies bridge has to cross onto the wrong side of the road to enter or leave the bridge. This is illegal.
Currently, on occasion cars have to stop to let trucks proceed across Downies Bridge. There is a very real elevated danger to other traffic if large trucks (B Doubles) use Downies Bridge.
There are also weight bearing load considerations to be taken into account.
Some one from Planning should inspect this bridge before a determination is made on this proposal.
The use of Downies Bridge should NOT be permitted at all.
There should be a designated route which precludes the use of Darcy Road, Downies Bridge and Military Road / Five islands road Port Kembla .
There needs to be heavy penalties for trucks violating this restriction; hence the trucks need to be clearly marked.

At it's meeting held on 26 July 2022, Wollongong City Council Neighbourhood Forum 7 resolved to comment on the Manildra Project as follows :-
Whilst there is much merit in the Manildra project, suitable safeguards need to be established to mitigate potential negative impacts on the Community such as: - a) noise and pollution, b) traffic issues arising from increased truck movements, c) additional wear and tear on roads and d) increased risk associated with adding further volatile goods handling operations to the Port.
Planning and Environment is urged to: -
1) Explore in detail with the applicant the extent to which it has considered the viability of using existing rail infrastructure as an alternate to road transport and why it has ruled out this possibility.
2) If existing rail infrastructure cannot be used: -
a) Specify the routes that trucks must use and specifically prohibit routes that would take trucks a) over Downies Bridge on Old Port Road and or b) through the residential areas of Berkeley, Lake Heights, Warrawong and Windang i.e. the use of King Street and Northcliffe Drive are prohibited.
b) Apply a levy on the proponent for Council and State Road upgrades and repairs.
c) Require the applicant to undertake and transparently publish the results of traffic surveys at regular intervals with a view to confirming the traffic projections provided in the application.
d) Restrict the hours of operation to exclude Sundays, Public Holidays and between 9.00 pm and 7.00 am.
3) Require the applicant to provide the explosion and fire risks associated with the project and provide the measures it will take to mitigate these risks.

Your attention is drawn to the SEPP 33 extract attached below.
The policy specifically states "While SEPP 33 is an enabling
instrument (that is, it allows for the development of industry) it also aims to ensure that
the merits of proposals are properly assessed (in relation to off-site risk and offence)
before being determined."

There does not appear to be any reference to "off site risk assessment" in any of the documents listed in the submission.
As this is a major concern of the community and Wollongong City Councillors we question the validity of the proposals ethical merits particularly given the poor safety record of the proponent.


1.2 The Policy
SEPP 33 presents a systematic approach to planning and assessing proposals for
potentially hazardous and offensive development for the purpose of industry or storage.
Through the policy, the permissibility of a proposal to which the policy applies is linked
to its safety and pollution control performance. While SEPP 33 is an enabling
instrument (that is, it allows for the development of industry) it also aims to ensure that
the merits of proposals are properly assessed (in relation to off-site risk and offence)
before being determined.
By providing for merit-based assessment, the policy overcomes the limitations of
previous definitions — in which a use was considered hazardous or offensive on the
basis of a particular type of industry, in isolation. The merit-based approach ensures
that locational and design considerations are an integral part of the assessment
process.
SEPP 33 ensures that only those proposals which are suitably located, and able to
demonstrate that they can be built and operated with an adequate level of safety and
pollution control, can proceed

Your attention needs to be drawn to the following section of Dept of Planning HIPAP number 4 (attached below) where specific reference is made to the following:
• the effects of significant events should, wherever possible, be contained within the
site boundary; and
• where the risk from an existing installation is already high, further development
should not pose any incremental risk.

When the Manildra proposal is measured against this criteria it fails.
It is apparent that any significant event could not be contained within the boundary of the site and would most certainly effect the community of Port Kembla; the nearest residential dwelling being 400 metres away.
and,
There already exists and exceptionally high risk from many existing volatile installations (Ixom, Cement Australia, Bluescope. Linde gas, Park Fuels, PKCT, PKGT, biofuels PK, the list goes on) and Manildra's ethanol plant will certainly elevate the incremental risk.

The risk to the community of Port Kembla is unacceptable. The risk is not only limited to the risk of fire, explosion, toxic fume engulfing Wollongong but also to the elevated risk of making Wollongong (and Port Kembla particularly ) a wartime target.
An officer of Dept of Planning needs to visit the area to understand just how close the volatile industries are to the city of Wollongong.

HIPAP number 4
2.5.4 Risk Criteria for Potentially Hazardous Development

Risk criteria for land use safety planning are set out in the Department’s Hazardous
Industry Planning Advisory Paper (HIPAP) No. 4.
2.5.4.1 General
In assessing the tolerability of risk from potentially hazardous development, both
qualitative and quantitative aspects need to be considered. Relevant general principles
are:
• the avoidance of all avoidable risks;
• the risk from a major hazard should be reduced wherever practicable, even where
the likelihood of exposure is low;
• the effects of significant events should, wherever possible, be contained within the
site boundary; and
• where the risk from an existing installation is already high, further development
should not pose any incremental risk.
Criteria are set conservatively, recognising that there is always a degree of uncertainty
in the results of the risk analysis.
The main quantitative criteria considered are fatality, injury, property and environmental
damage. The criteria most relevant to the study area are discussed below.

With regard to the proposal The Port Kembla Pollution Committee would like to draw your attention to the historically poor performance of The Manildra Group in terms of accidents.

We are aware that the Department of Planning is intimately aware of the history, the number and types of these accidents.

We have listed below just some of the accidents associated with the Manildra Group.

The final statement by an employee has been added to demonstrate just what sort of an employer Manildra can be.

It is apparent that this industry is an accident prone industry and the number of dangerous accidents is indicative that safety is not paramount to Manildra and accidents cannot be "risk assessed out" of the business.
The Port Kembla Community should not be expected to tolerate another dangerous industry located so close to the community and particularly one which when added to the exceptionally large number of volatile industries (operating in Port Kembla Harbour) in very close proximity to one and other has the potential to create a disaster in Wollongong.

Manildra has already demonstrated their contempt for rules, regulations and process by not complying with The Department Of Plannings directive (SEAR) to actively engage the community in the development of the EIS. The Port Kembla Community has not been consulted and engaged.

Can Manildra be trusted to operate in a safe manner if simple process is too difficult to abide by?

Below is just some of the dangerous accidents associated with Manildra.

https://www.energynewsbulletin.net › news › manildra-...
A 56-year-old man, a worker with ethanol producer, Manildra Group, which owns the tank, was taken to Wollongong Hospital with minor burns and injuries and ......

Potential Flour Mill Dust Explosion Injures One in Manildra ...
https://dustsafetyscience.com › flour-mill-explosion-ma...
19 May 2018 — Industry: Flour Milling (Agriculture) Equipment: Unknown. Company: Manildra

Investigations underway into Manildra Flour Mill explosions
https://www.9news.com.au › Videos
Preview Video
Investigators have arrived in Manildra after a series of explosions ... The building was extensively damaged, while one worker sustained minor injuries.
9News · 21 May 2018

Merton v Manildra Energy Australia Pty Ltd [2013] NSWSC 1482
https://mccabes.com.au › News & Blog
29 Oct 2013 — The plaintiff sustained physical and primary psychological injuries on 28 January 2004 as a result of an explosion caused by ethanol leaking ...

Base spirit supplier Manildra defends environmental record
https://drinksadventures.com.au › 2021/08/13 › neutral...
13 Aug 2021 — “Manildra's Bomaderry plant has breached its NSW Environment Protection Authority licence more than 10,000 times in recent years for the opacity

Investigation: RO-2010-002 - Australian Transport Safety Bureau
https://www.atsb.gov.au › investigation_reports › rair
10 Feb 2010 — The ARTC, Pacific National and the Manildra Group have put processes in place to ensure shunt orders are not fulfilled unless all shunt ..

Woman scalped in workplace accident near Nowra
https://www.illawarramercury.com.au › ... › Local News
The 48-year-old suffered severe head injuries after her hair became caught in the drive shaft of a machine at the Manildra Group mill on Bolong Road, ...

Manildra Australian flour mill restarts operations after explosion
https://www.world-grain.com › articles › 10396-manild...
21 May 2018 — “One employee obtained a minor injury and was treated at the scene. Emergency services were deployed and the incident has been contained.

UPDATED: Flour production resumes after Manildra fire
https://www.graincentral.com › news › overnight-fire-at...
11 Nov 2020 — The fire incident impacted the site for about a 30-hour period, and was attended by NSW emergency services including Fire and Rescue, NSW Rural ..

Of the 167 conditions in the approval, Shoalhaven Starches were found have complied with 116 conditions and
not complied with 15 conditions. An additional 36 conditions were not triggered.
Three of the non-compliances related to actual impacts to the environment:
- A discharge of starch into the Abernathy’s Creek;
- An exceedance of the opacity limits of the EPL; and
- An exceedance of the noise limits of the approval
One non-compliance related to the stockpiling of coal and woodchip without appropriate prior approval.

I would never recommend anyone getting a job in either packing sheds
Packer (Former Employee) - Bomaderry NSW - 7 October 2020
Don’t be a relief in the packing sheds.. you can and will be worked for anywhere up to 23days straight then one day off and back into it, you will get treated like s$&t and nothing is ever good enough for management whom have no idea how to run a coffee machine let alone a billion dollar company. You will get no notice of change from nights to days and no time time to adjust your sleep patterns... you will be required to give away all family commitments, RDO’s that aren’t rostered And can’t be taken without first acquiring assistance or potions from a wizard, holidays dont happen as a shift relief, probably expected to leave your partner and children. Most of the gentlemen in the packing sheds are depressed and unmotivated, the chances of moving up the ladder or out of the sheds are null and void and instantly blocked or hindered by management.
If you want a lifelong regret work in the packing area of Manildra bomaderry