Moorebank Waste Facility

This so-called "preferred project" report is absolutely biased for Moorebank Waste Recycling Plant and should not be used as evidence to support its approval by the PAC.

A few protest points I would like to point out:

1. The project preference report does not indicate the closest distance of this polluting factory to the nearest affected residential house. I live in on Travers Street. Here, it is on the side of the plateau where wind from the west will blow dust to the area and deposit dust to the area. There is no impact statement considering the likelihood of asbestos particles. Escaping from the plant that can result from human error. We cannot take chance when so many lifes can be affected. At work, we can get punished severely for workers affected by works exposing to asbestos dust. What about us residents staying next to the plant? This information is convenient missing and entirely mislead the public and PAC assessors on of how extremely close the distance between the plant and residential houses. If this plant is being approved, it would be one of the first ever construction waste recycling plant closest to residential houses.

2. Statement at clause 1.1 having misleading and untrue information in regards to only a small section of residential area is near to the site. How can this statement be put into the report as there is already 1000 houses built in Georges Fair?!! This number has not even includes the long existing residential area next to Georges Fair between Newbridge Road and Brickmakers Road.

3. Taking into consideration such a massive capacity 500,000 tonnes per annum, this waste recycling plant is expected to process 1602 tonnes per day, 6 days a week, 11 hours a day from 7am to 6pm. With the limited number of workers onsite and without mentioning about other machinery resources to prevent asbestos being processed at the facility, how can Moorebank Recycler assure that all the waste materials are free of asbestos?

4. The report is clearly stated that the recycled material consist of concrete, brick, asphalt, sandstone and sand. By all means, all these materials are actually very hazardous to human. Reference 1 & 2 clearly stated the danger of Asphalt and breathing in silica dust.

5. Poor site maintenance practise may incur mosquitoes, weeds, pests or vermin which will subsequently impact the Georges River environmental condition.

6. Clause 1.4.3 never consider and mention the impact of the dust generation, air contamination when the recycling material is exposed during transportation or material and handling of the materials between the crusher and machinery throughout the whole operation.

7. The operating hours are ridiculously long and even operating on Saturdays whereas the residents nearby are mainly spending the weekend as family day. In addition, operation hours during the weekday does not mean will not impact the resident as many family are still spending their time at home especially the retirees, preschool children, and home makers mum.

8. Section 2.3.2.3 comparing the additional traffic 1-2 trucks every 2 minutes should not be considered equal to the vehicles addition as the pick up speed of the truck is entirely different from a normal passenger car vehicles. Addition of 1-2 trucks in such a short time will definitely cause the massive traffic disturbance without considering the massive size of the truck, the pick up speed of the truck, hazard of the truck bring into the road safety, smoke of the truck exhaust due to most truck are poorly maintained and damage on the road condition.

9. Clause 2.4.2.8 taking a general statement from a Senate inquiry without the detail of the scientific aspect and detail of the issues of the inquiry to argue that silicosis is not a community problem is totally unacceptable as the evaluation should be case to case basis.

10. Clause 2.4.2.7 Poor standing of promises stated in the report such as performing asbestos screening without stating how to ensure the implementation and monitoring the effectiveness of the implementation. The site safety plan on the inspection process is poorly described without clearly stating how to manage the inspection of 1602 tonnes material per day. If only sampling inspection is performed, this also means that there is a risk that asbestos material will slip through and get into the recycling. Again, how can a normal staff differentiate asbestos from all the powdery substances of incoming construction wastes? Gyrock, crushed rocks, sands all mixed up even with asbestos cannot be visually differentiated at the incoming point.

11. Clause 2.14 stated that the land value of the residential area is not a consideration of the assessment is absolutely contradicting with the point that Moorebank Recycling Plant raise to support the 25 number of local jobs created. The damage of the local economy due to polluted suburb reputation, community being constantly exposed to health pollutant hazards and subsequently depreciation of property values is definitely far more devastating than just a mere number of jobs created.

12. The numerous numbers, tables and graphs churned and displayed in the report are merely theoretical, especially the dust and noise aspects. These are generated based on estimation models without any actual continuous monitoring of a similar operating plant. Merely stating that these numbers are acceptable is too much of assumption to make. In fact, there is no plan stated in the report that will be some hazard monitoring program in future. It mean that this project can be approved based on theoretical estimation of models and the actual hazard monitoring can be totally ignored.

In conclusion, this PPR report is entirely nonsense and biased towards supporting the building of this construction waste recycling plant.

Reference:
1. :Alsphalt Hazardous Substance Fact Sheet http://nj.gov/health/eoh/rtkweb/documents/fs/0170.pdf
2. :The Dangers of Breathing Silica Dust http://www2.worksafebc.com/i/posters/20 ... 09_04.html

3. Danger of disposal of Copper Chrome Arsenate Timber pg 2 (Attached Reference 3)

4. Health effect caused by cement. (Attached Reference 4)

5. Effect of Chronic Cement Dust Exposure on Lung Function.. (Attached Reference 5)

6. Impact of Dust Emission on Plant Vegetation in the Vicinity of Cement Plant.
(Attached Reference 6)

7. When People and Industry Live Side-by-Side: Health Impacts of PM Pollution
http://www.psr.org/environment-and-heal ... -side.html

Attached Reference 5)

6. Impact of Dust Emission on Plant Vegetation in the Vicinity of Cement Plant.
(Attached Reference 6)

7. When People and Industry Live Side-by-Side: Health Impacts of PM Pollution
http://www.psr.org/environment-and-heal ... -side.html

I consider the proposed facility to be detrimental to both the surrounding environment and community. In particular I am extemely concerned with levels of noise pollution, airborne waste pollutants and additional traffic congestion to be generated from this facility and the resultant affects on the adjoinging residential community.
I have attached a list of specific objections to the Development.

Please see our Objection attached.

Besides all these key points, we believe this is just not the place to establish a business like this.

Health and Safety must be considered.

Sincerely
Mark Grabe

Please see attachment

As residents of the Georges Fair Estate, I implore you to please consider the health hazards with living within such close proximity to a waste facility.



This is a newly developed residential estate where many young families with young children have recently moved into to live in a friendly and safe environment. The development of this plant would only bring unwanted harmful dust particles, heavy traffic and noise to the surrounds of the estate.



It is imperative that you take into account the well-being of our families and reject the Moorebank Waste Facility development proposal.



If the land area is required for more economic use, we believe the entire community would support the Marina development instead.

OPPOSITION TO THE MOOREBANK WASTE FACILITY
This so-called "preferred project" report is absolutely biased for Moorebank Waste Recycling Plant and should not be used as evidence to support its approval by the PAC.

A few protest points I would like to point out:
1. The project preference report does not indicate the closest distance of this polluting factory to the nearest affected residential house. I live in Conlon Ave where the distance is one of the closest to this plant (linear distance about 200m). This road is in direct line of sight of this pollutants generating plant. This information is convenient missing and entirely mislead the public and PAC assessors on of how extremely close the distance between the plant and residential houses. If this plant is being approved, it would be one of the first ever construction waste recycling plant closest to residential houses.
2. Statement at clause 1.1 having misleading and untrue information in regards to only a small section of residential area is near to the site. How can this statement be put into the report as there is already 1000 houses built in Georges Fair?!! This number has not even includes the long existing residential area next to Georges Fair between Newbridge Road and Brickmakers Road.
3. Taking into consideration such a massive capacity 500,000 tonnes per annum, this waste recycling plant is expected to process 1602 tonnes per day, 6 days a week, 11 hours a day from 7am to 6pm. With the limited number of workers onsite and without mentioning about other machinery resources to prevent asbestos being processed at the facility, how can Moorebank Recycler assure that all the waste materials are free of asbestos?
4. The report is clearly stated that the recycled material consist of concrete, brick, asphalt, sandstone and sand. By all means, all these materials are actually very hazardous to human. Reference 1 & 2 clearly stated the danger of Asphalt and breathing in silica dust.
5. Poor site maintenance practise may incur mosquitoes, weeds, pests or vermin which will subsequently impact the Georges River environmental condition.
6. Clause 1.4.3 never consider and mention the impact of the dust generation, air contamination when the recycling material is exposed during transportation or material and handling of the materials between the crusher and machinery throughout the whole operation.
7. The operating hours are ridiculously long and even operating on Saturdays whereas the residents nearby are mainly spending the weekend as family day. In addition, operation hours during the weekday does not mean will not impact the resident as many family are still spending their time at home especially the retirees, preschool children, and home makers mum.
8. Section 2.3.2.3 comparing the additional traffic 1-2 trucks every 2 minutes should not be considered equal to the vehicles addition as the pick up speed of the truck is entirely different from a normal passenger car vehicles. Addition of 1-2 trucks in such a short time will definitely cause the massive traffic disturbance without considering the massive size of the truck, the pick up speed of the truck, hazard of the truck bring into the road safety, smoke of the truck exhaust due to most truck are poorly maintained and damage on the road condition.
9. Clause 2.4.2.8 taking a general statement from a Senate inquiry without the detail of the scientific aspect and detail of the issues of the inquiry to argue that silicosis is not a community problem is totally unacceptable as the evaluation should be case to case basis.
10. Clause 2.4.2.7 Poor standing of promises stated in the report such as performing asbestos screening without stating how to ensure the implementation and monitoring the effectiveness of the implementation. The site safety plan on the inspection process is poorly described without clearly stating how to manage the inspection of 1602 tonnes material per day. If only sampling inspection is performed, this also means that there is a risk that asbestos material will slip through and get into the recycling. Again, how can a normal staff differentiate asbestos from all the powdery substances of incoming construction wastes? Gyrock, crushed rocks, sands all mixed up even with asbestos cannot be visually differentiated at the incoming point.
11. Clause 2.14 stated that the land value of the residential area is not a consideration of the assessment is absolutely contradicting with the point that Moorebank Recycling Plant raise to support the 25 number of local jobs created. The damage of the local economy due to polluted suburb reputation, community being constantly exposed to health pollutant hazards and subsequently depreciation of property values is definitely far more devastating than just a mere number of jobs created.
12. The numerous numbers, tables and graphs churned and displayed in the report are merely theoretical, especially the dust and noise aspects. These are generated based on estimation models without any actual continuous monitoring of a similar operating plant. Merely stating that these numbers are acceptable is too much of assumption to make. In fact, there is no plan stated in the report that will be some hazard monitoring program in future. It mean that this project can be approved based on theoretical estimation of models and the actual hazard monitoring can be totally ignored.

In conclusion, this PPR report is entirely nonsense and biased towards supporting the building of this construction waste recycling plant.

Reference:
1. :Alsphalt Hazardous Substance Fact Sheet http://nj.gov/health/eoh/rtkweb/documents/fs/0170.pdf
2. :The Dangers of Breathing Silica Dust http://www2.worksafebc.com/i/posters/20 ... 09_04.html

3. Danger of disposal of Copper Chrome Arsenate Timber pg 2 (Attached Reference 3)

4. Health effect caused by cement. (Attached Reference 4)

5. Effect of Chronic Cement Dust Exposure on Lung Function.. (Attached Reference 5)

6. Impact of Dust Emission on Plant Vegetation in the Vicinity of Cement Plant.
(Attached Reference 6)

7. When People and Industry Live Side-by-Side: Health Impacts of PM Pollution

OPPOSITION TO THE MOOREBANK WASTE FACILITY (MP 05_157) PPR

This so-called "preferred project" report is absolutely biased for Moorebank Waste Recycling Plant and should not be used as evidence to support its approval by the PAC.

A few protest points I would like to point out:
1. The project preference report does not indicate the closest distance of this polluting factory to the nearest affected residential house. I live in Conlon Ave where the distance is one of the closest to this plant (linear distance about 200m). This road is in direct line of sight of this pollutants generating plant. This information is convenient missing and entirely mislead the public and PAC assessors on of how extremely close the distance between the plant and residential houses. If this plant is being approved, it would be one of the first ever construction waste recycling plant closest to residential houses.
2. Statement at clause 1.1 having misleading and untrue information in regards to only a small section of residential area is near to the site. How can this statement be put into the report as there is already 1000 houses built in Georges Fair?!! This number has not even includes the long existing residential area next to Georges Fair between Newbridge Road and Brickmakers Road.
3. Taking into consideration such a massive capacity 500,000 tonnes per annum, this waste recycling plant is expected to process 1602 tonnes per day, 6 days a week, 11 hours a day from 7am to 6pm. With the limited number of workers onsite and without mentioning about other machinery resources to prevent asbestos being processed at the facility, how can Moorebank Recycler assure that all the waste materials are free of asbestos?
4. The report is clearly stated that the recycled material consist of concrete, brick, asphalt, sandstone and sand. By all means, all these materials are actually very hazardous to human. Reference 1 & 2 clearly stated the danger of Asphalt and breathing in silica dust.
5. Poor site maintenance practise may incur mosquitoes, weeds, pests or vermin which will subsequently impact the Georges River environmental condition.
6. Clause 1.4.3 never consider and mention the impact of the dust generation, air contamination when the recycling material is exposed during transportation or material and handling of the materials between the crusher and machinery throughout the whole operation.
7. The operating hours are ridiculously long and even operating on Saturdays whereas the residents nearby are mainly spending the weekend as family day. In addition, operation hours during the weekday does not mean will not impact the resident as many family are still spending their time at home especially the retirees, preschool children, and home makers mum.
8. Section 2.3.2.3 comparing the additional traffic 1-2 trucks every 2 minutes should not be considered equal to the vehicles addition as the pick up speed of the truck is entirely different from a normal passenger car vehicles. Addition of 1-2 trucks in such a short time will definitely cause the massive traffic disturbance without considering the massive size of the truck, the pick up speed of the truck, hazard of the truck bring into the road safety, smoke of the truck exhaust due to most truck are poorly maintained and damage on the road condition.
9. Clause 2.4.2.8 taking a general statement from a Senate inquiry without the detail of the scientific aspect and detail of the issues of the inquiry to argue that silicosis is not a community problem is totally unacceptable as the evaluation should be case to case basis.
10. Clause 2.4.2.7 Poor standing of promises stated in the report such as performing asbestos screening without stating how to ensure the implementation and monitoring the effectiveness of the implementation. The site safety plan on the inspection process is poorly described without clearly stating how to manage the inspection of 1602 tonnes material per day. If only sampling inspection is performed, this also means that there is a risk that asbestos material will slip through and get into the recycling. Again, how can a normal staff differentiate asbestos from all the powdery substances of incoming construction wastes? Gyrock, crushed rocks, sands all mixed up even with asbestos cannot be visually differentiated at the incoming point.
11. Clause 2.14 stated that the land value of the residential area is not a consideration of the assessment is absolutely contradicting with the point that Moorebank Recycling Plant raise to support the 25 number of local jobs created. The damage of the local economy due to polluted suburb reputation, community being constantly exposed to health pollutant hazards and subsequently depreciation of property values is definitely far more devastating than just a mere number of jobs created.
12. The numerous numbers, tables and graphs churned and displayed in the report are merely theoretical, especially the dust and noise aspects. These are generated based on estimation models without any actual continuous monitoring of a similar operating plant. Merely stating that these numbers are acceptable is too much of assumption to make. In fact, there is no plan stated in the report that will be some hazard monitoring program in future. It mean that this project can be approved based on theoretical estimation of models and the actual hazard monitoring can be totally ignored.

In conclusion, this PPR report is entirely nonsense and biased towards supporting the building of this construction waste recycling plant.

Reference:
1. :Alsphalt Hazardous Substance Fact Sheet http://nj.gov/health/eoh/rtkweb/documents/fs/0170.pdf
2. :The Dangers of Breathing Silica Dust http://www2.worksafebc.com/i/posters/20 ... 09_04.html

3. Danger of disposal of Copper Chrome Arsenate Timber pg 2 (Attached Reference 3)

4. Health effect caused by cement. (Attached Reference 4)

5. Effect of Chronic Cement Dust Exposure on Lung Function.. (Attached Reference 5)

6. Impact of Dust Emission on Plant Vegetation in the Vicinity of Cement Plant.
(Attached Reference 6)

7. When People and Industry Live Side-by-Side: Health Impacts of PM Pollution

To Whom It May Concern

I wish to lodge my continued objection to this ridiculous proposal to build a toxic polluting facility that has been labelled as an environmental recycling plant so close to residential property.
I am currently in the final stages of building mynew home, The Home in which I Intend to bring up my children in a healthy way which they deserve. Regardless of the proposed facility reducing its stack piles and wetting them down to crust, this will not be adequate to stop dust blowing into our homes and exposing us to deadly silica, There has been on many occasions a gust of wind that blows over the proposed site and into the georges fair estate between the trees adjacent to brickmakers drive. As the crust on these stack piles cracks in the wind the dust will pickup and blow to the estates,

I feel that the PPR does not justify itself in a way that we will be free from excesive dust, For instance the refernce to the World Health Organisation is inconclusive and does not mean that it has been tested fully, we only need to look at the miracle discovery of asbestos and where that led us years after exposure and the suffering cancer patients have to endure, silica is a real threat not only to humans but wildlife in the area,


The plant being built on the shoreline of the George's river opens the chances of adverse environmental disasters, concrete dust in a river system is known to be toxic and risks destroying the ecosystem in the river fish and other animals should not have to be exposed to this inhumane environmental hazard.

When i purchased my land i purchased it in a residential estate with the confirmation that the Benedicts Sand site was set for closure and in its place would be a new estate and small commercial precint, The site was also set for beautification with a Marina and parklands. This was something that would bring value to the surrounding properties and an area that all local residents could enjoy, The reference to this Benedicts site be it in regards to sound levels or pollution should be ignored as stated this site is set to close in place of a new residential estate.

Brickmakers Drive is not a wide road where large trucks can travel daily, This has been seen and documented on channel nines ACC programe, Since then a 5Tonne Load limit has been imposed on this road to ensure the safety of the residents in the area, You only have to watch the program to see the horror of a semi trailer mounting a chicane at high speed, May i remind the reader of the incident of the truck rolling on a bend not so long ago at the corner of orange grove rd and liverpool rd where a you child and wife lost there husband due to a truck rolling over. I would hate to see this happen again especially so close to my home.

The pickup speed of trucks coming in and out of the facility especially in peak hour will cause major incidents and death is inevitable as peak hour cars use brick makers drive to get home and frustrated truck drivers try to push there way out. Brickmakers drive was supposed to be a safe road for the families in georges fair that could use the path as a bike riding track and I have seen plenty of children of young age riding bikes with there family along this road . The road also has a 5tonne road limit imposed for the residents safety is not wide enough to allow an adequate turning circle for trucks pulling a dog to manoeuvre out nor are they able to turn right out of the site back to new bridge road. The PPR does not show the latest photos of Georges Fair nor does it show the new mirvac estate which is due for construction or the marina residential plan on the benedicts site.

** This plant will be in the heart of 3 estates at close proximity of less than 200metres with no other industrial property in the vicinity**


There is already a recycling facility on the Chipping Norton Side of newbridge rd that was moved many years ago from the Benedict's sand site in preparation for the new estates, This facility is fully housed in doors and does not have the risks that this new proposed site has.

We don't need 2 sites running so close to each other, It is of no benefit to anyone apart from the pockets of the investors of Moorebank Recyclers,

This PPR also references that the rubble will be screened for asbestos, considering asbestos is almost invisible to the human eye this is nothing but a farce and in today's society and with the known risks of asbestos all 3 estates and neighbouring houses should not be subject to this form of terrorism.

Asbestos has been used in many things and not just fibrous board,

Lastly I purchased this property and spent a lot of money on a house that owuld be safe to bring up my family a place that I would like to live my life in peace something that the rediculous running times will not allow I dont want to spend my days off listening to the sound of machinary braking away at concrete and other rubble,

This facility will destroy that dream and I will be forced to sell most probably at a loss which will cause financial hardship to me and my family.

I believe that there is a place for facilities such as this but not in a residential area

I strongly object to this ridiculous facility and would ask that the proposal be moved to a more suitable area outside of moorebank and in a strictly industrial area away from residential dwellings where people will not be a risk.

Daniel May
Georges Fair Estate

I/we wish to submit our objection to the proposed development being approved.
We have at the same address for more than 35 years and have had enough of all the dust and traffic noise from trucks from the recycling plants of Benedict Sands and Concrete Recyclers activities which are both in close proximity to our home in Elouera Crescent.

Stockpiles are as tall as most of the surrounding trees. Constantly we are assured that dust from the sites and the associated activities would be controlled. Despite what the authorities tell us it has always been a problem for all surrounding residents. Residents need to be asked face to face on their opinions about the dust problems.This has never happened at any level.
I wash my car at 7-30 pm and the following morning at 6-30 am or the following day the car clearly has a coating of dust.
I have heard many people with pools also complaining of the dust problem and in general how anything outside gets filthy in a matter of just a few days.

There are also many residents with health concerns about the asbestos related issues. I wish all concerned would admit that they cannot guarantee that anything that enters or leaves the sites does not contain any asbestos or other related hazardous materials, given the fact that most materials entering the site is from building demolition sites.

The small pocket of the Cumberland Forest that surrounds the site surely must be in danger of devastation from the constant dust and pollutant creating activities.
I fear for the future health of the Georges River with the pollutants and stagnant water that the wash down / separation plants from the holding ponds that are regularly flushed into the river.
Thanks to media coverage it was made public about the most unpleasant foul smell in the district that residents had to put up with and that apparently came from those water wash holding ponds. How quickly the smell disappeared once the media got involved!
There is an ongoing and never ending problem in our district with very noisy truck exhausts noise and exhaust brake noise. The site owners do not police their trucks for noisy exhausts nor do the Police or the RMS either.

We don't need more trucks on our roads and our district

The bottom line is that there are alternate sites for this type of industry, not near new and established housing estates or our fragile Georges River.

To all authorities, by rejecting this and existing and other future developments please give us a pleasant dust, noise and pollution free suburb to live in.

Regards Alan & Maree Higgins

see attached

See attached

See attached PDF file

To whom may concern,

I srongly object to the recycling proposal at moorebank as the following reasons.

TRAFFIC: Multiple issues remain with the safety of vehicles entering and exiting the site, both during construction and (if approved) during operation. During construction, trucks will access the site by turning left from the right lane of a three-lane road, daily, from 10am-3pm. These times will be unpoliced and will impact on a major arterial road. Medium rigid vehicles are expected to turn from the centre lane of a three-lane road to access the site, without escort. This is unsafe with multiple vehicles travelling in the left lane to turn into Brickmakers Dr. No warning will be given to vehicles that a large truck will cut them off a dangerous manner. Brickmakers Dr has a 5-tonne limit on the entire road. Trucks intending to access the facility are not permitted to use any portion of Brickmakers Dr. Trucks exiting the facility will use Brickmakers Dr via a stop sign. Heavy vehicle movement, at speed, under stop sign conditions, is blatantly unsafe and unpredictable for vehicles travelling along Brickmakers Dr and local pedestrians. No protective measures can be implemented to ensure heavy vehicles do not turn from Nuwarra Rd or Maddecks Ave into Brickmakers Dr. Traffic studies assume 5-6% heavy vehicle traffic on Brickmakers Dr. This road now has a 5-tonne limit and heavy vehicles are not permitted passage.
NOISE: Moorebank Recyclers argues that the current Benedict Sands site (Tanlane) should not be considered residential, even though it is currently zoned "residential", because there is no "guarantee" the area will be residential in the future. Plans for the Marina and residential development are currently with Liverpool City Council, which thoroughly supports the residential development. It is insufficient for Moorebank Recyclers to argue that there is no "guarantee". The zoning is relevant rather than approval for a particular development. The revised Acoustic Impact Assessment admits that there will be an increase in traffic noise (to an area with significant traffic noise already). Construction noise levels for the shorter term upgrade of the driveway and ramps will exceed criteria at future residences within Georges Fair and Tanlane. The projected noise level data should be ignored, as the levels predicted have all been exceeded in current/actual figures.
SILICA DUST (HEALTH RISKS): Published information shows serious health risks caused by continual long term exposure to small dust particles, particularly for children. Containment of dust particles cannot be adequately managed manually by watering stockpiles and truck tyres. The crust on stockpiles is easily eroded in medium to high winds and dust will be spread across Georges Fair and the Georges River. Dust spread from the high volume of trucks moving around the site on a crushed concrete surface, along with excavators shifting stockpiles, will spread dust which will not be contained simply by watering.
EFFECT ON PROPERTY VALUES: Studies on other potentially hazardous surrounds (such as high transmission power lines) to residential properties reveals discounting of up to 30% of market value. Such a decrease would have devastating financial impact on all residents. Part of the site will be visible from the Georges Fair housing estate and this will have a negative impact on property values.
ASBESTOS (HEALTH RISKS): Government waste policies state the detection of asbestos is an ongoing problem and challenge for the C&D waste recovery market. It warns that "recovery operators who adopt the most stringent testing regimes and make all possible effort to avoid any asbestos coming onto their sites cannot fully guarantee there is no asbestos fibres in their final products" (Department of Environment, `Construction and Demolition Waste Status Report', 2011).
SUITABILITY OF THE SITE: The `Preferred Project Report' falsely claims there is no evidence that Benedict will cease operations, despite a DA submission indicating their intention to cease operations. Liverpool City Council has determined that having a materials recycling facility at this site is not compatible with the existing and future land use pattern, which is predominantly residential development, environmental conservation and public open space. Moorebank Recyclers has had a materials recycling facility approved less than 20km from this site, in a zoned industrial area in St Peters, which negates the need for this facility. The facility has the potential to expose residents to odours, silica dust, asbestos and other dangerous particles. Moorebank Recyclers commits to "operate the MRF in a manner which is sympathetic to the amenity of the area". However, it is impossible to operate the facility in such a manner, given its residential and recreational areas.
STOCKPILE MANAGEMENT: The `Preferred Project Report' states "all aggregates will be kept damp". This is impossible to achieve at all times. The report claims spraying water on stockpiles will prevent dust emissions. The site is in a strong-wind area. Video will be shown at any future PAC meeting demonstrating the impact of strong winds on stockpiles. The report fails to address the risks with transporting the stockpiles around the facility and to and from the facility. The report refers to the "inherent moisture of the material". It is absurd to suggest that building material is inherently moist when it is generally dry material that is likely to be blown around during windy weather.
RECREATIONAL USE OF THE GEORGES RIVER: This project is inappropriate for the local area, now and in the future. There is no intention by Moorebank Recyclers to develop and open up the foreshore for public use. This facility will destroy the amenity of the local area whereas the Marina proposal will beautify the foreshore and is in keeping with the residential nature of the area.

To whom may concern,

I STRONGLY OBJECT TO THIS DEVELOPMENT FOR THESE REASONS SUCH AS TRAFFIC, NOISE, DUST AND ASBESTOS (HEALTH RISKS).

To keep the area as a residential, kids and people safe, less traffic and more chances to pick kids from child care/school care after work, more time to play and home cooking. Nothing personal but this one recycling plant could move to some other place instead of many families who had spend their life savings for homes. Cameras and fines for over speeding no cameras for slow traffic

I STRONGLY OBJECT TO THIS DEVELOPMENT FOR THESE REASONS:

This so-called "preferred project" report is absolutely biased for Moorebank Waste Recycling Plant and should not be used as evidence to support its approval by the PAC.

PROXIMITY TO RESIDENCES: The project preference report does not indicate the closest distance of this recycling facility to the nearest affected residential house. Residences in Conlon Ave and some portions of Brickmakers Dr. are located at a linear distance of about 200m. Conlon Ave road is in direct line of sight of this pollutants generating plant with very little bushes and trees in between. This information is convenient missing entirely misleading the public and PAC assessors on how extremely close the distance between the plant and residential houses is. If this plant is being approved, it would be one of the first ever construction waste recycling plant closest to residential houses.

Further, statement at clause 1.1 has misleading and untrue information that only a small section of residential area is near to the site. How can this statement be put into the report as there are already 1000 houses built in Georges Fair!! This number does not even include the long existing residential area next to Georges Fair between Newbridge Road and Brickmakers Dr.

TRAFFIC: Multiple issues remain with the safety of vehicles entering and exiting the site, both during construction and (if approved) during operation. During construction, trucks will access the site by turning left from the right lane of a three-lane road, daily, from 10am-3pm. These times will be unpoliced and will impact on a major arterial road. Medium rigid vehicles are expected to turn from the centre lane of a three-lane road to access the site, without escort. This is unsafe with multiple vehicles travelling in the left lane to turn into Brickmakers Dr. No warning will be given to vehicles that a large truck will cut them off a dangerous manner. Brickmakers Dr has a 5-tonne limit on the entire road. Trucks intending to access the facility are not permitted to use any portion of Brickmakers Dr. Trucks exiting the facility will use Brickmakers Dr via a stop sign. Heavy vehicle movement, at speed, under stop sign conditions, is blatantly unsafe and unpredictable for vehicles travelling along Brickmakers Dr and local pedestrians. No protective measures can be implemented to ensure heavy vehicles do not turn from Nuwarra Rd or Maddecks Ave into Brickmakers Dr. Traffic studies assume 5-6% heavy vehicle traffic on Brickmakers Dr. This road now has a 5-tonne limit and heavy vehicles are not permitted passage.

NOISE: Moorebank Recyclers argues that the current Benedict Sands site (Tanlane) should not be considered residential, even though it is currently zoned "residential", because there is no "guarantee" the area will be residential in the future. Plans for the Marina and residential development are currently with Liverpool City Council, which thoroughly supports the residential development. It is insufficient for Moorebank Recyclers to argue that there is no "guarantee". The zoning is relevant rather than approval for a particular development. The revised Acoustic Impact Assessment admits that there will be an increase in traffic noise (to an area with significant traffic noise already). Construction noise levels for the shorter term upgrade of the driveway and ramps will exceed criteria at future residences within Georges Fair and Tanlane. The projected noise level data should be ignored, as the levels predicted have all been exceeded in current/actual figures.

ASBESTOS (HEALTH RISKS): Government waste policies state the detection of asbestos is an ongoing problem and challenge for the C&D waste recovery market. It warns that "recovery operators who adopt the most stringent testing regimes and make all possible effort to avoid any asbestos coming onto their sites cannot fully guarantee there is no asbestos fibres in their final products" (Department of Environment, `Construction and Demolition Waste Status Report', 2011).

Clause 2.4.2.7 talks of poor standing promises such as performing asbestos screening without stating how the implementation and monitoring will be ensured. Taking into consideration the massive capacity of 500,000 tonnes per annum, this waste recycling plant is expected to process 1602 tonnes per day, 6 days a week, 11 hours a day from 7am to 6pm. The site safety plan on the inspection process is poorly described without clearly stating how to manage the inspection of 1602 tonnes material per day. If only sampling inspection is performed, this also means that there is a risk that asbestos material will slip through and get into the recycling. Again, how can a normal staff differentiate asbestos from all the powdery substances of incoming construction wastes? Gyrock, crushed rocks, sands all mixed up even with asbestos cannot be visually differentiated at the incoming point. Therefore, with the limited number of workers onsite and without mentioning about other machinery resources to prevent asbestos being processed at the facility, how can Moorebank Recycler assure that all the waste materials are free of asbestos?

NO PROPER MONITORING: The numerous numbers, tables and graphs churned and displayed in the report are merely theoretical, especially the dust and noise aspects. These are generated based on estimation models without any actual continuous monitoring of a similar operating plant. Merely stating that these numbers are acceptable is too much of an assumption to make. In fact, there is no plan stated in the report that there will be some hazard monitoring program in future. It means that this project can be approved based on theoretical estimation of models and the actual hazard monitoring can be totally ignored. In my view, polluting industries should never be erected any were near a residential community unless monitoring and controlling devices are installed that will shut down the plant if pollution exceeds the acceptable limit, especially when the limit itself keeps decreasing with time as we gain greater awareness of their health impacts.

TRANSPORTATION: Clause 1.4.3 never consider and mentions the impact of the dust generation, air contamination when the recycling material is exposed during transportation or handling of the materials between the crusher and machinery throughout the whole operation. The to and fro movement of 324 trucks per day will create huge dust clouds if one goes by what their trucks were shown to do in an ACA report on Channel 9 titled "Housing dream shattered".

SUITABILITY OF THE SITE: The `Preferred Project Report' falsely claims there is no evidence that Benedict will cease operations, despite a DA submission indicating their intention to cease operations. Liverpool City Council has determined that having a materials recycling facility at this site is not compatible with the existing and future land use pattern, which is predominantly residential development, environmental conservation and public open space. Moorebank Recyclers has had a materials recycling facility approved less than 20km from this site, in a zoned industrial area in St Peters, which negates the need for this facility. The facility has the potential to expose residents to odours, silica dust, asbestos and other dangerous particles. Moorebank Recyclers commits to "operate the MRF in a manner which is sympathetic to the amenity of the area". However, it is impossible to operate the facility in such a manner, given its residential and recreational areas.

STOCKPILE MANAGEMENT: The `Preferred Project Report' states "all aggregates will be kept damp". This is impossible to achieve at all times. The report claims spraying water on stockpiles will prevent dust emissions. The site is in a strong-wind area. Video will be shown at any future PAC meeting demonstrating the impact of strong winds on stockpiles. The report fails to address the risks with transportation of the stockpiles around the facility and to and from the facility. The report refers to the "inherent moisture of the material". It is absurd to suggest that building material is inherently moist when it is generally dry material that is likely to be blown around during windy weather.

LONG OPERATIONAL TIMES: The operating hours are ridiculously long and even operate on Saturdays whereas the working residents nearby mainly spend the weekend as family day. In addition, operation hours during the weekday does not mean it will not impact the residents, as many family still spending their time at home, especially the retirees, preschool children, and home maker mums.

RECREATIONAL USE OF THE GEORGES RIVER: This project is inappropriate for the local area, now and in the future. There is no intention by Moorebank Recyclers to develop and open up the foreshore for public use. This facility will destroy the amenity of the local area whereas the Marina proposal will beautify the foreshore and is in keeping with the residential nature of the area.

SILICA: The response of the recyclers on the subject of silica dust is highly inadequate and misleading. The harmful effects of silica dust are realised over a long period of time and since Industrialists generally avoid building sources of crystalline silica emissions close to communities, there may not be much information available for such situations. Moorebank Recyclers somehow appears bent on building in the midst of residences with utter disregard to people's health with their phoney arguments.

As pointed out in earlier objections the data on general public is not available because no systematic studies have been carried out. Moreover, the term "general public" often appears to exclude those who live in the vicinity of identified source of crystalline silica emissions, as the following paragraph suggests. "The California monitoring data (California OEHHA 2005; Richards et al. 2009) and US EPA (1996) and Environment Canada (2011) reports generally do not indicate the existence of any wide-spread significant concern about airborne crystalline silica exposures to the general public. (Note: "general public", as the term is used here, means individuals not living near an identified source of crystalline silica emissions.) However, US EPA (1996) stated that "some potential exists for environmental silicosis to human populations". Exposures of potential concern may be more likely if populations are close to large sources of uncontrolled emissions. Data from other air pollution control agencies shows that some emissions from industrial facilities could result in air concentrations above a level of concern for people living near these sources.

Non-occupational risks and how far the effects can be felt has been dealt with by Bridge 2009 who says the following:

"The question of non-occupational risk associated with communities living adjacent to peak sites requires examination. Community exposures to respirable crystalline silica (including freshly fractured, iron contaminated crystalline silica) in the near field of a quarry (for example) are likely to lie between ambient concentration and occupational concentrations in the ambient air. The available literature suggests ambient crystalline silica levels can be significantly elevated downwind of sites that may release silica particles. For example, Holmen and Shiraki 1991, confirm that crystalline silica in the respirable range downwind of a peak source can be significantly elevated above ambient concentrations."

"Further, the study by Holmen and Shiraki (2001) examined particulate concentrations downwind from a sand and gravel plant, including LIDAR measurement of plume height and downwind extent as well as particulate monitoring including analysis for crystalline silica. The technique used included collection of particulate on a cellulose substrate and subsequent laboratory analysis using scanning electron microscopy and X-ray diffraction. The findings of this study were that crystalline silica concentrations were significantly elevated downwind of the site as were both PM10 and PM2.5."

"In a similar case community monitoring in an area next to a steel plant (in Claymont, DE) that also recycles scrap metal showed high levels of PM pollution, including particularly toxic heavy metals like lead and mercury. This community is located much farther (more than 1 km) whereas the people living on Conlon Ave and the northern part of Brickmakers Dr. would be only ~250m from the recycling plant.

"More recently Shiraki and Holmen (2002) monitored silica concentrations in PM10 near a sand and gravel facility in central California. One upwind monitor and four downwind monitors were deployed. Upwind silica concentrations in the PM10 particle size fraction were found to be 4.6 ug/m3, whereas downwind concentrations ranged from 9.4 to 62.4 ug/m3. The higher concentrations were found closest to the source. These concentrations are well above the California OEHHA (2005) health benchmark of 3 ug/m3. The percent of crystalline silica, by weight, as a percent of total particulate weight, decreased with increasing distance from the source. However, the impact from this source was still evident, even at the furthest downwind monitor - 745 meters away. PM2.5 measurements were also attempted, but all values were below the method detection level used. Therefore no data was reported for PM2.5 size fraction silica concentrations."

"Although the risk of silicosis is regarded as negligible in the ambient environment, cases of non-occupational silicosis are recorded within the literature. The risk of silica related disease is a function of the cumulative dose, and environmental exposures to respirable crystalline silica can be significantly elevated downwind of industrial sources including industry, quarries and sand mining. Increasing the concentration of respirable particles containing crystalline silica near industrial sources increases the level of risk of silica disease in exposed populations."

"The current occupational exposure levels are shown to result in morbidity and mortality in workers and do not offer protection to communities (and associated sensitive sub-groups) exposed near peak sites."

"The risk associated with peak sites is exacerbated in situations where the community (including sensitive sub-groups) would be exposed to freshly fractured silica particles especially in the presence of iron. A typical example of this situation would be downwind of a quarry where rock is blasted and crushed."

Ecology is listing respirable crystalline silica as a toxic air pollutant (TAP) on the basis of work conducted by the California Office of Environmental Health Hazard Assessment (OEHHA). OEHHA is internationally recognized and accepted within the field of toxicology. OEHHA developed a Chronic Reference Exposure Level (CREL)
for respirable crystalline silica of 3 μg/m3 in 2005."

"A limit of 3ug/m3 (respirable crystalline silica) would protect communities, who are potentially exposed, in the vicinity of these peak sources. This would be a total exposure limit and include background ambient levels, and the cumulative exposure due to all industrial sources near the affected community."

Building products especially contain high amounts of silica and there is no known way of containing them completely, as the above extracts from literature as well as several submissions now and earlier have shown. They also show that Moorebank Recyclers has been providing very selective and misleading information to support their application. As mentioned above, the International community has already specified a limit of 3 μg/m3 for the respirable silica dust whereas the application is still talking in terms of a PM10 limit of 3 μg/m3 despite knowing that a significant portion of dust emerging from crushing of building products contains silica dust.
If the Department of Planning has any concern for health and well-being of the communities the proposal of Moorebank Reyclers should be rejected.


California Office of Environmental Health Hazard Assessment (California OEHHA). 2005. Chronic Reference Exposure Level (REL) for Silica (Crystalline, Respirable. (California Office of Health Hazard Evaluation.
- www.COEHHA.ca.gov/air/chronic_rels/silica_final.html).

Environment Canada. 2011. Quartz and Cristobalite: Draft screening assessment for the challenge. Environment Canada and Health Canada.
http://www.ec.gc.ca/ese-ees/1EB4F4EF-88EE-4679-9A6C-008F0CBC191C/batch12_14464-46-1%20%26%2014808-60-7_en.pdf

Holmen B.A., and Shiraki R, 2001 Near source measurement of crystalline silica concentrations in California: Pilot study Interim Report to California Air Resources Board, University of California, Davis.
Richards, J.R.; Brozell, T.T.; Rea, C.; Boraston, G.; Hayden, J. (2009). PM4 Crystalline Silica Emission Factors and Ambient Concentrations at Aggregate-Producing Sources in California. J. Air & Waste Manage. Assoc. 59: pp 1287-1295.

US EPA (1996) Ambient Levels and Non-cancer Health Effects of Inhaled Crystalline and Amorphous Silica: Health Issue Assessment. EPA/600/R-95/115. November 1996.

To whom it may concern,

I object to the construction and operation of a recycling facility that would handle approximately 500,000 tonnes of construction waste per year next to residential homes.

Regardless of the provisions made in their submission I believe the land in question would be better served as additional residential or commercial development as opposed to industrial.

Given the environmental and health issues raised in their submissions and the associated mitigation of risks can only be taken a that. Mitigation of risk. By not approving the development there would be no risk.

Regards
William Marasigan

I STRONGLY OBJECT TO THIS DEVELOPMENT FOR THESE REASONS:

This so-called Â"preferred projectÂ" report is absolutely biased for Moorebank Waste Recycling Plant and should not be used as evidence to support its approval by the PAC.

PROXIMITY TO RESIDENCES: The project preference report does not indicate the closest distance of this recycling facility to the
nearest affected residential house. Residences in Conlon Ave and some
portions of Brickmakers Dr. are located at a linear distance of about
200m. Conlon Ave road is in direct line of sight of this pollutants
generating plant with very little bushes and trees in between. This
information is convenient missing entirely misleading the public and
PAC assessors on how extremely close the distance between the plant
and residential houses is. If this plant is being approved, it would
be one of the first ever construction waste recycling plant closest to
residential houses.

Further, statement at clause 1.1 has misleading and untrue information
that only a small section of residential area is near to the site. How
can this statement be put into the report as there are already 1000
houses built in Georges Fair!! This number does not even include the
long existing residential area next to Georges Fair between Newbridge
Road and Brickmakers Dr.

TRAFFIC: Multiple issues remain with the safety of vehicles entering
and exiting the site, both during construction and (if approved)
during operation. During construction, trucks will access the site by
turning left from the right lane of a three-lane road, daily, from
10am-3pm. These times will be unpoliced and will impact on a major
arterial road. Medium rigid vehicles are expected to turn from the
centre lane of a three-lane road to access the site, without escort.
This is unsafe with multiple vehicles travelling in the left lane to
turn into Brickmakers Dr. No warning will be given to vehicles that a
large truck will cut them off a dangerous manner. Brickmakers Dr has
a 5-tonne limit on the entire road. Trucks intending to access the
facility are not permitted to use any portion of Brickmakers Dr.
Trucks exiting the facility will use Brickmakers Dr via a stop sign.
Heavy vehicle movement, at speed, under stop sign conditions, is
blatantly unsafe and unpredictable for vehicles travelling along
Brickmakers Dr and local pedestrians. No protective measures can be
implemented to ensure heavy vehicles do not turn from Nuwarra Rd or
Maddecks Ave into Brickmakers Dr. Traffic studies assume 5-6% heavy
vehicle traffic on Brickmakers Dr. This road now has a 5-tonne limit
and heavy vehicles are not permitted passage.

NOISE: Moorebank Recyclers argues that the current Benedict Sands site
(Tanlane) should not be considered residential, even though it is
currently zoned Â"residentialÂ", because there is no Â"guaranteeÂ" the
area will be residential in the future. Plans for the Marina and
residential development are currently with Liverpool City Council,
which thoroughly supports the residential development. It is
insufficient for Moorebank Recyclers to argue that there is no
Â"guaranteeÂ". The zoning is relevant rather than approval for a
particular development. The revised Acoustic Impact Assessment admits
that there will be an increase in traffic noise (to an area with
significant traffic noise already). Construction noise levels for the
shorter term upgrade of the driveway and ramps will exceed criteria at
future residences within Georges Fair and Tanlane. The projected noise
level data should be ignored, as the levels predicted have all been
exceeded in current/actual figures.

ASBESTOS (HEALTH RISKS): Government waste policies state the detection
of asbestos is an ongoing problem and challenge for the C&D waste
recovery market. It warns that "recovery operators who adopt the most
stringent testing regimes and make all possible effort to avoid any
asbestos coming onto their sites cannot fully guarantee there is no
asbestos fibres in their final products" (Department of Environment,
Â`Construction and Demolition Waste Status ReportÂ', 2011).

Clause 2.4.2.7 talks of poor standing promises such as performing
asbestos screening without stating how the implementation and
monitoring will be ensured. Taking into consideration the massive
capacity of 500,000 tonnes per annum, this waste recycling plant is
expected to process 1602 tonnes per day, 6 days a week, 11 hours a day
from 7am to 6pm. The site safety plan on the inspection process is
poorly described without clearly stating how to manage the inspection
of 1602 tonnes material per day. If only sampling inspection is
performed, this also means that there is a risk that asbestos material
will slip through and get into the recycling. Again, how can a normal
staff differentiate asbestos from all the powdery substances of
incoming construction wastes? Gyrock, crushed rocks, sands all mixed
up even with asbestos cannot be visually differentiated at the
incoming point. Therefore, with the limited number of workers onsite
and without mentioning about other machinery resources to prevent
asbestos being processed at the facility, how can Moorebank Recycler
assure that all the waste materials are free of asbestos?

NO PROPER MONITORING: The numerous numbers, tables and graphs churned
and displayed in the report are merely theoretical, especially the
dust and noise aspects. These are generated based on estimation models
without any actual continuous monitoring of a similar operating plant.
Merely stating that these numbers are acceptable is too much of an
assumption to make. In fact, there is no plan stated in the report
that there will be some hazard monitoring program in future. It means
that this project can be approved based on theoretical estimation of
models and the actual hazard monitoring can be totally ignored. In my
view, polluting industries should never be erected any were near a
residential community unless monitoring and controlling devices are
installed that will shut down the plant if pollution exceeds the
acceptable limit, especially when the limit itself keeps decreasing
with time as we gain greater awareness of their health impacts.

TRANSPORTATION: Clause 1.4.3 never consider and mentions the impact of
the dust generation, air contamination when the recycling material is
exposed during transportation or handling of the materials between the
crusher and machinery throughout the whole operation. The to and fro
movement of 324 trucks per day will create huge dust clouds if one
goes by what their trucks were shown to do in an ACA report on Channel
9 titled Â"Housing dream shatteredÂ".

SUITABILITY OF THE SITE: The Â`Preferred Project ReportÂ' falsely claims
there is no evidence that Benedict will cease operations, despite a DA
submission indicating their intention to cease operations. Liverpool
City Council has determined that having a materials recycling facility
at this site is not compatible with the existing and future land use
pattern, which is predominantly residential development, environmental
conservation and public open space. Moorebank Recyclers has had a
materials recycling facility approved less than 20km from this site,
in a zoned industrial area in St Peters, which negates the need for
this facility. The facility has the potential to expose residents to
odours, silica dust, asbestos and other dangerous particles. Moorebank
Recyclers commits to "operate the MRF in a manner which is sympathetic
to the amenity of the area". However, it is impossible to operate the
facility in such a manner, given its residential and recreational
areas.

STOCKPILE MANAGEMENT: The Â`Preferred Project ReportÂ' states Â"all
aggregates will be kept dampÂ". This is impossible to achieve at all
times. The report claims spraying water on stockpiles will prevent
dust emissions. The site is in a strong-wind area. Video will be
shown at any future PAC meeting demonstrating the impact of strong
winds on stockpiles. The report fails to address the risks with
transportation of the stockpiles around the facility and to and from
the facility. The report refers to the Â"inherent moisture of the
materialÂ". It is absurd to suggest that building material is
inherently moist when it is generally dry material that is likely to
be blown around during windy weather.

LONG OPERATIONAL TIMES: The operating hours are ridiculously long and
even operate on Saturdays whereas the working residents nearby mainly
spend the weekend as family day. In addition, operation hours during
the weekday does not mean it will not impact the residents, as many
family still spending their time at home, especially the retirees,
preschool children, and home maker mums. RECREATIONAL USE OF THE
GEORGES RIVER: This project is inappropriate for the local area, now
and in the future. There is no intention by Moorebank Recyclers to
develop and open up the foreshore for public use. This facility will
destroy the amenity of the local area whereas the Marina proposal will
beautify the foreshore and is in keeping with the residential nature
of the area.

SILICA: The response of the recyclers on the subject of silica dust is
highly inadequate and misleading. The harmful effects of silica dust
are realised over a long period of time and since Industrialists
generally avoid building sources of crystalline silica emissions close
to communities, there may not be much information available for such
situations. Moorebank Recyclers somehow appears bent on building in
the midst of residences with utter disregard to peopleÂ's health with
their phoney arguments.

As pointed out in earlier objections the data on general public is not
available because no systematic studies have been carried out.
Moreover, the term Â"general publicÂ" often appears to exclude those who
live in the vicinity of identified source of crystalline silica
emissions, as the following paragraph suggests. Â"The California
monitoring data (California OEHHA 2005; Richards et al. 2009) and US
EPA (1996) and Environment Canada (2011) reports generally do not
indicate the existence of any wide-spread significant concern about
airborne crystalline silica exposures to the general public. (Note:
Â"general publicÂ", as the term is used here, means individuals not
living near an identified source of crystalline silica emissions.)
However, US EPA (1996) stated that Â"some potential exists for
environmental silicosis to human populationsÂ". Exposures of potential
concern may be more likely if populations are close to large sources
of uncontrolled emissions. Data from other air pollution control
agencies shows that some emissions from industrial facilities could
result in air concentrations above a level of concern for people
living near these sources.



Non-occupational risks and how far the effects can be felt has been
dealt with by Bridge 2009 who says the following:



Â"The question of non-occupational risk associated with communities
living adjacent to peak sites requires examination. Community
exposures to respirable crystalline silica (including freshly
fractured, iron contaminated crystalline silica) in the near field of
a quarry (for example) are likely to lie between ambient concentration
and occupational concentrations in the ambient air. The available
literature suggests ambient crystalline silica levels can be
significantly elevated downwind of sites that may release silica
particles. For example, Holmen and Shiraki 1991, confirm that
crystalline silica in the respirable range downwind of a peak source
can be significantly elevated above ambient concentrations.Â"



Â"Further, the study by Holmen and Shiraki (2001) examined particulate
concentrations downwind from a sand and gravel plant, including LIDAR
measurement of plume height and downwind extent as well as particulate
monitoring including analysis for crystalline silica. The technique
used included collection of particulate on a cellulose substrate and
subsequent laboratory analysis using scanning electron microscopy and
X-ray diffraction. The findings of this study were that crystalline
silica concentrations were significantly elevated downwind of the site
as were both PM10 and PM2.5.Â"



Â"In a similar case community monitoring in an area next to a steel
plant (in Claymont, DE) that also recycles scrap metal showed high
levels of PM pollution, including particularly toxic heavy metals like
lead and mercury. This community is located much farther (more than 1
km) whereas the people living on Conlon Ave and the northern part of
Brickmakers Dr. would be only ~250m from the recycling plant.



Â"More recently Shiraki and Holmen (2002) monitored silica
concentrations in PM10 near a sand and gravel facility in central
California. One upwind monitor and four downwind monitors were
deployed. Upwind silica concentrations in the PM10 particle size
fraction were found to be 4.6 ug/m3, whereas downwind concentrations
ranged from 9.4 to 62.4 ug/m3. The higher concentrations were found
closest to the source. These concentrations are well above the
California OEHHA (2005) health benchmark of 3 ug/m3. The percent of
crystalline silica, by weight, as a percent of total particulate
weight, decreased with increasing distance from the source. However,
the impact from this source was still evident, even at the furthest
downwind monitor - 745 meters away. PM2.5 measurements were also
attempted, but all values were below the method detection level used.
Therefore no data was reported for PM2.5 size fraction silica
concentrations.Â"



Â"Although the risk of silicosis is regarded as negligible in the
ambient environment, cases of non-occupational silicosis are recorded
within the literature. The risk of silica related disease is a
function of the cumulative dose, and environmental exposures to
respirable crystalline silica can be significantly elevated downwind
of industrial sources including industry, quarries and sand mining.
Increasing the concentration of respirable particles containing
crystalline silica near industrial sources increases the level of risk
of silica disease in exposed populations.Â"



Â"The current occupational exposure levels are shown to result in
morbidity and mortality in workers and do not offer protection to
communities (and associated sensitive sub-groups) exposed near peak
sites.Â"



Â"The risk associated with peak sites is exacerbated in situations
where the community (including sensitive sub-groups) would be exposed
to freshly fractured silica particles especially in the presence of
iron. A typical example of this situation would be downwind of a
quarry where rock is blasted and crushed.Â"



Ecology is listing respirable crystalline silica as a toxic air
pollutant (TAP) on the basis of work conducted by the California
Office of Environmental Health Hazard Assessment (OEHHA). OEHHA is
internationally recognized and accepted within the field of
toxicology. OEHHA developed a Chronic Reference Exposure Level (CREL)
for respirable crystalline silica of 3 μg/m3 in 2005.Â"



Â"A limit of 3ug/m3 (respirable crystalline silica) would protect
communities, who are potentially exposed, in the vicinity of these
peak sources. This would be a total exposure limit and include
background ambient levels, and the cumulative exposure due to all
industrial sources near the affected community.Â"



Building products especially contain high amounts of silica and there
is no known way of containing them completely, as the above extracts
from literature as well as several submissions now and earlier have
shown. They also show that Moorebank Recyclers has been providing very
selective and misleading information to support their application. As
mentioned above, the International community has already specified a
limit of 3 μg/m3 for the respirable silica dust whereas the
application is still talking in terms of a PM10 limit of 3 μg/m3
despite knowing that a significant portion of dust emerging from
crushing of building products contains silica dust.

If the Department of Planning has any concern for health and
well-being of the communities the proposal of Moorebank Reyclers
should be rejected.





California Office of Environmental Health Hazard Assessment
(California OEHHA). 2005. Chronic Reference Exposure Level (REL) for
Silica (Crystalline, Respirable. (California Office of Health Hazard
Evaluation.

- www.COEHHA.ca.gov/air/chronic_rels/silica_final.html).



Environment Canada. 2011. Quartz and Cristobalite: Draft screening
assessment for the challenge. Environment Canada and Health Canada.

http://www.ec.gc.ca/ese-ees/1EB4F4EF-88EE-4679-9A6C-008F0CBC191C/batch12_14464-46-1%20%26%2014808-60-7_en.pdf



Holmen B.A., and Shiraki R, 2001 Near source measurement of
crystalline silica concentrations in California: Pilot study Interim
Report to California Air Resources Board, University of California,
Davis.

Richards, J.R.; Brozell, T.T.; Rea, C.; Boraston, G.; Hayden, J.
(2009). PM4 Crystalline Silica Emission Factors and Ambient
Concentrations at Aggregate-Producing Sources in California. J. Air &
Waste Manage. Assoc. 59: pp 1287-1295.



US EPA (1996) Ambient Levels and Non-cancer Health Effects of Inhaled
Crystalline and Amorphous Silica: Health Issue Assessment.
EPA/600/R-95/115. November 1996.


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I strongly object to this proposed waste facility development to proceed as a resident of the Georges Fair Estate it will be a devastating outcome for all of the families who have made it their home. We are all so sick and tired of these kinds of submissions. Can they not see the huge impact this will have on the residence?

Please do not allow this proposal to go ahead!