Moss Vale Plastics Recycling Facility

I write with concerns regarding two aspects of this proposal:
1. Traffic volumes; and
2. Noise in the vicinity of Stables Place and Trotters Lane, Moss Vale.
Traffic Volumes
A. Beaconsfield Road
Having reviewed Technical Report 6 to the EIS, I note the following:
1) The automatic tube count assessment of traffic on Beaconsfield Rd seems to have been conducted in the vicinity of Trotter’s Lane. Local experience would suggest that the majority of traffic on Beaconsfield Rd after Lytton Rd turns onto Roche Cl or Stables Pl. The tube will not have detected that traffic.
2) There is currently a significant residential development in the vicinity of 45 Beaconsfield Rd. This development will see a significant increase in firstly commercial and construction traffic, then residential traffic. This should be considered prior to accepting the current traffic volume assessment in Report 6.
3) The state of Beaconsfield Rd, particularly the shoulders, makes traffic flow limited when large vehicles are on many parts of the road. The road should be properly upgraded (to the condition between Roche Cl and Stables Pl prior to construction traffic being permitted to use Beaconsfield Rd in lieu of the planned access road.
4) The daycare centre at 50 Beaconsfield Rd has insufficient parking to accommodate clients. This, combined with the construction area opposite the centre creates traffic congestion in the area of Beaconsfield Rd between Stables Pl and Trotters Ln which spills past Stable Pl toward Roche Cl.

B. Lackey Road and Illawarra Highway
1) The intersection of Lackey Rd and Illawarra Hwy suffers from significant congestion, particularly during peak periods and for people turning right onto Argyle St throughout the day.
In light of the above, construction of the Plastics Recycling Facility should commence only after the access road from Lackey Rd is completed. After this time, unless significant works are undertaken at the intersection of Lackey Rd and Illawarra Hwy are undertaken to improve traffic flow, all traffic with business at the Facility should be required to use the route identified in the EIS (Berrima Rd/Douglas Rd).
Noise
A. The statement in the EIS (page vii), that there will be little to no disruption for people as close as 19m from Beaconsfield Rd, seems unlikely to be accurate. A drainage easement is present between Stables Pl and Trotters Ln. This easement creates a channeling effect for noise. From the Stable Pl cul-de-sac rail operations are routinely heard during the silent hours of the night. Noting this location is approximately 600m in a straight line (obstructed by buildings and vegetation) from the rail line it seems likely that an increase of heavy traffic on Beaconsfield Rd (particularly noting that the easement is at the base of the decline where trucks may use compression brakes) will increase noise along Stables Pl and Trotters Ln.
While we are not opposed to the development and the intent of mitigating environmental impacts of plastics, this development will have a significant impact on residents of Beaconsfield Rd, Roche Cl, Stables Pl and Trotters Ln. Noting the other causes of traffic congestion and the ongoing development of residential premises, the further impacts from the Facility development can easily be mitigated through first developing the access road and imposing conditions on traffic bound for the Facility.

Threat to air quality: I am an asthmatic and live in Lytton Road, and what I believe would be an inevitable deterioration of air quality if this huge facility goes ahead, would mean I’d have to move to avoid risk to my health.
I went to boarding school in Moss Vale, where many children with lung issues were sent because the air here was known to be pristine. It would be a tragedy if this air quality was severely compromised. (And yes, I have read the EIS, which paints a rosy picture of how things would play out, and frankly it was hard to take it seriously).
There is a child care centre in the path of the proposed facility, and the welfare of these youngsters may well be under threat too.
The EIS refers to the existing light industry in the immediate area – but there’s no comparison. What is there now causes no harm, but the plastic recycling facility would be massive, produce likely air pollution and result in trucks going back and forth pretty much 24/7.
This facility would be way too big for this area. And I do realise that development is inevitable, but this would not be progress. There’s a difference.
I am indebted to a piece in the Sydney Morning Herald on January 13, which presents the concerns clearly. And furthermore, the article reveals that Beijing-based businessman Lyu Yalin, who was front and centre in the leaflet about this development which was dropped in my letterbox a couple of years ago, has now taken a back seat on this project since it has come to light that he apparently has form in China on matters including air pollution – and was censured for these.
Finally: I’d be grateful to receive an explanation as to the proposed truck route. I have looked at documents on exhibition and can’t figure it out….I gather that trucks would come down Beaconsfield Road, heading for Lackey Road – but what I would like clarified: would trucks turn left into Lytton Road, out of Beaconsfield Road? Thank you.

See attached letter

I Danuta Hulajko, resident of Moss Vale object to the proposed development SSD—9409987
2.1 Does SEPP 33 Apply? (Hazardous and Offensive Development Application Guidelines Applying SEPP 33)
This section provides advice to consent authorities on deciding whether SEPP 33 applies to a proposal and how to apply the new definitions the policy introduces. Consent authorities should firstly consider whether the proposed use falls within the definition of ‘industry’ adopted by the planning instrument which applies or whether it is a ‘storage establishment’. Once a proposal is identified as an industry or storage establishment, consent authorities need to consider: • Does the proposal require development consent or approval under Part 3A or Part 4 of the EP&A Act? • Is the proposal ‘potentially hazardous industry’? • Is the proposal ‘potentially offensive industry’? Note: For the purposes of SEPP 33, a hazardous storage establishment is included in the definition of potentially hazardous industry. Similarly, an offensive storage establishment is included in the definition of potentially offensive industry. This means that a storage development is considered ‘industry’ for the purposes of applying the SEPP 33 tests, even if the development is non-industrial. An example may be a storage facility associated with the reticulation of LPG within a housing development. SEPP 33 will apply if a proposal for an industrial development requires consent, and it is either potentially hazardous industry or potentially offensive industry (or both). Figure 1 indicates the procedure for determining if SEPP 33 applies, while Figure 2 outlines the associated assessment process for a typical Part 4 local development. Question 2.1 what supporting information should I seek in order to determined
Base on the requirements of the SEPP 33 the proposed development is potentially hazardous in nature as it involves plastics and polymers for reprocessing. While the plastic products prior to recycling or final products may not be hazardous and toxic there are some stages in the reprocessing of each of those plastics are hazardous and toxic as discussed below.
Section 7.5.1 of the EIS
This section lists 6 types of plastics and polymers which will be crushed ( powder will be in the) , melted at a high temperature and molded into new plastic products. I cannot find anywhere in the EIS how the proponent is going to address this. The Material Safety Data Sheet (MSD) for each of those plastic is discussed below. Two of plastic proposed for recycling are potentially explosive in the powder form. Other byproducts like plastic sludge is deadly to the enviromement ( water, wildlife, humans , soil) and cannot be disposed just anywhere like in Bowral waste facility as GHD report suggests. The GHD Project Manager David Gamble could not answer any of my questions nor the Director of Plasrefine, Nanxi Zheng from China present at last week meeting with the community in Exeter.
To my knowledge Mrs. Zheng and her uncle in China (investor) do not have the expertise in plastic recycling at all.
Polyethylene terephthalate (PET) Bottles
Hazards of this product may be associated with its processing: spilled pellets create a slipping hazard. Molten plastic can cause severe thermal burns. Fumes produced during the thermal processing of polymer melt may cause eye, skin and respiratory tract irritation. Treat in the same way as other thermal burns and wood smoke inhalation.

https://www.polisanhellas.com/pdf/Doc_PetResins_MSDS_PoliPET_PolisanHellas_2017.pdf?fbclid=IwAR3LApoJLLjZYZX7zxB53GS-uSB2XD-Lss-4hq_T0XPPxm-26IEjdGcCbMY
High Density Polyethylene (HDPE) bottles
High Density Polyethylene (HDPE) In case of fire – • Extinguishing Media: Extinguish preferably with foam, carbon dioxide or dry chemical. • Fire Fighting Protective Equipment: A self-contained breathing apparatus and suitable protective clothing should be worn in fire conditions. • Hazardous Decomposition Product(s): Combustion or thermal decomposition will evolve irritant vapours. • Can melt and burn in a fire. Molten material tends to flow or drip and will propagate fire. See Physical Hazard Information. For more information, request the relevant Material Data Safety Sheet from RIL
That is very reassuring: “propagates fire...”

https://www.ril.com/DownloadFiles/Polymers/assessment/pra_relene_pe_hdp.pdf?fbclid=IwAR1SYiJSCl4SmPMO_Id5QOG4gvBSJ16Oj4nU3Jr8ZLrNFiNJPwIB8EEeuWY
Polypropylene (PP)
PP bottles, this is a real gem" Dust may form explosive mixtures with air"
Will accumulates static charges that may cause an electric spark (ignition source). and more horror precautions. You need to read it yourself. Sort of like dynamite to me.
“6.2 Environmental precautions
Gather pellets and powder thoroughly to avoid birds or fishes taking from draining water. Do not allow product to reach sewage system or water bodies. Inform respective authorities in case product reaches water, sewage system or soil
General information: Do not allow to enter into ground-water, surface water or drains.
Measures to prevent fire: Prevent from fire around handling area Measures to prevent aerosol and dust generation: maintain good housekeeping standards to prevent accumulation of dust. To avoid dust explosion resulting from the existence of powder, electrostatics eliminators and grounding should be fixed to such equipment as air transferring pipes, bag filters and hoppers. Use electrically conductive filters for bag filters”
Toxicological effects: - Acute toxicity (oral): Lack of data. - Acute toxicity (dermal): Lack of data. - Acute toxicity (inhalative): Lack of data. - Skin corrosion/irritation: Lack of data. May cause irritations
Eye damage/irritation: Lack of data. May cause irritations. - Sensitisation to the respiratory tract: Lack of data. Not to be expected - Skin sensitisation: Lack of data. Not to be expected - Germ cell mutagenicity/Genotoxicity: Lack of data. Not to be expected - Carcinogenicity: Lack of data. Not to be expected - Reproductive toxicity: Lack of data. Not to be expected - Effects on or via lactation: Lack of data. - Specific target organ toxicity (single exposure): Lack of data. - Dusts: Irritating to eyes, respiratory system and skin. - Specific target organ toxicity (repeated exposure): Lack of data.
Other information Styrene: - Harmful if inhaled. Causes damage to organs through prolonged or repeated exposure. - lung damages - May be fatal if swallowed and enters airways. - Causes serious eye irritation. Causes skin irritation. Acrylonitrile: - Toxic by inhalation, in contact with skin and if swallowed. - May cause cancer. Suspected of damaging the unborn child. - Causes skin irritation. May cause an allergic skin reaction. Causes serious eye - damage. 1,3-Butadiene: - May cause cancer. May cause genetic defects. Symptoms - Dust:Can cause skin, eye and respiratory tract irritation. - The melted product can cause severe burns. - Thermal treatment, Processing: - Irritating to eyes, respiratory system and skin. - In case of ingestion: Swallowing may cause gastrointestinal irritation and pain of guts.
12.3 Bioaccumulative potential To avoid bioaccumulation plastics should not be disposed in the sea or in other water environments.
12.5 Other adverse effects: General information: Do not allow to enter into ground-water, surface water or drains.

Low density polyethylene (LDPE) films
HAZARDOUS PRODUCTS OF COMBUSTION: Carbon dioxide, carbon monoxide and aldehydes
Exposure to CO2 can produce a variety of health effects. These may include headaches, dizziness, restlessness, a tingling or pins or needles feeling, difficulty breathing, sweating, tiredness, increased heart rate, elevated blood pressure, coma, asphyxia, and convulsions.
Carbon monoxide poisoning occurs when carbon monoxide builds up in your bloodstream. When too much carbon monoxide is in the air, your body replaces the oxygen in your red blood cells with carbon monoxide. This can lead to serious tissue damage, or even death.
Carbon monoxide is a colorless, odorless, tasteless gas produced by burning gasoline, wood, propane, charcoal or other fuel. Improperly ventilated appliances and engines, particularly in a tightly sealed or enclosed space, may allow carbon monoxide to accumulate to dangerous levels.
Uplasticized polyvibyl chloride (UPVC) pipes

Environmental precautions: Cautions should be exerted not to affect the environment resulting from release to rivers etc. Never discharge to the environment.
Melting point Softens at >75 0 C.
Fire Incompatibility Oxidising agents. Hydrogen peroxide, ozone, oxygen, potassium nitrate, and nitric acid are all oxidizing agents. All of the halogens are oxidizing agents (e.g., chlorine, bromine, fluorine Oxidizer as a Dangerous Material
Because an oxidizer may contribute to combustion, it may be classified as a dangerous material. The hazard symbol for an oxidizer is a circle with flames on top of it.

Storage Store in appropriate areas (outside or in warehouse) in accordance with site safety requirements. Do not store with oxidising agents.


https://www.redwoodplastics.com/wp-content/uploads/2010/03/LDPE-2012.pdf

LEP 2010 and the Proposed Southern Highlands Innovation Park DCP

The subject land and the adjoining land has been rezoned in 1981 from Rural to General Industrial. Since then the Wingecarribbe Council has not prepared a draft of this DCPP Plasrefine is potentially toxic and hazardous industry there not General Industry under the definition of the Wingecarribee Council LEP 2010. If approved it will generate a precedence of heavy /hazardous industry immediately adjacent to residential (R2) and Enviromental Living(E4) Primary Production Small Lots ( RU4).
Therefore the proposed development is incompatible with the adjacent zoning and land use.

The risk to the health and safety of the Southern Highlands Community, its air and water quality, road users both vehicular and pedestrian and the lack of rigour and accountability in this EIS along with the absence of critical detail which will not be provided until post consent make this facility completely unsuitable and unwelcome on its current site.

I hope this gets through. I am not computer literate.

I object to the project. it is not the appropriate site for the intended facility, too close to the Moss Vale township, too close to schools, to a preschool, too big in scope and scale to be located so close to the township. There are many critical infrastructure issues, community and environmental health issues, safety issues, traffic concerns, water and fire issues - the proposal must be rejected. The documentation reads as it the proponent is making it up as he/she goes along. Badly done and contemptuous of the Moss Vale and wider community. My submission is attached.

Pleas refer to the attached PDF.

My Objection is primarily on the basis of the unsuitability of the only access road to the proposed development which is Beaconsfield Rd Moss Vale. I am a resident on this road. Please see the attached submission for further details of my objection.

As a regular visitor to Moss Vale to see my grandmother who resides in Beaconsfield Road I would like to strongly object to the proposed development of the Moss Vale Plastics Recycling Business which I believe will have a significant negative impact to the environment in its currently proposed site.

A business of this nature established so close to suburban properties and utilising local traffic roads to manage large heavy vehicles during the construction and ongoing management of the proposed business in not in any way in keeping with modern environmental expectations.

Increased noise levels, unsuitability of Beaconsfield Rd for increased and/or heavy traffic , proximity of traffic near child care facilities, increased pollution from traffic and the business, visual pollution and the supply of power, electricity and water are all issues that will negatively impact on the local community and are not adequately addressed by the EIS.

I urge you to reject the business in the area it is proposed and establish these type of projects in areas that do not impact so negatively on the local communities and the semi rural environment that has drawn the local community to this area in the first place.

As a regular visitor to Moss Vale to see my grandmother who resides in Beaconsfield Road I would like to strongly object to the proposed development of the Moss Vale Plastics Recycling Business which I believe will have a significant negative impact to the environment in its currently proposed site.

A business of this nature established so close to suburban properties and utilising local traffic roads to manage large heavy vehicles during the construction and ongoing management of the proposed business in not in any way in keeping with modern environmental expectations.

Increased noise levels, unsuitability of Beaconsfield Rd for increased and/or heavy traffic , proximity of traffic near child care facilities, increased pollution from traffic and the business, visual pollution and the supply of power, electricity and water are all issues that will negatively impact on the local community and are not adequately addressed by the EIS.

I urge you to reject the business in the area it is proposed and establish these type of projects in areas that do not impact so negatively on the local communities and the semi rural environment that has drawn the local community to this area in the first place.

This project is not environmentally friendly nor community or housing friendly. In fact I believe it to be hazardous to the community for the following reasons,
The number of trucks that will deliver plastic to this site is enormous, the roads arent capable of handling large trucks let alone large numbers of large trucks. Pedestrians and local traffic will be in danger.
The area is adjacent to housing estates, schools, church and farming land, and is not suitable for smelly plastic manufacturing. A mouse factory is also next door.
The amount of water needed to wash the plastic is also enormous, and is expected to be wasted into an already overloaded sewer system.
The micro plastic particles will escape into the outer atmosphere, I dont believe they can be contained wholly within the manufacturing building.
The smell of hot plastic will annoy the local residents no end, on a 24 x 7 operation.
This is definitely the wrong site for this type of operation.

This is good for our economy

please see attachment

I wish to draw your attention to my attached submission.

Please see submission below. I object strongly to the building of the Plastics Recyling Facility in Moss Vale

I OBJECT TO THIS PROPOSAL FOR THE REASONS STATED IN MY ATTACHMENTS

I, Maree Gail Baxter wish to add an attachment as my submission.

Please refer to the attachment.

I support the establishment of a plastic recycling facility in the industrial area of Moss Vale. Australians should be willing to have facilities like this in their area so that recycling can occur locally and regionally. I would prefer the project received input via rail as there is a railway line nearby. I am pleased the company has lowered the number of truck movements daily and will only use Beaconsfield Road in the initial stages of road construction. I would like the establishment of a Community Consultation Committee as a condition for consent. This would keep local people in the loop and give them an avenue to raise their concerns once the project is begun.