Stolthaven Fuel Terminal - Stage 3

Stolthaven Bulk Fuel Terminal Mayfield - Stage 1 was approved in June 2012 and comprised five diesel or bio diesel tanks and annual throughput of 300ML. It utilised existing ship berthing facilities at M4 and had one truck loading gantry. Subsequent modifications in 2013, 2014 and 2015 quietly nudged the number of tanks to eight then ten with stepped increases in annual throughput up to a total of 1300ML by September 2015. I strongly object to the current proposal (SSD 15_7065) to expand the tank farm footprint hugely and almost triple the number of storage tanks to 27 and the annual throughput of fuel to 3500ML. Of equal concern is the addition of petroleum (three tanks) and jet fuel (one tank) to the site previously storing only diesel, biodiesel or additive.

The proposal to increase the area of the tank farm and raise the height of the largest tanks from 17.6m to 20m plus increasing the number of truck loading gantrys from four to ten plus six off-road parking spaces for idling trucks plus associated marine loading arm plus pipeline, pump and pipe systems plus administration building plus staff amenities and "light" car parking just seems too much and the risks too many. Pipeline failure, fracture or overfill at the site resulting in spillage, jets, mist or evaporation and possible ignition of flammable vapour could result in a catastrophe well in excess of the disaster in Buncefield in 2005. And what assurance can the proponent give as to the soundness and road-worthiness of the various road haulage contractors' vehicles (184 trucks per day) entering and leaving the site via the intersection of Industrial Drive and Ingall Street? An intersection on the boundary of Mayfield East Public School. Petrol particularly is a highly flammable liquid and readily gives off vapour which, being heavier than air, can travel a long way from the spill point. This is of particular concern to me given that Mayfield East Public School and Fronditha Aged Care Facility are just 500m from the proposed expanded tank farm. Also of concern to me is the nearness of Kooragang Nature Reserve, a nationally important wetland adjacent to the site and Hunter River National Park a mere 2.2km to the northeast.

Stolthaven Bulk Fuel Terminal -Stage 3 should not be approved as its scale and operation endanger nearby residential communities. Mayfield, Carrington, Wickham and Tighes Hill have all undergone a change in population in recent years that has seen an increase in the number of families with pre-school and school-age children coming into the suburbs. Schools and childcare centres are full, parks have been improved and playing fields upgraded all creating a vibrant, engaged community. This community as well as business, industry and the area's rail and road infrastructure are all vital for Newcastle's future and renewal. Why put it all at risk? Furthermore, the nearby environmental safe havens are too precious to be put in peril by such a vast and potentially dangerous facility.

Chapter 4.3 of the EIS lists "Project Benefits" many of which relate to improved traffic and transport outcomes such as reduced traffic congestion, fewer vehicle interactions and less emissions but these are mostly relevant to Sydney and the Metropolitan area. The "economic benefits" are not adequately supported by the current or forecast short and medium-term market for fuel in Newcastle and the Upper Hunter. When fully operational the proposed enlarged tank farm will provide just 12 jobs on site.

Instead of stockpiling large quantities of flammable fuel on site then endangering community and environment with 368 truck movements per day and the associated hazards and risks to human health, city facilities and fragile environment, may I suggest that NSW Government and the proponent explore efficient and cost effective distribution from ship to customer by pipeline and rail. The facility is in close proximity to a railway line yet there appears to be no consideration given to the use of rail for distribution.

The proposed expansion of the Stolthaven fuel terminal is inherent with a number of hazards and risks to the local community and environment surrounding the site. Amendments to the proposal should be considered before proceeding with this development to ensure the safety and wellbeing of the local community.

The key concerns related to this proposal include:

- the three-fold expansion of fuel storage - an additional 17 fuel storage tanks, taking the total number to 27, to be constructed increasing fuel storage capacity to triple the current amount
- the storage of excessive amounts of highly flammable liquids
- the increase in road transportation of the fuel in the local area
- in 2015 the Environmental Protection Agency raised concerns in relation to toxic emissions, in particular benzene, should an expansion proceed
- Stolthaven was fined for exceeding storage limits between 2013 and 2014.

The above issues carry the potential for a large-scale disaster and leave little margin for error should something go wrong with the management of facility. Mayfield East Public School and Fronditha Residential Aged Care facility are both within a 1km radius of the Stolthaven site. The safety and wellbeing of these two vulnerable populations along with the local residents in surrounding the area of Mayfield, Mayfield East, Wickham and Tighes Hill should be given priority over the expansion of a commercial operation.

The site is also directly adjacent to the Koorgang Wetlands, a Ramsar site with significant ecological value.

With such significant issues at stake, an alternative solution should be considered. Pipeline or rail transport would surely be more viable and safe solutions worthy of consideration, as opposed to placing lives and local environments at risk.

Given that the proposal is only set to create and additional 12 jobs, the risks of this proposal clearly outweigh the benefits.

Submission Uploaded

Dear Sir / Madam,

Please find, attached our letter supporting this development.

Regards,

Imma Kathir
Project Director
NWEC Pty Ltd

Please refer to attachment for information relating to Support for Stolthaven Mayfield Terminal Facility - Stage 3.

See attached submission document

See attached submission

See attached submission