Woodlawn Advanced Energy Recovery Centre

Today in Gundaroo we can already smell the sulphuric odour of decaying waste in the right wind conditions. This project jeopardises the integrity of our farmland, our health and our land values.
The organic methods we apply to raising our sheep are a wasted effort when toxins contaminate the soil that they graze on. Why should so many endure the fallout of a expanded facility for so little gain to the area in terms of jobs?
Once again this is big business putting profits before community health and safety.

I am extremely concerned about the proposed Veolia incinerator planned for Tarago. I live in Canberra and I am concerned about the toxic gases and particulates that will be belched into the air, 24/7 for the next 25 years if this gets the green light. They will not only be in the air, but will also end up in the soil and water, leading to unwanted, toxic impacts for agriculture across the surrounding region. This level of toxic ash pollution will also impact people’s health. We DO NOT WANT THIS INCINERATOR in our region!!!

Canberra, and the surrounding region, is known for its clean air, vineyards, truffle farms and sheep properties. I strongly OBJECT to the imposition of such an incinerator on our region.

Think outside the square and come up with a proper environmentally-friendly solution to Sydney’s waste. Don’t just burn it and cause the Canberra region to be significantly damaged.

Following a review of the Environmental Impact Statement (EIS) prepared by EMM for Veolia Environmental Services (Australia) the following key concerns have been identified that relate to the operation of the proposed Woodlawn Advanced Recovery Centre.
Groundwater impact assessment:
EIS Appendix U Groundwater impact assessment (EMM) states Veolia has adopted several leading practices to produce a project design that avoids and minimises impacts to water assets, however it is unclear what these leading practices are as the mitigation measures identified as no more than business as usual.
The assessment reviews the Willeroo borefields as a potential source of operational water. The report includes a field assessment which determines:
• A pumping rate of 9.7 L/s for up to 14 days continuous pumping is estimated to be the safe yield for GW042931 - Bore 3 (operating in isolation of other production bores). The pumping test analysis indicates that the current pumping rate of approximately 15 L/s is not sustainable, as after approximately 16 hours groundwater level is predicted to reach the pump intake;
• safe yield of 15 L/s cannot be maintained long term and hence only the early drawdown data was used to predict the safe yield of this production bore
• The predicted drawdown following 25 years of cyclic operation of the borefield (at 600 ML/yr) is shown in Figure 8.4. The water table drawdown is predicted to extend the width of the deep aquifer palaeochannel. Potential drawdown impacts at third party bores, which are a minimum 750 m away, are highly unlikely as pumping is not expected to be continuous for the 25 year period.
The assessment fails to outline the alternate source of water as a result of not achieving the 15L/s from the Willeroo borefields that is required during operation. If the water supply is not available or volumes are not sufficient, what is the impact on operations at the facility or where will this shortfall in water be supplied from.
What is the impact on groundwater dependent ecosystems from the continual drawdown of groundwater? This impact has not been assessed sufficiently.
The Groundwater Assessment identifies during drought conditions the facility will require a significant increase in groundwater use. The cumulative impact of this increase in groundwater use has not been assessed and consideration of local users has not been discussed, other than to state Veolia has a Licence and proposes to use the water with no regard to local or environmental constraints.

Air Quality Impact Assessment:
The EIS Appendix O Air Quality assessment confirms that under all three scenarios modelled, the local air quality will be adversely impacted due to an increase in emissions (excluding as a result of a bushfire). The assessment referenced a similar project in the UK using only one year of data from 2017 and showed where non-conformance against NSW EPA criteria would occur due to incorrect feedstock inputs. The assessment determines this to be an anomaly and an error, however, what engineering controls have been designed into the Woodlawn system to eliminate such issues occurring. While real-time monitoring will detect any exceedance, the air quality will be impacted as a result of the emissions entering the atmosphere and the real-time monitoring is reactive rather than a pro-active measure and does not prevent incidents from occurring.

Capability of Veolia to meet NSW EPA criteria and comply with DPE SDD conditions of approval:

Veolia has failed consistently to comply with both of its Environment Protection Licences (EPL) (No. 11455 CRISPS CREEK INTERMODAL FACILITY; and No. 11436 WOODLAWN LANDFILL) relevant to the operation of the Woodlawn facility on an ongoing basis and every year since 2017 and 2016 respectively.

In addition to non – compliances with EPL conditions, the EPA issued Veolia with a S. 96 Prevention Notice on 26 October 2022 as a consequence of not managing leachate water. The impact of this has the potential to result in groundwater and surface water contamination of off-site sources located at Crisps Creek and Lake Bathurst.

This Prevention Notice issued by EPA demonstrates that Veolia is not managing the environmental aspects of the site in a competent manner. The EIS Appendix V – Surface Water Impact Assessment states all water will be contained on site due to the level of contaminants (e.g. acid mine drainage etc) with no off-site discharge required, therefore no offsite impacts proposed. This statement is not consistent with the actual operational activities occurring on site currently.

In addition to the Veolia operations at Woodlawn, more widely, Veolia demonstrates ineffective systems to manage governance and environmental requirements. This is demonstrated through Veolia agreeing to an enforceable undertaking and agreeing to pay $590,000 as a result of its Horsely Park Waste Management Facility not managing asbestos appropriately (https://www.epa.nsw.gov.au/news/media-releases/2022/epamedia221007-$590000-financial-undertaking-secured-after-asbestos-find)

This demonstrates that while criteria and controls can be required for the operation of the Woodlawn facility, including the provision of monitoring data, it appears unlikely that Veolia will meet these requirements and the local community and environment will be impacted.

I object to the proposed incinerator (Advanced Energy Recovery Centre – ARC) being built near Tarago by Veolia. I oppose any such waste incinerators being built anywhere, but as a resident of Currawang NSW which is part of the region this proposal particularly concerns me.

Such “Waste-to-energy” or “Energy-from-Waste” incinerators have been referred to as regrets-based solution to our current waste and energy issues. It is short sighted in terms of being a bandaid solution that might help address some issues in the short-term, but doesn’t actually address any of the systemic problems that are causing these issues in the first place, and actually makes things worse in the long term.

I’m embarrassed that Australia isn’t rapidly moving towards a circular economy to avoid waste products, as well as improving our capability to recycle materials here at a speed to keep up with the rate that materials are being used and discarded. I am concerned that the proposed incinerator will detract from the greater goal of moving rapidly towards a circular economy, and that investing in such a facility will be locking in 3 decades of future carbon emissions and many environmental risks.

There are many academic and government bodies that recognise the potential environmental pollution from waste incinerators. Even the NSW Government has acknowledged in its own Energy from Waste Infrastructure Plan that waste incinerators impact human health stating “Populations can still experience health impacts when emissions are below the national standards, and for some common air pollutants, there is no safe threshold of impact”.

I’m sure Veolia do some good work, but unfortunately their operations at Woodlawn have had ongoing issues with foul odours over many years. At times we have suffered from a foul-smelling stench at our place some 15km away from the site, that has a sulphurous nostril burning sensation to it. This is hugely concerning as there are obviously large quantities of greenhouse gases and potentially other pollutants escaping from the facility. Veolia are not generally trusted to be able to manage a facility to government and EPA conditions by the broader community of the region. Veolia don’t have community acceptance to operate an incinerator at Woodlawn.

Please don’t proceed with any “Waste-to-energy” or “Energy-from-Waste” incinerators in the Tarago area, or indeed anywhere. We can and all should be looking to rapidly move to a waste hierarchy that sees waste reduction, reuse and recycling of materials taking precedence over energy recovery applications, and their associated environmental pollution and risks.

I live in nearby Mount Fairy and strongly object to Veolia’s proposed incinerator being built at Woodlawn near Tarago.
I believe that Veolia’s toxic industrial waste incinerator will:
1) negatively impact property values within the area
2) cause illness amongst locals who depend on harvested rain water for household useage, and also who grow fruit/vegetables for local consumption
3) cause illness to people who purchase products grown in the affected area
4) cause illness to animals/livestock which depends on local water sources and grazing due to the build up of toxins in the soil & water
5) create fear and angst in the local community
The main reason for my objection is:
If the NSW Government banned toxic waste incinerators in Sydney due to the risk to human health, then they simply should not be allowed to operate anywhere in the vicinity of any populations or food production areas.
If it’s not safe for Sydney, it isn’t safe anywhere
I personally rely on harvested rain water and locally grown vegetables for consumption. I also occasionally sell excess vegetables through local markets to supplement my income.
I am deeply concerned that the toxic air pollution which Veolia’s proposed incinerator will emit..... constantly for 25 years........ may affect my water supply(which is rooftop collection) the runoff into my dams (which I use to grow vegetables) and impact the health of my livestock due to the accumulation of toxins in the soil.
I am also concerned for the greater communities which include Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and beyond which have been identified as being within the toxic incinerators “plume”.
Why should we be considered second class citizens to Sydney?
The risk to human health outlined by the NSW Independent Planning Commission following the rejection of the Eastern Creek waste Incinerator in 2018 including:
- concerns about safety,
- insufficient evidence that the pollution control technologies would be capable of managing emissions,
- concern about the relationship between air quality impacts and water quality impacts,
- the possibility of adverse environmental outcomes, and
- concern about site suitability and human health impacts.
should be considered relevant to the proposed Woodlawn incinerator proposal.
Nothing is different. The EPA has evidence of Woodlawn failing to meet emission requirements with it’s existing Bioreactor.
Air pollution from the proposed incinerator includes acid gases, toxic heavy metal particulates (including cadmium, lead & mercury) and persistent organic particulates (such as PFAS, dioxins, furans, PCBs). I am deeply concerned that this air pollution will be blanketed across the neighbouring region, which can cause serious illness such as cancers and decreased lung function, and also accumulate in the surrounding environment over time in soil and water, to be absorbed by plants, crops and animals.
I do not wish to be concerned about breathing the air where I live, drinking the water and eating my crops.
I understand that the NSW Energy from Waste Policy states that incinerator proposals are only valid where “community acceptance to operate such a process has been obtained”. There is no community acceptance for a toxic waste facility at Woodlawn near Tarago.

Received via post 6/12/22

My name is Hannah Davey and I am a resident of Goulburn. I am writing this as I strongly object to Veolia's proposed incinerator being built in Tarago. Below is a discussion of my major concerns with the proposed waste incinerator.

Veolia’s proposed incinerator has detrimental consequences for Tarago, the surrounding areas and even Sydney as it is toxic to both our health and environment. The pollution from this incinerator (2.2 million tonnes of contaminated ash) will negatively impact air quality, water quality, agriculture and health in the area. This is because it will include acid gases, toxic heavy metal particulates and persistent organic particulates. This large amount and composition of this pollution classifies it as hazardous waste by the Environmental Protection Authority. This waste will be absorbed into soil and water and consumed by plants, crops and animals. Thus negatively impacting the agricultural industry in the area and people who consume the food from this area may be susceptible to cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and respiratory impairment.

Veolia has a track record of polluting local groundwaters and thus there is a high probability that they will not be able to safely manage the toxic outputs and as a result the Sydney water catchment will likely be impacted. Thus the incinerator will also negatively impact the health of those living in Sydney through the negatively affected water quality.

Furthermore I believe that if this waste incinerator is not deemed safe for Sydney, it is not safe anywhere. In July 2018, the Eastern creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission because of concerns about safety, insufficient evidence that the pollution control technologies would be capable of managing emissions, concern about the relationship between air quality impacts and water quality impacts, the possibility of adverse environmental outcomes, and concern about site suitability and human health impacts. The NSW Government has banned toxic waste incinerators in Sydney due to the risk to human health. The risks have not changed since that decision in 2018. Therefore this project must also be rejected as if they aren’t safe for Sydney then they aren’t safe for Tarago.

Therefore, the proposed waste incinerator should not be built, it will cause no good only harm for the regions from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and even Sydney.

I strongly object to the Veolia’s incinerator proposal. The ACT banned these incinerators as well as Sydney for health and environmental reasons so why is this proposal even being considered for another rural area. Yes, the Veolia is zoned as Industrial land but what about the near surrounding rural areas where people and animals need to live who will all be adversely affected by this proposal if it goes ahead. The effects of such a proposal will go further than the nearby surrounding areas given the widespread toxic ash that will be spread by such hazardous measures to deal with waste. If Veolia admits that the incinerator will exceed the NSW Government safety standards, how can it be allowed to go ahead? The toxic fly ash will have ever lasting and detrimental effects on our environment and our community through contamination of our food and water supplies. YOU MUST NOT LET SUCH A PROPOSAL GO AHEAD!

See attachment below

To whom it may concern,
I am an NSW resident and I strongly OPPOSE the Woodlawn Advanced Energy Recovery Centre proposal. The pollution this will create with the ash will cause death, cancer, compromised immune etc etc in so much of our Wildlife, Birds, Fish, farm stock etc.. let alone the impact it has on us humans. The toxins which they produce will accumulate in the soil and contaminate our water. The fallout will also settle on our house roofs and go into our drinking water.
These toxic incinerators CANNOT go ahead as there will be a great negative irreversible health, social and financial impact on our community.
We need to be reducing toxic pollution, not adding to the problem. Veolia’s financial gain will greatly negatively impact so many parts of our lives, health and safety.
Yours Sincerely
Janelle Goodridge

This project is a risk to public health on many levels. Toxic air pollution, Veolia has already admitted that the incinerator will exceed NSW Government safety standards. Persistent Organic Pollutants will leach into aquifers and poison springs, bores, creeks and rivers, lakes and dams throughout the Sydney catchment area. The air and water pollution will then contaminate food production and ultimately contribute to cancers, miscarriages and many other conditions. The emissions also will contribute to Climate Change which also adversely impacts Public Health.

I totally object to the Incinerator because that’s what it is. What about the carbon foootprint from transporting fromSydney to Tarago if they were serious about being carbon neutral why don’t they built it closer to the source. We drink tank water how safe will that be.
We have agriculture they also eat the grass and drink the water seriously who will buy my produce when contaminated. We are also part of the Sydney catchment do resident from that area know what’s going on. What is their management plan if a derailment was to happen. They have demonstrated that they can’t be trusted
regarding the smell that leaches from their plant so how can we trust them to let us know in real time if any incident happens regarding this proposed waste to energy Plant better known as an INCINERATOR.

Environment disaster, lots of people in the area would be affected is something goes wrong as it always does. Wind direction waste landing on roofs of houses that would end up in drinking water. Farming and grazing disaster, will there be any more traffic to these very run down roads

Seems pretty stupid to build a massive polluting project that could adversely affect a multi million dollar wine industry in Canberra, Bungendore and Collector. Not to mention impacts to tourism to those regions when people know there's an incinerator in the area that could affect their health. How can you ensure the long term health impacts of surrounding residents? It's also in the flight path of planes flying in and out of Canberra

I want to object to this project on environmental grounds. I think that adding an incinerator to the existing landfill site will add a lot of unnecessary air pollution to the surrounding rural area as well as to the ACT. This is likely to increase the burden on people who have any kind of lung conditions, including children with asthma. In addition, the incinerator will create tons and tons of toxic ash that will need to be disposed of. The incinerator will also generate tons of C02 emissions. All of this is contrary to NSW stated direction of decreasing C02 emissions and decreasing the burden of industrial wastes. I also think it is profoundly unfair to further burden Tarago and surrounding communities with the dust, noise, pollution and other negative effects of expanding Woodlawn's operations to include waste incineration -- despite the project's clever title which makes it look like an energy project rather than a waste disposal project. The pollution will have a negative impact on surrounding agricultural produce as well as on the quality of life of the residents. Last but not least, this type of incinerator was rejected for the Sydney area (as it should have been). If it's not considered to be safe for Sydneysiders, why should rural people have to put up with it? Out of sight, out of mind is not the right answer. The NSW government should be finding new ways to reduce waste and recycle what's left. This is the wrong project in the wrong place -- it should not go ahead.

Being so close to the Canberra wine district, which was massively impacted recently by bushfires and how smoke sat over the region and affected the entire 2020 vintage, I strongly oppose to this project being built.

I have serious concerns about the health impacts of such a facility so close to rapidly growing regional areas.

I do not support this proposal in any way.

Major concerns over the Air Quality produced from the proposed Woodlawn ARC during operations and especially during time of maintenance/repairs when Air Quality will be compromised and not monitored.
Please consider the relocation of this Project.

This project is DANGEROUS.

Woodlawn incinerator will impact the air I breathe and the land I live on. Veolia have a poor record of controlling the escape of pollutants. If incinerators are safe then burn the rubbish at the source- Sydney. If it is not safe in Sydney it is not safe here. Kurnell is a more appropriate site, it has polluted industrial sites, proximity to the rubbish and prevailing offshore winds. Our community will not accept you dumping your rubbish on us.