Regarding the proposed Veolia Woodlawn Advanced Energy Recovery Centre
I am objecting to the above proposal on the following grounds
1. The proposal is described as an “Advanced Energy Recovery Centre”, when it is in fact a waste incinerator which produces a relatively small amount of electrical power. I will expand on this point and show it is not accurately described.
2. The proposal is said to support the move to a “circular economy”, when in reality the burning of waste is not a long term solution and is likely to present an obstacle to the process of creating a circular economy involving the reuse and recycling of waste material.
3. There is only a vague reference to training in the EIS. The competence of the staff is of paramount importance as nearly all industrial incidents have at least part of their root cause the lack of competence of employees and inadequate management systems.
Section 1
The proposal is described as an “Advanced Energy Recovery Centre” when in reality it is an incinerator whose main purpose is to extend the life of the landfill facility by diverting around 1/3 of the waste which originated in Sydney to be burnt instead of landfill. The project is designed to thermally treat up to 380,000 tpa of residual solid waste and in return generate approximately 30MW of electrical energy. The project also claims that the export of electricity to the grid is considered to be a “GHG” offset. The project is said to save around 252,022t CO2 Eq GHG emissions per annum by incinerating waste and generating electricity in the ARC. The project is said to produce 71,828t CO2 Eq emissions and the argument is advanced that this only 0.01% of national emissions and 0.05% of NSW emissions. They state that GHG emissions intensity of electricity generated by the project is 0.64 Kg CO2 per KWh, and this lower than the NSW grid value of 0.85 kg CO2 per KWh. Using these figures for a full year I calculate 168,192 tonnes of carbon are released to the atmosphere by the ARC.
NB. Wind energy produces around 0.011 Kg of CO2 per KWh. So for 30MW we would have only 2,890 tonnes of carbon released, a factor of 1/58!
NB. NSW government is committed to a 50% reduction in emissions by 2030 and the largest coal mine in NSW will close by 2030 (source NSW Climate and Energy Action); indeed the Eraring coal fired power station (2800 MW) is also due to close in 2025.(source Chris Briggs University of Technology Sydney). Hence its not relevant to use coal fired generation as a comparison for this project, and as the projected life of the ARC is 25 years clearly this plant will be highly inefficient compared with the latest renewable power sources coming on line within a decade. This is in my opinion misrepresentation.
Furthermore there is some confusion in the rating of the electrical generator: parts of the appendix state 240,000 MWh, while the design output is 28.42 MW (not 30 MW). Appendix R on life cycle analysis states that “ Accounting for parasitic loss, the exportable electricity is expected to be up to 219,830 MWh, using this figure the power actually available to export is a maximum of 25.1 MW (based on a 24/365 year).
- Allowing for maintenance and annual shutdowns what is the likely lower figure?
Appendix R states that the proposed residual MSW and C&I waste based electricity production system has lower environmental impact than electricity production from coal, and biomass for all impact categories. They also state that the ARC will produce electricity with a lower environmental impact than natural gas except with regard to acidification.
The Appendix R makes the statement that there is avoidance of biogenic methane arising from the decomposition of MSW and C&I waste as this is diverted from landfill to the ARC.
- Is this the 6.12E+02 Kg CO2 equivalent referred to in table 10?
The Appendix R states that the annual savings are up to 395,034 tonnes CO2 eq.
- Is this correct or is the amount the lower value of 252,022t CO2 Eq GHG emissions per annum?
Section 2
In ES6 Evaluation of the project the statement is made that the “project meets the objective of the NSW Government to provide an ERF to serve Sydney by the NSW Waste and Sustainable Materials Strategy 2041 (DPIE 2021a) and will support the circular economy and the waste hierarchy by diverting some 380,000 tpa to landfill”. I disagree with this assertion for a number of reasons, which I will enumerate now.
1. According to the US EPA (epa.gov/recyclingstrategy/what-circular-economy) a circular economy is important because it is part of the strategy for slowing climate change. Clearly burning waste and adding CO2 eq emissions is not compatible with actions taken to mitigate the negative effects of climate change. The US EPA also makes the point that when a circular economy is properly designed and applied in a thoughtful and inclusive manner it has the potential to protect the environment, improve economics and elevate social justice. The community of Tarago and surrounding area are not being treated fairly with regard to social justice in the proposal for this incinerator, euphemistically described as a Waste to Energy Plant. The US EPA state that the aim of the circular economy is “Safe jobs and healthy communities are the goals”. The release of toxic material into the atmosphere poses a physical threat to the health of the community by inhalation or ingesting through contaminated food. Suspecting that the air, water or food grown locally is contaminated could have an impact on mental health in the area,
2. The NSW Government has published the NSW Waste and Sustainable Materials Strategy 2041 Stage 1 plan 2021-2027 in June 2021 which outlines how over the next SIX years they intend to move the state to a circular economy. The strategy is linked to the NSW Net Zero Plan Stage 1 2020-2030. The intention behind this legislation being to reduce waste and emissions. Accompanying this legislation is the NSW Plastics Action Plan which has been developed to address all stages of plastics life cycle.

- As plastic waste is considered to be part of the incinerator feedstock surely if the circular economy approach is to be deemed successful in the next decade we should be aiming for a greatly reduced tonnage of plastic waste going to waste?

Indeed, the NSW Plastics Action Plan states that there should be an accelerated transition to better plastic products and a ban on plastics which are problematic or unnecessary. As previously stated the EIS states that incinerating waste supports the circular economy, as I have shown this is not the case because the need for incinerator feedstock will be a disincentive to reprocessing and recycling waste. See Zero Waste Europe: The hidden costs of incineration: the case of Madeira and Azores Case Study January 2019 https://zerowasteeurope.eu/downloads/the-hidden-costs-of- incineration-the-case-of-madeira-and-azores/ This case study found that recycling of domestic waste was almost non-existent as the local council struggled to meet the demands for feedstock of the incinerator. Also https://www.wastedive.com/news/wheelabrator-baltimore-lawsuit-contract-dispute/552762/ where the waste handling company is suing Baltimore County USA for $32 million for failing to fulfil the contract for the supply of suitable waste.

- Presumably there would be some contractual obligation for customers to supply sufficient suitable waste and failure to do so would result in sizeable financial compensation?
Section 3
The issue of training of staff at the ARC is only briefly mentioned i.e
“It is considered that the Veolia’s ARC project will provide long-term livelihood benefits from ongoing and increased employment, community investment and involvement, and training and apprenticeship opportunities.”
Employee competence is of paramount importance in the operation of any industrial plant and associated equipment. Competence can be defined as “possessing the skills and underpinning knowledge to carry out the duties required by their employment, safely, effectively and efficiently”. The various tasks and duties to run the plant properly should be defined within Standard Operating Procedures (SOP) for each part of the plant and these must in turn be used to define the competencies of the employees to operate that plant or item of equipment. Errors of judgement and other Human Factors which can lead to serious incidents are almost always due to poor training and ineffective management systems. Whenever a new procedure is introduced involving a change in the SOP then it is essential that this is the subject of a properly executed change management procedure which ensures all employees are aware of the changes made and it is properly documented.
- What is Veolia doing about ensuring Human Factors is properly addressed and that staff will receive regular refresher training and reassessment of competencies?

There are many tragic examples of incidents which can be shown to have as their root cause human error or human factors.

- Will Veolia instigate a rigorous root cause analysis of all “near miss incidents” as well as accidents? Will these be transparent and available to the public? Will all Lost Time injuries be posted publicly?

As the famous quality management guru Dr W Edwards Deming stated in his 14 Points for Management, No8 “Drive out fear, so that everyone may work effectively for the company”. An example of an explosion and fire in an incineration plant can be found on the French government site ARIA No 45433 02/07/2014 in Clermont-Ferrand. Another example of Human Factors is that of a fire and explosion at a fuel storage depot at Buncefield, England 11/12/2005, when operators relied on the readings on their monitoring equipment although experience and observation should have warned them there was a problem. Forty people were injured. www.hse.gov.uk/comah/buncefield/

At its meeting on 24 November 2022 Yass Valley Council resolved to object to the Woodlawn Advanced Recovery Centre Tarago, Waste to Energy (incinerator) affirming the following:
• Council maintains its strong objection to the proposal in support of the surrounding region’s communities
• Council restates its call for an urgent review of the State Government’s Energy from Waste Infrastructure Plan before specific proposals are determined

I very strongly object to Veolia's proposal to build an incinerator in Tarago. I am a Bungendore resident and feel that our area will be seriously impacted by pollution from this enviromentally disastrous proposal.
The benefits for the residents of the large area that will be affected by the toxic waste are zero but the negative impacts on health and wellbeing are enormous.
Why is it considered ok to build this toxic incinerator in Tarago when they are banned in Sydney ?
The amount of power produced will be miniscule compared to the massive amount of pollution produced.
How can this toxic greenhouse gas producing disaster be justified when the government is supposed to be aiming for zero emissions ?
In closing I repeat my objection to this shortsighted, disastrous,toxic proposal.

I don’t want Sydney’s rubbish being burnt in our beautiful region and causing unknown irreparable damage to our local environment, farms and precious surrounding wilderness. I have 3 children and I don’t want their futures ruined because of these money making projects for some rich people in the city. It’s insulting that you think you can unload & burn your waste in our country towns polluting them with forever chemicals ruining our farms and our precious national parks!!!!! I am truly disgusted that this would even be considered particularly after one was rejected in the vicinity of Sydney due to the danger it posed. Why is it ok to put one here, destroying our region when it wasn’t it ok in Sydney? It’s not ok. This just shows me how little the NSW government and the corporations that donate to it, think of our country towns & its people. I completely reject and object to this terrible waste incinerator!!! Stop destroying our environment for profit!!!!

Please see the attached submission.

I live in Goulburn and work 15km from Tarago. I strongly object to Veolia’s proposed incinerator being built in Tarago.

I believe that Veolia’s toxic industrial waste incinerator will cause pollution toxic to humans and livestock in the area for our generation and future generations.

There are many reasons for my objection, such as:

• The proposal will create 2.2million tonnes of toxic waste ash, including 380,000 tonnes of air pollution control residue (fly ash) which is classified as hazardous waste by the Environmental Protection Authority (EPA). All of this will be dumped on site, risking further contamination of soil and groundwater as well as the Sydney water catchment.
Veolia’s track record of polluting local groundwater (recognised by EPA prevention notice in October 2022) proves they cannot be trusted to safely manage such toxic outputs.

• This incinerator will impact the health of our children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment. It is an intergenerational burden and legacy which cannot be allowed to go ahead.

• In July 2018, the Eastern Creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission as not being in the public interest. The reasons included 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. Since then, 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 back in 2018 – this project must also be rejected - If they aren’t safe for Sydney then they aren’t safe for Tarago.

Please stop the incinerator from going ahead.

Thanks

I am a member of the Tarago Community. I have been living locally for several years. I have had to put up with the stench from the bioreactor for the entire time that I have lived here. Veolia are not good neighbours and have repeatedly lied to the community and refused to comply with their licence conditions.
There are many reasons that I object to the proposed incinerator, I have listed some of them below:
This incinerator will impact the health of our children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment. It is an intergenerational burden and legacy which cannot be allowed to go ahead.
The proposal has already caused significant detrimental negative impact to surrounding communities’ mental health by increasing anxiety and depression. This will only be increased if the project goes ahead as those living nearby continue to stress about when their health will start to show the impacts of the pollution from the facility, or having to stay indoors.
The proposal will create 2.2million tonnes of toxic waste ash, including 380,000 tonnes of air pollution control residue (fly ash) which is classified as hazardous waste by the Environmental Protection Authority (EPA). All of this will be dumped on site, risking further contamination of soil and groundwater as well as the Sydney water catchment. Veolia’s track record of polluting local groundwaters (recognised by EPA prevention notice in October 2022) proves they cannot be trusted to safely manage such toxic outputs.
I note that in 2018 the NSW Planning Department refused an incinerator in Sydney. All of the reasons that were stated as to why that incinerator was not appropriate apply equally if not more to the proposed incinerator in Tarago. Tarago and surrounds are environmentally sensitive areas and the locals rely on tank water for their everyday lives. If an incinerator isnt safe enough for Sydney its not safe enough for Tarago.

I am a Tarago local and I have lived here for over twenty years. I strongly object to the proposed incinerator for the following reasons:
Food contaminated by incinerator toxins can cause cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and respiratory impairment.
Veolia’s incinerator proposal will emit toxic air pollution 24 hours a day, 365 days a year for 25 years, which will spread throughout the region from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and more.
The proposed incinerator will exceed NSW government safety standards for air emissions during start-up, shut-down and many other ‘non-standard’ operating conditions. Veolia’s overseas incinerators often exceed safety standards and Veolia has a track record locally for failing to comply with license conditions at their existing Woodlawn facility.
This incinerator will impact the health of our children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment. It is an intergenerational burden and legacy which cannot be allowed to go ahead.

I have read and listened to all propaganda provided in Veolias submission regarding how safe this proposed ARC is to the environment and human health and I remain totally unconvinced as to its suitability to its proposed location. The location is entirely based on convenience (easy access to the rubbish) and financial considerations. Veolia's current operations at Woodlawn have already breached safety guidelines on numerous occasions to the detriment of local residents. Yet Veolia expect people residing closeby to trust them to provide truthful predictions as to the levels of proposed pollutants emitted from this facility. For these reasons I am totally opposed to this development.