Name Withheld
Object
Name Withheld
Object
Balgowlah Heights
,
New South Wales
Message
The remediation of the Hydro aluminium land should reduce the mass of waste going to landfill and/ or onsite encapsulation (which has the effect of reserving land as a waste repository) for future generations, when there are resource recovery options available and preferred by NSW Waste. Allowing Hydro to bury SPL waste containing other unknown fill substances sets a precedent for other interests to resist resource recovery initiates set by NSW Waste to reduce waste going to landfills whether managed onsite or off-site. Hydro land could become a valuable asset for other important uses that NSW needs to have available without it being designated as restricted use due to legacy chemical contamination.
kurri autos
Comment
kurri autos
Comment
main rd heddon great
,
New South Wales
Message
* COMMENT - much of the application is based on assumptions and minimal / no modelling has been undertaken. For such an application which is proximal to current and future residential developments and the endangered ecological community - the Kurri Sand Swamp Woodland, the application is inappropriate;
* COMMENT - section 5.3 of the EIS refers to the remediation of the former BHP, Pasminco and Sydney Olympic Park sites and contends that these projects did not require containment cells and as such require leachate recovery systems as a control measure as opposed to a contingency which the application contends is the case for the proposal. It should be acknowledged that these projects are not located as close to residential dwellings as the Hydro site and these were planned 5-20 years ago. Social and environmental expectations have increased during this time and as a consequence the applicant should treat the contaminated material as opposed to cap and forget;
* COMMENT - the application notes that the immediate area surrounding the containment cell is proposed to be rezoned industrial. As a consequence, contaminated sites are generally more acceptable within these locations. The applicant contends that the rezoning to industrial will result in positive contributions to the social fabric of the immediate community. The applicant should note that a vast amount of industrial land is available ~ 5km in the Hunter Economic Zone where transferral of environmental liabilities associated with Hydro will not be assumed by the purchaser. QUESTION - who will be responsible for the environmental liabilities if Hydro fail to sell the land? What will happen if the rezoning is not approved?
* COMMENT - the application appears to be the cheap method of dealing with the issue. Other options such as high temperature treatment are feasible and will not result in environmental degradation being transferred to future generations. The application appears to be the quickest and cheapest way for Hydro to turn their back on the site and the mess they have created;
* QUESTION - why is much of the information and data only preliminary such as the associated visual impact, the quantity of material to be disposed of within the containment cell? COMMENT - as a neighbouring landholder definitive data and impacts is required for me to give a valid and comprehensive submission;
* QUESTION - the applicant has noted that a public platform may be established for those interested to view the demolition. Furthermore, the blast exclusion zone would be set at 1.5 times the height of the structure to be demolished. The applicant also notes that some dangerous waste may not be possible to be recovered from buildings / stacks prior to demolition due to safety / access issues. Has the applicant not considered the potential for airborne asbestos fibres / heavy metals migrating to the viewing platform and subsequently having adverse health impacts on those watching?
* QUESTION - there is a growing trend of high temperature treatment of asbestos, for example Germany receives a considerable volume of asbestos and treats via incineration. Has the applicant not considered this option for asbestos?
* QUESTION - if there are a number of firms who purchase proposed industrial lands (all of equal area and value), who inherits the environmental liabilities such as maintenance of the water treatment plant and performing environmental monitoring? Moreover, if this firm is a small business and widespread failure of the containment cell occurs, who will be responsible for remediation / decontamination? What happens if this forces the firm into receivership? Will Hydro establish a fund for potential failure of the containment cell?
* QUESTION - will groundwater monitoring bores be established within proximity of the containment cell to ensure no impact on groundwater networks?
* QUESTION - if the HDPE liner (still to be confirmed by the applicant) fails, what methods of detection are in place and what actions would be taken to remediate the issue?
* QUESTION - no details are provided for the water treatment plant. Who maintains the plant? What method of treatment would the plant offer? Is reverse osmosis considered? Following treatment, where will the brine be disposed of? Have Hydro determined appropriate disposal methods rather than assumed? Will water be pumped to the North Dam for irrigation?
* QUESTION - North Dam is viewed as an evaporative pond. What fail safe measures will be implemented to ensure this dam does not overtop and discharge into the surrounding environment? Who will ensure the dam does not silt and minimise storage capacity?
* QUESTION - no methods of decommissioning are discussed in the application. Once the containment cell is sealed, will earthmoving equipment be decontaminated? If so, where will the runoff be directed? How will the runoff be treated?
* QUESTION - the applicant assumes clay on site will be capable of sealing the containment cell. It has been described as dispersive on adjacent developments. What modelling has been completed to assess the clay on site? Where will clay be sourced if it is not suitable on site? If clay is sourced from site, what will be done with the void created by sourcing this material?
* QUESTION - an assessment regarding transferring spent pot lining to other sites is currently detailed as ongoing by the EIS. If the result of the assessment is unfavourable for transferral, will this material also be included in the containment cell?
* COMMENT - Section 1.4 notes that Hydro is committed to managing environmental legacies. Hydro should not be managing environmental legacies but rather resolve these issues. The application appears to be remediation where decontamination should be undertaken through high temperature treatment to deal with the issue rather than cover up. When were initial high temperature treatment trials undertaken?
* QUESTION - Table 5.4 justifies high temperature treatment as a non-viable option due to unknowns associated with whether the material would then be classified as inert or not etc. Why has the applicant not undertaken pilot / small scale experiments to disprove this option? Further table 5.6 notes that high temperature treatment on site is not time or cost effective without providing any justification. Why has offsite high temperature treatment not been considered if this is technologically sound? If this option is selected, the liability will not be transferred to another party and subsequently future generations;
* QUESTION - Table 5.5 describes the technological risks associated with unproven technology of high temperature treatment where table 5.6 notes onsite high temperature treatment is technologically sound. Please confirm this discrepancy;
* QUESTION - the applicant notes that offsite treatment and or disposal was not considered as this would transfer liabilities elsewhere and result in carbon emissions associated with transportation which would not be in line with Hydro's vision. Has the applicant not considered the emissions that will be produced through earthmoving and excavation for the creation of the containment cell or the fugitive emissions to be emitted for generations and discharged through the gas vents?
* QUESTION - Section 6.2 details Hydro's corporate social responsibility, with a positive social legacy by providing ongoing social, employment and economic opportunities. How do these values align with transferring adverse environmental legacies which have been `covered up' to future generations? This is a prime example of intergenerational inequality;
* QUESTION - the EIS notes that aluminium by products may emit flammable and harmful emissions when coming in contact with water. What controls will be in place to ensure human exposure prevented and bushfire risk eliminated?
* QUESTION - Section 8.83 notes that vegetation cover of the containment cell will be shallow rooted native grasses as these grasses will not adversely impact the capping layers (ie roots put pressure on the HDPE liner). What methods will be implemented to prevent growth of tree species? Moreover, the EIS notes that the containment cell will be designed to be water shedding to prevent infiltration and potential generation of leachate. In the case of high rainfall, will the grass species have the capacity to retain / deal with this water or would this water migrate to the liner? Moreover, in periods of drought and then followed by high rainfall (as predicted with climate change), with the lack of significant tree species, erosional risk is high when native grasses may die off. Have Trigger Action Response Plans (TARPs) been developed to deal with grass die off, high rainfall (which has been experienced in the past two years) and increased erosion?
* QUESTION - as described above, has climate change been assessed when determining the adequacy of the containment cell?
* QUESTION - table 8.2 provides an overview of the expected timeframes. Moreover, the EIS notes sediment and erosion controls such as hay bales and sedimentation fences will be implemented throughout the period of works. What control measures will be implemented to ensure contaminated material (located in the containment cell, stockpile area etc) is not transported during periods of high rainfall or drought? Will stockpiles be misted to minimise dust generation? Sedimentation fences will not contain heavy metal accumulations within sediment runoff;
* QUESTION - the EIS has noted a number of monitoring commitments to be undertaken quarterly, annually and following certain rainfall events. Why has telemetry not been considered? Telemetry should at a minimum be installed in containment dams etc to warn of nearing levels of overtopping. Telemetry would also be a safe measurement of gas emissions. If environmental monitoring is subcontracted out, what assurances are in place to ensure monitoring is implemented immediately after high rainfall events? What is the response time (for example, maintaining the water treatment plant, implementing sediment and erosion control measures etc) for implementing environmental controls as required?
* COMMENT - Section 9.4.2 and table 9.9.1 clearly demonstrates Hydro's motivations of converting the site into a mildly remediated site to then transfer onto another party and remove any future financial obligations. The application appears to be the bare minimum for dealing with a direction from the EPA to clean up and also make the site appealing to divest. If Hydro was serious about decontaminating the site, a high treatment method would be implemented, however this will impact Hydro's bottom line more considerably. The cell should not be developed as if it fails and the transferee does not have the financial capability of amending, the liability will be left to the NSW taxpayer. IF this cell is to be approved, Hydro at minimum should provide financial sureties as they are the ones who benefitted from the creation of this adverse environmental legacy;
* QUESTION - have soil samples, surface and groundwater samples been taken to ensure offsite migration has not occurred?
* COMMENT - section 5.3 of the EIS refers to the remediation of the former BHP, Pasminco and Sydney Olympic Park sites and contends that these projects did not require containment cells and as such require leachate recovery systems as a control measure as opposed to a contingency which the application contends is the case for the proposal. It should be acknowledged that these projects are not located as close to residential dwellings as the Hydro site and these were planned 5-20 years ago. Social and environmental expectations have increased during this time and as a consequence the applicant should treat the contaminated material as opposed to cap and forget;
* COMMENT - the application notes that the immediate area surrounding the containment cell is proposed to be rezoned industrial. As a consequence, contaminated sites are generally more acceptable within these locations. The applicant contends that the rezoning to industrial will result in positive contributions to the social fabric of the immediate community. The applicant should note that a vast amount of industrial land is available ~ 5km in the Hunter Economic Zone where transferral of environmental liabilities associated with Hydro will not be assumed by the purchaser. QUESTION - who will be responsible for the environmental liabilities if Hydro fail to sell the land? What will happen if the rezoning is not approved?
* COMMENT - the application appears to be the cheap method of dealing with the issue. Other options such as high temperature treatment are feasible and will not result in environmental degradation being transferred to future generations. The application appears to be the quickest and cheapest way for Hydro to turn their back on the site and the mess they have created;
* QUESTION - why is much of the information and data only preliminary such as the associated visual impact, the quantity of material to be disposed of within the containment cell? COMMENT - as a neighbouring landholder definitive data and impacts is required for me to give a valid and comprehensive submission;
* QUESTION - the applicant has noted that a public platform may be established for those interested to view the demolition. Furthermore, the blast exclusion zone would be set at 1.5 times the height of the structure to be demolished. The applicant also notes that some dangerous waste may not be possible to be recovered from buildings / stacks prior to demolition due to safety / access issues. Has the applicant not considered the potential for airborne asbestos fibres / heavy metals migrating to the viewing platform and subsequently having adverse health impacts on those watching?
* QUESTION - there is a growing trend of high temperature treatment of asbestos, for example Germany receives a considerable volume of asbestos and treats via incineration. Has the applicant not considered this option for asbestos?
* QUESTION - if there are a number of firms who purchase proposed industrial lands (all of equal area and value), who inherits the environmental liabilities such as maintenance of the water treatment plant and performing environmental monitoring? Moreover, if this firm is a small business and widespread failure of the containment cell occurs, who will be responsible for remediation / decontamination? What happens if this forces the firm into receivership? Will Hydro establish a fund for potential failure of the containment cell?
* QUESTION - will groundwater monitoring bores be established within proximity of the containment cell to ensure no impact on groundwater networks?
* QUESTION - if the HDPE liner (still to be confirmed by the applicant) fails, what methods of detection are in place and what actions would be taken to remediate the issue?
* QUESTION - no details are provided for the water treatment plant. Who maintains the plant? What method of treatment would the plant offer? Is reverse osmosis considered? Following treatment, where will the brine be disposed of? Have Hydro determined appropriate disposal methods rather than assumed? Will water be pumped to the North Dam for irrigation?
* QUESTION - North Dam is viewed as an evaporative pond. What fail safe measures will be implemented to ensure this dam does not overtop and discharge into the surrounding environment? Who will ensure the dam does not silt and minimise storage capacity?
* QUESTION - no methods of decommissioning are discussed in the application. Once the containment cell is sealed, will earthmoving equipment be decontaminated? If so, where will the runoff be directed? How will the runoff be treated?
* QUESTION - the applicant assumes clay on site will be capable of sealing the containment cell. It has been described as dispersive on adjacent developments. What modelling has been completed to assess the clay on site? Where will clay be sourced if it is not suitable on site? If clay is sourced from site, what will be done with the void created by sourcing this material?
* QUESTION - an assessment regarding transferring spent pot lining to other sites is currently detailed as ongoing by the EIS. If the result of the assessment is unfavourable for transferral, will this material also be included in the containment cell?
* COMMENT - Section 1.4 notes that Hydro is committed to managing environmental legacies. Hydro should not be managing environmental legacies but rather resolve these issues. The application appears to be remediation where decontamination should be undertaken through high temperature treatment to deal with the issue rather than cover up. When were initial high temperature treatment trials undertaken?
* QUESTION - Table 5.4 justifies high temperature treatment as a non-viable option due to unknowns associated with whether the material would then be classified as inert or not etc. Why has the applicant not undertaken pilot / small scale experiments to disprove this option? Further table 5.6 notes that high temperature treatment on site is not time or cost effective without providing any justification. Why has offsite high temperature treatment not been considered if this is technologically sound? If this option is selected, the liability will not be transferred to another party and subsequently future generations;
* QUESTION - Table 5.5 describes the technological risks associated with unproven technology of high temperature treatment where table 5.6 notes onsite high temperature treatment is technologically sound. Please confirm this discrepancy;
* QUESTION - the applicant notes that offsite treatment and or disposal was not considered as this would transfer liabilities elsewhere and result in carbon emissions associated with transportation which would not be in line with Hydro's vision. Has the applicant not considered the emissions that will be produced through earthmoving and excavation for the creation of the containment cell or the fugitive emissions to be emitted for generations and discharged through the gas vents?
* QUESTION - Section 6.2 details Hydro's corporate social responsibility, with a positive social legacy by providing ongoing social, employment and economic opportunities. How do these values align with transferring adverse environmental legacies which have been `covered up' to future generations? This is a prime example of intergenerational inequality;
* QUESTION - the EIS notes that aluminium by products may emit flammable and harmful emissions when coming in contact with water. What controls will be in place to ensure human exposure prevented and bushfire risk eliminated?
* QUESTION - Section 8.83 notes that vegetation cover of the containment cell will be shallow rooted native grasses as these grasses will not adversely impact the capping layers (ie roots put pressure on the HDPE liner). What methods will be implemented to prevent growth of tree species? Moreover, the EIS notes that the containment cell will be designed to be water shedding to prevent infiltration and potential generation of leachate. In the case of high rainfall, will the grass species have the capacity to retain / deal with this water or would this water migrate to the liner? Moreover, in periods of drought and then followed by high rainfall (as predicted with climate change), with the lack of significant tree species, erosional risk is high when native grasses may die off. Have Trigger Action Response Plans (TARPs) been developed to deal with grass die off, high rainfall (which has been experienced in the past two years) and increased erosion?
* QUESTION - as described above, has climate change been assessed when determining the adequacy of the containment cell?
* QUESTION - table 8.2 provides an overview of the expected timeframes. Moreover, the EIS notes sediment and erosion controls such as hay bales and sedimentation fences will be implemented throughout the period of works. What control measures will be implemented to ensure contaminated material (located in the containment cell, stockpile area etc) is not transported during periods of high rainfall or drought? Will stockpiles be misted to minimise dust generation? Sedimentation fences will not contain heavy metal accumulations within sediment runoff;
* QUESTION - the EIS has noted a number of monitoring commitments to be undertaken quarterly, annually and following certain rainfall events. Why has telemetry not been considered? Telemetry should at a minimum be installed in containment dams etc to warn of nearing levels of overtopping. Telemetry would also be a safe measurement of gas emissions. If environmental monitoring is subcontracted out, what assurances are in place to ensure monitoring is implemented immediately after high rainfall events? What is the response time (for example, maintaining the water treatment plant, implementing sediment and erosion control measures etc) for implementing environmental controls as required?
* COMMENT - Section 9.4.2 and table 9.9.1 clearly demonstrates Hydro's motivations of converting the site into a mildly remediated site to then transfer onto another party and remove any future financial obligations. The application appears to be the bare minimum for dealing with a direction from the EPA to clean up and also make the site appealing to divest. If Hydro was serious about decontaminating the site, a high treatment method would be implemented, however this will impact Hydro's bottom line more considerably. The cell should not be developed as if it fails and the transferee does not have the financial capability of amending, the liability will be left to the NSW taxpayer. IF this cell is to be approved, Hydro at minimum should provide financial sureties as they are the ones who benefitted from the creation of this adverse environmental legacy;
* QUESTION - have soil samples, surface and groundwater samples been taken to ensure offsite migration has not occurred?
Mary Bourke
Comment
Mary Bourke
Comment
Weston
,
New South Wales
Message
I would like to raise the following concerns. 1. Future liability for any pollution or emissions from the site when it is sold. 2. Transport of toxic waste from the site, possibly through Kurri Kurri and Weston, possibly 75 truck movements per day, with no destination outlined. 3. Proximity of houses, schools, TAFE, and townships will be affected by dust, noise, emissions of toxic gasses, leachates. 4. Future monitoring, both during demolition, and in the future, particularly of containment cell containing 266,000 cubic metres of toxic waste. 5. The dust, noise and toxic releases from demolition of the smoke stacks. 6. The impact of the crushing of bricks, concrete and other waste materials of over 100 tons per day. 7. The high risk of storing contaminated waste materials and its impact on watercourses and the Huner River catchment. 8. The overall impact of the project on residents of Kurri Kurri and Weston, which is not addressed adequately, if at all, in the submission, although Kurri Kurri hospital is mentioned, which is actually surrounded by Kurri Kurri and Weston townships.
Barry Kafer
Object
Barry Kafer
Object
Robert White
Object
Robert White
Object
Name Withheld
Object
Name Withheld
Object
Name Withheld
Object
Name Withheld
Object
not provided
,
New South Wales
Message
Dear MP's
I wish to bring to your attention a proposed State significant silica
sand mine at Bobs Farm behind Bobs Farm Public School. The DA and
EIS have been lodged with the Department of Planning and Environment.
Application number SSd‐6395. Submissions close 1/2/19. The
time frame is very short considering most people have been on
holidays.
Can you please read the brief attachment for your knowledge and
understanding of the situation and forward this email and
attachment to any relevant people who can help Bobs Farm community.
Also below are a few short videos/ links to gain an
understanding of the local school and community concerns.
Thank you for your assistance in this matter.
https://www.youtube.com/watch?v=eWoo3cJG7Ac&feature=youtu.be short
version
https://www.youtube.com/watch?v=eWoo3cJG7Ac&feature=youtu.be whole
history publica on.
https://www.facebook.com/nosandmineinbobsfarm Community Facebook page
I wish to bring to your attention a proposed State significant silica
sand mine at Bobs Farm behind Bobs Farm Public School. The DA and
EIS have been lodged with the Department of Planning and Environment.
Application number SSd‐6395. Submissions close 1/2/19. The
time frame is very short considering most people have been on
holidays.
Can you please read the brief attachment for your knowledge and
understanding of the situation and forward this email and
attachment to any relevant people who can help Bobs Farm community.
Also below are a few short videos/ links to gain an
understanding of the local school and community concerns.
Thank you for your assistance in this matter.
https://www.youtube.com/watch?v=eWoo3cJG7Ac&feature=youtu.be short
version
https://www.youtube.com/watch?v=eWoo3cJG7Ac&feature=youtu.be whole
history publica on.
https://www.facebook.com/nosandmineinbobsfarm Community Facebook page