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ENVIRONMENTAL ASSESSMENT REPORT Proposed Temporary Asphalt Plant 195 Circular Road, East Ridgley Fulton Hogan Industries Pty Ltd Board of the Environment Protection Authority November 2014

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Page 1: Proposed Temporary Asphalt Plant Hogan Pty Ltd... · 2014-11-25 · Environmental Assessment Report Fulton Hogan – Temporary Asphalt Plant, East Ridgley III Report summary This

ENVIRONMENTAL ASSESSMENT REPORT

Proposed Temporary Asphalt Plant

195 Circular Road, East Ridgley

Fulton Hogan Industries Pty Ltd

Board of the Environment Protection Authority

November 2014

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Environmental Assessment Report Fulton Hogan – Temporary Asphalt Plant, East Ridgley

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Environmental Assessment Report

Proponent Fulton Hogan Industries Pty Ltd (Fulton Hogan)

Proposal Temporary Asphalt Plant

Location 195 Circular Road, East Ridgley

NELMS no. PCE 9082

Permit application no. 2014/87 (Burnie City Council)

Folder EN-EM-EV-DE-238595

Document. H320671

Class of Assessment 2A

Assessment process milestones

27 June 2014 Notice of Intent lodged

22 July 2014 EER Guidelines issued

11 September 2014 Permit application submitted to Council

17 September 2014 Application/Referral received by Board

27 September 2014 Start of public consultation period

14 October 2014 End of public consultation period

28 October 2014 Supplementary information submitted to Board

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Acronyms

Air Quality, EPP

Board

Environment Protection Policy (Air Quality) 2004

Board of the Environment Protection Authority

BTEX

EAR

EER

Benzene, Toluene, Ethylene, Xylene

Environmental Assessment Report

Environmental Effects Report

dB(A)

DPIPWE

A-weighted decibels

Department of Primary Industries, Parks, Water and Environment

EIA

EMP

Environmental impact assessment

Environmental Management Plan

EMPC Act Environmental Management and Pollution Control Act 1994

EMPCS Environmental management and pollution control system

EPBC Act

IBC

IECA

L

Environment Protection and Biodiversity Conservation Act 1999 (Cth)

Intermediate bulk container

International Erosion Control Association

Litre

LUPA Act

mm

MSDS

OU

PAH

PEHS

PM

PSGs

Land Use Planning and Approvals Act 1993

Millimetres

Material Safety Data Sheet

Odour Units

Polycyclic aromatic hydrocarbon

Public and Environmental Health Service (Part of the Department of Health and Human Services)

Particulate Matter

Project Specific Guidelines

RMPS Resource management and planning system

SD

TSS

VOC

Sustainable development

Total suspended solids

Volatile organic compound

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Report summary

This report provides an environmental assessment of Fulton Hogan Industries Pty Ltd (Fulton Hogan)’s proposal to construct and operate a temporary mobile asphalt plant on a leased portion of 195 Circular Road, East Ridgley. Annual production volumes will be approximately 15,000 – 20,000 tonnes per year. This report has been prepared based on information provided by Fulton Hogan in the Environmental Effects Report (EER) and EER Supplement. Relevant government agencies and the public have been consulted and their submissions and comments considered as part of this assessment. Further details of the assessment process are presented in section 1 of this report. Section 2 describes the statutory objectives and principles underpinning the assessment. Details of the proposal are provided in section 3. Section 4 reviews the need for the proposal and considers the alternatives to the proposal. Section 5 summarises the public and agency consultation process and the key issues raised in that process. The detailed evaluation of environmental issues is contained in section 6. The report conclusions are contained in section 7. Appendix 1 contains details of comments made and issues raised in the consultation process. Appendix 2 contains the environmental permit conditions for the proposal. Attachment 2 of the permit conditions contains the table of commitments from the EER.

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Table of Contents

1 Approval process ..................................................................................... 1

2 SD objectives and EIA principles .............................................................. 2

3 The proposal ............................................................................................ 3

4 Need for the proposal and alternatives ..................................................... 7

5 Public and agency consultation ................................................................ 9

6 Evaluation of key issues ......................................................................... 10

7 Other issues ........................................................................................... 18

8 Report conclusions ................................................................................. 28

9 Report approval...................................................................................... 29

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1 Approval process

A Notice of Intent in relation to the proposal was received by the Board of the Environment Protection Authority (the Board) on 27 June 2014. An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Burnie City Council on 11 September. The proposal is defined as a ‘level 2 activity’ under clause 7(d)), schedule 2 of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being a pre-mix bitumen plant. Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The application was received by the Board on 17 September 2014. The Board required that information to support the proposal be provided in the form of a Environmental Effects Report (EER). Several drafts of the EER were submitted to the Department for comment prior to its finalisation and acceptance on behalf of the Board. The final EER was submitted to Council with the permit application. The EER was released for public inspection for a 14-day period commencing on 27 September 2014. An advertisement was placed in The Advocate and a notice was placed on the EPA website. The EER was also referred at this time to relevant government agencies for comment. One (1) public submission was received. On 21 October 2014, the Board requested that the proponent submit supplementary information to address public comments on the EER and to meet other information requirements. Satisfactory supplementary information was submitted by the proponent on 28 October 2014.

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2 SD objectives and EIA principles

The proposal must be considered by the Board in the context of the objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) (both sets of objectives are specified in Schedule 1 the EMPC Act). The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to further the RMPS and EMPCS objectives. The Board must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment Principles defined in Section 74 of the EMPC Act.

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3 The proposal

The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 1.0 of the EER. Table 1: Summary of the proposal’s main characteristics

Activity

Operation of a temporary mobile asphalt (pre-mix bitumen) plant for a period of 18 months, with an annual production of approximately 20,000 tonnes per year.

Location and planning context

Location A leased portion of 195 Circular Road, East Ridgley

Land zoning Rural Resource

Land tenure Private land (the asphalt plant site will be leased from the land owner)

Mining lease Site is part of 1218P/M

Lease area Approximately 0.9 hectares

Existing site

Land Use Farm land (currently used for storage and grazing)

Topography The proposed site is a generally flat parcel of land at an elevation of approximately 260m above sea level. The surrounding land has a similar gradient for approximately 500 metres radius with the exception of Rawlings Hill located approximately 450 metres to the south west which rises to 320 metres above sea level and a sloping gradient beyond the adjacent quarry down to the Pet River to the north.

Geology The geology of the site and the surrounding area is a Tertiary Basalt [basanaite (Tb)] of the Cenozoic Era.

Flora and Fauna According to the LIST and the Natural Values Atlas:

The vegetation classification on the site is (FAG) Agricultural, urban and exotic vegetation.

The site is located within the Emu River Catchment Area. However there are no creeks or streams running through the property.

There are no records of threatened flora within 1 km of the site

There are no known cases of threatened fauna within 1km of the site, however there is the potential for seven (7) threatened fauna species within 1 km of the site.

There are no records of raptor nests or sightings within 1km of the site.

There are no records of non‐threatened flora or fauna of conservation significance found within 1km of the site.

There are no records of declared or priority weeds found within 1 km of the site.

Local region

Climate The average annual rainfall in the East Ridgley area is approximately 1,200 mm per year. Prevailing winds are predominantly from the west and south west.

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Surrounding land zoning, tenure and uses

North: Farming land and Quarry operation. Further north is a Riparian forest area and Pet River (Pet River flows generally to the north east and merges with Emu Creek approximately 3 – 4 kilometres downstream. The closest resident is approximately 740 metres to the north west (Figures 10 and Figure 14 of the EER).

East: Farming land, closest resident is approximately 650 metres away (Figures 11 and 14 of the EER).

South: Farming land, closest resident is approximately 350 metres away (Figure 10 of the EER). This is the residence of Mr Gary and Mrs Pat Clarke, owners of the land on which the asphalt plant will be located. Views from the Clarkes residence to the asphalt plant will be blocked by natural topography (Figure 12 and 14 of the EER) which will also assist in minimising any environmental impact (i.e. noise/odour) to this residence).

West: Farming land, closest resident is approximately 1 kilometre away but with no clear line of site to the proposed asphalt plant location (Figures 13 and 14 of the EER).

Species of conservation significance

None

Proposed infrastructure

Major equipment Asphalt plant (Figures 1 and 16 of the EER), comprising of:

Parallel flow drum mixer (capacity 180 tonne/hour);

Diesel fired burner (heat source for aggregate heating and drying stages within the drum mixer);

25 tonne hot asphalt storage bin;

6 x cold feed bin unit;

Baghouse dust filter, dust extraction fan and associated discharge stack;

Truck load out and plant control room.

Other infrastructure

Laboratory building (container) with lunch room.

Inputs

Water From extension of mains supply

Energy Power via mains electricity supply

Other raw materials

Aggregate from the adjacent quarry.

Low-sulphur bitumen, hot oil, Sand, cement delivered from off-site.

Wastes and emissions

Liquid Surface water runoff from hardstand and stockpile areas.

Atmospheric Odour emissions from the asphalt plant, including the exhaust stack and baghouse.

Dust and particulates from the asphalt plant (including the primary collector and baghouse), load out area, internal and external traffic, and blow-off from stockpiles.

Solid General refuse including food scraps, paper and packaging.

Controlled wastes

Contaminated soil (if impacted)

Noise From the asphalt plant, and vehicles on site and going to and from the site.

Greenhouse gases

Emissions from asphalt plant and vehicles on-site.

Construction, commissioning and operations

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Proposal timetable

The Plant will be located at the site for around 18 months in total, with a brief 2 month intermission before returning back to the site.

The Asphalt plant is scheduled for mobilisation in September 2014 through to December 2014. The plant will then be relocated and will return back to the East Ridgley site in early 2015 and operate through to the end of 2015.

It is expected that production of asphalt will only occur over a 10‐12 week period in total

(i.e. 5‐6 production events over the 18 month period with each being a 2 week window for production and lay of the asphalt).

Operating hours (ongoing)

7:30am – 6:00pm Monday to Friday

7:30am – 12pm on Saturdays.

The plant will not be operational on Sunday or Public Holidays.

Other key characteristics

Stormwater runoff will be diverted via constructed channels to flow towards the quarry site and in the existing quarry sedimentation ponds.

The quarry’s amenities will be used for asphalt plant personnel.

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4 Need for the proposal and alternatives

Fulton Hogan proposes to develop a temporary mobile asphalt plant to manufacture specialty asphalt, for use at the Burnie Port and similar locations based on current and likely contracts. According to the EER, the temporary establishment of the plant on a leased portion of 195 Circular Road, East Ridgley is to service this specialised need. The existing pavements and infrastructure at the Burnie Port are failing and require imminent replacement. The intention is for the works to be largely conducted over the summer months when the environmental risk is lower and quality and efficient production can be best achieved. A number of alternative options were investigated for the location of the proposed mobile asphalt plant. A summary of the evaluation of each option including the advantages and disadvantages is outlined in Table 1 below as detailed in section 4.2 of the EER. Table 2: Other Options for Location of the Proposed Mobile Asphalt plant OPTION ADVANTAGES DISADVANTAGES

Burnie Port Located at the Port Proposed development in line with land use zoning

Potential environmental nuisance to nearby community (approx. 100m away) and residents (approx. 300m away) from dust, odour and noise impacts. Environmentally sensitive location on the water’s edge and exposed to winds which will exacerbate dust effects. Limited space available, which is required for the storage of excavated materials for future use by the Port.

Timber Mill (Massey Greene Drive, Burnie)

Closer to the Port Potential environmental nuisance to nearby and residents (approx. 150m away) from dust and odour. Insufficient room on site to locate the mobile asphalt plant and operate the facility safely. Proposed development was not in line with land use zoning. The proposed area was not in an industrial zoned area but rather an area currently zoned as ‘Open Space’

East Ridgley – within Quarry

Closest residents 350m or more away Close and immediate access to key raw product resource Minimises volume of trucks needed for manufacturing and delivery by a third.

Insufficient room to locate asphalt plant due to quarry waste stockpile footprint. Topography of quarry not level enough to locate the plant Discretionary land use planning permit required.

East Ridgley – adjacent to Quarry

Closest resident is 350m away behind a hill. Next closest residents are over

Discretionary land use planning permit required

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500m away. Keeps the plant out of the way of the community (minimal effect on Burnie) Direct access to dedicated truck haulage route to Burnie. Close and immediate access to key raw product resource providing a more economic and sustainable solution Minimises volume of trucks needed for manufacturing and delivery by a third.

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5 Public and agency consultation

A summary of the public representations and government agency/body submissions is contained in Appendix 1 of this report. One (1) public representation was received. The main issues raised in the representations were air emissions impacting local (their property) and regional (Burnie) air and water supply. The EER was referred to a number of government agencies/bodies with an interest in the proposal. Responses were received from the following:

Mineral Resources Tasmania, Department of State Growth (current mining lease)

Public and Environmental Health Service (PEHS), Department of Health and Human Services (air emissions)

Water & Marine Resources – Water licensing

The following areas of the Department of Primary Industries, Parks, Water and Environment also provided submissions on the EER:

Policy and Conservation Assessment Branch, DPIPWE

Aboriginal Heritage Tasmania

Heritage Tasmania

Regulatory Officer, Northern Regulation Section, EPA Division

Noise Specialist, EPA Division

Air Specialist, EPA Division

Water Specialist, EPA Division

The EER Supplement prepared by the proponent provides a response to each of the relevant environmental issues raised by the public and government agencies/bodies.

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6 Evaluation of key issues

The key environmental issues relevant to the proposal that were identified during the assessment process for detailed evaluation in this report were:

Air emissions

Noise emissions

Each of these issues is discussed in the following subsections.

6.1 Key issue 1 – Air Emissions

Description

Air emissions such as odour, particulates and dust from the asphalt plant baghouse, stockpiles, loading areas and vehicles, in conjunction with the adjacent quarry activities, have the potential to impact on nearby sensitive receptors, including residences if not appropriately mitigated and managed. Sources of emissions from the asphalt plant as detailed in Section 5.6.1 of the EER are listed below and their location is shown in the Fulton Hogan EMP (Appendix 3 of the EER).

Point Source Emissions Fugitive Emissions

Baghouse [PM10, PM2.5, Odour, inorganic compounds (metals) and organic compounds (BTEX), PAH’s, VOC’s (Asphalt Fume)]

Aggregate Stockpiles (Dust, PM10, PM2.5)

Asphalt Loading from Storage Silo (Odour)

The closest residence (the landowner) is located approximately 350m to the south behind a hill. All other sensitive receptors (including Ridgley Primary School in the NW direction from the proposed plant) are more than 500 m from the proposed plant. This includes residents located 650 metres to the east, 740 metres to the north west and 1 kilometre to the west (Figure 14 of the EER).

An air quality assessment was undertaken by EML Air Pty Ltd (EML Air) in July 2014 for Fulton Hogan that considered the meteorological conditions (predominant winds are from the west and south-west) and topography of the East Ridgley area and the location of sensitive receptors. The modelling was intended to demonstrate that emissions from the plant would not exceed applicable air quality and odour criteria under the Environment Protection Policy (Air Quality) 2004 (Air Quality, EPP) (Appendix 4 of the EER) at sensitive receptors. Odour emission rates from a point source were adopted from a comparable plant operated by Fulton Hogan while odour emission rates estimates from the asphalt loading process were based on the data available from EML Air’s archive.

The air quality criteria relevant to the project (Table 3 of the EER) were sourced from the Air Quality, EPP – Schedules 2 and 3 and the National Environment Protection Measure for Ambient Air Quality (for particulate matter).

According to Section 5.6.4 of the EER, the results of the modelling concluded:

The predictions for inspirable and respirable dust (as PM10 and PM2.5), nitrogen dioxide and carbon monoxide, inclusive of representative background levels, indicate that the emissions from the temporary plant would not exceed their respective Air Quality, EPP design concentrations in the area around the plant, with each pollutant having a significant margin of safety .

The predictions for individual metal, organic and inorganic pollutants also indicate that the emissions from the temporary plant would not exceed their respective Air Quality, EPP design concentrations in the area around the plant. Compliance with all Air Quality, EPP classified indicator pollutants was demonstrated with the adopted assumptions.

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The emission constituent with the lowest margin of safety was asphalt fume (assessed as 100% of VOC emissions from the vent stack). Peak predicted levels were at the Air Quality, EPP design criteria however these occurred to the west of the site within the quarry area, and only 25% of the criteria level was predicted at the nearest sensitive receiver location.

Odour was also a critically constraining criterion for this air quality assessment. However, if the plant were to operate every day for 10 hours per day then the 2 OU criteria level at the 99.5th percentile level was not predicted to extend as far from the plant to the nearest sensitive receiver, located to the south. This was a very conservative assessment as the actual operating hours per year are forecast to be much less than that adopted within the constraints of the modelling methodology. This would indicate that for the adopted odorous emissions to air from the production and load out operations the identified sensitive receivers in the area of the plant are very unlikely to be exposed to offensive odour.

Management measures

According to Section 5.6.5 of the EER the following management and mitigation measures will be implemented in relation to air emissions:

The asphalt plant will have an exhaust stack constructed to ensure emissions are treated through the baghouse prior to discharge to air (commitment 8). The baghouse dust filtration system will capture dust emissions from the drum mixer process exhaust stream, directing this through the baghouse, with final discharge to atmosphere through a vent stack. The baghouse discharge stack is designed to provide dispersion of any residual particulate matter and odour in the exhaust discharge stream. All of the dust captured by the baghouse filter will be re-directed back into the mixing process, enabling re-use of this dust waste stream in the asphalt production process.

Odour emissions from the asphalt plant shall be minimised by applying stringent quality control on the asphalt plant temperature (commitment 3). In addition asphalt will be temporarily stored in the elevated silo in preparation for load out. The silo will be insulated [to] effectively maintain the asphalt at a workable temperature which is lower than the original hot mix production temperature and therefore any “blue smoke” (visible) fugitive emissions should not be present (commitment 4).

The load out area will not be enclosed, however the asphalt feed conveyor to the silo and the silo will be enclosed (commitment 5). Asphalt will drop directly into the asphalt truck over a short period minimising fugitive odour. Load out of trucks will occur in an efficient manner (load out times approx. 2 minutes) minimising fugitive odour (commitment 6). The asphalt tray trucks will be immediately tarped and driven off-site (commitment 7).

The Air Management Plan detailed in Section 5.6.5 of the EER also states that maintenance and housekeeping will be implemented and scheduled to minimise the potential for dust emissions. This includes:

• Regular cleaning out of dust deposits from under the asphalt plant (commitment 10);

• Maintenance of dust management equipment will not be scheduled or conducted during hot, dry, windy conditions when the equipment is most needed (commitment 11);

• A water cart will be used as required to minimise airborne dust (commitment 13);

• Vehicles will be maintained as per maintenance schedules (commitment 18);

• Operations shall be visually inspected for visible dust emissions as part of the monthly environmental inspection and record observations and actions on the Environment Checklist (commitment 9); and

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• In the event of a dust suppression failure, management shall consider ceasing works in the affected areas that have the potential to generate dust (e.g. maintenance, loader movements) (commitment 14).

The EER also states that n days of unfavourable weather conditions [e.g. high winds], a review of onsite practices will be undertaken to schedule activities so as to mitigate dust generation.

The site will be sheeted with crushed rock and all traffic movement on site will be restricted to the crushed rock surface and a max speed of 10 km/h to reduce dust generation (commitment 12). Travel routes will be clearly defined to minimise the impact on existing [road networks]. Incoming and outgoing loads shall be covered to minimise dust generation while transported on public roads (commitment 17).

All stockpiled materials are to be located within the allocated areas as shown on the EMP (Appendix 3 of the EER). Stockpile heights will be managed at the asphalt plant such that stockpiles shall not exceed 8m in height (commitment 15). The stockpile height at the site shall be managed to minimise impacts on visual amenity. Stockpiles of any fine material with dust potential will be wet down as required so as to form a surface crust, which minimises release of airborne dust (commitment 16).

Air quality and odour from the site will be managed and implemented in accordance with the following:

• Fulton Hogan East Ridgley Mobile Asphalt Plant Environmental Management Plan (EMP) (refer Appendix 3 of the EER).

• Fulton Hogan Air Quality Procedure.

It should also be noted that the air modelling, and therefore compliance with the Air Quality, EPP is based on the proponent’s commitment to use low sulphur bitumen.

Figures 17 and 18 also indicate the use of a funnelled silo for the loading of asphalt onto trucks, which is likely to increase the efficiency of loading and time until loads are covered with tarps and reduce the potential for odour emissions.

Public and agency comment and responses

The EPA Division’s Air Specialist reviewed the air modelling conducted for the proposal and concurred with the conclusions presented in the EER report. The Air Specialist noted a couple of inconsistencies in the air modelling, which were subsequently addressed in the Supplementary Information.

One representor raised concerns in relation to exposure to carcinogens from the asphalt plant in air and water supply that may affect their family’s health. They also raised concerns of potential impacts to the Burnie water supply (Pet Reservoir).

The supplementary information reiterated that the air dispersion modelling completed for the EER has predicted peak concentrations that comply with the Air Quality, EPP health based criteria for all pollutant indicators around the proposed temporary asphalt plant and in particular at any sensitive receiver locations. It is also highlighted that the results were conservative based on emission factors used and the operating hours applied.

While cadmium and arsenic were not specifically included in the EER table within the air dispersion modelling report as there are no design criteria specified for these compounds in the Air Quality, EPP the supplementary information highlights that Asphalt Fume is specified (based on toxicity) in Air Quality, EPP and this inclusion would encapsulate all relevant compounds associated within the fume. In addressing the supplement request Fulton Hogan also used USEPA AP-42 data to extrapolate emission rates for arsenic and cadmium which revealed peak ground level concentrations that readily complied with concentrations specified elsewhere in Australia (e.g. Victoria) with appropriate safety margins at the property of the representor.

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In response to concerns to asphalt fume being carcinogenic, Fulton Hogan included in the supplementary information a copy of a communication provided by EuroBitume, which summarises the latest International Agency for Research on Cancer (IARC) published results (2010) which reports that no evidence was found to associate lung cancer and exposure to bitumen fumes by workers at asphalt plants.

The Supplementary Information also concluded that based on the modelling results the risk of impact to waters in any stock dam, surface waters or the Pet Reservoir from the temporary drum mix asphalt plant air emissions would be insignificant and there is negligible risk to human health.

The Public and Environmental Health Service (PEHS) reviewed the EER and considered that they did not require any additional health matters to be addressed within the report. PEHS also reviewed the public representation. They confirmed that

asphalt plants do emit fumes which are a mixture of hundreds of different chemicals that have the potential to harm human health but only at sufficiently large concentrations…and although elevated levels of these chemicals may be found near an asphalt plant, the levels are still considered to be low, with the potential for adverse health effects expected to be very low.

The response also reiterated that an asphalt plant must meet air quality criteria (the Air Quality, EPP) to operate and the Air Quality, EPP is based on the protection of public health. PEHS also confirmed, that no studies have linked residential exposure to asphalt fumes with cancer, nor is there any evidence that the low levels of emissions from an asphalt plant pose a risk to human health.

With regards to contamination of water supplies such as dams, the PEHS considered based on the absence of creeks or streams on the site, the closed system stormwater system and proposed mitigation and management measures that contamination of to surface waters such as dams is not expected.

Evaluation

Due to the infrequency of production of asphalt and the temporary nature of the facility, air dispersion modelling was not required under the Project Specific Guidelines. However, a thorough assessment of potential impacts of the likely pollutants that would be emitted from the plant was required. Additionally, measures to mitigate any potential impacts on sensitive receptors that may result from a worst case scenario release of pollutants from the proposed asphalt plant were required to be identified and discussed.

Fulton Hogan provided this information as well as conducting site specific air dispersion modelling. The modelling identified all potential sources of emissions, including odour and dust, and their likely emission rates and dispersion and compared results to the Environment Protection Policy (Air Quality) 2004 (Air Quality, EPP). As confirmed by the PEHS, the Air Quality, EPP outlines design ground level concentrations that must not be exceeded, inclusive of representative existing background concentrations at relevant receptor locations. Design ground level concentrations are specified to protect human health or other environmental factors if they are more sensitive than human health.

The air quality assessment undertaken by Fulton Hogan focused on demonstrating that emissions from the activity would not cause environmental harm or nuisance at the nearest sensitive receptors. This methodology is acceptable under clauses 11(f) and 13 of the Air Quality, EPP, which allows for the odour criteria defined in Schedule 3 of the EPP, Air Quality not to be applied . at the boundary of the land on which the source is located where the regulatory authority is satisfied that odour from the activity is not causing or is unlikely to cause an environmental nuisance or environmental harm at the nearest sensitive receptors..

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Fulton Hogan estimated that the cumulative air emissions from the asphalt plant would not exceed applicable quality and odour criteria under the Air Quality, EPP and therefore present a low risk of environmental nuisance. The air modelling and proposed management measures were reviewed by the EPA Division’s Air Specialist and PEHS who concurred with this conclusion. The supplementary information confirmed the findings of the air dispersion modelling and the expected compliance with the Air Quality, EPP at nearby sensitive receptors, including that of the representor and the Pet Reservoir.

As detailed in the supplementary information the air modelling can be considered conservative in its results based on the emission data for particulates, combustion gases, VOCs and other significant classified indicator emissions being based on a less refined fuel oil than proposed for the asphalt plant. The odour modelling also conservatively simulated emissions to air for 10 hours per day throughout the year, or for 3650 daylight hours. However, the proposed actual operating hours for the proposed plant is much less. These examples of conservatism highlight that the modelling shows worse case scenarios and further supports the conclusion that environmental nuisance at nearby sensitive receptors caused by air emissions from the activity is unlikely.

Although modelling indicates that environmental impacts at the nearest sensitive receptors are unlikely, the proponent will need to mitigate and manage the plant to ensure that compliance with the Air Quality, EPP is maintained and emissions minimised. The proponent will therefore be required to manage odour to prevent environmental nuisance beyond the boundary of the Land through condition A2. This condition is supported by the proponent’s commitment to the construction of an exhaust stack so that emissions are treated through the bag house (commitment 8) and emitted to air through the 6.09 metre high vent. And further supported through commitments to install an enclosed silo and asphalt feed conveyor (commitment 5) and the insulation of the silo (commitment 4), managing asphalt temperature and preventing the emission of odorous gases.

Mitigation and management of odorous gases is also required under condition A3. This condition imposes actions to prevent the production of avoidable fumes and odours (including temperature control) and also requires the prevention of emissions on loading of the trucks with asphalt. These requirements are supported by the commitment by the proponent to loading trucks in an efficient manner (commitment 6).

Meteorological conditions used in the air modelling (Section 2 of Appendix 4 of the EER) indicate that poor dispersion conditions for the stack are typically early or late in the day (or during periods of significant cloud cover) and for the load out in nocturnal hours this will be managed through restricting operating hours under condition G7.

The proponent will be required to control dust emissions under condition A4 and this will be supported through condition A5 which requires vehicles carrying loads that may cause dust emissions to be covered when leaving the land or travelling on public roads. The proponent’s commitments 9-16 and 18 are also considered appropriate to manage dust emissions at the site.

Fulton Hogan will be required to notify the Director prior to commissioning under condition G4, ensuring appropriate regulation and management. This will be further supported through the implementation of a complaints register under condition G5 and requiring notification of any air complaints to the Director within 24 hours under condition A1, allowing an appropriate and efficient response to any air emission issues.

Conclusions

Based on the review of Fulton Hogan’s air modelling by the EPA’s Air Specialist and the PEHS, and their concurrence with findings and proposed management measures it is concluded that the operation of the temporary, mobile asphalt plant presents a low risk of environmental nuisance at nearby sensitive receptors, including that of the representor and the Pet Reservoir.

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Fulton Hogan will be required to comply with the relevant EER commitments detailed in the Evaluation section above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

G3 Commitments encompassing commitments 4, 5, 6, 8, 9-16 and 18

G4 Notification Prior to Commissioning

G5 Complaints Register

G7 Operating Hours

A1 Air emission complaints

A2 Odour Management

A3 Control of odour emissions

A4 Control of dust emissions

A5 Covering of vehicles

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6.2 Key issue 2 – Noise Emissions

Description

The activity has the potential to cause noise emissions from the asphalt plant and associated vehicular movements, which may impact on nearby sensitive receptors, including residencies.

Fulton Hogan engaged Acoustic Consulting Australia Pty Ltd in July 2014 to confirm that the predicted noise levels from the plant would not contribute in such a way that the cumulative noise levels would exceed existing permissible noise limits for the area and meets the requirements of the Environment Protection Policy (Noise) 2009.

As the proposed mobile asphalt plant will be located within the existing mining lease and an existing Environmental Licence (No 3166) is attached to the mining lease, the modelling was based on the asphalt plant complying with the same requirements of the licence, which specifies that noise measured at the nearest sensitive receptor must not exceed 45dB(A) during the day period (7am to 7pm).

The noise modelling took into account the nearest sensitive receivers (residences nearest to the proposal site) as shown in Figure 21 of the EER as well as the proposed operating hours and the additive effects of the two sites.

The modelling indicates that predicted noise from the proposed asphalt plant operation is unlikely to cause non-compliance with the existing quarry licence requirement of 45dB(A) during the daytime period in the directions of the three closest residences.

In considering the results of the noise modelling, the noise report (Appendix 5 of the EER) notes that for the predicted noise level of 44dB(A) to occur at the closest residence (350 metres south of the activity) the plant would need to be operating with the presence of breezes blowing in that direction. The prevailing winds are from the west and the operation of the asphalt plant is intended to be limited to 5 to 6 production campaigns of approximately 2 weeks over the 18 months of operation. They therefore concluded the asphalt facility generated noise levels at the closest residence are unlikely to exceed 40dB(A) during the temporary existence of this activity

Section 5.9.3 of the EER also states that:

• The closest residence is that of the landowner on which the plant will be located and leased from;

• during calm conditions the resulting noise levels could be at least 5dB(A) lower; and

• when the wind is opposing the direction of sound propagation the predicted level would be substantially lower by 10dB(A); or more in some cases.

Management measures

Section 5.9.4 of the EER proposes to minimise noise from the asphalt plant by the following:

• Loader operations will be confined to the northern end of the site (commitment 29);

• All machinery on site shall be appropriately maintained to minimise noise emissions (commitment 30); and

• Vehicles shall not be kept idling unnecessarily, and will not be operated during noise sensitive hours (i.e. 6pm - 7am). This will be communicated through site inductions (commitment 31).

Noise management at the site will be implemented in accordance with the following:

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• Fulton Hogan East Ridgley Mobile Asphalt Plant EMP (refer Appendix 3 of the EER).

• Fulton Hogan Noise Procedure.

Public and agency comment and responses

None

Evaluation

The PSGs for the proposal required details of noise sources; the potential for noise generated by the activity to impact on nearby sensitive receptors and proposed mitigation measures. The proponent provided this information as well as conducting site specific noise modelling which confirmed that noise impacts are unlikely to occur at the three closest residences.

Noise impacts are expected to be further mitigated by the temporary nature of the activity and the limited number of pouring campaigns or events. The closest residence is also the landowner on which the plant will be located and leased from and has consented for the activity to occur on his land and not in the direction of prevailing winds.

To ensure that the activity is managed to prevent noise impacts on nearby sensitive receptors, noise emission limits will be placed on the activity under condition N1. This condition requires noise emissions measured at any noise sensitive premise in other ownership must not exceed 45dB(A) during the day and 40dB(A) at night. These levels include consideration of ambient noise, which in this case includes the adjacent quarry, and are consistent with the noise limits for the quarry and those modelled by the proponent.

Noise emission impacts will be further managed through the restriction of operating hours under condition G8, which restrict or prevents work at times when residencies are likely to be impacted or affected by noise (e.g. night time and Sundays). The proponent intends to minimise noise emissions through commitments 29, 30 and 31, which are considered appropriate to ensure noise limits are complied with.

The proponent will also be required to notify the Director prior to commissioning under condition G4, ensuring appropriate regulation and management. This will be further supported through the implementation of a complaints register under condition G5 and requiring notification of any noise complaints to the Director within 24 hours under condition N2.

Conclusions

Fulton Hogan will be required to comply with the relevant EER commitments detailed in the Evaluation section above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

G3 Commitments encompassing commitments 29, 30 and 31

G4 Notification Prior to Commissioning

G5 Complaints Register

G8 Operating Hours

N1 Noise limits

N2 Noise Complaints

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7 Other issues

In addition to the key issues, the following environmental issues are considered relevant to the proposal and have been evaluated in the following section:

1. Stormwater

2. Hazardous Substances

3. Traffic Impacts

4. Weed Management

5. Flora, Fauna & Habitat

6. Waste Management

7. Decommissioning & Rehabilitation

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Issue 1: Stormwater

Description of potential impacts

The activity has the potential to cause sediment and contaminated water from the site to enter the open paddocks or increasing the TSS and hydrocarbon released via the adjacent quarry’s sediment pond system if not appropriately managed.

East Ridgley has a high average annual rainfall of approximately 1,200 mm. The adjacent quarry has current compliance issues in relation to the management of stormwater, particularly during high rainfall events (pers. comm Regulatory Officer for the BIS Industries quarry).

The existing site slopes to the north toward vegetated open paddocks. There are no waterways on this land and all flow in this direction is anticipated to be sheet flow. Approximately 200 metres to the north of the site is a Riparian forest area and Pet River (Pet River flows generally to the north east and merges with Emu Creek approximately 3 – 4 kilometres downstream).

The site will be built up from the existing ground level. There will be no process water discharged from the plant.

Management measures proposed in EER

According to Section 5.2 of the EER, the asphalt plant is a closed system and as such there are no ongoing losses of pollutants. All chemical and fuel storage will be within bunded areas. The diesel tank will be self bunded and an impervious, geotextile lined, earthen bund shall be constructed for the bitumen and hot oil tank storage. This will ensure that in the event that there was an incident, stormwater will not be polluted. Bunding for all chemical and storage areas is commitment 21 of the EER.

Surface water runoff from the asphalt plant site will predominantly soak through the imported gravel base. Given that the site will be relatively flat there will be minimal stormwater sheet flow occurrences which can be treated using a Type 3 sediment control such as sediment fencing (IECA, Best Practice Erosion and Sediment Control, Book 1). Any stormwater runoff will be diverted to constructed channels and sediment fences prior to fanning out into the adjacent farming land buffer. This is reflected in Commitment 19 of the EER.

Two crossovers will be constructed over the exiting roadside drain in order to provide access in and out of the site. Pipes shall be installed under the crossovers in order to ensure that roadside runoff flows are not impeded. Both the site and the crossovers will be sealed in crushed rock material or equivalent and compacted to refusal. This will minimise the potential erosion from these surfaces. This is reflected in Commitment 20 of the EER.

The aggregate surfacing will be maintained so that mud tracked onto the surface does not become a stormwater pollutant (commitment 22). Visual inspections of any water runoff from the site shall be undertaken to verify that no pollutants are leaving the site (commitment 23). Section 5.2 also states that all traffic movements shall be restricted to the gravel surface, which will prevent any mud from being tracked onto roads.

Stormwater Management at the site will be managed and implemented in accordance with

the following:

Fulton Hogan East Ridgley Mobile Asphalt Plant EMP (refer Appendix 3 of the EER).

Fulton Hogan Erosion and Sediment Procedure.

Public and agency comment

None

Evaluation

The proposal is located in a high rainfall area and therefore stormwater management is necessary to ensure that sediment and pollutants do not leave the site and impact on the surrounding land or nearby Pet River. Condition E1 will require the proponent to manage stormwater and prevent the discharge of pollutants from the Land. This condition is consistent with commitments 19 and 20 of the EER which relate to the construction of stormwater channels, sediment fences and crossover drains to manage stormwater and potential pollutants.

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The proponent has also commitment to visual inspections of any runoff to verify that pollutants are not leaving the site (commitment 23), ensuring management of compliance with condition E1 and an early response in the event of a non-compliance

The maintenance of the aggregate surface to prevent mud becoming a stormwater pollutant, as detailed in commitment 22, is also considered appropriate.

Bunding of all chemical and fuel storage, as required under conditions H1 and H2 are considered appropriate to prevent pollutants entering stormwater at the site.

Conclusion

Fulton Hogan will be required to comply with the relevant EER commitments detailed in the Evaluation section above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

G3 Commitments encompassing commitments 19, 20, 22 and 23

E1 Stormwater

H1 Storage and handling of hazardous materials

H2 Hazardous materials (<250 litres)

Hazardous materials impacts and management are considered further in Issue 2 of the EAR.

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Issue 2: Hazardous Substances

Description of potential impacts

The activity has the potential to cause contamination of the site and nearby waterways from chemical or fuel/oil spills if not appropriately managed.

The following tanks are proposed for mobilisation of the Asphalt Plant – Bitumen, hot oil and diesel. The sizes of the largest tanks are 60,000 litres bitumen, 40,000 litres diesel and 700 litres hot oil.

A “Truck Slip” intermediate bulk container (IBC) will also be located on site for use by trucks prior to loading asphalt. Truck slip is sprayed in the backs of the trucks. It is used to ensure the asphalt doesn’t stick to the truck and will slide out on delivery.

The laboratory will also store minor quantities of chemical which will be contained in the laboratory container.

Management measures proposed in EER

According to Section 5.12 of the EER, a self bunded diesel tank (40,000 Litres) to run the burner will be located on the site. Bunding will be constructed for the balance of tank storage, including a Bitumen Tank (60,000 Litres) and Hot Oil Tank (700 Litres). This is reflected in commitment 34 of the EER.

Delivery of low‐sulphur bitumen and hot oil to the site will occur as needed and will be delivered by a mobile supplier only and the supplier vehicle will leave the site after delivery. Refilling of the Bitumen and Hot Oil tanks will occur at the tank refill points (Commitment 38).

Delivery of diesel to the site to refuel the diesel tank will occur as needed and is anticipated to be once every two months. Fuel will be delivered by a mobile supplier only and the supplier vehicle will leave the site after fuel delivery. All refuelling of plant and equipment will occur onsite at the diesel tank area (commitment 38). The diesel tank will also have an impervious, geotextile lined, earthen bund constructed at the refill point where the hose connects to the truck and the tank (Commitment 35). The tanker delivery drivers will remain at the truck at all times during refilling of the diesel, bitumen and hot oil tanks (Commitment 39).

Spill response equipment will be located on the site and will be readily available during refilling of tanks (Commitment 40). Any spill will be immediately cleaned up and responded to in accordance with the Fulton Hogan Incident and Emergency Response Flowchart – Chemical Oil and Fuel Spills (Commitment 41). Hydrocarbon contaminated dust can be returned to the fine processed material for reuse. Spill Kit absorbent material is to be disposed of in accordance with EPA Guidelines. In the event of an environmental incident this will be recorded and managed in accordance with the Fulton Hogan Case and Management Action Procedure (refer to Appendix 6 of the EER).

Fulton Hogan will endeavour to use ‘GreenSlip’ for the Truck Slip IBC wherever available, as it is a biodegradable product. The Truck Slip IBC will be stored on a porta-bund or an impervious, geotextile lined, earthen bund (Commitment 36). Any servicing oils from plant and equipment will be removed by contractor in accordance with EPA Guidelines (Commitment 37).

The laboratory will also store minor quantities of chemicals (i.e. <20L containers of Mineral Turpentine and Shellite) which will be contained in the laboratory container cupboard. Commitment 42 states a Spill Response Kit will be located at the Laboratory. An MSDS Register for all chemicals will be available on site (Commitment 43).

As part of good operational management Fulton Hogan will establish fire prevention measures and a Bushfire Hazard Management Plan to be followed during periods of high fire risk.

Hazardous substances, chemicals and fire management at the site will be implemented in accordance with the following:

Fulton Hogan East Ridgley Mobile Asphalt Plant EMP (refer Appendix 3 of the EER).

Fulton Hogan Chemical Management Procedure.

Fulton Hogan Incident and Emergency Response Flowchart‐ Bushfire.

Fulton Hogan Incident and Emergency Response Flowchart‐Fires and Explosions.

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Fulton Hogan East Ridgley Bushfire Hazard Management Plan.

Public and agency comment

None

Evaluation

The activity requires the storage and use of fuels, oils and chemicals that have the potential to cause environmental nuisance or harm if not appropriately managed. Appropriate bunding for all chemicals, fuels and oils in volumes exceeding 250 litres is required under condition H1. The proponent has also committed to a porta-bund to contain any spills or leaks from the Truck Slip IBC (commitment 36) and a bund at the diesel tank refill point (in addition to the tank itself being self bunded) (commitment 35). These measures implemented in accordance with relevant Australian Standards are considered appropriate for managing the potential for spills or leaks from these sources.

Further prevention of potential impacts from hazardous materials is also committed to by the proponent through restricting refuelling and refilling of hot oil and bitumen tank activities to the diesel tank area (Commitment 38). Undertaking such activities within a bunded area is required under condition H1.

Fulton Hogan has also committed to requiring tanker delivery drivers to remain at the truck at all times during refilling of the diesel, bitumen and hot oil tanks (Commitment 39) and requiring any servicing oils from plant and equipment to be removed by contractor in accordance with EPA Guidelines (Commitment 37).

The likely amounts of chemicals to be used in the laboratory, as detailed in section 5.12, are excluded from bunding requirements under condition H2 (less than 25L), however the proponent has committed to management within the laboratory, the maintenance of MSDS (commitment 42) which is considered appropriate to minimise any risk from the storage of chemicals at the site.

The installation and use of spill kits is required under condition H3, the proponent has committed to these being available at the refill point during refilling (Commitment 40) and the laboratory (Commitment 42). Spill management is further committed to by the proponent implementation of the Fulton Hogan Incident and Emergency Respond Flowchart – Chemical Oil and Fuel Spills (Commitment 41) and the Fulton Hogan Case and Management Action Procedure. Responding to any leaks or spills will be further supported through the requirements of G6. These actions are all considered satisfactory in managing any incidents.

Conclusion

Fulton Hogan will be required to comply with the relevant EER commitments detailed in the Evaluation section above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

G3 Commitments encompassing commitments 35-42

G6 Incident Response

G7 Incident Response Procedure

H1 Storage and handling of hazardous materials

H2 Hazardous materials (<250 litres)

H3 Spill kits

Details on the notification of incidents under Section 32 are provided in Schedule 3: Information of the permit’s environmental conditions. Information on the storage and handling of dangerous goods under relevant information is also provided in Schedule 3: Legal Obligations of the permits environmental conditions.

Disposal of spill material is considered in Issue 4 Waste Management of the EAR.

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Issue 3: Traffic Impacts

Description of potential impacts

The activity has the potential to increase traffic movements causing increased noise and dust issues and lack of amenity to local residents and other receptors.

The existing adjacent quarry operation has an estimated thirty (30) trucks coming to and from the site each day. With the asphalt plant operating next door an estimated twelve [six (6) trucks per day out and six (6) in empty] of the thirty (30) truck movements from the quarry will be for the delivery of aggregate to the asphalt plant.

In addition there will be the occasional delivery truck (sand, cement) delivering input product on an as required basis. By having the asphalt plant located adjacent to the quarry (which is providing the aggregate for the asphalt manufacturing process) truck traffic will be effectively reduce by a third from having the plant located at other locations closer to Burnie or the Port.

All traffic will enter and exit the site via the Quarry Access Road. When leaving the site trucks will turn right on Circular Road and then on to Ridgley Highway and follow the designated truck route to the Burnie Port and other locations.

Management measures proposed in EER

According to section 5.10.2 of the EER, traffic management at the site will be implemented in accordance with the following:

the Fulton Hogan East Ridgley Mobile Asphalt Plant EMP (refer Appendix 3 of the EER).

The proponent has also committed to ensuring that all traffic will enter and exit the site via the Quarry Access Road (commitment 32) and that prior to the commencement of an asphalt processing and pouring campaign surrounding residents and the Ridgley Primary School will be notified to advise of truck movements and to be aware of this during school pick up and drop off times (Commitment 33).

Public and agency comment

None

Evaluation

The number of vehicles, particularly trucks, entering and exiting the site and the Quarry Access Road is expected to increase with the operation of the asphalt plant. However, its location adjacent to the quarry will allow aggregate to be delivered directly to the plant across a road with limited access, reducing the overall vehicles accessing the plant from Circular Road and Ridgley Highway. The vehicles will also be using a designated truck route designed for use by large trucks to access the Burnie Port and using the Quarry Access Road which has already been accessed as suitable for truck and other vehicle movements as part of its licence to operate. Commitments 32 and 33 and the implementation of the EMP are considered appropriate to manage traffic issues.

Conclusion

Fulton Hogan will be required to comply with the relevant EER commitments detailed in the Evaluation section above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

G3 Commitments encompassing commitments 32 and 33

Air and Noise emissions which are also relevant to traffic management are considered in Key Issues 1 and 2, respectively.

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Issue 4: Weed Management

Description of potential impacts

The construction and operation of the asphalt plant has the potential to cause the spread of weeds, particularly through vehicular movements.

According the Natural Values Atlas, there are no records of declared weeds found within 1 km of the site. There are no records of priority weeds found within 1km of the site. According to the EER, the area for the plant will be raised (made proud) and the surface will be constructed of crushed rock creating a hard stand area. Vehicles will enter the site off a sealed surface and drive onto a crushed rock hardstand pavement. All other vehicular movements will occur on established roads on and off-site.

The asphalt plant will be operational for a period of 18 months and then the land returned to the land owner, with the hardstand area in place.

Management measures proposed in EER

According to Section 5.1 of the EER, the site will be established on a gravel hard stand area thereby restricting weed growth. In addition weed control will be implemented throughout the operation of the plant to prevent the establishment and spreading of weeds on and off the site. Trucks coming onto the site will enter the site from the quarry access road and will only drive on the gravel hard stand area.

The site will be monitored as part of routine environmental inspections for any potential import of weeds and these shall immediately be treated if identified. This is reflected in commitment 2 of the EER.

Public and agency comment

None

Evaluation

Based on the information provided in the EER it is unlikely that the construction and operation of the asphalt plant will cause the spread of weeds.

The EER states that the site will be monitored for weeds as part of routine environmental inspection and will be treated immediately if identified. This commitment (C2) will support compliance with weed management condition OP1.

Conclusion

Fulton Hogan will be required to comply with commitment 2 of the EER as detailed above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

G3 Commitments encompassing commitment 2

OP1 Weed Management

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Issue 5: Flora, fauna and habitat

Description of potential impacts

Impacts to threatened flora, fauna or vegetation/ecological communities may occur from the construction and operation of the asphalt plant.

The vegetation classification on the site is (FAG) Agricultural, urban and exotic vegetation and surrounding areas are (FUM) Extra urban miscellaneous and agricultural, urban and exotic.

The site is located within the Emu River Catchment Area. However there are no creeks or streams running through the property.

No threatened flora, fauna or vegetation communities are located on the site. Approximately 350 metres to the North is a 6.7 hectare area of Eucalyptus viminalis wet forest that is classified a

threatened community. There are no records of threatened flora or non‐threatened flora of conservation significance within 1 km of the site.

According to the Natural Value Atlas there are no known cases of threatened fauna within 1km of the site, however there is the potential for seven (7) threatened fauna species within 1 km of the site. Given that the prosed site is grassed vacant agricultural land it is considered unlikely that it is suitable habitat for any of these species and that potential for these species in the area is likely attributable to Pet River and surrounding Riparian areas and vegetation approximately 350m to the north of the site.

There are no records of raptor nests or sightings within 1km of the site and there are no records

of non‐threatened fauna of conservation significance found within 1km of the site.

Management measures proposed in EER

According to Section 5.1 of the EER no native vegetation or potential habitat cleared or disturbed in the establishment and/or operation of the mobile asphalt plant.

In the event that threatened fauna is encountered during the operation of the asphalt plant, Fulton Hogan shall notify applicable agencies for proposed actions of management. This is reflected in commitment 1 of the EER.

Public and agency comment

None

Evaluation

Based on the information provided in the EER, the potential for impacts to threatened flora, fauna or vegetation communities or flora and fauna of conservation significance is considered unlikely.

Conclusion

No management measures or conditions required.

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Issue 6: Waste Management

Description of potential impacts

Inappropriate disposal of general waste during construction and inappropriate disposal of general and solid waste during operation could cause contamination of land or water.

Management measures proposed in EER

According to the Waste Management Plan in section 5.8.2 of the EER, the waste hierarchy AVOID‐ REDUCE‐ REUSE‐ RECYCLE will be used by the site. This is reflected in commitment 24 of the EER.

The following general waste management practices will also be implemented at the site during operation of the plant:

A bin shall be maintained in the site office to ensure safe storage and disposal of any waste generated on the site (commitment 25 of the EER);

All waste disposed of from the site shall be taken to an appropriate facility in accordance with EPA guidelines (commitment 28 of the EER);

Use electronic means of communication where ever possible to reduce paper waste;

All sediment waste is to be placed in gravel stockpile (commitment 26 of the EER).

All used spill material is to be disposed of in accordance with EPA guidelines (commitment 27 of the EER);

Maintenance will be undertaken by mobile service companies who will take their waste; and

Promote [re]use of asphalt within product to increase recycling opportunities

Waste management at the site will be implemented in accordance with the following:

Fulton Hogan East Ridgley Mobile Asphalt Plant EMP (refer Appendix 3 of the EER).

Fulton Hogan Waste Management Procedure.

Fulton Hogan Resource Use Procedure.

Also of note is that the amenities at the quarry will be used by asphalt plant personnel, therefore management of effluent from toilets is not required on-site (Section 1.8 of the EER).

Public and agency comment

None

Evaluation

Limited general waste is expected to be generated during operation of the plant. Commitments 25 and 28 are considered appropriate to manage this issue. The collection of sediment waste and reuse as part of the gravel supply (commitment 26) is considered consistent with the waste hierarchy and appropriate in the event of sediment creation through stormwater. The commitment to compliance with EPA guidelines in management of spill material is also considered appropriate (Commitment 27). The implementation of the EMP and relevant procedures is considered sufficient to minimise any environmental risks.

Conclusion

Fulton Hogan will be required to comply with the relevant EER commitments detailed in the Evaluation section above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

G3 Commitments encompassing commitments 25-28

The waste management hierarchy detailed are provided as information within Schedule 3: Information of the permit’s environmental conditions. Stormwater impacts and management are considered in Issue 1 of the EAR. Hazardous materials impacts and management are considered further in Issue 2 of the EAR.

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Issue 7: Decommissioning and Rehabilitation

Description of potential impacts

Cessation of the activity and the demolition of facilities may cause impacts to the environment.

Management measures proposed in EER

According to Section 5.17 of the EER, rehabilitation of the site following completion of all asphalt production activities will include:

Removal of all associated plant and equipment including all materials and bunds (Commitment 54 of the EER).

The imported crushed rock base on which the plant had been placed will remain for use by the land owner for storage of farming equipment and supplies (Commitment 55 of the EER). This will ensure the sites continued use is consistent with the ‘Rural Resource’ zoning of the land allowing for continued primary industry and/or agricultural use.

The site will be subject to a complete site contamination assessment upon closure of the asphalt plant (Commitment 56 of the EER). Any identified contamination will be appropriately remediated either onsite using land farming techniques and or disposed off-site at an appropriately licensed waste facility in accordance with EPA requirements.

Decommissioning of the Plant will be managed in accordance with the following:

Fulton Hogan East Ridgley Mobile Asphalt Plant EMP (refer Appendix 3 of the EER).

Public and agency comment

None

Evaluation

Decommissioning of plant and equipment, as well as stabilising land surfaces and removal or mitigation of all environmental hazards or land contamination are required under standard condition DC2. The management of decommissioning activities will be further supported through conditions DC1 in requiring notification of cessation and DC3 in requiring notification of temporary suspension to allow appropriate land management.

The on-going use of the site after decommissioning will be considered by the Burnie City Council as part of their assessment of the development application under the Land Use Planning and Approvals Act 1993.

Conclusion

Fulton Hogan will be required to comply with the relevant EER commitments as detailed in the Evaluation section above.

Fulton Hogan will be required to comply with the following standard (generic) conditions:

DC1 Notification of cessation

DC2 Rehabilitation following cessation

DC3 Temporary suspension of activity

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8 Report conclusions

This assessment has been based on the information provided by Fulton Hogan, in the permit application, EER, EER Supplement and in correspondence and discussion between the EPA Division, Fulton Hogan and Fulton Hogan’s representatives. This assessment has incorporated specialist advice provided by EPA Division scientific specialists and regulatory staff and other government agencies. This assessment has taken into account issues raised in public submissions. It is concluded that:

1. the RMPS and EMPCS objectives have been duly and properly pursued in the assessment of the proposal; and

2. the assessment of the proposed activity has been undertaken in accordance with the Environmental Impact Assessment Principles.

It is concluded that the proposed activity is capable of being managed in an environmentally acceptable manner such that it is unlikely that the objectives of the Environmental Management and Pollution Control Act 1994 (the RMPS and EMPCS objectives) would be compromised, provided that the Permit Conditions - Environmental No. 9082 appended to this report are imposed and duly complied with, including commitments made by the proponent in the EER and EER Supplement.

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10 References

EnviroRisk Management Pty Ltd, Environmental Effects Report, Fulton Hogan, Proposed Mobile Asphalt Plant, A leased part of 195 Circular Road, East Ridgley, TAS dated 26 August 2014. EnviroRisk Management Pty Ltd, Supplementary Report to Submitted EER (Permit Application DA 2014/87), dated 27 October 2014.

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11 Appendices

Appendix 1 Summary of public and agency submissions Appendix 2 Permit conditions, includes Attachment 2 - EER commitments

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Appendix 1

Appendix 1 Summary of public and agency submissions

A. Public representations

Representation No.

EER section no.

Issue Comment Further information required by EPA

Environmental

1 5.6 Air emissions impacting local and regional water supplies

Asphalt fumes contain carcinogenic materials (including hydrogen sulphide, benzene, chromium, formaldehyde, polycyclic aromatic hydrocarbons (PAHs), cadmium, and arsenic), exposure to which can cause a public health risk.

Concerned that family will be exposed in air and water supply.

Concerned main water supply for Burnie (Pet Reservoir) could be impacted.

Review air modelling and results/conclusions and address exposure concerns to air and water supply at 168 Circular Road, East Ridgley and the Burnie water supply (Pet Reservoir).

B. EPA Division comments

Issue EER section no.

Comment Further information required by EPA

Air 5.6 The adapted fugitive emission rates seem to be unusually low compared with other available literature data.

It is expected that the emissions from the stack rather than fugitive emissions would be the major source of odour.

Clarify the reasons for the low fugitive emission rates and confirm the major source of odour.

Air 5.6 Given the predicted (westerly) wind direction, the isopleth equivalent to the criterion of 2 OU level (at the 99.5th percentile concentration, 1 hour average) has rather unexpected shape and location with respect to the location of the proposed plant. It would be appreciated if the modeller could provide reason for such results.

Provide reasons for the unexpected isopleth shape and if an error provide revised figures with correct isopleths and amended conclusions (if relevant).

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Appendix 2

Appendix 2 Permit conditions - Environmental

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