Town Planning, Agricultural & Environmental Consultants T ...manildra.com.au/documents/community/2008 Ethanol... · Associate: Colin Stoddart, Cert. TCP (NSW), Ass. Dip. TCP, MPIA

ENVIRONMENTAL ASSESSMENT REPORT

Town Planning, Agricultural & Environmental Consultants

Prepared for

SHOALHAVEN STARCHES PTY LTD

August 2008

ENVIRONMENTAL ASSESSMENT REPORT

MAJOR PROJECT – PART 3A

ENVIRONMENTAL PLANNING AND

ASSESSMENT ACT 1979

PROPOSED ETHANOL PRODUCTION UPGRADE

INCLUDING PROPOSED ODOUR REDUCTION AND

WASTE WATER TREATMENT MEASURES FOR

EXISTING SHOALHAVEN STARCHES OPERATIONS

CCCC SSSS PPPP LLLLCCCC SSSS PPPP LLLL

CCCCOWMAN OWMAN OWMAN OWMAN SSSSTODDART TODDART TODDART TODDART PPPPTY TY TY TY LLLLTDTDTDTD

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SHOALHAVEN STARCHES (MANILDRA GROUP)

BOLONG ROAD

BOMADERRY

Town Planning, Agricultural & Environmental Consultants

Peter Cowman, B.Sc.Agr., M.A.I.A.S.T. Stephen Richardson, M.App.Sc., B.T.P., Grad. Dip. Env. Mgt, C.P.P., MPIA Stuart Dixon, B.Urb & Reg Plan, C.P.P., MPIA Associate: Colin Stoddart, Cert. TCP (NSW), Ass. Dip. TCP, MPIA

The Holt Centre, 31 Kinghorne Street, Nowra Telephone (02) 4423 6198 (02) 4423 6199 Fax (02) 4423 1569

PO Box 738, Nowra NSW 2541 www.cowmanstoddart.com.au

Email – [email protected]

COWMAN STODDART PTY LTD

PROPOSED ETHANOL PRODUCTION UPGRADE

INCLUDING PROPOSED ODOUR REDUCTION

AND WASTE WATER TREATMENT MEASURES

FOR EXISTING SHOALHAVEN STARCHES OPERATIONS

SHOALHAVEN STARCHES (MANILDRA GROUP)

BOLONG ROAD, BOMADERRY

Ref. 07/34

Environmental Assessment Report Shoalhaven Starches Pty Ltd

Proposed Ethanol Production Upgrade, Bolong Road, Bomaderry

Cowman Stoddart Pty Ltd Ref. 07/34 - August 08

CERTIFICATION OF ENVIRONMENTAL ASSESSMENT PREPARED PURSUANT TO PART 3A OF THE ENVIRONMENTAL PLANNING

AND ASSESSMENT ACT 1979

ENVIRONMENTAL ASSESSMENT PREPARED BY Name: S. D. Richardson

Qualifications: M. Appl. Sc., B.T.P., Grad. Dip. Env. Mgt,

CPP, MPIA

Address: Cowman Stoddart Pty Ltd 31 Kinghorne Street NOWRA NSW 2541

in respect of

PROJECT TO WHICH PART 3A APPLIES Proponent Name: Shoalhaven Starches Pty Ltd Proponent Address: Land to be developed: Address Bolong Road, Bomaderry Lot No. DP/MPS, Vol/Fol etc. Various parcels Proposed Development: Proposed ethanol production upgrade including

proposed odour reduction and waste water treatment measures for existing Shoalhaven Starches operations

Environmental Assessment An Environmental Assessment is attached

Certification I certify that I have prepared this environmental

assessment and to the best of our knowledge

• It has been prepared in accordance with Section 75E of the Environmental Planning and Assessment Act 1979,

• The information contained in the environmental Assessment is neither false nor misleading.

Signature:

Name: S. D. Richardson

Date: August, 2008

COWMAN STODDART PTY LTD COWMAN STODDART PTY LTD

CONTENTS

1.0 INTRODUCTION ................................................................................................ 1

1.1 BACKGROUND TO PROJECT............................................................................ 1

1.2 THE PROPOSAL.................................................................................................. 2

1.2.1 Environmental Audit........................................................................................ 3

1.3 PART 3A OF THE ENVIRONMENTAL PLANNING & ASSESSMENT ACT 1979 ................................................................................ 3

2.0 BACKGROUND ................................................................................................. 5

2.1 PRODUCTION PROCESSES.............................................................................. 5

2.2 OPERATING WORKFORCE................................................................................ 6

2.2.1 Operations ...................................................................................................... 6

2.2.2 Workforce........................................................................................................ 6

2.3 RAW MATERIALS ................................................................................................ 7

2.4 HISTORY OF DEVELOPMENT ON THE SITE ................................................... 8

3.0 THE SUBJECT SITE AND SURROUNDS ....................................................... 13

3.1 THE SITE AND ITS SURROUNDING LOCALITY............................................. 13

4.0 CONSULTATION ............................................................................................. 17

4.1 INTRODUCTION ................................................................................................ 17

4.2 PRELIMINARY ENVIRONMENTAL ASSESSMENT......................................... 17

4.3 GOVERNMENT AGENCY CONSULTATION.................................................... 17

4.4 COMMUNITY CONSULTATION ........................................................................ 18

4.5 REVIEW OF DRAFT ENVIRONMENTAL ASSESSMENT ................................ 22

4.6 ABORIGINAL STAKEHOLDER CONSULTATION............................................ 22

5.0 THE PROPOSED DEVELOPMENT ................................................................. 23

5.1 OBJECTIVES OF THE ETHANOL UPGRADE.................................................. 23

5.2 ENVIRONMENTAL AUDIT................................................................................. 23

5.3 JUSTIFICATION FOR PROJECT ...................................................................... 25

5.4 SUMMARY OF PROPOSAL .............................................................................. 28

5.5 THE STARCH PLANT ........................................................................................ 31

5.6 THE GRAIN PLANT............................................................................................ 32


5.7 ETHANOL PLANT .............................................................................................. 32

5.8 WASTE WATER TREATMENT AND DISPOSAL.............................................. 35

5.8.1 Stillage Recovery.......................................................................................... 35

5.8.2 Waste Water Disposal .................................................................................. 40

5.9 PROPOSED NEW PACKING PLANT AND CONTAINER LOADING AREA .......................................................................... 45

5.10 ENERGY AND UTILITIES .................................................................................. 48

5.10.1 Energy........................................................................................................... 48

5.10.2 Water Supply ................................................................................................ 49

5.10.3 Pipelines ....................................................................................................... 50

6.0 STATUTORY APPROVAL CONTEXT............................................................. 51

6.1 COMMONWEALTH LEGISLATION ................................................................... 51

6.1.1 Environment Protection & Biodiversity Conservation Act............................. 51

6.1.2 Commonwealth Aboriginal Heritage Legislation........................................... 53

6.2 STATE LEGISLATION........................................................................................ 54

6.2.1 Environmental Planning & Assessment (EP&A) Act 1979 ........................... 54

6.2.2 Threatened Species Conservation Act ......................................................... 59

6.2.3 Protection of the Environment Operations Act ............................................. 61

6.2.4 Water Management Act 2000....................................................................... 62

6.2.5 Native Vegetation Act 2003 .......................................................................... 62

6.2.6 The Roads Act 1993 ..................................................................................... 63

6.2.7 National Parks and Wildlife Act 1975 ........................................................... 64

6.3 STATE ENVIRONMENTAL PLANNING POLICIES .......................................... 65

6.3.1 SEPP No. 14 - Coastal Wetlands ................................................................. 65

6.3.2 SEPP No. 33 - Hazardous and Offensive Development .............................. 66

6.3.3 SEPP No. 71 - Coastal Protection................................................................ 66

6.3.4 SEPP (Major Projects) 2005......................................................................... 68

6.3.5 SEPP (Infrastructure) 2007........................................................................... 68

6.3.6 NSW Coastal Policy...................................................................................... 70

6.3.7 Riparian Corridor Guidelines for Controlled Activities .................................. 71

6.3.8 Riparian Corridor Management Study Guidelines........................................ 72


6.4 REGIONAL ENVIRONMENTAL PLANS AND STRATEGIES........................... 73

6.4.1 Illawarra Regional Environmental Plan......................................................... 73

6.4.2 South Coast Regional Strategy .................................................................... 76

6.5 SHOALHAVEN LOCAL ENVIRONMENTAL PLAN 1985 .................................. 78

6.6 DEVELOPMENT CONTROL PLANS (DCPS) ................................................... 86

6.7 APPROVAL REGIME FOR PROJECT .............................................................. 90

7.0 KEY ISSUES .................................................................................................... 91

7.1 AIR QUALITY (INCLUDING ODOUR) ASSESSMENT ..................................... 91

7.1.1 Environmental Audit...................................................................................... 92

7.1.2 Emissions Inventory...................................................................................... 96

7.1.3 Assessment of Air Quality Impacts............................................................. 106

7.1.4 Conclusions ................................................................................................ 124

7.2 GREENHOUSE GAS EMISSIONS .................................................................. 126

7.2.1 Energy and Greenhouse Analysis .............................................................. 127

7.2.2 Greenhouse Emission Reduction ............................................................... 135

7.3 WASTEWATER TREATMENT......................................................................... 138

7.3.1 Existing Wastewater Treatment Processes................................................ 138

7.3.2 Wastewater Treatment and Fitness for Purpose of Treated Effluent. ........ 140

7.4 EFFLUENT IRRIGATION AND STORAGE ..................................................... 154

7.4.1 Local Environment ...................................................................................... 154

7.4.2 Wastewater ................................................................................................. 155

7.4.3 Soil Salinity ................................................................................................. 159

7.4.4 Plant nutrition.............................................................................................. 167

7.4.5 Water Balance Analyses............................................................................. 173

7.4.6 Irrigation Management Plan........................................................................ 175

7.4.7 Implementation of Irrigation Program ......................................................... 178

7.4.8 Summary and Conclusions......................................................................... 181

7.5 WATER AND SOILS......................................................................................... 183

7.5.1 Water Supply .............................................................................................. 183

7.5.2 Stormwater Management ........................................................................... 184

7.5.3 Acid Sulphate Soils..................................................................................... 188

7.5.4 Contamination............................................................................................. 192


7.6 NOISE ............................................................................................................... 198

7.6.1 Ethanol Upgrade Acoustic Design Targets................................................. 198

7.6.2 Acoustic Assessment.................................................................................. 201

7.6.3 Construction Noise ..................................................................................... 208

7.6.4 Conclusion .................................................................................................. 210

7.7 TRANSPORT, ACCESS AND PARKING ........................................................ 211

7.7.1 Local Traffic Network .................................................................................. 211

7.7.2 Existing Traffic Summary............................................................................ 214

7.7.3 Regional Access ......................................................................................... 215

7.7.4 Site Access ................................................................................................. 216

7.7.5 Pedestrian Access ...................................................................................... 218

7.7.6 Traffic Generation ....................................................................................... 219

7.7.7 Light Vehicle Trip Distribution..................................................................... 220

7.7.8 Heavy Vehicle Trip Distribution................................................................... 220

7.7.9 Rail Access ................................................................................................. 223

7.7.10 Parking........................................................................................................ 224

7.7.11 Council, RTA and Community Issues......................................................... 225

7.7.12 Site Access ................................................................................................. 230

7.7.13 Traffic Generation ....................................................................................... 233

7.7.14 Future Intersection Performance ................................................................ 236

7.7.15 Minimising General Traffic Impacts ............................................................ 237

7.7.16 Parking........................................................................................................ 239

7.7.17 Conclusions and Recommendations .......................................................... 240

7.8 HAZARDS AND RISK....................................................................................... 242

7.9 RIVER BANK STABILITY AND RIPARIAN MANAGEMENT........................... 248

7.9.1 Geomorphology .......................................................................................... 248

7.9.2 Existing Riparian Health ............................................................................. 251

7.9.3 Potential Impacts ........................................................................................ 260

7.9.4 Conclusion .................................................................................................. 262

7.9.5 Recommendations...................................................................................... 263

7.10 FLOODING ....................................................................................................... 266

7.10.1 Hydraulic Impacts ....................................................................................... 267


7.10.2 Economic, Social and Environmental Impacts ........................................... 278

7.10.3 Mitigation Measures.................................................................................... 279

7.11 WASTE MANAGEMENT .................................................................................. 284

7.11.1 Legal and Regulatory Requirements .......................................................... 284

7.11.2 Waste Identification and Classification ....................................................... 285

7.11.3 Environmental Management Plan .............................................................. 286

7.12 VISUAL IMPACT............................................................................................... 291

7.13 FLORA AND FAUNA ........................................................................................ 303

7.13.1 Description of the Vegetation...................................................................... 303

7.13.2 Plant Species Recorded ............................................................................. 304

7.13.3 Fauna Habitat ............................................................................................. 305

7.13.4 Impact of the Proposed Upgrade................................................................ 307

7.13.5 Conclusion and Recommendations of Flora and Fauna Assessment........ 307

7.14 HERITAGE AND ARCHAEOLOGICAL ISSUES ............................................. 308

7.14.1 Aboriginal Archaeology............................................................................... 308

7.14.2 European Heritage...................................................................................... 318

8.0 STATEMENT OF COMMITMENTS – ENVIRONMENTAL MANAGEMENT..320

8.1 LEGISLATIVE REQUIREMENTS..................................................................... 320

8.1.1 Legislation and Regulations........................................................................ 320

8.1.2 Policies and Guidelines .............................................................................. 321

8.2 APPROVALS, PERMITS AND LICENCES...................................................... 321

8.3 SPECIFIC COMMITMENTS............................................................................. 322

8.3.1 Construction Environmental Management Plan ......................................... 322

8.3.2 General Environmental Management......................................................... 323

8.3.3 Soil and Water Management ...................................................................... 324

8.3.4 Noise and Vibration Management .............................................................. 326

8.3.5 Traffic, Access and Parking........................................................................ 329

8.3.6 Air Quality Management ............................................................................. 330

8.3.7 Odours ........................................................................................................ 331

8.3.8 Greenhouse Gas Emissions....................................................................... 332

8.3.9 Waste and Chemical Management ............................................................ 333

8.3.10 Waste Water and Irrigation Management................................................... 335

8.3.11 Hazard and Risk Management ................................................................... 336


8.3.12 Flooding ...................................................................................................... 337

8.3.13 Riparian and Riverbank Stability ................................................................ 338

8.3.14 Weed Management .................................................................................... 339

8.3.15 Stock Exclusion .......................................................................................... 340

8.3.16 Vegetation Management Plan .................................................................... 340

8.3.17 Visual Amenity ............................................................................................ 341

8.3.18 Site Contamination and Acid Sulphate Soils .............................................. 342

8.3.19 Flora and Fauna ......................................................................................... 344

8.3.20 Aboriginal Heritage ..................................................................................... 344

9.0 CONCLUSION................................................................................................ 346


FIGURES

Figure 1 Site Locality Plan

Figure 2 Plan of Existing Factory Site Depicting Existing Plant as well as Plant that has Previously been Approved but not Yet Built

Figure 3 Site Plan Depicting Proposed Additions to Factory Site

Figure 4 Configuration of Wet Weather Storage Pond No. 7

Figure 5 Elevation Details of the Proposed Plant Upgrade

Figure 6 Flow Chart Depicting the Proposal in Terms of the Processes at the Site

Figure 7 Diagram detailing the Water Treatment Process associated with the Proposal

Figure 8 Mass Balance and Process Flow

Figure 9 Planning Provisions Applying to the Site

Figure 10 Factory Odour Impact Model – Scenario A (Existing Factory)

Figure 11 Factory Odour Impact Model – Scenario B (Existing Factory with Stage 1 Odour Control)

Figure 12 Factory Odour Impact Model – Scenario C (Factory with Stage 1 Odour Control and Ethanol Upgrade)

Figure 13 Factory Odour Impact Model – Scenario D

(Factory with Stage 2 Odour Control and Ethanol Upgrade)

Figure 14 Factory Odour Impact Model – Scenario E (Factory with Stage 3 Odour Control and Ethanol Upgrade)

Figure 15 Factory Odour Impact Model – Scenario F (Existing Factory without DDG Plant)

Figure 16 Factory and Environmental Farm Odour Impact Model – Scenario G

Figure 17 Maximum Predicted Ground Level PM10 Concentrations (24-Hour Average)

Figure 18 Flow Diagram Depicting the Proposed BVF/SO Basin System

Figure 19 Flow Diagram Depicting the Proposed MBR/RO System

Figure 20 Diagrammatic View of MBR/RO Plant

Figure 21 The Time Trend in the Root-Density Weighted EC Concentrations


FIGURES (continued)

Figure 22 The relation between the mean annual ECw between 1995 and 2007 and the corresponding annual percolation (A), irrigation

volume (B), and TDS load (C).

Figure 23 The Monthly Irrigation Volumes in Dry, Medium and Wet Months

Figure 24 Average Distribution of Daily Irrigation Volumes for the Last 3 Years

Figure 25 Acid Sulfate Soil Risk Map

Figure 26 Transport Routes Around the Site

Figure 27 Traffic Access Arrangements

Figure 28 Plan identifying Car Parking over the Factory Site

Figure 29 Individual Fatality Risk Profile for the Shoalhaven Operation

Figure 30 All Works Since 1990 Extreme Flood

Figure 31 All Works Since 1990 1% AEP Flood



Figure 34 Vantage Points for Plates


ANNEXURES

Annexure A Director-General’s Requirements for the Preparation of this Environmental Assessment - Addressed

Annexure B Government Agency Requirements - Addressed

Annexure C Government Agency Submissions in response to Draft Environmental Assessment

Annexure D Aboriginal Impact Assessment prepared by South East Archaeology Pty Ltd

Annexure E Flora & Fauna Assessment prepared by Kevin Mills & Associates

Annexure F Preliminary Hazard Analysis prepared by GHD Pty Ltd

Annexure G Traffic Impact Assessment prepared by Christopher Stapleton Consulting Pty Ltd

Annexure H NSW Coastal Policy 1997 Compliance Checklist for the Preparation of Development Proposals

Annexure I Riparian Assessment prepared by Coffey Environments Pty Ltd

Annexure J Environmental Site Assessment prepared by Coffey Environments Pty Ltd

Annexure K Hydraulic, Economic and Social Impacts of Flooding prepared by Webb McKeown & Associates Pty Ltd

Annexure L Waste Management Report, prepared by Stephenson Environmental Management Australia

Annexure M Air Quality Assessment Report

prepared by GHD Pty Ltd

Annexure N Greenhouse Gas Assessment prepared by GHD Pty Ltd

Annexure O(i) Agronomic Investigations – Fitness for Purpose of Treated Wastewater prepared by Dr John Murtagh, Roy Lawrie and Glenys Lugg

Annexure O(ii) Agronomic Investigations – Fitness for Purpose of Treated Wastewater

Supplementary Information including Monitoring Program prepared by Dr John Murtagh, Roy Lawrie and Glenys Lugg


ANNEXURES (continued)

Annexure P Environmental Management Report

prepared by GHD Pty Ltd

Annexure Q(i) Acoustical Assessment prepared by The Acoustic Group

Annexure Q(ii) Acoustic Assessment of Site Operations prepared by The Acoustic Group

Annexure R Report on Community Consultation prepared by Twyford Consulting




i

EXECUTIVE SUMMARY

Shoalhaven Starches is a member of the Manildra Group of companies. The Manildra Group

is a wholly Australian owned business and the largest processor of wheat in Australia. It

manufactures a wide range of wheat based products for food and industrial markets both

locally and internationally.

The Shoalhaven Starches factory located on Bolong Road, Bomaderry produces a range of

products for the food, beverage, confectionary paper and motor transport industries including:

starch, gluten, glucose and ethanol. During these processes, treated waste water is produced

and spray irrigated onto pastures of the Company’s Environmental Farm, which comprises

over 1000 ha of land situated to the north of the factory site.

In 2003 the Minister for Planning approved a development application (DA223) for the

Company’s Pollution Reduction Program No. 7. This approval which, included the extension

of the company’s irrigation of waste water onto additional farm lands, also enabled ethanol

production at the plant to increase from 100 million litres per year to 126 million litres per year.

The use of ethanol as a fuel (or fuel additive) has many benefits including:

• it is a renewable fuel and lessens reliance on fossil fuels;

• it reduces greenhouse gas emissions and other air pollutants such as carbon monoxide

and particulates;

• it reduces imports of oil and stimulates regional and local economies if produced locally.

Given the above benefits, the Federal and State Governments have introduced a range of

initiatives to encourage the increased use of ethanol as a fuel additive.

The NSW Government has recently mandated the blending of 2% of ethanol into the total

volume of petrol sold in NSW as a first step towards a10% ethanol content by 2011.

As a result, the Manildra Group is planning to increase its ethanol production capacity to meet

the expected increase in demand for ethanol arising from these initiatives by upgrading the

existing ethanol plant, located at the Shoalhaven Starches Plant at Bomaderry.

Shoalhaven Starches plans to increase ethanol production at its Bomaderry Plant from the

current approved 126 million litres per year to 300 million litres per year.

To accomplish the increase in ethanol production, this proposal will require some plant

upgrades and an increase in the throughput of raw materials, principally flour and grain.




ii

The following additions and alterations are proposed to the existing factory site as part of the

ethanol upgrade:

• the provision of an additional dryer for the starch/gluten plant;

• additional equipment and storage vessels for the ethanol plant including 3 additional

fermenters, additional cooling towers and molecular sieves;

• upgrades to the Stillage Recovery Plant including 6 additional Dried Distillers Grains

Syrup (DDGS) dryers; 10 decanters; chemical storage and two evaporators. The

proposal also includes the installation of a DDGS Pellet Plant within this part of the site;

and,

• the establishment of a new packing plant, container loading area and a rail spur line. The

establishment of this facility on the northern side of Bolong Road will require the provision

of an overhead bridge structure to allow product and safe pedestrian movement across

Bolong Road.

In addition to the upgrade to the Company’s ethanol plant, Shoalhaven Starches also propose

to undertake comprehensive odour reduction measures for both the existing factory site and

the works associated with this proposal. In 2006, the Land and Environment Court required

Shoalhaven Starches to engage a suitably qualified person to conduct a comprehensive

environmental audit of the factory and Environmental Farm. This environmental audit has

been completed (by GHD Pty Ltd). The audit report includes a number of recommendations

for the implementation of works to the existing site, some of which require development

approval. These works have therefore been included with this project. The Department of

Environment and Climate Change (DECC) have advised that the recommendations of the

audit report will need to be implemented prior to the operation of the ethanol upgrade project.

The proposal also includes the biological treatment of waste waters from the factory site. It is

proposed to re-use over half the treated waste water within the factory processes and the

remainder irrigated onto the Company’s Environmental Farm.

The project will also involve an upgrade to services to the site such as electric power, natural

gas, etc. The proposal includes the provision of an additional gas fired boiler and a gas fired

co-generation plant.

The proposed development is a project within the terms of Part 3A of the Environmental

Planning & Assessment Act 1979. It comes within Item 3 to Schedule 1 of the State

Environmental Planning Policy (Major Projects) 2005. In this regard, it is a development

having a capital investment more than $30 million for the purpose of an agricultural produce

industry and food and beverage processing.




iii

The estimated capital cost of the expansion of the plant is approximately $200 million.

The project will create an estimated peak construction workforce of up to 150 jobs during an

estimated12 month construction phase. Operation of the upgraded plant will not only assist in

sustainably maintaining the existing workforce currently comprising around 250 direct

employees; but will also create up to an estimated 25 additional direct on-going positions on

the site.

The preparation of this Environmental Assessment has been undertaken following consultation

with relevant Government agencies, including:

• The Department of Planning

• The Department of Environmental and Climate Change.

• The Department of Water and Energy

• The Roads & Traffic Authority; and

• Shoalhaven City Council.

Community Consultation groups and Aboriginal stakeholders have been consulted.

This Environmental Assessment has been prepared to address issues raised by the

requirements of the Director-General of the Department of Planning as well as the issues

raised by government agencies and the local community.

The Environmental Assessment (EA):

• Considers relevant statutory and non-statutory requirements including the provisions of

State, Regional and Local planning provisions and strategies. The EA concludes the

proposal is consistent with these planning strategies and provisions.

• Assesses the impacts of the proposal on local air quality focussing on odours, particulate

emissions and greenhouse gas emissions. The EA includes a comprehensive air quality

assessment that addresses issues pertaining to odours with specific reference to the

timing and implementation of the findings of the Environmental Audit. The assessment

identifies odour sources and predicts odour emissions from the proposed expansion, and

models the cumulative odour impacts at the closest residential premises and describes

odour mitigation measures.

In terms of air quality all particulate emissions following the upgrade were assessed to be

within the limits prescribed by the relevant regulations. Modelling indicates that the

implementation of odour controls at the factory, and including the installation of a

wastewater treatment plant at the Environmental Farm will mitigate the potential for future

offensive odours beyond the boundary of the premises.




iv

The Environmental Assessment:

• Is also supported by a specific greenhouse gas assessment prepared by GHD which

includes a quantitative analysis of the emissions of the project; and a qualitative analysis of

the impacts of these emissions in accordance with the requirements of the Australian

Greenhouse Office’s “Factors and Methods Workbook” 2006. The assessment outlines

measures to reduce and/or offset emissions and includes an analysis of energy use.

• Includes an acoustic assessment prepared by The Acoustic Group. This assessment

details the noise impacts of the existing factory, identifies the additional noise sources

from the proposed expansion and assesses the cumulative noise impact at residences

both during construction and operation. The assessment also examines operational traffic

noise (both road and rail). The EA concludes that the proposal will not result in noise

levels generated from the overall site exceeding existing Environmental Protection

Licence requirements for the site.

• Addresses water management issues with respect to the identification of water supply,

consumption and waste streams. The EA details water supply including potable and non-

potable services. In addition the EA describes the proposed waste water treatment

process for the existing facility and the proposed expansion. In this regard the proposal

seeks to introduce biological treatment of wastewater generated from the factory which will

enable over half of the treated wastewater to be re-used within the factory production

processes. The remainder will be irrigated onto the Company’s Environmental Farm. The

quality of the wastewater that will be irrigated will also be significantly improved from that

currently irrigated; and the overall quantity will be reduced. The EA is supported by an

assessment prepared jointly by Agricultural Water Management; NSW Department of

Primary Industries; and Shoalhaven Starches; which concludes the treated waste water

and retentate from the wastewater treatment process will be suitable for farm irrigation.

• Includes an assessment of the proposal, carried out by Webb McKeown & Associates that

undertakes a flood risk analysis identifying impacts both in terms of the site and within the

broader locality. The EA concludes that the economic, social and environmental impacts

associated with increased flood levels associated with this proposal will not be significant.

In order to compensate for any potential adverse impacts of the existing and proposed

works, a range of management measures have been proposed to mitigate these impacts

on the northern floodplain. .

• Provides a Preliminary Hazard Analysis (PHA) prepared by GHD. The PHA was

completed in accordance with State Environmental Planning Policy No. 33, HIPAP No. 6

Guidelines for Hazard Analysis, and the Risk Criteria for Land Use Safety Planning given




v

in HIPAP No. 4. Individual Fatality Risk was calculated and the PHA demonstrates that

the risk is acceptable as all risk contours are in compliance with the relevant risk criteria of

HIPAP No. 4.

• Provides an assessment prepared by Christopher Stapleton Consulting of vehicle access,

traffic and parking characteristics of the proposal including the potential impacts on the

local and regional road network. This report assesses the cumulative impact of existing

traffic volumes and expansion related traffic on the existing road and rail network during

construction and operation; including capacity, safety, intersections, site access, and

parking.

The proposal will continue to utilise rail as the primary mode of transport, eliminating the

need for approximately 400 heavy vehicle trips per week. In addition whilst the proposal

will increase the number of trains servicing the site; due to the siting of the proposed

packing plant on the northern side of Bolong Road, the proposal will halve the number of

closures of Bolong Road at the existing railway crossing.

The proposal will generate up to an additional 88 vehicle trips daily to the local road

network, with a maximum peak hour generation of 8 vehicle trips. This is considered a

minor traffic increase which can be accommodated by proposed local road upgrades and

will have no significant impact on the local road network.

• Provides an assessment of the proposed works on the scenic qualities of the locality. In

particular the EA outlines measures to reduce the overall visual impact of works

associated with the proposal on the broader landscape. Of particular relevance is the

proposed overhead pedestrian and product bridge that will connect the existing factory

site to the proposed packing plant on the northern side of Bolong Road. Shoalhaven City

Council have given ‘in principle’ support to this structure subject to consideration being

given to its appearance. This is an important consideration given Bolong Road, and this

site, is a ‘gateway’ entrance to the Nowra/Bomaderry urban area.

• Outlines waste management measures incorporated within the site. In this regard the EA

is supported by a Waste Management Report prepared by Stephenson Environmental

Management Australia. This report describes waste generated at the site and methods of

disposal. Shoalhaven Starches currently has an existing Waste Management Standard

Operating Procedure in place as part of the Company’s Quality System. The proposed

expansion will require the current procedure/system to be amended where appropriate to

cope with the additional volume of waste.

• Addresses riverbank stability and riparian corridors and includes recommendations to

preserve the integrity of the adjoining banks of the Shoalhaven River. The EA is




vi

supported by a Riparian Assessment prepared by Coffey Environments. This assessment

includes recommendations for revegetation and enhancement works to improve bank

stability. It is also recommended that Shoalhaven Starches develop and implement a

Vegetation Management Plan.

• Examines the likelihood of occurrence of site contamination and acid sulphate soils; and

incorporates measures to mitigate the affects associated with disturbing such soils. The

EA is supported by an assessment carried out by Coffey Environments investigating the

presence of site contamination and Acid Sulphate Soils.

• Examines both non-Indigenous and Indigenous cultural heritage issues. The EA is

supported by an Aboriginal Heritage Assessment prepared by South East Archaeology.

This assessment concludes that the proposal will not have any significant impacts on any

items of Aboriginal heritage.

• Is also supported by Flora & Fauna Assessment prepared by Kevin Mills & Associates.

This assessment, which includes an analysis of impacts on critical habitats, threatened

species, populations and ecological communities and their habitats, concludes that the

proposal will not adversely impact threatened species or their habitats.

Following an assessment of the key issues associated with this proposal, this Environmental

Assessment concludes that the proposal is suitable for the site and this locality. The

Environmental Assessment includes a Statement of Commitments outlining environmental

management, mitigation and monitoring measures that should be implemented to minimise

potential impacts associated with the proposal.

The Minister’s approval is sought for the proposal.



Cowman Stoddart Pty Ltd Ref. 07/34 - August 08 Page 1

1.0 INTRODUCTION

1.1 BACKGROUND TO PROJECT

Shoalhaven Starches is a member of the Manildra Group of companies. The Manildra

Group is a wholly Australian owned business and the largest processor of wheat in

Australia. It manufactures a wide range of wheat based products for food and industrial

markets both locally and internationally.

The Shoalhaven Starches factory located on Bolong Road, Bomaderry produces a range

of products for the food, beverage, confectionary, paper and motor-transport industries

including: starch, glucose and ethanol. During these processes, treated waste water is

produced and spray irrigated onto pastures of the Company’s Environmental Farm,

which comprises over 1000 ha of land situated to the north of the factory site.

In 2003 the Minister for Planning approved a development application (DA223) for the

Company’s Pollution Reduction Program No. 7 and which included the extension of the

company’s irrigation of treated waste water onto additional lands. This approval also

enabled ethanol production at the plant to increase from 100 million litres per year to 126

million litres per year.

The use of ethanol as a fuel (or fuel additive) has many benefits including:


• it reduces greenhouse gas emissions and other air pollutants such as carbon

monoxide and particulates;

• it reduces imports of oil and stimulates regional and local economies if produced

locally.

Given the above benefits, the Federal and State Governments have introduced a range

of initiatives to encourage the increased use of ethanol as a fuel additive.

The NSW Government has recently mandated the blending of 2% of ethanol into the

total volume of petrol sold in NSW as a first step towards a10% ethanol content by 2011.

As a result, the Manildra Group is planning to increase its ethanol production capacity to

meet the expected increase in demand for ethanol arising from these initiatives by

upgrading the existing ethanol plant, located at the Shoalhaven Starches factory at

Bomaderry.

Shoalhaven Starches plan to increase ethanol production at its Bomaderry Plant from

the current approved 126 million litres per year to 300 million litres per year. To




accomplish the increase in ethanol production will require some plant upgrades and an

increase in throughput of raw materials, principally flour and grain.

In addition to the above, and following investigation of odour complaints in 2004, the

Department of Environment and Climate Change (DECC) successfully prosecuted

Shoalhaven Starches in the Land and Environment Court in 2006 for the emission of

offensive odours. The Land and Environment Court required Shoalhaven Starches to

engage a suitably qualified person to prepare a comprehensive environmental audit of

the facility and Environmental Farm. GHD Pty Ltd was subsequently engaged by

Shoalhaven Starches to undertake this audit. This audit has been completed and the

report has been submitted to the Court and the DECC. The audit recommended a range

of measures to mitigate the potential for future offensive odours beyond the boundary.

This proposal therefore includes those works recommended by this audit which require

development approval. Implementation of measures which do not require development

approval are currently underway.

1.2 THE PROPOSAL

Shoalhaven Starches plans to increase ethanol production at its Bomaderry plant from

the current approved 126 million litres per year to 300 million litres per year.


upgrades and an increase in processing of raw materials, principally flour and grain

1. The following additions and alterations are proposed to the existing factory site as

part of the ethanol upgrade:

• the provision of an additional dryer for the starch/gluten production plant;

• additional equipment and storage capacity for the ethanol plant including

3 additional fermenters, an additional molecular sieve and associated

additional cooling towers;

• upgrades to the Stillage Recovery Plant including 6 additional Dried Distillers

Grains Syrup (DDGS) dryers; 10 decanters and chemical storage; and two

evaporators. The proposal will also include the installation of a DDGS Pellet

Plant within this part of the site;

• the establishment of a new packing plant and container loading area (including

new railway spur line). The establishment of the new packing plant on the

northern side of Bolong road will require the construction of an overhead

bridge structure to allow product and safe pedestrian movement across

Bolong Road.




2. The proposal includes the biological treatment of waste waters from the factory

site. Over half the treated waste water will be re-used within the factory and the

remainder will be irrigated onto the Company’s Environmental Farm. The

biological treatment of factory waste water will require the adaption of Wet

Weather Storage Pond No. 7 currently under construction on the Company’s

Environmental Farm.

3. The project will also involve an upgrade to services to the site such as electric

power, natural gas, etc. The proposal includes the provision of an additional gas

fired boiler and a gas fired co-generation plant.

1.2.1 Environmental Audit

Following investigation of odour complaints in 2004, DECC successfully prosecuted

Shoalhaven Starches in the Land and Environment Court in 2006 for the emission of

offensive odours.

The Land and Environment Court judgement of 2 November 2006 required Shoalhaven

Starches to engage a suitably qualified person to conduct a comprehensive

environmental audit of the factory and Environmental Farm in order to identify and

quantify all odours generated by the operations, and to provide recommendations for the

improved management of odours. Shoalhaven Starches engaged GHD Pty Ltd to

conduct the environmental audit.

This environmental audit has been completed and a report of the audit has been

submitted to the Land and Environment Court and the DECC. The Audit Report includes

a range of recommendations for improvements to the Shoalhaven Starches factory and

Environmental Farm operations. In addition to which, the Company has agreed to a

Plan and Timetable to implement the recommendations of the Environmental Audit.

Many of the works associated with these recommendations do not require development

approvals and the Company has commenced to undertake these measures. A number

of the recommended works may require development approval. These works are

therefore included as part of this proposal. The recommendations of this Audit report will

need to be addressed prior to commencement of operation of the Ethanol Upgrade

project.

1.3 PART 3A OF THE ENVIRONMENTAL PLANNING & ASSESSMENT ACT 1979

The proposed development is a project within the terms of Part 3A of the Environmental

Planning & Assessment Act 1979. It comes within Item 3 to Schedule 1 of the State

Environmental Planning Policy (Major Projects) 2005. In this regard, it is a development




having a capital investment more than $30 million for the purpose of an agricultural

produce industry and food and beverage processing (ethanol plant).

The estimated capital cost of the expansion of the plant is approximately $200 million.

The project will create an estimated peak construction workforce of up to 150 jobs during

an estimated 12 month construction phase. Operation of the upgraded plant will not only

assist in sustainably maintaining the existing workforce at the plant currently comprising

around 250 employees; but is also expected to create up to an estimated 25 additional

on-going positions on the site.




2.0 BACKGROUND

2.1 PRODUCTION PROCESSES

The production process at the Shoalhaven Starches plant has developed over a number

of years. Originally the plant was primarily concerned with the production of starch and

gluten from flour. However the Company has pursued a number of technological

innovations particularly with respect to reducing the environmental impacts of the

Company’s operations. As a result Shoalhaven Starches has been moving towards a

“closed” system of production. Essentially this entails the efficient use of end products to

ensure wastage is reduced to a minimum.

The first step in the production process is the delivery of flour and grain, by rail, from the

Company’s flour mills at Manildra, Gunnedah and Narrandera. The trainloads are

brought into the plant via the switching yard at Bomaderry.

The Company has received approval from the Minister for Planning for the erection of a

flour mill on site to enable the milling of part of the Company’s flour requirements to be

processed directly on the site. The remainder of the Company’s flour requirement will

continue to be sourced from the Company’s off-site flour mills.

Flour is transferred via storage to the “wet end” of the plant where fresh water is added.

The subsequent mixing and separation process produces starch and gluten.

The gluten is dried to enable it to be packaged and distributed as a high protein food

additive for human consumption. This product is then taken from the site after

packaging for both local and export markets. The wastage from the starch process is

used for fermentation and distillation to produce ethanol.

The starch that is separated from the flour is either dried or remains in liquid form. The

dried and liquid starch is sold to the paper and food industries. The starch is used for

food, cardboard, paper and other industrial purposes. The wastage from the liquid

starch process is used in the ethanol production process.

Starch is also used in the production of syrups on the site. The syrups plant products

include glucose and brewer’s syrup. These are used for foods, chocolates,

confectionery, beer, soft drinks and fruit juice. The syrups plant also has some wastage

that is used in the ethanol process.

The wastage from the starch, gluten and syrup production processes are combined to

feed the fermentation and distillation stage of ethanol production. The outputs are fuel




and industrial grade ethanol. Industrial grade ethanol is used in producing

pharmaceuticals, printer’s ink and methylated spirits.

Ethanol production results in some solid and waste water wastage, which is processed

through the stillage recovery process plant (which was approved as part of PRP No. 7 in

2005). The waste solids are recovered as DDGS (Dried Distillers Grains Syrup), dried

and sold as a high protein cattle feed with the remaining water used for irrigation. The

waste water resulting from the ethanol production is pumped to holding tanks and pH

corrected, before being irrigated onto Shoalhaven Starches Environmental Farm to the

north of Bolong Road. This farm land is used for fodder crops, pasture and cattle

grazing.

2.2 OPERATING WORKFORCE

2.2.1 Operations

The existing factory operates 24 hours per day, 7 days a week, 365 days of the year.

2.2.2 Workforce

The plant employs a total of 250 staff, covering all components of production - operators,

administrative personnel and maintenance staff. Employee breakdown and hours of

shifts are as follows:

A total of around 250 employees Management, Technical & Administration 60

Day Workers 60

Shift Production (spread over 4 shifts) 130

Hours of Shifts

Plant: 6:00 am to 6:00 pm - 30 employees

6:00 pm to 6:00 am - 30 employees

Day – 7:00 am to 3:00 pm but variable 60 employees, 50 Management, Technical & Administration

Farm: 5:00 am to 5:00 pm - 2 employees

5:00 pm to 5:00 am - 1 employee

7:00 am to 3:00 pm - 3 employees

Shift work at both the factory and farm is undertaken on a 2 day, 2 night and 4 day off

basis.




2.3 RAW MATERIALS

There are six major raw material components used in the Shoalhaven Starches process.

These are flour, grain; coal; natural gas; fresh water and salt water.

Flour is delivered to the site from the Company’s mills at Manildra, Gunnedah and

Narrandera each day of the week except Sunday. The flour arrives into the plant by

Company owned stainless steel rail wagons. The wagons have bottom dumping doors

and are unloaded in a building. From the silos, the flour is moved into the plant by air as

required. The current approved flour consumption of the plant is 10,000 tonnes per

week.

Grain is delivered to the site by rail. At present up to approximately 552 tonnes of grain

is delivered to the site per day. The grain is used entirely in the production of ethanol

and DDG. The grain is “dumped” from the train into an underground hopper and

conveyed by screw conveyors and bucket elevator into a silo.

Coal is delivered by road from Wallerawang near Lithgow. At present 10 trucks of

30 tonnes per truck are delivered daily. The coal storage area is located between the

Shoalhaven River and the existing boilers. The transfer of coal from the storage bins to

the boilers is undertaken by front-end loader pushing the coal through a grate and into a

pneumatic conveying system up to the boilers.

Natural Gas - The Shoalhaven Starches plant operates partly on natural gas. The site is

connected to a natural gas reticulation main. At present the site’s natural gas

requirement is about 180 Terajoules per annum. Natural gas is used primarily as a

“Back up” energy source for the gluten and starch dryers.

Fresh water is utilised in the starch production process. At present on average a total of

8300 kilolitres of water is used on a daily basis. This comprises 5100 Kl from the town

water supply, and 2400 Kl from a raw water supply provided by Shoalhaven City Council

via a pipeline from the Shoalhaven Paper Mill.

Salt water from the Shoalhaven River is used to cool items of plant before the water is

returned to the river.

In addition the factory operations utilise a range of enzymes, additives, fuels and other

products in the overall operations. At present the plant utilises approximately 30 tonnes

each of acid and caustic products per week.




2.4 HISTORY OF DEVELOPMENT ON THE SITE

Shoalhaven Starches Pty Ltd is a member of the Manildra Group of Companies, a wholly

Australian owned business and the largest processor of wheat in Australia. The

Manildra Group originated from the NSW country town of Manildra where a single flour

mill was purchased in 1952.

The Shoalhaven Starches wheat starch and gluten plant at Nowra was originally

constructed in 1970. The Manildra flour mills, at Manildra, Narrandera and Gunnedah,

supply the Shoalhaven Starches factory, which currently produces wheat starch, gluten,

syrups and ethanol (industrial and fuel grades). The Shoalhaven Starches operation

provides direct on-site employment for 250 employees. Through the use of contractors it

also indirectly creates employment for many more people in the local and regional

economies.

In order to address the issue of waste water disposal, in 1984 Shoalhaven Starches

installed a spray irrigation system, using farmland it owned on the northern side of

Bolong Road at Bomaderry.

In June 1991, two storage ponds were built (Ponds No. 1 and 2) resulting in the

cessation of waste water discharge to the Shoalhaven River.

To further reduce product wastage, Shoalhaven Starches sought to use excess starch

for the production of ethanol. Ethanol production began at the Shoalhaven site in June

1992.

In 1994, the NSW Government approved the installation of a larger ethanol distillery

within the existing site. The new distillery and its associated facilities enabled production

of ethanol to increase from 20 million litres per annum to a production capacity of 100

million litres per year.

Subsequent to this approval Shoalhaven City Council issued development consent for:

• a protein isolate plant and DDGS Dryer; and

• a sorghum grinding plant.

Shoalhaven City Council issued development approval for the construction of a wet

weather storage pond (Pond No. 6) on the 27th April 2001. At present, with the

completion of Pond No. 6, Shoalhaven Starches has a combined waste water storage

capacity within the existing ponds of 925 ML. A further wet weather storage pond (Pond

No. 7) was approved by the Minister for Planning on the 23 December 2002. Pond No. 7

is currently under construction.




On the 1st June, 2001 the Minister for Urban Affairs & Planning, Dr Andrew Refshauge

MP, declared both the Shoalhaven Starches factory and Environmental Farm as being

State Significant Development for the purposes of the then Section 76A(7) of the

Environmental Planning & Assessment Act. Under the provisions of this declaration, all

development except “alterations and additions to existing development which, in the

opinion of the Minister in consultation with Council, are of minor nature and do not to any

significant extent change the scale, size, design or environmental impact of the existing

development” requires the Minister’s consent.

In 2003 the Minister for Planning issued development consent (D223) for Shoalhaven

Starches Pollution Reduction Program (PRP) No. 7. This approval enabled the

implementation of the Company’s Waste Water Management Strategy, and essentially

sought to remove solids (suspended and soluble) from the Company’s waste water, prior

to its irrigation on the Environmental Farm.

This process, known as Stillage Recovery, essentially involved the introduction of

additional decanters, the installation of an evaporation plant and additional dryers, to

remove solids from the waste water. It is the remaining solids in the waste water that

when sprayed onto the Environmental Farm, or stored in the wet weather storage ponds,

which have the potential to result in the generation of odours.

The recovery of the suspended and soluble solids from the waste water could not be

undertaken by the dryers in this process, without firstly providing additional coarse

solids. Additional coarse solids (grain) were required to be imported to the site.

As a consequence of the additional grain, the starch contained in the grain resulted in a

need to increase ethanol production. This increase in ethanol production required the

installation of additional fermenters, associated cooling towers and molecular sieves.

The increase in ethanol production also resulted in an increase in waste water, which

was required to be disposed on the environmental farm. In this regard this previous

proposal also included an increase in waste water disposal area on the Environmental

Farm.

The plant associated with this previous approval has now been substantially installed

and commissioned.

Shoalhaven Starches have subsequently recently received the following development

approvals:




• The establishment of a flour mill on the factory site. This proposal provides for the

transportation of wheat directly to the site by train for processing into industrial grade

flour for the use in the production of starch and gluten at the factory site.

• An application pursuant to Section 96 of the Environmental Planning & Assessment

Act seeking to modify the development approval for the PRP No. 7 project to enable

a DDGS Dryer to be installed in a slightly different location in the same building as

previously approved; and the installation of an additional evaporator (a redundant

piece of equipment located at the Company’s Altona Plant in Victoria) to provide

standby capacity for the existing evaporator plant when sections of the existing plant

are out of service or cleaning.

• A Section 96 modification application for a standby fermenter tank to be installed on

the site, to enable the existing fermenter tanks to be taken out of service for

maintenance one at a time.

The Department of Planning have indicated a preference for a single development

approval to cover the overall Shoalhaven Starches operations. This would require

Shoalhaven Starches to surrender the existing approvals for the site; and the

Department of Planning to issue a single approval for the overall site. Table 1 details

the various approvals associated with the Shoalhaven Starches site.

Table 1

Development & Building Approvals - Shoalhaven Starches

Approval Number

Project Consent Authority

Date of Approval

BA 84/759 Brick & Colourbond Industrial Additions SCC 1984 17 April

BA 84/556 Cliplock Industrial Building SCC 1984 17 April

BA 84/555 Transformer Stands SCC 1984 8 June

BA 86/814 Pump Shed Silo & Retention Pond SCC 1986 10 June

BA 88/1466 Brick Store Room & Shed SCC 1988 16 June

BA 88/0858 Three Metal Clad Storage Tanks SCC 1988 26 April

BA 88/853 Three Metal Clad Storage Tanks SCC 1988 26 April

BA 88/2450 Metal Clad Boiler House SCC 1988 9 September

BA 89/735 Brick Veneer/Metal Clad Factory Addition SCC 1989 26 April

BA 89/3315 Metal Clad Farm Shed SCC 1989 28 November

BA 89/922 Brick/Metal Clad Factory Alteration SCC 1989 7 June

BA 90/4165 Storage Ponds (2 x 11ML) SCC 1990 4 December

BA 91/1241 Effluent Storage Pond (1 x 27ML) SCC 1991 15 May

BA 92/5295 Metal Clad Boiler House SCC 1992 1 December




Table 1 (continued)

Approval Number


Date of Approval

BA 91/2384 Ethanol Storage and Recovery Tanks, Pump House and Loading Bay

SCC 1992 10 January

BA 93/3246 Steel Factory Building (Packaging) SCC 1993 16 December

BA 93/2504 Additional Starch & Gluten Dryers SCC 199323 September

BA 94/1887 Flour Unloading Facility SCC 1994 15 August

BA 93/3333 Methanol/Gasoline Denaturant Storage SCC 1994 11 February

BA 94/1353 Distillery & Fermentation Tanks SCC 1994 17 June

BA 93/3334 Electrical Switch Room Alterations SCC 1994 27 January

BA 94/1969 Saltwater Pumping Station SCC 1994 31 August

BA 94/1593 Extension of Starch Process Wet End Area SCC 1994 5 September

BA 94/0648 Horse Stable Complex SCC 1994 7 April

BA96/2080 Industrial Building Extensions SCC 1996 4 November

BA 97/244 Stage2 DME Plant and Refining Columns SCC 1997 14 April

BA 97/1871 Starch Tanks and Access Ways SCC 1997 14 November

BA 97/721 Tank Housing Structure for Glucose Plant SCC 1997 14 October

BA 97/419 Lime Silo SCC 1997 20 March

BA 97/ 787 Commercial Additions - Acid Storage Tank for Waste Treatment

SCC 1997 26 May

BA 98/2080 Temporary Office Building SCC 1998 10 July

BA 97/721 Glucose Tanks, Ion Exchange Tanks, Stair and Walkway

SCC 1998 24 February

BA/DA 94/1887 Flour Silos SCC 2001 13 February

DA 85/2595 Retention Pond at Pump House SCC 1985 20 November

DA 88/3155 Ethanol Distillery Anaerobic Fermentation Facility, Associated Storage Tanks and Staff Carparking

SCC 1989 22 August

DA 91/2178 Alcohol Outloading and Storage Facilities; Associated Fire Fighting Facilities; Landscaping; Carparking

SCC 1991 2 October

DA 91/1166 Effluent Storage Pond (1x27ML) SCC 1991 26 April

DA 92/1451 LPG Facility SCC 1992 15 May

DA 92/1776 Modifications to Ethanol Distillation Plant SCC 1992 28 July

DA 92/1738 Extensions to Existing Boiling Plant Site SCC 1992 4 November

DA 93/2774 Relocation of Packaging Facilities SCC 1993 5 November

DA 95/1041 Temporary Saltwater Pump SCC 1995 22 May

DA 94/1904 Gluten Grinding Building SCC 1995 23 January

DA 97/0176 Construction of a Tank Housing Structure for the refinement of Glucose

SCC 1997 25 August

DA 98/1457 Overhead Product Loading Tanks SCC 1998 27 August




Table 1 (continued)

Approval Number


Date of Approval

DA 99/1764 Integrated Development - Installation of 55 Tonne per hour Coal Fire Boiler

SCC 1999 1 September

DA 99/1069 Effluent Storage Dam No 5 SCC 1999 3 March

DA 99/3364 Temporary Portable Office Building for Two Years

SCC 1999 3 November

DA 98/2004 No 4 Gluten Dryer SCC 1999 30 March

DA 99/1663 Commercial Building Extensions - 4 x Additional Filter Tanks

SCC 1999 31 May

DA 99/1662 Storage Shed for the Purposes of Rural Industry

SCC 1999 9 April

DA 00/2682 PI Plant Including Dryers (to be constructed in 2 Stages)

SCC 2000 11 December

DA 002427 Sorghum Plant SCC 2000 15 December

DA 00/2489 Installation of Raw Water Line SCC 2000 15 September

DA 00/2682 Modification of Development Consent Protein Isolate Plant Including Dryers (to be constructed in 2 stages)

SCC 2001 21 March

DA 00/3555 Proposed Effluent Storage Pond (Pond 6) SCC 2001 27 April

DA 02-2205 Awning - Cover for Loading of Vehicles SCC 2002 3 June

DA 03/4140 Remote Fire Monitoring System SCC 2004 3 March

DA 07/2529 New Gas Meter Set SCC 2007 12 October

DS00/1187 (BA/DA94/1887)

Use of Existing Flour Silos for the purpose of Storage

SCC 2001 13 February

DA 7/94

Stage 3 Ethanol Expansion and installation of a spray irrigation system for wastewater disposal to farm north of factory

MP 25 May 1994

DA 265-8-2002 Proposed Construction and Operation of Effluent Storage Pond No 7

MP 2002 23 December

DA 265-8-2002 Modification for Construction and Operation of Pond 7

MP 2008 11 February

DA 223-7-2002 PRP No. 7 - Installation of stillage recovery, expansion of grain, glucose, starch and ethanol plants and extension of environmental farm irrigation area.

MP 2003 6 March

DA 391-11-2002 (MOD-90-7-2006-i)

Modification to Cooling Towers on Slab Foundation

MP

21st January 2003

DA 223-7-2002 (MOD-61-7-2007)

Relocation of DDG No 4 Dryer and Installation of additional evaporator

MP 2007 10 July

07_0021 Flour Mill MP 2007 4 October

Note: SCC – Shoalhaven City Council MP – Minister for Planning




3.0 THE SUBJECT SITE AND SURROUNDS

3.1 THE SITE AND ITS SURROUNDING LOCALITY

The Shoalhaven Starches factory site is situated on various allotments of land on Bolong

Road, Bomaderry within the City of Shoalhaven. The factory site, which is located on

the south side of Bolong Road on the northern bank of the Shoalhaven River, has an

area of approximately 12.5 hectares (refer Plate 1). This proposal will also involve a

portion of land that the Company owns located on the northern side of Bolong Road

(Lot 5 DP 825808, Lot 2 DP 538285) and the adaptive conversion of the Wet Weather

Storage Pond No. 7 to biologically treat waste waters prior to re-use in the factory

processes on the site or irrigation on the Environmental Farm. Pond No. 7 is situated

upon Lot 1 DP 842231.

The development concerns the following parcels of land:

Lot Deposited Plan (DP) No.

A FP 334511

B FP 334511

B FP 376494

1 385145

1 838753

62 1078788

201 1062668

A 371386

Lot 142 1069758

5 825808

2 538289

1 842231

The town of Bomaderry is located 0.5 km (approx.) to the west of the factory site, and

the Nowra urban area is situated 2.0 km to the south west of the site. The “Riverview

Road” area of the Nowra Township is situated approximately 600 metres immediately

opposite the factory site across the Shoalhaven River.

The village of Terara is situated approximately 1.5 kilometres to the south east of the

site, across the Shoalhaven River. Pig Island is situated between the factory site and

the village of Terara and is currently used for dairy cattle grazing.




Plate 1: Aerial view of Shoalhaven Starches factory site.

There are a number of industrial land uses, which have developed on the strip of land

between Bolong Road and the Shoalhaven River. Industrial activities include a metal

fabrication factory, the Shoalhaven Starches site, Shoalhaven Dairy Co-op (Australian

Co-operative Foods Ltd) (now closed down) and the Shoalhaven Paper Mill (Australian

Papers). The industrial area is serviced by a privately owned railway spur line that runs

from just north of the Nowra-Bomaderry station via the starch plant and Dairy Co-op to

the Paper Mill.

The state railway terminates at Bomaderry Railway Station with a separate, privately

owned spur line to the factory site. Shoalhaven City Council sewerage treatment works

is situated between the railway station and the factory.

The Company also has an Environmental Farm located over 1000 hectares on the

northern side of Bolong Road. This area is cleared grazing land and contains spray

irrigation lines and wet weather storage ponds (total capacity 925 Megalitres). Table 2

provides further details of the wet weather pond system. There are at present 6 wet

weather storage ponds on the farm that form part of the waste water management

system for the factory. A seventh pond approved in 2002 is currently in the process of

being constructed. The proposal will result in treated waste water from the factory site,

currently directed to the Environmental Farm for irrigation, to be further treated within this

pond under construction prior to its reuse within the factory or irrigated on the Farm.




Table 2

Wet Weather Storage Ponds

Pond Storage Capacity (ML)

1 11

2 11

3 33

4 125

5 250

6 500

7 (as approved) 220

Total Capacity 1140 ML

Figure 4 provides a layout of the wet weather storage ponds.

The Environmental Farm stretches over a broad area of the northern floodplain of the

Shoalhaven River, stretching from Bolong Road in the south towards Jaspers Brush in

the north. Apart from its use as the Environmental Farm, this broad floodplain area is

mainly used for grazing (dairy cattle). The area comprises mainly large rural properties

with isolated dwellings, although there is a clustering of rural residential development

along Jennings Lane (approximately 1 kilometre away) and Back Forest Road

(approximately between 500 metres to 1.2 kilometres away) to the west of the

Environmental Farm; and Jaspers Brush Road, approximately 1.2 kilometres to the north

of the Environmental Farm. This proposal will result in a significant improvement in the

quality of waste water diverted onto the Environmental Farm.

Figure 1 is a site locality plan depicting the location of the factory site and Environmental

Farm as well as the surrounding locality.

Figure 2 is a plan of the existing factory site depicting the layout of existing plant on the

site as well as plant that has been previously approved but not yet built.

Plate 1 provides an aerial view over the factory site.

Cowman Stoddart Pty Ltd

Ref. 07/34 - August 08

Page 16



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4.0 CONSULTATION

4.1 INTRODUCTION

The stakeholder consultation adopted through the Environmental Assessment process

sought to provide a structured, transparent and open communication with key

stakeholders including the local community. It enabled the dissemination of information

about the project; and provided an opportunity for concerns raised by government

agencies and the local community to be identified early and addressed in the EA

process.

4.2 PRELIMINARY ENVIRONMENTAL ASSESSMENT

A Preliminary Environmental Assessment was prepared for this proposal and was

referred to the Department of Planning as part of the process for formulating the

Director-General’s requirements (DGRs) for this project. The Department forwarded the

document to relevant government agencies including the Department of Environment &

Climate Change, Department of Water & Energy, Roads and Traffic Authority and

Shoalhaven City Council seeking these agencies’ requirements for the preparation of the

EA. These agency requirements formed the basis for the subsequent DGRs issued by

the Department.

4.3 GOVERNMENT AGENCY CONSULTATION

Relevant government agencies consulted during the EA process included:

• Department of Planning;

• Department of Environment and Climate Change

• Department of Water & Energy

• Roads and Traffic Authority

• Shoalhaven City Council

On-going consultation was undertaken with government agencies listed above during the

preparation of this EA and associated technical reports. This included face to face

meetings, telephone discussions, written correspondence, as well as formal consultation

to ensure the EA and its associated technical papers addressed the requirements of the

various government agencies.

Annexure A to the EA includes a table that outlines the Director-General’s

Requirements (DGRs) for the 5 the preparation of this EA and details where each of the




requirements have been addressed in this EA. Annexure B to the EA includes tables

outline the requirements of the above Government agencies and details where these

requirements have been addressed in the EA.

4.4 COMMUNITY CONSULTATION

A community consultation program has been undertaken with the assistance of Twyford

Consultants and which included the following:

• Several meetings with the Community Consultation Group. The Community

Consultation Group was set up following and in accordance with the Minister’s

approval for the Pollution Reduction Program (PRP) No. 7 in 2003. The Community

Consultation Group includes resident representatives from Nowra, Bomaderry,

Terara and the ‘Backforest Road’ rural area to the east of the Company’s

Environmental Farm.

• Set up an exhibition of the proposal at the Shoalhaven Expo which was open to the

public on Saturday 26th July 2008. This included holding an open seminar for

interested persons.

• Community briefing meetings with specific community groups including Shoalhaven

Business Chamber Executive, Riverwatch, Australian Conservation Foundation,

Shoalhaven River Alliance, Bomaderry Creek Landcare, Shoalhaven Landcare

Association, Shoalhaven City Council (Councillors and senior staff), and the Area

Consultative Committee.

• Advertisements in the local print media (South Coast Register) detailing the

proposal and providing details where further information about the project could be

obtained.

• The preparation and distribution of a Community Newsletter providing details of the

project. This newsletter was distributed to residents within Bomaderry, Nowra,

Terara and rural areas surrounding the facility and Environmental Farm. A total of

5000 newsletters were printed, with 3700 distributed in the local area; with the

remainder distributed to the Community Consultation Group; briefing meetings and

the Shoalhaven Expo.

• Separate Fact Sheets were also prepared in terms of the proposed waste water

treatment plant; odour management plan; and ethanol upgrade project. These fact

sheets provided further information about these specific facets of the project.




• The Manildra website was also set up to provide details of the project including

access to the above Fact Sheets and details of where additional information could

be obtained.

• Twyford Consulting also established and staffed a 1800 telephone number to take

calls, questions and comments from the community.

• Twyford Consulting also utilised their specialist community engagement database

software (Darzin) to record input from the community.

As a result of the community consultation program the following is a summary of the

issues that were identified (with comments explaining where these issues are addressed

in the EA documentation included). Annexure R to this EA is a report prepared by

Twyford Consulting providing greater detail about the community consultation approach

and issues that were raised.

Odour

Throughout the consultation process the issue of odour and odour control has been the

most significant, both in terms of number of mentions, and the passion with which they

spoke about it. Members of the local community said that they have lived with odours

from the factory and the environmental farm for many years. For many of these people,

the key issue for the proposed project is controlling the odours. A number of different

people and organisations throughout the consultation process indicated strong support

for the project on the basis that it would resolve the long-running issue of odour. Several

asked how they could best indicate their support to for the project to the Department of

Planning.

Comments

The EA is supported by an Odour Assessment and includes recommendations for odour

management controls to be implemented both in terms of the existing plant and the

proposed upgrade works. This issue is addressed in detail in Section 7.1 of the EA and

the Air Quality (Odour) Assessment forms Annexure M to this EA.

Water

The next most significant issue is that of water use, treatment, irrigation, and the impacts

of the proposed project on these. Unlike the issue of odour, water-related issues

generated more interest and curiosity than passion. People are interested in the

proposed treatment of water, while they are more passionate about resolving odour

issues. In many ways water issues relate back to the odour issue, as it is the existing




water treatment regime that is responsible for some of the odour control problems.

Issues related more specifically to water use and treatment included those concerning

the recycling of water, water extraction from the river, the volume of water purchased

from Council, whether the volume of water to be irrigated is to be increased or

decreased. Strong support was expressed for the proposal to recycle water. Some

concern was expressed about the potential impacts of continuing irrigation on the water

table.

Comments

The proposed development will result in a reduction in the level of potable water utilised

by the factory processes and will involve the introduction of a water treatment plant that

will enable 4.5 ML of treated waste water to be reused in the factory processes. This

issue is addressed in Section 7.3 and 7.5.1 of the EA.

Issues relating to odours emanating from irrigation waters are discussed in Section 7.1

and Annexure M to the EA.

Section 7.4 of the EA addresses issues pertaining to the irrigation and storage of treated

waste waters and the EA is supported by specific agronomic investigations (Annexures

O(i) and O(ii)) which address the adequacy of treated waste water for irrigation

purposes.

Noise

Another issue that emerged was that of noise, primarily of the operation of the plant.

Questions were asked about the manner in which noise would be controlled, particularly

from the proposed packing plant which is closer to residential areas than the existing

facility.

Comments

Noise impacts associated with the construction and operation of the project are

discussed in Section 7.6 of the EA and the EA is supported by an Acoustic Assessment

included in Annexure Q(i) and an Acoustic Audit of the site in Annexure Q(ii).

Ethanol Production

A third important issue concerns the process by which ethanol is produced at the plant.

There is a level of awareness in the community that ethanol in many parts of the world is

produced from grains such as corn and wheat, with a subsequent impact on food

availability and pricing. There is concern that the process at the Shoalhaven Starches

factory is similar. Members of the community are concerned that the proposal will use




more grain, exacerbating the impacts of food for fuel production. The idea that ethanol

production impacts food availability and prices appeared to generate higher levels of

concern throughout the consultation than any issue apart from odour control.

Comments

This issue is discussed in terms of the justification of the proposal in Section 5.3 of the

EA. In this regard it is important to note that unlike other ethanol producers who produce

ethanol directly from grain and thereby compete with other industrial users of grain such

as feed lots. At Shoalhaven Starches it is lower grade starch and wastage from the

starch, gluten and syrup production processes that when combined feed the

fermentation and distillation stages of ethanol production. In this way ethanol produced

at Shoalhaven Starches is a value added product processed from the Company’s waste

stream.

The primary purpose for the majority of raw materials delivered to the site is for the

production of gluten and starch which are used in a range of industries including food,

paper, cardboard, confectionery, soft drink, beer and other manufacturing industries.

Traffic and Transport

Traffic and transport issues arose during the consultation. Questions were asked about

the impact of truck and rail movements on local road and rail infrastructure.

Comments

The impacts of heavy vehicle movements associated with the proposed ethanol upgrade

project are addressed in Section 7.7 of the EA and Section 7.6 in terms of the amenity

impacts of heavy vehicle movements.

Employment and Economy

Another issue about which there was some discussion is that of economic impact and

job creation. The general feeling was overwhelmingly that the impact of the proposed

development on the regional economy would be positive.

Comments

Section 5.3 of the EA provides a justification for the project and including an outline of

the positive economic effects that both the existing and proposed operations will have on

the local, and indeed regional and state economies. Section 2.2 outlines the existing

operating workforce of the site. These sections of the EA discuss the employment

generating nature of the project both in terms of construction and operation.




Visual impact

− Visual impacts of existing and proposed plant are significant. Tree planting would reduce it.

− Important that the bridge over Bolong Road is not an eyesore

Comments

Section 7.12 of the EA addressed the visual impacts of both the existing operations and

proposed development and makes recommendations with respect to minimising the

visual impacts of the development. These recommendations are incorporated as

commitments to be undertaken by the Company in Section 8.3.17 of the EA.

4.5 REVIEW OF DRAFT ENVIRONMENTAL ASSESSMENT

In accordance with standard procedures a copy of the draft Environmental Assessment

report (EA) document was referred to the Department of Planning (DoP) for review. The

Department referred this draft EA to the Department of Environment and Climate

Change (DECC), Roads & Traffic Authority, Department of Water and Energy (DWE)

(previously DNR) and Shoalhaven City Council (SCC) for review.

Annexure C to the EA outlines the issues raised by government agencies (DoP and

DECC) received during the designated review period in terms of the draft EA and where

matters raised are outlined in the EA.

4.6 ABORIGINAL STAKEHOLDER CONSULTATION

Consultation was carried out in accordance with DECC National Parks & Wildlife Act

1974 - Part 6 Approvals - Interim Consultation Requirements for Applicants guidelines as

part of the Aboriginal Heritage Assessment carried out by South East Archaeology

(Annexure D). This report included consultation with the Nowra Local Aboriginal Land

Council and Jerrinja Consultants.




5.0 THE PROPOSED DEVELOPMENT

5.1 OBJECTIVES OF THE ETHANOL UPGRADE

The use of ethanol as a motor vehicle fuel (or fuel additive) has many benefits including:





locally.

The Federal and State Governments have introduced a range of initiatives to encourage

the increased use of ethanol as a fuel additive.

The NSW Government has recently mandated the blending of 2% ethanol into the total

volume of petrol sold in NSW as a first step towards a 10% ethanol content in 2011,

The Manildra Group is planning to increase its ethanol production capacity to meet the

expected increase in demand for ethanol arising from the NSW Government’s timetable

for implementation of its further ethanol initiatives by upgrading its existing ethanol plant,

located at the Shoalhaven Starches Plant at Bomaderry.

Shoalhaven Starches plans to increase ethanol production at its Bomaderry plant from

the current approved 126 million litres per year to 300 million litres per year and to

undertake other plant upgrades at that facility to improve its overall competitiveness and

environmental performance.

5.2 ENVIRONMENTAL AUDIT

The Land and Environment Court on the 2 November 2006 handed down a judgement

that required Shoalhaven Starches to engage a suitably qualified person to conduct a

comprehensive audit of the factory and Environmental Farm in order to identify and


improved management of odours. Shoalhaven Starches engaged GHD Pty Ltd to

conduct the environmental audit.

The objective of the environmental audit program was to address the requirements of

Condition 2 of Annexure B to the Land and Environment Court judgement of 2 November

2006, which states:




(2) For the purposes of ensuring no offensive odours as defined by the Protection of the Environment Operations Act 1997 are emitted from the premises, the defendant must engage a suitably qualified expert or experts to conduct an environmental audit that must:

(a) Identify and list every process, activity and substance stored or used at the premises that generates or has the potential to generate odours.

(b) Benchmark each process and activity identified at (a) against comparable international best available technology and industry best management practice relating to the control of odour from that process and activity.

(c) Identify and list every actual and every potential source of offensive odour at the premises. This must include all point, diffuse and fugitive sources.

(d) Identify for each odour source identified at (c) the cause or causes of the odour.

(e) Quantify for each odour source identified at (c) the actual and potential nature, strength and duration of occurrence of the odour in accordance with the publication “NSW DEC 2005 Approved Methods for the Sampling and Analysis of Air Pollutants in NSW”.

(f) Model for each odour source identified at (c) the impacts and potential impacts of the odour at all sensitive receptors in accordance with the publication “NSW DEC 2005 Approved Methods of the Modelling and Assessment of Air Pollutants in NSW”.

(g) Identify all available options to prevent the generation of offensive odour for each actual and potential odour source identified at (c).

(h) Where at (g) prevention is not possible, identify all available options to minimise the generation of offensive odour for each actual and potential odour source identified at (c).

(i) Describe, quantify and model the likely environmental impacts of implementing each option identified at (g) and (h).

(j) State for each actual and potential odour source identified at (c), the preferred option for the prevention or minimisation of the generation of offensive odour from that source.

(k) Review the adequacy of policies, procedures, standards, practices and training at the premises in relation to environmental performance and in particular odour management. Where any inadequacy is found to exist recommend options to address each inadequacy.

(l) Produce an audit report that details all of the above.




The Environmental Audit has now been completed and submitted to the Land and

Environment Court and DECC. The DECC have indicated that the recommendations of

the audit will need to be undertaken prior to the commissioning of the Ethanol Upgrade

project. The proposed ethanol upgrade has been devised to integrate with the odour

management plan arising from the Environmental Audit.

5.3 JUSTIFICATION FOR PROJECT

As outlined in Section 5.1 the use of ethanol as a motor vehicle fuel (or fuel additive) has

many benefits including:





locally.

Recognising these benefits, Federal and State Governments have introduced a range of

initiatives to encourage the increased use of ethanol as a fuel additive. The NSW

Government recently mandated the blending of 2% ethanol into the total volume of petrol

sold in NSW as a first step towards a 10% ethanol content in 2011. This proposal seeks

to meet the expected increase in demand for ethanol arising from the NSW

Government’s timetable for implementation of its further ethanol initiatives.

In doing so the project also seeks to implement an Odour Management Plan for the

factory site and Environmental Farm which has been based upon the findings of the

Environmental Audit that has been undertaken for the site. The Odour Management

Plan will seek to substantially reduce odours that are generated from the site. The

implementation of the proposed Ethanol Upgrade Project will be integrated with the

Odour Management Plan for the overall site.

The proposal also includes a comprehensive Waste Water Treatment Plant that will have

the volumetric and operational capacity to treat the total waste water flow and organic

load from the factory site. This plant will incorporate sequential anaerobic and aerobic

digestion facilities. This treatment process will enable over half of the waste waters

generated by the site to be re-used within the factory processes. The remainder will be

irrigated onto the Company’s Irrigation Farm.

The ability to re-use treated waste waters within the factory process will result in a

significant reduction in demand in the amount of water (treated and raw water) that is

currently imported to the site from the Council’s water system.




In addition, the amount of treated waste waters that will be required to be irrigated onto

the Environmental Farm will not only be able to be reduced, but the quality of the treated

waste waters will be significantly improved. This will have the additional benefit of

reducing the potential for odours to be generated from the Environmental Farm.

It should also be noted that methane generated from the anaerobic waste water

treatment processes within this plant will be re-directed and used as a heating fuel in the

Company’s boilers. This will reduce the amount of coal that will be required to be used

on site; thereby reducing greenhouse gas emissions that would otherwise be created.

All the above measures will ensure the long term sustainability of the Shoalhaven

Starches factory site at Bomaderry.

As outlined in Section 5.1, flour that is transported and produced on the site is processed

into gluten and starch. Gluten is a high protein food additive for human consumption.

Starch processed at the plant is a necessary ingredient used by food, paper, cardboard

and other manufacturing industries.

Starch is also used in the production of syrups on the site. The syrups plant products

include glucose and brewers syrup. These products are essential for the production of

foods, confectionary, chocolate, soft drink, fruit juice and beer.

In a broader strategic context the Shoalhaven Starches factory is a key supplier of

ingredients to many industries within NSW. The products created at the Shoalhaven

Starches Plant at Bomaderry are essential ingredients for a wide range of industries

within NSW and Australia. These industries depend significantly upon products

produced at the Shoalhaven Starches Plant, products that are not in many cases

produced elsewhere. Were the Shoalhaven Starches plant to cease operations such a

cessation would have significant adverse implications to other industries within the State

and Australia as a whole. This was one of the reasons why the NSW Government in

1993 identified the Shoalhaven Starches Plant at Bomaderry as a State Significant Site.

Other ethanol producers produce ethanol directly from grain and thereby compete with

other users of grain such as food manufacturers and stock feed lots. At Shoalhaven

Starches it is the lower grade starch and wastage from the starch, gluten and syrup

production processes that when combined feed the fermentation and distillation stages

of ethanol production. In this way ethanol produced at Shoalhaven Starches is a value

added product processed from the Company’s waste stream.

As outlined above the primary purpose for the majority of raw materials delivered to the

site is for the production of gluten, starch and glucose which are used in a range of




industries including food, paper, cardboard, confectionery, soft drink, beer and other

manufacturing industries.

The total raw material input (flour and grain) into the Shoalhaven Starches’ processes

associated with this proposal is equivalent to 1,155,000 t/a. Increasing the Shoalhaven

Starches’ ethanol production to 300 ML per annum would be equivalent to 240,000 t/a.

The remaining product output (starch, gluten, glucose and DDGS) would therefore be

equivalent to approximately 955,000 t/a. The majority of production output from the

Shoalhaven Starches’ plant following the ethanol upgrade project will continue to involve

food related production. Ethanol production will involve only approximately 20% of the

total production output from the Shoalhaven Starches’ plant.

Clearly it is evident that unlike other ethanol producers which utilise food grain crops to

solely produce ethanol fuel – this proposal seeks to mainly produce food (and other)

products from flour; with only a comparably small quantity of grain used directly to

produce ethanol. In effect the Shoalhaven Starches’ operations seek to value add along

their production processes, including the processing of what would otherwise be a waste

stream into a valuable biofuel such as ethanol.

Apart from the important role that the Shoalhaven Starches Plant plays in the NSW

economy, the factory plays a particularly important role in the local Shoalhaven (and

South Coast) economy. The Shoalhaven Starches factory site at Bomaderry directly

employs 250 employees; with this project creating an estimated additional 25 ongoing

positions. It is also estimated that up to 150 jobs will be created for the estimated

12 month construction phase.

Such employment generation needs to be seen in a broader context with the recent loss

of significant employers within the Shoalhaven including Gates Rubber at South Nowra,

the recent closure of the Dairy Farmers Co-operative operations and the reduction in

production (and also employment) at the Australian Paper Mill, (both operations situated

along Bolong Road). Shoalhaven Starches is one of the few major employers within this

region seeking to generate additional employment for the local economy.

This project will ensure the on-going operations of the Shoalhaven Starches plant at

Bomaderry in a commercially and environmentally sustainable manner. In doing so the

ethanol upgrade project will be integrated into an Odour Management Plan for the site,

that will result in significant reduction in odours that emanate from the site. The project

also includes the implementation of a waste water treatment plant that will treat waste

waters to a higher quality standard where over half of the waste water treated will be




able to be re-used in the factory process on the site. The remainder will be able to be

irrigated in a sustainable manner on the Company’s Environmental Farm.

5.4 SUMMARY OF PROPOSAL

Table 3 below provides a summary of the proposed development.

Table 3

Summary of Proposal

Factory Component Proposed Works Associated with

Ethanol Upgrade Project

Existing Approved

Production

Proposed Production

Starch Plant Dryer, including grinder. 10,000 tonnes per week flour processing

20,000 tonnes per week flour processing

Grain Plant Nil. Existing equipment has sufficient spare capacity.

3864 tonnes per week (552 tonnes/day) of grain

6720 tonnes per week (960 tonnes per day) of grain

Ethanol Plant 3 additional fermenters and associated additional cooling towers (2).

Molecular sieves and associated additional cooling towers (2).

126 ML p.a. ethanol

300 ML p.a. ethanol

Stillage Recovery (DDGS Plant)

6 additional DDGS Dryers (and associated equipment including 10 decanters).

2 additional evaporators.

Proposed extension to DDGS Loadout.

2 additional storage tanks (15 m height).

Overhead Services Gantry

Chemical Storage.

DDGS Pellet Plant.

Bioscrubber vessel.

Motor Control Centre (MCC) Room.

Additional Cooling Towers.

2030 tonnes per week DDGS

6400 tonnes per week DDGS

Packing Plant Construct new Packing Plant and Container Loading Facility on Lot 5 DP 825808.

Provide new additional rail siding (270 m long).

Provide pedestrian and service overbridge to connect packing plant site to factory site.

Weighbridge.

Production at the packing plant is determined upon the type and size of

packaging and market demand.




Table 3 (continued)

Factory Component Proposed Works Associated with

Ethanol Upgrade Project

Existing Approved

Production

Proposed Production

Environmental Farm Adapt Approved Pond No. 7 as an Anaerobic and Aerobic Waste Water Treatment Pond comprising:

• Bulk Volume Fermenter (BVF) 90 type reactor (90 ML capacity).

• Sulphide Oxidation (SO) Basin (103 ML) (irrigation water).

• Membrane Bio-Reactor (MBR) (4 ML).

• Reverse Osmosis (RO) (water to be re-used in factory).

Approximately 8.1 ML per day.

Power Generation Gas-fired Boiler

Gas-fired Co-generator

100 t/h

40 MW

Pipelines • Proposed treated water pipeline from Paper Mill to site.

• Proposed methane gas pipeline from Waste Water Treatment Plant to factory.

• Proposed electricity line between Waste Water Treatment Plant and site.

(Distance of above pipelines about 2 km)

• Proposed product pipeline between proposed Pedestrian Overpass and Packing Plant.

N/A N/A

Fire System • Shed (pumps).

• 2 water reservoir tanks (capacity 1.5 ML each).

N/A N/A

As outlined in Section 5.2 of this EA the proposed ethanol upgrade project has been

devised to integrate with the odour management plan arising from the Environmental

Audit. These works will be discussed in greater detail in Section 7.1 of the EA. Table 4

provides a brief summary of the proposed works outlined in the odour management plan

as they relate to each of the factory components, including those associated with the

proposed ethanol upgrade.




Table 4

Summary of Proposed Works associated with Odour Management Controls

Factory Component Proposed Odour Control

Existing Factory

DDG Plant • Bioscrubber.

• Pellet Packing Plant.

• Housekeeping actions (eg. ductwork cleaning and maintenance).

• Installation of wet legs on tanks to condensate vapour emissions.

• Improvements to industrial ventilation.

• Curtains to be installed DDG loadout doors.

Distillery Bioscrubbers (Stage 3 if required).

Ethanol • Decommissioning cooling towers.

• Installation of wet legs on tanks to condensate vapour emissions.

Flour Mill Improve dispersion from discharge points.

Glucose Plant Installation of wet legs on tanks to condensate vapour emissions.

Starch Plant • Housekeeping actions (eg. ductwork cleaning and maintenance).

• Improve dispersion from discharge points (such as gluten dryers, starch dryers).

Proposed Ethanol Upgrade

DDG Plant Bioscrubber.

Ethanol Plant Improve dispersion from discharge points.

Starch Plant Housekeeping actions (eg. ductwork cleaning and maintenance).

Figure 3 is a site plan depicting the proposed additions to the factory site.

Figure 4 outlines the configuration of the wet weather storage pond No. 7 located on the

Company’s Environmental Farm and the proposed works associated with the waste

water treatment plant.

Figure 5 includes elevation details of the proposed plant upgrade.

Figure 6 provides a flow chart depicting the proposal in terms of the processes at the

site.

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5.5 THE STARCH PLANT

Flour is pneumatically conveyed from storage bins to the starch plant, where the flour is

mixed with water and separated into two components:

(i) Gluten, which has a high protein content (about 75%) is sold to local and export

markets.

(ii) Starch, which is processed and then directed to:

(a) dry starch markets, both local and export;

(b) domestic liquid starch markets;

(c) the glucose plant which processes the starch further to produce glucose and

other products;

(d) the ethanol plant, where the starch is converted to sugars, which are

fermented and distilled to produce ethanol.

This proposal will require an increase in the amount of flour transferred to the site for

processing from the current approved 10,000 tonnes per week to 15,000 tonnes per

week, in addition to the 5000 tonnes per week of flour to be produced on-site by the

Company’s previously approved flour mill

Shoalhaven Starches indicate that existing plant within the starch and gluten production

plants; and approved flour mill, will be largely able to accommodate the increase in flour

processing associated with this proposal.

An additional dryer and grinder will need to be installed adjacent to the proposed Dryer

No. 5 (approved under the previous PRP No. 7 approval). This dryer and grinder would

have similar throughput and operating parameters as the existing dryers.

Air emissions from these processes would be ducted to and passed through fabric filters

(located in a baghouse) to reduce particulate matter emissions before being discharged

vertically to air via a stack approximately 33 m above ground level (approximately 5 m

above the height of the supported building).

Ductwork associated with these processes would be designed with consideration to the

good practice ductwork design and maintenance outlined in the Audit Report; in

particular, measures to minimise contamination in the ductwork in order to reduce the

potential for the generation of malodorous emissions.




5.6 THE GRAIN PLANT

Waste product from the starch, gluten and syrup production processes at the factory are

combined to feed the fermentation and distillation stage in the ethanol production

process. The outputs of the process are fuel and industrial grade ethanol. The residue

from the ethanol process is directed to the Stillage Recovery Plant where the solids are

removed for high protein cattle feed and the clean water is directed to the Environmental

Farm for irrigation purposes.

The distillery at Shoalhaven Starches is supplied feed material from 2 sources on the

site:

• Starch from the starch plant; and

• Crushed grain from the grain processing plant.

These feed streams are fermented and distilled in the distillery. The product from the

distillery is ethanol. The by-products from this process are the remaining grain husks

and “unfermentables” from the feed stream; carried by water.

Grain is also used as a coarse fibre in the feed to the DDGS dryers as part of the stillage

recovery process to dry soluble solids recovered from waste water by evaporation. If

insufficient fibre is fed into the dryers, the moist syrup fed into the dryers cannot be

adequately absorbed and the product becomes “sticky”. After a period the syrup sticks

to the heating surface of the dryer resulting in a loss of drying capability.

There is therefore a need to mix grain fibre into the syrup to ensure that the mixture is

sufficiently friable to enable the DDGS Dryers to operate efficiently.

In order to enable sufficient grain for the increase in ethanol production at the site it is

proposed to increase the intake of grain from the currently approved 552 tonnes per day

to 960 tonnes per day. According to Shoalhaven Starches existing plant and equipment

will have sufficient spare capacity to accommodate this increase in grain intake.

5.7 ETHANOL PLANT

The ethanol plant utilises waste from the starch, gluten and syrups sections of the plant

to feed fermentation and distillation, which produces ethanol. In effect the ethanol

production process comprises an integral component of the Company’s waste water

treatment process. An essential difference therefore between ethanol produced by

Shoalhaven Starches and ethanol produced by other producers, is the ethanol produced

at Shoalhaven Starches is a value added product from the Company’s waste stream

from the production of gluten and starch. The ethanol produced from waste starch does




not involve the diversion of grain from other markets (such as livestock feed). Indeed a

further value added product from the waste stream from the production processes at the

Plant is dried DDGS which provides an alternative stock feed product. (This will be

discussed further in Section 5.8 of this EA.)

The starch from the starch plant and grain crushed from the grain plant are mixed in the

fermentation plant and the starch in this feedstock is converted to sugars, which are then

fermented to produce ethanol. The fermentation process is a natural process where

yeast converts the incoming sugars to ethanol. This process requires a residence time

of approximately 50 hours, which necessitates the use of large holding tanks called

fermenters, which allow time for the process to take place producing a “beer” to feed the

distillery.

The distillery (refer Plate 2) separates the ethanol from the “beer” in the “beer” column

then purifies the ethanol by passing it through rectification columns and molecular sieves

which remove the remaining water, which is not removed by the “beer” column. The

ethanol is then ready for sale.

Plate 2: Existing Distillery and Cooling Towers.




In order to increase ethanol production from the current approved 126 megalitres per

annum to 300 megalitres per annum Shoalhaven Starches envisage that much of the

existing and approved plant associated with the distillery will have sufficient spare

capacity to accommodate the increase in production. In order to increase production

however it will be necessary to install:

• an additional 3 fermentation tanks;

• additional cooling towers (4);

• additional molecular sieves (2) and associated additional cooling towers (2).

It is proposed to locate the three new fermentation tanks (each with a capacity of 3 ML)

and associated cooling towers at the eastern extremity of the factory site, within the

vicinity of existing approved fermenter tanks. (Refer Plate 3 – view of existing

fermenters).

Additional molecular sieves (refer Plate 4) with associated heat exchangers, pumps and

cooling towers will be installed within the existing ethanol distillation plant structure,

adjacent to existing molecular sieves. Molecular sieves receive industrial grade ethanol

from the storage tanks, process it to fuel grade ethanol and then pump it back to storage.

The molecular sieves essentially remove water content from the industrial grade ethanol.

The new molecular sieves will operate in parallel with the existing molecular sieves.

Plate 3: View of Existing Fermenters.




Plate 4: View of existing Molecular Sieves.

The additional fermenter tanks would be located next to the existing fermenter tanks.

Each fermenter tank will be fitted with an exhaust stack (17 m above ground level) that

will allow free vertical discharge.

The proposed cooling towers will be located in an area away from potential sources of

contamination and would only use fresh make-up cooling water. As such, odour

emissions from these cooling towers are anticipated to be negligible.

Due to the ethanol upgrade it is proposed to upgrade the site’s fire fighting system. This

upgraded system will be sited on land directly opposite the ethanol plant and will

comprise a building to house pumps and 2 water tanks for water reserve supply. Each

tank will have a capacity of 1.5 ML.

5.8 WASTE WATER TREATMENT AND DISPOSAL

5.8.1 Stillage Recovery

The 2003 approval by the Minister for Planning of the Company’s Pollution Reduction

Program No. 7 introduced a Stillage Recovery process into the production process at the

plant. Stillage recovery essentially seeks to improve the system whereby suspended

and soluble solids are removed from the Company’s waste water system.

This process includes the use of decanters, evaporators and DDGS dryers.




Decanters (refer Plate 5) are essentially mechanical separation devices, which operate

by centrifugal separation process that separates out the unfermented suspended solids

in stillage, ie. the waste liquid left over from the distillation of ethanol. The increase in

ethanol production will require the installation of an additional 10 decanters in a new

purpose built building to the west of the site.

Plate 5: Decanter

Evaporators (refer Plate 6) are designed to reduce the water content of “thin” stillage

after it passes through the decanters and the coarse solids are removed. The

evaporators operate by mechanical vapour recompression. The thin stillage from the

decanters is fed into tubes within the evaporator and heated by recompressed steam.

The water within the overflow is heated to a point where the water evaporates and is

separated from the remaining solids, which remain as syrup. The liquid (ie. condensate)

is captured and directed to the Environmental Farm for irrigation.

The existing and approved evaporation plant, according to Shoalhaven Starches, will

largely have sufficient capacity to accommodate the increase in production of ethanol

associated with this proposal. Only one additional evaporator will need to be erected

within the existing evaporation plant to accommodate this proposal.

The syrup product is directed to DDGS dryers (refer Plate 7) for further drying. The

DDGS dryer is essentially a barrel in which a bundle of steam heated tubes are rotated

at low speed. Evaporator concentrate (syrup) and decanter concentrate (wet insoluble

solids) are fed into one end of the barrel and traversed through to the other end by

shovels. Heat from the tubes removes moisture.




Plate 6: Existing Evaporator.

Plate 7: Existing Dryer




Dried DDGS is removed from the barrel and conveyed to the storage room for further

loading into trucks.

The proposed increase in ethanol production at the plant will require 6 additional DDGS

dryers with the associated 10 new decanters to be installed within the western portion of

the site. It is expected that the new plant associated with the stillage recovery process

will increase dry product from the current approved 2030 tonnes per week to 6400

tonnes per week.

The six (6) new dryers and associated decanters will be fitted with the required

equipment to meet statutory emission requirements for particulate and odour emissions.

The product from the drying process results in a dry product that is sold for use as stock

feed.

The increase in production of DDGS will require the existing DDGS load-out to be

extended to enable the storage of the additional product.

The proposed equipment would be housed in a new building located to the west of the

existing DDG plant area. The building would be maintained under slight negative

pressure in order to minimise fugitive odour emissions from the building.

Discharges to air from the dryers, decanters and associated equipment will be collected

and ducted to bioscrubbers for treatment. The bioscrubbers are to be situated adjacent

the building housing the dryers and associated equipment.

The proposed evaporators are not, themselves, direct sources of odour emissions

however, the condensate formed during the evaporation process is a potential odour

source. Hence, air emissions from the DDG (liquids-line) storage tanks handling

condensate will also be ducted to the bioscrubber for treatment.

Shoalhaven Starches also propose to install a DDGS Pellet Plant, which essentially

seeks to provide the Company with a greater flexibility to meet market demand for this

product. It should also be noted that the installation of a DDGS Pellet Plant was one of

the recommendations of the Environmental Audit on the basis that it would reduce

fugitive odour and dust emissions currently associated with the handling and storage of

the granular DDG product.

It is proposed to site the Pellet Plant partly adjacent the existing DDGS Dryer building.

The plant will consist of a series of bins and mills to process the loose DDGS material

into pellets.




The Pellet Plant will consist of:

• A pellet mill, housed in an extension to the existing DDG storage area. The pellet

mill machinery would include two discharges (through baghouses), each with a

discharge rate of approximately 500 m3/min.

• An internal mill conveyor under negative pressure and vented through a baghouse

at a discharge rate of approximately 12 m3/min.

• An enclosed product conveyor to transport the pelletised DDG from the pellet mill to

the existing DDG storage facility; and

• A pellet out-load system, which would be aspirated through a baghouse with a

nominal discharge rate of approximately 20 m3/min.

Given the potential for offensive odour emissions from the DDG plant process, air

emissions from the above discharge points will be ducted to the bioscrubber via a fabric

filter before being discharged to air.

Essentially the pellet plant will process granular DDGS material into pellets to better

enable this product to meet export demand. The existing granular DDGS material is

more suited to domestic markets. The processing of this granular material into pellets

will enable the Company to export this material overseas during periods when the local

demand for DDGS is reduced. This proposal essentially seeks to provide greater

flexibility for the processing of DDGS on the site to meet the demands of both the local

and export markets.

The additional benefit with the installation of a DDGS Pellet Plant is the anticipated role

that such a plant will have in reducing odours that emanate from this part of the site.

The Environmental Audit specifically recommended the installation of a DDGS Pellet

Plant.

The Pellet Plant will provide an alternative means of processing the DDGS material that

is processed on the site into an alternative product for re-sale and re-use.

Essentially DDGS from the DDGS Dryers that would otherwise be directed to the DDGS

load out as granular material will be able to be re-directed to the Pellet Plant.

In order to operate the additional plant it is proposed to construct an overhead gantry

linking the main factory site with the proposed additional plant at the DDGS site. This

gantry will house piping for additional services required for the additional plant. This

gantry is required as the provision of underground services is not practical due to:

• The need to cross Abernethy’s Creek.




• The location of existing buildings and services within this area.

• The service gantry includes steam pipes which should not be placed underground.

Such pipework if placed underground would need to be placed in a tunnel

construction which would not practically be possible to be sited through the subject

site.

A Motor Control Centre (MCC) is also proposed to be sited in this part of the complex.

The MCC will house transformers and switch gear to provide power to this area.

In addition to the proposed Pellet Plant, in accordance with the Company’s Odour

Management Plan prepared in response to the Environmental Audit, a number of

measures are initially proposed to reduce odours in the DDGS Plant including:

• improving the DDG Dryer fume handling system;

• covering or venting the condensate tank;

• better housekeeping initiatives;

• directing odour airstreams to a Bioscrubber.

Not all of these measures require development approval. It is proposed to measure the

effectiveness of these measures. If these measures are found to be insufficient, further

measures as proposed by the Environmental Audit will be implemented.

5.8.2 Waste Water Disposal

The increase in ethanol production will result in an increase in the volume of water used

in the upgraded plant processes and a subsequent increase in waste water.

The Company has been investigating various options with respect to the treatment and

re-use or disposal of additional waste water generated by the proposed ethanol upgrade.

The Company proposes to treat its waste water sequentially through anaerobic and

aerobic digestion systems located and incorporated within one of the existing waste

water storage ponds to fully treat all organic material and eliminate the odour generating

potential. The proposal therefore seeks to adapt the approved Wet Weather Storage

Pond No. 7 located upon the Company’s Environmental Farm for this purpose – refer

Plate 8.




Plate 8: Aerial view of proposed Waste Water Storage Ponds.

Anaerobic digestion is a biological process whereby organic wastes are broken down by

micro-organisms adapted for life and growth in the absence of dissolved oxygen that is

under anaerobic conditions. These micro-organisms obtain oxygen for their life

processes from the combined oxygen contained within the organic materials and

concomitantly generate a mixture of methane and carbon dioxide. So as the BOD is

digested, biogas containing energy-rich methane is produced. It is proposed to re-direct

this biogas for use as an energy source in the Factory’s operations. The process set up

in one of the ponds has been selected because of its ability to digest both dissolved and

particulate organic material. The large volume of the pond will also allow substantial

fluctuations in both the quantity and quality of the incoming waste water to be averaged

out. Anaerobic digestion is used as the first step of the overall digestion because it is

able to handle high concentrations of organic material. This step will not eliminate all the

organic material but will reduce it to a level that can be further processed to almost

complete removal by aerobic digestion.

The preferred anaerobic digester format, a Bulk Volume Fermenter (BVF), will comprise

a 90 ML lagoon/pond that will be completely covered with a gas tight floating cover.

Infrastructure within the pond under the cover will facilitate the action of the anaerobic

micro-organisms responsible for digestion of the soluble and suspended organic matter.

The average hydraulic residence time in the BVF will be about 10 days. Metabolism of

the organic matter will generate a mixture of methane and carbon dioxide. A small




negative pressure will be maintained under the cover by continuously withdrawing the

gas mixture (biogas) for use as an energy source.

The BVF system was selected as it eliminates the need for any primary treatment such

as dissolved air flotation and can accept soluble and suspended organic solids produced

at the factory. It will generate little waste sludge of its own, with the sludge/biomass

generated being digested downstream by the aerobic system. The large size of the BVF

and the volume of biomass provide a reactor that can absorb potential shock loadings of

pH, temperature or solids content. Biogas will be drawn off uniformly and continuously

for use in the boiler.

Residual soluble organic matter in the effluent from the BVF is further removed under

aerobic conditions by micro-organisms that metabolise this soluble organic matter to

generate biomass (microbial cells) and treated effluent. This process will occur in two

parallel systems, a Membrane Batch Reactor (MBR) and a sulphur oxidising (SO) basin.

The aerobic digestion process utilises micro-organisms that can utilise low levels of

soluble organic material as an energy source for life and growth. The consequence of

this activity is the generation of carbon dioxide and insoluble biomass ( the bacterial cells

themselves) while continually depleting the content of soluble organics from its

surroundings until there is little to none remaining. At this point the biomass can be

removed and the water released for disposal or re-use.

It is proposed to modify the approved Pond No. 7 to enable the sequential anaerobic and

aerobic processes. Residual volume will be used as additional wet weather storage

capacity. Pond 7 currently provides a storage capacity of 250 ML. It is proposed that

the anaerobic digestion pond will be approximately 90ML and will be sealed over by a

floating cover designed to eliminate air, to allow biogas collection underneath and to

prevent odour from escaping to the environment. The aerobic digestion will occur in an

adjacent 15 ML pond. To facilitate the whole process additionally an enclosed tank of

approximately 4 ML will act as an initial receival buffer so that any fluctuations in quality

of in-feed that might be injurious to the anaerobic micro-organisms can be identified and

averaged before being delivered into the anaerobic digester. Another pond

approximately 10 ML capacity will act as a holding buffer for the fully treated waste water

prior to its release for in-factory use, and irrigation on the Environmental Farm, or use by

the Australia Paper Mill.

Effluent from the MBR would be sent to the proposed Reverse Osmosis (RO) plant for

further treatment prior to its reuse at the factory, with the biomass being returned to the

BVF for digestion. The RO plant will consist of a two-train Koch module with a capacity




of up to 6 ML/day production of permeate (clean water) to be reused in the factory.

A two-train model was chosen to allow water treatment to continue when one train is

down for cleaning and/or maintenance.

The SO basin is a biological aerobic system that is designed to oxidise sulphur and

hence minimise the formation of reduced sulphur compounds, which can be potentially

odorous. The SO would be used for provide treated effluent to allow the sustainable

irrigation of the existing pasture at the Environmental Farm. In addition, the SO basin

allows for emergency treatment/storage of effluent from the BVF in the case of

breakdowns of the MBR or the RO plant.

Effluent from the SO basin and retentate from the RO plant would be used for

sustainable irrigation of pasture at the Environmental Farm. Two spray irrigation

systems will be used at the Farm; traveller and pivot sprays. The pivot spray systems

are fitted with low mist nozzles.

It is estimated that 70 cubic metres of biomass (4% solids) will be produced per day from

the BVF, which would be readily disposed to land by spray irrigation in less than one

hour during a given day.

• An irrigation management plan for the operation of the Environmental Farm is

addressed in Section 7.4 of this EA.

Figure 7 is a simple diagram detailing the water treatment process associated with the

proposal.

Figure 8 details a proposed water and waste water balance for the site following the

ethanol upgrade project.



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5.9 PROPOSED NEW PACKING PLANT AND CONTAINER LOADING AREA

It is also proposed to relocate the existing packing plant and its associated container

loading facilities from their current congested position within the existing factory complex

to an undeveloped property owned by the Manildra Group of Companies on the northern

side of Bolong Road (refer to Plate 9 – view of proposed packing plant). The property

comprises two allotments: Lot 5 DP 825808 and Lot 2 DP 538289 (refer Plates 10

and 11).

The future use of the building containing the existing packing plant has yet to be

determined.

Plate 9: View of Proposed Packing Plant




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Plate 10: Aerial view of site of proposed packing plant.

Plate 11: Aerial photograph over proposed Packing Plant site.

Proposed Packing Plant site

Bolong Road

Shoalhaven Starches factory site




Page 47

The proposal will seek to erect a purpose designed and built factory building with

dimensions of approximately 75 metres by 40 metres, and having a height of

approximately 10 metres above ground level. This building will also contain two storage

silos located centrally within the Packing Plant building and with heights of approximately

30 metres above ground level.

In addition to the above it is proposed to relocate the Company’s container loading

facility (associated with the packing plant) adjacent to the proposed new packing plant.

This area will comprise dimensions of approximately 80 metres by about 80 metres, and

will comprise a bitumen sealed hard stand surface. A new railway spur line is also

proposed to be extended from the existing railway to service this container loading area.

It is also proposed to install a weighbridge on this site.

It is proposed that dried gluten/starch will be pneumatically conveyed from the existing

site to the proposed new packing plant via an overhead bridge to cross Bolong Road.

This dried material will be pneumatically conveyed and stored in the proposed silos. This

overhead bridge will also double as a pedestrian bridge to improve safety for pedestrians

crossing between the existing factory site and the packing plant site.

The silos will feed the proposed new packing plant. The need for the new packing plant

has largely arisen from the demands of the Company’s customers who are seeking

improvements to the sealing of the bags used for packaging. At present difficulties arise

with the current packing plant whereby bags are filled and weighed separately. This

results in damages to the seals of bags through the ‘double handling’ of bags; resulting

in leakages.

The existing system involves product being blown into bags, which also results in the

escape of product resulting in product loss and dust generation.

The new packing plant will overcome these difficulties as product will not be blown into

bags, but rather mechanically packed. Furthermore, sealing and weighing operations

will be completed simultaneously resulting in a reduction in leakages.

Overall the new packing plant will provide a more efficient packaging system with less

product loss and dust generation. Air emissions, in particular odour emissions, from this

plant are anticipated to be negligible.

In addition the new system will result in a reduction of packaging materials. Under the

current system ‘3 ply’ paper bags are required to be used in packaging. The new

packing plant will be able to use ‘2 ply’ bags resulting in a 30% reduction in packaging

materials.




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Given the efficiency gains, the new packing plant will be able to meet the requirements

of the proposed production increases in starch and gluten, associated with this proposal.

The existing packing plant would not be able to meet these requirements; it simply does

not have the spare capacity.

The new plant will have other advantages:

• The existing plant is located within a heavily congested section of the factory. This

area has heavy truck; train; and forklift movements creating safety concerns for

employees. The new site will be significantly less congested.

• The existing packing plant, as with the remainder of the factory, operates 24 hours

per day, seven days a week, 365 days of the year. It is not possible to close the

existing packing plant operations down while new plant is installed. The new

packing plant will enable existing operations to continue up until the new packing

plant is commissioned.

• With heavy vehicles entering the site by left turn only via Bolong Road the number of

heavy vehicle movements crossing Bolong Road will be reduced; thereby reducing

the traffic conflicts along this route.

5.10 ENERGY AND UTILITIES

5.10.1 Energy

Baseline (2006-2007) energy used at the Shoalhaven Starches‘ operations during

operation are summarised as follows:

• Coal − 2,835,000 Gigajoules per annum (GJ/a)

• Natural gas − 168,536 GJ/a

• Diesel on-site − 25,476 GJ/a

• Electricity − 467,679 GJ/a

The total (gross) energy requirements for the plant following the upgrade proposal will be

as follows:

• Coal − 2,943,000 GJ/a

• Natural gas − 6,800,000 GJ/a

• Diesel on-site − 25,476 GJ/a

• Electricity − 50,400 GJ/a

(Reference – Greenhouse Gas Assessment – GHD Pty Ltd – Annexure N.)

In order to accommodate this increase in energy requirements, the Company proposes:




Page 49

• to install an additional gas-fired boiler; and

• a gas-fired co-generation plant.

Additional Gas-fired Boiler

The proposal includes an additional natural gas-fired boiler (20 MW) which would be

used as a standby system should any coal-fired units fail or are used to supplement the

steam supply should the coal-fired boilers not meet demand.

Co-generation Plant

It is also proposed to install a gas-fired co-generation plan, which would be used to

supply electricity and steam to the factory. Electric power using natural gas as fuel

would be generated using two gas turbine generators to deliver a net power output of

35 MW.

5.10.2 Water Supply

As will be explained in greater detail in Section 5.10 of this EA, the proposal will result in

an increase in water consumption at the plant to accommodate the upgrade. It is

proposed however to reduce the amount of potable water used at the site; and instead

increase the amount of raw water used at the site.

A daily average of 8,300 kilolitres of water is used presently by Shoalhaven Starches for

their total operations, comprising:

• 5,100 KL from the municipal drinking water supply; and

• 2,400 KL from a raw water supply provided by Shoalhaven City Council via a

pipeline from the Australian Paper Mill.

The proposed upgrade of the facilities for increased production of ethanol and gluten

and associated by-products will necessitate increased water usage; both potable water

for processing flour and non-potable water for steam generation, cooling and other uses.

After installation of the proposed Waste Water Treatment Plant and the availability of

treated water for re-use, daily water supply will comprise:

• 4,000 KL of potable quality water;

• 3,700 KL of raw water;

• 4,500 KL of treated water for re-use.

The Company will obtain 4000 KL of its potable water quality requirement from

Shoalhaven City Council. The remaining 4,500 KL of potable water will be obtained from




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water processed through the Waste Water Treatment Plant. The 3700 KL of raw water

will come from the Paper Mill as is currently the case.

5.10.3 Pipelines

The proposed upgrade will also require the following pipeline upgrades:

• At present a raw water pipeline extends from the Australian Paper Mill to the site to

supply the Company’s raw water supply requirements. This pipeline may require to

be augmented with an additional pipeline to accommodate increased raw water

volume.

• Methane will be generated from the proposed BVF reactor within the proposed

waste water treatment plant. It is proposed to capture this methane and direct it in a

pipeline back to the factory as a fuel in the boilers.

• The Water Treatment Plant will also require the extension of an electricity line

between the plant and the factory site.

• The siting of the new packing plant on the northern side of Bolong Road will

necessitate the transfer of product from the factory to this site via an overhead

bridge. This product will then be transferred by an overland pipeline between the

overhead bridge and the Packing Plant.




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6.0 STATUTORY APPROVAL CONTEXT

6.1 COMMONWEALTH LEGISLATION

6.1.1 Environment Protection & Biodiversity Conservation Act

The Commonwealth Environmental Protection and Biodiversity Conservation Act 1999

specifies that approval is required from the Commonwealth Minister for the Environment

for actions that have, will have or are likely to have a significant impact on a matter of

“national environmental significance”, including:

(i) declared World Heritage Areas;

(ii) declared RAMSAR wetlands;

(iii) listed threatened species and ecological communities;

(iv) listed migratory species;

(v) nuclear actions; and

(vi) the environment of Commonwealth marine areas.

Actions on or outside Commonwealth land that have, will have or are likely to have a

significant impact on the environment on or outside Commonwealth land must also be

referred to the Commonwealth Minister for assessment and approval.

The Department of Environment and Heritage (2005) has published guidelines to assist

in determining whether an action will have or is likely to have a significant impact on a

matter of national environmental significance and, hence, whether a referral should be

submitted to the Department for a decision by the Minister on whether assessment and

approval is required under the EPBC Act.

The Guidelines state that, to make a decision as to whether or not to refer an action to

the Minister, you should consider the following questions:

1. Are there matters of national environmental significance located in the area of the proposed action?

2. Considering the proposed action at its broadest scope, is there potential for impacts on matters of national environmental significance?

3. Are there any proposed measures to avoid or reduce impacts on matters of national environ-mental significance?

4. Are any impacts of the proposed action on matters of national environmental significance likely to be significant impacts?




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The Guidelines provide the following important definitions:

"A significant impact is an impact which is important, notable, or of consequence,

having regard to its context or intensity. Whether or not an action is likely to have a

significant impact depends upon the sensitivity, value, and quality of the environment

which is impacted, and upon the intensity, duration, magnitude and geographic extent

of the impacts. You should consider all of these factors when determining whether an

action is likely to have a significant impact on matters of national environmental

significance."

"To be likely, it is not necessary for a significant impact to have a greater then 50%

chance of happening, it is sufficient if a significant impact on a matter of national

environmental significance is a real or not remote chance or possibility."

"Population, in relation to critically endangered, endangered or vulnerable, threatened

species, means:

• a geographically distinct regional population, or collection of local populations; or

• a regional population, or collection of local populations occurring within a

particular bioregion."

"An important population is a population that is necessary for a species’ long-term

survival and recovery. This may include populations that are:

• key source populations either for breeding or dispersal;

• populations that are necessary for maintaining genetic diversity; and/or

• populations that are near the limit of the species' range.

"Habitat critical to the survival of a species refers to:

• habitat identified in a recovery plan for the species as habitat critical for those

species or communities; and/or

• habitat listed on the Register of Critical Habitat maintained by the Minister under

the Act; and/or

• areas that are necessary:

− for activities such as foraging, breeding, roosting, or dispersal,

− for succession,

− to maintain genetic diversity and long term evolutionary development, or

− for the reintroduction of populations or recovery of the species."




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A Flora and Fauna Assessment prepared by Kevin Mills & Associates (KMA) supports

this EA (Annexure E). In relation to the provisions of this legislation KMA conclude:

“The proposed upgrade is not likely to have a significant effect on any matters of national environmental significance listed under the Environment Protection and Biodiversity Conservation Act. Referral to the Commonwealth Environment Minister for approval is therefore not warranted.”

Issues pertaining to the ecological impacts associated with this proposal are addressed

in Section 7.13 of this EA.

6.1.2 Commonwealth Aboriginal Heritage Legislation

The Aboriginal and Torres Strait Islander Heritage Protection Act, 1984, provides for the

protection of areas and objects which are of significance to Aboriginal people in

accordance with Aboriginal tradition. The Act allows Aboriginals to apply to the Minister

to seek protection for significant Aboriginal areas and objects. The Minister has broad

powers to make such a declaration should the Minister be satisfied that the area or

object is a significant Aboriginal area or object and is under immediate threat of injury or

desecration. An ‘emergency declaration’ can remain in force for up to thirty days. It is

an offence under the Act to contravene a provision of a declaration. Provisions are

made for penalties of up to $50,000 for a corporation found guilty of contravening the Act

and up to $10,000 and imprisonment for a maximum of five years, for a person found

guilty of contravening the Act.

Under the Act, ‘Aboriginal tradition’ means:

‘the body of traditions, observances, customs and beliefs of Aboriginals generally or of a particular community or group of Aboriginals, and includes such traditions, observances, customs or beliefs relating to particular persons, areas, objects or relationships’ (Section 3).

A ‘significant Aboriginal area’ refers to:

An area of land or water in Australia being of ‘particular significance to Aboriginals in accordance with Aboriginal tradition’ (Section 3).

A ‘significant Aboriginal object’ refers to:

An object (including Aboriginal remains) of ‘particular significance to Aboriginals in accordance with Aboriginal traditions’ (Section 3).

For the purposes of the Act, an area or object is considered to be injured or desecrated

if:

a) in the case of an area, it is used or treated in a manner inconsistent with Aboriginal tradition; or the use or significance of the area in accordance with Aboriginal tradition is adversely affected by reason of




Page 54

anything done in or near the area; or passage through or over, or entry upon the area by any person occurs in a manner inconsistent with Aboriginal tradition; and

b) in the case of an object, it is used or treated in a manner inconsistent with Aboriginal tradition (Section 3).

A national heritage system commenced on 1 January 2004, largely replacing the

previous Australian Heritage Commission Act 1975; its primary features under the

amended Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)

and the Australian Heritage Council Act 2003 include:

• A National Heritage List of places of national heritage significance;

• A Commonwealth Heritage List of heritage places owned or managed by the

Commonwealth;

• Creation of the Australian Heritage Council – an independent expert body to advise

the Minister on the listing and protection of heritage places; and

• Continued management of the Register of the National Estate, a list of more than

13,000 heritage places around Australia that has been compiled by the former

Australian Heritage Commission since 1976.

This EA is supported by an Aboriginal Heritage Assessment prepared by South East

Archaeology (Annexure D). This assessment identifies that the lands affected by the

project does not contain any heritage items registered for indigenous values under the

Aboriginal and Torres Strait Islander Heritage Protection Act 1984, Environmental

Protection and Biodiversity Conservation Act 1999 or the Australian Heritage Council Act

2003.

6.2 STATE LEGISLATION

6.2.1 Environmental Planning & Assessment (EP&A) Act 1979

Objects of the EP&A Act

Section 5 of the Act outlines the objects of the Act as follows:

5 Objects

The objects of this Act are:

(a) to encourage:

(i) the proper management, development and conservation of natural and artificial resources, including agricultural land, natural areas, forests, minerals, water, cities, towns and villages for the




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purpose of promoting the social and economic welfare of the community and a better environment,

(ii) the promotion and co-ordination of the orderly and economic use and development of land,

(iii) the protection, provision and co-ordination of communication and utility services,

(iv) the provision of land for public purposes,

(v) the provision and co-ordination of community services and facilities, and

(vi) the protection of the environment, including the protection and conservation of native animals and plants, including threatened species, populations and ecological communities, and their habitats, and

(vii) ecologically sustainable development, and

(viii) the provision and maintenance of affordable housing, and

(b) to promote the sharing of the responsibility for environmental planning between the different levels of government in the State, and

(c) to provide increased opportunity for public involvement and participation in environmental planning and assessment.

Comments

The proposal is consistent with the above objects as:

• The proposal seeks to increase ethanol production. Ethanol is a renewable fuel that

lessens reliance on fossil fuels.

• It reduces greenhouse gas emissions and other air pollutants.

• It reduces imports of oil and stimulates regional and local economics.

• The proposal will sustainably maintain the existing workforce at the plant; and

increase employment for an additional 25 positions.

• The proposal includes a comprehensive approach to the protection of the

environment including odour reduction and the re-use of waste waters both within

factory processes and for irrigation of farmland.

Part 3A Major Projects

The introduction of Part 3A to the Environmental Planning & Assessment Act 1979; and

the introduction of State Environmental Planning Policy (Major Projects); brought about a

change in the regime concerning the assessment of state significant development.

Pursuant to Section 75B of the Act, development subject to the provisions of Part 3A of




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the Act includes development referred to within a State Environmental Planning Policy.

The Minister for Planning is the consent authority for such development.

State Environmental Planning Policy (Major Projects) supports the introduction of

Part 3A to the Act. Schedules 1 and 2 of this SEPP outline those developments that are

essentially subject to the provisions of Part 3A of the Act.

Schedule 1 SEPP (Major Projects)

Schedule 1 of SEPP (Major Projects) outlines classes of development that, if in the

opinion of the Minister, are declared to be projects to which Part 3A of the Act apply.

Group 1 within this schedule outlines criteria for agricultural, timber and related

industries and includes:

3 Agricultural produce industries and food and beverage processing

Development that employs 100 or more people or has a capital investment value of more than $30 million for any of the following purposes:

(a) abattoirs or meat packing, boning or products plants; milk or butter factories; fish packing, processing, canning or marketing facilities; animal or pet feed; gelatine plants; tanneries; wool scouring or topping; rendering plants, or

(b) cotton gins; cotton seed mills; sugar mills; sugar refineries; grain mills or silo complexes; edible or essential oils processing; breweries; distilleries; ethanol plants; soft drink manufacture; fruit juice works; canning or bottling works; bakeries; small goods manufacture, cereal processing or margarine manufacturing, or

(c) organic fertiliser plants or composting facilities or works.

This proposal includes alterations and additions to an exiting ethanol plant that currently

employs 250 people. The proposed alterations and additions to the factory are

estimated to involve a capital investment of approximately $200 million and will provide

on-going employment for up to an additional 25 people in the operation of the plant.

Schedule 2 SEPP (Major Projects)

Schedule 2 of SEPP (Major Projects) also outlines those classes of development

situated within the coastal zone that are also deemed to be state significant

development. This Schedule includes:

1 Coastal areas

(1) Development within the coastal zone for any of the following purposes:

(a) extractive industries,

(b) landfill facilities,




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(c) mining that is designated development and that is wholly or partly in a sensitive coastal location,

(d) marinas that are designated development and that are wholly or partly in a sensitive coastal location,

(e) the following types of industries (other than mining or extractive industries) but only if they are:

(i) designated development, and

(ii) in the case of the metropolitan coastal zone—wholly or partly in a sensitive coastal location:

agricultural produce industries, bitumen pre-mix industries, breweries or distilleries, cement works, ceramic or glass industries, chemical industries or works, chemical storage facilities, composting facilities or works, contaminated soil treatment works, crushing, grinding or separating works, drum or container reconditioning works, electricity generating stations, livestock intensive industries, livestock processing industries, mineral processing or metallurgical works, paper, pulp or pulp products industries, petroleum works, wood or timber milling or processing works, or wood preservation works,

The subject site is situated within the Coastal zone. The classes of development

outlined in bold above are applicable to the subject site.

Relevant legislation and other approvals

Approvals under the eight Acts listed under Section 75U Clause 1 of the EP&A Act are

not required for developments identified as Major Projects. These Acts include:

a) the concurrence under Part 3 of the Coastal Protection Act 1979 of the Minister administering that Part of the Act,

(b) a permit under section 201, 205 or 219 of the Fisheries Management Act 1994,

(c) an approval under Part 4, or an excavation permit under section 139, of the Heritage Act 1977,

(d) a permit under section 87 or a consent under section 90 of the National Parks and Wildlife Act 1974,

(e) an authorisation referred to in section 12 of the Native Vegetation Act 2003 (or under any Act to be repealed by that Act) to clear native vegetation,

(f) a permit under Part 3A of the Rivers and Foreshores Improvement Act 1948,

(g) a bush fire safety authority under section 100B of the Rural Fires Act 1997,




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(h) a water use approval under section 89, a water management work approval under section 90 or an activity approval under section 91 of the Water Management Act 2000.

Section 79C - Matters for Consideration

Section 79C of the Act outlines that matters that must be evaluated or taken into

consideration with respect to development applications. Section 79C outlines the

following:

79C Evaluation

(1) Matters for consideration-general. In determining a development application, a consent authority is to take into consideration such of the following matters as are of relevance to the development the subject of the development application:

(a) the provisions of:

(i) any environmental planning instrument, and

(ii) any draft environmental planning instrument that is or has been placed on public exhibition and details of which have been notified to the consent authority (unless the Director-General has notified the consent authority that the making of the draft instrument has been deferred indefinitely or has not been approved), and

(iii) any development control plan, and

(iiia) any planning agreement that has been entered into under section 93F, or any draft planning agreement that a developer has offered to enter into under section 93F, and

(iv) the regulations (to the extent that they prescribe matters for the purposes of this paragraph),

that apply to the land to which the development application relates,

(b) the likely impacts of that development, including environmental impacts on both the natural and built environments, and social and economic impacts in the locality,

(c) the suitability of the site for the development,

(d) any submissions made in accordance with this Act or the regulations,

(e) the public interest.

Comments

The above matters are addressed within the body of this EA.




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6.2.2 Threatened Species Conservation Act

The New South Wales Environmental Planning and Assessment Act 1979, as amended

by the Threatened Species Conservation Act 1995 and Threatened Species

Conservation Amendment Act 2002, requires that various factors be taken into account

in deciding whether a proposed action, development or activity is likely to have a

significant effect on threatened species, populations or communities, or their habitats

and, hence, whether the preparation of a Species Impact Statement (SIS) is warranted.

The TSC Amendment Act also specifies that any assessment guidelines issued by the

Minister for the Environment be taken into account when making an assessment of

significance. The Department of Environment and Conservation published the

guidelines in August 2005. Referred to as the Assessment of Significance Guidelines,

they clarify technical terms and assist in the interpretation and application of the various

factors.

The Guidelines state that:

"the revised factors maintain the same intent [as the Eight Part Test] but focus consideration of the likely impacts in the context of the local rather than the regional environment as the long-term loss of biodiversity at all levels arises primarily from the accumulation of losses and depletions of populations at a local level. This is the broad principle underpinning the TSC Act, State and Federal biodiversity strategies and national agreements. The consideration of impacts at a local level is designed to make it easier for local government to assess, and easier for applicants and consultants to undertake the Assessment of Significance because there is no longer a need to research regional and statewide information in considering potential impacts. Further consideration is required when a significant effect is likely and is more appropriately considered when preparing a Species Impact Statement."

"When applying each factor, consideration must be given to all of the likely direct and indirect impacts of the proposal. Direct impacts are those that directly affect habitat and individuals and include but are not limited to acute death through predation, trampling, poisoning of the animal/plant itself and removal of suitable habitat. Indirect impacts occur when project-related activities affect resources in a manner other than a direct loss of the resource. A broad range of impacts need to be considered, for example, killing of species through starvation, exposure, predation, by domestic and/or feral animals, loss of breeding opportunities, loss of shade/shelter, deleterious changes in the water table, increased soil salinity, promotion of erosion, inhibition of nitrogen fixation, provision of suitable seed bed for exotic weed invasion, fertiliser drift, or increased human activity within or directly adjacent to sensitive habitat areas."




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"Mitigating, ameliorative or compensatory measures proposed as part of the action, development or activity should not be considered in determining the degree of effect on threatened species, populations, or ecological communities, unless the measure has been proven successful for that species in a similar situation."

"In determining the nature and magnitude of an impact, it is important to consider matters such as:

• Pre-construction, construction and occupation/maintenance phases,

• All on-site and off-site impacts, including location, installation, operation and maintenance of auxiliary infrastructure and fire management zones,

• All direct and indirect impacts,

• The frequency and duration of each known or likely impact/action,

• The total impact which can be attributed to that action over the entire geographic area affected, and over time,

• The sensitivity of the receiving environment, and

• The degree of confidence with which the impacts of the action are known and understood."

"Application of the precautionary principle requires that a lack of scientific certainty about the potential impacts of an action does not in itself justify a decision that the action is not likely to have a significant impact. If the information is not available to conclusively determine that there will not be a significant impact on the threatened species, population or ecological community, or its habitat then it should be assumed that a significant impact is likely."

The factors to be considered are as follows:

(a) in the case of a threatened species, whether the action proposed is likely to have an adverse effect on the life cycle of the species such that a viable local population of the species is likely to be placed at risk of extinction;

(b) in the case of an endangered population, whether the action proposed is likely to have an adverse effect on the life cycle of the species that constitutes the endangered population such that a viable local population of the species is likely to be placed at risk of extinction;

(c) in the case of an endangered ecological community or critically endangered ecological community, whether the action proposed;

(i) is likely to have an adverse effect on the extent of the ecological community such that its local occurrence is likely to be placed at risk of extinction;




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(ii) is likely to substantially and adversely modify the composition of the ecological community such that its occurrence is likely to be placed at risk of extinction;

(d) in relation to the habitat of a threatened species, population or ecological community;

(i) the extent to which habitat is likely to be removed or modified as a result of the action proposed;

(ii) whether an area of habitat is likely to become fragmented or isolated from other areas of habitat as a result of the proposed action;

(iii) the importance of the habitat to be removed, modified, fragmented or isolated to the long-term survival of the species, population or ecological community in the locality;

(e) whether the action proposed is likely to have an adverse effect on critical habitat (either directly or indirectly);

(f) whether the action proposed is consistent with the objectives or actions of a recovery plan or threat abatement plan;

(g) whether the action proposed constitutes or is part of a key threatening process or is likely to result in the operation of, or increase the impact of, a key threatening process.

A Flora and Fauna Assessment prepared by Kevin Mills & Associates (KMA) supports

this EA (Annexure E). In relation to the provisions of this legislation KMA conclude:

“The proposed upgrade is not likely to have a significant effect on species, populations or communities listed under the Threatened Species Conservation Act 1995, or their habitats; hence, the preparation of a Species Impact Statement (SIS) is not warranted.”

Issues pertaining to the ecological impacts associated with this proposal are addressed

in Section 7.13 of this EA.

6.2.3 Protection of the Environment Operations Act

The existing development has an Environmental Protection Licence (EPL) under the

Protection of the Environment Operations Act 1997 (POEO Act) (EPL No. 883). The

licence imposes requirements in terms of:

• discharges to air, water and land;

• irrigation controls;

• management of irrigation;

• maintenance of irrigation reticulation;

• odour control.




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The proposal will necessitate the modification of the terms / provisions of this licence to

be reviewed.

6.2.4 Water Management Act 2000

The Water Management Act 2000 (WMA) brought into effect in February 2008 the

provision for controlled activities for certain types of developments and activities carried

out in or near a river, lake or estuary. The purpose of WMA 2000 is to provide

sustainable, integrated and comprehensive management of NSW State waters and a

guide for water management activities (DNR, 2008).

The NSW Department of Water and Energy (DWE) administers the WMA 2000 and has

developed guidelines to assist applicants considering carrying out a controlled activity on

waterfront land. The guidelines provide information on the design and construction of

controlled activities and other mechanisms for the protection of waterfront land,

including:

• in-stream works;

• laying pipes and cables in watercourses;

• outlet structures;

• riparian corridors;

• Vegetation Management Plans;

• watercourse crossings.

Given the provisions of Section 75U of the EP&A Act (as outlined in Section 6.2.4 of this

EA) as the proposal constitutes a Major Project the need to obtain a controlled activity

approval pursuant to Section 91 of this Act is not required.

6.2.5 Native Vegetation Act 2003

The objectives of the Native Vegetation Conservation Act essentially relate to the

conservation and management of native vegetation. The definition of “native vegetation”

under the Act is quite broad, it includes; trees, understorey plants, groundcovers and

plants occurring in a wetland. Under the provisions of Section 12 of the Act, the clearing

of native vegetation (except under certain exemption and exclusion circumstances)

requires to obtain an approval under this legislation from the relevant Catchment

Management Authority.

Pursuant to Section 5 of this Act certain land is excluded from the provisions of this

legislation including land within a zone designated “residential” (but not “rural-




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residential”), “village”, “township”, “industrial” or “business” under an environmental

planning instrument. Works associated with the factory site and packing plant are zoned

Industrial 4(e) and is therefore excluded from the provisions of this legislation.

Furthermore pursuant to Section 75U(e) of the EP&A Act, an approval under Section 12

of this Act is not required to be obtained for a project affected by Part 3A of the EP&A

Act.

Under these circumstances this legislation does not apply to this proposal.

6.2.6 The Roads Act 1993

Section 138 of the Roads Act deals with works and structures within road reserves and

states:

138 Works and structures

(1) A person must not:

(a) erect a structure or carry out a work in, on or over a public road, or

(b) dig up or disturb the surface of a public road, or

(c) remove or interfere with a structure, work or tree on a public road, or

(d) pump water into a public road from any land adjoining the road, or

(e) connect a road (whether public or private) to a classified road,

otherwise than with the consent of the appropriate roads authority. Maximum penalty: 10 penalty units.

(2) A consent may not be given with respect to a classified road except with the concurrence of the RTA.

(3) If the applicant is a public authority, the roads authority and, in the case of a classified road, the RTA must consult with the applicant before deciding whether or not to grant consent or concurrence.

(4) This section applies to a roads authority and to any employee of a roads authority in the same way as it applies to any other person.

(5) This section applies despite the provisions of any other Act or law to the contrary, but does not apply to anything done under the provisions of the Pipelines Act 1967 or under any other provision of an Act that expressly excludes the operation of this section.

The current proposal does include the laying of pipework along and across Bolong

Road, specifically in terms of water and gas (methane) pipelines between the site and




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the Paper Mill. In addition the proposal includes the provision of a pedestrian/product

overhead bridge over Bolong Road. These works are proposed to be undertaken along

and over Bolong Road. Such works will therefore necessitate approvals under Section

138 of the Roads Act. This will also trigger the integrated development provisions of the

EP&A Act.

6.2.7 National Parks and Wildlife Act 1975

The National Parks and Wildlife Act 1974 (as amended) provides the primary basis for

the legal protection and management of Aboriginal heritage sites within NSW.

Implementation of the Aboriginal heritage provisions of this Act is the responsibility of the

Department of Environment and Climate Change (NSW) (DECC). The rationale behind

the Act is to prevent unnecessary or unwarranted destruction of Aboriginal objects and

to protect and conserve objects where such action is considered warranted.

With the exception of some artefacts in collections, the Act generally defines all

Aboriginal objects to be the property of the Crown. The Act then provides various

controls for the protection, management and destruction of these objects. An ‘Aboriginal

object’ is defined as

‘any deposit, object or material evidence (not being a handicraft made for sale) relating to the Aboriginal habitation of the area that comprises New South Wales, being habitation before or concurrent with (or both) the occupation of that area by persons of non-Aboriginal extraction, and includes Aboriginal remains’ [Section 5(1)].’

Under the terms of the National Parks and Wildlife Act 1974, it is an offence for a person

to:

• Knowingly destroy, damage or deface an Aboriginal object or place, or knowingly

cause or permit the destruction, defacement or damage to an Aboriginal object or

place, without first obtaining the consent of the Director-General of DECC;

• Disturb or excavate any land, or cause any land to be disturbed or excavated, for

the purpose of discovering an object, without first obtaining the consent of the

Director-General of DECC; and

• Collect on any land an object that is the property of the Crown, other than an object

under the control of the Australian Museum, without obtaining appropriate

authorisation from the Director-General of DECC.

Under the National Parks and Wildlife Act 1974, ‘Aboriginal areas’ may also be declared

over private land, where Aboriginal objects or places are located, with the consent of the

owner or occupier. The purpose of reserving land as an ‘Aboriginal area’ is to identify,




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protect and conserve areas associated with a person, event or historical theme, or

containing a building, place, object, feature or landscape of natural or cultural

significance to Aboriginal people, or of importance in improving public understanding of

Aboriginal culture and its development and transitions (Section 30K).

Under Section 91AA of the Act, if the Director-General is of the opinion that any action is

being, or is about to be carried out that is likely to significantly affect an Aboriginal object

or Aboriginal place or any other item of cultural heritage situated on land reserved under

the Act, the Director-General may make a stop-work order for a period of 40 days.

Under the Part 3A Major Project amendments to the Environmental Planning and

Assessment Act 1979 (EP&A Act), subsequent to approval being granted, Section 90

Consent to impact Aboriginal objects or a Section 87 Permit under the National Parks

and Wildlife Act 1974 may not be required. In lieu however, a Part 3A application

involving a Statement of Commitments outline proposed heritage management and

mitigation measures must be approved. Also, under more recent Part 3A Major Project

amendments (Section 75U{4}), a Section 87 Permit may not be required for investigation

of artefact deposits where the investigation is being undertaken for the purpose of

complying with an environmental assessment requirements issued in connection with an

application for approval to carry out a project or for a concept plan for a project.

6.3 STATE ENVIRONMENTAL PLANNING POLICIES

The following State Environmental Planning Policies (SEPPs) are relevant to the

consideration of the proposed development:

6.3.1 SEPP No. 14 - Coastal Wetlands

The aim of this policy is to “ensure that coastal wetlands are preserved and protected in

the environmental and economic interest of the state”.

In respect of land to which this policy applies, development consent is required to:

(a) clear that land; (b) construct a levee on that land; (c) drain that land; or (d) fill that land.

One SEPP No. 14 wetland (No. 369) is located within the Company’s Environmental

Farm land located across Bolong Road to the north of the factory site. The works

associated with this proposal however are not sited within the vicinity of this wetland.

The provisions of this SEPP will therefore not apply to this proposal.




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6.3.2 SEPP No. 33 - Hazardous and Offensive Development

The Shoalhaven factory site comprises a “potentially hazardous industry” and “potentially

offensive industry” under the provisions of this SEPP. “Potential hazardous industry” as

defined by clause 3 of the SEPP means:

““potentially hazardous industry" means a development for the purposes of any industry which, if the development were to operate without employing any measures (including, for example, isolation from existing or likely future development on other land) to reduce or minimise its impact in the locality or on the existing or likely future development on other land, would pose a significant risk in relation to the locality:

(a) to human health, life or property, or

(b) to the biophysical environment,

and includes a hazardous industry and a hazardous storage establishment.”

Under the provisions of clause 12 of this SEPP any proposal involving a potentially

hazardous industry must prepare a Preliminary Hazard Analysis in accordance with the

relevant Circulars and Guidelines published by the Department of Planning.

A Preliminary Hazard Analysis has been prepared for this project by GHD Pty Ltd and

forms Annexure F to this EA. This matter is further addressed in Section 7.8 of this EA.

6.3.3 SEPP No. 71 - Coastal Protection

On the 1st November 2002 the State Government gazetted SEPP No. 71. This policy

• “identifies State significant development in the coastal zone, and

• requires development applications to carry out development in sensitive coastal locations to be referred to the Director-General for comment, and

• identifies master plan requirements for certain development in the coastal zone.”

The coastal zone has the same meaning as in the Coastal Protection Act 1979. This Act

essentially maps the area of land and waters that lie to the west of coastal waters. From

a perusal of this mapping it is evident that the coastal zone covers the subject land.

Under these circumstances, the subject site would be affected by the provisions of this

Policy.

The proposal is consistent with the objectives of the Policy and the matters for

consideration, as detailed in clause 8 of the Policy for the following reasons:




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• The proposal does not affect or impinge on public access to or along the coastal

foreshore. Given the nature of the bank of the Shoalhaven River which adjoins the

subject site there is little opportunity to provide public access along this foreshore.

• The proposed works are situated within an industrial zoned area within the vicinity of

industrial plant of a similar purpose, scale and height as that which is proposed and

is therefore considered to be suitable development given its type, location and

design.

• The development will not result in any additional overshadowing of foreshore areas

compared to that which currently occurs. The proposed works are of a height and

scale that matches existing development on the site.

• The scenic qualities of the area will not diminish (refer Section 7.12 of this EA).

• The proposal will not lead to adverse impacts on threatened fauna and flora (refer

Section 6.2.2 of this EA).

• The proposal does not propose any structures that are likely to impact on fish,

marine vegetation or their habitats.

• The site is not identified as a wildlife corridor.

• It is considered that the proposal will not lead to conflict between land based and

water based coastal activities.

• It is not anticipated that the proposal will impact on Aboriginal heritage (refer Section

7.14.1 of this EA).

In terms of the provisions of Part 4 of the SEPP (clauses 13 – 16) the following

comments are made:

• The proposed development will not impede or diminish public access to coastal

foreshore areas. As outlined above given the nature of the bank of the Shoalhaven

River which adjoins the subject site there is little opportunity to provide new public

access along this foreshore

• The proposal includes a comprehensive waste water treatment plant to treat waste

waters associated with the project.

• The development will not impact upon local stormwater quality (refer Section 7.5.2

of this EA).

The development is also not subject to the provisions of Part 5 (Master Plans) of the

SEPP as the proposal does not seek to subdivide land.




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6.3.4 SEPP (Major Projects) 2005

The aims of this Policy are as follows:

(a) to identify development to which the development assessment and approval process under Part 3A of the Act applies;

(b) to identify any such development that is a critical infrastructure project for the purposes of Part 3A of the Act;

(c) to facilitate the development, redevelopment or protection of important urban, coastal and regional sites of economic, environmental or social significance to the State so as to facilitate the orderly use, development or conservation of those State significant sites for the benefit of the State;

(d) to facilitate service delivery outcomes for a range of public services and to provide for the development of major sites for a public purpose or redevelopment of major sites no longer appropriate or suitable for public purposes;

(e) to rationalise and clarify the provisions making the Minister the approval authority for development and sites of State significance, and to keep those provisions under review so that the approval process is devolved to Councils when State planning objectives have been achieved.

This SEPP is addressed in Section 6.2.1 of this report. Essentially the Minister has

declared that this project is a Major Project pursuant to the provisions of Part 3A of the

EP&A Act and SEPP (Major Projects) 2005. The provisions of this policy therefore apply

to this project.

6.3.5 SEPP (Infrastructure) 2007

SEPP (Infrastructure) was made by the NSW Government on the 21st December 2007.

The stated aims of the SEPP are to facilitate the effective delivery of infrastructure

across the State by:

(a) improving regulatory certainty and efficiency through a consistent planning regime for infrastructure and the provision of services, and

(b) providing greater flexibility in the location of infrastructure and service facilities, and

(c) allowing for the efficient development, redevelopment or disposal of surplus government owned land, and

(d) identifying the environmental assessment category into which different types of infrastructure and services development fall (including identifying certain development of minimal environmental impact as exempt development), and




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(e) identifying matters to be considered in the assessment of development adjacent to particular types of infrastructure development, and

(f) providing for consultation with relevant public authorities about certain development during the assessment process or prior to development commencing.

Division 17 of the SEPP relates to Roads and Traffic Clause 101 of the SEPP reads:

101 Development with frontage to classified road

(1) The objectives of this clause are:

(a) to ensure that new development does not compromise the effective and ongoing operation and function of classified roads, and

(b) to prevent or reduce the potential impact of traffic noise and vehicle emission on development adjacent to classified roads.

(2) The consent authority must not grant consent to development on land that has a frontage to a classified road unless it is satisfied that:

(a) where practicable, vehicular access to the land is provided by a road other than the classified road, and

(b) the safety, efficiency and ongoing operation of the classified road will not be adversely affected by the development as a result of:

(i) the design of the vehicular access to the land, or

(ii) the emission of smoke or dust from the development, or

(iii) the nature, volume or frequency of vehicles using the classified road to gain access to the land, and

(c) the development is of a type that is not sensitive to traffic noise or vehicle emissions, or is appropriately located and designed, or includes measures, to ameliorate potential traffic noise or vehicle emissions within the site of the development arising from the adjacent classified road.

Clause 104 of the SEPP reads:

“104 Traffic-generating development

(1) This clause applies to development specified in Column of Table to Schedule 3 that involves:

(a) new premises of the relevant size or capacity, or

(b) an enlargement or extension of existing premises, being an alteration or addition of the relevant size or capacity.

(2) In this clause, “relevant size or capacity” means:




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(a) in relation to development on a site that has direct vehicular or pedestrian access to any road – the size or capacity specified opposite that development in Column 2 of the Table to Schedule 3, or

(b) in relation to development on a site that has direct vehicular or pedestrian access to a classified road or to a road that connects to a classified road where the access (measured along the alignment of the connecting road) is within 90 m of the connection – the size or capacity specified opposite that development in Column 3 of the Table to Schedule 3.

(3) Before determining a development application for development to which this clause applies, the consent authority must:

(a) give written notice of the application to the RTA within 7 days after the application is made, and

(b) take into consideration:

(i) any submission that the RTA provides in response to that notice within 21 days after the notice was given (unless, before the 21 days have passed, the RTA advises that it will not be making a submission), and

(ii) the accessibility of the site concerned, including:

(A) the efficiency of movement of people and freight to and from the site and the extent of multi-purpose trips, and

(B) the potential to minimise the need for travel by car and to maximise movement of freight in containers or bulk freight by rail, and

(iii) any potential traffic safety, road congestion or parking implications of the development.

(4) The consent authority must give the RTA a copy of the determination of the application within 7 days after the determination is made.”

Annexure G to this EA is a Traffic Assessment prepared by Christopher Stapleton

Consulting. Traffic issues are further addressed in Section 7.7 of this EA.

6.3.6 NSW Coastal Policy

The State Coastal Policy applies generally:

• three nautical miles seaward of the mainland and offshore islands;

• one kilometre landward of the open coast high water mark;

• a distance of one kilometre around:




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⇒ all bays, estuaries, coastal lakes, lagoons and islands;

⇒ tidal waters of coastal rivers to the limit of mangroves as defined by NSW

Fisheries (1985) maps or the tidal limit whichever is closer to the sea;

• within the line on the maps being taken to the nearest cadastral boundary and/or

easily recognisable physical boundary, in consultation with coastal councils.

The relevant objectives of the State Coastal Policy in terms of this proposal are:

• To give the impacts of natural processes and hazards a high priority in the planning and management of coastal areas;

• To identify and protect areas of high natural or built aesthetic quality.

• To design and locate development to complement the surrounding environment and to recognise good aesthetic qualities.

• To effectively manage and conserve cultural heritage places, items and landscapes.

• To identify and facilitate opportunities for the sustainable development and use of resources.

• To develop land use and management plans which ensure the sustainable development and use of resources.

Annexure H to this EA includes a checklist addressing how the provisions of the Coastal

Policy apply to this proposal.

6.3.7 Riparian Corridor Guidelines for Controlled Activities

DWE is required to assess the impact of a controlled activity to ensure that there will be

minimal impact on waterfront land. The guidelines (DWE, 2008) define three riparian

corridor zones that should be considered when determining appropriate riparian corridor

widths for a controlled activity:

1. A Core Riparian Zone (CRZ) is the land contained within and adjacent to the channel. The Department will seek to ensure that the CRZ remains, or becomes vegetated, with fully structured native vegetation (including groundcovers, shrubs and trees). The width of the CRZ from the banks of the stream is determined by assessing the importance and riparian functionality of the watercourse (Table 1), merits of the site and long-term use of the land. There should be no infrastructure such as roads, drainage, stormwater structures, services, etc. within the CRZ.

2. A Vegetated Buffer (VB) protects the environmental integrity of the CRZ from week invasion, micro-climate changes, litter, trampling and pollution. There should be no infrastructure such as roads, drainage,




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stormwater structures, services, etc. within the VB. The recommended width of the VB is 10 metres but this depends on merit issues.

3. An Asset Protection Zone (APZ) is a requirement of the NSW Rural Fire Service and is designed to protect assets (houses, buildings, etc.) from potential bushfire damage. The APZ is measured from the asset to the outer edge of the vegetated buffer (VB). The APZ should contain cleared land which means that it can not be part of the CRZ or VB. The APZ must not result in clearing of the CRZ or VB. Infrastructure such as roads, drainage, stormwater structures, services, etc. can be located within APZs.

DWE recommends riparian corridor widths for controlled activities be based on

watercourse order with consideration given to the merit of the site and any impacts of the

proposed activity. DWE specified in the DG’s requirements for the Shoalhaven Starches

Ethanol Plant expansion that watercourse classification and corridor widths are based on

the Riparian Corridor Management Study (RCMS) Guidelines developed by the former

DIPNR (2004).

The EA is supported by an assessment prepared by Coffey Environments Pty Ltd which

addresses the requirements of these guidelines. A copy of this assessment forms

Annexure I to this EA. Riparian corridor issues are discussed in Section 7.9 of the EA.

6.3.8 Riparian Corridor Management Study Guidelines

The RCMS Guidelines provides a stream classification system to identify minimum

riparian corridor widths along watercourses. This body of work was initially developed

for the Wollongong LGA. The RCMS process has since been widely adopted and

applied to the Northwest and Southwest growth centres, other LGAs and land release

sites, and in the Riparian Corridor Guidelines for Controlled Activities of WMA 2000.

The stream classification system of the RCMS process incorporates three categories

that reflect the environmental significance of watercourses. The purpose of each

category and minimum riparian widths are as follows:

1 Category 1 – Environmental Corridor

Purpose: to protect and enhance ecological connectivity between key remnant

native vegetation within and between catchments and achieving all four key

objectives.

Minimum width: a CRZ of 40 m (measure from top of bank) along both sides of the

watercourse and a 10 m vegetated buffer zone.




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2 Category 2 – Terrestrial and Aquatic Habitat

Purpose: to provide for a viable and robust node or reach of riparian habitat (both

aquatic and terrestrial) that would achieve key objectives one, two and three.


watercourse and a 10 m vegetated buffer zone.

3 Category 3 – Bank Stability and Water Control

Purpose: recognises the critical role of riparian vegetation for stabilising the bed

and banks of watercourses and filtering catchment run-off and the contribution of

this to overall catchment health and retention of land, thus achieving objectives

one and two.


watercourse with no requirement for a buffer zone.

The EA is supported by an assessment prepared by Coffey Environments Pty Ltd which

addresses the requirements of these guidelines. A copy of this assessment forms

Annexure I to this EA. Riparian corridor issues are discussed in Section 7.9 of the EA.

6.4 REGIONAL ENVIRONMENTAL PLANS AND STRATEGIES

6.4.1 Illawarra Regional Environmental Plan

The subject site is affected by the provisions of the Illawarra Regional Environmental

Plan (IREP). The IREP was gazetted on 11 April 1986 and provides a statutory

framework that ensures that regional needs and interests are taken into account in local

and state planning activities.

The main purpose of the IREP is to provide a framework for the coordination of

responsibilities between State and local government agencies, to ensure that:

• the best use of land resources is achieved;

• the quality of life, especially as it is affected by land use is maintained and where

possible improved;

• regional needs and interests are taken into account in local and state planning;

• a stable and attractive climate exists for public and private investment.

From a perusal of the plans which accompany the IREP it is evident that the subject land

has been identified as part of a large area of land in the Nowra / Bomaderry district with




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landscape or environmental attributes. Shoalhaven Starches Environmental Farm is also

identified as comprising largely land identified as prime crop and pasture land,

Prime Crop and Pasture Land

Clause 12 of the IREP refers to the subdivision of land that is identified as prime crop

and pasture land and states:

12 Subdivision of land for agriculture

(1) Where an environmental planning instrument provides that land, the whole or any part of which is identified on the map as land of prime crop and pasture potential, may be subdivided to create an allotment of less than 40 hectares to be used for the purpose of agriculture, before granting development consent to subdivide the land for that purpose the consent authority:

(a) shall consult with the Director-General of the Department of Agriculture, and

(b) shall be satisfied that the land, when subdivided, will be capable of supporting, and will be used to support, a viable crop or pasture farming enterprise.

(2) For the purposes of subclause (1), intensive undercover livestock rearing, mushroom growing, hydroponic crop raising and similar enterprises not dependent upon the productive capacity of the soil are not crop or pasture farming enterprises.

(3) This clause does not apply to the land shown edged heavy black (other than the land bounded by a black line edged by a broken line) on Sheet 1 of the map marked “Illawarra Regional Environmental Plan No 2-Jamberoo Valley”, the original of which is deposited in the office of the Department, copies of which are deposited in the offices of the Councils of the Municipalities of Kiama and Shellharbour

Comment

The provisions of this clause are not relevant to this proposal as the application does not

seek to subdivide prime crop and pasture land.

Land of Environmental Attributes

The “Illawarra Region Landscape and Environment Study” supports the Region Plan and

provides recommendations in terms of these attributes. The site is located within Unit 6

– Shoalhaven Delta as identified by this study. The factory site is affected by the

Ve policy recommendation while the Environmental Farm is affected by the IIIf policy

recommendation of the “Illawarra Region Landscape and Environment Study”. These

policy recommendations stipulate:




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Ve - Built up corridor comprising existing village, non-urban 1(a) and Non-urban 1(b) zones. No recommendations for change.

IIIf - Prime crop and pasture land. Zoning should ensure agronomic and pastoral based enterprises only.

The proposal is consistent with these recommendations.

Industry

Part VI of the IREP is concerned with industry. Industrial objectives relevant to this

proposal are:

48. The objective relating to industry are:

(a) To ensure that there is sufficient industrially zoned land to meet industrial needs.

(b) To encourage industries and other enterprises to locate within the region to diversify the economic base or act as stimuli to the local economy or both and so provide new employment opportunities; and

(c) To locate industrial land where it will meet the particular requirements of industry while having a minimal adverse impact on the natural environment and the amenity of living areas.

The IREP also states that adequate services must be available to meet the demands of

any industrial development, which may be permissible under the provisions of the

Council’s Local Environmental Plan

High Rise Buildings

Under clause 139 of the IREP, provisions relating to high rise buildings are addressed:

139(2) The consent authority shall not consent to a development application to erect a building or to alter an existing building by increasing its height, where the building after erection or alteration will have a height:

(a) in the case of land shown on the map as regional commercial centre and land zoned 2(c) Residential “C” under Wollongong Local Environmental Plan No. 38 (other than that north of Bourke Street or Corrimal Street) of more than 20 metres; or

(b) in the case of other land in the Wollongong sub region and the Shoalhaven sub region of more than 11 metres,

without the concurrence of the Director.

The IREP makes provision for the control of building heights. Specifically clause

139(2)(b) requires the concurrence of the Director-General of Planning for consent to




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erect a building where the building will have a height of more than 11 metres. The

proposal includes components, which are over 20 metres in height, and the Director-

General of Planning’s concurrence is therefore required prior to the issuing of any

consent for these aspects of this project.

Clause 139(3) sets out the matters for consideration that the Director-General must take

into consideration in granting concurrence under this clause, including:

a) the height, scale, bulk and density of the proposed building;

b) the external appearance and materials used on the exterior of the proposed building;

c) the relationship of the proposed building to the streetscape or landscape;

d) the effect of the proposed building on public amenity, including pedestrian amenity;

e) the effect of the proposed development on wind patterns and wind velocity in public places;

f) the effect of the proposed building on overshadowing of public places;

g) the effect of the proposed building on views from public places;

h) the effect of the proposed building on any items of the environmental heritage in the vicinity; and

i) the effect of reflections from the exterior of the proposed building on roads, public places and buildings in the vicinity.

The scenic qualities of the site and visual impact of the proposed development are dealt

with in Section 7.12 of the EA.

The construction and operation of the proposed development would not conflict with the

relevant stated aims and provisions contained in the IREP and similarly, there are no

further provisions of the IREP that affect the application.

6.4.2 South Coast Regional Strategy

The primary purpose of the South Coast Regional Strategy is to ensure that adequate

land is available and appropriately located to sustainably accommodate projected

housing and employment needs for the South Coast Region for the next 25 years.

In summary the aims of the strategy include:

• Protect high value environments including pristine coastal lakes, estuaries, aquifers, threatened species, vegetation communities and




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habitat corridors by ensuring that no new urban development occurs in these important areas and their catchments.

• Cater for a housing demand of up to 45,600 new dwellings by 2031 to accommodate the additional 60,000 people expected in the Region over the next 25 years.

• Increase the amount of housing in existing centres to ensure the needs of future households are better met, in particular the needs of smaller households and an ageing population.

• Prioritise and manage the release of future urban lands to ensure that new development occurs in and around existing well serviced centres and towns.

• Use the recommendations of the Sensitive Urban Lands Panel to guide the finalisation of the development form and environmental management of the 17 ‘sensitive urban lands’.

• Manage the environmental impact of settlement by focusing new urban development in existing identified growth areas such as Nowra-Bomaderry, Milton-Ulladulla, Batemans Bay and Bega.

• Only consider additional development sites if it can be demonstrated that they satisfy the Sustainability Criteria (Appendix 1).

• No new towns or villages will be supported unless compelling reasons are presented and they can satisfy the Sustainability Criteria.

• No new rural residential zones will be supported unless as part of an agreed structure plan or settlement strategy.

• Ensure an adequate supply of land to support economic growth and provide capacity to accommodate a projected 25,800 new jobs, particularly in the areas of finance, administration, business services, health, aged care and tourism.

• Limit development in places constrained by coastal processes, flooding, wetlands, important primary industry resources and significant scenic and cultural landscapes.

• Protect the cultural and Aboriginal heritage values and visual character of rural and coastal towns and villages and surrounding landscapes.

Where development or rezoning increases the need for State infrastructure, the Minister for Planning may require a contribution to the provision of such infrastructure, having regard to the State Infrastructure Strategy and equity considerations.

Section 7 of the Strategy relates to “Economic development and employment growth”.

This section of the strategy concerns in part the need to identify sufficient employment

and land capacity to provide for a projected 25,800 new jobs in the region and

specifically 14,400 within the Shoalhaven.




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The identified “Actions” under the strategy deal essentially with the preparation of local

environmental plans and the need for monitoring the supply of employment lands in the

region. The Strategy does not make any specific recommendations in terms of the

development of industrial sites – such as that proposed by this application.

6.5 SHOALHAVEN LOCAL ENVIRONMENTAL PLAN 1985

The Main Factory Site

The majority of the existing Shoalhaven Starches Factory Site within which the ethanol,

glucose, starch and grain plants are sited is zoned 4(e) Industrial (Restricted

Development) under the provisions of Shoalhaven Local Environmental Plan 1985. The

objective of this zone is:

“...identify locations in existing industrial areas with development problems where special consideration will be required before development can be approved.”

Industrial development is permissible under the provisions of this zoning.

The Proposed Packing Plant and Container Storage

The proposed Packing Plant and container storage are proposed to be sited upon Lot 2

DP 538289 and Lot 5 DP 825808 Bolong Road, Bomaderry. This land is located along

the northern side of Bolong Road directly opposite the existing factory and the

Company’s administration offices.

These parcels of land are zoned Rural 1(g) and Industrial 4(e) (Restricted Development)

pursuant to the provisions of SLEP 1985.

The proposed Packing Plant and container storage area is proposed to be sited entirely

on Lot 5. This component is to be sited entirely within that part of the site zoned 4(e).

As outlined above, industrial development is permissible under this zoning.

The only works proposed within the Rural 1(g) zone are an access road and railway spur

line. Roads are a permissible use within the 1(g) zone subject to consent.

The proposed railway spur line is plant associated with the overall Shoalhaven Starches’

factory complex.

The Environmental Planning and Assessment Model Provisions 1980 (“the Model

Provisions”) are adopted by Shoalhaven Local Environmental Plan 1985 (subject to a

few exemptions). Clause 35 and Schedule 1 of the Model Provisions outline those

activities that may be carried out without development approval, and includes:




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1. The carrying out by persons carrying on railway undertakings on land comprised in their undertakings of:

(a) any development required in connection with the movement of traffic by rail, including the construction, reconstruction, alteration, maintenance and repair of ways, works and plant, and

(b) the erection within the limits of a railway station for any purpose,

but excluding:

(c) the construction of new railways, railway stations and bridges over roads,

(d) the erection, reconstruction and alteration of buildings for purposes other than railway undertaking purposes outside the limits of a railway station and the reconstruction or alteration so as materially to affect the design thereof of railway stations or bridges,

(e) the formation or alteration of any means of access to a road, and

(f) the erection, reconstruction and alteration of buildings for purposes other than railway purposes where such buildings have direct access to a public place.

As the rail spur line concerns development in connection with the movement of traffic by

rail; and is not one of the listed exclusions as the proposal does not comprise:

− a new railway, railway station or bridge;

− a new building;

− an access to a road.

Under these circumstances this component of the proposal is subject to the provisions of

Clause 35 of the Model Provisions.

The Eastern Portion of the Site (Amendment No. 59)

The eastern portion of the factory site, ie. that portion of the site to the east of the

Ethanol Distillery, is zoned Rural 1(g) under the provisions of SLEP 1985. This area is

however affected by the provisions of an amendment to the SLEP 1985 (Amendment

No. 59). The aim of this amending LEP is:

“To protect the environment of the City of Shoalhaven by permitting development on the land to which this plan applies, for the purposes of facilities associated with the starch mill located on land adjoining the land to which the plan applies that will improve the quality of processed water waste water leaving the mill site.”




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The amending LEP enables:

“the erection of facilities associated with a starch mill situated on the adjoining land, including a fire service tank and pumphouse, ethanol storage and recovery tanks and associated loading facilities and an employee car park, provided that the Council is satisfied that:

a) the capacity of the floodway to accommodate flood flows is maintained; and

b) all structures are designed to withstand at least a 1 in 100 year flood; and

c) all footings and foundations are protected against scouring erosion and undermining; and

d) there will be adequate safeguards to contain and collect leaks and spillages.”

The Far Eastern Portion of the Site

The PRP No. 7 project (approved by the Minister for Planning in 2003) included a

proposal to relocate an employee car park to an area to the east of what was then the

existing car park. This adjoining land is zoned Rural 1(g) Flood Liable under the

provisions of the Shoalhaven Local Environmental Plan 1985.

The present ethanol upgrade proposal seeks to erect three fermentation tanks that will

be sited either wholly or partly within this area of the site.

It is noted that “rural industry” is a permissible use within the Rural 1(g) zone. The

Shoalhaven Local Environmental Plan 1985 adopts (with certain exceptions) the

Environmental Planning & Assessment Model Provisions. Under the Model Provisions a

rural industry means the:

“handling, treating, processing or packing of primary products and includes the servicing in a workshop of plant or equipment used for rural purposes in the locality.

The proposed fermenters are plant associated with the overall Shoalhaven Starches

factory complex. As outlined this factory complex processes wheat, other grains and

flour to produce a range of products. Under these circumstances, such an activity would

sit within the above definition and therefore the proposed fermenters, forming part of the

Shoalhaven Starches complex would be a permissible use within the Rural 1(g) zone as

a “rural industry”.




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Area to West of Abernethy’s Creek (Amendment No. 171)

That portion of the site which is situated to the west of Abernethy’s Creek is also zoned

Rural 1(g) Flood liable zone, as well as partly Environmental Protection 7(f3) Foreshores

Protection zone and partly 4(e) Industrial (Restricted Development) zone.

The land is however affected by Amendment No 171 to SLEP 1985. The aims of this

amending LEP are to:

“a) Provide for the expansion of an existing industrial operation which is located on land adjoining the land to which this land applies, provided the Shoalhaven City Council is satisfied that issues related to flooding, traffic impact, risk, noise, visual impact, the management of the riparian buffer zone and the potential existence of acid sulphate soils have been addressed; and

b) Acknowledge the importance of establishing an adequate riparian buffer zone adjoining Bomaderry Creek and the Shoalhaven River by zoning an appropriate area Environmental Protection (F3) (Foreshores Protection) zone under the City of Shoalhaven Local Environmental Plan 1985.”

This Amendment to SLEP permits the erection of facilities ancillary to the starch mill

situated on adjoining land provided the consent authority is satisfied that issues relating

to flooding, traffic impact, risk, noise, visual impact, management of riparian buffer zone

and potential existence of acid sulphate soils have been addressed. This proposal

seeks to locate additional evaporators and 6 additional DDGS Dryers (and associated

plant), extension to the approved DDG Loadout (PRP No. 7), additional evaporators,

chemical storage, condensate defatting plant, DDGS Pellet Plant, and associated

bioscrubbers and gas fired co-generation plant in this part of the site. Given these uses

are ancillary to the existing DDGS Plant located on this site, and forms part of the overall

Starch Plant operations, such uses are permissible subject to development consent. In

this regard the proposed gas-fired co-generation plant does not encroach into the 7(f3)

zone that is situated along the foreshores of Bomaderry Creek and the Shoalhaven

River under this plan amendment.

Area North of Bolong Road - Proposed Fire System (Amendment No. 173)

The proposal includes the siting of a fire system on Lot 142 DP 1069758, located on the

north side of Bolong Road immediately opposite the factory site.

This land is zoned Rural 1(g) flood liable and is also affected by Amendment No. 173.

The aim of this amendment is:

“To provide for the establishment of a carbon dioxide processing and storage plant on the subject land, provided the Shoalhaven City Council is satisfied




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that issues related to flooding, traffic impact, risk, noise visual impact, management of riparian buffer zone along Abernethy’s Creek and the potential existence of acid sulphate soils have been addressed.”.

The proposed fire system comprises an integral component of the overall development’s

fire safety system associated with the overall Shoalhaven Starches’ factory complex

(and including the adjoining carbon dioxide plant).

It is noted that “rural industry” is a permissible use within the Rural 1(g) zone. The

Shoalhaven Local Environmental Plan 1985 adopts (with certain exceptions) the

Environmental Planning & Assessment Model Provisions. Under the Model Provisions a

rural industry means the:

“handling, treating, processing or packing of primary products and includes the servicing in a workshop of plant or equipment used for rural purposes in the locality.”

The proposed fire system is associated with the overall Shoalhaven Starches’ factory

complex. As outlined the factory complex processes wheat, other grains and flour to

produce a range of products. Under these circumstances, such an activity would sit

within the above definition and therefore the proposed fire system, forming part of the

Shoalhaven Starches’ complex would be a permissible use within the Rural 1(g) zone as

a “rural industry”.

The Environmental Farm

The land associated with the Environmental Farm is zoned Rural 1(g) Flood Liable under

SLEP 1985. The objectives of the Rural 1(g) zone are:

(a) to limit the erection of structures on land subject to periodic inundation,

(b) to ensure that dwelling-houses are erected on land subject to periodic inundation only in conjunction with agricultural use,

(c) to ensure that the effect of inundation is not increased through development,

(d) to restrict development and how it is carried out so that its potential to have an adverse impact on site and off site on acid sulfate soils is reduced or eliminated, and

(e) to conserve and maintain the productive potential of prime crop and pasture land.

Activities involving waste treatment and disposal, in each case involving the use of water

are permissible subject to development consent. This proposal includes the adaptive

re-use of part of the existing Pond No. 7 as an anaerobic and aerobic waste water

treatment plant. Such a use is therefore permissible within the 1(g) zone.




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Environmental Management Provisions

The following environmental management provisions of SLEP 1985 have relevance to

the proposal.

Clause 26 (2) & (3) Soil, water and effluent management

26 (2) In deciding whether arrangements for drainage of stormwater and other surface water and the treatment and disposal of effluent are satisfactory, the Council must take into account whether the proposed systems can be accomplished in a manner which meets the following objectives:

(a) economical feasibility and practicality in terms of design, installation and maintenance,

(b) protection of public health,

(c) protection of surface water,

(d) protection of ground water,

(e) encouragement of the utilisation of wastewaters as a resource rather than a waste for disposal, and

(f) protection of community amenity.

(3) Despite any other provision of this plan, except clauses 2, 9 (3) and 21 and the objectives of the zone in which development the subject of this clause is proposed, the Council may consent to the construction of devices which, in the opinion of the Council, are to be used principally for the purpose of soil and water management or water pollution control.

Comment

Stormwater management issues are discussed further in Section 7.5.2 of this EA.

Clause 27 Development on acid sulfate soils

26(1) This clause applies to land identified as having high probability to be affected by acid sulfate soils on the map prepared by the Department of Land and Water Conservation entitled “ Acid Sulfate Soil Risk Map ” dated December 1997 and available for public inspection at the office of the Council.

(2) Despite any other provision of this plan, the consent of the Council is required for any development which involves or is likely to involve, through drainage, earthworks, or any other means, the exposure to the atmosphere of any part of soil which contains iron pyrites within land to which this clause applies.

(3) The Council must not consent to development described in subclause (2) unless it is satisfied that measures can and will be taken to avoid or mitigate the actual or potential contamination of




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waterways in the vicinity of the land concerned by acid from acid sulfate soils.

Comment

Acid Sulphate Soil mapping indicates the subject site is subject to a low probability for

the presence of acid sulphate soils. The provisions of this clause therefore do not apply

to this proposal.

The EA is supported by an Acid Sulphate Soil Assessment carried out by Coffey

Environments Pty Ltd and which forms Annexure J to this EA. This matter is further

discussed in Section 7.5.3 of this EA.

Clause 28 Danger of bush fire

(1) The Council must not grant consent to the carrying out of development on bush fire prone land if it is of the opinion that:

(a) the development may have a significant adverse effect on the implementation of:

(i) any strategies for bush fire hazard reduction or risk management adopted by the Council, or

(ii) any relevant provisions of the Act or the Rural Fires Act 1997 , and

(b) the development, including the arrangements for access to and from the development, may constitute a significant threat to the lives of residents, visitors or emergency services personnel, and

(c) the development may give rise to an increased demand for emergency services during bush fire events that will result in a significant decrease in the ability of the emergency services to effectively control major bush fires.

Note: Section 146 of the Act provides that bush fire prone land is land recorded by the Council as such on a map certified by the Commissioner of the NSW Rural Fire Service as a bush fire prone land map for the area of the Council.

(2) The Council must not grant consent to the carrying out of development on bush fire prone land unless it is satisfied that adequate measures are proposed to avoid or mitigate the threat from bush fire, having regard to:

(a) the siting of the development, and

(b) the design of, and the materials used in, any structures involved in the development, and

(c) the clearing of vegetation, and




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(d) the provision of asset protection zones, landscaping and fire control aids (such as roads and water supplies).

(3) Before deciding to grant consent to any development on bush fire prone land, the Council:

(a) must have regard to the requirements set out in Planning for Bushfire Protection (ISBN 0 9585987 8 9) , prepared by Planning & Environment Services, NSW Rural Fire Service in co-operation with the Department of Planning (as it then was), and published in December 2001, and

(b) must be satisfied that those requirements will be met as far as is practicable in the circumstances.

Comment

The subject site is not mapped as being bushfire prone by mapping prepared by

Shoalhaven City Council. Given; the site is not mapped as being bushfire prone; and is

a developed industrial site that adjoins the Shoalhaven River; this clause would not

apply to this proposal.

29 Development of flood liable land

(1) Subject to subclause (2), the Council must not consent to the carrying out of development on land which, in its opinion, is flood liable.

(2) The Council may consent to the carrying out of development on flood liable land if:

(a) the development is for a purpose ancillary or incidental to the use of land for the purpose of agriculture, or

(b) the development comprises the extension or alteration of an existing dwelling-house, or

(c) the land is in any urban zone under this plan, or

(d) the Council has received a flood assessment report, in relation to the land, that addresses each of the matters referred to in subclause (3), and the Council is of the opinion that the development is feasible despite the land being flood liable.

(3) In considering an application to which subclause (2) applies, the Council must make an assessment of:

(a) the likely levels, velocity, sedimentation and debris carrying effects of flooding,

(b) the structural sufficiency of any building the subject of the application and its ability to withstand flooding,

(c) the effect which the development, if carried out, will or is likely to have on the flow characteristics of floodwaters,




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(d) whether or not access to the site will be possible during a flood, and

(e) the likely increased demand for assistance from emergency services during a flood.

(4) In granting consent to a development application made pursuant to subclause (2), the Council may impose conditions that set floor levels, require filling, structural changes or additions or require other measures to mitigate the effects of flooding or assist in emergency situations.

Comment

The EA is supported by a flood assessment report prepared by Webb McKeown Pty Ltd

which forms Annexure K to this EA. Flooding issues are further discussed in Section

7.10 of this EA.

Figure 9 details the zoning provisions applying to the site.

6.6 DEVELOPMENT CONTROL PLANS (DCPs)

DCP No. 18 – Car Parking Guidelines

Council’s Car Parking Guidelines, DCP 18, provides the requirements for on-site car

parking for developments. In relation to this proposal, the Guidelines require parking at

the following rates outlined in Table 5.

Table 5

Car Parking Requirements under DCP 18

Land Use Council Requirement

General Industry - Factories 1 space per 100 m2 gross floor area.

Given the nature of this project, which involves the placement of large pieces of plant

within buildings and therefore the size of buildings does not necessary correlate with

employee numbers and parking demand, the above parking rate is not really relevant to

this proposal. In this regard the works associated with this proposal will involve the

following approximate areas:

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Table 6

Ethanol Upgrade Parking Assessment – DCP No.18

Plant Approximate Area (m2)

Starch Dryer 700 m2

Gas-fired Boiler 150 m2

Extension to DDG

Loadout

Evaporator

Bioscrubbers

Pellet Plant

DDGS Dryers

MCC Room

500 m2

50 m2

200 m2

200 m2

2400 m2

375 m2

Gas-fired Co-generator Plant 1000 m2

Chemical Storage 150 m2

Packing Plant 3000 m2

Fire Services 200 m2

Total Area 8925 m2

Based upon Council’s DCP requirements the development would require to provide

about 89 car parking spaces in addition to the existing situation.

DCP No. 18 parking requirements however have little relevance to the specific

requirements of this project. The areas associated with this project relate mainly to the

housing of specific plant, which in most cases are of a significant size, and require

housing for noise attenuation purposes. There is therefore no correlation between the

scale of the works proposed and the likely number of employees that will be generated

by these works.

Under these circumstances a site specific car parking assessment supports this proposal

and is included in the Traffic Impact Assessment. This assessment addresses the

parking requirements for the proposal in light of the likely additional employment

generated by the proposal.

The EA is supported by a Traffic Impact Assessment prepared by Christopher Stapleton

Consulting (Annexure G). Parking requirements for the project are further addressed in

Section 7.7 of this EA.




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DCP No. 93 −−−− Controls Waste Minimisation and Management

This DCP requires that development applications consider the management and

reduction of waste. A separate Waste Management Report accompanies the EA

(Annexure L) prepared by Stephenson Environmental Management Australia. This

matter is further addressed in Section 7.11 of this EA.

DCP 106 – Floodplain Management

This DCP provides guidelines for development on flood prone land. The objectives of

the DCP are as follows:

“a) To minimise risk to human life and damage to property by controlling development on flood prone land;

b) To ensure that developers and the community are conscious of the potential flood hazard and consequent risk associated with the use and development of land within the floodplain;

c) To establish guidelines for development on flood prone land having regard to the NSW Flood Policy and NSW Floodplain Development Manual (2005);

d) To protect the integrity of floodplains and floodways;

e) To ensure that all land uses and essential services are appropriately sited and designed in recognition of all potential floods;

f) To ensure that development on the floodplain does not adversely affect the amenity or ecology of an area;

g) To ensure that development on the floodplain complies with Ecological Sustainable Development principals and guidelines;

h) To ensure that development on flood prone land does not place an unacceptable financial burden on landowners or the community; and,

i) To control development and works within each floodplain having regard to the characteristics of each floodplain and the level of information that is available for each floodplain, in particular the availability of Floodplain Risk Management Studies and Plans prepared in accordance with the NSW Floodplain Management Manual (2005).”

Flooding impacts of the proposal are addressed in Section 7.10 of the EA. Webb

McKeown & Associates were engaged by Shoalhaven Starches to address the

hydraulic, economic, social and environmental impacts of flooding associated with this

proposal. The report forms Annexure L to this EA.

In terms of the provisions of DCP No. 106, Webb McKeown’s report makes the following

comments:




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“It is noted that a Final Shoalhaven River Floodplain Risk Management Plan has not been issued but a Draft has been with Council for over 12 months and is in the last stages of being finalised. In light of this Webb McKeown have assessed the flooding impacts associated with the proposed works assuming that there is a current Floodplain Risk Management Plan for the study area.

Determination of Relevant Controls

Land Use Category: Industrial + Earthworks + Non-Urban Open Space

Flood Planning Area: (Taken from Draft Shoalhaven River Floodplain Risk Management Study.) High Hazard Floodway adjacent to the bank of the Shoalhaven River and High Hazard Flood Storage away from the bank.

Compliance Requirements

The following requirements need to be satisfied in order to comply with DCP 106 – Floodplain Management. The responses are provided in Capitals and in Bold beneath.

Floor Level of Buildings

1% AEP + 0.5 m (Flood Planning Level)

Shoalhaven Starches will undertake their own flood damage risk assessment for each building, taking into account the use of the building, damage potential, access requirements and other such information. These details will be addressed at the detail design stage and submitted with the construction certificate.

Building Components

Any part of the building below the Flood Planning Level must be built of flood compatible materials.

These details will be addressed at the detail design stage and submitted with the construction certificate.

Structural Soundness

An appropriate Consulting Engineer’s Report must be provided stating that the building/structure can withstand floodwaters including debris and buoyancy forces up to a 0.2% AEP event (or 1% AEP + 0.5 m whichever is the higher).

These details will be addressed at the detail design stage and submitted with the construction certificate.

Flood Affectation

An appropriate Consulting Engineer’s Report is provided stating that the development will not increase flood hazard or flood damage to other




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properties or adversely affect flood behaviour for a 5% AEP up to the PMP scenario.

Documented as part of this present report

Access

Reliable emergency vehicle and pedestrian access is required during a 1% AEP event.

It is not possible to provide emergency access due to the low lying nature of Bolong Road. Shoalhaven Starches has a flood evacuation plan (Appendix C) and this will ensure all staff are safely removed from the site prior to inundation.

Flood Evacuation Plan

An Engineer’s Report must be provided demonstrating that permanent, fail safe, maintenance free measures are incorporated in the development to ensure the timely, orderly and safe evacuation of people is possible from the area and that it will not add significant cost and disruption to the community or SES.

Refer Shoalhaven Starches ‘Flood Evacuation Plan in Appendix C.

Management and Design

The applicant is to demonstrate that there is an area where hazardous and valuable goods can be stored above the flood planning level.

These details will be addressed at the detail design stage and submitted with the construction certificate.”

6.7 APPROVAL REGIME FOR PROJECT

As outlined above in Section 6.2.1, the proposed development meets the criteria for a

Major Project under Part 3A of the EP&A Act and SEPP (Major Project) 2005. The

consent authority for the project will be the Minister for Planning.

In accordance with Part 3A of the EP&A Act, approvals listed under eight Acts listed

under Section 75U Clause 1 of the EP&A Act are not required.

The existing development has an Environmental Protection Licence (EPL) under the

Protection of the Environment Operations Act 1997 (POEO Act) (EPL No. 883). The

proposal is required to demonstrate that the proposal will be able to satisfy the existing

requirements of this licence.




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7.0 KEY ISSUES

The Director-General of Planning has issued requirements for the preparation of this EA,

dated 2nd May2008. These requirements were revised from those originally proposed on the

17th January 2008. The following section of the EA addresses those key issues as outlined in

the requirements of the Director-General of the Department of Planning for the Environmental

Assessment for this proposal. Annexure A to this EA provides a summary of the

requirements and stipulates where within the EA the requirements are addressed.

Annexure B provides a summary of the requirements of the relevant government agencies

and stipulates where within the EA these issues are addressed.

7.1 AIR QUALITY (INCLUDING ODOUR) ASSESSMENT

GHD Pty Ltd (GHD) was engaged by Shoalhaven Starches to conduct an air quality

impact assessment. A copy of this assessment forms Annexure M to this EA. This

section of the EA is based upon the findings of this assessment.

The air quality assessment carried out by GHD demonstrates that:

• adequate action will be taken to mitigate odour impact at the existing level of

production to achieve compliance with Section 129 of the Protection of the

Environment Operations Act 1997 (POEO Act); and

• the proposed upgrade to the facility will satisfy the requirements for potential air

quality impacts, in particular offensive odour impact, on public health, amenity and

the environment.

Air quality, and in particular odours, have long been an issue of contention with respect

to the Shoalhaven Starches operation.

Members of the community have made a number of complaints to Shoalhaven Starches

and the NSW Department of Environment and Climate Change (DECC; formerly known

as the Department of Environment and Conservation (DEC) and Environment Protection

Agency (EPA)) regarding odours reported to have emanated from Shoalhaven Starches

operations. Following investigation of odour complaints, DECC successfully prosecuted

Shoalhaven Starches in the Land and Environment Court for the emission of offensive

odours.

The Land and Environment Court judgement of 2 November 2006 required Shoalhaven

Starches to engage a suitably qualified person to conduct a comprehensive

environmental audit of the factory and environmental farm in order to identify and





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improved management of odours. Shoalhaven Starches engaged GHD to conduct the

environmental audit.

The environmental audit of odour sources at Shoalhaven Starches was conducted

between December 2006 and June 2007. The audit considered the management of

processes, activities and substances stored or used at the premises that generate or

have the potential to generate odours.

The findings of the “Shoalhaven Starches Environmental Audit – Odour Sources” (GHD,

2007), hereinafter referred to as the ‘Audit Report’, form the basis of the data for the

assessment prepared by GHD and which supports this EA, with additional information

collected in the time since the Audit Report supplied by Shoalhaven Starches.

Therefore, as an integral part of the proposed upgrade to the company’s Ethanol Plant,

Shoalhaven Starches also propose to implement odour mitigation measures, identified in

the Audit Report, at the Environmental Farm and for both the existing factory site and the

odour sources associated with the proposed ethanol upgrade operations.

7.1.1 Environmental Audit

Overview of the Audit Report

The main processing and materials treatment areas at Shoalhaven Starches comprise

the starch plant, glucose plant, ethanol and distillation plant, DDG plant and

environmental farm. Each of these plants was examined by GHD to identify processes,

activities and substances stored that were potential sources of odour. The audit

identified 20 potential sources in the starch plant, 27 in the glucose plant, 36 in the

ethanol and distillation plants, 48 in the DDG plant and 18 at the environmental farm.

Subsequent to the odour emission inventory and atmospheric dispersion model analysis,

a list of principal sources was identified for further assessment within the audit. These

were distinguished by being the highest mass emission rate odour sources, sources with

a very unpleasant hedonic tone and sources with the high potential to contribute to

ground level impact at sensitive receptors. This list of principal odour sources included

the Environmental Farm (all odour sources) and 52 individual odour sources at the

factory.

Odour Management Plan

Potential odour control measures (prevention and minimisation) were identified for the

principal sources of potentially offensive odour from the factory and the Environmental

Farm.




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Odour controls at the factory primarily involved improved housekeeping, collection and

treatment of emissions using biological treatment, and containment of fugitive emissions

from buildings by more complete enclosure of the buildings and application of a negative

air pressure.

Long-term odour management strategies were identified for the Environmental Farm as

a whole, which primarily involves installation of a biological (anaerobic and aerobic)

wastewater treatment plant.

The Air Quality Assessment Report prepared by GHD (Annexure M) prioritises odour

management target areas stemming from the Audit Report and the rationale behind

each ranking. The ranking forms the basis of the staged implementation of odour

mitigation actions. Management of lower ranked sources (e.g. examples from the

glucose and distillation plants) would yield such diminished returns on equipment or

process modification, given the low relative contribution of each individual source, that

that such modifications could not be reasonably justified.

Odour Management for Principal Factory Sources

The odour minimisation and control measures identified for implementation at the

Shoalhaven Starches factory include:

• Improvements to atmospheric dispersion;

• Improvements to industrial ventilation and housekeeping; and

• Installation of a biological treatment system to treat significant odour sources.

Atmospheric Dispersion

The use of elevated emission points (stacks) can reduce odour concentration at

downwind ground level receptors because of atmospheric dispersion (ie. dilution with

ambient air).

The technical framework document for the assessment and management of odour from

stationary sources in NSW (DEC, 2006) states that good control practice for any stack

should:

• be high enough to minimise building downwash;

• have a minimum exhaust velocity of 15 m/s to avoid stack-tip downwash;

• have a final vertical discharge directed vertically upwards; and

• have a free vertical discharge (ie. not have rain caps, which would restrict the

upward flow).




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This form of odour control has been selected for principal odour sources that have a high

volume of exhaust emissions, which cannot be prevented or practically treated to reduce

odour concentration, such as the gluten and starch dryer exhausts.

Industrial Ventilation

Ductwork

The design and maintenance of the industrial ventilation system used to capture and

transport foul plant air to a downstream control system or discharge point is critical in the

food industry where putrescent contamination in the ductwork can lead to malodorous

emissions. If these are exhausted untreated they add to the odour load on downstream

odour control systems.

Cooling Towers

In response to the recommendations of the Audit Report, Shoalhaven Starches has put

into practice the following actions:

• protection from potentially contaminating materials;

• regular monitoring of cooling water and replacement of contaminated cooling water;

• potable water or water from the new WWTP will be used in the cooling towers.

Condensate will not be used.

Fugitive Emissions from Buildings

Significant fugitive odour emissions have been identified from the DDG Dryer building

that houses the existing DDG dryers and associated equipment.

Shoalhaven Starches has taken steps to resize the DDG dryer fans to improve the fume

collection system that feeds foul air stream to boilers. Shoalhaven Starches anticipates

that fugitive emissions from the DDG dryer building can be reduced by up to 90%.

Biological Treatment System

The use of biological oxidation for odour control is well accepted in the food

manufacturing industry. BioTrickling Filters (BTF) or BioScrubbers and BioFilters (BF)

are types of biological systems.

Odorous air streams will be collected in a stainless steel ducting system, which would

use a combination of close hooding and hard piped connections to collect all selected

DDG odour source emissions and some additional dilution air. The air stream would be

fed via a venturi wet scrubbing system, which would fulfil two roles. Firstly, it would

remove readily water-soluble compounds such as methanol, ethanol, propanol and




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particulate matter and be discharged to the proposed wastewater treatment plan via a

timed blowdown system. Secondly, it would cool and humidify the air stream

conditioning it for the biological treatment system. The inlet air stream to the biological

treatment system would be controlled at a temperature of less than 40oC by the

humidification of the air stream.

The inlet conditions for the biological system are strict in terms of temperature, water

content and particulate matter load.

The cooling of the air stream would be achieved using a venturi scrubber.

After conditioning, the foul air would be then treated using a BioTrickling Filter (BTF).

The BTF uses immobilised bacteria in a scrubbing tower to oxidise the components of

the air stream. The BTF uses an inorganic packing matrix and is able to purge the

by-products of oxidation. Additional nutrients are added to the biological system as

required.

DDG Pelletiser Plant

Shoalhaven Starches proposes to install a pelletiser plant to pelletise existing granular

DDG produced at the site as part of the ethanol plant upgrade works. The installation of

a pelletiser plant was one of the recommendations of the Audit Report on the basis that

it reduced fugitive odour and dust emissions currently associated with the handling and

storage of the granular DDG product.

The Pellet Plant will be used to pelletise up to 100% of the existing DDG production,

depending on market demand, and should better enable Shoalhaven Starches to target

export opportunities.

Air emissions from discharge points associated with the Pellet Plant will be ducted to the

bioscrubber via a fabric filter before being discharged to air.

An additional measure to reduce fugitive emissions from this plant area is the installation

of plastic curtains on the doors to reduce the flow of air through the building.

Shoalhaven Starches anticipates that fugitive emissions from the DDG storage areas

can be reduced by up to 85%.

Odour Management Plan for the Environmental Farm

Odour management strategies were identified in the Audit Report for the Environmental

Farm as a whole. These primarily involved the installation of a biological (anaerobic and

aerobic) wastewater treatment plant, re-use of treated wastewater within the factory; and

irrigation of treated wastewater using low mist sprays.




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The proposal includes biological treatment of wastewater from the factory site. A portion

of the treated wastewater will be re-used within the factory and the surplus irrigated onto

the Environmental Farm.

A Wastewater Treatment Plant (WWTP) will be constructed in stages at the

Environmental Farm and will be associated with the storage ponds. The WWTP will

have sufficient volumetric and operational capability to treat the total flow and organic

load received from the Shoalhaven Starches factory site. The WWTP will be constituted

by sequential anaerobic digestion and aerobic digestion facilities.

Treated effluent from this system could be irrigated with low, if any, discernable odour

emissions. Any discernible odours released during irrigation are expected to have an

earthy or musty characteristic, which is likely to blend with the palette of odour typical of

the surrounding rural/agricultural environment.

7.1.2 Emissions Inventory

Air emissions associated with the operation of the Shoalhaven Starches facility and

proposed ethanol upgrade may include:

• odour;

• particulate matter; and

• products of combustion.

Odour

Odour emanating from Shoalhaven Starches is comprised of a complex mixture of

primarily odorous volatile organic compounds (VOC). VOC speciation data from a range

of principal odour sources indicates that the individual VOCs within the mixture tend to

be classified under odour-based air quality criteria rather than toxicity-based. Therefore,

for the purpose of the assessment carried out by GHD, VOC emissions from Shoalhaven

Starches, except VOC emission associated with coal combustion, will be dealt with

collectively as odour.

The objective of the odour emission rate (OER) inventory was to derive a worst-case

snapshot of odour emissions based on the available odour emission data. The primary

sources of OER data include the OER dataset presented in the Audit Report and the

results of subsequent odour testing commission by Shoalhaven Starches in the period of

time between the completion of the Audit Report and the preparation of this report.

In accordance with the Approved Methods for the Sampling and Analysis of Air

Pollutants in NSW, all OER data used in the assessment carried out by GHD were




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collected with consideration to the DECC OM-7, with all odour samples being analysed

by an olfactometry laboratory that was NATA accredited for olfactometry to the

Australian Standard 4323.3 2001: Determination of odour concentration by dynamic

olfactometry.

Factory

A breakdown of the principal odour sources from the existing factory OER and proposed

ethanol upgrade at the different stages of odour control implementation is given in

Table 5-1 of Annexure M to this EA.

Table 7 below provides a summarised version of Table 5-1 of the Air Quality

Assessment and outlines the overall proposed odour control measures and the relevant

staging of these measures.

Table 7

Summary – Odour Controls and Staging – Existing Factory and Proposed Ethanol Upgrade

Plant Odour Source Odour Control

STAGE 1

Existing Factory

DDG (liquids) Feed dump tank, condensate tank, vent condenser, finish feed tank, finisher, pump, dryer feed tank, feed holding tank, CIP tank.

BIO

DDG (Solids) • DDG product storage sheds.

• Grounds and cooling towers.

• DDG cooler and associated baghouses.

• Decanter heat exchanger.

• Decanter feed tanks

PP

HK

BIO

Repair

WL

DDG Building IV

Ethanol • Cooling towers.

• Grain Retention Tank 2 / Feed to Distillery / Farm Tank.

D

WL

Flour Cyclone and fabric filters. ID

Glucose Enzyme tanks. WL

Starch • No. 1 – 4 gluten dryers, No. 1, 3, 4, 5 starch dryers, spray dryer.

• Kestair dryer

HK

D




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Table 7 (continued)

Plant Odour Source Odour Control


DDG DDG tank vents/transfer cyclones (6 units) / DDG dryers/decanters (10 units) / Pelletiser Baghouse (2) / general ventilation.

BIO

Ethanol Fermenters. ID

Starch Gluten dryer / gluten grinder. HK

STAGE 2

Existing Factors

DDG Condensor drain decanter (1 – 4) BIO

Ethanol Propagation tanks (1 – 5)

Farm tanks.

BIO

Glucose Enzyme tank BIO


DDG DDG tank vents IV

STAGE 3

DDG Light Phase Tank BIO

Distillery Molecular sieve

Vacuum Drum

BIO

Ethanol Jet cooker 2 + 4 / Jet cooler 1 – retention tank. BIO

Glucose Drum vacuum receiver / ion exchange effluent tank / Cooker A + B Flash tanks

BIO

Starch Cooker A + B Flash tanks

Dry gluten bin

Gluten Dryers 1 – 4 Starch Dryers 1, 3, 4, 5

BIO

CTS

CTS

Note: Odour control abbreviations used are as follows: BIO – bioscrubber, WL – wet-leg installed on tanks to condense vapour emissions; D – decommissioned plant item; HK – housekeeping actions such as ductwork cleaning and maintenance; IV – industrial ventilation improvements; ID – improve dispersion from discharge points; PP – DDG pelletiser plant installation; CTS – common tall stack; Nil – no odour control at this stage.

Based upon the above it is evident that the majority of odour control measures will

involve Stage 1 control measures.

The staging of odour control implementation proposed by Shoalhaven Starches is based

on the prioritisation of the factory odour sources as presented in Table 3-1 of the Air

Quality Assessment prepared by GHD (Annexure M).

The timing for each odour control stage is as follows:

• Stage 1 – April 2009 (subject to date of approval) includes:




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− duct high priority DDG (liquid and solid lines) odour sources to the bioscrubber;

− install wet-legs on key odour sources that are not ducted to the bioscrubber at

this stage;

− clean starch and gluten dryer ductwork;

− improve factory housekeeping;

− pelletise DDG product; and

− decommission designated odour sources.

• Stage 2 – to reassess within 6 months of completion of Stage 1 and implementing

Stage 2 odour controls as required, includes:

− duct medium priority odour sources to the bioscrubber; and

− investigate feasibility of directing individual starch and gluten dryer discharge

points upwards and increasing stack heights;

• Stage 3 – if required, depending on outcomes at Stage 2, includes:

− duct individual starch and gluten dryer discharge points to a common tall stack

(CTS);

− duct low priority odour sources to the bioscrubber.

With the Stage 1 odour controls in place, treatment of potential sources of odour

associated with the proposed ethanol upgrade would be integrated with these odour

controls.

Shoalhaven Starches propose reassessment of the odour controls will involve the

following:

1. Following completion of odour control stage implementation a meeting will be held

with the community consultation group to ascertain whether members of the

community have experienced reduction in odours.

2. A review will be undertaken of the number and nature of complaints received by

the Company in connection with odours.

Depending upon the findings of the above measures, odour monitoring may be

necessary to evaluate odour control measures.

The OER data prepared by GHD show the following key features:




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• Odour emissions from the existing factory (468,105 OUm3/s) could be reduced up to

66% (158,296 OU m3/s) after implementation of Stage 1 odour controls and up to

75% (117,852 OU m3/s) after stage 2 odour controls. A significantly diminished

OER reduction is evident between Stage 2 and Stage 3, however, this does not

translate into a diminished reduction in the potential for off-site odour impact

because the primary action in Stage 3 is improved dispersion from the gluten and

starch dryers through the installation of a common tall stack or equivalent measure.

• The ethanol upgrade results in an incremental increase to the factory OER of

approximately 24% (or 49,583 OU m3/s) with Stage 1 odour controls. A similar

increment is evident for the other stages as a result of odour control for the ethanol

upgrade being applied at the outset.

• OERs for each existing factory source assigned to the bioscrubber total 79,594

OU m3/s, 137,021 OU m3/s and 145,721 at Stages 1, 2 and 3, respectively. It is

anticipated that the bioscrubber would achieve an odour removal efficiency of at

least 85%.

• After the ethanol upgrade, the incremental increase to the bioscrubber load at

Stages 1, 2 and 3 is 14,238 OU m3/s, 16,363 OU m3/s and 16,363 OU m3/s,

respectively; and

• OERs for each individual source assigned to the common stack at Stage 3 total

58,069 OU m3/s.

Odour emission testing has not been previously conducted on the coal-fired boiler

No. 5/6 exhaust stack (EPA DP 35). Recent odour testing conducted to determine the

odour destruction efficiency of the boiler, which is currently used to treat odorous

emissions from the DDG dryers and transfer cyclones, indicated that the OER input from

the DDG dryers and cyclones is less than the OER at the boiler exhaust. This result

suggests that the coal-fired boiler exhaust gases are a source of odour emissions.

Odour character tests suggest a combination of typical combustion type odours

characteristics and low level DDG type odours. The measured OER for the boiler No.

5/6 exhaust was 80,761 OU m3/s. Of this total, less than 10% can be attributed to the

DDG sources that are ducted to the boiler for treatment because the total OER for these

DDG sources was determined to be 8,321 OU m3/s at the inlet to the boiler. Further

tests are being conducted to ascertain the DDG odour destruction efficiency of the boiler.

As part of Stage 1 odour controls, Shoalhaven Starches has taken steps to resize DDG

dryer fans to improve fume collection system that feeds foul air stream to boilers.

Therefore, to account for this, reallocation of the odour emissions to a different release




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point, 90% of the measured fugitive emissions from the DDG dryer building have been

added to the odour emission load from the DDG dryer/cyclones of 8,321 OU m3/s to give

a total of 71,775 OU m3/s (DDG odours) emitted from the boiler 5/6 stack at Stage 1.

This is a conservative approach as it assumes an odour destruction efficiency of zero –

this approach will be used until further information becomes available on the actual

destruction efficiency.

Foul process air from the DDG dryers is not ducted to Boilers No. 2 or No. 4. These

boilers were found to have OERs of 13,104 OU m3/s and 22,889 OU m3/s, respectively.

Therefore, collectively, the three boiler exhaust stacks represent a significant proportion

of the total factory OER (13,104 + 22,889 + 72,440 OU m3/s). However, these odour

emissions do not represent a significant proportion of odour impact at ground level due

to the good dispersive characteristics of these discharge points (tall stacks with buoyant

plumes) and the fact that the meteorological condition that would bring about maximum

odour impact from the boiler stacks (unstable atmosphere) is opposite to the conditions

that would result in maximum odour impact from the rest of the factory odour sources at

ground level or near ground plume release). Furthermore, the character of the odour

emitted from the boilers is different from the factory odour, which further decreases the

risk of cumulative odour impact. Therefore, for the purposes of this assessment, odours

emanating from the boilers as a result of coal-combustion have not been included in the

dispersion modelling assessment.

Environmental Farm

The clear condensates are pumped to storage ponds (Ponds No. 1, 2, 3, 5 and 6) at the

Environmental Farm, where they are acidified with sulfuric acid to limit microbial activity

and hence odour generation. The ‘dirty’ wastewater streams are, combined in the farm

tank (located at the factory) and pumped to a partially covered pond for storage where

they are acidified. Prior to wastewater disposal by irrigation on pasture at the

Environmental Farm using spray irrigators (travellers or pivot sprays equipped with low

mist nozzles), lime is added in the mixer tank to wastewater drawn from the ponds to

raise the pH.

The majority of the emitted odours had a hedonic range from mildly pleasant to mildly

unpleasant, with the exception of the mixer tank vent (F1) and Pond 4 (F5), which had

very unpleasant hedonic tones.

In response to the recommendations of the Audit Report, Shoalhaven Starches

proposed to install and operate a wastewater treatment plant. Key components included




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the bulk volume fermenter (BVF), sulfur oxidising (SO) basin and membrane batch

reactor (MBR) plant – refer to Section 7.3 of the EA for details on the WWTP.

In deriving the OER inventory for before and after the WWTP installation, a typical

irrigation rate at the environmental farm of approximately 5 to 6 ML in a given day was

adopted. This was assumed to comprise the use of pivot irrigator No. 130 (equipped

with low mist nozzles) plus two small travellers and two large travellers.

A breakdown of the odour sources from the existing operation at the Environmental

Farm before and after the installation of the proposed wastewater treatment plant is

given in Table 8

Table 8

OER Inventory - Environmental Farm

Odour Source Group OER before WWTP

(OU m3/s) OER after WWTP

(OU m3/s)

Mixer tank 150,000 Nil1

Ponds 290,000 3,6002

Spray irrigation 540,000 Negligible3

Irrigated land 90,000 Negligible3

BVF − Negligible4

MBR plant5 − 500

SO Basin6 − 23,400

TOTAL 1,070,000 27,500

1 Decommissioned with installation of WWTP.

2 Treated effluent storage pond for new WWTP. Adopted specific OER = 0.1 OU/m

2/s for

treated effluent ponds (assumed to be pond 5). 3 ADI (the supplier of the WWTP) advised Shoalhaven Starches that the treated effluent from

the SO basin could be irrigated with low, if any, discernable odour emissions. Any discernible odours released during irrigation are expected to have an earthy or musty characteristics, which is likely to blend with the palette of odour typical of the surrounding rural/agricultural environment.

4 A small negative pressure will be maintained under the BVF cover so that the gas mixture

(biogas) can be continuously drawn for use as an energy source. 5 Adopted specific OER = 1.0 OU/m

2/s for MBR plant with exposed surface area of

approximately 500 m2.

6 It is assumed that the surface of the SO basin would have an odour emission gradient ranging

from 2.5 to 0.2 OU/m2/s. Adopted mean specific OER = 1.4 OU/m

2/s, which was applied to

the exposed surface area of approximately 17,300 m2. A higher specific OER was adopted for

the SO basin than the MBR on the assumption that there would be less activated sludge in the SO basin to adsorb the odorous compounds.




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The OER data presented in Table 8 show that odour emissions from the Environmental

Farm under normal operating conditions could be reduced by approximately 95% after

commissioning of the proposed wastewater treatment plant.

The proposed ethanol upgrade has been factored into the design of the proposed

wastewater treatment system and, as such, no incremental increase in potential odour

generation is expected as a result of the ethanol project.

Particulate Matter

The term total suspended particulate (TSP) matter refers to airborne particles typically

less than 50 microns (µm) in aerodynamic diameter. The fraction of suspended particles

that is less than 10 µm is referred to as PM10.

The primary source of particulate matter emissions at Shoalhaven Starches factory is the

coal-fired boilers used for steam generation. Coal ash from the boilers may either settle

out in the boiler (bottom ash) or be entrained in the flue gas (fly ash). The secondary

source of this type of emissions are the significant material dryers, grinders and material

handling units within the factory, which are equipped with fabric filters (baghouses) or

wet-scrubbers to control emissions to air.

Shoalhaven Starches also proposed to operate (stand-by) gas-fired boilers at the

factory. PM10 is emitted in very low amounts from natural gas combustion. Hence the

infrequent operation of these stand-by systems is not anticipated to result in a significant

increase to PM10 emissions or off-site impact.

Fugitive emissions of TSP and PM10 have not been included in GHD’s assessment.

GHD assumed that the application of standard dust mitigation measures (eg.

housekeeping) would provide adequate control to minimise air quality impacts.

The TSP and PM10 emission data show the following key features:

• the ethanol upgrade results in a negligible (< 3% TSP, < 8% PM10) incremental

increase to both PM10 and TSP emissions; and

• the total TSP and PM10 emission rates are 13.3 g/s and 3.9 g/s, respectively.

The Protection of the Environment Operations (Clean Air) Regulation 2002 prescribes

the maximum in-stack concentrations for commercial and industrial activities and plant.

The results of GHD’s modelling indicate that boilers No. 2 and No. 4 do not meet

regulations for in-stack TSP concentration. Shoalhaven Starches advised GHD that

action would be taken to clean and repair the existing emission control system (cyclone)

and then re-test each boiler exhaust for compliance. If the tests were not satisfactory,




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investigations would be undertaken to i) install fabric filtration (baghouse) systems; or ii)

install gas burners to replace the existing coal-fired boiler.

The proposed gluten dryer and gluten grinder would be fitted with fabric filtration systems

that would be able to achieve an in-stack concentration of < 10 mg/m3, which complies

with the Schedule 4 – Group 6 requirements of 20 mg/m3 TSP.

In-stack emission concentration data for the gas-fired boilers and turbines were not

available for this assessment, however, it is anticipated that exhaust would be compliant

with the regulations mentioned above.

Products of Combustion

The primary pollutants from coal and gas fired boilers are oxides of nitrogen (NOx),

formed by the high temperatures in the combustors, sulfur dioxide (SO2), formed from

the sulfur content of the fuel, VOCs, polycyclic aromatic hydrocarbons (PAH) and carbon

monoxide (CO), all formed by incomplete combustion of the fuel.

The Protection of the Environment Operations (Clean Air) Regulation 2002 prescribes

the maximum in-stack concentrations for commercial and industrial activities and plant.

According to GHD, in-stack emission concentration data for the proposed gas-fired boiler

and turbines were not available for their assessment, however, GHD anticipate that

proposed boiler/turbine exhaust would be compliant with the regulations mentioned

above.

Construction

The types of emissions to air during the construction process will primarily consist of:

• dust emissions from both the mechanical disturbance and wind erosion of crustal

material; and

• exhaust emissions from the range of motor vehicle and mobile plant required for the

project.

The major potential dust sources during construction activity are expected to include:

• clearance of vegetation, rock and soil material;

• general surface earthworks and construction works;

• top soil and soil handling (eg stockpiling, loading, dumping);

• levelling and grading of soil surfaces;




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• passage of construction and administrative vehicles over unsealed sections of road

or localised unconsolidated soil surfaces; and

• wind erosion of unstable/uncovered surfaces and stockpiles and other

unconsolidated surfaces.

Recommended in-principle air quality mitigation measures to minimise potential impacts

on air quality during project construction include:

• Site managers should be provided with daily weather updates that would contain

warnings of the onset of strong winds. The site manager could then take steps to

pre-water construction areas and stockpiles before they are disturbed and continue

watering during any activities where fugitive dust may be produced;

• Dry material should be watered prior to it being loaded for haulage;

• Physical barriers should be constructed to act as windbreaks for the construction

site or for stockpile areas;

• Dust screens (eg. shade cloth) should be installed on construction site boundaries

that are adjacent to sensitive receptors;

• Storage piles should be a suitable height, width and slope and placed in areas

protected from the wind and away from public places where possible. Spoil

stockpiles should be water sprayed regularly and dry material stockpiles should be

covered;

• Existing vegetation should be retained where possible or re-vegetate cleared areas

and stockpiles with fast growing species for rapid coverage to temporarily or

permanently stabilise soil;

• Construction traffic should be controlled by designating specific routes for haulage

and access. Vehicle speeds should be limited to 25 km/h;

• All trucks hauling dirt, sand, soil or other loose materials to and from the

construction site should be covered;

• Material spillage on roads and pathways should be cleaned up immediately;

• Earthmoving activities should be suspended during times of high winds, particularly

when dust plumes are directed towards sensitive receptors; and

• All construction vehicles, mobile plant and machinery should be maintained and

operated in accordance with the manufacturers’ specifications to minimise exhaust

emissions.




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7.1.3 Assessment of Air Quality Impacts

The air quality impact assessment criteria are applicable at the nearest existing or likely

future off-site sensitive receptors. The predicted incremental impact (predicted impact

due to Shoalhaven Starches operations) and the predicted total impact (incremental

impact plus background) of each pollutant modelled by GHD are detailed as follows:

Odour

The predicted odour impact for the existing factory under several operating scenarios

was examined by GHD to gain a better understanding of the predicted odour levels that

would occur after implementing the nominated stages of odour control (ie. Environmental

Farm odour sources are not included in the models).

The extent of interaction between the odour plumes emanating from the factory and

Environmental Farm was also examined by GHD.

Factory

Odour model simulations were conducted by GHD to predict the impact for each of the

scenarios described in Table 9

Table 9

Odour Model Scenarios

Scenario Scenario Description Odour

Control Ethanol Upgrade

Figure

A Factory principal odour sources with existing level of odour control

Existing No 8

B Factory principal odour sources with Stage 1 odour control

Stage 1 No 9

C Factory principal odour sources with Stage 1 odour control plus ethanol upgrade odour sources

Stage 1 Yes 10

D Factory principal odour sources with Stage 2 odour control plus ethanol upgrade odour sources

Stage 2 Yes 11

E Factory principal odour sources with Stage 3 odour control plus ethanol upgrade odour sources

Stage 3 Yes 12

F Factory principal odour sources with existing level of odour control minus DDG plant odour sources

Existing No 13

For each scenario, the model odour predictions at each grid receptor were ranked from

highest to lowest and the 88th highest (99%ile, 1-second average). Predictions at each




Page 107

receptor were then contoured. These contours (or concentration isopleths) were

overlaid upon a scaled aerial photograph of the area for interpretation and comparison

with the odour criteria. The concentration contour plots for each odour model scenario

are presented in Figures 10 to 16.

Table 10 summarises the results of the odour model scenarios, it shows the predicted

odour concentration at the factory site boundary and at sensitive receptors in Nowra,

North Nowra, Bomaderry and Terara.

Table 10

Odour Model Results - Factory

Predicted Ground Level Odour (OU, 99%ile, 1-sec. avg)

Ref. Scenario Description Bomaderry (R1)

N Nowra (R2)

Nowra (R3)

Terara (R4)

Factory – western

boundary

A Factory principal odour sources with existing level of odour control

40 13 20 18 100

B Factory principal odour sources with Stage 1 odour control

5 3 5 5 ~ 20

C Factory principal odour sources with Stage 1 odour control plus ethanol upgrade odour sources

6 3 5 5 ~ 20

D Factory principal odour sources with Stage 2 odour control plus ethanol upgrade odour sources

3 2 3 3 ~ 10

E Factory principal odour sources with Stage 3 odour control plus ethanol upgrade odour sources

2 1 < 2 < 2 ~ 5

F Factory principal odour sources with existing level of odour control minus DDG plant odour sources

5 2 5 5 ~

The results presented in Table 6 are summarised as follows:

Existing Odour Control – Scenario A

Predicted odour concentrations for the existing factory indicate that the 2 OU (99%ile,

1-second average) criterion is not met at any of the receptors, with odour levels of

approximately 40 OU on the southern fringes of Bomaderry and 20 OU on the northern

fringes of Nowra (refer to Figure 10).




Page 108

Stage 1 Odour Control – Scenario B

A substantial reduction in off-site odour impact is clearly evident after implementation of

stage 1 odour control to the existing factory, with predicted odour levels in the range of

3 to 5 OU at the closer sensitive receptors (refer to Figure 11).

Stage 1 Odour Control Plus Ethanol Upgrade– Scenario C

The ethanol upgrade model results show a slight (~ 20%) increase to the predicted

odour levels at the sensitive receptor at Bomaderry (R1) but did not show a significant

increase at the other receptors.

These results suggest that, for the most part, application of stage 1 odour controls to the

factory has essentially countered the potential for significant incremental odour impact as

a result of the proposed ethanol upgrade (refer to Figure 12).

Stage 2 Odour Control Plus Ethanol Upgrade– Scenario D

Implementation of stage 2 odour control results in a further decrease in predicted odour

impact but the predicted odour levels at the sensitive receptors are still above 2 OU

criterion at three of the four receptors (Figure 13).

However, it is noteworthy that the predicted odour levels are the same or slightly lower

than the predicted odour levels for Scenario F (Figure 15), which represents the factory

prior to the installation of the DDG plant.

Stage 3 Odour Control Plus Ethanol Upgrade– Scenario E

With implementation of stage 3 odour control at the factory the 2 OU criterion is met at

all sensitive receptors at Bomaderry, Terara, North Nowra and Nowra (refer to

Figure 14).

Implications

The factory odour emissions can be a significant odour source contributing to off-site

odour impact, particularly in the residential areas immediately adjacent to the factory.

A breakdown of the odour source contribution to the predicted ground level odour

indicates that the DDG plant contributes the greatest (~ 50%) to the predicted odour

impact at receptors adjacent to the factory (Nowra, North Nowra, Bomaderry and

Terara).

Furthermore, the model results for the existing factory operation correspond with the

odour complaint history over the last few years since installation of the DDG plant at the

factory. That history was marked by complaints from residents located in Bomaderry

and Nowra. Prior to the installation of the DDG plant, odour complaints attributed to the




Page 109

factory operation were infrequent. This supports the notion that, although it is likely that

the nearby sensitive receptors did not experience a period that was free of odour

impacts with respect the factory operations without the DDG plant, the level of odour

impact was likely to have been inoffensive.

Analysis of the odour source contribution to the predicted ground level odour after

implementation of stage 1 odour control (Scenario C) indicates that the starch and gluten

dryers contribute approximately 30% to the predicted odour impact at receptors adjacent

to the factory and up to 50% of the predicted odour level after the implementation of

stage 2 odour control (Scenario D). This equates to approximately 2 OU for each of

these scenarios, which on its own indicates that odour emissions from these sources are

sufficient to breach the odour criterion. However, the odour character (flour, dough,

grain) and hedonic tone (ranging from mildly pleasant to mildly unpleasant) of the

emissions from these sources is not likely to be considered offensive. The

understanding that odour complaints against the factory have not been directly attributed

to the operation of these dryers supports this.

Therefore, in light of the above, the staged approach to odour management

implementation is merited in that progression to stage 3 odour control to meet the 2 OU

criterion, may not be warranted if the incidence of odour complaint is effectively mitigated

at Stage 1 or Stage 2.

It should also be borne in mind that the 2 OU criterion was developed to limit odour

nuisance to acceptable levels. Modelling to determine compliance or otherwise to the

criterion according to GHD is a design tool rather than a regulatory tool, and the

overriding goal should be to minimise odour complaints rather than obtain technical

attainment of a derived criterion.

Factory and Environmental Farm

The extent of interaction between the odour plumes emanating from the factory and

Environmental Farm (wastewater treatment plant) was examined based on the odour

emission estimates for the proposed wastewater treatment plant components (SO basin,

MBR and treated effluent storage) at the Environmental Farm (refer to Sections 7.3) and

factory odour emissions after stage 1 odour control plus the ethanol upgrade

(Scenario G).

Figure 16 shows that there is not a significant increase to the predicted odour levels at

the selected receptors near the factory as a result of adding the odour emissions from




Page 110

the wastewater treatment plant into the model that represents the factory after stage 1

odour control plus the ethanol upgrade (compared to scenario C in previous section).

Figure 16 also shows that the 7 OU criterion would be achieved at the rural residences

located near the environmental farm. The 7 OU contour is confined within the

Environmental Farm boundary except for a minor excursion over the southern boundary.



Page 111

F

igu

re 1

0:

Fa

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Imp

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Mo

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Sc

en

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(E

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)



Page 112

F

igu

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1:

Fac

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Od

ou

r Im

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ct

Mo

de

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cen

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o B

(E

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on

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Page 113

Fig

ure

12:

Fac

tory

Od

ou

r Im

pact

Mo

del – S

cen

ari

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(F

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ith

Sta

ge 1

Od

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l an

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than

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pg

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Page 114

F

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Imp

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Mo

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(F

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Page 115

Fig

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14

: F

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Page 116

Fig

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Sc

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Page 117

F

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re 1

6:

Facto

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nd

En

vir

on

men

tal F

arm

Od

ou

r Im

pac

t M

od

el

– S

ce

na

rio

G




Page 118

Particulate Matter

The air quality impacts of PM10 and TSP emissions from Shoalhaven Starches (includes

ethanol upgrade and stage 1 odour control) operation have been assessed using

atmospheric dispersion modelling.

The impact of dust emissions principally relates to the potential effect on human health

on inhalation of particles in the air column, and it is the finer fraction (PM10) that have

the greater potential to cause respiratory health effects.

A secondary effect relates to the deposition of the course fraction of TSP onto surfaces

(eg. car roofs, clothes line at nearby receptors), which is an impact on amenity. Typical,

depositions effects are confined to short ranges, as the settling velocity of the course

particles is significant and drop out from the dust plume is local only.

In GHD’s assessment the off-site in-air concentration of TSP and PM10 has been

modelled so as to determine the off-site health risk to exposure to particular emissions.

The amenity impacts of dust deposition is assumed to be confined within the site

boundary and surrounding industrial area and therefore has not been modelled. In any

event, modelling of deposition rate requires particle size distribution data from each

source and is unable to model wet deposition to any degree of accuracy.

Table 11 provides a summary of the predicted incremental PM10 and TSP

concentrations at the nearest receptors.

Table 11

Odour Model Results - Factory

Predicted Incremental Ground Level Concentration

(µµµµg/m3)

Pollutant Averaging

Period Bomaderry

(R1) N Nowra

(R2) Nowra (R3)

Terara (R4)

PM10 24-hour 10 5 7 4

PM 10 Annual 1 0.5 0.5 0.75

TSP Annual 2 1 1 1.5

Table 11 shows that the predicted incremental impact at each sensitive receptor is at

least an order of magnitude below the PM10 criteria of 50 µg/m3 (24-hour) and 30 µg/m3

(annual) and TSP criterion of 90 µg/m3 (annual). Therefore, it is likely that impact of

emissions from the boilers and dryers on a day-to-day basis would be negligible.




Page 119

It is also evident from the results in the above table that even with the addition of a PM10

background level of 15 – 20 µg/m3, the total (cumulative) impact would still be well below

the assessment criteria.

Figure 17 shows the 24-hour average ground level concentration contours for particulate

matter less than 10µm (PM10). The highest predicted concentration at the nearest

receptors is 10 µg/m3, which is 20% of the assessment criterion of 50 µg/m3.



Page 120

F

igu

re 1

7:

Maxim

um

Pre

dic

ted

Gro

un

d L

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M10 C

on

cen

trati

on

s (

24-h

ou

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(Ae

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00

7)




Page 121

Products of Combustion

Nitrogen Dioxide

The DECC Approved Methods outlines three approved methods for assessing the

oxidation of nitrogen oxide to nitrogen dioxide in the atmosphere. Method 1 was used by

GHD whereby it was assumed that 100% of the oxides of nitrogen emitted are converted

to nitrogen dioxide. There are two levels of assessment for this method:

• Level 1 assessment: Maximum 1 hour predicted and maximum 1 hour background

nitrogen dioxide concentration; and

• Level 2 Assessment: Contemporaneous 1-hour predicted and 1-hour background

nitrogen dioxide concentration.

As contemporaneous site-specific background air quality data was not available, a

level 2 assessment could not be made.

According to GHD, the maximum (100 percentile) predicted total (incremental plus

background) impact for nitrogen dioxide would readily comply with the 1-hour and annual

average criteria at the sensitive receivers.

Sulphur Dioxide

According to GHD the maximum predicted ground level sulphur dioxide concentrations

were found to be well below the DECC criteria at the sensitive receptors.

The DECC air quality criteria for sulphur dioxide also includes a short-term peak

concentration (10-minute average) limit of 712 µg/m3. Dispersion models, such as

CALPUFF, use the power law expression to link short-term averaging at t minutes (t < 60

minutes) to 1-hour average as (Ct/C60) = (60/t)0.2. Applying this relationship, under

conservative assumptions, the peak 10-minute average ground level sulphur dioxide

concentration is expected to be approximately 1.5 times higher than the maximum

predicted 1-hour ground level concentration, which according to GHD at all receptors,

would be readily compliant with the criterion.

Carbon Monoxide

According to GHD the maximum (100 percentile) predicted ground level carbon

monoxide concentrations were also found to be well below the DECC criteria at the

sensitive receptors.

The DECC air quality criteria for carbon monoxide also includes a short-term peak

concentration (15-minute average) limit of 100 mg/m3. According to GHD, the peak




Page 122

15-minute average ground level carbon monoxide concentration is expected to be

approximately 1.3 times higher than the maximum predicted 1-hour ground level

concentration, which, at all receptors, would be readily compliant with the criterion.

Heavy Metals

A screening approach was used by GHD to assess compliance with the air quality

impact assessment criteria for heavy metals. The aggregate mass emissions for Type 1

heavy metals (antimony, arsenic, cadmium, lead and mercury) and Type 2 (beryllium,

chromium, cobalt, manganese, nickel and selenium) were modelled and compared in

turn against the criterion for each species. In affect in each simulation it is assumed by

GHD that 100% of the aggregate is solely portioned to the metal concerned, which will

obviously provide an overestimate of predicted impact for each individual heavy metal

within each group.

The maximum predicted (99.9 percentile, 1-hour average) ground level heavy metal

type 1 concentration, at the most exposed sensitive receptor (R1), was 0.00004 mg/m3,

which is lower than the respective air quality criteria for all constituents, except for

cadmium at 0.000018 mg/m3. The maximum predicted (99.9 percentile, 1-hour average)

ground level cadmium concentration at the most exposed sensitive receptor (R1) was

0.0000009 mg/m3, which complies with the criterion.

The maximum predicted (99.9 percentile, 1-hour average) ground level heavy metal

type 2 concentration, at the most exposed receptor (R1), was 0.000035 mg/m3, which is

lower than the respective air quality criteria for all constituents, except for beryllium at

0.000004 mg/m3. The maximum predicted (99.9 percentile, 1-hour average) ground

level beryllium concentration at the most exposed sensitive receptor (R1) was 0.000002

mg/m3, which complies with the criterion.

The DECC criteria also require consideration to be given to the maximum predicted

ground level concentration at and beyond the site boundary of the factory. According to

GHD the maximum predicted (99.9 percentile, 1-hour average) ground level

concentration for each heavy metal complies with the respective criteria at the factory

site boundary, except beryllium. However, the beryllium criterion is met within a distance

of less than 100 metres from the northwest site boundary.

Emissions from boiler stack no. 2 and no. 4 make the greatest contribution to ground

level impact near the site boundary. Stack emission test data for these boilers indicates

that a significant proportion of the measured heavy metals are likely to be adsorbed to

the emitted particulate matter, therefore, improvements that will be made to the




Page 123

particulate emission control systems on these boilers should also reduce the levels of

heavy metals emitted.

VOC

Organic compounds emitted as minority products of fossil fuel (natural gas and coal)

combustion may include:

• Acetaldehyde;

• Benzene;

• Carbon disulphide;

• Chloroform;

• Cyanide;

• Ethyl benzene;

• Formaldehyde;

• Methyl ethyl ketone;

• Methyl methacrylate;

• Phenol;

• Toluene;

• Styrene; and

• Xylene.

Speciated VOC emission data for the boiler exhaust emissions were not available for

GHD’s assessment.

Therefore, a screening approach was used to assess compliance with the air quality

impact assessment criteria for the compounds listed above. Total VOCs were modelled

by GHD using the total VOC mass emission rate and the predicted peak aggregate VOC

ground level concentration was determined. This value will obviously provide an over-

estimate of predicted impact for each individual compound.

The maximum predicted (99.9 percentile, 1-hour average) ground level aggregate VOC

concentration, at and beyond the factory site boundary, was 0.017 mg/m3, which is lower

than the respective DECC principal toxic air pollutant criteria for all the compounds listed

above.

The maximum predicted (99.9 percentile, 1-hour average) ground level total VOC, at the

most exposed sensitive receptor (R1), was 0.005 mg/m3, which shows that an even

greater margin of compliance would be achieved at the nearest sensitive receptor.




Page 124

PAH

According to GHD the maximum predicted (99.9 percentile, 1-hour average) ground level

total PAH concentration, at and beyond the factory site boundary, was 0.0011 µg/m3,

which is lower than the DECC PAH criterion of 0.4 µg/m3.

The maximum predicted (99.9 percentile, 1-hour average) ground level total VOC, at the

most exposed sensitive receptor (R1), was 0.00019 µg/m3, which is 0.05% of the

criterion – that is more than 1000-fold below the criterion at the most exposed receptor.

7.1.4 Conclusions

The air pollution emission inventory and dispersion modelling for the proposed ethanol

upgrade has led to the following conclusions, as presented by GHD:

• “In this assessment, odour, particulates and products of combustion were assessed against DECC air quality impact assessment criteria. All constituents assessed over all relevant averaging times were below their respective assessment criteria for the adopted emission characteristics, with the exception of odour. Odour was found to be the critical constituent for compliance with the DECC air quality impact criteria;

• The implementation of stage 1 odour controls to the factory would essentially counter the potential for significant incremental odour impact as a result of the proposed ethanol upgrade. Approximately 70% of potentially odorous emissions associated with the proposed ethanol upgrade would be treated using a bioscrubber. The remaining odour emissions would be subject to odour minimisation measures, which include adequate dispersion and ventilation maintenance (e.g. ductwork cleaning) – refer to section 8.1.1;

• Model results indicate that the implementation of stage 3 odour control at the factory would be required to achieve compliance with the DECC design odour criterion of 2 OU at the nearest sensitive receptors. However, it was demonstrated that installation of a wastewater treatment plant at the environmental farm and stage 2 or even stage 1 odour control measures at the factory might sufficiently mitigate the potential for future offensive odour impact (e.g. odour complaints) – refer to Section 8.1.1; and

• There is not a significant incremental increase to the predicted odour levels at the receptors near the factory, when odour emissions from the proposed wastewater treatment plant at the environmental farm are taken into consideration using the adopted emission characteristics detailed in the emission inventory. Furthermore, the model shows that the 7 OU odour criterion would be achieved at the rural residences located near the environmental farm – refer to section 8.1.2.”

It is evident from the findings and conclusions of the Air Quality Assessment carried out

by GHD Pty Ltd that particulates and products of combustion associated with the




Page 125

proposed ethanol upgrade were found to be below the relevant assessment criteria for

the adopted emission characteristics.

Odour however was found to be the critical constituent for compliance with DECC air

quality impact criteria.

In light of the findings and conclusions of the Air Quality Assessment, Shoalhaven

Starches propose to integrate the Ethanol Production Upgrade with the Odour

Management Plan that has been developed for the site and which emanated from the

Environmental Audit that GHD Pty Ltd has undertaken of the site.

Shoalhaven Starches therefore commit to the odour control measures as detailed in

Table 5-1 of the Air Quality Assessment and which are summarised in Table 7 of

this EA.

Shoalhaven Starches furthermore commit to treat waste water generated from factory

process sequentially through anaerobic and aerobic digestion systems to be established

within the existing approved wet weather storage pond No. 7, and as described in

Section 5.8.2 of the EA.

Furthermore Shoalhaven Starches will commit to the implementation of the above odour

control measures in three stages, in a manner as detailed in Table 5-1 of the Air Quality

Assessment prepared by GHD Pty Ltd and as summarised in Table 7 of this EA.

The staging of the odour control implementation proposed by Shoalhaven Starches is

based on the prioritisation of the odour sources as presented in Table 3-1 of the Air

Quality Assessment prepared by GHD Pty Ltd.

The timing for each odour control stage will be as follows:

• Stage 1 – December 2008;

• Stage 2 – Reassess within 6 months of completion of Stage 1 and implement Stage

2 as required; and

• Stage 3 – if required, depending upon outcomes of Stage 2.

To assess the outcomes of each stage of the odour management controls Shoalhaven

Starches will undertake the following measures:

1. Following completion of each stage of odour control measures, a meeting will be

held with the Community Consultation Group to ascertain whether members of the

community have experienced improvement in terms of odours.




Page 126

2. A review will also be undertaken of the number and nature of complaints received

by the Company in connection with odours.

If following these measures it is evident that there is a reduction in the number of

complaints; and the local Community Consultation Group indicate improvements, then

works associated with subsequent stages will be deferred.

However if there is no demonstrated improvement, then odour monitoring will be

undertaken to further evaluate odour control measures.

If as a result of this monitoring it is found that odours are still emanating from the site,

works associated with subsequent stages of the odour management plan will be

undertaken.

7.2 GREENHOUSE GAS EMISSIONS

GHD were engaged by Shoalhaven Starches to undertake a greenhouse assessment of

the project. A copy of this assessment is included as Annexure N of this EA.

The scope of this assessment has been based on the Director-General’s requirements

for the environmental assessment of the Project:

� A full greenhouse gas assessment, including a quantitative analysis of the scope 1, 2 and 3 emissions of the project, and a qualitative analysis of the impacts of these emissions, in accordance with the requirements of the Australian Greenhouse Office’s Factors and Methods Workbook 2006;

� Evaluate the feasibility of measures to reduce and/or offset emissions, including an analysis of energy use.

The methodology for conducting the assessment has been based on the Department of

Planning’s Guidelines Energy and Greenhouse in EIA, August 2002 (the ‘Guidelines’).

The Guidelines set out a systematic approach to the assessment of the energy and

greenhouse impacts associated with a proposal.

The purpose of the greenhouse assessment carried out by GHD was to calculate the

emissions of greenhouse gases associated with the proposed development, and to

compare these to the baseline scenario. In order to obtain a comprehensive estimate,

emission sources were considered (both direct and indirect), associated with:

• The construction of the new plant;

• The preparation and acquisition of raw materials;

• Transfer of major raw materials (including wheat) to Bomaderry by truck or train;




Page 127

• Energy and fuel used on site for the production of ethanol, starch, gluten and other

products, including grid electricity, natural gas, petroleum, diesel, etc;

• Storage of products on site;

• Waste disposal and wastewater treatment;

• Transport of products from Shoalhaven Starches to depots, distributors and

consumers;

• Usage of ethanol blend fuels; and

• Final plant decommissioning.

The emissions from these life cycle stages were then aggregated and compared to the

no-change scenario of continuing to operate the current Shoalhaven Starches facility

(without upgrade).

The greenhouse assessment was prepared by GHD in accordance with the general

principles of:

• The recognised international standard –The Greenhouse Gas Protocol, A Corporate

Accounting and Reporting Standard developed by the World Business Council for

Sustainable Development (GHG Protocol);

• Life Cycle Assessment principles (ISO 14040 series); and

• The Department of Climate Change (DCC) National Greenhouse Accounts (NGA)

Factors, 2008 (which replaces the Australian Greenhouse Office (AGO) Factors and

Methods Workbook).

These are considered to represent best practice in Australian greenhouse gas

accounting

7.2.1 Energy and Greenhouse Analysis

Energy Use Results

Baseline, gross and net energy used during operation are summarised by GHD in

Table 12.

According to GHD total energy use at the Shoalhaven Starches site will increase by

2.7 times current levels. The analysis shows that the primary energy source is the

combustion of natural gas (responsible for 94% of net energy use). The proposed

ethanol plant upgrade will include a cogeneration facility that will be powered by natural

gas and biogas captured from wastewater treatment. The large increase in natural gas




Page 128

consumption will be offset to some extent by a reduction in purchased electricity from the

grid. Following the upgrade, purchased electricity consumption will be cut to 11% of

baseline usage.

Transport energy use for raw materials and products account for 6% and 4% net energy

use respectively. The small increase in coal use for the proposed plant only accounts for

2% of net energy use.



Page 129

Tab

le 1

2

En

erg

y U

se S

um

ma

ry

Ba

seli

ne

En

erg

y U

se

(E

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tin

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En

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se

Ex

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et

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(Up

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Un

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GJ/a

Sc

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t/a

2,8

35,0

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109,0

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t/

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2,9

43

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4,0

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t/a

10

8,0

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Natu

ral

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−

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68,5

36

GJ/

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168,5

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6,8

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31,4

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10,8

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/a

467,6

79

14,0

00,0

00

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50

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0,8

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7,2

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Sc

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Die

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transport

38.6

G

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19,8

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14,8

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11,7

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4,1

36

Die

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− P

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38.6

G

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13,3

15

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5

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52

21,2

63

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6,7

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To

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4,1

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6

7,0

83,1

09




Page 130

Greenhouse Emission Results

The results from the greenhouse assessment are summarised by GHD in Table 13

below.

Table 13

Greenhouse Gas Emissions Assessment Results by Life Cycle Stage and Scope

Life Cycle Stage Baseline

Emissions 1

Gross Emissions

2

Net Emissions

3

Units t CO2 - e/a t CO2-e/a t CO2 - e/a Uncertainty

Construction (annualised over 30 years)

0 302 302 High

Raw material supply 174,335 421,284 246,949 Moderate

Raw material transport to Bomaderry

9,003 43,122 34,119 Moderate

Manufacture at Bomaderry 445,969 736, 709 290,740 Low

Product transportation 28,613 61,662 23,049 Moderate

Product usage -96,730 -461,842 -365,12 High

Decommissioning (annualised over 30 years)

0 -31 -31 High

Total Emissions 667,920 1,263,088 749,257

Total Credits -96,730 -461,882 -519,241

Total 4 571,190 801,206 230,016

Scope 1 emissions component of total

292,136 611,097 318,962


115,621 12,460 -103,161


163,433 177,649 14,215

Notes:

Listed figures may not sum exactly to the totals due to rounding.

1. Baseline emissions of the existing Shoalhaven Starches plant

2. Gross emissions of the existing and new plant

3. Net Emissions is calculated as gross emissions minus baseline emissions

4. Total annual emissions based on annual Scope 1, 2 and Scope 3 emissions (including annualised construction and

decommissioning emissions).

Baseline Emissions

The total baseline emissions for the existing plant, based on the 2006/07 period, amount

to 571,190 t CO2-e per annum. These emissions include the Scope 1, 2 and 3

emissions associated with the production of ethanol and other products at the site, and

the upstream and downstream impacts. Construction and decommissioning are not




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applicable. If the proposed plant expansion were not to go ahead, the emissions

associated with the baseline would continue into the future.

Total Gross Emissions

Total gross annual net emissions are calculated based on annual Scope 1, 2 and Scope

3 emissions, excluding annualised construction and decommissioning emissions.

Total gross annual emissions amount to 800,934 tonnes CO2-e compared to 571,190

tonnes CO2-e for the existing plant (2006/07 baseline) – an increase of 229,745 tonnes

CO2-e (40%). This compares well according to GHD with the total increase in energy

usage of 2.7 times current levels and indicates that lower greenhouse intensity fuels are

being used for the proposed plant.

Total annual NSW emissions for 2006/2007 are 158.2 Mega-tonnes CO2-e. The

estimated additional annual emissions from the project account for approximately 0.15%

of the state’s total emissions. The estimated total gross emissions (existing and

upgrade) from the project account for approximately 0.5% of the total annual emissions.

Total (net) project emissions

The greenhouse assessment indicates total (net) project emissions of 230,016 tonnes of

CO2-e per year, including annualised emissions from the construction and

decommissioning stages of the project. Total estimated missions from the construction

and decommissioning stages have been annualised over a 30 year period.

The project will result in a net increase of greenhouse gas emissions, even when the

downstream reduction as a result of replacing petroleum fuels with bioethanol is taken

into account (ie. the increased greenhouse gas emissions of the project will not be

completely offset by the reduced downstream emissions). The use of lower emissions

fuels at the plant will result in the products manufactured at the site having lower

associated emissions intensities than they have currently (however the larger volumes to

be produced mean that the total emissions will increase).

Table 13 shows the total emissions and total credits associated with the no change

(baseline) scenario, the proposed development (gross) scenario and the difference

between them (net). The total emissions figure is the sum of all of the positive emissions

associated with the production across the life cycle.

Positive emissions arise from the combustion of fuels, waste disposal, fugitive emissions

of greenhouse gases, etc. The total credits figure is the sum of all the emissions credits

throughout the life cycle.




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Emissions credits arise from activities that result in a reduction of greenhouse gas

emissions, such as the combustion of ethanol instead of petroleum fuel, the reuse or

recycling of resources instead of using virgin materials, etc. In the same way that the

total emissions consider the upstream and downstream greenhouse gas emissions

associated with the activities undertaken by Shoalhaven Starches, the total credits figure

considers any upstream and downstream reduction in greenhouse gas emissions. As

such, the total credits are subtracted from the total emissions to calculate the total

emissions associated with the production at Bomaderry, for each of the three considered

scenarios.

The Guidelines indicate that the uncertainty associated with emissions should be stated.

A qualitative assessment of uncertainty has been included in Table 13, based on the

perceived accuracy of the data and emissions factors for each life cycle stage. The most

accurate emission data is associated with manufacture.

The most emissions intensive stage of the project is manufacturing at the Bomaderry

production site.

Total annual NSW emissions for 2006/2007 are 158.2 Mega-tonnes CO2-e (based on

AGO ‘State and Territory Greenhouse Gas Inventories 2005 M arch 2007). The

estimated additional annual emissions from the project would account for approximately

0.15% of the state’s total emissions.

Fuel Combustion

The most emissions intensive stage of the project is manufacturing at the Bomaderry

production site.

Emissions due to product use are negative since they displace emissions due to

combustion of petrol, as indicated in Table 14.

Table 14

Combustion Emissions

Parameter Value Units

Ethanol energy content 23.4 GJ/kL

Energy content petrol 34.2 GJ/kL

Petrol EF 2.5 t CO2-e/kL

1 kL ethanol replaces 0.684 kL petrol

Emissions eliminated -1.711 t CO2-e/kL ethanol




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Major emission sources

The top ten annual net emission sources are listed in Table 15. It can be seen that the

three highest emission sources are:

1. Natural gas combustion (58% of positive emissions);

2. Flour production (15% of positive emissions);

3. Grain production (9% of positive emissions).

These emission sources are responsible for 82% of positive emissions. The total for the

ten highest sources captures 97% of positive emissions.

Table 15

Top 10 Net Emission Sources

Ranking Source Emissions (t CO2-e)

Fraction of net positive emissions

1 Natural Gas 434,361 58.0%

2 Flour production 115,208 15.4%

3 Grain production 66,949 8.9%

4 Millfeed production 29,880 4.0%

5 Sugar transportation 28,632 3.8%

6 Lime production 16,293 2.2%

7 Sugar production 12,512 1.7%

8 Coal combustion 10,055 1.3%

9 Starch distribution 7,775 1.0%

10 Stillage distribution 4,738

Total 721,666 97.0%

The top 3 credits in the net emissions inventory are:

1. Replacement of petroleum with ethanol fuels;

2. Reduction in electricity consumption;

3. Wastewater treatment biogas capture.

These emission sources are responsible for credits of 517,288 tCO2-e/a. The total of all

the credits are equivalent to 519,241 tCO2-e/a.

Greenhouse Intensity

Greenhouse intensity is normally expressed as the emissions per unit of production for

operational emissions only (based on current practice with DCC Greenhouse Challenge




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reporting requirements). The greenhouse intensity can be used to benchmark against

an organisation’s previous performance or across an industry sector.

In summary, according to GHD net emissions intensity is lower than both the gross and

baseline emissions intensities. When compared to NGA average values for ethanol

production, the Shoalhaven Starches values are considerably lower. The current

production emission intensity value is approximately 5% lower, and following the

upgrade the intensity will be 16% lower. The net emissions intensity is approximately

26% lower than the Australian average value. These differences should be considered

indicative only, since they fall within the uncertainty of the emissions intensity values.

Best Practice Ethanol Emissions

In Australia, fuel ethanol can be manufactured from a number of sources, including

wheat, sugar cane, molasses and wood waste, however, at present it is only

manufactured on a commercial scale from the fermentation of sugars from wheat and

molasses. A large fraction of the total life cycle emissions associated with the production

of fuel ethanol arises from the production and processing of the major raw material

inputs. Significant savings are therefore achieved when a waste material from another

process is utilised, rather than an agricultural input that is grown for the purpose.

CSIRO (and partners) published a report in 2003 titled “Final Report (EV45A/2/F3C) to

the Australian Greenhouse Office on the Stage 2 study of Life-cycle Emissions Analysis

of Alternative Fuels for Heavy Vehicles” which used life cycle assessment principles to

compare environmental indicators for a number of fuels.

Best practice fuel ethanol production uses wood waste as the major raw material.

Although ethanol produced from wood waste has a much lower emission intensity than

any of the other feedstocks, the production of ethanol in this way is still largely in the

research and development stage, and there are no facilities in Australia that produce

ethanol in this way on a mass scale.

The next best technology options are associated with the fermentation of wheat starch

and wheat starch waste. Best practice in this sector also involves heat recovery from

wheat straw, with an emissions intensity of 0.8 t CO2-e/kL.

The process currently undertaken by Shoalhaven Starches uses wheat starch waste as

the feedstock, although the proposed expansion will also ferment wheat grain and

refined sugar to produce ethanol. The emissions intensity of ethanol produced at

Shoalhaven Starches following the upgrade will be 0.96 t CO2-e/kL.




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Although the Shoalhaven Starches process does not include (or propose to include) heat

recovery from the combustion of wheat waste, these materials are sold as a useful

product (animal feed), and are not wasted.

Until ethanol production from wood waste becomes a commercial option, production

from wheat and wheat starch waste, such as the process carried out by Shoalhaven

Starches, will represent the lowest emissions option in Australia.

International processes and production have not been included in the assessment by

GHD because growing conditions, and the markets for raw materials and process

products and by products, vary considerably from Australian conditions, and as such, are

not considered to be comparable.

7.2.2 Greenhouse Emission Reduction

Direct Greenhouse Gas Minimisation

According to GHD direct greenhouse gas emissions (ie. those generated on site) can be

minimised at the Shoalhaven Starches site by:

• Adoption of best available technology for fuel combustion;

• Greenhouse gas capture and destruction; and

• Switching from high-emissions to low-emissions fuels.

Adoption of best available technology

The proposed plant will incorporate a gas fired cogeneration plant. This represents

according to GHD the best available technology economically achievable to meet the

heat and energy needs of the proposed plant.

Additional equipment for the proposed plant, such as fermentation tanks, cooling towers,

dryers, evaporators, etc will be designed to minimise operational energy use.

Greenhouse gas capture

The existing plant sends wastewater to a series of treatment ponds, where anaerobic

decomposition generates methane. This methane is not captured from the system and

contributes to greenhouse gas emissions (approximately 5% of current positive

emissions).

The proposed plant incorporates a new wastewater treatment system where 100% of

biogas generated is captured for energy generation. This will effectively reduce

greenhouse emissions by 31,000 tonnes per annum, and will recover 260 TJ annually,

further reducing Shoalhaven Starches’ consumption of fossil fuels.




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Emissions savings resulting from the energy recovery from biogas are taken into account

in the calculations. The combustion of the biogas has an emissions factor of zero tonnes

of CO2-e per GJ and the fugitive emissions from the wastewater treatment plant are also

zero. If the biogas capture and energy recovery were not undertaken, emissions would

be considerably higher, since more natural gas would need to be purchased to meet

energy needs, and methane would be released from the wastewater treatment plant.

These avoided emissions result in the products from the plant having lower emissions

intensities than they would otherwise.

Fuel use switching

Natural gas

The proposed plant will mainly use natural gas as the primary fuel source. Natural gas

produces much lower greenhouse emissions than the amount of coal of equivalent

energy. Using natural gas in the proposed plant instead of coal saves approximately

187,680 t CO2-e/a.

Coal

Following the plant expansion, 109 kt of coal will be used at Bomaderry (gross). Coal is

a very emissions intensive fuel, and its use will create approximately 274,000 t CO2-e, or

34% of all gross emissions. If the existing coal-fired boiler was replaced with a natural

gas fired boiler, emissions could be reduced by around 81,000 t CO2-e (a reduction of

30% compared to the coal emissions, and 10% of the total gross emissions).

Replacement of the coal-fired boiler has not been included in the current budget for the

proposed plant.

Diesel

Shoalhaven Starches uses 660 kL of diesel fuel annually, and this volume will not

change following the upgrade. This results in annual emissions of approximately 1,910 t

CO2-e. By switching to a biodiesel blend, emissions could be reduced. A 10% biodiesel

(canola) blend would result in total emissions of 1,880 t CO2-e, a reduction of 30 t CO2-

e annually, or 0.004% of gross emissions. Any changes would be insignificant.

Indirect Greenhouse Gas Minimisation

Indirect greenhouse gas emissions (ie. those generated off site as a result of ethanol

production, such as electricity use) can be minimised at the Shoalhaven Starches site

by:

• purchase of renewable energy (GreenPower); and




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• using alternative feedstock.

Purchasing 100% GreenPower

Shoalhaven Starches current electricity consumption is 130 GWh. Following the

upgrade, Shoalhaven Starches will reduce electricity consumption to 14 GWh purchased

from the grid. 14 GWh accounts for 14,840 t CO2-e, or 1.8% of total gross emissions.

Purchasing 100% accredited renewable energy, such as GreenPower would remove

these emissions from the inventory.

GreenPower is, however, considerably more expensive than standard grid electricity,

and is considerably more expensive than purchasing external greenhouse emissions

offsets:

• GreenPower costs approximately an additional 5 cents per kWh, which equates to

an abatement cost of $47/ t CO2-e for NSW electricity; and

• There are a number of external greenhouse gas emissions offsets available on the

market, which range in price from less than $10/ t CO2-e to more than $30/ t CO2-e.

An average cost is approximately $15/t CO2-e.

Following the proposed upgrade, switching to 100% GreenPower would cost an

estimated $0.7 million annually for the entire site (plant, farm and wastewater treatment

plant). Offsetting electricity emissions through the purchase of offsets would cost an

estimated $0.2 million annually (based on an assumed cost of $15/t CO2-e).

While the purchase of external offsets can be counted against emissions from any

source, the use of GreenPower is limited to emissions associated with the use of

electricity only. The cost to purchase GreenPower has not been included in the current

budget for the proposed plant.

Alternative feedstock

Out of the top ten emission sources, five are due to embodied energy in raw materials

(flour, grain, millfeed, lime and sugar), which account for 32% of net positive emissions.

Other possible grain-based feedstocks will have similar order of magnitude emissions.

The only feasible way to significantly reduce raw material emissions is by replacing grain

and other premium agricultural products with waste products, which have much lower

greenhouse intensities. It is highly unlikely that there would be sufficient agricultural

waste products available to manufacture 3 ML of ethanol. Importing waste products to

Bomaderry would also increase transportation emissions, since they would need to be




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sourced more widely that the proposed raw materials, and since they are less effective,

a greater quantity would be required. It is not feasible to switch process feedstocks.

Offset Residual Emissions

Opportunities to offset residual greenhouse gas emissions include the following:

Greenhouse offsets purchase

Net greenhouse emissions amount to 230,016 t CO2-e/a. These emissions could be

offset by purchasing greenhouse offsets or credits. There are a number of offset/credit

providers in the current marketplace, with an average offset cost of around $15/t CO2-e.

Costs to offset 100% net emissions amount to approximately $3.5 million annually. (The

cost to offset 100% emissions by purchasing external offsets is currently significantly

lower than purchasing GreenPower which would cost $0.7 million to offset only 2% of

emissions.) The cost to purchase offsets has not been included in the current budget for

the proposed plant.

Plantation sinks

Another alternative is for Shoalhaven Starches to establish a tree plantation to offset

emissions at a nearby or remote location. Approximately four trees per year are required

to offset one tonne of CO2-e, so a one million tree plantation (over 1,000 hectares)

would be required to offset the net emissions from the proposed plant per year. This

option is not really feasible for Shoalhaven Starches as it is outside of core business and

would be more cost effective to purchase offsets from existing plantation providers that

are accredited under the DCC Greenhouse Friendly program or NSW Greenhouse Gas

Reduction Scheme.

Approximately 4,000 trees have been planted on the environmental farm, and an

additional 4,000 are planned, however, the order of magnitude of these plantings is far

too small to have a significant impact on Shoalhaven Starches’ net emissions.

7.3 WASTEWATER TREATMENT

7.3.1 Existing Wastewater Treatment Processes

Since the 1980s and before cessation of effluent discharges to the river, Shoalhaven

Starches has sought to value-add to their list of products from the residuals that result

from the primary process. The plant is a food production facility with raw material inputs

of water and flour. These are mixed and after a separation process, starch (as slurry or

dried) and gluten are extracted as products. Glucose syrup, brewers’ syrup and




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maltodextrins also made from starch. The Environmental Farm (EF) was established for

the beneficial re-use of effluent through land application.

Since 1995, ethanol has been recovered as a waste product from the starch, gluten and

syrups components of the plant and after distillation several grades for fuel, industry and

beverage applications are produced. All the starch is consumed from the liquid effluent

stream. By 2001 the by-products from the fermentation process have also been

captured for beneficial use. Carbon dioxide (CO2) is harvested by BOC Gases and, after

screening the liquid effluent, Shoalhaven Starches recovers the suspended solids

principally fibre, protein and yeast and produces DDG (dried distillers grain) as a stock

food. The remainder of the effluent stream is irrigated onto the EF.

Since 2004 a new evaporation process, stillage recovery, approved by the Minister for

Planning in 2003, was introduced as a further addition to the Pollution Reduction

Program (PRP7) NSW EPA License 883. Through evaporation dissolved substances in

the clarified effluent are concentrated to a thick syrup, very high in BOD, comprising

mainly lactic and acetic acids, yeast protein and minor adjuncts from fermentation. This

syrup is added to the recovered suspended solids and dried to yield Distillers Dried

Grains Syrups (DDGS) which are used as stock feed. As a by-product from evaporation,

a condensate is recovered which is more than 99% water although containing residual,

steam-volatilised organic substances including low levels of fatty and odorous materials.

Nevertheless, the condensate has considerable advantages for both retention, if

necessary, and for irrigation.

The importance of an efficient waste management system can not be emphasised

enough for a food manufacturer. Appropriate handling, processing and storage of

materials are included in the Good Manufacturing Practices (GMP) as part of the Food

Safety Policy that The Manildra Group of Companies maintains. Audits from internal,

external, national and international companies, Industry Institutes and authorities are

regular and essential to ensure product safety. Hazard Analysis and Critical Control

Point (HACCP) based Food Safety Management systems are implemented, as are

cleaner production principles.

As part of Shoalhaven Starches commitment to cleaner production the company has a

record of one of the most efficient water users for this type of industry in the world. For

every tonne of flour Shoalhaven Starches uses 3 tonne of water whereas similar

industries worldwide use as much as three times this amount. All production managers

and staff are active in identifying water savings to reduce the environmental load, cost

and minimise effluent to the farm through improved water management.




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Despite significant expenditure committed over the past 25 years or so which

progressively has resulted in significant reduction in pollutants in the effluent, effluent

volume and residual pollutants remain a limitation to further expansion of the

Shoalhaven Starches operation. Presently, total volume of effluent is approximately

4.6 ML per day comprising about 3 ML per day of condensate with reduced organic load

plus 1 ML per day of “washdown” water that includes effluent contributions from several

processes and contains a higher level of organic substances. When favourable climate

and soil conditions allow, the combined total effluent is irrigated (after addition of lime to

achieve the required pH). If irrigation is not immediately possible then the condensate

and washdown streams are stored separately. The washdown water is acidified with

sulphuric acid and stored in a covered pond to prevent odour release until such time as it

can be irrigated.

In order to further expand the ethanol production operations, it proposed to install a full

waste water treatment plant that will minimise organic waste, eliminate odour, allow

water and biogas generation to be reused within the factory.

7.3.2 Wastewater Treatment and Fitness for Purpose of Treated Effluent.

The WWTP Proposed to be Installed

It is proposed to install a full biological wastewater treatment plant to minimise the

amount of bio-degradable organic substances in the combined effluent (“condensate”

and “washdown” streams) from the Shoalhaven Starches plant. Full biological

wastewater treatment will be implemented prior to the commencement of operation of

the upgrade to the ethanol production process. After biological treatment a further two

tiers of physical filtration processes will be installed to enable treated water to be utilised

for particular re-use applications.

Extensive data obtained over years of analysis of effluent sampling and volume

recording of various effluent streams has enabled a Shoalhaven Starches to determine

the average Chemical Oxygen Demand (COD) and Biological Oxygen Demand (BOD)

for the combined effluent from the plant which will represent the in-feed to the WWTP.

Maximum and minimum levels have also been determined to provide assurance that

WWTP design will more than meet the average and peak demands on the system.

Detailed modelling and projections of increased water usage and increased effluent

volume generation with increasing production have been made by Shoalhaven Starches

to ensure that the proposed waste water treatment plant will have more than adequate

capacity to meet the maximum demand at the fully expanded status.




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Projections made on the basis of proposed increase in flour throughput and data

accumulated by Shoalhaven Starches from designated sampling points according to the

Company’s EPL indicate that up to 8.10 ML / day of effluent may in-flow to the proposed

WWTP containing current key pollutant concentrations at an average COD of 8000ppm,

average BOD of 2800ppm, Total Suspended Solids (TSS) of 2700ppm, Total Nitrogen of

44 ppm and Total Phosphorus of 20 ppm. The combined effluent will reach the WWTP

with a pH in the range 3.0 – 3.5.

Magnesium hydroxide will be dosed into the effluent to neutralise the acidity with an

estimated requirement of about 980 kg/day and temporarily stored in a 3 ML capacity

buffer tank to allow provision of a uniform feed to anaerobic digestion.

To best absorb the range of volume flow and organic load a Bulk Volume Fermenter

(BVF) type reactor is proposed with a capacity of 90 ML (providing an average residence

time of about 11 days). This facility together with the subsequent aerobic pond will be

supplied by ADI Systems Inc., Canada. The COD and BOD of the out-flow from the BVF

are projected to be reduced to 800 and 280 ppm, and the TSS to 270 ppm respectively.

The BVF will be a completely enclosed lagoon having a floating insulated cover secured

at the perimeter thereby preventing the emanation of odours. This will greatly ameliorate

the odour emission from the effluent on the Farm in accordance with recommendations

of the GHD “Audit Report”.

Plate 12 shows an example of the type of cover that will be installed with this component

of the proposal.

Plate 12: Example of cover over BVF




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Anaerobic digestion of the organic substances contained in the in-feed to the BVF will

generate 30,000 m3/day of biogas containing 65% methane. This will be drawn off the

lagoon under mild negative pressure and piped to the Shoalhaven Starches plant for

direct usage as fuel, partially replacing natural gas for the provision of steam.

It is proposed that out-flow from the BVF will be directed to one of two aerobic treatment

processes having regard to the quantities of water required to be treated and to the

subsequent purpose. Deodorisation and further reduction of BOD will be achieved by

aeration followed by prolonged holding in a large volume Sulphide Oxidation (SO) basin

having 103 ML capacity and an average holding time of 40 days. Out-flow from the SO

basin is predicted to be reduced to about 70 ppm BOD and 240 ppm COD, and TSS of

190 ppm. The suitability of this effluent for irrigation on the Environmental Farm is

discussed further in Section 7.4 of this EA.

Figure 18 is a flow diagram depicting the proposed BVF/SO Basin system.

Plate 13 Is an aerial photograph taken over the pond complex located upon the

Shoalhaven Starches Environmental Farm. The pond shown under construction in this

photograph is the pond associated with this proposal.

Plate 13: Aerial photograph over pond complex.

For re-use in the Shoalhaven Starches production plant, water must be treated to reduce

COD and BOD. A more effective method (of aerobic digestion of COD and BOD

together with separation of Suspended Solids is proposed by the installation and

operation of a Membrane Bio-Reactor (MBR). In this smaller tank configuration of only

about 4 ML, effluent from the BVF will be vigorously aerated for a shorter time to




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extensively reduce the COD and BOD further reducing the potential for odorous

emissions. When sufficiently reduced, treated water will be filtered through

microfiltration membranes under very low driving pressure, so the membranes become

only minimally fouled and can be effectively cleaned by regular, intermittent back-flush.

Figure 19 is a flow diagram depicting the proposed MBR/RO system.

Plate 14 provides a photograph of an example of MBR/RO plant while Figure 20

provides a diagrammatic view of such a plant.

Plate 14: Example of an MBR/RO plant.

Systems using both flat-sheet and hollow-fibre membrane configurations have been

considered. The more modern and innovative hollow fibre configuration offered by Tenix

Alliance are proposed to be used due to lower power requirements and ease of

maintenance. There is also industry acceptance of this approach with several major

installations operating successfully in Australia. Having the hollow fibres configured in

bundles with central air release and bubble abrasion to keep the membrane surface

clear provides greater efficiency and less power as the air only needs to operate 25% of

time.



Page 144

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Treated water discharged from the proposed MBR is estimated by Tenix (based upon

having the performance of a similar installation at Joe White Maltings, Perth), to result in

levels of COD and BOD of 80 and 14 ppm respectively. The Total Suspended Solids

(TSS) is estimated at 3 ppm and the Total Dissolved Solids (TDS) at 1106 ppm. The

TDS represents the sum of all ions. A significant level of magnesium will result from the

magnesium hydroxide neutralisation of the feed to the BVF but most particularly a high

level of bicarbonate ion is predicted to occur due to the neutral to alkaline conditions of

the BVF and the large quantity of carbon dioxide being generated in the anaerobic

digestion process. The quality of this water is suited to re-use in the plant for several

non-food applications including washdown, vapour scrubbing and cooling tower

evaporation.

To enable the re-use of the treated water in food operations, water must be potable

standard as defined by the NHMRC Drinking Water Guidelines 2004 in terms of both

chemical and microbiological content of the treated waste water. The approach

proposed is in accordance with the recommendations of the Australian Guidelines for

Water Recycling: Managing Health and Environmental Risks (Phase 2) Draft 2007 with

the provision of Multiple Barriers considered to be the foundation for ensuring safe

drinking water. The proposed process provides microfiltration, reverse osmosis and

chemical sanitation as three sequential barriers to microbial contamination of treated

water for in-plant re-use.

To achieve the required water quality it is proposed that the MBR out-flow (microfiltration

membrane permeate) will be polished through a Reverse Osmosis (RO) membrane

system that will allow the chemical and microbiological standards to be achieved.

A modern design from Koch-Puron using Mega-magnum large diameter spiral-wound

modules supplied through Tenix Alliance is proposed. Due to the large membrane area

accommodated in each of the 18 inch diameter modules, the amount of pipework will be

reduced and simplified, the footprint will be reduced, cleaning costs and chemicals will

be reduced and energy requirements will be reduced. Furthermore it has been

determined that by using “loose RO” membranes the treated water will contain zero BOD

but a low level of dissolved salts conforming with the Guidelines and appropriate to the

food application process in the plant. This facility has an advantage of being able to

operate at only 5 – 10 bar compared to 30 - 40 bar typically required for normal RO. The

consequences will be reduced energy requirements, less noise from the medium-

pressure pumps and more cost effective, lighter pipe construction. The RO plant will be

sized to enable supply of all of the water required for processing flour to starch, gluten

and other products.




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RO membranes do not allow passage of micro-organisms through the membranes,

therefore water permeating the membranes will be sterile. It is proposed however that

some short term storage of the purified water will be necessary as a buffer to production

processes, introducing a low level of risk of microbiological contamination in the stored

water. To minimise this risk a chlorine or chlorine dioxide-based sanitation system will

be provided to ensure that the microbiological standards of the Drinking Water

Guidelines are met. E.coli (thermo tolerant coliforms) are used as indicators of faecal

contamination and hence the safety of water for drinking. Routine microbiological testing

of the treated water will be undertaken to ensure that the required standard of absence

of E.coli in 100mL sample of water is continuously achieved.

RO membranes allow only water and the smallest of organic chemical molecules such

as ethanol to permeate the membrane. It is proposed however to use more energy

efficient, “loose RO” membranes that will allow the permeation of a small proportion of

some ionic species. The Drinking Water Guidelines are particularly concerned with

contamination by toxic organic substances such as pesticides and inorganic substances

such as heavy metals that may have a long term toxic effect. The only possible source

of such pesticides in the industrial waste water from the plant would be through the

wheat flour supplied to Shoalhaven Starches. The presence of pesticide residues is

routinely tested at the flour mills. The proposed RO membranes will provide a further

effective barrier to ensure contamination of the treated water by organic residues does

not occur.

Analysis of effluent to the Environmental Farm has shown that levels of potentially toxic

metals are all below the limits for potable water in the Drinking Water. Projecting that

these concentrations of dissolved substances pass through the BVF and MBR systems

to reach the RO membrane system, and with ionic rejections specified by the supplier to

be in excess of 75%, then the levels of potentially toxic metal ions in the RO permeate

will be substantially below the limits specified in the Drinking Water Guidelines.

It is possible that a very low level of odour and/or flavour may be detectable in the

treated water permeating the RO membranes (as experienced in the Joe White Maltings,

Perth, waste water treatment plant) although the feedstock to their MBR is significantly

different. In RO trials of evaporator condensate without prior anaerobic digestion

conducted at Shoalhaven Starches, a very low residual odour / flavour level was

effectively treated with activated carbon treatment configured in cartridge format to

eliminate any carbon leakage. Activated carbon treatment will be installed for elimination




Page 149

of odour and flavour in the treated water proposed for re-use in combination with food

materials.

Prevention of Pollution of Waters

The proposed WWTP will accept and process the total effluent from the Shoalhaven

Starches plant predicted to be on average 8.1 ML per day and with capacity to

accommodate predicted daily fluctuations.

The WWTP will operate in conjunction with the existing storage ponds providing an

additional 196 ML of capacity in the buffer tank, BVF and SO basin.

Routine operation of the Farm requires a minimum application of irrigation water. This

will be obtained primarily and directly with treated water from the SO basin and secondly

from the retentate from the RO plant. The total treated waste water available to the

Environmental Farm is predicted to be 3.6 ML/ day.

The WWTP will reduce the level of organics in all the primarily-treated waste water, and

through secondary processing, enabling the re-use in plant of at least 55% of the effluent

water. The suitability of this effluent for irrigation on the Environmental Farm and

compliance with Section 120 of POEO Act 1997 has been considered and provided in

Section 7.4 of this EA.

Shoalhaven Starches predict the WWTP operating in conjunction with the storage ponds

will enable the Shoalhaven Starches plant to operate at the proposed expanded rate.

Wastewater Treatment Options

Shoalhaven Starches has carried out an extensive assessment of wastewater treatment

options.

Extensive trials with MF and RO membrane systems identified options for re-processing

and re-use of the large volume of evaporator condensate with low level organic load.

Limitations encountered due to very low levels of fat and the difficulty in stripping this

pointed to the necessity to fully digest the total organic load by anaerobic and aerobic

processes.

Anaerobic systems have been investigated including extensive discussions with

potential suppliers and inspection of relevant installations. This included consideration

of “high-rate” systems using relatively low volumes under digestion with intense digestion

facility and “low-rate” systems having larger volumes with less intense digestion. The

latter was selected for its ability to more readily absorb significant fluctuations in both




Page 150

volume feed rate and organic load. Furthermore running costs will be lower and the

likelihood of odour emission will also be lower.

Aerobic systems were also investigated in conjunction with projected re-use options both

in-plant and on-farm. Given the large volume of treated effluent to be produced from the

BVF anaerobic digester requiring further aerobic treatment and in particular the high

energy cost associated with intense aeration, a two-tier system has been selected which

will allow a proportion of the BVF output to be treated more economically to a quality

suitable for irrigation purposes through a Sulphide Oxidation basin and a larger

proportion to be treated through a Membrane Bio-Reactor to achieve reduction in

organic load to a level suitable for some in-plant applications. As an alternative to use of

an MBR, microfiltration (MF) membrane systems were also considered. MF would have

effectively removed all suspended solids from the SO basin output but would not have

resulted in further digestion of residual BOD and may have been more expensive to run

and maintain due to more dynamic filtration and the need for more frequent cleaning.

To re-use the treated water for direct food processing operations, Drinking Water

standards need to be achieved. Reverse Osmosis systems are widely used in water

treatment for polishing pre-treated water to achieve potable quality. Although RO

systems are now essentially standard operating facilities, there are still developments in

technology being made to achieve greater efficiency and reduced cost. RO systems

from several suppliers were considered. Furthermore, RO membranes are available

with degrees of “tightness” that determines the effective rejection of dissolved

substances. For the food application required in Shoalhaven Starches plant a low level

of salt in the water is acceptable and may even be advantageous. The proposed system

combines the latest in RO technology development, namely the use of “mega-magnum”

large diameter modules for compactness and efficiency together with “loose RO”

membranes requiring lower pressure to operate and so saving on energy and reducing

noise emanation from pumps.

Issues Associated with the Retentate

Application of “loose” Reverse Osmosis to the polishing of the MBR output will result in

approximately 75% of the feed volume permeating the membrane and about 25% (or 1.5

ML/day) being rejected as membrane concentrate (or “retentate”). Because hydrated

ions of different species are of different size their rates of diffusion and the extents to

which they are rejected differ. With between 75 and 98% rejection of the various ions,

the concentration of each ion type in the concentrate is a consequence of the extent of

concentration multiplied by the extent of rejection; the ionic content of the concentrate is




Page 151

projected to be about 3970ppm, being the sum of all ion types. However, more than half

of ionic content is bicarbonate which is inherently unstable. One option is to use a small

amount of acid to neutralise the alkaline bicarbonate ion decomposing it leaving less

than 2000 ppm sum of ions principally those of sodium, magnesium, chloride and

phosphate.

Apart from the additional magnesium, the total concentration of ions in the combined

effluent are not predicted to change from the present, therefore, the total predicted ion

outflow to the farm will increase in proportion to the increase in flour throughput in the

Shoalhaven Starches plant plus the additional magnesium.

Several options have been investigated with respect to the disposal of the retentate

including:

1. ocean release;

2. evaporation;

3. disposal to Council’s sewerage system;

4. river release;

5. irrigation on to Environmental Farm.

The following is a summary of the findings of these investigations.

1. Ocean Release

Two ocean release options have been tentatively considered.

The first involves the provision of a pipeline from the plant to Shoalhaven Heads and the

direct disposal of the retentate to the ocean through a new ocean outfall.

The initial difficulty with this option is the availability of suitable land to construct a

pipeline through to the ocean. Much of Seven Mile Beach for instance adjoins National

Park. It would be unlikely that a commercial entity would be able to obtain the necessary

approvals to construct a pipeline through National Park, notwithstanding the

environmental implications for laying pipework through National Park.

Other options are limited by Crown Land ownership; and subject to Aboriginal land

claims.

In addition, pipeline routes may need to traverse environmentally sensitive lands

including coastal wetlands; coastal dunal areas; or National Park. All options which were

considered inappropriate.




Page 152

This option would also necessitate a pipeline with a length of at least 13 – 15 kilometres;

which would also involve a prohibitively costly construction.

An alternative to creating a new ocean outfall at Shoalhaven Heads is to utilise the

existing sewerage ocean outfall at Culburra Beach. The existing outfall at Culburra has

had its role reduced since the implementation of the Shoalhaven Northern Regional

Effluent Management Scheme. This sewerage management scheme introduced the

land application of treated effluent; that had previously been disposed through this ocean

outfall.

As with the Shoalhaven Heads option described above, the major constraint for

disposing the retentate to this outfall would be the need to construct a pipeline system

that would connect into this outfall. It is estimated this would involve a pipeline with a

distance of approximately 25 kilometres – which would be prohibitively expensive.

2. Evaporation

Another option considered involves evaporating the retentate to extract the salts within

the retentate as solids. It is envisaged that evaporation would require three separate

processes to be undertaken:

1. The retentate stream would need to be concentrated into a liquor containing 20%

TDS. The evaporation required to achieve this rate would be 60 tph.

The capital investment necessary to achieve this rate of evaporation would be

$8 million; and would involve power consumption of 2000 kw. Significant

quantities of sulphuric acid would also be required to break down bicarbonate

levels.

2. The second step in the process is to further concentrate the above brine to

produce a slurry of salts, to about 25% solid.

This second phase would involve a further capital investment of $2.2 million and

consume 100 kw in power.

3. The third phase in the process would involve filtering the above slurry to produce a

‘cake’. Typically these salt cakes would contain 40% occluded brine. The cake

would be disposed to landfill. The capital investment to undertake this third system

is estimated to be $0.7 million and involve 22 kw of power consumption.

It is evident from the above that evaporation presents several disadvantages:

• The capital investment necessary to implement such a process is estimated to be

over $10 million.




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• In order to evaporate the retentate into a ‘cake’ product would require considerable

power consumption (and associated generation of greenhouse gas emissions).

• At the end of the process the ‘cake’ is required to be disposed to landfill. This is

estimated to create 24,000 tonnes of solids per annum. The trucking cost alone

($250/tonne) is estimated to cost $6 million per year. Furthermore this rate of waste

would take up valuable landfill space.

3. Disposal to Council’s Sewer

Extensive consultation has been undertaken between Shoalhaven Starches’

representatives and Shoalhaven City Council with the view of exploring the disposal of

the retentate directly into Council’s sewerage system.

According to Shoalhaven City Council the main difficulty associated with the retentate is

the elevated levels of TDS (3456) associated with the retentate. These levels exceed

the limits imposed by the proposed extension of the Northern Regional Effluent

Management Scheme to which it is intended to extend to the Bomaderry STP. Council

is therefore unable to accept the retentate into its sewerage management system.

4. River Release

Shoalhaven Starches have also investigated the possibility of diluting the retentate and

disposing it directly into the Shoalhaven River. In carrying out this investigation

Shoalhaven Starches engaged the CSIRO to undertake a toxicity assessment of the

retentate on estuarine biota. This assessment concluded:

“The retentate was not acutely toxic to bacteria, amphipods or fish. The retentate was of low toxicity in the two chronic tests, oyster larval development and microalgal growth inhibition.

It is possible that the toxicity observed in both chronic tests may be due to metals (copper and zinc) were present in the retentate at concentrations high enough to cause toxicity to both test species. Toxicity would depend on the metals being present in forms that are bioavailable to the test organisms.

The estimated ‘safe’ dilution of retentate required to protect 95% of the species at the edge of the mixing zone in the Shoalhaven River (with 50% confidence) is 1:13. Thus the initial retentate dilution of 1:30 proposed by Manildra prior to river discharge, should be more than sufficient to achieve the “safe” dilution estimated in this study.”

Notwithstanding the findings of this assessment that a ‘safe’ dilution could be achieved;

the DECC in consultation with Shoalhaven Starches have consistently expressed

reservations with respect to permitting river release of the retentate. Under these

circumstances this option will not be further explored at this time.




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5. Irrigation to the Environmental Farm

Given the shortcomings associated with the above options the final option that has been

investigated with respect to disposal of the retentate is that of land application to the

Environmental Farm; in conjunction with the treated waste waters not re-used in the

factory process. This option is further explored in Section 7.4 of the EA.

7.4 EFFLUENT IRRIGATION AND STORAGE

This section of the EAR is based upon a joint report prepared on behalf of Shoalhaven

Starches by Dr John Murtagh (Agricultural Water Management), Mr Roy Lawrie (NSW

Department of Primary Industries) and Glenys Lugg (Shoalhaven Starches Pty Ltd).

A copy of this report forms Annexure O(i) to this EA. This report was prepared in

response to the requirements of the DECC which required:

• A full water balance that demonstrates a capacity of the project to avoid water pollution.

• A full irrigation management plan for the Environmental Farm, demonstrating the agronomic capacity of the land, soil, crop and climate combination to sustainably assimilate the effluent.

• Demonstrate that there is sufficient storage to prevent pollution of waters when prolonged wet weather prevents irrigation.

7.4.1 Local Environment

The monthly rainfall and evapotranspiration at Nowra are summarised in Table 16, and

were based on records from the Bureau of Meteorology. The rainfall records covered 68

years from 1940 - 2007 and included a variety of wet and dry years. The pan

evaporation records were converted to potential rates of evapotranspiration from a mixed

summer-grass/ryegrass pasture by multiplying by appropriate pan and crop coefficients.

Table 16

Mean Monthly Rainfall and Potential Evapotranspiration

Month J F M A M J J A S O N D Yr

Rain (mm/mth) 90 122 106 96 95 116 55 67 62 90 84 75 1057

Evapotranspiration pasture (mm/mth)

126 103 95 46 69 56 57 70 100 135 136 130 1123

The annual rainfall distribution varied as follows:

Driest 1/10 – dry Median 1/10 – wet Wettest

515 mm 603 mm 977 mm 1634 mm 2248 mm




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Points of note are:

• The area receives a moderate rainfall that averages 1057 mm/yr;

• Mean rainfall is less than potential evapotranspiration from July-January. Hence,

these are the months when irrigation will be most needed, but variation in rainfall

can also create an irrigation demand in any month;

• The depressed evapotranspiration in April allows for the effect of renovation before

over sowing with ryegrass.

The pasture evapotranspiration was based on a mixed summer-grass/ryegrass pasture

and the higher water use of the ryegrass meant that the seasonal trend also reflected

the changing species composition between the warmer and cooler months.

7.4.2 Wastewater

Three general classes of wastewater have been / will be used for irrigation on the

environmental farm:

• Wastewater from the starch production process before June 2004. This flow was

heavily limed as part of the odour-control process. The wastewater during this

period is termed the pre-dryer wastewater.

• From June 2004, some of the wastewater flow was processed through a DDG dryer

to remove solids. It dramatically reduced the COD concentration and less lime was

added to the wastewater. This gave the post-dryer wastewater.

• The on-site treatment and reuse of some of the wastewater flow, as part of the

current ethanol production upgrade proposal, will cause another marked change in

composition of the wastewater. In addition, the composition of the irrigation water

will depend on the blending of the waste flow from the sulphur oxidation (SO) pond

and a proportion of retentate from the RO plant.

With the implementation of the ethanol upgrade, wastewater flows that will be used for

irrigation will come from two sources:

• Some of the discharges from the sulphur oxidation (SO) basin, amounting to an

average of 2.1 ML/d. A second discharge stream from the SO basin will direct

discharges to a proposed wastewater treatment plant.

• The wastewater treatment plant will produce a clean water flow and a retentate flow

that will contain most the water contaminants from the inflow. The retentate flow will

average 1.5 ML/d and may be used for irrigation.




Page 156

The study prepared by Murtagh, Lawrie & Lugg considered three options where none,

half or all of the retentate was used for irrigation. Thus the total flow to the farm equalled

2.1, 2.85 or 3.6 ML/d.

Chemical Composition of Wastewater

Details of the chemical composition are given in Tables 17 and 18. The composition

during the pre-dryer and post-dryer stages was provided by Shoalhaven Starches,

except that the calcium concentration was increased to allow for the calcium hydroxide

that was added as a neutralising agent to the acidified wastewater.

The pre-dryer wastewater had a very high nitrogen concentration, much of which was in

organic forms. Hence the nitrate concentration was less than might be expected on first

glance.

The suggested composition after the upgrade was also provided by Shoalhaven

Starches. It is emphasised that the post-upgrade composition is a tentative estimate. It

was based on experiences in other plants and may not translate directly to the proposed

upgraded plant.

Two measures were used to quantify the total concentration of soluble components in

the wastewater:

TDS: Total dissolved solids; the combined content of all soluble (pass through a 2 µm

sieve) inorganic and organic substances. In the following, the TDS was

estimated by summing the concentrations of the various ions. This approach will

introduce a slight underestimate of the total concentration when minor

components are not included.

EC: Electrical conductivity; a measure of the conductivity of a solution that is related

to the TDS. Note that the relation between the two depends on the ionic

composition. The EC is often used because of the ease of measurement, and as

discussed later it provides the standard expression of soil salinity when

considering the effect on plant growth.




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Table 17

Some Chemical Constituents in Wastewater from Different Processes

Composition of wastewater from:

Analyte Unit Pre-dryer Post-dryer

Post-upgrade SO basin

Post-upgrade retentate

pH pH units ~9 9.1

TDS mg/L 4,802 2,090 1,323 4,399

Ca++ mg/L 2,469 1,042 8 24

Mg++ mg/L 97 17 122 470

Na+ mg/L 460 167 85 285

K+ mg/L 12 39

CO3-- - mg/L

HCO3- - mg/L 850 2,991

SO4- - mg/L 384 23 91

Cl- mg/L 800 230 105 392

NO3- mg/L 970 173 60 48

PO4+++ mg/L 6 77 60 59

Total N mg/L 35,000 39 41

Total P mg/L 200 25 112

Much of the magnesium in the post-upgrade wastewater will be introduced when

magnesium hydroxide is added to the buffer tank as a pH stabilising agent. Based on

experience elsewhere, some uncertainty surrounds the continuing need for the treatment

to continue at the suggested level and lower amounts may suffice once the system has

stabilised. Also, other alkaline agents (eg soda ash) could be used at this step. The

point to be made here is that there is scope to reduce the magnesium inputs should the

magnesium concentration in the soil prove to be a problem over time (see later

discussion).

The current investigation by Murtagh et al. considered three options, where nil, 50% or

100% of the retentate flow was mixed with the waste flow from the SO pond to provide

the irrigation water. The resulting net composition of the irrigation water is given in

Table 18.




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Table 18

The Net Chemical Composition of the Post-Upgrade Irrigation

Water, with Three Proportions of Retentate in Wastewater Blend

Proportion of retentate in wastewater blend

Item Unit Nil

retentate 50%

retentate 100%

retentate

Composition of wastewater blend

Total flow ML/d 2.1 2.85 3.6

TDS mg/L 1,325 2,134 2,606

TDS load * t/ha/yr 2.1 4.6 7.0

Ca++ mg/L 8 12 15

Mg++ mg/L 122 214 267

Na+ mg/L 85 138 168

K+ mg/L 12 19 23

HCO3- - mg/L 850 1413 1742

SO4- - mg/L 23 41 51

Cl- mg/L 105 181 225

NO3- mg/L 60 57 55

PO4+++ mg/L 60 60 60

* The TDS load was calculated for a total irrigation area of 487ha.

Points of note are:

• The high TDS concentration that increased from 1,325 mg/L with no retentate in

irrigation water to 2,606 mg/L with all the retentate in irrigation water;

• The substantial reduction in the calcium concentration relative to the current and

past wastewater;

• The increase in the magnesium concentration from 18 mg/L in the post-dryer

(current) phase to 85-168 mg/L depending on the wastewater blend;

• The large amount of bicarbonate in the future wastewater;

• The marked reduction in sulphate.

The consequences of using irrigation water with these compositions on the sustainability

of the soil and plant growth are discussed in the next section.




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7.4.3 Soil Salinity

The main issue with soil salinity is the addition of solutes to the soil solution that can

harm plants through their osmotic effect on water and nutrient uptake. In this context,

the identification of the various solutes is important because of their varying ionic

strengths and behaviour in the soil solution.

Past and Present Soil Salinity

The soils on the environmental farm were monitored over many years and the results

include measurements of soil salinity down the soil profile. The 1995-2006 results are

tabulated in the annual “Environmental Monitoring Reports” prepared by the NSW

Department of Primary Industries. The 2007 results were obtained directly from Roy

Lawrie.

The profile measurements were given as the EC in a 1:5 soil:water mixture and were

transformed as follows for purposes of the current investigation:

• The various EC measurements from various depths within the upper 50 cm of the

soil profile were used to obtain a root-density weighted mean EC (ECw). In doing so,

the 5 measured values over the 50 cm range were weighted with a weight of five in

the uppermost sample (10 cm) ranging to a weight of one at 50 cm, which was the

lowermost sample that was used. This was done to obtain the effective EC over the

major rooting zone, with the greatest weight applying to depths where roots were

most dense.

• This gave the ECw values in Table 19. Since different paddocks were sampled in

each year and some had consistently lower EC concentrations than others,

paddock-weighted ECw’s were calculated for each paddock (Table 20 and

Figure 21). The weight was the overall mean ECw divided by the mean for that

paddock. It was done to counteract the effect of paddock differences on annual

means given the intermittent sampling.

Note that the paddock weighting was done to obtain better estimates of annual means,

and only the annual means should be used for direct interpretation.




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Table 19

The Root-Density Weighted EC Concentrations (ECw)

in Various Paddocks in Years when Samples were Taken

Paddock

21 Levee

38 Backslope

39 Swamp

110 P1

130 P3

140 Soper

Annual mean

ECw (dS/m)

1995 0.90 0.64 0.68 0.74

1996 1.19 1.19

1997

1998 1.19 1.19

1999 0.14 0.70 0.65 1.43 1.08 0.80

2000 0.87 1.32 1.10

2001 0.55 0.95 0.75

2002 0.94 1.18 1.06

2003 1.17 2.23 1.70

2004 0.70 2.04 1.37

2005 0.90 1.16 1.03

2006 0.42 1.73 1.07

2007 0.28 1.24 0.76

Paddock mean

0.42 0.86 1.18 0.75 1.48 1.33 1.00

Paddock 21 had the lowest ECw while paddocks 130 and 140 had the highest. Many

factors could contribute to these differences including differences in soil hydraulic

properties, elevation, watertable influence and irrigation volumes. Given that the main

emphasis of the current investigation was to examine the annual change in EC with the

changing quality of the wastewater to estimate future trends, it was beyond the scope of

the investigation to delve into these issues. Also a commentary on the soil EC

measurements is provided in the annual monitoring reports.




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Table 20

The Root-Density Weighted and Paddock Weighted Mean EC Concentrations in Various Paddocks, and Annual Means

Paddock

21 Levee

38 Backslope

39 Swamp

110 P1

130 P3

140 Soper

Annual mean

ECw (dS/m)

1995 1.05 0.85 0.46 0.79

1996 1.01 1.01

1997

1998 1.01 1.01

1999 0.34 0.82 0.87 0.97 0.82 0.76

2000 1.17 0.90 1.03

2001 1.33 0.72 1.02

2002 1.09 1.00 1.05

2003 1.57 1.51 1.54

2004 1.68 1.54 1.61

2005 1.05 0.99 1.02

2006 0.56 1.17 0.87

2007 0.67 0.93 0.80

* The paddock weight was the overall mean ECw (1.00 dS/m) divided by the mean ECw for each paddock given in Table 1.

YEAR

19951997

19992001

20032005

2007

EC

W

(dS

/m)

0.4

0.8

1.2

1.6

2.0

Pre-dryers Post- dryers

Figure 21: The Time Trend in the Root-Density Weighted EC Concentrations.




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The results show:

• High ECw values throughout the period.

• Markedly higher values in 2003-2004.

• An increase in the ECw from 1995 to 2003-2004 (pre-dryer phase), and a decline to

half the peak value three years later in 2007 (post-dryer phase).

• Some annual variation, with lower values in 1995 and 1999.

Before the introduction of the DDG dryers, there was a slow increase in the ECw until

2002, followed by a large increase during the next two years. It was not clear why the

sudden increase occurred. The dryers were introduced in November 2003 but their

impact on the quality of the irrigation water was delayed until much of the stored and

heavily-limed wastewater was used. Hence the 2004 results were placed in the pre-dryer

phase. Thereafter the ECw declined and was attributed to the considerable decline in

the wastewater TDS (Table 17).

One explanation for the high ECw in 2003-2004 is that the heavily limed wastewater

simply maintained the relatively high ECw until 2002 and that some separate effect

caused the subsequent added increase. One suggestion is that the separate effect

came from the addition of settled solids from the bottom of dams to the irrigation water

during these years. However the possible effect could not be verified by the chemical

testing and hence was not allowed for in the estimation of the TDS loads.

The various Environmental Monitoring Reports showed inconsistent patterns in the

change in soil salinity with depth, and suggested that the different patterns may be

related to soil type and elevation. One consistent result was that whenever the soil EC

in the uppermost sample (10cm) exceeded 2 dS/m the soil salinity always declined with

depth. This was taken to indicate that the highest soil EC’s were caused by recent salt

applications.

Factors Affecting Soil Salinity

This section describes attempts to relate the measured ECw values to various driving

factors (independent variables) in order to understand why the soil salinity varied

between years and in doing so obtain a relation that could be used to predict future

salinity after the upgrade.

Varying driving factors were investigated and some of the relationships that were tested

are graphed in Figure 22.




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PERCOLATION (mm/yr)

0 100 200 300

EC

W

(dS

/m)

0.4

0.8

1.2

1.6

2.0

IRRIGATION (ML/ha/yr)

2 3 4

A B

TDS LOAD (t/ha/yr)

0 5 10 15 20

C

2

1

Figure 22: The relation between the mean annual ECw between 1995 and 2007 and the corresponding annual percolation (A), irrigation volume (B),

and TDS load (C). The circles and triangles indicate years when pre-dryer and post-dryer wastewater was used respectively.

None of the relations properly explained the high ECw in 2003 and 2004, and as

discussed below arguments can be developed to either include or exclude these values

when developing a predictor relation.

The lack of a relation with percolation (Figure 22A) places the soil salinity in a different

class to the common situation where the salinity is dominated by the soluble and mobile

sodium and chloride ions. Under such conditions, and in contrast to the experience on

the Environmental Farm, the leaching of these ions causes a decline ECw when there is

high rainfall and a high rate of percolation. The message that was drawn from the result

was that the usual approach to examining soil salinity does not apply in this case.

Similarly the irrigation volume alone did not explain the variation in soil salinity, but the

combination of irrigation volume and TDS concentration (the TDS load) was more

successful. Especially note that the two high values were placed at the high end of the

range in TDS load in Figure 22C. Regression analysis was used to fit the two lines

shown in Figure 22C using the ECw as the dependent variable and the TDS load as the

independent variables. The two high values were included when estimating line 1, but

were excluded for line 2.

Two explanations can be advanced for the relation between the TDS load and ECw

(Figure 22C)




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• The high ECw values during 2003-04 were part of the general pattern of ECw during

the per-dryer phase, and hence line 1 in Figure 22C best illustrates the trend for

TDS load effects on ECw.

• The high ECw values are outliers that represent a separate but unexplained effect. If

so, line 2 best illustrates the TDS load effect.

Both explanations accept that the TDS loads during the pre-dryer and post-dryer phases

acted similarly on ECw even though their composition varied somewhat (Table 17). The

main compositional difference was the higher calcium concentration in the pre-dryer

wastewater. However, given the dominance of calcium ions in the soil by the time post-

dryer wastewater was used for irrigation, calcium related reactions in the soil and their

effect on the ECw would apply equally to both phases. Hence, a common relation

between the TDS load and ECw in both phases was accepted.

Given the lack of an explanation for the high ECw values in 2003-2004, line 1 which

included the high values, was taken as the basis for estimating future trends in ECw.

Note that this relation only applies to a situation with overall high ECw values.

Future Changes in Soil Salinity

The relation between TDS load and ECw that was derived above was used to estimate

the possible changes when post-upgrade wastewater was used for irrigation. It is

recognised that the following is a somewhat empirical analysis but past experience on

the Environmental Farm has shown that pasture production will continue under TDS

loads that would be unacceptable under other circumstances. The key to explaining the

Environmental Farm experience almost certainly lies with the chemical composition of

the wastewater and soil solution but the processes that could occur in the soil are only

partly understood. Hence a method was sought that built on the field experience over

past years.

The expected TDS concentration in the post-upgrade wastewater will be 1,325 – 2,606

mg/L depending on the proportion of retentate in irrigation water (Table 18). With the

expected irrigation volume, this will result in a TDS load of:

• 2.1 t/ha/yr with no retentate in irrigation water;

• 4.6 t/ha/yr with 50% retentate;

• 7.0 t/ha/yr with 100% retentate.

Fitting these loads to line 1 in Figure 2C gave expected ECw of:

• 0.72 dS/m with no retentate;




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• 0.81 dS/m with 50% retentate;

• 0.91 dS/m with 100% retentate.

In essence, the slope of line 1 in Figure 22C indicates that the effect of the annual load

of soluble salts on ECw was somewhat balanced by reactions within the soil that

removed salts from the soil solution when the ECw was at a high level. Hence the

potential effect of the high TDS load was markedly ameliorated. In this regard, the

precipitation of calcium compounds would be important, but there would also be some

absorption by plants, net adsorption to soil, and leaching. Under these circumstances,

since the post-upgrade TDS loads will be in the same general range or less, they should

not cause a deterioration in pasture productivity on the environmental farm, at least in

the short term while the chemical composition of the soil solution remained similar.

Relevant issues in this regard are:

• If no retentate was included in the irrigation water, the TDS load of 2.1 t/ha/yr would

be much less than past experience and could lead to a decline in soil salinity;

• Even with 100% retentate in the irrigation water the TDS load of 7 t/ha/yr will be less

than half the load during the pre-dryer phase;

• The calcium concentrations will be important;

• The post-upgrade irrigation water will contain a high proportion of bicarbonate ions.

Given the existing high calcium concentration in the soil, some of the bicarbonate

will precipitate out of the soil solution. Also, the conductivity factor of bicarbonate

ions is only 19-39% of the factors for the more common cations in soil. Both effects

will tend to reduce the ECw;

The expected effects of other ions including magnesium on plant nutrition and growth

are discussed elsewhere.

The above projections rely heavily on the presence of surplus calcium ions in the soil

solution to promote precipitation. In this regard, it will be very important that the soil

salinity and calcium concentrations be monitored on an ongoing basis to both test the

above projections and to indicate longer term trends in soil salinity.

Soil Salinity and Plant Growth

In order to estimate the effect of ECw on plant growth it is necessary to convert this value

that applies to a 1:5 soil:water mix to the equivalent in a more concentrated solution (soil

paste) that plants would experience in soil. The EC in a soil paste is abbreviated as

ECE. If the soil solution was dominated by the soluble sodium and chloride ions, a




Page 166

conversion factor of 10 (with a sandy clay loam soil) would be used but a smaller factor

applies with the expected composition where precipitation will be enhanced at higher

concentrations.

In the absence of information on the composition of the soil solution, conversion factors

of 4 and 6 were used in the following discussion. These roughly apply to soil solutions

where the concentration of all salts in proportion to just the chloride salts, as quantified

by the ratio of EC1:5 to the EC due to chlorides, is between 100 to one and 10 to one

respectively. The corresponding expected ECEs with conversion factors of 4 and 6 are:

• 3.2 – 4.8 dS/m current (2007);

• 2.9 – 4.3 dS/m with post-upgrade irrigation using no retentate;

• 3.2 – 4.9 dS/m with post-upgrade irrigation using 50% retentate;

• 3.6 – 5.5 dS/m with post-upgrade irrigation using 100% retentate.

The EPA Guidelines (2004) indicate that the productivity of ryegrass will not be affected

by an ECE up to 5.6 dS/m, and that it will decline by 10% at 6.9 dS/m. White clover,

which is less tolerant, will suffer about a 25-48% reduction in productivity with 100%

retentate, depending on which conversion factor is appropriate. Other publications

indicate that kikuyu will suffer just a 2-8% reduction in productivity.

Two points can be made about these conclusions:

• The projected effects fit field experience where grass pastures have remained

productive, but white clover has a limited presence;

• The current and projected ECEs are approaching the upper limit for good

productivity by pasture grasses.

Recent monitoring reports (Environmental Farm: 2005 and 2006 Environmental

Monitoring Reports by R Lawrie and S Eldridge) have noted that that soil aggregate

stability is satisfactory. There is a low risk that this situation will change with the post-

upgrade wastewater, but ongoing monitoring will be essential especially if 100%

retentate is used for irrigation, given the sodium and chloride concentrations in the

retentate.

The expected ECEs were based on the projected TDS concentrations, which are in the

high range, and an irrigation volume which averaged out at a relatively low 1.6-2.7

ML/ha/yr depending of the proportion of retentate that is used for irrigation. Should

either of these increase substantially, the pasture productivity could suffer from the

consequent increase in ECE.




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Recommendation

Murtagh, Lawrie and Lugg in this regard make the following recommendations:

“Based on just the salinity study, wastewater with 100% retentate could be used for irrigation on the environmental farm. This recommendation is made with the proviso that the study was forced to use empirical analyses based on past experience using wastewater of a different composition. If field experience shows an unacceptable increase in soil salinity or an adverse effect on pasture productivity the quantity of retentate may have to be modified.

Adverse changes will occur gradually and careful monitoring of the soil will provide an advance warning. Issues that will be important are the soil salinity and the ionic composition of the soil solution, especially calcium concentration. Better information on the detailed composition of the wastewater that is used for irrigation, and annual soil and pasture sampling of a few selected paddocks will also improve the predictive capabilities.”

7.4.4 Plant nutrition

This section of the EA examines the nutrient levels on the Environmental Farm,

considering both the past use of wastewater and the future use where the wastewater

will contain varying proportions of retentate.

Wastewater Characteristics

Table 21

Wastewater Characteristics Based on Two Sources of Information (Labelled 1 and 2 within the Table).

Option N P K S Ca Mg

1a 57 26 ? 31.2*32/96 19.5 30.4

2a 44 20 11 23*32/96 5 3

(+ 121.3)

1b 209 96 ? 38.2 71.6 111.6

2b 262 119 65.4 45.4 29.7 17.8

(+ 722)

3b 116 53 29 20 13 7.9

(+ 722)

a mg/l

b kg/ha per year and assumes irrigation area is 497 ha.

The various elemental loads in wastewater (Table 21) were calculated with three

alternative wastewater flow rates:

1 = “combined flow” of 5ML/day taken from fax from Shoalhaven Starches dated

11/2/08




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2 = “total effluent” flow of 8.1 ML/day

3 = total effluent for irrigation of 3.6 ML/day

Comments on Table

There is reasonable agreement between the option 1 and option 2 estimates for N, P, S.

However the Ca and Mg loads are less with option 2 relative to option 1, but this will

have little effect because:

• the soil is loaded with calcium, and

• the magnesium input is going to be much bigger.

Both options 1 and 2 gave higher loads than option 3.

The option 2 values were used for the following calculations, which included three

scenarios.

Scenario 1

The farm gets all of the retentate: (this calculation is based on 2b in the table).

Scenario 2

The farm gets half of the retentate: this will be calculated by subtracting 50% of the

retentate nutrients from 2b in the table.

Scenario 3

The farm gets none of the retentate: this will be calculated by subtracting all of the

retentate nutrients from the 2b figures.

Retentate Calculations – Volume and Loading Rates

1.5 ML/day over 497 ha = 1.1 ML/ha yearly

Table 22

Nutrients in the Waste Water

N P K S Ca Mg

1 mg/L 180*14/62 352*31/95 36 138*32/96 20 470

2 kg/ha/year 44.7 126 39.6 50.6 22 517

3 kg/ha/year 22.4 63 19.8 25.3 11 259

1 = from flow sheet 7/2/08

2 = annual loading (per ha)

3 = 50% of annual loading (per ha)




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Nutrient Uptake by Irrigated Ryegrass

Using the recent tissue analysis from Pivot 2 (Bay 5) (NSW DPI Report No.

R07-00615-F-V3), (note this is real data; not something from a textbook) and yield of

pasture harvested (ie 60-68 bales/ha, 500kg per bale, 50% moisture), then in one year

the pasture will take up the following amounts (kg/ha)

Table 23

Nutrient Uptake by Pasture (kg/ha/yr)

N P K S Ca Mg

497 71.4 662 36.5 84.8 25.7

Compare this with the 3 scenarios in Table 25 that provides the projected annual

nutrient balances.

Table 24

Nutrient Inputs (kg/ha/yr) for Scenarios 1, 2 and 3

Scenario N P K S Ca Mg

1 262 119 65.4 45.6 29.7 740

2 262-22.4 = 239.6

119-63 = 56

65.4-19.8 = 45.6

45.6-25.3 = 20.3

29.7-11 = 18.7

740-259 = 481

3 262-44.7 = 217.3

119-126 = 0

65.4-39.6 = 25.8

45.6-50.6 = 0

29.7-22 = 7.7

740-517 = 223

Scenario 1 (All retentate goes to the Farm)

N deficit; 497 – 262 = 235 kg/ha N fertiliser needed

P surplus; small, around 47 kg/ha – retention by soil

K large deficit; about 600 kg/ha of K fertiliser needed after 1-2 years

S small surplus; 10 kg/ha either retained as CaSO4 or lost to groundwater

Ca small deficit; huge store already in soil

Mg big surplus; over 700 kg/ha will be retained by soil profile as exchangeable Mg,

displacing other cations from topsoil, then other lower horizons. Plant nutrition

could be disturbed after say 5 years.




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Scenario 2 (Half the retentate goes to the Farm)

N deficit; 260 kg/ha N fertiliser needed

P deficit; 15 kg/ha but huge store already in soil

K big deficit; 615 kg/ha K fertiliser needed

S small deficit; 10 kg/ha can be obtained from soil

Ca deficit; 65 kg/ha can be obtained from soil for many years

Mg big surplus; 455 kg/ha and while soil degradation likely it could take 10 years

Scenario 3 (No retentate goes to the Farm)

N deficit; 280kg/ha N fertiliser needed

P deficit; 70 kg/ha but huge store already in soil

K big deficit; 61 kg/ha K fertiliser needed

S deficit; 10 kg/ha which can probably come from soil store

Ca deficit; 77 kg/ha which can come from soil for many years

Mg big surplus; about 200 kg/ha but due to high Ca and K levels will not lead to soil

degradation or nutrient imbalances if K fertiliser is added for at least 20 years.

Soil Nutrient Levels Ca, Mg and K

Previous irrigation practices have greatly increased the soil nutrient levels since irrigation

commenced. Annual monitoring of surface soils and testing down the profile every three

years has provided the following data.

Table 25

Exchangeable Cations [cmol(+)/kg] - Mostly Plant Available

Ca Mg K

1 21 to 60 3 to 6 1.2 to 3 cmol(+)/kg

2 40 4 2 cmol(+)/kg

3 12800 640 1040 kg/ha

4 -55 +716 -597 kg/ha

1 Range of exchangeable cation concentrations in surface soils (0 - 10 cm depth).

2 Typical figure in many paddocks.

3 Estimated available nutrient content, kg/ha, 0 - 10 cm..

4 Annual deficit or surplus as projected for Scenario 1.




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Under Scenario 1 (all retentate going to irrigation), soil potassium levels will be depleted

in less than 2 years, unless potassium fertiliser is applied.

Rising magnesium levels will depress potassium uptake by the irrigated pastures unless

potassium fertiliser is applied, probably after 1 year.

After 3 years the exchangeable calcium/magnesium ratio, currently favourable for plant

growth will start to fall below 2:1, potentially reducing growth. After 8 years the topsoil

will become dominated by exchangeable magnesium, increasing the risk of soil

structural degradation unless calcium is added (as lime or gypsum, or as calcium nitrate

fertiliser).

These changes will be delayed if the paddocks are cultivated, incorporating the surface

soil into the subsurface layers (to 20 or 30 cm).

Soil Nutrient Levels – N, P and S

Nitrogen

The availability of these nutrients is largely controlled by the action of soil micro-

organisms on the store of organic matter. The total amount of these nutrients is very

large, due to the surplus built up under previous irrigation practices. Under Scenario 1,

there will be a decrease of nitrogen levels, which will probably require supplementation

with nitrogen fertilisers especially in spring when pastures are growing rapidly.

It is not possible to estimate accurately how much is needed, but the soil and plant tissue

testing can guide applications in future years.

Phosphorus

Soil phosphorus levels, both total and available, are high in the topsoil but decrease in

the subsurface layers. There will be a small annual surplus (47 kg/ha) under Scenario 1.

Soil phosphorus sorption levels are falling in the surface soils, due to the very high

additions of P in previous years, but remain elevated in the subsoils. These deeper

layers are highly acidic and contain elevated concentrations of exchangeable aluminium

which boosts retention of phosphorus, reducing plant uptake and leaching. Monitoring of

soil profiles for phosphorus sorption will indicate if downward P movement is excessive.

(ie. beyond the rootzone).

Levels of available (ie. mobile) phosphorus remain very low in irrigated subsoils after

many years of receiving heavy phosphorus applications, mostly because of high

P retention in the surface. Annual testing of surface soils shows that the P sorption of

the 100 mm to 200 mm depth remains higher than the 0-100 mm depth (in 30 paddocks




Page 172

over the last 3 years). The difference mainly arises because sorption is reduced by

these P levels.

Sulphur

There will be small sulphur surplus under Scenario 1. Sulphur is likely to be retained in

the soil as gypsum (calcium sulphate) due to the very high calcium levels. The content

of sulphate (and total sulphur) was high in most soils prior to irrigation.

Detailed testing in 1996 of 36 profiles prior to the development of the centre pivot

irrigation system, showed total S levels were high; in the topsoils due to elevated organic

matter contents, and in the subsoils due to the presence of acid sulphate soil layers.

Levels of 0.1 or 0.2% total S are common. This is equivalent to 4000 kg/ha in the top

30 cm or over 13000 kg/ha in the top metre of the profile (@ 0.1% S).

Many decades of irrigation are needed if these high background levels are to increase

significantly, or to have any influence on groundwater sulphate levels.

It should be noted that there is considerable variation in nutrient levels across the farm,

due to the differences in the history of previous irrigation. Paddocks with the longest

history of use will be more able to withstand the changed wastewater characteristics

than those that received less wastewater in the past.

Recommendations for Management Plan

Murtagh, Lawrie and Lugg make the following recommendations with respect to an

Irrigation Management Plan:

“Scenario 1

•••• Monitor soil properties in irrigated paddocks in top 30 cm of profile (to guide management, especially use of fertilisers and irrigation regime).

•••• Apply nitrogen fertiliser after each cut of forage; about 100 kg N/ha at least twice in the first year, more in later years

•••• Apply potassium fertiliser after each cut (preferably as potassium nitrate, depending on cost, potassium chloride is second preference) at least 250 kg K /ha in first year, rising to 500kg K/ha after 3 years; soil monitoring data to be used as a guide here.

•••• Investigate use of lower rates of magnesium hydroxide in the wastewater treatment process

•••• Consider applying a leaching irrigation, if rainfall is low, to move excess magnesium out of the topsoil to the lower horizons.




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Scenario 2 and Scenario 3

• Monitor soil properties annually in irrigated paddocks in top 30 cm of the profile.

• Apply nitrogen fertiliser after each cut of forage at 100 kg N/ha t least 3 times a year.

• Apply potassium fertiliser after each cut (preferably as nitrate); rate depends on soil test level, but may need 300 kg K/ha in first year and will increase to 400 kg K/ha after 3 years.”

As this proposal will involve 100% retentate being irrigated onto the Environmental Farm,

Scenario 1 will apply to this project.

7.4.5 Water Balance Analyses

The proposal will result in wastewater either being re-used within the factory process or

used for farm irrigation. Hence, there will be no discharges of wastewater to the

Shoalhaven River. In this regard, wet weather storages are used to hold surplus

wastewater during periods of wet weather when the soil is too wet to irrigate.

Previous investigations estimated the wet-weather storage requirements with a

wastewater flow of 4.6 ML/d. The present study examined the adequacy of the

proposed storage arrangements with a flow of 2.1 – 3.6 ML/d depending on the

proportion of retentate that is directed to farm irrigation. The aim was to establish

whether there was sufficient storage to prevent discharges under a range of rainfall

conditions as represented by the historical rainfall at Nowra. As such, the emphasis in

this section is on the hydraulic components on the proposed reuse system, in contrast to

the chemical aspects that are discussed elsewhere.

To do this, the H2OB water balance model was used to estimate the day to day change

in the soil moisture level under varying degrees of wetness and hence when it was dry

enough to irrigate. It did that by solving the water balance each day during the 68 years

of rainfall records that were used in the analyses. The inflow of wastewater was then

balanced against the outflow to irrigation, with the storages providing a buffering

capacity.

Values of key variables were as follows, with more details and broad capabilities of the

H2OB model being described in Annexure O(i).

• Wastewater flow of 2.1 ML/d with no retentate used for irrigation, increasing to

3.6 ML/d with 100% reuse of retentate for irrigation;

• Pasture irrigation with 238 ha under centre pivots and 276 ha with travelling

irrigators; a total area of 514 ha;




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• Total available storage of 823 ML.

Water Balance Results

Mean annual results are given in Table 26.

Table 26

The Reuse and Irrigation Volume with Different Proportions of Retentate

in the Wastewater used for Irrigation

Proportion of retentate (%)

Wastewater flow (ML/d)

Required storage (ML)

Reuse (%) Irrigation (ML/yr)

0 2.1 401 100 727

50 2.85 504 100 1004

100 3.6 636 100 1274

There was 100% reuse and no river discharges under all rainfall sequences in the

historical record, provided the storage capacity was 401-636 ML, depending on the

wastewater flow. As the available storage capacity will be 823 ML the 100% reuse was

easily obtained.

The difference between the annual irrigation volume of 727 – 1274 ML/yr and the annual

wastewater flow of 767 – 1315 ML/yr was accounted for by the net evaporation from the

storages.

The pattern of monthly irrigation in months of different wetness are shown in Figure 23.

MONTH

J F M A M J J A S O N D

IRR

IGA

TIO

N

(mm

/mth

)

0

50

100

150

200

250

MONTH

J F M A M J J A S O N D

Median

1/10-dry

1/10-wet

2.1 ML/d

1/10-dry

Median

1/10-wet

3.6 ML/d

Figure 23: The Monthly Irrigation Volumes in Dry, Medium and Wet Months.




Page 175

With no retentate use, the daily wastewater flow of 2.1 ML/d equates to about 64

ML/mth. Under median conditions, the irrigation volume was slightly less than the

wastewater flow indicating that some wastewater would be stored until drier than median

conditions permitted more irrigation. Note also than even under very dry (1/10-dry)

conditions the highest irrigation volume occurred in July, indicating that a shortage of

water held back the irrigation volumes during the warmer months.

When all the retentate was used, the increased flow supplied about 110 ML/mth. About

the same amount was used under median conditions, and increased only under drier

conditions when some water was available from the storages, especially during the

cooler months.

These results illustrate how the pasture will be underwatered during many months that

are drier than average.

The main conclusion is that the existing storage capacity is more than sufficient to

provide wet-weather storage and thus avoid discharges to the river.

7.4.6 Irrigation Management Plan

Summary

The Irrigation Management Plan addresses the impact of future irrigation activities at the

Environmental Farm (EF). Included are soil effects, water quality, storage and recycling.

Irrigation scheduling at the site was reviewed in 2003 investigating the current and other

available methods. Existing procedures developed specifically for the wastewater

infrastructure were determined to be the most appropriate. The quality of the

wastewater improved post 2004 so that irrigation and soil properties were improved.

Further analysis of the irrigation data since then, has defined other important

characteristics such as a frequency distribution of irrigation volume and pumping

capacity upgrades.

Rainfall variation is the dominant limitation to the continuously operating business which

is dependent upon beneficial irrigation. Hence the irrigation scheme depends heavily on

the provision of adequate wet weather storage capacity to prevent discharges during wet

weather.

By entering into the next stage of water treatment and recovery, the Company will move

to a less weather dependent factory-operating status; will recover water for factory and

agricultural reuse; will generate biogas for cleaner production and will minimise offensive

odours.




Page 176

Site Description

The Environmental Farm is 960 hectares of which approximately half is irrigated. The

spray irrigation infrastructure consists of seven centre pivots and 185 irrigation

runs/transects for hydraulic propelled travelling irrigators.

The underground network of poly pipe, which distributes the wastewater, is

approximately 44 kilometres in length. There are 4 main irrigation lines from which

lateral lines branch to licensed irrigation paddocks.

The size of this irrigation enterprise determines the choice of the method to schedule the

application of wastewater. Instrumentation which precisely measures the soil water

content is specific to the location within a block and to the depth installed. These

limitations, together with the cost of instrumentation of paddocks or even the number of

soil types across the farm would outweigh the usefulness of such an exercise. Also site

specific instruments are reliant upon the siting of equipment in a representative area of

the paddock.

Irrigation Scheduling and Practices

The initial training in the 1980s for the irrigators employed by the Company was the soil

moisture deficit technique. This approach is to be enhanced by the use of the IRRICALC

program giving a combination of meteorological data and visual inspection of paddocks

to control irrigation.

Comprehensive records are kept of the irrigation volumes that are applied to all

paddocks. An analysis of irrigation records since January 2003 has also confirmed the

irrigation intervals for each paddock which is related to soil type.

Three irrigation scheduling techniques were re-evaluated in 2005. They were current

practice; including the use of the “IRRICALC” irrigation-scheduling software and

evaporation deficit calculations. The exercise revealed that the experience of the

personnel coupled with the chemical limitations of the wastewater provided the best

outcome in terms of timeliness, efficiency, odour reduction and operational cost.

Commercially available instrumentation and strategies are valuable learning tools.

However, the time involved with potential re-siting, breakdowns and verification

monitoring disadvantaged the efficiency of the operation. Ultimately the quality of the

wastewater itself eliminated the commercially available techniques as specific practices

had to be devised for the wastewater operation. The site specific evaporation deficit

data was useful as a backup.




Page 177

Simple probe and physical inspection of each area could not be replaced by systems

that are reliant upon assumptions of homogeneity of soil within a paddock. Experienced

scientific modellers have a verification process commonly known as “ground-truthing”

such as pre-irrigation inspections.

While there are various aids to assist with irrigation scheduling, it is more important that

the irrigation area is inspected on a regular basis by experienced operators.

The Company feels that this system of irrigation management is the best way to

effectively utilise the wastewater across the farm whilst avoiding the potential for

environmental harm.

Standard Operating Procedures (SOP) are being reviewed as machinery descriptions

are too specific. A more generic text will be substituted.

Review of Irrigation Limitations

Since 2005, several major factors have had an effect upon the irrigation operation.

• The condensate dominated wastewater has approximately 1% solids (including the

lime adjustment).

• The soil monitoring program since this change has recorded a stabilisation and

subsequent decreases for several important parameters.

Limitations for the existing irrigation area are similar to the 2005 report. Coastal weather

patterns are variable and even during the last three drought years, the effective irrigation

period has been reduced by a quarter. See Figure 24.

Rainfall variation is the dominant limitation to the continuously operating business which

is dependent upon beneficial irrigation. Hence the irrigation scheme depends heavily on

the provision of adequate wet weather storage capacity to prevent discharges during wet

weather.

Irrigation data collated and presented annually to the DECC, has been analysed.

A frequency distribution chart of rounded daily volumes was generated for similar

periods for the last 3 years.




Page 178

0

20

40

60

80

100

120F

req

uen

cy

0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23

Irrigated Volume (ML)

Three Year Average Distribution of Daily Irrigation Volumes

To obtain a summary of the existing irrigation practices, the data was then averaged to

reveal the following points.

• Zero irrigation volumes exist for 100 days per year.

• The effective irrigation year is 265 days.

• The effective median irrigation volume is 5 ML per day.

• Irrigation hours vary according to soil moisture and weather patterns.

• Irrigations larger than 20 ML per day occur only 3 times per year.

7.4.7 Implementation of Irrigation Program

In response to a request from the DECC, Murtagh, Lawrie & Lugg were engaged to

confirm how the irrigation program will be implemented, to provide details of the mass

balance of various analytes in the waste water, and to detail the monitoring program that

will confirm how the irrigation is affecting the Environmental Farm environment.

A supplementary report addressing these matters forms Annexure O(ii) to this EA.

According to this supplementary submission the mass balances showed that the balance

between inputs from waste water and losses in silage that is harvested from the

Environmental Farm would be:

Figure 24: Average Distribution of Daily Irrigation Volumes for the Last 3 Years.




Page 179

• Positive for phosphorus, magnesium, sodium, bicarbonate, chloride and sulphate.

That is more of these analytes will be added than will be removed in silage.

• Balanced for calcium.

• Negative for nitrogen and potassium.

Of the six analytes with a positive balance, only sodium and chloride are likely to strongly

leach and this, according to this supplementary submission, was viewed as desirable to

limit the development of soil salinity. Nor did they contribute to environmental harm

because of the saline nature of the receiving waters and subsoil. Of the remaining four

analytes, most if not all of the phosphorus, magnesium and bicarbonate will precipitate in

the soil, while some of the sulphate will precipitate or from acid and some might leach.

Leaching sulphate will not be detectible because of the considerable quantity of sulphate

compounds and ions in the acid sulfate environment.

The negative mass balances with nitrogen and potassium indicate that they will not

leach and will not constitute an environmental risk, but will have implications for plant

nutrition.

The proposed monitoring program which is detailed in Annexure O(ii) includes:

• Documenting the volume and chemical composition of the waste water to confirm

the mass of each analyte that will be added to the Environmental Farm.

• Annual soil monitoring to determine the time trends in the concentration of those

analytes that re likely to accumulate in the soil, or to be important for plant nutrition.

• Monitoring of the chemical composition of herbage to document the removal of

selected nutrients and the need for fertiliser use.

• Monitoring groundwater to detect leaching of surplus magnesium, this being the only

analyte that is likely to leach and that is not already common in the receiving waters.

Details are also provided of the remedial measures that should be implemented should

the various analytes accumulate to undesirable levels.

Table 27 provides a checklist of the required actions for monitoring and related issues.

It also details the sections in Annexures O(i) and O(ii) where more detail is provided.




Page 180

Table 27

Checklist – Required Actions for Monitoring and Related Issues

Item Reason Frequency How Section

WASTEWATER

Irrigation volume Used in mass load calculations

As used Flowmeters 4.1 Annexure O(i)

Composition – suite A high concentration

Identify surplus Monthly Chemical analyses

4.1 Annexure O(i)

Composition – suite B low concentration

Identify deficit and need for fertiliser

Monthly Chemical analyses

4.1 Annexure O(i)

SOIL

Composition – suite C

Detect changes over time

Annual Soil cores (0 – 30 cm)

4.2 Annexure O(i)

Soil structure Maintain structure Annual Dispersion test 4.2 Annexure O(i)

HERBAGE - HARVESTED

Harvested quantity Used in mass removal calculations

At each harvest

Bale count by average weight

4.3 Annexure O(i)

Composition – suite D

Mass removal and need for fertiliser

All cuts (bulked)

Chemical analysis 4.3 Annexure O(i)

HERBAGE - GRAZED

Animal grazing days

Used in mass removal calculations

Ongoing Counts 4.3 Annexure O(i)

Composition − suite D

Mass removal and need for fertiliser

Annual Leaf plucks and chemical analysis

4.3 Annexure O(i)

GROUNDWATER

Composition

− suite E

Detect leaching due to surplus

Annual Chemical analysis 4.4 Annexure O(i)

REMEDIATION

Response Correct undesirable effects

As required Recommendations 3 Annexure O(i)

Suite A chem.. testing, high conc. – pH, EC, Mg, Na, HCO3, Cl, SO4. Suite B chem.. testing, low conc. – total N, total P, K, Ca. Suite C chem.. testing, soil – pH, EC, total P, K, (Exch. Ca, Mg, K, Na), soluble Na, Cl. Suite D chem.. testing, herbage – total N, P, K, Ca, Mg. Suite E chem.. testing, groundwater - Mg




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Table 28 outlines the key issues for operational planning, and where details may be

found in Annexures O(i) and O(ii).

Table 28

Key Issues for Operation Planning

Item Aim How Section

Crop types Maintain high productivity Continue with existing ryegrass and kikuyu pastures.

Pasture productivity Maintain high productivity Use fertiliser and overseeding as required.

3 Annexure O(ii)

Irrigation Avoid overwatering Deficit irrigation. 7.3 Annexure O(i)

Soil quality Avoid unacceptable salt accumulation

Monitor and change inputs or outputs where required.

4 Annexure O(ii)

Nutrient removal Reduce accumulation of surplus analytes in soil

Cut and removal of herbage.

3 Annexure O(ii)

7.4.8 Summary and Conclusions

With the implementation of the ethanol upgrade, waste water flows that will be used for

irrigation will come from two sources:

• Some discharges from the SO basin amounting to an average of 2.1 ML/day.

• The waste water treatment plant will produce a clean water flow and a retentate flow

that will contain most of the water contaminants from the inflow. The retentate flow

will average 1.5 ML/day.

Shoalhaven Starches propose to use both of the above flows for irrigation onto the

Company’s Environmental Farm (including 100% of the retentate flow).

The assessment by Murtagh, Lawrie and Lugg (Annexure O(i)) identifies that based

upon salinity, treated waste water, containing 100% retentate can be used for irrigation

on the Company’s Environmental Farm.

According to this assessment adverse changes will occur gradually and careful

monitoring of the soil will provide advanced warning. If field experience identifies issues

arising in relation to soil salinity or adverse effect on pasture productivity the

management practices associated with the irrigation of retentate may have to be

reviewed.




Page 182

Shoalhaven Starches therefore commit to undertaking a monitoring program of the soil

(including soil salinity and the ionic composition of the soil solution, especially calcium

concentration). Such will include annual soil and pasture sampling of selected paddocks

to improve predictive capabilities.

In terms of an ongoing management plan for the irrigation of waste waters on the

Environmental Farm, Shoalhaven Starches commit to the following:

• Monitor soil properties in irrigated paddocks in top 30 cm of profile (to guide management, especially use of fertilisers and irrigation regime).

• Apply nitrogen fertiliser after each cut of forage; about 100 kg N/ha at least twice in the first year, more in later years.

• Apply potassium fertiliser after each cut (preferably as potassium nitrate, depending on cost, potassium chloride is second preference) at least 250 kg K/ha in first year, rising to 500 kg K/ha after 3 years; soil monitoring data to be used as a guide here.

• Investigate use of lower rates of magnesium hydroxide in the waste water treatment process.

• Consider applying a leaching irrigation, if rainfall is low, to move excess magnesium out of the topsoil to the lower horizons.

During prolong wet weather periods when the soil is too wet to irrigate there is a need to

provide wet weather storage for the treated waste waters. This is achieved in the Wet

Weather Storage Ponds.

Annexure O(i) concludes, when all the retentate is used, the existing storage capacity is

more than sufficient to provide we-weather storage.

The supplementary submission prepared by Murtagh, Lawrie & Lugg (Annexure O(ii)):

confirms how the irrigation program will be implemented; provides details of the mass

balance of various analytes in the waste water; and details the monitoring program that

will demonstrate how irrigation is affecting the Environmental Farm environment.

The proposed monitoring program includes:

• Documenting the volume and chemical composition of the waste water to confirm

the mass of each analyte that will be added to the Farm.

• Annual soil monitoring to determine the time trends in the concentration of those

analytes that are likely to accumulate in the soil, or to be important for plant nutrition.

• Monitoring of the chemical composition of herbage to document the removal of

selected nutrients and the need for fertiliser use.




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• Monitoring groundwater to detect leaching of surplus magnesium, this being the only

analyte that is likely to leach and that is not already common in the receiving waters.

Details are also provided of the remedial measures that should be implemented should

the various analytes accumulate to undesirable levels.

7.5 WATER AND SOILS

7.5.1 Water Supply

Water is used in the starch production process. Production of starch and protein (gluten)

from wheat flour is a water-based mechanical separation process, which results in the

production of an aqueous waste stream which contains residual fibre, soluble sugars,

soluble protein and low-grade starch.

It is common practice in the worldwide starch-gluten industry that up to 10 tonnes of

water is required for each tonne of flour processed. Using technology developed at

Shoalhaven Starches, water consumption is approximately 3 tonnes per tonne of flour

processed and equivalent to world’s best practice.

A daily average of 8,300 kilolitres of water is used presently by Shoalhaven Starches for

their total operations, comprising:

• 5,100 KL from the municipal drinking water supply; and

• 2,400 KL from a raw water supply provided by Shoalhaven City Council via a

pipeline from the Australian Paper Mill.

The proposed upgrade of the facilities for increased production of ethanol and gluten

and associated by-products will necessitate increased water usage; both potable water

for processing flour and non-potable water for steam generation, cooling and other uses.

After installation of the proposed Waste Water Treatment Plant and the availability of

treated water for re-use, daily water supply will comprise:

• 4000 KL of potable quality water;

• 3700 KL of raw water;

• 4500 KL of treated water for re-use.

The Company will obtain 4000 KL of potable quality water from the Shoalhaven City

Council. The remaining 4500 KL of potable water requirement will be obtained from the

waste water processed by the water treatment process associated with this proposal.

The 3700 KL of raw water will come via the Australian Paper Mill as is currently the case.




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Figure 8 details a proposed water and waste water balance for the site following the

ethanol upgrade project.

Water Discharges

The Shoalhaven Starches Factory and Environmental Farm are licensed premises under

the Protection of the Environment Operations Act. Waste water discharges from the site

are licensed by the DECC (EPL 883).

The plant has a licensed outfall into the Shoalhaven River. The outfall point is a 50 cm

diameter metal pipe discharging at the end of an existing jetty. It also has a cooling

water discharge comprising a 50 cm diameter pipe which discharges onto a gabion

spillway.

Under the terms of the Company’s EPL water waste streams associated with the plant

include:

• river water passed through the boiler condensers and the primary side of the heat

exchangers;

• boiler water treatment plant regeneration waters; and

• pH adjusted glucose plant ion exchange unit regeneration waters.

7.5.2 Stormwater Management

Shoalhaven Starches engaged GHD Pty Ltd to examine stormwater management

(including erosion and sediment controls) for this proposal. GHD’s report, titled

Environmental Management Report, forms Annexure P to this EA. The following

section of the EAR is based upon the findings of this report.

7.5.2.1 Existing Stormwater Management System

Factory

Shoalhaven Starches’ existing site stormwater management system at the factory is

divided into three zones. The zones are:

• Zone 1 – all site stormwater generated in this zone is collected and passed through

a first flush pit to remove gross solids and pollutants prior to discharge to the

Shoalhaven River;

• Zone 2 – all site stormwater generated in this area is collected in pits and drainage

channels and conveyed to the Environmental Farm where it is stored in dams prior

to being irrigated. No stormwater from this zone is discharged to the Shoalhaven

River; and




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• Zone 3 – all site stormwater generated by this area of the site is collected and

pumped to the Environmental Farm during small storm events. Stormwater is

discharged to the Shoalhaven River system during heavy rainfall events.

Pond No. 7 (Environmental Farm)

Pond No. 7 at the Environmental Farm is located on relatively flat undeveloped

agricultural land, several hundred metres away from the nearest major watercourse.

The surrounding area has no formalised stormwater management system and

rainfall/stormwater is managed through infiltration into the surrounding soils.

Packing Plant Location

The proposed location of the packing plant is currently undeveloped land and therefore

has no existing stormwater management system.

Raw Water Pipeline Route

The proposed raw water pipeline would be located within the boundary of the

Environmental Farm, parallel to Bolong Road, would cross to the southern side of

Bolong Road and through the Boweld property, before entering the Factory property and

running adjacent to the railway. The route has no formalised stormwater management

system.

7.5.2.2 Construction Stormwater Management

Factory

Zone 1

The proposed additional fermenters and cooling towers would be located at the eastern

part of the factory within Zone 1. Consequently all runoff generated at this location

during construction works would be discharged to the Shoalhaven River following initial

treatment. Construction activities in this area would therefore require the implementation

of strict construction environmental management measures to minimise the risk of

pollutants (including sediment, chemicals and oils/fuels) from being discharged to the

river. Detailed mitigation measures have therefore been proposed and outlined in

Section 8.0 of the EA to contain stormwater runoff on site and to minimise the risks of

contaminated discharges to the river.

Zone 2

The proposed additional molecular sieves and cooling towers would be located within

the ethanol plant in the central part of the factory within Zone 2. Stormwater from this

area would be conveyed to the Environmental Farm for treatment and irrigation.




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Appropriate environmental management controls have been proposed for construction

works in this zone to prevent contaminants being transported to the Environmental Farm

(refer Section 7.5.2 of this EA).

Zone 3

The proposed additional starch dryer and gas-fired boiler would be located on the east

bank of Abernethy’s Drain within Zone 3. The proposed chemical storage facility,

evaporator, DDG load-out extension, DDG pellet plant, cooling towers, bioscrubbers and

co-generation plant would be located to the west of Abernethy’s Drain, also in Zone 3.

Stormwater runoff generated at these locations by larger rainfall events would be

discharged to the Shoalhaven River.

Construction activities in this area would require the implementation of strict construction

environmental management measures to minimise the risk of pollutants from being

discharged to the Shoalhaven River or Abernethy’s Drain. Detailed erosion and

sediment controls proposed for the works are provided in Section 7.5.2 of this EA.

Pond No. 7 (Environmental Farm)

The adaption works required to convert Pond No. 7 into the anaerobic and aerobic waste

water treatment plant are likely to be relatively minor civil works, including the installation

of pipework, aeration blowers, tank covers, etc. These works would not be expected to

generate significant risk of pollution. However, the works should be conducted in

accordance with the Pond No. 7 Construction Environmental Management Plan (CEMP)

prepared by GHD in 2007 for the bulk earthworks associated with construction of the

pond.


Stormwater generated during construction of the packing plant would flow to the existing

swampy depression located to the north of the site. Appropriate construction

environmental management measures would be required to minimise the risk of

pollutants being discharged off site. Erosion and sediment controls proposed for the

works are detailed in Annexure P of this EA.


Stormwater generated during construction of the raw water pipeline would generally be

confined to the trench and immediate surrounds. The construction area would generally

be surrounded by pasture or grassland with a low slope, which would act as a swale,

enabling significant removal of any suspended solids.




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7.5.2.3 Operational Stormwater Management

Factory

Operation of the proposed works would not alter the existing site stormwater

management system at the factory. The proposed works would also not be expected to

substantially increase the volume of stormwater generated from the site as the bulk of

the factory surface area is currently surfaced with bitumen or other relatively

impermeable surface cover.

The design of the individual components of the upgrade would incorporate relevant

design guidance and stormwater management practices, including bunding (particularly

around the chemical storage facility) to meet DECC requirements, and the appropriate

containment, treatment and disposal/discharge of stormwater runoff generated by the

new works.

The DECC have raised issue with respect to spills containment both in terms of the

proposed works as well as the existing site.

Within the central portion of the site, containing the ethanol distillery, starch plant and

fermentation area, the Distillery is contained within a bunded area in accordance with

relevant Australian Standards. The eastern portion of the site contains ethanol storage

and other loading facilities. The ethanol storage and recovery area are also contained

within bunded areas in accordance with the relevant Australian Standards.

There are instances however within the older developed areas within the factory site

where storage vessels and areas are not bunded in accordance with relevant Australian

Standards.

Any new storage plant and equipment associated with the proposed ethanol upgrade

project will be bunded in accordance with relevant Australian Standards.

It is also proposed however that Shoalhaven Starches will commit to undertake a review

of the of the factory site to identify and analyse areas of the factory site where bunding of

storage vessels and areas is not provided. Based upon this “gaps” analysis an

implementation strategy can be formulated which seeks to instigate bunding where it is

necessary throughout the factory site. Such a strategy could be formalised in

consultation with DECC and incorporated into a Pollution Reduction Program under the

Company’s Environmental Protection Licence.




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Environmental Farm

Operation of the proposed works would not alter the existing site stormwater

management system at the Environmental Farm, and would not be expected to

substantially increase the volume of stormwater generated from the site.


Operation of the packing plant would be expected to increase stormwater generated at

the site when compared to its current undeveloped state.

Stormwater generated from the packing plant site would drain to a first flush pit to

remove gross solids and pollutants prior to being discharged to a soak-away located to

the north of the site. Following larger rainfall events it is anticipated that the soak-away

would discharge to the existing swampy wetland.


The pipeline trench would be restored and revegetated following completion of

construction. Operation of the pipeline would not be expected to generate stormwater.

7.5.3 Acid Sulphate Soils

Acid Sulphate Soils (ASS) is naturally occurring soil and sediment containing iron

sulphides which when exposed to oxygen can generate sulphuric acid. Coffey

Environments (“Coffeys”) were engaged by Shoalhaven Starches to undertake an

environmental assessment of the site in germs of the presence of acid sulphate soils.

A copy of Coffey’s assessment report forms Annexure J to this EA.

According to Coffeys the Burrier/Berry 1:25,000 Acid Sulfate Soil Risk Map (1997)

edition 2, prepared by the Department of Land and Water Conservation (DLWC),

indicates the following for each of the investigation areas (refer Figure 25):

• The Eastern and Western Plant Areas are generally located in areas with a low

probability of ASS occurrence being described as elevated alluvial plains and

levees. ASS, if present, are considered to be sporadic in occurrence greater than

3 m below the ground surface.

• The Central Plant Areas and the proposed fire service facility are generally located

in areas with a low probability of ASS occurrence being described as elevated

alluvial plains and levees. ASS, if present, are considered to be sporadic in

occurrence within 1 m of the ground surface and up to 3 m.

FIG

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• The area encompassed by the proposed Packaging Plant is generally located in

areas with a low probability of ASS occurrence being described as an elevated

alluvial plain. ASS, if present are considered to be sporadic in occurrence indicated

as occurring at depths at 1 m below the ground surface and up to 3 m.

• The area of the proposed water treatment and filtration plant at the Environmental

Farm is located in an area with low and high probability of ASS occurrence. Areas

of high probability are described as low alluvial plains, estuarine sand plains,

estuarine swamps, backswamps and/or subpratidal flats. ASS, if present, are

considered to be widespread or sporadic within 1 m of the ground surface with a

severe environmental risk if disturbed. Areas of low probability are described as

elevated alluvial plains and levees. ASS, if present, are considered to be sporadic in

occurrence between depths of 1 m and 3 m below the ground surface. The map

shows areas immediately north and northeast towards Broughton Creek, are high

probability ASS at depths near surface or within 1 m of the ground surface.

• The proposed gas and water pipeline routes run through areas with a low probability

of ASS occurrence, noted as alluvial plains and levees. ASS if present would occur

between 1 m to > 3 m of the ground surface.

• The map shows areas immediately to the south of the site within the river, as being

estuarine bottom sediments with a high probability of ASS occurrence. Areas with

a high probability of ASS occurrence are also shown further to the north of the study

areas.

Coffeys make the following findings in relation to Acid Sulphate Soils and this project:

Central and Eastern Plant Area

Sampling locations in this area recorded fill soils ranging from 0.6 m to 0.75 m comprised

of silty sands and some gravel (probably pavement materials) which were not indicative

of ASS. Underlying soils were typically described as topsoil/alluvial/estuarine silts with

varying proportions of clay and sand. No evidence of jarosite staining was noted at the

locations. A sulfidic type odour was noted below a depth of about 2.4m in borehole

CBH104. Screening results did not record a field pH below 4 or a pH below 3 after

oxidation with H2O2. Five samples were selected for testing using the (Chromium

Reducible Sulfur) SCR method. The results are presented in Table LR9 within Coffeys

Assessment and these did not suggest that the soils were ASS.




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Western Plant Area

Sampling locations in this area recorded fill soils ranging from 0 to 1.1 m comprised

mainly of gravels and sands (probably pavement materials) which were not indicative of

ASS. Underlying soils were typically described as alluvial silts and clays. No evidence

of jarosite staining was noted at the locations. Screening results did not record a field

pH below 4 or a pH below 3 after oxidation with H2O2. Results of sampling suggest

acidity is non-sulphuric and therefore not considered to be an ASS. One sample

suggests that the soil in this horizon could be an actual ASS, but does not appear to

have capacity for further additional acid production.

Proposed Packing Plant

Sampling locations in this area generally recorded topsoil/alluvial and estuarine soils.

Estuarine soils were generally noted in the northern and eastern parts of this area which

are typically the lower lying parts. Typically stiffer alluvial soils were noted in the central

and southern parts of this area. The estuarine soils were typically dark grey and black

clayey silts whilst alluvial soils were typically sandy and silty clays.

Field screening results generally recorded pH values greater than 4. After oxidation with

H2O2, some samples recorded pH values below 3 which suggests the potential presence

of unoxidised sulphides.

Laboratory results indicated Total Actual Acidity (TAA) values ranging between 22 m/t

and 123 m/t suggesting soils are actual ASS. SCR results typically suggest that the soils

do not have unoxidised sulfides that would lead to further oxidation, except for one

sample. According to Coffeys, results also suggest that not all of the acidity is sulphuric,

but sufficient sulphuric acidity is present to designate these soils as Actual ASS. Sample

results for a test pit excavated near the southern end of the proposed footbridge over

Bolong Road did not indicate the presence of ASS.

Proposed Fire Services and Gas Facility

Sampling locations in this area generally recorded alluvial soils with some possible

estuarine soils deeper in the profile below about 1 m. Screening results showed field pH

values greater than 4. After oxidation with H2O2, some samples recorded pH values

below 3 which suggests the potential presence of unoxidised sulphides.

The results from samples from the proposed fire service area tested using the SCR

method noted TAA concentrations exceeding the action criteria and ranging between

47 m/t and 63 m/t. Results for these samples suggest the acidity is mostly non-

sulphuric.




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Samples from the proposed gas facility were tested using the Suspended Peroxide

Oxidisable Combined Acidity and Sulphate (SPOCAS) method. TAA concentrations

exceeded the action criteria ranging between 51 m/t and 80 m/t. Oxidisable sulphur

concentrations for three out of the four samples tested recorded values between 0.04%

and 0.07% which exceed the action criteria. These soils appear to be ASS.

Proposed Water Treatment and Filtration Plant (area near Effluent Pond 7)

One sampling location in this area generally recorded the presence of alluvial soils.

Screening results showed field pH values greater than 4. Samples screened with H2O2

did not show a drop in pH below 3.

One sample recorded a TAA concentration of 19 m/t which exceeds the action criteria.

Soils in this general area have previously been assessed as part of the Pond 7

construction and these soils have been managed as ASS.

Proposed Pipeline Route Options (refer Figures 3 & 4)

Option 1

Boreholes drilled within the western half of the pipeline route for this option noted mainly

the presence of alluvial soils and also topsoil fill materials. As this area is a service

corridor, some of the materials encountered could possibly be associated with former

trench backfill materials. A thin band of clayey silt logged as estuarine material was

observed. Screening results for this section of pipeline generally recorded pH values

greater than 4. Samples indicated a pH drop below 3 after screening with H2O2. Some

ASS could be encountered along this section but are likely to be sporadic.

Option 2

Test pits excavated in the western half of this route option typically encountered gravelly

fill soils from 0.6 m to 0.9 m which were not indicative of ASS. Underlying soils were

noted as very stiff alluvial clays. Samples of the alluvial clays were tested using the SCR

method and the results did not suggest the soils were ASS.

The eastern part of this route encountered topsoil overlying stiff to very stiff alluvial clays.

with a possible estuarine layer between 0.9 m and 1.1 m. Screening results indicated

field pH values greater than 4 and pH values greater than 3 after oxidation. Selected

samples tested using the SCR method did not suggest that the soils were ASS.




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Conclusion – Acid Sulphate Soils

In terms of the presence of Acid Sulphate Soils, Coffeys make the following conclusions:

Acid sulphate soil risk maps suggest that the majority of areas being assessed are in an area with a low probability of acid sulphate soil occurrence. The area of the proposed water treatment and filtration plant near the effluent ponds is closer or within a high risk area. Field screening and laboratory results indicated that ASS were not likely to be present in the central and eastern plant areas and fire service area. ASS are likely to be encountered within the packing plant (particularly the lower lying areas, north and east) and were confirmed in this assessment. For the remaining areas (western plant area, gas facility, near Pond 7, and pipeline routes) ASS are likely to be sporadic and possibly in lenses (if present).

We would recommend that an Acid Sulfate Soils Management Plan (ASSMP) be prepared for the packing plant and areas of the site where soil disturbances are likely to intersect ASS. Depending on further details of the proposed development and level of disturbance, further assessment could be carried out to increase the confidence in the lateral and vertical extent of the ASS.

It is probable that acid sulphate soils could occur at depths beyond those assessed in this study.

Should the proposed depth of disturbance change or different soils be encountered, then this would need to be re-assessed.

Based upon the findings of the ASS assessment carried out by Coffeys, Shoalhaven

Starches commit to preparing an Acid Sulphate Soils Management Plan for the proposed

Packing Plant site; and any areas of the site where soil disturbance is likely to intersect

with ASS. In this regard Shoalhaven Starches have over the years gained considerable

experience with undertaking construction works on land with potential acid sulphate

soils.

7.5.4 Contamination

Coffeys also undertook an assessment of the project site in terms of likely site

contamination (Annexure J). The scope of work carried out by Coffeys included:

• A site history and desk study to identify potential Areas of Environmental Concern

(AECs) and Chemicals of Concern (COCs) including: a review of previous site

ownership, review of available records held by Manildra and others, review of

Section 149 certificates, review of selected aerial photographs, holding interviews

with available people familiar with the history of the site, review of published

geological and topographic maps, ASS risk maps, a search of nearby groundwater

bores registered with the NSW Department of Water and Energy (DWE), review of

NSW Department of Environment and Climate Change (DECC) records for listing of




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the site, review of dangerous goods licences held for the site by NSW WorkCover,

review of the relevant sections of previous reports and collation of this information;

• A site walkover to visually assess potential sources of contamination, observe

surrounding landuses, topography, drainage, nearby sensitive environments, and

assess details of the site history and desk study to further assess potential AECs

and COCs;

• Collection of soil samples from boreholes, test pits and surface samples. The

samples were also collected in duplicate and screened for Volatile Organic

Compounds (VOC) using a Photoionisation Detector (PID);

• Carrying out field screening tests to check for ASS on selected soil samples;

• Installation, development and sampling of one groundwater monitoring well;

• Laboratory analysis of selected soil samples for a suite of potential COCs including:

− Total Petroleum Hydrocarbons (TPH), Benzene, Toluene, Ethylbenzene,

Xylenes (BTEX), Polycyclic;

− Aromatic Hydrocarbons (PAH), heavy metals (arsenic, cadmium, chromium,

copper, lead, mercury, nickel, zinc), Polychlorinated Biphenyls (PCB),

Organochlorine Pesticides (OCP);

− Organophosphorous Pesticides (OPP), pH and asbestos. Groundwater

samples were also analysed for biological parameters and nutrients;

• Laboratory analysis of selected soil samples using the Suspended Peroxide

Combined Acidity and Sulfate (SPOCAS) or the chromium reducible sulphur method

(SCR) for purposes of Acid Sulfate Soils assessment;

• Preparation of this report summarising the site history, results of fieldwork,

presenting and interpreting analytical results and findings, comparing chemical

concentrations to applicable guidelines, and making recommendations on the need

for further investigation and / or remediation and management with respect to site

contamination.

The results of the contamination assessment prepared by Coffeys identified seven main

potential AECs within the areas being the subject of this assessment based on the past

and present activities identified from the site history study. The AECs were noted as

having between a low and moderate likelihood of contamination.




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In general, preliminary soil sampling in the majority of the areas assessed did not show

evidence of contamination. Soil contamination was noted in the central western part of

the proposed packing plant (Lot 5 DP 825808) in a relatively small area that appears to

contain some fill materials and ramping west towards the neighbouring properties. This

area recorded petroleum hydrocarbon contamination and asbestos contamination in the

form of some fibre cement fragments. The asbestos identified could present a health

issue for users of the site and during redevelopment. According to Coffeys this part of

the proposed packing plant requires further assessment and remediation/management

with respect to the identified contamination.

WorkCover NSW regards fibro in soil as ‘friable asbestos material’, that is ‘asbestos

inappropriately buried (i.e. not in accordance to any environmental legislative

requirements) (Ref: WorkCover NSW: Your Guide to Working with Asbestos, Safety

guidelines and requirements for working with asbestos, dated 20 March 2003).

When handling such materials the work must be carried out by appropriately qualified

and licensed contractors in accordance with all relevant codes of practice and standards

such as National Occupational Health and Safety Commission (2005): Code of Practice

for the Safe Removal of Asbestos (2nd Ed)[NOHSC:2002(2005)]. Excavated materials

with fibre cement will also be regarded as asbestos waste and require disposal to an

appropriately licensed facility.

Remediation of the asbestos contamination is likely to involve excavation and offsite

disposal of asbestos contaminated fill. The general steps in the process include:

• Developing an Asbestos Removal Plan;

• Removal of the affected materials under supervision of a suitably licensed AS1

asbestos removal contractor;

• Carrying out NATA accredited air monitoring throughout the duration of the

remediation works;

• Disposal of asbestos contaminated material to a waste facility licensed to accept

asbestos waste; and

• Validation sampling of the resulting excavation.

This would address the identified contamination issue with no further management

required.

Depending on the volume of material assessed to be removed, this option can be costly

due to the relatively high disposal costs.




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An alternative form of management could involve encapsulation on site. Encapsulation

may be restricted due to the site development works including a basement excavation.

Concentrations of the potential chemicals of concern tested in other parts of the

assessment areas did not suggest evidence of soil contamination. There were some

access restrictions in areas of the Shoalhaven Starches Plant due to the presence of

existing infrastructure. Based on the results of this assessment, the potential for

widespread soil contamination that would preclude these areas from being redeveloped

for industrial landuse is considered to be low. Some relatively localised contamination

could exist from previous activities (particularly within the Shoalhaven Starches Plant). It

is Coffey’s understanding that the amount of soil disturbance in the Shoalhaven

Starches Plant areas is likely to be relatively limited and that structures would be

supported on driven piles.

According to Coffeys soils excavated from the site as part of site construction works

should be appropriately managed. If any evidence of potential contamination is

identified such as odorous soils, stained, soils, unusually discoloured soil, etc. then

Coffeys should be contacted to make an assessment of these soils for contamination.

Excess soil that requires disposal offsite should be appropriately classified based on the

DECC (2008) Waste Classification Guidelines. If practical during construction, Coffeys

recommend that fill soils in the upper parts of the soil profile be kept separate to

underlying natural soils as these generally have a higher likelihood of being impacted.

Elevated concentrations of zinc and lead were noted in groundwater sampled from one

well within the proposed packing plant site above drinking water and/or protection of

freshwater aquatic ecosystem trigger values. At this stage the source of the zinc

concentration is not known and could be associated with background concentrations.

Groundwater across all the proposed upgrade areas was not assessed as part of this

study. It would generally appear that there is a low to moderate likelihood that

groundwater is impacted at the sites. Further testing would be required to better assess

the groundwater for beneficial reuses, if this was necessary Coffeys would recommend

that if groundwater is intersected as part of construction works and requires

management, that this groundwater be appropriately tested.

Conclusion – Site Contamination

In terms of site contamination and this project, Coffeys conclude:

“The results of this contamination assessment identified seven main potential AECs within the areas being the subject of this assessment based on the past and present activities identified from the site history study. The AECs




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were noted as having between a low and moderate likelihood of contamination.

In general, preliminary soil sampling in the majority of the areas assessed did not show evidence of contamination. Soil contamination was noted in the central western part of the proposed packing plant (Lot 5 DP 825808) in a relatively small area that appears to contain some fill materials and ramping west towards the neighbouring properties. This area recorded petroleum hydrocarbon contamination and asbestos contamination in the form of some fibre cement fragments. The asbestos identified could present a health issue for users of the site and during redevelopment. This part of the proposed packing plant requires further assessment and remediation/management with respect to the identified contamination.

WorkCover NSW regards fibro in soil as ‘friable asbestos material’, that is ‘asbestos inappropriately buried (i.e. not in accordance to any environmental legislative requirements) (Ref: WorkCover NSW: Your Guide to Working with Asbestos, Safety guidelines and requirements for working with asbestos, dated 20 March 2003).

When handling such materials the work must be carried out by appropriately qualified and licensed contractors in accordance with all relevant codes of practice and standards such as National Occupational Health and Safety Commission (2005): Code of Practice for the Safe Removal of Asbestos (2nd Ed) NOHSC:2002 (2005)]. Excavated materials with fibre cement will also be regarded as asbestos waste and require disposal to an appropriately licensed facility.

Remediation of the asbestos contamination is likely to involve excavation and offsite disposal of asbestos contaminated fill. The general steps in the process include:

• Developing an Asbestos Removal Plan;

• Removal of the affected materials under supervision of a suitably licensed AS1 asbestos removal contractor;

• Carrying out NATA accredited air monitoring throughout the duration of the remediation works;

• Disposal of asbestos contaminated material to a waste facility licensed to accept asbestos waste; and

• Validation sampling of the resulting excavation.

This would address the identified contamination issue with no further management required.

Depending on the volume of material assessed to be removed, this option can be costly due to the relatively high disposal costs.

An alternative form of management could involve encapsulation on site. Encapsulation may be restricted due to the site development works including a basement excavation.




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Concentrations of the potential chemicals of concern tested in other parts of the assessment areas did not suggest evidence of soil contamination. There were some access restrictions in areas of the Shoalhaven Starches Plant due to the presence of existing infrastructure. Based on the results of this assessment, the potential for widespread soil contamination that would preclude these areas from being redeveloped for industrial landuse is considered to be low. Some relatively localised contamination could exist from previous activities (particularly within the Shoalhaven Starches Plant). We are of the understanding that the amount of soil disturbance in the Shoalhaven Starches Plant areas is likely to be relatively limited and that structures would be supported on driven piles.

Soils excavated from the site as part of site construction works should be appropriately managed. If any evidence of potential contamination is identified such as odorous soils, stained, soils, unusually discoloured soil etc. then Coffey Environments should be contacted to make an assessment of these soils for contamination.

Excess soil that requires disposal offsite should be appropriately classified based on the DECC (2008) Waste Classification Guidelines. If practical during construction, we would recommend that fill soils in the upper parts of the soil profile be kept separate to underlying natural soils as these generally have a higher likelihood of being impacted.

Elevated concentrations of zinc and lead were noted in groundwater sampled from one well within the proposed packing plant above drinking water and/or protection of freshwater aquatic ecosystem trigger values. At this stage the source of the zinc concentration is not known and could be associated with background concentrations. Groundwater across all the proposed upgrade areas was not assessed as part of this study. It would generally appear that there is a low to moderate likelihood that groundwater is impacted at the sites. Further testing would be required to better assess the groundwater for beneficial reuses, if this was required. We would recommend that if groundwater is intersected as part of construction works and requires management, that this groundwater be appropriately tested.”

In light of the recommendations of Coffeys in terms of site contamination, Shoalhaven

Starches will commit to engaging a suitably qualified consultant (such as Coffeys) to

prepare a Scope of Works to investigate the best means of remediating asbestos

contamination on this portion of the site. This Scope of Works will investigate which

approach either:

• development of an Asbestos Removal Plan; or

• encapsulation.

Is the preferred approach for treating asbestos contamination on this site. This is the

preferred approach as it will enable detailed construction plans to be considered; and

enable a detailed costing of the two alternatives to be considered.




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Shoalhaven Starches also commit to ensuring that all contractors involved in

construction works on the site are instructed that if there is any evidence of potential

contamination (as evidenced by odorous soils, stained soils, unusually discoloured soils)

then Coffey Environments (or other suitably qualified consultant) will be contacted

immediately to make an assessment of these soils for contamination.

Shoalhaven Starches also undertake to ensure that all excess soil that requires disposal

offsite will be classified in accordance with the DECC (2008) Waste Classification

Guidelines.

Shoalhaven Starches will also undertake to ensure that fill soils in the upper parts of the

soil profile will be kept separate to underlying natural soils.

In terms of groundwater, Shoalhaven Starches in conjunction with a suitable qualified

consultant will commit to appropriately testing groundwater if groundwater is intersected

as part of any construction works.

7.6 NOISE

Shoalhaven Starches engaged The Acoustic Group to undertake an acoustical

assessment for the proposed ethanol upgrade. A copy of The Acoustic Group’s report

forms Annexure Q(i) to this EA. This section of the EA is based upon the findings of

this assessment.

7.6.1 Ethanol Upgrade Acoustic Design Targets

7.6.1.1 Factory Site

The Director-General of Planning’s requirements for this project required an audit of the

existing plant noise emission. This Audit was carried out by The Acoustic Group in

March 2008. The Acoustic Group report (38.3849.R50 dated 5th June, 2008)

(Annexure Q(ii) found compliance with noise conditions issued by the NSW EPA (now

part of the DECC).

The acoustic audit nominated noise criteria for the Ethanol Upgrade project, based upon

the Shoalhaven Starches Noise Reduction Program 7 (PRP7) and Chapter 12 of the

EPA’s Industrial Noise Policy (INP).

The current EPA Licence issued for the subject premises requires the company to

achieve specific noise contribution levels at four reference residential boundaries

nominated to the south and north as follows:




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The LA10(15 minute) sound pressure level contribution generated from the site must not exceed the following levels when measured at or near the boundary of any residential premises:

- 38 dB(A) at locations in Terara on the south side of the Shoalhaven River;

- 38 dB(A) at locations in Nowra on the south side of the Shoalhaven River;

- 42 dB(A) at locations in Meroo Street, Bomaderry; and

- 40 dB(A) at other residential locations in Bomaderry.

For this project based upon the findings of The Acoustic Group, the residential noise

emission target has been set at 15 dB(A) below the EPA Licence noise limits at the

reference location targets so as to ensure the upgrade does not increase the site noise

emission levels. The noise emission targets for the project are therefore as follows:

The LA10 (15 minute) sound pressure level contribution generated from the Ethanol Upgrade must not exceed the following levels when measured at or near the boundary of any residential premises:

- 23 dB(A) at locations in Terara on the south side of the Shoalhaven River;

- 23 dB(A) at locations in Nowra on the south side of the Shoalhaven River;

- 27 dB(A) at locations in Meroo Street, Bomaderry; and

- 25 dB(A) at other residential locations in Bomaderry.

The noise design target, if taken as a Leq(15 minutes) goal 15 dB(A) below the EPA Licence

criteria, according to The Acoustic Group will ensure that the INP intrusive noise goal is

satisfied with a significant safety margin.

As the above noise limit is 15 dB below the License Conditions then compliance with

that criterion will result in the INP amenity noise target automatically being satisfied

according to The Acoustic Group.

7.6.1.1 Traffic and Rail Movements

There are four major routes that can be utilised by trucks to/from from the site. Route 1

is west along Bolong Road and then north along the Princess Highway (19% of the

traffic). Route 2 is north along Railway Street then north along Meroo Road (58% of the

traffic). Route 3 is north along Railway Street then west along Cambewarra Road (16%

of the traffic). Route 4 is along Bolong Road then south along the Princess Highway

(7% of the traffic).

During the night time (10:00 pm to 7:00 am) there will be a maximum of 19 additional

truck movements in the night which averages out to 2 per hour. Therefore the most




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affected residential location will be on Railway Street which can have a maximum of

2 truck movements per hour during the night time.

With respect to the day time (7:00 am to 10:00 pm), there will be a maximum of

19 additional movements in the day which averages out to 1 per hour.

With respect to train movements, there are currently at most two train movements during

the night time period (one movement before midnight and one after midnight). On a

weekly basis there are nine night time train movements per week (six movements before

midnight and three movements after midnight) but not equally distributed throughout the

week, ie. not all days of the week have the two train movements during the night time

period. The proposal will not result in more than the current maximum of two train

movements for each night time period. The proposal will generate a maximum of two

train movements during the night time period for every day of the week. This will result

on a weekly basis fourteen night time train movements per week.

The INP covers truck and rail movements whilst on the subject land, but such traffic

movements when external to the site fall under different criteria.

For road traffic, the relevant guidelines are the NSW EPA’s Environmental Criteria for

Road Traffic Noise (“ECRTN”). The critical location with respect to additional traffic,

according to The Acoustic Group, are the residences on Railway Street which in acoustic

terms can be classified as a collector road (whilst Cambewarra Road and Meroo Road

would be classified as arterial/subarterial). Development type 8 (identified as

developments with potential to create additional traffic on collector road) in Table 1 of the

ECTN has a day time criterion of Leq(1hr) 60 dB(A) and a night time criterion of Leq(1hr) 55

dB(A). Under the technical notes to the table, notes vii and ix proposes that traffic from

the development should not lead to an increase in existing noise levels of more than 2

dB.

Existing rail traffic is assessed under the noise control guideline Chapter 163 of the NSW

EPA’s Environmental Noise Control Manual (“ENCM”). This guideline sets out noise

levels in relation to rail movements as they may impact upon residential receivers. The

criterion specifies a 24 hour Leq level of 60 dB(A) for existing operations with a maximum

passby level of 85 dB(A).

In 2003 the Rail Infrastructure Corporation and the State Rail Authority issued an Interim

Guideline For Councils which has a internal day time criterion of an Leq(1hr) 40 dB(A) and

an internal night time criterion of an Leq(1hr) 35 dB(A) with all windows and doors closed.

A typical attenuation from an external space into an internal space with all windows and




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doors closed is 20-25 dB(A). On a conservative basis utilising the 20 dB(A) attenuation

will result in the external goal of an Leq(1hr) 60 dB(A) for the day time and an Leq(1hr)

55 dB(A) for the night time.

7.6.2 Acoustic Assessment

7.6.2.1 The Factory Site

The majority of equipment associated with this proposal that are of a high noise emission

are housed in concrete rooms with the external building envelope in colourbond or

composite wall/roof systems. The proposal involves the following equipment:

1 x Product Dryer (and its associated equipment)

3 x Fermenters (with associated pumps and motors)

6 x Additional Fermenter cooling towers

1 x Molecular Sieve and associated 2 x cooling towers

8 x Additional DDG cooling towers

6 x DDG Dryers (and its associated equipment)

1 x DDG Pellet Plant

1 x Odour Scrubber

1 x Evaporator

1 x Co-Generator

1 x Gas-fired Boiler

1 x Packing Plant

Container Loading area (Forklift)

9 x Blowers at the Manildra Environmental Farm

2 x Emergency Fire System pumps

For the purpose of assessing the noise controls associated with the nominated plant The

Acoustic Group have run the EM computer model for Shoalhaven Starches under neutral

weather conditions to establish in-plant shielding and the attenuation to the reference

residential locations.

The manufacturer’s noise data for the various plant times has been expressed generally

in a dB(A) format rather than octave bands. For this ENM assessment The Acoustic

Group utilised a broadband spectrum to derive the attenuation to residential reference

locations.




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According to The Acoustic Group, analysis of the proposed plant items located within

buildings without any additional noise control measures would exceed the overall EPA

noise limits and obviously the more stringent criteria nominated for the project.

As a result of the analysis carried out by The Acoustic Group in order to meet

compliance with the residential design goals the following noise control measures are

required, according to The Acoustic Group, to be implemented.

Product Dryer

Equipment will be housed in a building that will be constructed of Ultrapanels having an

Rw of not less than 35. The upper 3 floors of the building and the roof is to be

constructed of material having an Rw of not less than 17 (Colorbond or similar).

Equipment that has a sound power level above 80 dB(A) is to be enclosed in a separate

room with the walls and ceiling/floor having an Rw of not less than 40.

Fermenters

No additional noise control measures are necessary according to The Acoustic Group

except for the transfer pumps which are to be enclosed with material having an Rw of

not less than 15.

Fermenters – Cooling Towers

During the night time period, the fan speed of the 6 cooling towers is to be reduced to

60% of full fan speed. The fan speed reduction is to be automatically adjusted

(computer or time clock controlled) rather than by manual controls.

Molecular Sieve

The molecular sieve pumps and compressors associated with this proposal are to be

enclosed with material having an Rw of not less than 35.

Molecular Sieve – Cooling Towers




Cooling Towers







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Water pumps numbers 1 - 4 are to have noise control measures (or replaced) in order to

have a sound pressure level of 68 dB(A) at 1 metre.

DDG Dryers

The majority of the equipment will be housed in a building that will be constructed of

Ultrapanels having an Rw of not less than 35.

Any equipment that has a sound power level above 90 dB(A) is to be enclosed in a

separate room with the walls and ceiling/floor having an Rw of not less than 40.

DDG Pellet Plant

The majority of the equipment will be housed in a building that will be constructed of

Ultrapanels having an Rw of not less than 35.

Any equipment that has a sound power level above 90 dB(A) is to be enclosed in a

separate room with the walls and ceiling/floor having an Rw of not less than 40.

Odour Scrubber

The equipment will be housed in a building (walls and ceilings/roof) that will be

constructed of material having an Rw of not less than 35 such as Ultrapanels.

Evaporator

The majority of the equipment will be housed in a building (walls and ceilings/roof) which

has to be constructed of material of an Rw of not less than 25.

The two turbo fans are to be enclosed in a separate room with the walls and ceiling/floor

having an Rw of not less than 40.

Co-Generator

At this stage of the development application, sound level data for the Co-Generator is

not available. However the maximum sound power level of 93 dB(A) from all discharges

from the Co-Generator building has been derived to maintain compliance with the design

criteria.

Gas Fired Boiler

The Acoustic Group were provided with the sound power level of the discharge duct of

the boiler. To maintain compliance with the design criteria the discharge of the duct is to

achieve an attenuation of 25 dB(A) so that the sound pressure level from the discharge

duct does not exceed 72 dB(A) at 1 metre.




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Packing Plant

All walls and the roof/ceiling of the packing plant is to be constructed of material having

an Rw of not less than 35 dB(A).

Container Loading Area

The forklift (new item) that is used for the loading and stacking of containers is to have a

maximum sound pressure level of 80 dB(A) at 1 metre.

The northern end of the container loading area is to have a solid masonry wall not less

than 8.5 metres in height and the western and eastern end of the container loading area

is to have a solid masonry wall not less than 8 metres in height.

The Acoustic Group have been advised that there will be no train movements on the

spur line that forms part of the container loading area between the night time period of

10:00 pm to 7:00 am.

As part of the management plan of the container loading area during the night time

period (10:00 pm to 7:00 am) the forklift trucks will only stack two containers high at

locations within 10 metres from the wall and only one container high above the ground

for locations more than 10 metres from the wall. No loading of the train in the proposed

container loading area will take place during the night time period.

Blowers at Manildra Environmental Farm

With respect to the blowers, The Acoustic Group have been advised that they will have

enclosures that result in a sound pressure level of 70 dB(A) at 1 metre.

Emergency Fire System

The fire pumps are only utilised for emergency and a maximum of 1 hour per week

during the day time for testing purposes only, and do not form part of the EPA criteria

under normal plant operations.

With the above noise control measures, according to The Acoustic Group, the noise

contribution from this proposal will meet the design goals.

7.6.2.2 Road Traffic

With respect to road traffic noise associated with the proposal the critical acoustic issue

according to The Acoustic Group relates to truck movements during the night time period

of 10:00 pm to 7:00 am.

Figure 26 nominates four traffic routes. Section 2.7 of the traffic impact assessment

carried out by Christopher Stapleton Consulting identifies the percentage break up of




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truck movements whilst Section 4.2 identifies that the proposal could generate up to an

additional 19 heavy vehicles per day (38 movements). Shoalhaven Starches advise that

their planning regime has the additional truck movements evenly distributed throughout

the day and night with the majority of the trucks seeking to travel to and from the north.

Ambient noise levels were carried out by The Acoustic Group in connection with the

previous PRP7 project with the use of unattended loggers located adjacent to the truck

routes. These revealed ambient traffic Leq in the day time period significantly greater

than that during the night time period. As the trucks will be evenly distributed throughout

the day and night, any traffic noise contribution arising from the proposal would not

approach the EPA’s ECRTN criteria for the different road classifications in the day time

period, whilst night time movements are expected to generate some minor increases in

the traffic/ambient Leq levels.

The EPA has a separate noise policy identified as Environmental Criteria for Road

Traffic Noise (“ECRTN”) which relates to road traffic movements. Table 1 of the ECRTN

nominates criteria for different road classifications for noise emission level for daytime

and night time operations. Category 7 covers land use developments with potential to

create additional traffic on existing freeway/arterials and nominates a daytime criteria of

60 dB(A) Leq and a night time criterion of 55 dB(A). If either criterion is already

exceeded, the EPA place a specification that traffic arising from the development should

not lead to an increase in existing noise levels of more than 2 dB.

EPA Road Traffic Development Category 8 is identified as a land use development with

potential to create additional traffic on collector roads, where the daytime criteria is

expressed as an Leq 60 dB(A) for a one hour period and night time criterion of Leq 55

dB(A) (one hour). Again if either criterion is already exceeded, the traffic arising from the

development should not lead to an increase in existing levels more than 2 dB.

A guide to the terms used in Table 1, of the ECRTN, indicates that an existing

freeway/arterial road is a road that includes sub-arterial roads and is a road that handles

through traffic, with characteristically heavy and continuous traffic flows during peak

periods, where through traffic is passing through a locality bound for another locality.

A collector road is defined as a road in a built-up area that collects local traffic leaving a

locality and connects to a sub-arterial road. In the previous PRP7 application it was

concluded that from the aerial maps for the area that Railway Street leading up to

Cambewarra Road could be considered a collector road or a subarterial road, however

Cambewarra Road, Meroo Road and Bolong Road (west of the development) were




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identified as sub-arterial roads, and would be classified as freeway/arterial roads for the

purposes of the ECRTN.

Therefore the criterion applied to the assessment of road traffic varies upon: road

classification; whether the EPA criterion is already exceeded or not; and whether as a

result of a development the criteria would be exceeded.

According to The Acoustic Group, Railway Street experiences the majority of night time

traffic (14 movements during the night). The traffic movements do not impact on

residential dwellings until the intersection of Railway Street and Cambewarra Road at

the railway overpass. For an equitable distribution of heavy vehicles, the residential

dwellings north of the railway bridge could experience an additional 14 truck movements

during the night or 1.56 truck movements per hour.

Ambient logger measurements conducted on the property immediately south of

Cambewarra Road, but between Meroo Road and the railway line obtained a night time

Leq(9 hr) of 54.6 dB(A) thereby leading to an overall EPA noise limit for trucks of 56.6

dB(A).

Attended measurements during the day time found Leq(1 hr) levels greater than that

recorded for the PRP7 project but individual truck movements similar to the values

identified in the PRP7 assessment.

Attended measurements carried out by The Acoustic Group of heavy vehicle operations

at the intersection of Cambewarra Road and Railway Street found a mean sound

exposure level (SEL) 85.3 dB(A) at the nearest residential boundary. If Railway Street is

considered to be a collector road on the basis of two vehicle movements in any one hour

would result in a sound level contribution of 49.2 dB(A) at the residential facade which

when added to the existing night time ambient Leq(9 hr) of 54.6 dB(A) would result in an

overall Leq level of 55.7 dB(A) which complies with the EPA design target.

If however the above intersection is to be ranked as a sub-arterial road, then it is

necessary to assess the resultant Leq level from the passage of 14 movements during

the night that would result in an Leq(9 hr) contribution of 48.2 dB(A). This contribution when

added to the existing Leq(9 hr) of 54.6 dB(A) would realise a total Leq level of 55.5 dB(A).

This level satisfies the ECRTN requirements.

Similarly, traffic movements on Meroo Road north of Cambewarra Road (route 2) would

be subject to an additional 11 truck movements throughout the night. Route 2 is

designated as a sub-arterial road and therefore under the ECRTN is categorised as a

freeway/arterial road. From an average SEL of 83.8 dB(A) at the residential boundary,




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the Leq (9 hr) contribution determined at the residential façade from the 11 truck

movements would be 45.6 dB(A). When added to a night time Leq level of 54.6 dB(A)

results in a Leq level of 55.1 dB(A) which satisfies the ECRTN requirements.

Similarly, traffic movements on Cambewarra Road (route 3) would be subject to an

additional 3 truck movements throughout the night. Route 3 is designated as a sub-

arterial road and therefore under the ECRTN is categorised as a freeway/arterial road.

From an average SEL of 83.5 dB(A) at the residential boundary, the Leq (9 hr) contribution

determined at the residential facade from the 3 truck movements would be 39.7 dB(A).

When added to a night time Leq level of 55.8 dB(A) results in a Leq level of 55.8 dB(A)

which satisfies the ECRTN requirements.

7.6.2.3 Rail Traffic

In terms of additional rail traffic noise, a rail traffic noise assessment was carried out by

The Acoustic Group for the previous PRP7 project and the measurement results were

presented in the PRP7 acoustic assessment report prepared by Steven Cooper

Acoustics (report number 32.3849.R17:NSC dated December 2002).

For the critical night time period, the subject proposal doesn’t use the packing plant spur

line at night. Additional train movements arising from the proposal and the existing train

movements during the night time period not exceed 2 movements (one departure and

one arrival).

The trains (when arriving from the north) would move onto the existing spur line (ie. will

not go into Bomaderry Station), crossing Railway Street and continue round at a slow

speed to enter the site. When departing, the train would cross Railway Street and then

travel along the spur line out onto the main line. The train then reverses back down the

main line to a siding at Bomaderry Station where the train remains until its scheduled

departure to Sydney.

At the nearest residence to the railway line (Railway Street) the following sound

exposure levels from the different train activities were derived:

Activity SEL dB(A) Leq(1 hr) dB(A)

Train crossing Bolong Road 77.7 42

Train up onto main line and reverse to station 88.4 53

Train arrived on main line 87.0 52

Train departure on main line 81.2 46




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All the above activities would not occur within a one hour period. Activities that could fit

into a one hour period would include a train arriving on the main line and crossing

Railway Street; or the train crossing Railway Street and up to the main line and reversing

to the station. On a worst case basis, the activities in one hour would be for the train

crossing Railway Street and up to the main line and reversing to the station resulting in

an SEL of 88.4 dB(A) which is an external Leq(1hr) of 53 dB(A). This external level would

for closed window situation reduce an Leq(1hr) of 28-33 dB(A) and would therefore,

according to The Acoustic Group, be below the Interim Guidelines for Rail Traffic Noise.

7.6.3 Construction Noise

7.6.3.1 Construction Noise Control Goals

Construction noise is not controlled by the Company’s EPA Licence and utilises different

noise indices to that for the operating plant.

The current EPA Licence conditions relate to criteria derived from night time ambient

measurements and the EPA Environmental Noise Control Manual (the “ENCM”) that

utilised the concept of an average maximum (L10) noise level versus the average

minimum (L90 background) level.

Contained in the ENCM are a set of Noise Control Guidelines for various types of noise

emission sources. A Construction Site Noise Guideline is set out in Chapter 171 of the

ENCM and indicates the following criteria may be specified in a development consent or

building application:

The LA10,T noise levels emanating from the construction site shall not exceed the background levels by the following criteria, in the interval specified:

- 20 dB(A) for construction activity period up to 4 weeks

- 10 dB(A) for construction activity period over 4 weeks and up to 26 weeks.

- 5 dB(A) for construction activity period over 26 weeks.

Time Restrictions of Monday to Friday, 7am to 6pm, and Saturday 7am to 1pm if audible on residential premises and no construction work to take place on Sundays or Public Holidays.

The ENCM indicates the LA10,T sound pressure levels shall be measured or computed at

any point within one metre of the boundary of the nearest affected residential premises.

Measurements shall be made over a 10 to 15 minute interval (T), using the “fast”

response of the sound level meter. The LA10,T is the A-weighted sound pressure level

which is exceeded for 10 percent of the time over the measurement interval T.




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As the sites associated with this proposal are already level, cleared ground the principal

noise emission construction activities for the erection of the buildings are associated with

the piling and foundation works associated with the proposed concrete slabs, and

pouring of the slabs. This work is carried out on an infrequent basis. The construction of

the buildings proper and fit out of the buildings generates significantly lower noise levels.

Based on other construction projects at Shoalhaven Starches there will be piles driven

throughout the site of the various slabs, where such piles are driven by a pile driving rig.

The total works associated with all the slabs will take a period of up to 4 months, being

3 months for all the pile driving operations (occurring on an infrequent basis) and 1 week

for the preparation/pouring of the slabs. Whilst pile driving operations will be undertaken

over extended periods; the individual pile driving operations will occur over discrete short

periods. The actual pouring of all the slabs will be conducted over a month.

This same form of construction (including the driving of piles) has occurred on the

Shoalhaven Starches site over the last eleven years without receipt of any noise

complaints.

Due to the location of the various plant items being significantly removed from residential

premises and the existing ambient levels, primarily as a result of traffic in the area,

normal construction activities are not envisaged to create a noise impact. However, the

proposed concrete foundation slabs requires the driving of piles (by a pile rig) into the

ground, which creates a greater level of noise than for normal building and excavation

works.

On past experience, according to The Acoustic Group, it is not envisaged there would be

any noise disturbance in relation to the piling operations for the proposed concrete slabs,

if such operations were restricted to the daytime period.

The Company has an ongoing building works program that has not given rise to any

noise complaints and as such the forming and pouring of the slab and any other site

works associated with the subject application is not envisaged to generate any noise

impacts.

7.6.3.2 Noise Emission from Construction of the Plant

In order to consider the likelihood of noise emission from the proposed construction, The

Acoustic Group have utilised noise data from previous projects, as set out in below.




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Sound Power Noise Emission Levels of Plant Items – dB(A)

Typical Plant Max. Noise Level Sound Power Item or Equipment L10 at 7 metres Level

Bulldozer Caterpillar D7 88 113

Front End Loader Wheeled 90 115

Crane Truck Mounted 85 110

Piling Hammer for piles 93 118

The piling operations occur on an infrequent basis and are spread over a period of time

which reduces the noise impact from the operations.

Therefore other than the piling operations for the packing plant, all other construction

activities would not exceed background +10 dB(A) and therefore would satisfy the EPA

secondary criterion of background +10 dB(A) for construction works less than 26 weeks.

7.6.4 Conclusion

The Acoustical Assessment prepared by The Acoustic Group makes the following

conclusion with respect to this proposal.

“An acoustical assessment of the proposed Ethanol Upgrade at the Shoalhaven Starches plant has been undertaken with reference to the INP requirements and the EPA Licence for the plant.

A site noise audit was carried out in March 2008 and found compliance with noise conditions issued by the EPA.

For the proposed Ethanol Upgrade a design target of 15 dB(A) below the EPA Licence conditions at the residential reference locations has been used so as to ensure the upgrade does not increase the current site noise emission levels.

Other than for day time construction activities, the critical period for noise assessment is the night time period of 10 pm to 7 am where the ambient approaches the EPA Licence limits.

Various noise control measures (in terms of construction and management) are set out in the report above.

An assessment of rail traffic movements during the night time period revealed compliance with the EPA rail traffic noise guidelines and the RIC Interim Guidelines.

An assessment of the additional truck movements as a result of the Ethanol Upgrade project has revealed compliance with the EPA’s ECRTN requirements.”

It is evident from the Acoustic Assessment carried out by The Acoustic Group based

upon a site noise audit the existing operations comply with the noise requirements set




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out in the Company’s EPL. This demonstrates Shoalhaven Starches’ ongoing

commitment to ensure its operations not only satisfy its EPL requirements, but also

minimise its impacts on the local community. The Company has over the years made

significant investment to ensure its activities comply with these requirements.

Based upon the findings of the noise audit, noise emission design targets have been

devised by The Acoustic Group for the proposed Ethanol Upgrade Project of 15 dB(A)

below the EPL conditions at the residential reference location. This noise emission

design target will ensure the works associated with the upgrade will not increase the

site’s current noise emissions.

In order to achieve these noise design targets the assessment carried out by The

Acoustic Group sets out specific noise control measures for the various plant involved

with this proposal. These controls are set out in Section 7.6.2.1 of this EA.

The Assessment also confirms that the additional heavy vehicle movements associated

with the proposal will comply with the relevant DECC guidelines.

The Acoustic Assessment also identifies that rail movements associated with the

proposal will also comply with DECC guidelines, provided the Packing Plant railway

siding/spur line is not used at night.

In terms of construction activities, the main issue that arises with this proposal relates to

noise emissions from piling and foundation works. These works however are carried out

on an infrequent basis during discrete periods during the construction period. This form

of construction and foundation work has occurred over the site for many years without

the receipt of noise complaints.

7.7 TRANSPORT, ACCESS AND PARKING

The EA is supported by a Traffic Impact Assessment prepared by Christopher Stapleton

Consulting (CSC). A copy of this assessment the forms Annexure G to this EA. This

section of the EA is based upon the findings of this Traffic Impact Assessment.

7.7.1 Local Traffic Network

The Princes Highway

The local traffic network is dominated by the Princes Highway, which provides primary

north-south access through the north and south of Nowra. Through the majority of the

‘local’ network shown in Figure 26, the Princes Highway has a speed limit of 70km/h, but

there are also local restrictions (School Zones) which reduce the speed limit during the

morning commuter peak period and early afternoon commuter peak period..




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Nowra CDB

& South

Coastal Route

North

Moss

Vale

North to Kiama,

Wollongong, Sydney

Shoalhaven

Starches

Bomaderry

Industrial

Map reproduced with permission of UBD. Copyright Universal Publishers Pty Ltd DG 01-08

Figure 26: Transport Routes Around the Site




Page 213

The Princes Highway through the local network generally provides a minimum of

4 lanes, with additional capacity at major junctions controlled by signalised intersections

and high capacity roundabouts.

With heavy vehicle limits on the coastal routes to the north (Route 293 – Bolong Road)

the vast majority of heavy vehicle traffic from Bomaderry uses the Princes Highway for

sub-regional and regional access, principally entering/departing the Princes Highway at

Meroo Road and Bolong Road.

According to CSC, the Princes Highway provides the following key intersections:

• Princes Highway and Bolong Road (Signalised)

• Princes Highway and Cambewarra Road (Roundabout)

• Princes Highway and Meroo Road (Priority)

• Princes Highway and Illaroo Road/Shoalhaven River Bridge

Route 293 (Bolong Road)

An alternative to the Princes Highway for north-south traffic is provided by Bolong Road,

which generally follows the coastline between Gerringong and Nowra. While heavy

vehicle restrictions (5 t weight) apply north of Bomaderry, according to CSC the RTA

have determined that there is significant potential for new development to the north-east

of Nowra which would be serviced by Bolong Road.

Bolong Road provides the following key intersections:

• Princes Highway and Bolong Road (Signalised)

• Bolong Road and Meroo Street (roundabout)

• Bolong Road and Railway Street

• Bolong Road and Site Access Points

Additional Bomaderry Routes

Railway Street, Cambewarra Road and Meroo Road (north of Cambewarra Road) form

an important access route through Bomaderry for local industrial developments,

including the Shoalhaven Starches. Some weight/size restrictions apply to a small

section of this route, specifically Railway Street south of Cambewarra Road to the public

weighbridge; Cambewarra Road; and Meroo Road between Cambewarra Road and

McIntyre Way.




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According to CSC, these restrictions apply only to restricted access vehicles; which

means only vehicles over 19 m or over 50 t are prohibited from this small section of the

local network. All vehicles under 19 m in length or 50 t in weight are permitted to use

this section of the network, while Railway Street (between Bolong Road and the public

weighbridge) and Meroo Road (north of McIntyre Way) are designated by the RTA for

restricted access vehicle routes for vehicles up to 26 m in length and over 50 t.

Restricted access vehicles are also able to turn to and from Bolong Road to Railway

Street for access to the weighbridge.

7.7.2 Existing Traffic Summary

Intersections

According to CSC, even under super-peak site and recreational design hour conditions,

the key site and local intersections operate at a good - satisfactory level of service (LoS),

with low average delays and significant spare capacity. The regional intersection of the

Princes Highway and Bolong Road experiences moderate delays and maintains an

overall LoS “B”; the worst delay (for the right hand turn from Bolong Road) is

experienced by very few vehicles; in turn, this low volume does not impact as greatly on

the left turning traffic flow, not on the opposed southbound movement (particularly in the

AM peak hour).

Critically, according to CSC, the proposal will not add to the flows at the intersection of

Princes Highway and Bolong Road by more than a few vehicles in any peak hour, and

with consideration of the existing surveyed super-peak site conditions it is probable that

the future generation of the site under standard operating conditions will actually be

lower than the generation used in this analysis of existing conditions.

Bomaderry ‘Local’ Flows

The traffic surveys – and specifically the heavy vehicle log undertaken by Shoalhaven

Starches - clearly identify preferred heavy vehicle routes through Bomaderry for access

between Shoalhaven Starches (and other local industrial development) and the north

and west (and specifically the Princes Highway north). It must be acknowledged that the

overwhelming majority of heavy vehicle using the local routes are fully entitled to do so.

Notwithstanding, the log survey does indicate that a small number of AustRoads Class

10 vehicles (generally restricted access vehicles) use this route; information is not

available to indicate whether these vehicles exceeded the limits imposed on the route,

but it is the view of CSC that this does occur occasionally.




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Finally, it is important to note that the traffic surveys – and specifically the survey of the

Bolong Road and Railway Street intersection - identify a heavy vehicle trip demand to

other local industries located west of Shoalhaven Starches, ie. by no means is

Shoalhaven Starches the only generator of heavy vehicles in the local network, and

specifically along both the local industrial route and at the intersection of the Princes

Highway and Bolong Road.

7.7.3 Regional Access

Regional access for the Site is provided via Bolong Road to the Princes Highway; from

the Princes Highway, trips distribute to the north and south, as well as to the west (via a

northern route through Albion Park to the Hume Highway, or via Moss Vale). Light

vehicle trips disperse from the Site along all local routes, including Bolong Road

eastbound for trips to the north (via Gerroa).

Heavy vehicles are not permitted to use Bolong Road (eastbound) for regional trips, and

restricted access vehicles are not permitted to use the Princes Highway south of Nowra,

nor the central portion of the Bomaderry industrial access route.

In general, heavy vehicles generated by Shoalhaven Starches use the following regional

routes:

North

• Via Bolong Road, Railway Street, Cambewarra Road and Meroo Road to the

Princes Highway.

• Via Bolong Road and the Princes Highway (generally restricted access vehicles

only).

South

• Via Bolong Road and the Princes Highway south.

• Via Bolong Road, Railway Street and Cambewarra Road (through Moss Vale).

• Via Bolong Road and the Princes Highway north through Mount Ousley and Wilton

(generally restricted access vehicles only).

West

• Via Bolong Road and the Princes Highway north (generally restricted access

vehicles only) through Mount Ousley and Wilton

• Via Bolong Road, Railway Street and Cambewarra Road (through Moss Vale)




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The percentage distribution of heavy vehicle trips to each of these shows the dominance

of the local Bomaderry route for access to and from the north. CSC note also that in

discussions with Council it was agreed that generally the only vehicles using the route

via the Princes Highway and Bolong Road were restricted access vehicles, ie. in general

all other vehicles from both the Site and other local industrial Sites in Bomaderry travel

via the local industrial route (when travelling between Bolong Road and the north and

west).

7.7.4 Site Access

Vehicle access to the Site is provided via four separate access points to Bolong Road.

Vehicle movements to these access points remain relatively constant throughout the

week; some small access changes occur at present when a train is stopped on-site,

requiring vehicles to [occasionally] depart via a different access point, the proposal will

provide additional rail siding capacity on-site, which is expected to eliminate temporary

rerouting demand.

It is also the case that at the time of that surveys were undertaken for the Traffic Impact

Assessment that construction work on-site resulted in some minor rerouting of trips.

This resulted in significantly higher than normal daily flows at Access Point 1, as well as

the rerouting of some vehicles to Access Point 3. The standard access operating

conditions which will be reinstated following the current construction period are detailed

below.

Access Point 1 (Eastern)

Access Point 1 is located at the eastern end of Shoalhaven Starches. The intersection

of this access point and Bolong Road is designed as a Type C intersection (as described

by AustRoads) and was developed after consultation with the RTA and Council as part

of a past upgrade of the Site.

The intersection design was specifically due to the access point being located in the

vicinity of the transition point of speed zones in Bolong Road (60 km/h – 100 km/h

eastbound, 100 km/h – 60 km/h westbound), rather than significant traffic volume or

sight distance issues.

Traffic flows show clearly that flows are moderate, particularly to and from Shoalhaven

Starches, and sight distance exceeds all design requirements in both directions.

Access Point 1 provides for:

• Ethanol trucks (arrival and departure).




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• Brewers trucks (arrival and departure).

• Glucose trucks (arrival and departure).

• Starch trucks (arrival and departure).

Access Point 2 (Central)

Access Point 2 is located to the east of the railway line, and directly adjacent to (east of)

a drainage culvert (Abernethy’s Creek). This intersection does not provide sufficient

width to allow an eastbound vehicle to pass a vehicle turning right into Shoalhaven

Starches, and as such a turning vehicle can delay eastbound vehicles. Overall though,

the intersection operates at a good LoS due to the low turning volumes, and the recent

provision of a pedestrian footbridge linking the pedestrian paths on the southern side of

Bolong Road has significantly improved pedestrian (and general) safety.

Council have referenced a previous consent condition for Shoalhaven Starches which

requires that the intersection of Access Point 2 be upgraded to provide a Type A

intersection, ie. a design which would allow an eastbound vehicle to pass a vehicle

turning right into the site. Final planning for this upgrade is currently underway, with a

draft design provided in Appendix A of the Traffic Impact Assessment (Annexure G).


• Minor office and staff vehicle demand.

• Brewers trucks (departure only).

• Bulk starch (arrival and departure).

• Glucose trucks (departure only).

Access Point 3 (Western)

Access Point 3 is located at the end of a spur that leads from the eastern portion of the

Shoalhaven Starches around behind smaller industrial units to a point adjacent (west) of

the Cleary Bros Concrete site. The spur continues to an intersection with Bolong Road.

This Type A intersection was recently upgraded, to provide a sealed pavement of the

immediate intersection and southern verge, in line with the recommendations of CSC

2002 PRP7 Traffic Report.

The access driveway from Bolong Road provides access to a small office and training

building, and to a small staff car park. Further to recent upgrade approvals, Access

Point 3 provides heavy vehicle access to and from the rear of the primary Site (via the

spur) and to staff car parking areas. Access Point 3 also provides access (egress) for




Page 218

the adjacent Cleary Bros site; the driveway and intersection with Bolong Road therefore

generates trips from the Site and from Cleary Bros.


• Staff vehicles (office, training and general staff arrival and departure).

• Coal trucks (arrival and departure).

• Stillage trucks (arrival and departure).

• Cleary Bros trucks (departure and occasional arrival).

Council have indicated a requirement for an extension of the sealed pavement at this

intersection, and greater definition of the Access Point 3 driveway itself. Final planning

for this upgrade is currently underway, with a draft design provided in Appendix A of the

Traffic Impact Assessment (Annexure G).

Access Point 4 (Car Park)

Manildra has recently purchased the former "Moorehouse" industrial site, which is

located west of the railway spur off Bolong Road. The site was specifically purchased in

order to provide a central car parking location for staff, as well as ancillary storage and

workshop space.

Access Point 4 provides separate ingress and egress driveways to Bolong Road. Both

driveways operate at a good level of service due to the low turning demands and good

sight distance.


• Staff vehicle parking.

• Minor service/workshop vehicle demands.

In discussions between CSC and Council staff, no issues were raised in regard to the

operation of the Access Point 4 driveways, though the surveys provided by Council

indicate that at times one of the driveway gates was closed, necessitating ingress and

egress from the same driveway.

CSC notes that these minor intersections are not formally designed as Type A

intersections. CSC indicate that they have observed vehicles passing a turning vehicle

(ingress driveway) as per a Type A intersection due to the width of the adjacent verge.

7.7.5 Pedestrian Access

Most pedestrian access demand is met on-site, with simple connector links between the

formal and informal parking areas and the primary work locations. Internally, most areas




Page 219

of Shoalhaven Starches have fixed pedestrian walkways – these are generally areas

where safety around heavy equipment and machinery is paramount. General access

demand from the on-site parking areas is accommodated by internal roads and

pathways. Pedestrian links between the western end of Shoalhaven Starches (offices,

training parking areas) and the primary work areas east of Abernethy’s Creek have been

improved through recent upgrade stages.

A minor but constant pedestrian demand is also generated along Bolong Road, a

demand which is not met by the current design of the carriageway (in the vicinity of

Access Point 2, and Abernethy’s Creek); as a result, pedestrians walk on the edge of the

carriageway between the existing footpaths east and west of the Creek.

This situation is currently in the process of being rectified by the development of a

pedestrian bridge adjacent to Bolong Road.

7.7.6 Traffic Generation

CSC commissioned a series of surveys to properly define the traffic generation of the

Site (and the local area). The survey locations and peak periods were fully discussed

with Council officers prior to their implementation.

In summary, Shoalhaven Starches (ie. August 2007, standard generation plus

construction generation) generated:

• A weekday average of approximately 1,400 light vehicle trips.

• A weekday average of approximately 300 heavy vehicle trips.

• An AM commuter peak hour generation of 113 light vehicle trips and 40 heavy

vehicle trips.

• A PM commuter peak hour generation of 104 light vehicle trips and 11 heavy vehicle

trips.

The surveyed AM peak period generation therefore represents approximately 10% of the

daily generation, while the surveyed PM peak generation represents approximately 7%

of daily generation. These percentages are entirely commensurate with a site that

operates 24 hours a day, and specifically generates staff peaks outside of the commuter

peak periods (ie. major shift changes occur early in the morning and early in the

afternoon). Additional interrogation of the traffic data provided by Council for the key

access points (Access Point 1 and Access Point 3) shows that the generation of heavy

vehicles during the commuter peak hour across the week represents less than 10% of

daily heavy vehicle generation.




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Importantly the survey period significantly overestimated the ‘standard’ generation of the

Site, specifically due to the high number of construction and contractor vehicle trips that

were occurring during the survey period.

Based on standard staff numbers, visitor numbers, and what is a small inter-trip demand

(where vehicles will simply drive from one access point to another via Bolong Road)

CSC have estimated the following ‘standard’ operating traffic generation for the Site; this

includes the additional ‘standard’ generation which will be generated following the

completion of the current on-site upgrade works:

• Approximately 800 – 900 light vehicle trips per day.

• Approximately 150 heavy vehicle trips per day.

These traffic flow figures are commensurate with traffic generation forecasts for the Site

from past upgrade proposal assessments.

Notwithstanding, CSC has assessed the existing and future operations of the local traffic

network based on the higher surveyed figures that include the contractor/construction

demand, and indeed these flows have also been factored (as per consultation with

Council) to represent recreational peak flows. This provides for a super peak-generation

assessment of the site, which in our opinion would therefore also provide an assessment

of future construction peak demands for this current proposal.

7.7.7 Light Vehicle Trip Distribution

Light vehicle trips (staff and visitors) distribute broadly to the following routes:

• Bolong Road to the east (Shoalhaven Heads).

• Bolong Road and the Princes Highway to the south (Nowra).

• Bolong Road, Railway Street and Meroo Road to the north and Bomaderry.

• Bolong Road, Railway Street and Cambewarra Road to the west and Bomaderry.

While vehicle trips are concentrated at Shoalhaven Starches – and specifically at Access

Point 3 and Access Point 4 – vehicles quickly disperse from Bolong Road via local

roads. The majority of staff reside in the local Bomaderry and Nowra area.

7.7.8 Heavy Vehicle Trip Distribution

The distribution of heavy trips to the local network has been raised by Council as an

important issue in the assessment of the upgrade proposal.




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General Heavy Vehicle Distribution

The general distribution of trips to the local and regional road network can be determined

with reference to the heavy vehicle log survey. The log shows the following general

heavy vehicle distribution over a 24 hour period:

• 19% of trips utilise Route 1, Bolong Road and Princes Highway, for trips to and from

the north.

• 58% of trips utilise Route 2, Bolong Road, Railway Street, Cambewarra Road and

Meroo Road to the Princes Highway for trips to and from the north.

• 16% of trips utilise Route 3, Bolong Road, Railway Street and Cambewarra Road for

trips to and from the west.

• 7% of trips utilise Route 4, Bolong Road and Princes Highway for trips to and from

the south.

Restricted Access Vehicle Movements

The Site generates a number of types of heavy vehicles, being rigid trucks; semi-trailers;

‘truck and dog” combinations; and “B-Doubles”.

According to CSC there is evidence that a small number of restricted access vehicles

may use the restricted route. Some 8 Class 10 vehicle trips were logged as utilising

Route 2 for trips to and from the north over the survey week, and an additional 8 Class

10 vehicle trips were logged as utilising Route 3 for trips to and from the west over the

survey week. It is possible that a percentage of these vehicles exceeded the restricted

vehicle access limits.

Shoalhaven Starches has policies in place which detail the routes required for restricted

access vehicles to access the Site; these policies specifically extend to private

contractors. CSC acknowledges that these policies do not guarantee that the occasional

restricted access vehicle will not use the local route to and from the Princes Highway.

Notwithstanding, the heavy vehicle log and the results of the fixed counters

strongly indicate that there is no systemic use of the local routes by restricted

access vehicle generated by the Site, or indeed generated by other local industrial

sites.

VKT, Route Speed and General Transport Costs

An important issue in reviewing the current distribution of heavy vehicles through the

local road network to the Princes Highway north of Bomaderry is the minimisation of




Page 222

vehicle kilometres travelled (VKT), and with it general emission and time costs, that the

local routes provide.

VKT is a measurement of total trip distance, and is normally associated with a relative

travel cost. VKT has become an increasingly important measurement of ‘impacts’

associated with developments, and is a key consideration of the RTA, Department of

Planning and Department of Transport. If a vehicle is required to change to a new route

that was (for example) 1 km longer than the existing route, there would not be any

immediate indication of a cost increase. However, considering the cost per kilometre of

a trip and multiplying that cost over a year, the costs start to add up. Travel time, with

consideration of congestion and other limiting factors, is also relevant.

Shoalhaven Starches’ generated vehicles – and specifically heavy vehicles - using the

local route through Bomaderry (and particularly via Meroo Road) utilise this route

because it is generally faster – particularly during commuter peak periods when flows

are heavier and School Zone restrictions are also in place along the Highway - and

because it is shorter than the Princes Highway route by approximately 1.5km. If these

trips, small in number as they are, were forced to use the Princes Highway route during

these periods, there could be a resulting increase in costs per annum, as well as

increased time and emission costs.

The most important efficiency strategy implemented at Shoalhaven Starches to reduce

VKT – and indeed all traffic related costs and impacts - is the use of rail; this massively

reduces the impacts of heavy vehicle generation of the Site, heavy vehicle movements in

the local area, and impacts at local intersections.

CSC is of the opinion that the zoning of the Bomaderry industrial area by Council

specifically consents to the movement of industrial vehicles through the local residential

areas; indeed, Meroo Road north of Cambewarra Road is specifically zoned by the RTA

for even restricted access vehicles. It is therefore unrealistic to suggest that the heavy

vehicle traffic generated by these industrial sites be required to deviate significantly to

avoid all residential areas. Further, it is not appropriate for the Site itself to be

considered external to Bomaderry; it is an integral and longstanding facility in

Bomaderry, and therefore it is incorrect to suggest that heavy vehicle trips generated by

the Site along the local route are ‘through trips’ as stated by Council in correspondence

to the DoP.

Finally, Christopher Stapleton Consulting Pty Ltd notes that the Department of Planning

in its assessment of the Shoalhaven Starches Flour Mill upgrade construction stage




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(Report on the Assessment of Development Application No. DA-391-11-2002)

specifically required that vehicles be routed by the local route:

The Department is satisfied that the local road network would not be significantly affected by construction traffic but recommends that truck movements are undertaken, where practicable, outside peak hours and that the utilisation of the Bolong Road and Railway Street intersection is maximised (in order to minimise use of the Bolong Road / Princes Highway intersection which is busier).

Notwithstanding, there is an obligation to maximise amenity for local residential, and of

course to ensure that the Proposal does not exacerbate impacts in the local

area/intersections. This is most critically achieved by a proposal that will generate

only up to 8 additional peak hour trips, and achieves the vast majority of its

transport task using rail.

7.7.9 Rail Access

Shoalhaven Starches transports the majority of its raw materials and export product via

rail; this is one of the major benefits of the location of the subject site (by design), as it

significantly reduces heavy vehicle movements that would otherwise be required.

The Bolong Road level crossing is used by Shoalhaven Starches’ two rail operators to

transport flour, containers, mill mix and sorghum to and from the Site. The current

number of trains servicing the Site is:

• 7 Flour trains per week.

• 2 Container trains per week.

• 1 Sorghum or additional container train per week.

Over the course of the year, trains transport approximately 700,000 tonnes of materials

and product to and from Shoalhaven Starches; this is the equivalent of some 28,000

heavy vehicle loads, or 56,000 heavy vehicle trips per year that are not required due to

the provision of rail transport. On an average day, rail replaces approximately 200 heavy

vehicle trips that would otherwise be generated in the local area.

The weekly 10 inbound trains also generate 10 outbound train movements, thereby

totalling 20 train movements each week. However, as the sidings currently available at

Shoalhaven Starches do not accommodate full trains (ie. the trains are longer than the

available length of track on-site) there is currently a need to divide trains at Bolong Road

and leave parts of the train stowed between Railway Road and Bolong Road. This

shunting requirement creates a further 20 – 30 rail movements (across Bolong Road)

each week.




Page 224

The total weekly rail usage of the Bolong Road Level Crossing is therefore

approximately 40 – 50 rail movements per week, ie. 40 – 50 closures of Bolong Road to

facilitate the movement of trains.

Shoalhaven Starches owns and maintains the lights and bells at Bolong Road as a

major risk management mitigation measure. Notwithstanding, Council in recent and past

correspondence relating to the Site have indicated a requirement for an upgrade of the

railway crossing to provide boom-gates. Additionally, community representatives have

requested information relating to ability to extend the use of rail.

7.7.10 Parking

Shoalhaven Starches generates a peak parking demand through the day when it has a

full complement of shift and day staff on-site, and (as is generally the case) there is also

a small visitor demand. Based on observations by CSC and a review of the survey data,

it is clear that there is a relatively minor amount of car sharing and virtually no other

significant car driver reduction measures (ie. public transport) available.

Based on these factors, CSC estimate that the peak parking demand of the Site during

standard operating periods is between 160 to 180 spaces.

The capacity of on-site parking has recently been augmented by the purchase of the

“Moorehouse” site at Bolong Road; this area is now utilised as the primary (central) car

parking, and provides capacity for approximately 110 vehicles. Along with other

dedicated parking areas, the total on-site parking provision exceeds 230 parking spaces.

The standard operating parking demand has in recent times (and during the survey

period) been augmented by contractor parking, such that the construction super-peak

demand may be as high as 300 parking spaces. While areas around the Site have been

established by Shoalhaven Starches for parking to offset this temporary peak demand, it

is apparent that off-site parking is (or at least until recently was) occurring.

Parking off-site (on the Bolong Street verge adjacent to Access Point 1) was observed

by CSC. This is contractor parking, the accommodation of which is provided by the

on-site capacity and temporary parking areas, but which was still observed to be

occurring.

Shoalhaven Starches have instructed all staff and contractors in regard to the availability

of on-site parking. CSC also note that Council is determined to enforce the parking

restrictions, a determination which CSC fully supports.




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7.7.11 Council, RTA and Community Issues

Prior to examining the specific details and potential impacts of the Proposal, it is

important to review the comments of Council in their correspondence to the Department

of Planning, in which they outline a number of issues (and specifically outstanding

conditions) associated with earlier upgrade approvals for the Site, along with general

issues associated with the Proposal.

These issues, along with comments provided by the RTA, are detailed in the recent

Director General Requirements (Annexure A).

Shoalhaven City Council Issues

Outstanding Conditions

It is acknowledged by Shoalhaven Starches that there are currently outstanding consent

conditions in relation to past approvals for the Site. CSC is not aware of the reasons for

the non-compliance, but has examined each of the conditions detailed by Council.

Pedestrian Footbridge

Conditioned works (from earlier Site upgrade proposals) include a pedestrian footbridge

on the southern side of Bolong Road across Abernethy’s Creek.

This condition has been addressed on an interim basis with the recent construction of a

temporary pedestrian footbridge linking the existing footpaths either side of Abernethy’s

drain. The design and construction of the footbridge was completed following

consultation and approval by Council. The provision of a permanent footbridge crossing

will need to be designed and integrated with the proposed upgrading works associated

with Access 2.

Access Point 2

Conditioned works (from earlier Site upgrade proposals) at Access Point 2 include a

requirement to increase the passing area at the intersection adjacent to Abernethy’s

Creek, which in turn will require a widening of the culvert. Specifically, the condition

requires full compliance with a Type A (AustRoads) design.

CSC recommended the retention of access (two way) at Access Point 2 – and

specifically the retention of right hand turn access from Bolong Road - requires the

implementation of the upgrade design of the intersection, in line with the design

approved by the RTA and Council.

This recommendation has been adopted by Shoalhaven Starches as part of the

Proposal, and is included in the current works for the recently approved Flour Mill




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Project. A revised draft design – provided to CSC by Allen Price & Associates on behalf

of Shoalhaven Starches – is shown in Appendix A to the Traffic Assessment.

Access Point 3

An upgrade of the intersection of Access Point 3 at Bolong Road to provide a formal

Type A intersection was completed in 2003 but Council has indicated (in

correspondence) that the upgrade should be extended to include the driveway and

adjacent shoulder seal to limit ongoing maintenance and safety related issues.

It is the recommendation of CSC that a full seal of the carriageway should be

implemented which includes the eastbound passing verge; additionally, the access

driveway for at least the distance from Bolong Road to the proposed controlled access

point to the site south of the Cleary Bros access point should be formalised, specifically

as a concrete driveway similar to the adjacent Cleary Bros entry driveway from Bolong

Road.

This recommendation has been adopted by Shoalhaven Starches as part of the

Proposal.

Railway Crossing

Council has indicated that there is an outstanding condition associated with an earlier

(1990’s) upgrade proposal which required an upgrade of the railway crossing when

traffic flows and rail movements met the RTA warrants for boom gates; it is the opinion of

Council that such warrants are currently met.

Based upon advice provided by Mr Glen Dawe, National Manager Rail Transport of the

Manildra Group, boom gates are not currently required. This opinion is based on the

following:

• Firstly, and most significantly, the Proposal will actually see a reduction in the

number of rail movements at the crossing through the introduction of greater rail

capacity (length) on-site south of Bolong Road, and siding capacity on the proposed

packaging plant site on the north side of Bolong Road.

• The use of Bolong Road must also be considered in the light of the train operations

which cross this level crossing:

� Trains approach the crossing and STOP.

� The crossings Lights and Bells, which have recently been upgraded to meet

Standards, are then activated.

� Locomotives sound their Horn and are then escorted across the crossing.




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� Train speed is walking pace, ie. less than 4 km/hr.

� As locomotives are in full view of road traffic in all directions with an approach

visibility of 250 metres, and are stationary before using the crossing, full

recognition of impending rail usage of the crossing is available to all motorists.

� There are many examples elsewhere where rail movements exceed those at

Bolong Road and manual crossing protection solely is provided.

� Manildra owns and maintains the lights and bells at Bolong Road as a major

risk management mitigation measure.

According to CSC having regard to the available warrants, it is their opinion that the

warrants specifically refer to faster moving (ie. suburban) trains, and certainly not

circumstances where the movement is at such a slow pace, with good sight distance and

accompanied by lights and bells as for the existing crossing.

Further details of the means by which the Proposal will actually reduce rail movements

at Bolong Road are provided below.

Hannigans Lane

Council has indicated that sight distances available at the Hannigans Lane Access to the

Environmental Farm are marginally obstructed by adjacent foliage; while Council has

acknowledged that this is a minor issue, it is nonetheless the recommendation of CSC

that pruning (or the like) be undertaken to ensure that sight distances are provided. This

recommendation has been adopted by Shoalhaven Starches as part of the Proposal.

Packaging Plant Access

Based upon discussions between CSC and Council staff, subsequent to the submissions

from SCC to the DoP and which formed the basis of the DGRs for the project, Council

has indicated a preference for access to the packaging plant to be provided solely from

Railway Street, rather than the proposed one-way (heavy vehicle) system with egress

via Bolong Road (left turn in only) and egress to Railway Street.

CSC would agree that where possible, access is better provided from an access road

such as Railway Street for all movements, particularly given Railway Street is already

used for predominantly industrial traffic. Notwithstanding, CSC support the Bolong Road

access proposal based on the provision of the safest and most efficient means of

providing access to the packaging plant site while maintaining:

• The capacity for rail movements and handling to be accommodated north of Bolong

Road, and thereby allowing train movements across Bolong Road to be halved. It




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would be all but impossible to provide this level of rail benefit while accommodating

the turning paths required from a single access point to Railway Street.

• An appropriate area for the operation of the large container forklift which will be

employed on the packaging plant site; the size of the site along with the handling,

storage and rail requirements prevents the provision of suitable turning facilities for

heavy vehicles entering from Railway Street.

• Minimal impacts on existing traffic (in Bolong Road).

CSC acknowledges that the proposal will introduce a new (very minor) access point to

Bolong Road. However, this left in only access point can be efficiently incorporated into

the design for the Access Point 2 upgrade, and will include a short deceleration lane.

Most importantly, the access point will generate only 15 daily vehicle trips, with all heavy

vehicle egress (along with staff ingress and egress) to Railway Street.

Heavy Vehicles through Bomaderry

Council has over a number of years investigated the use of heavy vehicles in local

roads, particularly along the local access routes between the local industrial areas and

the Princes Highway to the north-west. These specifically include Railway Street, Meroo

Road and Cambewarra Road.

CSC has identified the (albeit minimal) use of local routes by restricted access vehicles.

This is not appropriate, and it will be imperative that Shoalhaven Starches further

emphasise to drivers the required route via Bolong Road and the Princes Highway;

enforcement may also be required, and would be supported by CSC.

However, the local routes are entirely appropriate for the vast majority of vehicles

(excluding restricted access vehicles) and provide efficient routing for the majority of

heavy vehicle trips, not only from the Site but from the broader Bomaderry industrial

precinct to the east of the residential areas. Indeed, these local routes provide the only

access for a large number of the industrial sites in Bomaderry, and as such would be

virtually impossible to restrict.

It is also recognised by CSC that the potential resulting increases (of additional local

heavy vehicle restrictions) in traffic flows at the intersection of the Princes Highway &

Bolong Road may reduce its performance, such that there would be a greater potential

for multiple heavy vehicle movements blocking the southbound movement from Bolong

Road (based on the current intersection geometry). This would in all probability require

an upgrade of the intersection – and specifically the widening of the westbound

approach to provide a lengthened right hand turn lane.




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CSC notes that Council has not raised any specific traffic capacity issues in relation to

the movement of heavy vehicles along the local routes, and that in consultation with the

Community Consultation Group no specific issues were raised in regard to heavy vehicle

movements. Certainly, it is possible that there may be some general amenity concerns

that could be raised in a review of heavy vehicle movements, but no specific issues have

been defined, and Council has provided no information relating to specific incidents or

issues relating to heavy vehicles in the area.

CSC acknowledges that the Proposal will introduce a new (very minor) access point to


the design for the Access Point 2 upgrade, and will include a short deceleration lane.

RTA Issues

The RTA, in both their correspondence to the Department of Planning of January 2008

and in our discussions has raised essentially the same issues as those raised by

Council. These include:

• The fulfilment of outstanding consent conditions relating to the Bolong Road access

points.

• The proper design of those access points.

• Any potential construction impacts.

Significantly, the RTA expressed no significant issue with the local heavy vehicle route,

or with the operation of local intersections.

As with their consultation with Council, CSC has engaged fully with the RTA to ensure

that all local and site specific issues have been examined appropriately. From a regional

traffic perspective, this has specifically included a review of future traffic flows along the

primary regional routes, and the establishment of an appropriate forecast horizon and

average growth rate for the assessment.

Community Issues

Based upon initial discussion with the Community Consultation Group the only traffic

related issue was the potential use of rail to convey a greater proportion of materials

from the Site, and specifically a greater proportion of materials generated by the current

proposal. It is acknowledged that this request relates largely to residential amenity and

the movement of heavy vehicles (in general).




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In responding to this issue, CSC notes that the current use of rail by Shoalhaven

Starches allows for the removal of up to 200 heavy vehicle trips a day from local roads,

and up to 56,000 heavy vehicle movements per year.

For the current proposal, the overwhelming majority of additional materials and product

will also be transported by rail, resulting in up to 4 additional trains per week servicing

the Site; this is estimated to represent the equivalent of a further 20,000 heavy vehicle

trips per year.

The existing heavy vehicle trips generated by the Site are servicing end users not readily

or practicably accessed by rail. This includes the delivery of some materials to the Site,

but more importantly the transportation of product to regional and interstate centres

where the use of rail is not possible (due to the time demands of product storage).

In the future, the transportation of materials and product to regional and interstate sites

not readily accessible by rail will require 19 additional heavy vehicles per day, or the

generation of 38 additional heavy vehicle trips.

It is important to note that ‘back-loading’ – where a full train arrives and unloads, and

thence is reloaded before departing – is not possible due to the different carriage

requirements for the transportation of materials as opposed to export product.

Container trains are loaded in and out of Nowra. Trains coming in bring in empty

containers and trains departing take loaded containers by rail to Port Botany for export;

this reflects Government policy, which is seeking to achieve a rail market share of 25%

for all Botany/Port related movements.

7.7.12 Site Access

The Site will retain the existing primary access points off Bolong Road, while the

packaging plant will require a new ingress (left in) only driveway from Bolong Road, and

an upgraded of the existing access point off Railway Street. The design and operation

of each of the access points is described below.

Access Point 1

With reference to the traffic generation estimates an additional 15 heavy vehicles

(30 movements) will utilise Access Point 1 daily; while the surveyed contractor vehicle

movements will be removed by the time standard operation commence, CSC have in

their assessment retained the surveyed flows to provide a super-peak assessment which

in their opinion would represent significantly higher flows than under future standard




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operations. In their view this approach provides an appropriate approach, as it is difficult

to envisage construction demands exceeding those experienced in August 2007.

Shoalhaven Starches and CSC have on numerous occasions requested a review of the

speed limit provided in Bolong Road adjacent to Access Point 1. It is CSC’s view that it

would be appropriate to relocate the speed zone to the east, such that vehicles were

travelling at an urban speed (60 km/h) past the Site.

According to CSC, Shoalhaven Starches should certainly be considered as part of the

consolidated urban environment. It is difficult to reconcile the significant speed

reductions provided by the RTA and Council along other parts of the road network

(including the Princes Highway) where speeds are reduced from 80 km/h or even

100 km/h to 40 km/h or 50 km/h well outside of activity zones; yet at the Site, which is

clearly designated as the start of the urban (Bomaderry) environment, it has not been

possible to relocate the speed thresholds to the east.

Access Point 2

The proposal does not increase movements at Access Point 2; nonetheless, the

operation of Access Point 2 will be enhanced by the implementation of an upgraded

Type A intersection.

Access Point 3

An additional 4 heavy vehicles (8 movements) and 10 staff vehicles (20 movements) will

utilise Access Point 3 daily in association with the ethanol upgrade; conversely,

15 heavy vehicles (30 movements) and 5 staff vehicles (10 movements) will be removed

from Access Point 3 daily through the development of the packaging plant, and therefore

the relocation of the current on-site packaging plant vehicle generation.

In response to Council’s identification of the design issues at Access Point 3, CSC has

recommended that the full carriageway (including the passing area on the northern

verge) be sealed, and that a concrete driveway be constructed which extends south to

the entry point to the Site, which will be controlled by a boom gate.

Access Point 4

The capacity of the Access 4 car park is generally fully utilised at present, though

additional shift staff (outside of peak hours) would potentially be able to use the car park.

As for Access Point 3, additional staff movements generated by the proposal will largely

be offset by the relocation of the packaging plant.




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According to CSC this ingress point was at times also being used for egress. It was the

observation of Council staff that on some occasions the egress driveway gate was

closed, requiring egress from the ‘ingress’ driveway. CSC notes that the intersection

surveys did not record this occurring during the peak periods (presumably because both

ingress and egress gates were open).

It is the recommendation of CSC that both the ingress and egress gates be open at all

times to allow for the separation of ingress and egress.

Packaging Plant Access

Access to the packaging plant is proposed via a one way system with ingress via Bolong

Road (left turn in only) and egress to Railway Street.

This access proposal has been adopted as it provides the greatest level of safety and

efficiency for both vehicles generated to and past the access points, while retaining the

capacity on-site (packaging plant) to maximise operational safety and efficiency by

removing conflicts between heavy vehicles and forklifts servicing the container loading

area adjacent to the proposed packing plant.

The packaging plant access design proposal does not necessitate the provision of large

turning paths (on-site) such as would be required to accommodate heavy vehicles

accessing the packaging plant solely from Railway Street. With a one-way system in

place between Bolong Road and Railway Street, the design provides for:

• The accommodation of significant additional rail infrastructure, including siding,

handling and loading facilities. By providing the means to split (and store) trains

north of Bolong Road (ie. on the packaging plant site) the Proposal will halve the

number of rail movement across Bolong Road daily.

• An appropriate area for the operation of the large container forklift, which will be

employed on the packaging plant site.

• A restricted level of access provision (left turn in only for heavy vehicles only) that

would not impact the existing Bolong Road traffic flows.

CSC acknowledges that the proposal will introduce a new (very minor) access point to


the design for the Access Point 2 upgrade, and will include an appropriately designed

deceleration lane. Most importantly, the access point will generate only 15 daily vehicle

trips, with all egress (along with staff ingress and egress) to Railway Street.




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An existing driveway is located on the southern boundary of the packaging plant site to

Railway Street; this driveway will be upgraded to conform to AS 2890.2:2002, specifically

to allow for the movement of heavy vehicles from the Site. Access for staff vehicles

(ingress and egress) will also be provided via the Railway Street driveway.

7.7.13 Traffic Generation

As discussed above, the Proposal will see only a very minor increase in the light

and heavy vehicle traffic generation of the Site, with the majority of the extra (and

existing) transport task accomplished by rail.

Rail Transport

The proposal will generate an additional 4 trains per week to the Site. The use of rail

already saves the generation of up to 56,000 heavy vehicle trips per year. The provision

of 4 additional trains per week is estimated to eliminate some 20,000 heavy vehicle trips

per year, or 50 – 100 heavy vehicle trips daily.

The new packaging plant (incorporating the packaging facility, warehouse and container

storage area) will be served by a new siding between Railway Road and Bolong Road.

This new facility, with its dedicated siding, will eliminate container related train and

shunting movements from Bolong Road level crossing, ie. eliminate the existing demand

for access to the primary Bolong Road Site.

Additionally, the rail siding capacity at the existing Site will include the lengthening of the

current siding and the creation of a new loop siding south of Bolong Road. This will

eliminate the need for flour and sorghum trains to divide at Bolong Road to allow for

unloading at their respective receival pits. As a result of these siding works, full trains

will be able to be accommodated on-site north of Bolong Road, and will have the

requisite siding space to allow unloading without impinging on Bolong Road.

The net result of these proposals will be a reduction in train movements across the

Bolong Road level crossing by up to 26 movements per week, including 8 – 10 fewer

container movements (facilitated by the new packaging plant infrastructure) and 16 fewer

shunting movements (facilitated by the new Site rail siding infrastructure).

Therefore while the Site will increase the amount of materials moved by train,

thereby maintaining the minimum low heavy vehicle trip demand, the total usage

of the Bolong Road level crossing will be 16 – 24 movements per week. This

represents approximately a 50% reduction in the current crossings of Bolong

Road.




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The precise timing of these movements to and from the Site – therefore requiring a

closure of Bolong Road – are not known at this time, as the movements will require

scheduling with the rail network demands and are controlled by rail authorities and

therefore out of the control of Shoalhaven Starches. However, in CSC view the closure

of Bolong Road for the short period of time for the train to cross wholly into the Site will

continue to have no significant impact on flows in Bolong Road. CSC recommend that

the movements – as far as possible – continue to occur outside of peak periods.

Road Transport Demand and Staff Trips

For those materials and products not deliverable by rail, heavy vehicle transport will be

required. The proposal will marginally increase heavy vehicle and staff movements to

the Site, though these movements will be largely off-set by the relocation of the

packaging plant and its associated movements.

The Site traffic generation will increase as follows:

• An additional 30 daily ethanol heavy vehicle trips via Access Point 1. Based on

existing and future ethanol delivery vehicle demands, it is estimated that

approximately 50% of these vehicles will be articulated vehicles, and 50% restricted

access vehicles.

• An additional 8 daily DDG heavy vehicle trips to Access Point 3, offset entirely by

the relocation of 30 daily heavy vehicle trips rips to the proposed off-site packaging

plant. Heavy vehicle trips to Access Point 3 would therefore decrease from current

levels by 22 trips per day. Based on existing and future characteristics DDG

delivery vehicle demands, it is estimated that majority of these vehicles will be

articulated vehicles.

• An additional 50 daily staff vehicle trips across Access Points 3 and 4, off-set

significantly by the relocation of 30 daily packaging plant staff trips, (ie. a net

increase of approximately 20 trips daily).

• A total of 30 -50 light vehicles and 30 heavy vehicles accessing the packaging plant

daily, with 15 heavy vehicle ingress trips daily from Bolong Road, and 15 heavy

vehicle trips along with 30 - 50 staff trips daily to Railway Street. Based on existing

and future packaging demands, it is estimated that the majority of these vehicles will

be articulated vehicles.




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Future Daily Trips

With consideration of the additional traffic demands outlined above, the daily traffic

generation of the primary Bolong Road Site will increase by a total of 8 heavy vehicle

trips daily, and by 20 light vehicle trips daily.

The total future traffic flow of the primary Bolong Road site would therefore increase to

approximately 920 light vehicle trips and 160 heavy vehicle trips daily under standard

operation periods.

The packaging plant site will generate 30 heavy vehicle trips and 30 light vehicle trips

daily.

Future Peak Hour Trips

With reference to the existing peak hour movements and a review of distribution patterns

(time) of the ethanol and DDG components of the existing Site (and indeed all heavy

vehicle distribution patterns, which overwhelmingly show a propensity for trips outside of

the peak periods as is standard based on operational peaks at a site operating 24 hours

a day), CSC has estimated that the proposal could generate an additional 8 vehicles to

the local network during a peak hour, including up to 4 heavy vehicles and 4 light (staff)

vehicles).

These generation characteristics tally also with the daily/hourly data breakdown from the

classifier counter surveys provided by SCC.

Trip Distribution

As discussed above, the proposal will see additional heavy vehicle trips being generated

to Access Point 1 but a reduction in trips to Access Point 3; additional light vehicle trips

will also be generated to Access Point 4 and other on-site parking areas accessed from

Access Point 3.

Based on the peak periods and accounting for a small additional redistribution of staff

parking trips and the other access points for general parking CSC has determined the

following distribution profile:

• Access Point 1 would generate up to a maximum 4 additional heavy vehicle trips in

the peak hour, being 2 ingress and 2 egress trips.

• Access Point 2 would generate no additional vehicle trips in the peak hour.

• Access Point 3 would generate up to a maximum 2 additional light vehicle trips but

up to 5 fewer heavy vehicle trip in the peak hour.




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• Access Point 4 would generate up to a maximum 2 additional light vehicle trips in

the peak hour.

• The packaging plant access point in Bolong Road would generate up to 3 heavy

vehicle trips and the Railway Street access point up to 2 heavy vehicle trips and 3

light vehicle trips in the peak hour.

Away from Shoalhaven Starches, the additional trips are expected to distribute to the

local road network in an identical manner to the current distribution. With ethanol

deliveries utilising both articulated vehicles and restricted access vehicles, and DDG

deliveries primarily articulated vehicles, the potential exists for up to 2 restricted access

vehicles to be generated during a peak hour, ie. to be generated to the key regional

intersection of the Princes Highway and Bolong Road. The remaining trips would be

distributed via the local industrial route. CSC again notes that at present no more than a

single restricted access vehicle was surveyed making the critical right hand turn

movement from Bolong Road to the Princes Highway in any single hour.

Staff vehicles will be distributed to the general local area via all available routes in the

peak hours, resulting in an additional 2 - 4 vehicles at the intersection of Bolong Street

and Railway Street, and 1 – 2 vehicles at the intersection of Princes Highway and

Bolong Road.

7.7.14 Future Intersection Performance

Even a cursory review of the additional traffic generation potential of the Proposal

according to CSC strongly indicates that the Proposal will have little impact in and

of itself on the future road network.

The estimated maximum increase in peak hour traffic flows – a total of 8 vehicle trips – is

dwarfed by the average annual increases in local flows such that the total additional trips

generated by the Proposal represent only a minor proportion of a single year’s average

growth in flows along Bolong Road.

CSC notes that average growth forecasts are in themselves based on the additional

minor generation of local areas, as well as broader new generators; that annual growth

is further based on a super-peak recreational flow that is appropriate for design

purposes, but significantly exceeds average weekday traffic flows.

Additionally, CSC would again stress that the site generated traffic flows used in their

assessment are themselves a significant overstatement of standard operations, given

that they include a large number of contractor vehicles working on earlier approved site

upgrades. The generation of these contractors alone during the survey period




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represents a significantly higher peak period generation than which would be

generated by the proposal, ie. the 'existing' conditions represent a Site generation

significantly in excess of the standard operations upon which traffic impacts would

generally be assessed, and significantly in excess of the standard operations which will

prevail following the implementation of the Proposal works.

Notwithstanding, CSC has examined the future intersection performance using SIDRA.

Following advice from Council, CSC has in the analysis modelled a higher cycle time to

reflect the operations of the RTA in accommodating additional traffic demands at key

regional intersections; the cycle time has been increased from 110 seconds to

130 seconds for the critical AM peak hour.

Additionally, the operations at the intersection of Bolong Road and Access Point 2 are

based on the provision of a Type A intersection as has been adopted by Shoalhaven

Starches for this intersection.

7.7.15 Minimising General Traffic Impacts

The most important works to be undertaken by Shoalhaven Starches to minimise any

potential impacts arising from upgrades of the site are the outstanding upgrade works at

Access Point 2 and Access Point 3; these are critical to the provision of safe and efficient

access for the Site into the future.

The design of this intersection is to be integrated with respect to the proposed

pedestrian crossing of Abernethy’s Creek; the proposed pedestrian/product overhead

bridge; and the vehicular access to the proposed Packing Plant. A conceptual design for

the upgrading of each of the access points to proposed development is included in

Figure 27.

Additionally, the provision of new rail infrastructure will significantly reduce the demand

for rail movements across Bolong Road to the benefit of motorists.

As discussed, Council has raised the potential of limiting or potentially excluding heavy

vehicle from the local industrial route through Bomaderry.

Council has in the past committed to heavy vehicle projects which have not eventuated.

For example, a heavy vehicle bypass (along, we understand, the alignment of Meroo

Road and then Railway Street) was proposed in the late 1990’s but has now been

abandoned. More recently, Council indicated a proposal to upgrade the pavement

surfaces along the route (for, we understand, noise attenuation and potentially some

widening benefits), but this project has yet to be confirmed. Council has also

FIG

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7

Fig

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27:

Tra

ffic

Ac

cess A

rra

ng

em

en

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acknowledged that it would be virtually impossible to impose load limits in the local roads

given that they service areas zoned for industrial development.

It is the opinion of CSC that at this time there are no compelling reasons to impose such

restrictions, particularly as these local routes are recognised and essential to the

provision of industrial access for the Bomaderry industrial precinct, which certainly

extends to the Site. Additionally:

• There is no apparent mechanism by which it would be possible to limit the use of the

local road by some industrial sites, yet retain their use by other industrial sites.

• There would be potential impacts at the intersection of the Princes Highway and

Bolong Road due to an increase in the number of vehicles – and specifically heavy

vehicles – making the right hand turn movement to the north. It is CSC’s opinion

that these impacts could be reduced by an upgrade of the intersection (increasing

the right hand turn lane capacity) but it would be unreasonable for Council to force

vehicles (from all local sites) to use this route and then impose costs on those site

operators. Further, there is not currently in place any mechanism by which a

contribution could be provided.

• It is certainly the case that if the site traffic (or indeed traffic from any specific

development) were to have a demonstrable impact, some action would be required.

However, this is not the case; there is no evidence that the few additional trips

generated by this proposal have any significant impact on its operation, with the

most significant potential for additional delay occurring simply as a result of

additional traffic flows (average annual growth) along the Princes Highway and

along Bolong Road.

It is the recommendation of CSC that Shoalhaven Starches commits to be involved in

any future consultation with the RTA and Council that examines the use of heavy

vehicles throughout the entire area, as it is certainly the case that Shoalhaven Starches

is a significant generator of heavy vehicle trips. However, it is inappropriate to suggest

that Shoalhaven Starches is the lone generator, with the traffic surveys clearly showing a

significant local heavy vehicle generation not directed to/from the site.

It is further recommended by CSC that should additional studies relating to more general

amenity issues show that the additional trips generated by the Proposal do have an

impact (on amenity) then additional impact minimisation measures must be assessed by

Shoalhaven Starches in consultation with Council, the RTA and the local community.




Page 239

Finally, CSC strongly support the enforcement of the existing restricted access vehicle

route restrictions. While there are transport benefits associated with the use of restricted

access vehicles, it is nonetheless the case that their operation along non-approved

routes is inappropriate.

7.7.16 Parking

Figure 28 provides a plan identifying car parking over the factory site. With the

acquisition of the “Moorehouse” site, the provision of parking for the site has been

significantly increased. The site currently provides approximately 259 formal parking

spaces, including:

• 21 spaces in the Main Office area.

• 12 spaces in the Project Office area.

• 14 spaces to the rear of the Project Office.

• 110 spaces in the “Moorehouse” maintenance workshop area car park accessed

from Access Point 4.

• 50 spaces in the DDG Loadout area.

• 52 contractor parking spaces to the south west of the site.

In this regard the following parking spaces are proposed to be provided:

• Maintenance workshop area (“Moorehouse”) – 40 spaces;

• Proposed Packing Plant – 34 spaces;

• East of coal storage area – 20 spaces.

Based on the above with an existing provision of 259 spaces and proposed additional 94

spaces the Shoalhaven Starches’ site will be available to provide a total of 353 spaces,

including both permanent and temporary contractor parking.

CSC has estimated the current peak parking demand – based on staff on-site and

minimal car driver reduction opportunities – at 180 parking spaces.

While an additional 15 staff would be on-site at any one time (5 office staff and 10 shift

staff) the Proposal will see 15 staff relocated to the new packaging plant, and as such

there is unlikely to be any significant increase in on-site parking demand; the 353

parking spaces to be provided on-site will provide in excess of peak demands.

FIG

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Fig

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28:

Pla

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den

tify

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car

park

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over

the

Facto

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ite

.




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According to CSC the parking currently available on-site would also accommodate the

bulk of additional demand that could be generated during super-peak periods, such as

during a construction period.

Given that parking areas will therefore be available on-site in excess of the combined

demand of both standard staff requirements plus contractor requirements, there is no

reason for parking to be generated off-site, and specifically in Bolong Road. CSC would

support any enforcement initiatives aimed at eliminating any remnant parking demand in

Bolong Road in contravention of existing parking restrictions.

7.7.17 Conclusions and Recommendations

Christopher Stapleton Consulting Pty Ltd has prepared a detailed and independent

assessment of the access, traffic and parking issues associated with the Proposal,

utilising available data, design standards and traffic analysis models. CSC conclude

that:

• Manildra is committed to the implementation of outstanding development consent conditions. These include a significant upgrade of Access Point 2 to full compliance with a Type A intersection, and incorporating a pedestrian access bridge (recently completed); and a further upgrade of Access Point 3 to limit ongoing maintenance.

• The Proposal will continue to utilise rail as a primary mode of transport, eliminating an additional demand for approximately 400 heavy vehicle trips per week. While the number of trains servicing the Site will increase (by 4 trains), the packaging plant site on the northern side of Bolong Road, along with additional on-site railway siding capacity, will reduce movements across Bolong Road to approximately half current the levels, i.e. halve the number of closures of Bolong Road at the existing railway crossing.

• The Proposal will generate up to 88 additional vehicle trips daily (24 hours) to the local road network; the additional peak hour generation of the Proposal to the local road network would be up to 8 vehicle trips. These very minor traffic increases can be accommodated by the same conditioned local road upgrades as required for the recent SSFM Project, and have no significant impact on the local traffic network.

• The provision of a one-way access system from Bolong Road to Railway Street for heavy vehicles accessing the packaging plant is required to provide for safe on-site access and handling, and to incorporate greater rail capacity which in turn will reduce rail crossings of Bolong Road.

• The utilisation of local industrial access routes by heavy vehicles is entirely appropriate and provides VKT, emission and time cost savings, as well as reducing impacts at key intersections.

• Parking is provided on-site and for the packaging plant in excess of the peak staff parking demand.




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The Traffic Impact Assessment prepared by CSC makes the following recommendations

to achieve appropriate transport outcomes on the Site:

i. Access Point 2 will be upgraded following approval of final design plans by the relevant local authorities. The upgrade will be implemented as part of the approved SSFM Project, and completed prior to the commencement of the operations provided for by this Proposal.

ii. Access Point 3 will be upgraded following approval of final design plans by the relevant local authorities. The upgrade will be implemented as part of the approved SSFM Project, and completed prior to the commencement of the operations provided for by this Proposal.

iii. A new left in only ingress driveway will be provided from Bolong Road to the packaging plant following approval of final design plans by the relevant local authorities.

iv. The packaging plant driveway to Railway Street will be upgraded to full compliance with the appropriate AS 2890.2:2002 design standards.

v. The gates providing access to the primary Site car park (Access Point 4) will remain open at all times to allow for the separation of ingress and egress movements; this recommendation has already be implemented by Manildra.

vi. That rail movements continue to be – as far as practicable – scheduled outside of local peak periods, and specifically outside of the morning and afternoon commuter peak periods, though it is acknowledged that Manildra does not have direct control over the scheduling of rail movements.

vii. That Manildra continues to provide heavy vehicle drivers with information and training in regard to the use of the designated restricted access vehicle route by restricted access vehicles, and the availability of on-site parking areas.

viii. That Manildra works constructively with SCC, the RTA and local community through any future implementation of local heavy vehicle route changes; this may include changes to the use of the local industrial vehicle route and key regional routes.

Following their assessment of the key issues associated with the proposal, and with the

application of the recommendations outlined above, Christopher Stapleton Consulting

Pty Ltd conclude that the proposal is supportable from an access, traffic and parking

perspective.

Whilst CSC recommend that road upgrading works associated with Access Points 2

and 3 are to be completed prior to the commencement of this project, Shoalhaven

Starches, as discussed with staff from the Department of Planning, commit to completing




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these works prior to the commencement of operation of the approved Flour Mill project.

This commitment is confirmed in Section 8.3.5 of this EA.

7.8 HAZARDS AND RISK

In general, risk assessment of industrial developments follows 5 basic steps:

• identification of potential hazards;

• an evaluation of safeguards to minimise the chance of occurrence of the identified

hazards and their impact;

• an assessment of the magnitude of the consequences of the identified hazards;

• an assessment of the likelihood of occurrence; and

• an assessment of the risk by a combination of the consequences and likelihoods

and comparison with tolerability criteria.

The Department of Planning has prepared a set of guidelines to help determine the level

required according to the nature of the development:

• Multi-level Risk Assessment (MRA) describes the level and extent of the analysis

reflecting the nature, scale, location of the proposed development;

• Hazardous Industry Planning Advisory Paper (HIPAP) No. 6 provides guidelines on

requirements of the analysis;

• Hazardous Industry Planning Advisory Paper (HIPAP) No. 4 provides the adopted

risk criteria for land use planning decisions;

• SEPP No. 33 provides a screening tool to determine whether a proposed

development is hazardous and offensive, whether it requires a PHA, whether the

PHA needs to be qualitative or quantitative and whether a detailed transportation

study is required.

Shoalhaven Starches engaged the services of GHD Pty Ltd to prepare a Preliminary

Hazard Assessment (PHA) for the proposal. A copy of this PHA forms Annexure F to

this EA. This section of the EA is based upon the findings of this report.

The PHA was completed in accordance with the screening criteria detailed in the State

Environmental Planning Policy (SEPP) 33 guideline of the then Department of Urban

Affairs and Planning (DUAP), now the DoP. The Hazard Assessment was completed in

accordance to Hazardous Industry Planning Advisory Paper (HIPAP) No. 6.




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The major hazards identified in the PHA were included in the Quantitative Risk

Assessment (QRA) which was completed using SAFETI (Software for the Assessment of

Fire, Explosion, Toxic Impact) and the risk criteria given in HIPAP No. 4 for off-site

impact.

The QRA included the existing operation and the new hazards introduced by the

proposed upgrade.

Hazard Identification

According to GHD the major hazards, introduced by the proposed upgrade, that have

potential for off-site impact are:

• Co-generation Plant: potential for fire and explosion associated with natural gas;

• Ethanol Loading Bay: Increased loading frequency associated with increased

ethanol production leading to increased likelihood of release of ethanol due to

human factors or mechanical failures;

• Gas Fired Boiler (150 tph steam).

The existing major hazards, included in the QRA, that have potential for off-site risk are:

• Ethanol Storage Tank Farm: the storage capacity will not change;

• Ethanol Loading Pump: will operate more frequently;

• Distillation Units;

• Molecular Sieves;

• Gas Fired Boiler No. 2.

The dust cloud explosion hazards are not included in this QRA. According to GHD a

separate risk assessment was completed for the dust cloud explosion during an earlier

plant upgrade last year and was demonstrated not to have off-site impact.

Frequency Analysis

The failure frequencies of equipment were calculated by GHD using failure rate data

obtained from the UK Health and Safety Executive (HSE) for pipes and equipment. The

UK HSE data is derived from off-shore operations in a harsh environment and hence is

considered to be conservative when applied to a clean on-shore process.

Consequence Assessment

Thermal radiation with respect to fire, and overpressure with respect to explosion,

associated with ethanol and natural gas were assessed.




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The ethanol fire was modelled as a pool fire and natural gas fire was modelled as a jet

fire. Overpressure was modelled as a vapour cloud explosion with respect to ethanol

vapour and natural gas.

Risk Assessment

The failure frequencies and consequences were combined in SAFETI to calculate the

risk contours for the Shoalhaven facility.

Individual Fatality Risk contours were calculated and overlaid on the map of the

Shoalhaven facility to show the impact zone. The Individual Risk results for the

nominated risk criteria of HIPAP No. 4 are given below in Figure 29.



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Fig

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The risk calculated for the existing operation and the proposed upgrade of the

Shoalhaven facility according to GHD, is acceptable as the risk contours are in

compliance with the nominated risk criteria of HIPAP No. 4. There are no sensitive

areas nearby the site affected by the operation.

The key information from the Individual Fatality Risk profile are:

• 50 x 10-6/yr risk contour around the ethanol production facility is within the site

boundary. The individual sites around the Manildra plant are not affected.

• The 5 x 10-6/yr to 0.5 x 10-6/yr risk contours go over the Bolong Road but does not

breach the risk criteria.

• The Cogeneration plant to be located in the south corner of the site does not breach

any risk criteria.

The off-site risk from the existing operation and the proposed modification is acceptable

according to GHD. However, opportunities for risk reduction should be continuously

reviewed and implemented.

Societal Risk

According to GHD, there are no residential or sensitive population close to the site to be

affected by a large incident on the site. The closest residential area is over 350 m away

to the west beyond the railway line.

Injury Risk

The closest residential area is over 350 m away from the ethanol facility and the

maximum distance from an explosion or fire is:

• 4.7 kW/m2 (70 m)

• 7 kPa (110 m)

Therefore according to GHD injury risk to people in the residential area is not possible

from a fire or explosion event in the ethanol facility.

Property Damage

There are no hazardous industries close to the site according to GHD to cause

escalation issue from an incident on the Manildra site.

• The overpressure of 14 kPa does not extend more than 70 m from the ethanol

facility. The explosion overpressure (14 kPa) from the co-generation unit does not




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exceed the boundary. Figures C1 and C2 in Appendix C of the PHA show the

explosion overpressure contours for the cogeneration unit and mol sieve.

• The thermal radiation of 23 kW/m2 does not extend beyond the site.

The PHA prepared by GHD concludes:

“The Quantitative Risk Assessment (QRA) as part of the Preliminary Hazard Analysis (PHA) was completed for the proposed Ethanol Facility upgrade at the Shoalhaven site. The QRA incorporated the proposed ethanol production upgrade and the existing operation to show the total risk associated with the site.

The hazardous materials and hazardous operations that have potential for off site impact were included in the QRA. The new hazards with potential for off site impact introduced by the proposed upgrade are:

• Cogeneration Plant; and

• Increased ethanol loading frequency, as a result of doubling of ethanol production capacity, which increases the likelihood of release of ethanol in the loading bay.

The PHA was completed in accordance with the State Environmental Planning Policy (SEPP) 33 guideline of NSW DUAP (now DoP) and HIPAP No. 6 guideline for Hazard Analysis. The QRA was completed using the Risk Criteria for Land Use Safety Planning given in HIPAP No. 4.

Individual Fatality Risk was calculated using SAFETI (Software for the Assessment of Fire, Explosion and Toxic Impact) and the risk is demonstrated to be acceptable as all the risk contours are in compliance with the nominated risk criteria of HIPAP No. 4.”

The PHA prepared by GHD makes the following recommendations with respect to the

proposed ethanol upgrade project:

“The off site risk assessment completed for the proposed ethanol production upgrade is in compliance with the DoP risk criteria given in HIPAP No. 4. However, it is recommended to identify opportunities during the design phase of the project to improve the safety of the process. This can be achieved through design reviews and appropriate safety studies.

The following recommendations are made to improve the safety of the proposed upgrade:

1. Complete the Hazard and Operability (HAZOP) for the new plants i.e. co-generation, gas fired boiler and mol sieve at the completion of the detail design;

2. Review the impact of the increased production capacity on the existing process units (vessels and pipes) with respect to mechanical integrity;




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3. Consider completing a traffic risk assessment with respect to increased traffic movement associated with raw materials and ethanol movement to and from the site;

4. Review the fire fighting capability with respect to new plant and equipment such as the co-generation plant and gas fired boilers;

5. Review the emergency shutdown system and emergency procedures with respect to the new plants (co-generation and boiler).”

7.9 RIVER BANK STABILITY AND RIPARIAN MANAGEMENT

Coffey Environments Pty Ltd were engaged by Shoalhaven Starches to:

• detail potential impacts on river bank stability;

• provide options for stabilisation works;

• address riparian corridor issues including riparian corridor widths and revegetation

works.

This section of the EAR is based upon the findings of this assessment. A copy of this

assessment forms Annexure I of this EAR.

7.9.1 Geomorphology

The site is situated on an active floodplain with small levees, minor depressions and

backwater swamps on alluvium deposits. The Soil Landscape Series Sheet 9028 (1993)

Kiama indicates the floodplain landscape is level to gently undulating along river beds

and banks with flat to gently undulating terrace surfaces along the Shoalhaven River.

Natural Geomorphological Processes

Flow characteristics

Shoalhaven floodplain is 6 -10 km wide, with minimal relief (approximately 5 m with

slopes of less than 3%). Stream morphology and ecosystem characteristics are strongly

influenced by changing flow direction as a result of tidal saltwater inputs and freshwater

inputs after rainfall events.

Shoalhaven River

The factory site abuts Shoalhaven River, which is characterised by small narrow terraces

with a relief of approximately 2 – 5 m. Spatial variation is uniform with a steady laminar

flow and minimal surface roughness. According to Coffey Environments the River was

not in flood and wind shear was minimal, giving a slight ripple effect on the surface of the




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river. Water inflows were recorded between the factory and river at 0.45 m, indicating a

presence of infiltration and interflow through the soil profile to groundwater.

Bomaderry Creek

Bomaderry Creek flows through the township of Bomaderry and Nowra North before

converging with Shoalhaven River adjacent to the factory site. Spatial variation was

uniform with a steady laminar flow. The top of the bank ranged between 1 – 3 m from

the surface. Water inflow was recorded at 0.45 m at the nearest borehole (CBH100)

located between the existing Coal Pit and Bomaderry Creek.

Abernethy’s Creek

Abernethy’s Creek passes through the factory site before it converges with Shoalhaven

River. It has been previously dredged and channelled and resembles an open drain,

with hardened sections within the factory site. Bank heights range between 1 – 3 m.

Spatial variation was uniform with a steady laminar flow, although it may become

turbulent during heavy rainfall as there are large rocks present in the streambed. Water

inflow was detected at 2.2 m.

Broughton Creek

Broughton Creek forms the eastern boundary of the Environmental Farm over a distance

of about 3.6 km. This section exhibits the typically characteristics of an active

meandering stream in alluvial floodplain deposits including scouring and deposition on

meanders, and evidence of meander cut-offs within the stream network. Spatial

variation was uniform with a steady laminar flow and bank heights ranged between 0 –

3 m.

Bank erosion and deposition

Bank erosion is related to two major types of processes: fluvial entrainment and the

weakening and weathering of bank materials which enhance the potential for mass

wasting (Ritter et al., 2002). The weakening and weathering of bank materials is

accelerated by the lack of vegetative cover and binding root systems generally

associated with structurally diverse ecosystems. Much of the floodplain, particularly in

and around the factory site and environmental farm, has been previously cleared for

pasture and dairy farming. Therefore natural bank erosion and deposition is likely to

have been influenced by human activities for some time.

The floodplain is subject to scour, sheet and rill erosions during floods and may be

covered by varying depths of alluvial materials as the floodwaters recede. Minor stream

bank recession and bank collapse was common, particularly in areas where vegetation




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has been removed. Bank materials would be transported down stream and either

deposited in the mouth of the estuary or carried out to sea during high rainfall and flood

events.

Sediment deposition in Shoalhaven River occurs on the upstream side of Pig Island,

adjacent to the factory site. Historical aerial photos show how the spit of Pig Island has

changed over the past 50 years. Deposition in this area has created deeper channels

along the edges of the Shoalhaven River, encouraging scouring of the riverbank. It is

likely that recent bank recession and collapses on the northern bank is attributable to the

removal of native riparian vegetation for the construction and operation of the factory site

in conjunction with the aforementioned scouring process.

As the provision of appropriate foreshore riparian zones and setbacks were not

implemented during construction of the factory, bank stability has been undermined

along Shoalhaven River, and Abernethy’s and Bomaderry Creeks. Poor site planning,

lack of riparian buffers, weed infestation, inappropriate plantings, reduced vegetation

quality and cover, and channelling works, in addition to natural scouring, are all likely to

have contributed to riverbank recession in and around the factory site.

Broughton Creek is located adjacent to the Environmental Farm. Broughton creek is a

natural meandering stream traversing the Shoalhaven floodplain. Meander cut-offs were

identified in the stream network, indicating significant entrainment and deposition

associated with relatively frequent flood events (approximately twice a year) over a

prolonged period of time. Due to the low lying nature of the landscape, some meander

cut-off currently exhibit characteristics normally associated with saline wetlands.

Abernethy’s Creek has been significantly modified in the past as a flood mitigation

measure and in more recent years to increase the angle and promote rapid stream flow

from Shoalhaven Council’s waste water treatment plant to Shoalhaven River. The creek

has been channelled and straightened, and periodically dredged. Council recently

authorised the removal of a section of riparian vegetation to access the creek and carry

out dredging operations. Consequently, the bank has been undercut along the water

surface due to the lack of a binding root structure.

Soil Profiles

The Shoalhaven floodplain is characterised by a complex soil pattern as a result of

natural scouring and alluvial deposition. Alluvium consists of gravel, sand, silt and clay

derived mainly from sandstone and shale overlying buried estuarine sediments

(Hazelton, 1993).




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Dominant soil materials include fine sandy loam to sandy loam and fine sandy clay to

sandy clay in topsoil, over sandy clay and light to medium clay to heavy clay. Soil

material deposition sequences include levees and lower terraces up to 100 cm in depth,

upper terraces up to 150 cm in depth, and point bar alluvial deposition up to 100 cm.

Shoalhaven River

Alluvium consisting of grey fine to medium clayey gravel with medium plasticity and

traces of fine grained sand, over brown-red silty sandy clay. Soils were wet and water

inflow was reached at 0.45 m.

Bomaderry Creek

Alluvium consisting of dark brown silty clay of medium plasticity with traces of rootlets,

decreasing in plasticity at 0.7 m and turning to orange and brown mottled silty clay of

high plasticity at 3.3 m. Soil moisture was low in the upper profile, reaching plastic limit

at 3.3 m.

Abernethy’s Creek

Alluvium consisting of fine to course grained sand with traces of medium grain gravel

(reworked topsoil), over silty sand to 1.5 m. The B horizon consists of clayey silt with low

to medium plasticity, with traces of rootlets and an odour of sulphur at 2.2 m, and holes

for bio-turbation at 3 m. Soil moisture increased with depth with water inflow at 2.2 m

and plastic limit was reached at 3 m.

Geomorphological Discontinuities

Natural geomorphic processes in the Shoalhaven floodplain have been influenced by

human settlement and activities since settlement. The floodplain and estuary has

number of urban settlements, including Nowra. Human activities include agriculture

(primarily dairy farming), tourism, defence, and industry. Given the nature of land use on

the floodplain there are numerous geomorphic discontinues affecting stream flow and

geomorphic processes, water quality, aquatic ecosystems and riparian health.

7.9.2 Existing Riparian Health

Vegetation

Much of the remnant vegetation on the site had been removed prior to the development

of the factory and environmental farm to make way for agriculture, particularly dairy

farming. It is most likely that the site was previously covered by at least two vegetation

formations: Forested Wetlands and Saline Wetlands. The vegetation classes for these




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formations would have been Coastal Swamp Forest and Mangrove Swamps

respectively.

Buffer zones

Healthy, vegetated riparian habitat is essential to the natural ecological functioning of

associated watercourses. Riparian and riverine ecosystems function in an integrated

fashion, whereby impoundment, channelisation and diversion of a watercourse may

influence the hydrological qualities of the riparian ecosystem and bank stability.

Similarly, impacts to the riparian ecosystem such as vegetation clearing and stock

grazing can cause erosion of stream banks and enlargement of channels, thus

influencing the functionality of the riverine ecosystem (National Research Council, 1992).

A key factor in conserving the integrated functionality of riparian and riverine ecosystems

involves maintaining, or establishing, a healthy and adequate vegetated corridor.

Guidelines for riparian corridors in NSW have been developed under the WMA Act 2000

and are dependent on stream order classification (refer Sections 6.3.7 and 6.3.8).

As part of the DG’s Requirements, DWE classified the watercourses that are adjacent to,

or traversing the Shoalhaven Starches factory site and environmental farm and provided

recommended CRZ and vegetated buffers, outlined in Table 29.

Table 29

Watercourse classification and recommended buffer zones

Watercourse Category Recommended

CRZ Recommended

Vegetation Buffer

Shoalhaven River Category 1 40 m 10 m

Bomaderry Creek Category 1 40 m 10 m

Broughton Creek Category 1 40 m 10 m

Abernethy’s Creek Category 2 20 m 10 m

The existing riparian buffers were calculated by Coffey Environments from satellite

imagery. Distances were taken at approximate 100 m intervals or where significant

changes were apparent. The results are provided in Table 30 and are indicative of the

width of the canopy of the riparian zone only and not understorey cover. Vegetation

health including structural and floristic diversity, tree maturity and weediness was

assessed during the site visit and is discussed in detail in the following section.




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Table 30

Existing Riparian Vegetation

Watercourse Category Span of

riverbank (m)*

Max. width (m)

Min. width (m)

Average width (m)

Span of

riparian veg. ≥≥≥≥ recommended

CRZ (m)

Shoalhaven River

Category 1 920 91 0 32 98.4

Bomaderry Creek

Category 1 509 91 11 33 72.5

Broughton Creek Category 1 3600 70 0 19 312.6

Abernethy’s Creek

Category 2 425 3 0 − 0

* Total distance (m) of riverbank that is adjacent to or traversing the site.

The existing core riparian zones and vegetated buffers for all the above watercourses do

not meet the recommendations provided by DWE along the majority length of each

riverbank.

Vegetation condition

Shoalhaven River

The vegetation fronting Shoalhaven River to the confluence with Abernethy’s drain

consists of a number of mature remnant trees such as Eucalyptus botryoides and

Casuarina glauca. Further downstream, the bank and upper bank is dominated by

opportunistic colonisers, primarily coral trees Erythrina x sykesii that have established

over the past 20 - 50 years. Three areas were devoid of a canopy: the outside bank

edge at the mouth of Bomaderry Creek, the area near the No. 1 DDG Dryer, and the

engineered rock wall. Manildra Group has revegetated the riparian zone around the

cooling towers with overstorey species, although no understorey enhancement

measures have been undertaken.

Overall canopy demonstrated low floristic diversity and poor canopy structure along the

river frontage. The canopy above 10 m consisted of a few mature native trees along the

upper bank between the confluence of Bomaderry Creek and Abernethy’s Creek. These

trees accounted for ~ 5% of foliage projective cover (FPC) along the riparian zone. A

low shrubby canopy (3 - 5m) was present behind the bank edge consisting of Black

wattle Acacia mernsii and Casuarina glauca, with some revegetated areas adjacent to

the cooling towers. The shrubby canopy accounts for 95% FPC, while the revegetated

area possibly accounts for 15% FPC.




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The midstorey was either absent or dominated by exotic species, particularly Lantana

camara.

The groundlayer ranged from 100% to less than 5% cover depending on the overlying

canopy composition. Along the river bank, exotic pasture species dominated, whereas

under the denser shrubby canopy the groundlayer was generally absent. In the areas

that had been revegetated the groundlayer consisted of exotic pasture species.

Mature remnant trees along the River frontage were generally confined to the western

section and ranged in age between 30 - 70 years. No significant hollows were detected

during the site walkover. The remaining vegetation (shrubby canopy) appeared to be

between 7-15 years old. No seedlings of canopy species were located indicating

minimal natural recruitment is occurring.

The lower stratums have been subject to significant weed infestation with up to 20% of

the midstorey and groundlayer consisting of exotic species.

Bomaderry Creek

A number of mature remnant trees were recorded along Bomaderry Creek to the

confluence with the Shoalhaven River. The lower stratums fronting Bomaderry Creek is

highly modified and has significant weed infestation. Lantana dominated the midstorey

and groundlayer space with up to 100% FPC in some areas. Access to the river

frontage was restricted due to the thick weedy midstorey layer.

The mature canopy trees greater than 10 m were evenly spaced or clumped along the

upper bank edge. These trees accounted for ~20-25% FPC. A low shrubby canopy

(3 - 5m) was present behind the bank edge which accounted for ~ 95% of FPC where it

was encountered. Overall the upper and lower canopy demonstrated moderate floristic

diversity and poor to moderate canopy structure.

The midstorey was lacking in native species due to densely growing weed species

including Lantana, African Boxthorn Lycium ferocissimum, Blackberry Rubus fruticosus,

Asparagus asparagoides, Large Leaf Privet Ligstrum lucidum and Small Leaf Privet

Ligstrum sinense. In several areas Lantana made up 100% FPC, while in others other

weeds competed for midstorey and groundlayer space.

The groundlayer ranged from < 5% to 100% cover depending on the overlying canopy

composition. Along the riverbank, weed species dominated, whereas under the dense

shrubby canopy the groundlayer was generally absent. The groundlayer in areas along

the steep embankment, which possessed of a moderately natural canopy, consisted of




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~ 30% bare soil and 30 - 50% FPC by weed species. A few native species were

present, however, overall native floristic diversity was considered poor.

The remnant mature trees were generally ~ 30 - 70 years old. No significant hollows

were detected. The lower stratums appeared to be between 7 - 15 years. Seedlings of

native species were located indicating some unassisted regeneration of the canopy was

occurring.

Abernethy’s Creek

The riparian area fronting Abernethy’s Creek has been either cleared of vegetation or

highly modified by human activities and/or weed infestation. The central portion is

landscaped using non-indigenous native tree species. The southern portion has

undergone recent attempts to revegetate with endemic species with partial success.

The northern portion on Shoalhaven Starches property has recently been cleared by

Shoalhaven City Council in order to dredge the streambed and relieve upstream

flooding. Revegetation has not been undertaken and natural recruitment has thus far

been dominated by weed species.

No mature remnant trees or shrubby canopy species were recorded along the creek line.

The midstorey structure was very poor and limited to some low shrubby weed species

(Lantana) and previously planted native trees such as Casuarinas in competition.

Floristic diversity of native flora was very low with weed species outcompeting native

species, particularly in the southern section where exotic climbers were strangling

planted trees.

The groundlayer was dominated by exotic perennial shrubs and vines or exposed earth.

Broughton Creek

The majority of riparian vegetation along Broughton Creek has been previously cleared

for pastoral agriculture and dairy farming. A thin discontinuous edge of riparian

vegetation remains. This edge exhibits a patchy distribution of Saline Wetlands

formation (Mangrove Swamp) which is listed under SEPP No.14 Coastal Wetlands, with

minor saltmarsh components. There were also some remnant Forested Wetland

(Coastal Swamp Forest) components which at times were contiguous with other

remnants. Riparian works undertaken by Manildra included the establishment of a ‘hot’

wire to fenceout stock located with the area, minor planting to promote mangrove

(Avicennia marina) establishment and stabilise eroding banks.

The canopy on the upper bank greater than 10 m in height consisted of mature isolated

or stands of Eucalypts, providing < 5% to 30 - 40% FPC. There were also discontinuous




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stretches of mangrove swamp along the lower stream bank. These lower areas were

dominated by mangrove canopy which accounted for ~ 50 - 65% FPC. Floristic diversity

was high in areas where a canopy existed. In comparison, diversity on exposed banks

that were actively eroding was found to be very poor.

The midstorey was dependent on the depth of transect which varied considerably along

the creek frontage (0 - 70m). Those areas were the depth of riparian vegetation was

equal or greater than 10 m displayed moderate to high structural and floristic diversity.

Areas possessing only single trees or small clumps along actively eroding banks

displayed little or no native midstorey development, with occasional low shrubby weeds

present. A few shrubby weed species were encountered in areas of mature trees on the

upper bank. Areas of relatively diverse vegetation had been invaded by exotic climbers

which appeared to be increasing in numbers.

Large areas along the creek frontage were dominated by the exotic pastoral perennial

Kikuyu grass Pennisetum clandestinum up to 1 m in height. In areas with good canopy

structure, the groundlayer consisted of clumping perennials, low shrubs and

herbaceous/grassy species. These areas were considered to have relatively high

structural and floristic diversity, important representative components of Mangrove

Swamp and Coastal Floodplain Wetland communities. Exposed earth was evident in

areas undergoing period inundation, and on the face of eroding banks.

The canopy species consisted of a few E. botryoides and E. botryoides x salinga,

although the presence of seedlings indicated natural recruitment of casuarinas

mangroves only. Similarly, mature specimens of Melaleuca stypheliodes and

M. linariifolia were identified without any indications of recently recruited seedlings. This

is most likely a result of the dominate Kikuyu grass on most areas of the upper

embankment.

Bank Stability

The major cause of erosion occurring on site is from fluvial scour, a natural geomorphic

process within an active floodplain. Fluvial scour on site has been amplified by the lack

of healthy, diverse and contiguous riparian vegetation along the foreshore of each

waterway. Bank stability is also influenced by surface gradients, soil type, and surface

drainage characteristics of the factory facilities.




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Shoalhaven River

The bank of the River adjacent to the factory has a known history of recession. The

factory is located on the terraced bank of Shoalhaven River and is therefore subject to

natural scouring and channel expansion.

A recent bank collapse occurred along a small section of the River adjacent to No. 1

DDG Dryer. Given the proximity of the bank to the factory, immediate engineering

remediation was carried out. A stepped rock wall was constructed to breach the receded

area. Vegetative cover on the bank behind the wall is dominated by Kikuyu grass, which

would limit the successful establishment of native species.

The riparian zone between Abernethy’s Creek outflow and the eastern boundary of the

property ranges from between 1 – 3 m from the top of the bank and is dominated by

mature Coral trees. Sections of the foreshore dominated by Coral trees are of particular

concern for bank erosion and failure, especially as the distance between the river and

the factory is minimal.

Evidence of further bank erosion was recorded near the Slurry Plant and Grain

Processing Plant. In both areas a small section of the upper bank had ‘sunk’ or ‘blown

out’ within 1 – 2 m of the edge. Tensile cracking on the upper bank was evident near the

new rock wall. It is likely the bank directly behind the rock wall is now stable. However

the bank on either side is prone to recession due to the lack of binding deep rooted

vegetative cover and the eddying effect created by the wall.

The foreshore of Shoalhaven River between the convergences of Bomaderry Creek and

Abernethy’s Creek has less weed infestation and greater floristic and structural diversity,

with small stands of mature Eucalypts. Nevertheless, evidence of bank erosion in the

form of undercutting and slumping was recorded, particularly in areas where diverse

understorey and groundcover species were absent and the bank is exposed.

Surface runoff from the flat area where the proposed new facilities were being

assembled has resulted in shallow gully erosion (1 cm deep by 2 – 3 m wide) in the area

adjacent to the proposed new cooling tower. Evidence suggests the surface runoff is

cutting back into the riparian bank. At present this is minor however it has the potential

to increase over time.




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Bomaderry Creek

The majority of the upper bank of Bomaderry Creek is dominated by dense thickets of

impenetrable Lantana. A number of mature casuarinas and acacias were present on the

bank down to the waters edge. The understorey and groundlayer, where present, was

dominated by weed species including Lantana, Kikuyu grass and African Boxthorn.

Evidence on a previously felled tree indicates bank undercutting and scouring may be

occurring on the lee side of each meander.

Further downstream near the convergence with Shoalhaven River, the riparian zone

becomes more open. Near the mouth of the Creek, Kikuyu Grass dominates and there

is little overstorey. A ‘sandy’ edge has developed on the eastern side of Bomaderry

Creek where it meets Shoalhaven River, indicating sediment deposition is occurring.

Notwithstanding, tensile cracking near the bank edge was recorded in this area. Further

cracking is likely given the lack of vegetative cover and exposure to the mechanics of

wetting and drying, particularly during flood events.

A surface water outflow was identified in the area near the electrical easement, north of

the proposed gas-fired co-generator. This area receives runoff from the western plant

and showed evidence of sediment trapping using emplacement of hay bales. Under

heavy rainfall, this area may be prone to minor surface erosion.

Abernethy’s Creek

The riparian zone of Abernethy’s Creek is in very poor condition. The upper section,

directly downstream of the Council operated waste water treatment plant was recently

dredged to minimise upstream flooding. Undercutting of the bank has occurred to a

much greater extent than the eastern side of the creek.

The central section of the Creek is dominated by weed species, where present, with

large patches of exposed earth along both sides of the bank. Medium sized rocks have

been placed along the waters edge to minimise erosion with some success. Some bank

hardening has been undertaken around the footings of the footbridges that have been

constructed. These footings have provided opportunity for deposition of sediment and

debris carried downstream during high flows and flood events. Further, eddying

upstream of these deposits has been causing minor channel expansion.

The lower section of Abernethy’s Creek is funnelled into a drain discharging into

Shoalhaven River. The bank has a high diversity of introduced species with areas of

thick weedy undergrowth that limited access to the bank edge.




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Broughton Creek

Several areas have been identified where erosion and bank failure had occurred. Areas

of failure were generally consistent with riparian zones lacking structural and floristic

diversity, and occurred on the long edge of the meander bend. The major cause of

erosion and bank failure is from fluvial scour, a natural geomorphic process within an

active floodplain that has been amplified by the lack of healthy, diverse and contiguous

riparian vegetation along the foreshore of Broughton Creek.

The unfenced Creek frontage is utilised for high ground grazing during flood events,

approximately twice a year. This area has very little riparian vegetation with a few

juvenile eucalypts and casuarinas, no understorey species and a groundlayer dominated

by Kikuyu grass, which is periodically slashed. Tensile cracking was common and one

section of the bank had recently slumped. Furthermore, several young trees had been

undercut and collapsed into the Creek.

Further upstream, within the fenced area, a large Eucalypt had been undercut, falling

into the creek. The riparian zone in this area was limited to a few mature trees,

scattered shrubs and extensive covering of Kikuyu grass. The undercut tree was

positioned on the pinnacle of the meander bend. The exposed root system was bound

with clayey soil and water was observed in the resultant space, indicating reduced shear

resistant due to an unstable saturated clay horizon as the precursor to tree collapse.

Soil slumping was also recorded where the fence traverses the ‘point’ of a sharp

meander. Although one side of this area is well vegetation with many mature trees and

good floristic diversity in the lower stratums, the other side is dominated by Kikuyu grass

with the occasional mature tree. Slashing does not occur and Kikuyu grass is approx

1 m high. Evidence suggests the lower bank may be prone to undercutting due to the

lack of binding root system, exposed earth and the position of the meander.

A surface drainage channel was identified at the closet point between Pivot No. 7 and

Broughton Creek. Pivot No. 7 is enclosed by a swale approximately 0.3 - 0.5 m in

height, forcing irrigated water to infiltrate the surface. As such the drainage channel is

only likely to flow into Broughton Creek during periods of heavy and prolonged rainfall

and flood events. Conversely, its presence may allow saltwater to intrude into the upper

riparian zone. This exposed drain may be prone to erosive processes and salinisation.

Areas of deposition along Broughton Creek adjacent to the Environmental Farm were

identified as point bars on two major meanders. The outside bank edge of these point

bars are known areas of bank recession and failure due to the superelevated water




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surface as the water channels around the meander. Given that Broughton Creek

traverses the Shoalhaven floodplain for approximately 5 km before discharging into

Shoalhaven River it is likely that further deposition occurs downstream in areas not

included in the site investigation.

Compliance with RCMS Guidelines

The Department of Water and Energy (DWE) undertook a desktop review and

categorised all four waterways onsite in relation to RCMS Guidelines, as follows:

Shoalhaven River Category 1 watercourse

Bomaderry Creek Category 1 watercourse

Broughton Creek Category 1 watercourse

Abernethy’s Creek Category 2 watercourse

The eastern section of Shoalhaven River and Abernethy’s Creek do not have the

appropriate setbacks from the factory facilities and it is unlikely that an appropriate

riparian zone can be established.

The western section of Shoalhaven River and the lower section of Bomaderry Creek do

have appropriate setbacks and revegetation / enhancement works may help according

to Coffey Environments improve the existing riparian vegetation.

The riparian zone along Broughton Creek does, in a few places, meet the 40 m CRZ

requirement and 10 m buffer zone. The existing riparian vegetation is not contiguous

and quality varies significantly. Notwithstanding, adequate setbacks are available

according to Coffey Environments along the length of the Creek frontage.

7.9.3 Potential Impacts

Riparian zone

The proposed expansion is likely to involve the removal of vegetation where the

proposed gas-fired co-generator has been sighted, which abuts the area zoned 7(f3).

The approximate area of vegetation that would be removed would result in the loss of a

dense thicket of Black wattle. This thicket is nearing the end of its lifecycle and is slowly

being invaded be Lantana. No other proposed facilities on the factory site have been

sighted within the riparian zones and it is unlikely that any further removal of vegetation

will occur for the construction and/or operation of these facilities.

None of the proposed new facilities are located within the vicinity of Broughton Creek.

Consequently, further vegetation clearance along the frontage of Broughton Creek is




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unlikely. The remaining riparian vegetation has been ‘hot’ wired for protection primarily

against stock grazing.

Given the prevalence of weed species in the riparian zones of each waterway, there is a

high likelihood that weed infestations will increase in intensity and spread to new areas.

However, it is unlikely that the proposed new facilities will be a contributing factor. Weed

infestations are limited by dispersal rates and current site presence. The potential for

further incursions along the foreshore of Bomaderry Creek and Shoalhaven River from

mature seed producing noxious weeds is high unless control measures are

implemented.

On the Environmental Farm the potential for weed species to recruit and establish is

limited due to the extent and density of Kikuyu grass along the foreshore. There is the

potential for minor invasions of mature lantana, African Boxthorn and Privet in more

floristic and structurally diverse areas.

Water quality on the farm may be an issue that adversely impacts on ecosystem health

in riparian zones. The proposed aerobic / anaerobic pond system will improve the

quality and reduce the volume of wastewater to be irrigated into the Pivot No. 7.

Wastewater will be treated to a higher level and become available for reuse in the

factory. As a result the volume and quality of water infiltrating Pivot No. 7 and flowing via

subsurface pathways into Broughton Creek should improve and is therefore not likely to

further impact on riparian health.

Bank Stability

The proposed expansion is unlikely to impact further on bank stability within the Factory

site and Environmental Farm.

According to Coffey Environments bank recession and failure was predominately a result

of fluvial scour and was most prominent in areas impacted by fast flow direction changes

and with reduced riparian health. The proposed new facilities will not influence these

fluvial processes. Nevertheless, changes in soil moisture and engineered loads, and

loss of further vegetation are all potential contributing factors to diminished bank stability.

Table 31 outlines the proposed facilities within close proximity to a waterway. Given the

factory is located on an active floodplain the position of these facilities may increase the

loading on the alluvial soils. The additional weight may cause the soil around the

footings to bulge, which may undermine slope stability if it occurs within close proximity

of a stream bank. Further investigation will be required prior to construction of these

facilities.




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Table 31

Proposed Facilities Close to a Waterway

Proposed facility Waterway Approx. distance (m)

Gas-fired co-generator Bomaderry Creek 20

Chemical storage facility Abernethy’s Creek 10

Dryer No. 5 Abernethy’s Creek 15

The existing Stormwater Management System has the capacity to integrate with the new

facilities with the exception of the proposed packing plant, Raw-water Pipeline Route

and Pond No. 7 on the Environmental Farm (GHD, 2008). Appropriate stormwater

drainage will be constructed for these facilities. It is therefore unlikely that the proposed

facilities will result in an increase in impervious surfaces or surface run-off, and

contribute to changing soil moisture conditions along stream banks. So long as the

integrity of bunds is maintained, stormwater collected within the factory site will be

collected and diverted to either Shoalhaven River or the Environmental Farm for

treatment.

The wetting and drying of soils along the banks of each waterway is therefore a

consequence of rainfall, flooding, surface run-off outside the bunds, sub-surface flows,

or from pipes located outside of the bunded areas. These factors exist already and are

not likely to increase in severity as a result of the expansion.

Notwithstanding, the potential for bank instability leading to failure is present under

current conditions as a result of fluvial scour, reduced ecosystem health and changing

soil moisture conditions.

7.9.4 Conclusion

With respect to riverbank stability and riparian corridors Coffey Environments conclude:

“The riparian zones of the four watercourses traversing or bordering the Shoalhaven Starches site are in poor condition due to inappropriate setbacks, weed infestation, inappropriate foreshore plantings (Coral trees), and widespread clearing. With the exception of the ‘spit’ between Bomaderry Creek and Shoalhaven River and sections along Broughton, the vegetated riparian zones fail to meet the recommended buffer zones put forward by DWE.

The onsite investigation revealed the overall condition of vegetation to be poor with low structural and floristic diversity, and a high prevalence of weed species along all four watercourses. Remnant vegetation on Broughton Creek did exhibit good ecosystem diversity in some isolated areas. Several




Page 263

noxious weeds were recorded and are expected to increase in intensity and spread without the implementation of control measures.

Bank recession and failure was evident on Shoalhaven River and Broughton Creek. Areas of recession were generally associated with fluvial scour on the long edge of the meander and amplified by poor vegetation health and weed infestation. Slumping, undercutting and cracking was recorded, indicating further recession is likely.

Given the degraded state of the riparian zones, it is unlikely that the proposed facilities will further impact on vegetation health or bank stability. Nevertheless, further investigation into engineer loads of facilities within close proximity of stream banks may be necessary. Furthermore, all new facilities will need to be incorporated into the existing bunds or have new bunds constructed.

Bank stability for Bomaderry, Abernethy’s and Broughton Creeks should improve with the implementation of the recommendations provided in the following section. Given the severity of fluvial scour occurring along Shoalhaven River, revegetation and enhancement is unlikely to prevent further failures, although it may slow the rate of recession.

7.9.5 Recommendations


process within an active floodplain that has been amplified by the lack of healthy, diverse

and contiguous riparian vegetation along the foreshore of each waterway. According to

Coffeys it is unlikely that major revegetation works within the riparian zone will arrest

bank recession occurring as a result of fluvial scour. However, increasing groundcover

and promoting binding root growth as close to the toe of the bank as close as possible

may slow the rate of bank recession. The success of revegetation as a means of

stabilising areas prone to recession is dependant on the physiological ability of plant

species to bind the soil. Most large trees have a root system reaching up to 3 m in depth

and a lateral extension similar to the width of the crown.

The following are specific recommendations made by Coffey Environments. Shoalhaven

Starches commit to implementing these recommendations.

Shoalhaven River

The bank of Shoalhaven River ranges between 2 - 5m with steep slopes due to

continuous fluvial scour. The eastern section of the foreshore does not have an

appropriate setback and is dominated by Coral trees and other weeds which further

undermine bank stability. The effectiveness of revegetation works on the top of the bank

will be limited by bank height as the root system of mature trees is unlikely to reach the

watertable. The slope, changing flow direction and weed infestation will limit the




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effectiveness of revegetation works on the bank. Given the limitations, recommended

actions for Shoalhaven River include:

• �Planting fast growing native species at the top of the bank to slow surface erosion and allow time for the establishment of slower, deep rooted trees which will act to protect the bank, in part, in the future.

• �Planting deep native rooted trees behind the bank along the western section (between Bomaderry and Abernethy’s Creek) and enhancement of understorey and groundcover species, with particular focus on known areas of erosion.

Bomaderry Creek

Bank stability along the frontage of the southern section is undermined by poor structural

and floristic diversity, areas of exposed earth and weed infestation. The bank ranges

from 1 – 3 m above the water surface and a number of large mature trees were

recorded, indicating the presence of a binding root system potentially reaching the water

table. Enhancement measures to improve riparian health and bank stability, particularly

in the southern section, include:

• �Planting mangroves on the lower bank and sandy sediments at the mean high water mark.

• �Revegetation of the mid and upper bank with native species in conjunction with weed control measures (discussed below).

Abernethy’s Creek

The riparian zone of Abernethy’s Creek is highly degraded due to weed infestation and

lack of an appropriate setback from the factory. Bank stability in the upper section has

been undermined by the removal of vegetation and bank erosion along the waterline

was evident. Tree planting along Abernethy’s Creek is problematic due to the lack of

space and high modification associated with the factory, and prevalence of weeds.

Enhancement measures to improve bank stability and riparian health include:

• Planting of canopy species at approx 5 – 10 m intervals along the top of the bank, where possible.

• Weed suppression until canopy species are of sufficient size to ‘shade out’ weed species.

• Weed control measures to prevent further infestation (complete removal will most likely reduce bank stability in the short to mid term).

• Revegetation of the western side of the creek, north of Bolong Rd, with native canopy, midstorey and groundlayer species.




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• Effective dialogue will be required to reach an agreement with Shoalhaven City Council regarding ongoing access for dredging activities.

Broughton Creek

Sections of Broughton Creek have been subject to bank scour due to superelevated

water level and flow associated with the outside edge of meanders, and further amplified

by poor structural and floristic diversity. Unfortunately previous enhancement trails using

mangroves have not been successful due to bank failure and burial of seedlings. Bank

height is estimated at average between 2 – 3 m with an almost vertical slope. Significant

areas are covered with dense Kikuyu grass, which is likely to out-compete new plantings

with continued maintenance. Enhancement measures to slow ongoing erosion leading

to bank stabilisation include:

• Planting fast growing native shrub species along the bank and canopy species behind the bank in areas prone to bank failure.

• Spot controlling Kikuyu grass to provide adequate space for native species to grow.

• Widespread spraying of Kikuyu is not recommended as it would reduce the cover and bank stabilisation provided by this species.

Weed Management

Extensive weed infestations were identified along all of the waterways bordering or

traversing through the property including a number of noxious weeds listed under class 4

and 5 of the Shoalhaven Local Government Area. Plans of Management for the control

and eradication of class 4 weeds have been published by Council, and detail the

following actions:

• Constant suppression of African Boxthorn and Blackberry.

• Suppression and removal of Large Leaf Privet and Small Leaf Privet from urban areas.

• Further clarification for privet identified onsite may be required to the zonings of 4(a) General Industrial and 7(f3) Environmental Protection Foreshores.

• Removal of Lantana where it supports local Council and Volunteers efforts.

The removal of African Boxthorn and Blackberry will be most effectively achieved by

‘spot’ spraying using appropriately registered herbicide due to the low number of

individuals sighted throughout the sight. The species was most prevalent in the riparian




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area of Bomaderry Creek. Ongoing monitoring will be required to ensure control

measures are effective and weed species have not re-established.

Significant areas of lantana were identified onsite, with dense thickets recorded adjacent

to Bomaderry Creek and in a number of locations along Broughton Creek. It is

recommended that some patches are removed to improve overall ecosystem health and

allow the re-establishment of midstorey and groundcover species. Removal of Lantana

should be conducted in conjunction with understorey replanting and enhancement.

Lantana is shallow rooted and unlikely to contribute greatly to bank stability. The

removal of Lantana from bank edges and slopes should allow deeper rooted native

species the opportunity to establish and improve bank stability. Lantana is easily

removed by cutting and mulching back into the ground. This method will provide some

soil protection following weed removal to reduce both erosion and further weed

infestation.

Stock Exclusion

Stock currently graze a small section of foreshore along Broughton Creek during flood

events (approx twice a year). Current grazing distances range between 5 to ~ 15 m from

the mean high water mark. It is recommended that a stock exclusion zone be

established from the top of the bank to a minimum 15 m. This would provide sufficient

area for the development of a sacrificial fast growing edge and longer term

establishment of larger canopy species for long term bank stabilisation. In areas where

15 m exclusion is not possible, a small riparian zone should be established behind the

bank to avoid browsing and trampling of newly planted species.

Vegetation Management Plan

A vegetation management plan (VMP) for the factory site and environmental farm should

be developed to ensure riparian areas are managed appropriately and in accordance

with strategic objectives. The VMP should outline management zones and establish

guidelines riparian management, focusing on the required actions to carryout the above

recommendations. In addition, the VMP should incorporate site specific measures

relating to personnel access, weed management, incident management, ASS, surface

drainage and erosion controls.

7.10 FLOODING

The site is located on the northern bank of the Shoalhaven River adjacent to Abernethy’s

Creek and on the southern side of Bolong Road. The site is within the 1% Annual

Exceedance Probability (AEP) floodplain of the Shoalhaven River as defined in the




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Lower Shoalhaven River Flood Study (April, 1990) which was prepared by Webb,

McKeown & Associates (WM) for Public Works.

During major rainfall events, runoff from the Shoalhaven River catchment enters the site

from the south and from the Bomaderry Creek catchment to the west. Once the banks

of the Shoalhaven River and Bomaderry Creek are overtopped, floodwaters pass over

the site, between the existing plant and associated buildings and towards Bolong Road.

Once Bolong is overtopped, floodwaters continue north, spreading out over the low-lying

floodplain. Ultimately the floodwaters return back to the Shoalhaven River further

downstream of the site. The northern floodplain is also inundated from local catchment

runoff directly entering the floodplain. The main contributor is Broughton Creek.

The largest floods in recent times have been in August 1974, June 1975, March 1978

and April 1988. These events would all have overtopped the river bank (in parts) and

caused overbank inundation. Of the four, the largest was March 1978 which reached

approximately 5.0 m AHD near the site.

In addition to the existing plant and associated buildings at the subject site, other

development is evident on the Shoalhaven River floodplain in the vicinity. This includes

a concrete batching plant (Cleary Bros), a paper mill, the Dairy Farmers complex (now

closed), the 5 wet weather storage ponds opposite the paper mill, and on the opposite

(southern) river bank, the Riverview Road and Terara village flood protection levees.

These developments on the floodplain have resulted in a reduction in the available flow

area and floodplain storage capacity during a major flood event.

Webb McKeown & Associates have been engaged by Shoalhaven Starches to

investigate the likely hydraulic, economic, social and environmental impact of flooding as

a result of the proposed expansion. Webb McKeown & Associates report forms

Annexure K to this EA. This section of the EA is based upon the findings of this

assessment.

7.10.1 Hydraulic Impacts

The potential impacts of works within the floodplain on hydraulic characteristics are

twofold – firstly a loss of temporary floodplain storage volume and secondly a loss of flow

area. It is the loss of flow area which produces the greatest impact, as the area of

floodplain storage lost due to all works since 1990, represents approximately less than

1% of the total available floodplain storage area for the northern floodplain (say 3000+

hectares).




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The hydraulic assessment undertaken by Webb McKeown & Associates using the CELL

Model established for the 1990 Lower Shoalhaven River Flood Study, prepared for

Public Works in April 1990 by Webb McKeown. Whilst more sophisticated computer

programs are now available the CELL Model is the most up to date hydraulic model of

the Lower Shoalhaven River floodplain available and is capable of assessing the two

impacts on hydraulic characteristics outlined above.

The CELL Model was run for the Extreme, 1%, 2% and 5% AEP (Annual Exceedance

Probability) design events for three scenarios:

• Existing conditions as at 1990.

• Current development conditions, assumed to be Stage 2 Works plus construction of

Pond No. 6 (already constructed), Pond No. 7 (under construction) and the

proposed works at the plant outside the agreed envelope as part of the October

2002 report.

• Proposed development conditions as above PLUS the ethanol upgrade and odour

reduction works proposed in 2008 (Figure 5).

Hydraulic Impacts

Hydraulic impacts can be subdivided into the following categories:

• increase in water level,

• increase in frequency of inundation,

• increase in duration of flooding,

• increase in extent of inundation at the perimeter of the floodplain,

• increase in velocity of floodwaters across the floodplain.

Increase in Water Level

An increase in water level is probably the most obvious effect of works upon the

floodplain. A summary of design flood levels (1990 conditions) is provided in Table 32

together with the cumulative impacts of all construction works since 1990, plus the

proposed upgrade associated with this proposal.




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Table 32

Design Flood Levels

Design Flood Level (mAHD) Relative Impact Location

5% AEP 2% AEP 1% AEP Extreme

Shoalhaven Starches Plant (Cell 26)

4.2 (0.11)

4.8 (0.10)

5.3 (0.07)

7.3 (0.08)

Dairy Farmers (Cell 29) 3.8 *

4.5 (0.02)

5.1 (0.04)

7.2 (0.07)

Paper Mill (Cell 57) 3.8 *

4.5 (0.02)

5.0 (0.05)

7.2 (0.08)

Rural Area North of Bolong Road

3.8 *

4.5 *

5.0 (0.04)

7.1 (0.10)

North of Bolong Road and West of Shoalhaven Starches Plant (Cell 4)

3.8 (0.04)

4.6 *

5.0 (0.03)

7.2 (0.08)

South of Bolong Road and West of Shoalhaven Starches Plant (Cell 18)

5.0 (0.02)

5.4 (0.03)

5.8 (0.04)

7.8 (0.08)

Notes: The values in brackets represent the cumulative flood impacts (as indicated on Figures 8a, b, c & d) of works undertaken since 1990 (including all seven ponds and the proposed ethanol plant upgrade and odour reduction works).

* indicates that the impact is equal to or less than ±0.01m.

Small differences between the flood impacts indicated above and those published in previous reports by Webb McKeown may be evident due to slight changes in the hydraulic model structure and how the ponds and other works are represented.

Figures 30 to 33 indicate the cumulative differences in flood level of all works on the

floodplain since 1990 (Stage 2 works, all ponds, as well as the proposed ethanol plant

upgrade and odour reduction works). It is apparent that the proposed ethanol plant

upgrade and odour reduction works will only marginally increase design flood levels

(differences shown in boxes on Figures 30 to 33).



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Fig

ure

30

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Fig

ure

31:

All

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ince 1

990 1

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EP

Flo

od

.



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Fig

ure

32:

All

wo

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ince 1

990 2

% A

EP

Flo

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.



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Fig

ure

33:

All

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% A

EP

Flo

od




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The main impact of increasing flood levels is a greater depth of inundation of residential

and commercial/industrial floor levels.

As part of the present study additional residential floor levels were obtained along

Hannigans Lane and Edwards Avenue (refer Appendix B). The floor levels are:

• No. 125 - 4.29 m AHD;

• No. 190 - 4.15 m AHD;

• No. 191 - 4.22 m AHD;

• No. 219 - 3.54 m AHD;

• cottage near Meadow Grove - 4.42 m AHD.

According to Webb McKeown, No. 219 would be first inundated in a 5% AEP event with

the other buildings inundated in a flood between the 5% and 2% AEP event. In a 1%

AEP event No. 219 would be inundated to a depth of 1.6 m and the others by

approximately 1 m. According to Webb McKeown in events up to and including the 1%

AEP event the cumulative hydraulic impacts of the existing and proposed works on the

floodplain by Shoalhaven Starches have nil impact north of Edwards Avenue. Thus

these buildings are not adversely affected by the proposed works. In the Extreme event

No. 125 could experience an increase of +0.02 m.

Increase in Frequency of Inundation

An increase in frequency of inundation occurs as a result of an increase in flood level.

For example, a rise in flood level of 0.1 m within the 2% to 1% AEP flood range would

represent an approximate 10 year increase in frequency of inundation (say from a 1 in

70 year to a 1 in 60 year). This impact is of particular importance if flooding occurs more

frequently (say in less than a 5% AEP event) or has major implications such as closure

of a road or factory. Bolong Road is first cut in approximately a 5% AEP event or

smaller. According to Webb McKeown however there is minimal impact in a 5% AEP

event and thus minimal increase in frequency of inundation of Bolong Road or those

buildings first inundated in a 5% AEP event.

Increase in Duration of Inundation

Table 33 provides an example of the increases in duration of inundation for the

transformer at the Paper Mill (floor at 4.5 m AHD). The location was chosen as it

produces the greatest cumulative increases in level.




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Table 33

Duration of Inundation for the Transformer at the Paper Mill

Transformer floor level of 4.5 m AHD

Event Duration of inundation

Increase in duration following all works

since 1990 % Increase

Extreme Flood > 48 hours (estimate)

2 hours 4%

1% AEP 16 hours ¾ hour 4%

2% AEP Level just reaches 4.5 m AHD

5% AEP Level does not reach 4.5 m AHD

According to Wee McKeown, the results indicate that there is no significant increase in

the duration of inundation due to the cumulative effects of all works on the floodplain

since 1990.

Increase in Extent of Inundation

The northern floodplain is low lying land (ground levels at 2 m AHD or below) with no

areas of high ground except around the perimeter. It is entirely inundated by floodwaters

in say the 10% AEP event and greater. Thus any increase in flood level, caused by

development, will only result in an increase in the extent of inundation around the

perimeter of the floodplain. The increased area of inundation will vary between floods

and depends upon the grade of the topography at the perimeter and the length of the

perimeter. A flat grade will result in a large increase in area, whilst a steep grade will

result in only a small increase.

The assumed areal extent of inundation on the northern side of the Shoalhaven River is

some 3000+ hectares (based upon mapping undertaken for the Draft Lower Shoalhaven

Floodplain Risk Management Study).

All of the works undertaken since 1990 have been located along Bolong Road and near

the river. As the effects of development on the floodplain decreases with distance from

the works, this means that a large part of the perimeter of the floodplain will not be

affected by an increase in flood level. Many parts of the perimeter are over eight

kilometres away (near Berry) and as such will experience nil increase in flood level.

Even the nearest edge of the floodplain at Bomaderry is still some two kilometres from

the ponds which are the major contributors to an increase in flood level. For calculation




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purposes Webb McKeown assumed that three kilometres of perimeter will be affected in

the 1% AEP event by an increase of (say) 0.1 m (this is a conservative value with a more

realistic value of 0.03 m). Webb McKeown used Council’s Airborne Laser Scanning

(ALS) data to estimate the lateral increase in flood extent (approximately 2 m) and this

indicates an areal increase of approximately 6000 m2.

Increase in Velocity of Floodwaters

Comparison of velocities between different floodplain conditions is more complex than

comparison of peak levels. The main difference being that the peak flood velocity may

not necessarily occur at the same time as the peak flood height. More often than not it

will occur when floodwaters first enter an area at a time of very small flow. This velocity

is generally not relevant for comparison purposes. A more appropriate velocity is that

which is experienced at peak flood height since, in combination with the deepest

floodwaters this is likely to represent the greatest flood hazard. Consequently the

assessment has been made using peak height velocities. The CELL model provides the

average velocity for a cross-section at peak flood height. It should be noted that local

velocities between obstructions may be higher than this average velocity.

According to Webb McKeown, velocities are only available in the CELL Model at Weirs

or Cross Sections. On the northern floodplain the cells are linked by Weirs and the

average velocities were obtained at all relevant locations. The effect of the works at the

plant on velocities cannot be accurately assessed using the CELL Model due to the

relatively small scale of the proposed works. For this reason the study has focussed on

the area near the storage ponds.

In summary according to Webb McKeown, the changes in velocity are largely confined to

the area in and around the ponds where flows have been re-directed as a result of the

“barrier” caused by their construction. Elsewhere there are no significant changes in

velocity.

It should be noted that the majority of changes occur on land owned by Shoalhaven

Starches. The main exceptions are on Bolong Road (Council owned) and on other

private ownerships (largely the Paper Mill). The effect of changes in velocity will have

little impact on rural lands as it is unlikely that this will cause any increases in erosion or

damages. Along Hannigans Lane where five residential properties are located there is a

slight reduction in velocity as a result of construction of the ponds.

Immediately west of the Shoalhaven Starches plant there is no significant change in

peak velocity.




Page 277

According to Webb McKeown:

• Blocking of the flow path due to all the works at or near the Shoalhaven Starches

plant since 1990 have slightly increased flood levels in the immediate upstream area

but also results in less floodwaters entering the northern floodplain. This produces a

slight reduction in the affectation caused by construction of the wet weather storage

ponds.

• In the 5% AEP event (an event of similar magnitude to the March 1978 flood) there

is no increase in flood level (or consequent changes in extent of inundation etc.) as

a result of the works constructed and proposed on the floodplain since 1990 at the

Paper Mill or north of Bolong Road. There is an exception of + 0.11 m at the

Shoalhaven Starches plant itself, and + 0.02 m immediately west of the Shoalhaven

Starches plant. This means that in the smaller more frequent events, up to a 5%

AEP, the works on the floodplain have little impact. The main reason for this is that

there is little flow across the northern floodplain in these events as the floodplain

predominantly acts as a flood storage area with only a small flow across the river

bank itself. In the smaller floods (up to the 5% AEP) the northern floodplain is

largely filled by local catchment runoff and particularly from Broughton Creek. In

larger events where flows breakout from the main river, the impacts become more

significant. It should be noted that in the 5% AEP event the northern bank of the

Shoalhaven River is only just overtopped (at a few locations) and thus the impacts

of the works on the floodplain for this event may produce anomalous results due to

the shallow depths.

• In the 2% AEP event (approximately 0.7 m higher than the 5% AEP or March 1978

flood) there is a maximum cumulative increase of + 0.10 m. This is confined to the

area near the Shoalhaven Starches plant with up to + 0.03 m elsewhere.

• In the 1% AEP event (approximately 1.2 m higher than the 5% AEP or March 1978

flood) the cumulative increases range from 0.03 m to 0.07 m within the locality of the

Shoalhaven Starches plant. There is no impact within the Shoalhaven River or the

residential areas to the south (Terara or Riverview Road).

• Hazard is defined as the source of potential harm or a situation with a potential to

cause loss. The works on the floodplain since 1990 have increased the hazard.

However the extent of the increase is minor and does not add significantly to the

existing (pre 1990) high hazard (on account of the depth of inundation).




Page 278

Development in a High Hazard Area

The locations of the proposed works as part of the current proposal are primarily

determined by the availability of land adjacent to the existing Shoalhaven Starches plant.

There is no other suitable land available within the local area outside of a high hazard

area which can be used for the proposed purposes.

Shoalhaven Starches has a Flood Evacuation Plan and this should ensure that the

occupants (and all other personnel at the plant) will be safely evacuated from the

floodplain prior to the flood peak arriving.

7.10.2 Economic, Social and Environmental Impacts

According to Webb McKeown the economic impacts of the increases will vary from

property to property. In many cases, the buildings affected are already inundated before

any increases in level occur. This means that the majority of flood damages have

already been incurred and any incremental increases in flood damages due to the works

will be relatively minor.

The Paper Mill is inundated in a 5% AEP event (as occurred in March 1978) and the

increase in depth of inundation is only a small fraction of the total depth experienced at

the site. Some stock and equipment will be affected whilst for other fixtures there will be

no increase in damages. Overall, it is considered that there will be an increase in

damages, but it is likely to be only a small percentage of the total.

The Dairy Farmers plant (now vacant) is raised some 1.2 m above the 1% AEP flood

level and so will experience no inundation (or increases in flood damages) until

approximately a 0.1 % AEP event.

The frequency of closing a plant due to flooding is the greatest cost to the owners. The

two largest plants on the floodplain (excluding Shoalhaven Starches) are the Paper Mill

and Dairy Farmers. For both of these plants (and we presume Boweld) this occurs at

the 5% AEP (or a lower) level which is not affected by the cumulative increases.

Social impacts according to Webb McKeown are closely tied to economic impacts but

are most influenced by the occurrence of floods. Therefore once the area is evacuated

(say a 5% AEP event), the social impacts do not increase significantly and are generally

unaffected by the cumulative increases.

Environmental impacts associated with the increases in flood levels are negligible

according to Webb McKeown as there is little impact upon the duration of inundation,




Page 279

and the increases in level represent only a very small percentage increase in overall

depth of flooding.

Future Development

The effects of the impacts must also be considered in light of the possible future uses of

the land. As far as one can foreshadow at this time, the majority of the northern

floodplain will remain as rural land as there is little opportunity for non flood compatible

development due to the considerable depths of inundation and flood hazard. For these

areas the impacts on future users will be nil.

There will undoubtedly be some further expansion or redevelopment within the existing

three major plants in the future, and the increases in flood levels due to the works may

require equipment or floors to be set at a higher level, assuming that the owners wished

to construct above a certain AEP. This might involve some additional expense

(additional fill) to achieve this objective, but it is unlikely to be significant and in many

cases (raising electrics) there will be no real increase.

Climate Change

Whilst not an issue raised in the formal Director-General’s Requirements for this project

it is noted that concern has been raised that any flooding assessment should also be

cognisant of the future potential for climate change. Such an assessment requires

further detailed modelling which Shoalhaven Starches undertakes to have prepared prior

to the completion of the exhibition of this EA. Such an assessment will be undertaken in

accordance with the DECC “Floodplain Risk Management Guidelines – Practical

Consideration of Climate Change”.

7.10.3 Mitigation Measures

According to Webb McKeown the hydraulic impacts of the proposed ethanol upgrade

and odour reduction works (increase in flood level, change in velocity or flow) cannot be

negated by any sustainable means but the consequences of the impacts can be

minimised.

Flood management measures such as dredging the Shoalhaven River to increase the

channel’s capacity have been considered, but these are not environmentally suitable,

socially acceptable or economically viable to negate or reduce the increases in flood

levels. Direct mitigation of economic damages through levees or flood proofing of

buildings is also not viable. The main difficulty with levees lies in maintaining

accessibility to the buildings or area as well as internal drainage within the leveed area

and possible adverse hydraulic impacts elsewhere.




Page 280

Property or response management are the most appropriate measures for addressing

the associated environmental, economic and social effects of the cumulative flood

impacts. The following provides a summary of possible mitigation measures.

Modify the Proposed Design or Relocate the Works

Proposed New Packing Plant and Container Loading Area – including Railway Spur Line

The packing plant and container loading area is located within a flood storage area

which will have minimal restriction on flow paths. It is bounded to the west by high

ground, to the north by Council’s sewage plant and to the south by properties along

Bolong Road. As far as possible the works are located away from Abernethy’s Drain.

It is not possible to relocate or re-design the layout to further minimise the hydraulic

impact as these works must be close to the existing rail line.

In conclusion the size, shape and general dimensions of the works have been designed

to provide minimal hydraulic impact, whilst at the same time recognising the necessary

site requirements (adjacent to the rail line).

Works at the Plant

The proposed new equipment is necessary for the continued growth of the plant. Due to

site constraints, it is not possible to alter the locations and designs to any significant

extent in order to minimise the hydraulic impacts.

Improve Flood Warning System

The Shoalhaven River has an ALERT flood warning system which is operated by

Council and the Bureau of Meteorology. Discussions with the Paper Mill management

(and indicated in their Emergency Flood Policy document) have confirmed the

importance of flood warning in reducing flood damages (move product, raise pumps). If

the flood warning system was improved (as proposed in the Riverview Road Floodplain

Management Plan) this would provide a benefit to all floodplain users. In doing so this

action may reduce the potential increases in economic damages at the Paper Mill and

elsewhere resulting from the increases in flood levels.

There are a variety of ways of improving the ALERT system and these are documented

in the Riverview Road Floodplain Management Study and Plan. These measures would

also provide benefit to all other floodplain users.




Page 281

Provide or Improve Flood Emergency Plans

As noted previously, the Paper Mill already has an Emergency Plan. In discussions with

the management of the Paper Mill in 2001 it was apparent that improvements could be

made which may further reduce potential damages.

The main improvement could be achieved by a re-examination of the workings of the

plant and updating of the Emergency Plan. Survey of the motors/equipment would also

assist in ensuring that the actions proposed in the plan accurately “target” the affected

areas in the most cost effective and timely manner. For example, the benefits of moving

stock may far outweigh any other possible measure. However, there is also the possible

opportunity to introduce some flood preventative measures (raising switch gear, for

example). The feasibility of such proposals would need to be examined by a qualified

mechanical/electrical expert. If these works were carried out they may eliminate the

increases in damages caused by the cumulative increases in flood levels.

There is no Emergency Plan for Dairy Farmers and it is unlikely that providing such a

plan would be of benefit on account of the low probability of the plant itself being

inundated and as the plant is presently vacant.

It is unlikely that Emergency Plans for residential and small commercial premises would

be beneficial, due to the relatively high turnover rate, and as such it has not been

considered further.

Provide Depth Indicators

Signs indicating water depth can assist floodplain users in evacuating the floodplain. It

has been noted that at present there are few along Bolong Road. Provision of such

signs would assist in minimising future damages for all occupants along Bolong Road

and increase their awareness of the flood hazard.

Improved Flood Awareness and Preparedness

One of the most beneficial means of reducing flood damages to existing buildings

(residential, commercial and industrial) is to improve the awareness and preparedness of

the occupants. There are a number of ways of undertaking such a scheme and these

are outlined in the Riverview Road Floodplain Management Plan. Funding of a scheme

would assist in improving the community’s flood awareness and consequently reducing

flood damages.




Page 282

Dedication of a Floodway on the Northern Bank

The DLWC (correspondences of 27th June 2002, 15th January 2001 and previous) has

proposed the idea of dedicating a “floodway” zone on the northern bank. This would

provide a “cap” on future development in the area and also ensure that present or any

future development does not impact upon the major flow paths in the area. This concept

was examined by Webb McKeown as part of the investigation for Pond No. 6 (March

2001) and the outcomes are summarised as follows.

In order to examine the effects of further development along the river bank, a series of

hydraulic model simulations were undertaken as part of the studies for Pond No. 6. The

objective was to use the hydraulic CELL Model to demonstrate that “beyond say a limit

of 100 metres no further development should be permitted”, on account of the significant

increase in flood levels.

The model results did not support the proposition that the river bank is a critical area for

preventing further development. A run simulating a 100 m wide barrier to flow (parallel

to the river bank) immediately east of the Shoalhaven Starches plant indicated a

± 0.01 m or less impact on river levels for the range of flood events (5% AEP to

Extreme). The main reasons for this result are:

• The northern river bank is relatively high (4.4 m to 5.4 m AHD) which means that the

bank is only just overtopped (by a maximum of 0.3 m) in the 5% AEP event;

• The northern river bank is some six kilometres long (Bomaderry to Broughton

Creek). 100 m represents less than 2% of the total distance.

• There is a minor increase in flood level (0.01 m or less) in the Shoalhaven River as

a result of the 100 m barrier. This consequently produces an increase in flow over

the remainder of the river bank (this can be a significant increase in total flow as the

river bank is relatively long) which partially compensates for the isolated loss of

overflow area on the northern bank.

• In the 1% AEP event a 100 m barrier will reduce the flow over the river bank at this

location (Weir 109) by approximately 100 m3/s out of a total flow of 270 m3/s (37%

reduction). However a 100 m3/s increase in flow in the Shoalhaven River represents

only 0.7% of the total flow of around 14 000 m3/s. This increase is easily spread

across the 1 kilometre wide river resulting in the nominal increase in flood level of

0.01 m or less. According to Webb McKeown the increases in flood level due to the

storage ponds were partially mitigated by reducing the flow into the northern

floodplain. Flood levels do rise in the Shoalhaven River but by less than 0.01 m.




Page 283

• The main reasons for the impacts associated with the Storage Ponds (Nos. 1 to 7) is

that they occupy a relatively large waterway area in a 1% AEP event (say 3 m high

and approximately 550 m long by 550 m wide), and together with a “flat” flood

gradient this means that any increases are transmitted a long way upstream. Within

the Shoalhaven River proper there is a much “steeper” flood gradient and any

impacts dissipate within a shorter distance.

From these preliminary results it is clear that dedication of a “floodway” zone is

necessary to prevent total “blocking” of the northern river bank. However, the results

indicate that blocking (say) a 100 m wide strip, does not have a significant impact upon

flood levels.

The flow path across the northern river bank is the key control which determines how

much of the floodwaters passing under Nowra Bridge enters the northern floodplain.

The bank has the highest ground levels in the immediate area and thus any reduction in

its capacity will reduce the ability of floodwaters to reach the overbank floodplain. The

developments along Bolong Road, including the small commercial/industrial buildings in

the eastern part of Bomaderry, the Shoalhaven Starches, Dairy Farmers and Paper Mill

plants have all contributed to a reduction in the capacity of the flow path. Any further

intense development along the river bank will need to be examined in detail. However,

the ponds which are the main impediment to flows are all located some 500 m from the

river bank. Thus their impact on the flow paths from the river is negligible as the

floodwaters have largely dissipated once they cross Bolong Road.

House Raising

House raising is a means by which the entire house can be raised (typically on piers)

above the nominated flood levels. In this way flood damages within the house can be

eliminated to the nominated level. However external damages and the risk to life in

moving to/from the house during a flood are not affected. This measure is really only

appropriate for non-brick buildings on piers (preliminary inspection by Webb McKeown

indicates that all buildings along Hannigans Lane may be suitable). The cost is typically

$60,000 per building and this measure has been widely used throughout NSW. It

generally cannot be used for commercial/industrial buildings due to their size and as they

are typically on concrete slabs.




Page 284

7.11 WASTE MANAGEMENT

This section of the EA is based upon a Waste Management Report prepared by

Stephenson Environmental Management Australia (SEMA). A copy of this report forms

Annexure L to this EA. This report was prepared in response to the Director-General’s

requirements for the preparation of this EA which required:

“Waste Management – identify the quantity and type of all liquid and solid waste generated at the site and how this waste would be handled, processed and if necessary disposed of.

The purpose of the report prepared by SEMA is to describe the current waste generated

on the site and current disposal methods. Shoalhaven Starches already has an existing

Waste Management Standard Operating Procedure in place as part of the company’s

quality system.

The proposed expansion will see the current procedure/system amended where

appropriate to cope with the additional volume of waste.

Shoalhaven Starches has a Quality System, which contains procedures relating to

environmental aspects of the operation. The company is also in the process of

developing and implementing an Environmental Management System (EMS) in

accordance with the International Standard ISO 14001. Where applicable, cross-

referencing to these procedures has occurred within the Waste Management Report

prepared by SEMA.

7.11.1 Legal and Regulatory Requirements

Waste Avoidance and Resource Recovery (WARR) Act 2001

This Act seeks to encourage the most efficient use of resources and to reduce

environmental harm in accordance with the principles of ecologically sustainable

development. In addition the Act seeks to ensure that resource management options

are considered against the waste hierarchy.

Shoalhaven Starches has taken these principles into account when developing waste

management strategies.

Protection of the Environment Operations Act 1997

Shoalhaven Starches has been licensed by the NSW EPA, and now DECC, under the

provisions of the Protection of the Environment Operations Act 1997. The environment

protection licence (No. 883) remains in force for the life of the Facility.

Shoalhaven Starches must continue to comply with the conditions of the EPL.




Page 285

7.11.2 Waste Identification and Classification

Types, Volumes and Classification

Table 34 summarises the solid waste generated from various areas of the operation,

what waste can be generated and the classification in terms of the DECC Guidelines.

Table 34

Solid Waste Generated on Site

Process Area Waste Generated

Gluten Plant Reject waste

Starch Plant Reject waste

Damaged and out of spec packed powered product

Gluten and Starch Plants Dry product spills

Ethanol and Distillation Plants Wastes from Grain line and fermenters

Quarantine waste

Coal Fired Boilers Boiler and fly ash

All areas of the plant and Environmental Farm

Cardboard and paper

Scrap Metal (Stainless and Black)

Plastic wrapping and paper bags

Timber

Plastic and metal drums

General rubbish

Environmental Farm Settled Solids

Analytical vials

Table 35 lists all the types of solid waste generated, which are not reprocessed in the

production factory and their associated classification under the NSW EPA Environmental

Guidelines: Assessment, Classification & Management of Liquid and Non-Liquid Wastes

(NSW, EPA, 1999).




Page 286

Table 35

Waste Classification of Materials Taken Off-site for Disposal

Type of Waste Waste Classification

Quarantine waste Liquid and Non-Liquid Hazardous

Boiler ash Inert/solid waste

Cardboard and paper products Non-liquid solid waste

Scrap Metal (Stainless and Black) Inert/ solid waste

Timber Inert/ solid waste

Plastic drums and palecons Inert/ solid waste

Analytical vials Hazardous – DG Class 8 – UN3264-1830

Settled Solids Liquid-Group B Food Waste

7.11.3 Environmental Management Plan

7.11.3.1 Solid Waste Management

Shoalhaven Starches goal is to minimise the generation of solid waste on site and to

handle the waste that is generated in a manner that it will not pollute the environment.

The Company’s performance objectives and targets are to:

• avoid, minimise or recycle wherever possible, or responsibly dispose of waste;

• maximise the re-use or recycling of wastes that are generated during construction.

Shoalhaven Starches has adopted the Resource Management Hierarchy principles of

the WARR Act which are as follows:

• avoid unnecessary resource consumption as a priority;

• avoidance would be followed by resource recovery (including reuse of materials,

reprocessing, recycling and energy recovery); and

• disposal would be taken as the last resort.

Shoalhaven Starches has a Waste Management System procedure (SA-P-140) already

in place. This procedure outlines the waste to which the procedure applies and outlines

the procedures of managing and disposing of the wastes generated at the factory site.

SA-P-140 would be up-dated to include the elements of the proposed increase in

ethanol production and the associated activities if the development proceeds.




Page 287

Table 36 is a summary of solid wastes that may be generated during the construction

period and how they will be managed or disposed of. The table also includes the

expected waste volumes to be generated as a result of the production increase. The

exact impact on waste volumes will not be known at this point in time, however a 40%

increase across the board has been used.

In order to facilitate waste management in the future the following recommendations

should be implemented:

• Waste Management Database is established to track volumes of waste being

generated.

• Where they don’t already exist, the Environmental Manager, or their delegate,

develop written agreements with all “waste” disposal companies for those wastes

that are taken off-site for reuse, reprocessing/disposal.

The agreement should specify, but not be limited:

− The name of company.

− What material/waste that are taking off-site.

− Where material is being transported to.

− Disposal method – landfill, reused, reprocessed, etc.

− Pickup interval.

− Reporting requirements – eg. providing Shoalhaven Starches with monthly or

quarterly reports on the volume of waste pickup.

− Records/licences/permits allowing companies to transport and dispose of the

waste.

• Maintaining copies of all written agreements.

Shoalhaven Starches commit to implementing the above recommendations.



Page 288

Tab

le 3

6

So

lid

Waste

Man

ag

em

en

t – W

aste

s G

en

era

ted

Pro

ces

s A

rea

Waste

ge

ne

rate

d

Dis

po

sal

Meth

od

Cu

rren

t A

pp

rox.

Vo

lum

e

Dis

po

sed

of

Off

-s

ite

pe

r W

eek

Pro

po

se

d

Ap

pro

x.

Vo

lum

e

Dis

po

sed

of

Off

-sit

e p

er

Week

Glu

ten P

lan

t R

eje

ct w

ast

e

Re

ass

ign

ed

or

repro

cesse

d w

ithin

pro

ductio

n p

lant

No

t a

pp

licab

le

No

t a

pp

licab

le

Sta

rch P

lant

Reje

ct w

ast

e

Re

ass

ign

ed

or

repro

cesse

d w

ithin

pro

ductio

n p

lant

No

t a

pp

licab

le

No

t a

pp

licab

le

D

am

ag

ed

an

d o

ut o

f sp

ec

packed

po

wdere

d p

rodu

ct

Re

cyc

led b

ack a

t th

e b

egin

nin

g o

f th

e p

roce

ss a

t th

e F

lou

r L

oa

de

r N

ot a

pp

licab

le

No

t a

pp

licab

le

Glu

co

se P

lant

Carb

on f

iltera

id

Use

d a

s a

n ing

red

ient in

to D

DG

s

2 to

nne

s

2.8

ton

nes

Glu

ten a

nd S

tarc

h

Pla

nts

D

ry p

rodu

ct s

pill

s C

lea

n u

nco

nta

min

ate

d d

ry p

rodu

ct

is r

epro

ce

ssed

thro

ugh t

he

fact

ory

and s

lurr

y is

sent to

th

e f

erm

en

tation

pla

nt.

No

t a

pp

licab

le

No

t a

pplic

ab

le

D

am

ag

ed

ba

gs o

f st

arc

h

Da

ma

ge b

ag

s o

f sta

rch a

re r

epro

cesse

d thro

ug

h f

erm

enta

tio

n

pla

nt

or

for

starc

h s

lurr

y N

ot a

pp

licab

le

No

t a

pp

licab

le

D

am

ag

ed

ba

gs o

f g

lute

n

Da

ma

ged

ba

gs

of g

lute

n a

re to b

e r

epro

cesse

d t

hro

ugh th

e

ded

icate

d r

ecyc

ling

ho

pp

er

and

re

cord

ed o

n t

he p

ackin

g r

ecord

N

ot a

pp

licab

le

No

t a

pp

licab

le

Q

uara

ntin

e w

aste

P

lace

d in a

de

sig

na

ted c

on

tam

inate

d w

aste

bin

. A

de

sig

nate

d

waste

com

pa

ny

colle

cts

the

mate

ria

l for

ultim

ate

dis

po

sal

No

t a

pp

licab

le

No

t a

pp

licab

le

Coal F

ired

Boile

rs

Bo

iler

and f

ly a

sh

Prim

arily

take

n o

ff s

ite b

y a

lice

nsed c

om

merc

ial co

mp

ost

er

an

d

lan

dsca

per

to b

e u

se

d a

s a

hort

icu

ltura

l co

mpo

st

ingre

die

nt.

50

to

nn

es

70

to

nne

s

Als

o s

om

e o

f th

e a

sh is

use

d b

y S

hoa

lha

ven

Sta

rch

es

as a

ba

se

for

roa

ds,

for

ne

w infr

astr

uctu

re a

nd to

be m

ixe

d w

ith s

oil

to le

ve

l dep

ressio

ns in

irrig

ation p

add

ock

s on t

he E

nvi

ron

menta

l Fa

rm.

296 t

onn

es

414 t

onn

es



Page 289

Tab

le 3

6 (

co

nti

nu

ed

)

Pro

ces

s A

rea

Waste

ge

ne

rate

d

Dis

po

sal

Meth

od

Cu

rren

t A

pp

rox.

Vo

lum

e

Dis

po

sed

of

Off

-s

ite

pe

r W

eek

Pro

po

se

d

Ap

pro

x.

Vo

lum

e

Dis

po

sed

of

Off

-sit

e p

er

Week

Card

bo

ard

and p

ap

er

ba

gs

Co

llect

ed

in

de

sign

ate

d b

ins

and

co

llecte

d b

y co

ntr

act

or

for

recyc

ling.

2.2

5 t

on

ne

s 3.1

5 t

on

ne

s A

ll are

as

of th

e p

lant

and f

arm

in

clu

din

g

ma

in s

tore

, o

ffic

e/lab

, w

ork

shops a

nd

packin

g o

pe

ration

Me

tal

Co

llect

ed

in

de

sign

ate

d b

ins

and

rou

tin

ely

re

cyc

led b

y th

e

main

ten

an

ce c

rew

or

sold

to a

co

mm

erc

ial re

cyc

ler.

6.2

ton

nes

8.6

8 t

on

ne

s

T

imb

er

Takin

g t

o local w

ast

e m

an

ag

em

ent

cen

tre t

o b

e c

rush

ed

an

d

pre

pare

d for

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7.11.3.2 Liquid Waste Management

Shoalhaven Starches goal is to minimise the generation of liquid waste on site and to

handle the waste that is generated in a manner that it will not pollute the environment.

The Company’s performance objectives and targets are to:

• Avoid, minimise or recycle wherever possible or responsibly dispose of waste

• To maximise the re-use or recycling of liquid wastes that are generated

• Ensure irrigation of the wastewater is sustainable

Shoalhaven Starches has adopted the Resource Management Hierarchy principles of

the WARR Act which are as follows:

• Avoid unnecessary resource consumption as a priority

• Avoidance would be followed by resource recovery (including reuse of materials,

reprocessing, recycling and energy recovery) and

• Disposal would be taken as the last resort.

Shoalhaven Starches has following plan/procedure/document in place to manage liquid

waste on the factory site and minimise potential for pollution:

• Surface Water Management Plan

• Cooling water release monitoring – EN-P-0050

• Manildra Group – Shoalhaven Starches – Dangerous Goods. This document

contains drawings showing the location, type and volumes of various dangerous and

hazardous goods depots around the facility. It also contains the Dangerous Goods

Monitoring Plan.

Shoalhaven Starches Environmental Farm personnel use the following Standard

Procedures, Work Instructions and plans to operate and manage the farm:

(1) EN-P-0020 – Filling Out and Using the Environmental Farm 24hr Report

(2) EN-P-0090 – Environmental Farm – Pre Irrigation Checks

(3) EN-P-0100 - Irrigation with Pivot Irrigators

(4) EN-P-0110 – Irrigation with Travelling Irrigators

(5) EN-P-0120 – Flushing Irrigation Lines and Pivots

(6) EN-P-0160 – Odour Reduction at Irrigation Start-Up




(7) SA-P-140 – Waste Management System

(8) EN-P-0150 – Acid Protocol for Effluent Storage Ponds.

Table 37 summarises the liquid wastes currently generated, current disposal methods

and the volumes currently generated. It also includes the proposed current disposal

methods and volumes if ethanol production increases as proposed.

Table 37

Summary of Liquid Wastes

Process Area

Waste generated

Current Disposal Method

Proposed Disposal Method

Current Approx. Volume

Disposed of Off-site

Proposed Approx. Volume

Disposed of Off-site

Entire plant operations

Washdown Water

Pumped to the Environmental Farm’s storage ponds for disposal via irrigation

Biological wastewater treatment plant and either re-used in the plant, or diverted to the Environmental Farm for irrigation.

1.24 ML per day

2.25 ML per day

Condensate Pumped to the Environmental Farm’s storage ponds for disposal via irrigation

Biological wastewater treatment plant and either re-used in the plant, or diverted to the Environmental Farm for irrigation.

2.83 LM per day

5.75 ML per day

Retentate Biological treatment and disposal to Environmental Farm.

Not applicable

1.5 ML per day

COD reagent

Returned to supplier

Returned to supplier 0.125 L per week

0.2 L per week

7.12 VISUAL IMPACT

The Shoalhaven Starches Factory Site is located on Bolong Road, one of the main

gateway entrances to the Nowra/Bomaderry urban areas, and a significant tourist route

along this section of the South Coast.

The Scenic Character and Environment

The Shoalhaven Starches factory site is situated on Bolong Road, the gateway to

Bomaderry, within an area currently containing a mixture of rural and industrial land

uses. These different land uses contrast with each other and result in a mixed visual

character.




The rural areas, much of which comprises the Shoalhaven Starches Environmental

Farm, are generally flat to gently undulating and planted with pasture grasses. These

areas have a typical rural/agricultural character, common throughout the region. To the

north and forming a background to the rural landscape are the timbered slopes of the

Cambewarra escarpment.

The Shoalhaven City Council Heritage Study 1995 – 1998 prepared by Peter Freeman

Pty Ltd in association with JRC Planning Services identified the rural landscapes north of

the Shoalhaven River as the Berry-Bolong Pastoral Landscape. This Study described

this area as:

“North of the Shoalhaven River the area is dominated by the close relationship between the Princes Highway (formalised by Berry in 1857/1858) and the railway (1893) which were instrumental in determining the location of new homesteads on Berry estate lands which resulted from drainage schemes implemented by Sir John Hay. In the foothills to the north-west, and towards Cambewarra, settlement patterns were in the main determined by the impact of Free Selection after 1861. Sub-zones include the Cambewarra-Tapitallee area, Bellawongarah and the catchment areas of Broughton Creek north of Berry. The latter are focused around communities which developed outside the Berry Estate: Cambewarra, Tapitallee, Bundewallah, Woodhill and Broughton Vale. The scale and character are dependent on the distribution of small dairy farms, with internal and external boundaries created by modified and natural vegetation (River Oaks), roads, creeks and property boundaries.

Continuing dairy farms has contributed to the survival of the underlying late nineteenth and early twentieth century landscape patterns.”

The Shoalhaven Starches factory complex is characterised by typical industrial

structures with an overall bulk and scale that dominates the surrounding locality. The

site, despite being partially screened by vegetation along Bolong Road, the Shoalhaven

River and Abernethy’s Creek visually dominates the locality. The development is

particularly exposed to view along Bolong Road. This view reveals some of the internal

structures within the site including recovery and storage tanks, car park, fermentation

tanks and the Ethanol Plant. Overall the appearance of the site is typical of an industrial

facility of this nature.

The most relevant vantage points from where the factory site is visible would include:

The Princes Highway – views of the existing factory site are possible from selected

locations along the Princes Highway north of Bomaderry, travelling in both a northerly

and southerly direction. Whilst the factory site is visible in the landscape, its overall

visual impact is reduced by virtue of the distance between the plant; the intermittent




nature of the views; a rise in topography which screens the site from view; and

vegetation.

Burraga (Pig) Island – Burraga Island is situated in the middle of the Shoalhaven River

and provides the closest vantage point to the southern boundary of the site. The island

however is privately owned and not accessible to the public. Vegetation screening along

the riverbank adjacent to the site also reduces the visibility of the existing buildings and

structures.

Bolong Road – Bolong Road runs along the frontage of the site. Views of the plant are

possible when travelling in both an easterly or westerly direction. Some attempts have

been made to provide some tree planting along the boundaries to “soften” the

appearance of the development. The existing building forms and structures are however

clearly visible to motorists travelling along this stretch of Bolong Road.

Nowra Bridge – The Nowra Bridge crosses the Shoalhaven River and provides limited

opportunities for views of the factory site. The dominant visual elements from the bridge

are the river, vegetation along the riverbanks and the escarpment. The visual impact of

the factory site is reduced by distance as well as the bridge structure which permits only

glimpses of the site.

Bomaderry urban area – The existing plant is visible from a number of locations within

the eastern outskirts of Bomaderry. Bomaderry is slightly elevated and some locations

within the urban area do have extensive views of the site.

Terara – Distant views of the Plant are possible from a number of vantage points in and

around the village of Terara on the southern bank of the River. The visual impact of the

site however is reduced by distance, the intervening landform of Burraga (Pig) Island

and the vegetated riverbanks.

Riverview Road – Views of the site are available from residential development on the

southern bank of the Shoalhaven River. Vegetation along both the northern and

southern banks of the river partially screen the site from view.

Cambewarra Lookout – Cambewarra lookout is a popular tourist lookout providing

panoramic views over the Shoalhaven floodplain and estuary. Shoalhaven Starches,

like the other significant industrial sites, is visible from the lookout.




Visual Impact of Proposal

In terms of visual impact of the proposed works on the factory site, there are essentially

3 components: the installation of plant and structures within the existing factory site; the

additional buildings and plant to be sited with the DDGS Plant to the west of Abernethy’s

Creek; and the proposed new packing plant and container loading area to the north of

Bolong Road (including proposed pedestrian bridge and fire system)

The proposed structures within the existing factory site are generally of a similar height

as the existing structures. The building forms, shapes and characteristics are also

similar to those that presently exist on the site, and will conform to the visual character of

the site, ie. it is industrial development within an industrial setting.

The development of the land to the west of Abernethy’s Creek will include additional

cooling towers; buildings housing dryers and associated equipment with an overall

height of approximately 20 metres; and gas co-generation plant (approximately

15 metres maximum).

The proposed packing plant and container loading area will be located on the northern

side of Bolong Road and will have a height of 10 metres. The siting of the packing plant

will also include an overhead pedestrian / service bridge across Bolong Road to service

this site. This bridge structure will comprise a height of 11.6 metres.

The visual impact of these works from the identified vantage points (refer Figure 34) is

described as follows:

The Princes Highway

The Shoalhaven Starches factory is mainly visible from a section of the Princes Highway

between Boxsells Lane and Devitts Lane, Jaspers Brush (refer Plate 15). Due to the

configuration of the highway and the siting of the factory, only southbound vehicles view

the site. Vantage points along this section of the highway are 4.5 to 5.0 km from the site.

The site becomes less exposed and is eventually obscured by a rise in topography

further south of Boxsells Lane.

Given the distance form these vantage points the factory site is only barely visible. The

rising topography upon which Bomaderry is sited screens the western portion of the site,

as does intervening vegetation.

Given the distance of these views, and the screening of the site attributed to terrain and

vegetation it is considered the developments associated with this project will not

adversely impact on views from these vantage points.



Page 295

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Bolong Road

The existing factory site is clearly visible from Bolong Road by vehicles approaching

from the east, and along the frontage of the site refer (Plate 16).

Many of the proposed works associated with this proposal are located within the existing

developed portion of the existing factory site; and within proximity of similar designed

and sized structures to that proposed. For instance the proposed additional Fermenters

are sited adjacent to existing fermentation tanks; and the additional starch dryer, cooling

towers and molecular sieves are sited within the vicinity of similar structures.

Works associated with the DDGS Plant sited to the west of Abernethy’s Creek will mainly

involve structures of a similar bulk and scale as existing structures within this part of the

site.

These works will be partially screened from view along Bolong Road by virtue of existing

development sited along the Bolong Road frontage. Where element intrude above the

skyline of existing buildings they will be of a form similar to existing industrial structures

within the vicinity. (Refer Plates 17 and 18.)

The main components of the project that will be visible along Bolong Road will be the

new packing plant (and silos) and in particular the proposed overhead pedestrian /

product bridge that will cross Bolong Road.

The packing plant site is currently cleared. It adjoins a railway line, other industrial

development and Councils’ Sewerage Treatment Works. This development will involve

a substantial building with a height of 10 metres and silos with a height of just over

30 metres. The site however is to a larger extent shielded from view from Bolong Road

by existing development.

The proposed overhead pedestrian and product bridge will be clearly visible across

Bolong Road, Bolong Road is essentially a “gateway” into the Nowra / Bomaderry urban

area.

Shoalhaven City Council has resolved to give “In principle” support for this structure. In

doing so, however Council seeks the Company to agree to re-design the exterior

elements of the structure to improve its architectural and visual qualities commensurate

with a standard appropriate for the gateway to this urban area. The Company agrees to

Council’s view in this regard; and will endeavour to work with Council in providing a

design which meets Council’s concerns in this regard.




Plate 15: View of Shoalhaven Starches Factory from Princes Highway (within vicinity of Boxsells Lane). Factory stack barely visible from this vantage point.

Plate 16: View of Shoalhaven Starches factory site from Bolong Road from the east of the site.




Plate 17: View from Bolong Road of Access Point 2.

Plate 18: View from Bolong Road of the ‘Moorhouse’ site. Existing DDG plant is to rear of the ‘Moorhouse’ site.




Bomaderry Urban Area

The township of Bomaderry is slightly elevated and some locations within this urban area

have extensive views of the site (refer Plate 19). The proposed works particularly those

within the existing factory site are however unlikely to be visually prominent from these

vantage points.

The works to the west of Abernethy’s Creek however will be visible. These structures

will be similar in height to components of the existing factory site, and will be sited within

proximity of other industrial activities. In this way the vistas from these vantage points

will not be significantly altered.

Nowra Bridge

The view from Nowra Bridge to the east is mainly dominated by the river, riparian

vegetation and the floodplain (refer Plate 20). The site is largely obscured by riverside

vegetation. Works to the west of Abernethy’s Creek will be sited closer to this vantage

point than the remainder of the factory complex, and these structures are likely to

protrude above the canopy of the vegetation along the river. These structures however

will be sited within the overall “silhouette” of the existing factory complex, and will not

intrude into the existing skyline created by the existing factory.

The remainder of the works associated with this proposal will not be visible from this

vantage point.

Plate 19: View of Shoalhaven Starches factory site from corner of Meroo Road and Cambewarra Road, Bomaderry




Plate 20: View of Shoalhaven Starches factory site from Nowra Bridge over the Shoalhaven River

Riverview Road

The main vantage point from where the proposed works to the west of Abernethy’s

Creek will be visible will be from residences along Riverview Road directly south of the

site (refer Plate 21). This view is from a distance of about 750 metres. Riverside

vegetation along both the northern and southern banks of the river will screen much of

the site from view. In this way it is unlikely that the container storage will be visible from

this vantage point.

These works are likely to intrude above the tree canopy. This is the case with the

existing factory development. From this vantage point however, these works will be

sited within close proximity of the existing factory complex, and will be viewed within this

context.

The other works associated with the proposal will not be visible from this vantage point.

It is noted there are ‘gaps’ in the vegetation along the riverbank to the south of the site,

and the proposed development may be visible through these ‘gaps’. There is, therefore,

scope for supplementary landscaping and revegetation to take place along the riverbank

adjoining the factory site to help soften or obscure views of the site, particularly from this

vantage point.




Plate 21: View of Shoalhaven Starches factory site from Riverview Road area.

Terara

The village of Terara is approximately 1.5 kilometres from the factory. The proposed

works associated with this development will not be visible from this vantage point, mainly

due to vegetation along the riverbank (refer Plate 22).

Cambewarra Lookout

Cambewarra Lookout is situated about 7 km to the northwest of the site. Views from the

lookout are from an elevation over 620 m ASL, and encompass the Shoalhaven River

floodplain and the coast including Jervis Bay. Whilst the factory site is visible from this

vantage point, due to scale of the view, it would be extremely difficult to make out the

works associated with the project from this vantage point.

Overall it is considered that the proposed works will not create a significant adverse

visual impact due, principally, to the existing industrial development. There are however

measures which Shoalhaven Starches commit to implementing to assist in screening

and further minimising any visual impact.




Plate 22: View of Shoalhaven Starches factory site from village of Terara.

• The existing screening vegetation around the site is effective, particularly along the

river bank, however additional supplementary plantings of dense bands of native

trees and shrubs along the southern boundary of the site with the river (particularly

between the river and the proposed evaporator columns) would further reduce the

visibility of the development. In this regard a landscape and revegetation plan

should be prepared for that portion of the site zoned 7(f3) with suitable riparian

vegetation and including trees which will grow to a height to soften the view of these

works. Such a plan should be prepared prior to works commencing on the site.

• In order to reduce the visual impact and the proposed Fermenters, the northern and

eastern boundaries of the site should be landscaped with a combination of trees and

shrubs. Landscaping should also be incorporated between the packing plant /

container loading yard to Bolong Road to soften the appearance of this development

to Bolong Road. The abovementioned landscape and revegetation plan should also

detail such landscaping measures.

• Where planting has already been established, measures should be taken to protect

existing vegetation during the construction phase.




• In addition to landscaping, new structures can be constructed and treated to reduce

visual impact. Where appropriate and possible, buildings and structures should be

constructed of similar materials as those previously used on the site and be of a

non-reflective nature. Colours should blend with existing structures on the site to

ensure visual harmony. Consideration should be given to incorporating a cladding

colour which will blend with the surrounding locality.

• The exterior elements of the proposed overhead pedestrian / product bridge across

Bolong Road should be re-designed to improve its architectural and visual qualities

commensurate with this “gateway” site.

7.13 FLORA AND FAUNA

The following section of the EA is based upon the findings of the Flora and Fauna

Assessment prepared by Kevin Mills & Associates (KMA) and which is included as

Annexure E to this EA.

7.13.1 Description of the Vegetation

i. Factory Site

According to KMA no native vegetation occurs on the proposed ethanol upgrade sites at

the factory. Most of the sites have been cleared and sealed, and/or subjected to such

heavy use or traffic as to obliterate all vegetation, native or otherwise, except for

occasional weeds. The sites for the proposed water treatment / filtration plant and gas-

fired co-generators, which are located about 50 metres and 70 metres from the northern

bank of the Shoalhaven River, respectively, were found to be cleared land. A narrow

riparian corridor augmented by recently planted trees stands between the edge of the

river and these sites.

ii. Environmental Farm

The Shoalhaven Starches' Environmental Farm has been cleared and farmed for more

than a century. Located on the broad floodplain of the lower Shoalhaven River, much of

the farm is irrigated with wastewater from the company’s plant. The paddocks have

been pasture improved and grazed for many years, and native vegetation has almost

totally disappeared, except along the edge of Broughton Creek.

iii. Packing plant, rail siding, etc.

The site for the proposed packing plant, container loading area and associated access

road and rail siding is on cleared land owned by Shoalhaven Starches on the northern

side of Bolong Road. The site is in a cleared paddock dominated, according to KMA, by




Kikuyu Grass Pennisetum clandestinum and other introduced species such as White

Clover Trifolium repens, Mouse-eared Chickweed Cerastium glomeratum, Paddy's

Lucerne Sida rhombifolia, Fireweed Senecio madagascariensis, Spear Thistle Cirsium

vulgare and Blackberry Rubus fruticosus. There are occasional Black Wattles Acacia

mearnsii on the site.

There are a few trees in the far southern part of the site and near Abernethy’s Creek on

the eastern edge of the site; these are mostly Black Wattle Acacia mearnsii.

iv. Pipeline Route

The proposed pipeline is from the eastwards along the northern side of Bolong Road

within freehold land, mainly owned by Shoalhaven Starches, to the factory site. The

route is treeless, and according to KMA is dominated by a thick sward of Kikuyu Grass

Pennisetum clandestinum.

v. Changes to Storage Ponds

The area to be affected by alterations to the existing and approved wet weather storage

ponds (currently nearing completion) is cleared land use for grazing, a paddock

dominated by Kikuyu Grass Pennisetum clandestinum and other introduced pasture

species.

7.13.2 Plant Species Recorded

The plant species recorded by KMA in the areas to be affected by the proposed works

have been listed below, in Table 38. Native plants are uncommon in those areas

because of the long history of industrial use (on the factory site) and grazing (on the

environmental farm). Mainly introduced plant species are present.




Table 38

Plant Species

Taxonomic Name Common Name

Native Plant Species

Acacia mearnsii

Elaeocharis sphacelata

Hypolepis muelleri

Ranunculus inundatus

Black Wattle

Tall Spike-rush

Harsh Ground Fern

River Buttercup

Introduced Plant Species

Ageratina adenophora Crofton Weed

Cerastium glomeratum Mouse-eared Chickweed

Cirsium vulgare Spear Thistle

Hypochaeris radicata Flatweed

Ipomoea indica Morning Glory

Lantana camara Lantana

Paspalum urvillei Vasey Grass

Pennisetum clandestinum Kikuyu Grass

Rubus fruticosus sp. agg. Blackberry

Senecio madagascariensis Fireweed

Sida rhombifolia Paddy's Lucerne

Trifolium repens White Clover

Verbena bonariensis Purpletop

7.13.3 Fauna Habitat

According to KMA there is little to attract native animals to the factory site, but

Shoalhaven Starches' Environmental Farm provides wetland habitat for a wide range of

water birds. The fauna species that have been recorded by KMA on the Shoalhaven

Starches land at Bomaderry have been listed below, in Table 39. All of the species were

recorded on the Environmental Farm during previous surveys by KMA. Only a few

species were observed during the current survey on the sites to be affected by the

proposal upgrade; (see column 3 - Table 39). According to KMA this is not surprising,

given the highly modified nature of the sites.




Table 39

Fauna Species Recorded on Shoalhaven Starches’ Land, Bomaderry

Current Survey

Species Taxonomic Name 2007/08

Mammals

Brown Hare* Lepus capensis

Cattle* Bos taurus X

Short-beaked Echidna Tachyglossus aculeatus

Birds

Australian Magpie Gymnorhina tibicen X

Australian Pelican Pelecanus conspicillatus

Australian Raven Corvus coronoides X

Australian White Ibis Threskiornis molucca X

Australian Wood Duck Chenonetta jubata

Black-faced Cuckoo-shrike Coracina novaehollandiae

Black-shouldered Kite Elanus axillaris

Brown Songlark Cincloramphus cruralis

Cattle Egret* Ardea ibis X

Chestnut Teal Anas castanea

Common Mynah* Acridotheres tristis X

Common Starling* Sturnus vulgaris X

Darter Anhinga melanogaster

Dollarbird Eurystomus orientalis

European Goldfinch Carduelis carduelis

Fairy Martin Hirundo ariel

Galah Cacatua roseicapilla

Golden-headed Cisticola Cisticola exilis

Great Cormorant Phalacrocorax carbo

Great Egret Ardea alba

Grey Butcherbird Cracticus torquatus

Grey Fantail Rhipidura fuliginosa

Grey Shrike-thrush Colluricincla harmonica X

Grey Teal Anans gracilis

House Sparrow* Passer domesticus X

Little Pied Cormorant Phalacrocorax melanoleucos

Magpie-lark Grallina cyanoleuca X




Table 39 (continued)

Current Survey Species Taxonomic Name 2007/08

Masked Lapwing Vanellus miles X

Olive-backed Oriole Oriolus sagittatus X

Rainbow Lorikeet Trichoglossus haematodus

Richard's Pipit Anthus novaeseelandiae

Rock Dove* Columba livia

Sacred Kingfisher Todiramphus sanctus

Silver Gull Larus novaehollandiae

Spotted Turtle-Dove* Streptopelia chinensis

Straw-necked Ibis Threskiornis spinicollis X

Superb Fairy-wren Malurus cyaneus X

Welcome Swallow Hirundo neoxena X

White-bellied Sea-Eagle Haliaeetus leucogaster

White-faced Heron Egretta novaehollandiae

White-necked Heron Ardea pacifica

Willie Wagtail Rhipidura leucophrys

Yellow Thornbill Acanthiza nana

Yellow-billed Spoonbill Platalea flavipes

Yellow-rumped Thornbill Acanthiza chrysorrhoa

Frogs

Common Eastern Froglet Crinia signifera X

*Introduced species.

7.13.4 Impact of the Proposed Upgrade

Impact on Native Vegetation and Fauna Habitat

According to KMA the proposed upgrade will have little impact on flora and fauna. The

site has a low diversity of native plant species and, except for the ponds on the

Environmental Farm, there is little to attract native animals.

7.13.5 Conclusion and Recommendations of Flora and Fauna Assessment

The Flora and Fauna Assessment prepared by KMA makes the following conclusion with

respect to this project:




The proposed upgrade will have little impact on native flora and fauna. There are no areas of high conservation value on the site. The proposal is not likely to have an adverse impact on species, populations and communities listed under the New South Wales Threatened Species Conservation Act, 1995 and the Commonwealth Environment Protection and Biodiversity Conservation Act, 1999; no threatened species, populations or communities are known to occur on the subject land or are expected to occur there. The preparation of a Species Impact Statement (SIS) nor referral to the Commonwealth Environment Minister for approval is therefore not warranted.

The Flora & Fauna Assessment prepared by KMA makes the following

recommendations with respect to this proposal:

Recommendations

1. As far as is practicable, given the presence of the factory, the verges of Abernethy’s Creek should be planted with native species.

2. Appropriate screen plantings should be installed around the packing shed/loading area; local native species should be used for this purpose.

3. Additional plantings should be made in the environmental protection zone near the Shoalhaven River.

4. The list of local native species at Appendix 1 should be utilised in the planting programs around the site, as identified above. The list is not exhaustive and it is expected that not all species be used.

Shoalhaven Starches commits to implementing the above recommendations.

7.14 HERITAGE AND ARCHAEOLOGICAL ISSUES

7.14.1 Aboriginal Archaeology

South East Archaeology (SEA) was engaged by Shoalhaven Starches to undertake a

review of the potential Aboriginal heritage significance of the project site. Annexure D to

this EA is a copy of the Aboriginal Heritage Assessment report prepared by SEA in

relation to the likely impacts associated with this proposal on Aboriginal heritage

significance.

The principal aims of the Aboriginal heritage impact assessment were to:

• Undertake research, register searches and an archaeological survey and

consultation with the Aboriginal community to identify and record any aboriginal

heritage evidence, areas of potential evidence and cultural values within the study

area;




• Assess the potential impacts of the proposal upon any identified or potential

Aboriginal heritage evidence or cultural values;

• Assess the significance of any Aboriginal heritage evidence or cultural values

identified;

• Provide details of any Aboriginal heritage evidence in accordance with Department

of Environment and Climate Change (NSW) (DECC) requirements;

• Consult with the local Aboriginal community as per the DECC policy entitled Interim

Community Consultation Requirements for Applicants;

• Present recommendations for the management of any identified Aboriginal heritage

evidence, potential heritage resources or cultural values; and

• Prepare a formal archaeological report to meet the requirements of DECC and DoP.

The heritage investigation has proceeded by recourse to the archaeological and

environmental background of the locality, followed by a field inspection undertaken with

the assistance of representatives of the registered Aboriginal stakeholders. This

investigation was undertaken by an archaeologist (Peter Kuskie) with appropriate

qualifications and experience in Aboriginal heritage, in accordance with the DoP and

DECC requirements and guidelines.

Methodology

During the initial stages of the investigation, research was conducted into the

environmental, historical and archaeological background of the study area, and a search

was undertaken of the DECC ‘Aboriginal Heritage Information Management System’ and

other relevant heritage registers and planning instruments.

Consultation and involvement of the Aboriginal community was undertaken as per the

requirements of the DECC policy entitled Interim Community Consultation Requirements

for Applicants.

A survey has previously been undertaken of the eastern portion of the pipeline routes

currently under investigation, by Navin (1992). Navin (1992) investigated a 50 hectare

area for extensions to the Shoalhaven Paper Mill, and 22 hectares for the adjacent

Starches storage ponds. A survey has also been undertaken by Kuskie (2002) of

proposed extensions to the Starches Factory, which incorporated a portion of the area at

the Starches Factory presently under investigation. The survey was undertaken on 18

November 2002 with the assistance of the Nowra LALC and Shoalhaven Aboriginal

Elders (Kuskie 2002).




Field inspection of the study area was undertaken on 30 January 2008 by Peter Kuskie

of South East Archaeology, accompanied by Jason Davison of Dungarn Consultancy.

Given the high extent of existing land use impacts that have rendered the potential for

heritage evidence negligible in most portions of the study area, along with extremely low

surface visibility due to grass cover in those portions of the study area not totally

impacted by previous land use, the previous survey coverage (Navin 1992, Kuskie 2002)

and the predictive model, minimal areas were inspected directly on foot. Much of the

inspection consisted of visual reconnaissance, which encompassed the entire study

area.

Results and Discussion

The survey by Kuskie (2002) covered much of the area at the Starches Factory presently

under investigation. A total area of 4,160 m2 was inspected on the level-very gentle river

levee on the western side of the Starches Factory and 2,240 m2 on the levee on the

eastern side of the Starches Factory. Subsequent works have been undertaken in these

areas and the present inspection confirmed that due to the extensive impacts, there is

negligible potential for Aboriginal heritage evidence in both of these areas, along with the

other locations of proposed facilities within the Starches Factory.

Visual inspection was made of the area of the proposed facilities on industrial land

immediately north of the Starches Factory and Bolong Road. This area has been highly

impacted by earthworks, drainage works and other construction activities. Dense

pasture grasses limit surface visibility to virtually nil and therefore detailed survey was

not undertaken. Given the formation history of this low-lying floodplain, it represents an

environment context that has not been conducive to Aboriginal occupation. The only

Aboriginal use of this area is likely to have involved occasional exploitation of

subsistence resources from marshes or swamps, for which negligible evidence could be

anticipated to remain. In consideration of these factors, the potential for stone artefacts

to occur in this area is assessed as very low and the potential for all other forms of

Aboriginal heritage evidence to occur as negligible.

Visual inspection was made of the margins of Bolong Road, alongside which water and

gas pipelines may be installed to connect the Starches Factory with the storage ponds

and Paper Mill. The verges of Bolong Road are vegetated by introduced grasses and

have been highly impacted by earthmoving works, road construction, drainage works

and essential services (pipelines, telecommunications cables and electricity). The dense

cover of grass substantially limits surface visibility. The high level of recent land use




impacts in these areas has also reduced the potential for virtually all forms of Aboriginal

heritage evidence to occur as negligible, or in the case of stone artefacts, very low.

A survey has previously been undertaken of the eastern portion of the pipeline routes

currently under investigation, by Navin (1992). Navin (1992) investigated a 50 hectare

area for extensions to the Shoalhaven Paper Mill, and 22 hectares for the adjacent

Starches storage ponds. Navin (1992) identified two isolated artefacts, a ground edge

hatchet (APPM Isolated Find 1, DECC #52-5-288 and 52-5-289) listed twice on DECC

AHIMS at AMG grid references 283650:6140940 and 283660:614092, and a broken

alluvial pebble (APPM Isolated Find 2, DECC #52-5-290) listed on DECC AHIMS at

AMG grid reference 283500:6140900. The hatchet was identified within the wall of an

artificial drainage channel on the northern side of Bolong Road, 0.3 metres below the

present surface. Navin (1992) concluded that the item was not in situ. The hatchet was

made from a fine-grained volcanic alluvial pebble, by bifacial grinding and minor unifacial

flaking. The broken alluvial pebble was also located within a drainage channel on the

northern side of Bolong Road and comprised a similar stone material. Both items

appear to be located marginally adjacent to the proposed pipeline routes. The current

status of both items is uncertain.

Navin (1992) interpreted this evidence as accurately reflecting the generally low

archaeological sensitivity of the locality, with the possible use of the elevated river banks

(levee) as an access corridor.

No Aboriginal heritage evidence or cultural values were identified within the study area

during the present archaeological investigation. As discussed above, due to the extent

of recent land use impacts along with the topographical nature of the locality, the

potential for virtually all forms of Aboriginal heritage evidence (eg. scarred trees, carved

trees, ceremonial sites, stone arrangements, rock shelters, lithic quarries) is negligible.

In relation to the unobtrusive stone artefacts, although the levee may have served as a

corridor for movement as identified by Navin (1992), the extent of ground disturbance

renders the potential for artefacts within the Starches Factory as negligible and within the

adjacent industrial land and the margins of Bolong Road as very low. Although the

possible presence of a very low density of artefacts consistent with background discard

cannot be discounted in areas not totally impacted by recent land use, there exists a

very low potential for artefact deposits of sufficient integrity to be of research value.

While people may have occasionally visited this portion of the study area, the resulting

artefactual evidence is unlikely to be of sufficient nature, integrity, research potential or

representativeness to be of significance.




Aboriginal Consultation

The Aboriginal heritage assessment prepared by SEA involved a comprehensive

program of Aboriginal consultation that complies with the policy requirements of the

Department of Environment and Climate Change (NSW) that were introduced on

1 January 2005. These requirements are specified in the policy entitled Interim

Community Consultation Requirements for Applicants and involve the following

procedures:

1) Providing written notification of the project to the Local Aboriginal Land Council,

DECC, Registrar of Aboriginal Owners (Department of Aboriginal Affairs), NSW

Native Title Services and relevant Local Councils, requesting that if they are aware

of any Aboriginal persons/organisations who may wish to be consulted about the

project to provide such advice in writing, with a minimum of 10 day response

period;

Compliance with Procedure #1 was achieved through correspondence forwarded to the relevant organisations on 21 August 2007. Responses were received from the Office of the Registrar of the Aboriginal Land Rights Act, Shoalhaven City Council and DECC.

The Office of the Registrar of the Aboriginal Land Rights Act advised that there are no Registered Aboriginal Owners within this specific locality. Shoalhaven City Council advised that the Jerrinja LALC, Nowra LALC and Ulladulla LALC should be contacted. DECC advised that in addition to Nowra LALC, the Jerrinja LALC, Jerrinja Consultants, South East Coast Gadu Elders Aboriginal Corporation, Merrimans LALC, Ulladulla LALC, South Coast Aboriginal and Elders and Friends Group Organisation and Mr Lionel P Mongta should be contacted (refer to Appendix 2).

2) Providing written notification of the project directly to those Aboriginal

persons/organisations that were identified in Step 1 above, requesting those who

may be interested in participating in the project to register their interest in writing,

with a minimum 10 day response period.

Compliance with Procedure #2 was achieved by writing to the organisations nominated above by DECC and Shoalhaven City Council with an invitation register an interest as per the DECC policy. Non of these organisations registered an interest.

3) Placing a media advertisement to the same effect in the local press requesting any

Aboriginal persons/organisations who may be interested in participating in the

project to register their interest in writing, with a minimum 10 day response period;

Compliance with Procedure #3 was achieved by placing an advertisement in the Public Notices section of the Nowra South Coast




Register on 24 August 2007, requesting any Aboriginal persons/organisations who may be interested in participating in the project to register their interest in writing. Mr Jason Davison of Dungarn Consultancy registered an interest. The client also elected to continue to involve the Nowra LALC in the assessment, even though a formal registration of interest was not received.

4) Providing detailed information about the heritage impact assessment, including the

proposed methodology, to the Aboriginal persons/organisations who registered

their interest in writing in Steps 1 – 3 above, with a minimum 21 day response

period for comments;

5) Comments received from registered Aboriginal persons/organisations in Step 4,

including information on areas of cultural significance, potential culturally

acceptable mitigation measures, the nature of the assessment methodology and

any other relevant traditional knowledge or issues, must be considered in order to

finalise the assessment methodology;

Compliance with Procedures “4 and 5 was achieved by writing to the two organisations that registered an interest or were considered to be registered (Nowra LALC and Dungarn Consultancy) on 13 December 2007 providing them with the proposed methodology for the assessment and requesting their comment. No comments were received.

6) Field inspection in consultation with the registered Aboriginal stakeholders;

Compliance with Procedure #6 was achieved by undertaking the field inspection in consultation with the registered Aboriginal stakeholders. The inspection was undertaken on 30 January 2008 by Peter Kuskie of South East Archaeology, assisted by Mr Jason Davison of Dungarn Consultancy. Despite prior arrangements, Mr Simms from the Nowra LALC was unable to attend, but was satisfied for the inspection to continue in his absence.

7) Notifying the registered Aboriginal stakeholders and the Local Aboriginal Land

Council (even if not registered) of the availability of the draft Aboriginal heritage

impact assessment report and their comments invited; and

Compliance with Procedure #7 is being achieved by providing copies of the draft archaeological assessment report to the Nowra LALC and Dungarn Consultancy with a request for their comment.

8) Preparation of a final Aboriginal heritage impact assessment report that addresses

and incorporates the input of the registered Aboriginal stakeholders.

Compliance with Procedure #8 can be achieved through preparation of a final Aboriginal heritage impact assessment report that addresses and incorporates any input received from the registered Aboriginal stakeholders. Comments received can be attached and the




consultation database amended accordingly. Copies of the final report can be forwarded to the registered Aboriginal stakeholders.

In addition to the consultation above, both the Nowra LALC and Shoalhaven Elders were

involved in an earlier investigation of the Starches Factory by Kuskie (2002) and the

Nowra LALC was involved in the previous investigation of the eastern end of the pipeline

routes by Navin (1992).

Mitigation and Management Strategies

Development may involve substantial impacts to the ground surface associated with the

construction of facilities. However, according to SEA, much of the proposed works will

occur in locations that have already been totally impacted by recent land use and have

negligible heritage potential. The remainder of the area has also been subject to high

impacts and in consideration of Aboriginal land use modelling, is of very low heritage

potential. No Aboriginal heritage sites are listed within the study area on any heritage

registers or planning instruments, although two isolated artefacts are in the immediate

vicinity of the eastern end of the pipeline routes north of the existing Paper Mill.

General strategies for the management of the identified and potential Aboriginal heritage

resources within the study area are presented below. A key consideration in selecting a

suitable strategy is the recognition that Aboriginal heritage is of primary importance to

the local Aboriginal community, and that decisions about the management of the sites

should be made in consultation with the registered Aboriginal stakeholders.

Strategy A (Further Investigation)

In circumstances where a site is identified, but the extent of the site, the nature of its

contents, its level of integrity and/or its level of significance cannot be adequately

assessed solely through surface survey (generally because of conditions of low surface

visibility or sediment deposition), sub-surface testing may be an appropriate strategy to

further assess the site. Testing is also appropriate in locations where artefact or midden

deposits are predicted to occur through application of a predictive model of site location,

in order to identify whether such deposits exist and their nature, extent, integrity and

significance.

Test excavations can take the form of auger holes, shovel pits, mechanically excavated

trenches or surface scrapes. A Section 87 Permit is generally required from DECC to

undertake sub-surface testing, unless Part 3A approval has been granted and in lieu a

Statement of Commitments outlining such measures has been approved. Approval of a

Section 87 Permit can take up to eight weeks, following receipt by DECC of all

necessary information. A research design specifying the aims and methods is an




essential component of a Permit application and therefore requires approval from DECC.

Consultation is also required with the relevant Aboriginal stakeholders as per the DECC

policy entitled Interim Community Consultation Requirements for Applicants.

This is a pro-active strategy, which should result in the identification, assessment and

management of the Aboriginal heritage resource prior to any development activity

occurring. Following assessment of each Aboriginal site, management strategies as

outlined below (B – E) can be applied.

In relation to the proposed Starches upgrade, the inspection is considered satisfactory enough to present an effective assessment of the Aboriginal heritage resources potentially present within the study area. Test excavations are unlikely to add significantly to the present assessment or lead to alternative management strategies, and on this basis, the imperative for further investigation is considered to be very low.

Strategy B: Conservation

The suitability of conservation as a management option has long been recognised. This

strategy is suitable for all heritage sites, but particularly those of high archaeological

significance and/or high cultural significance. Conservation is also highly appropriate for

specific archaeological resources and environmental/cultural contexts, as part of a

regional strategy aimed at conserving a representative sample of identified and potential

heritage resources.

Options exist within development proposals that can be utilised for the conservation

identified or potential Aboriginal heritage resources, including exclusion of development

from zones of high heritage significance or potential, or preservation of areas within

formal conservation zones.

In relation to the proposed Starches upgrade, the imperative for specific conservation measures is limited by the small size of the proposed area of impact, high levels of existing ground disturbance, absence of identified heritage evidence of significance and the low potential for heritage evidence to occur. In consideration of these factors, specific conservation measures are not warranted.

Strategy C: Mitigated Impact (Salvage)

In circumstances where a site is of moderate or high significance within a local context,

but the options for conservation are limited and the surface collection of artefacts or

excavation of deposits could yield benefits to the Aboriginal community and/or the

archaeological study of Aboriginal occupation, the strategy of salvage can be

considered.




Salvage may include the collection of surface artefacts or systematic excavation of

artefact or midden deposits, normally as part of a Section 90 Consent obtained from

DECC. This strategy is the primary means of minimising impacts to Aboriginal heritage

from development projects where the option of conservation is not feasible.

The specific aims of any salvage project and the methodology could only be finalised

after consultation with the registered Aboriginal stakeholders and DECC, in relation to an

application for a Section 90 Consent. The application would need to address the views

and policy and legislative requirements of these key stakeholders. Consultation is

required with the relevant Aboriginal stakeholders as per the DECC policy entitled

Interim Community Consultation Requirements for Applicants. Alternatively, if a Part 3A

approval is granted, Section 90 Consent may be required but in lieu a Statement of

Commitments outlining proposed heritage management and mitigation measures must

be approved.

In relation to the proposed Starches upgrade, salvage measures are not warranted unless impacts cannot be avoided to one of the two isolated artefacts close to the project area (APPM Isolated Find 1). In this event, the ground-edge hatched (Isolated Find 1), should be subject to surface collection if it is likely to be impacted and can be successfully relocated, as initially recommended by Navin (1992).

Strategy D: Unmitigated Impact

The strategy of unmitigated impact involves the proponent making application to DECC

for a Section 90 Consent for any known Aboriginal objects that will be affected by a

proposal. This Consent must normally be obtained prior to the commencement of works

affecting the evidence, because all objects are protected under the terms of the National

Parks and Wildlife Act 1974. Alternatively, if a Part 3A approval is granted, Section 90

Consent may not be required, but in lieu a Statement of Commitments outlining

proposed heritage management and mitigation measures must be approved.

The support of the registered Aboriginal stakeholders should be obtained, through

further liaison, for any Section 90 Consent application or Part 3A Statement of

Commitments. Consultation is required with the local Aboriginal community as per the

DECC policy entitled Interim Community Consultation Requirements for Applicants.

DECC guarantees to process applications within eight weeks, subject to receipt of all

necessary information. This strategy is typically suitable when a site is of low scientific

significance, the local Aboriginal community holds no objections, and it is unfeasible to

implement any other strategy.




In relation to the proposed Starches upgrade, unmitigated impact is not warranted unless impacts cannot be avoided to one of the two isolated artefacts close to the project area (APPM Isolated Find 2) that does not require surface collection.

Strategy E (Monitoring)

An alternative strategy for zones where archaeological deposits are predicted to occur is

to monitor construction, particularly any initial earthmoving and soil removal works, for

the presence of artefacts, shell or skeletal remains.

Monitoring is the primary strategy for managing the possible occurrence of Aboriginal

skeletal remains. Monitoring for the presence of shell and stone artefacts is also often of

value to the Aboriginal community, who may be seeking to identify and salvage material

that was not visible on the surface during a preliminary study. The sieving of graded

deposits is also a practical measure that enhances the benefits of monitoring for

artefacts.

Monitoring for artefacts (in preference to sub-surface testing) is not a widely accepted

method within the context of a scientific investigation, because it could result in

substantial and costly delays to construction, late revisions to development plans, and/or

cause undesirable impacts to sites of cultural or scientific significance. However, when

Development Consent is granted, monitoring for the presence of artefacts and other

features during initial earthworks can be of scientific benefit and benefit to the Aboriginal

community. Monitoring undertaken in this circumstance may enable the identification

and retrieval of cultural evidence that may not otherwise have been recorded or

salvaged.

In relation to the proposed Starches upgrade, monitoring is not warranted as the potential for heritage evidence to occur is very low.

Recommendations

According to SEA the development area has either been totally impacted by recent land

use and has negligible heritage potential, or has been subject to high impacts and in

consideration of Aboriginal land use modelling, is of very low heritage potential. No

Aboriginal heritage sites are listed within the study area on any heritage registers or

planning instruments, although two isolated artefacts occur in the immediate vicinity of

the eastern end of the proposed pipeline routes, north of the existing Shoalhaven Paper

Mill (Figure 1). In the absence of appropriate management and mitigation measures, it

is concluded that the impacts of the proposal on Aboriginal heritage will be very low.




The following recommendations are made by SEA on the basis of legal requirements

including the NSW National Parks and Wildlife Act 1974 and Environmental Planning

and Assessment Act 1979, the results of the investigation and consultation with the local

Aboriginal community. Shoalhaven Starches commits to implementing these

recommendations.

� Provisions relating to Aboriginal heritage should be included in an Environmental Management Plan for the project. These provisions should be formulated in consultation with the registered Aboriginal stakeholders and specify the policies and actions required to manage the potential impacts of the proposal on Aboriginal heritage after Part 3A approval is granted. The plan should include management procedures for previously unrecorded Aboriginal heritage evidence and skeletal remains (should such evidence be identified during construction), procedures for further Aboriginal consultation should such evidence be identified, and mitigation measures involving surface collection for the identified isolated artefact site APPM Isolated Find 1 (DECC #52-5-288 and 52-5-289) should it be subject to impacts. The plan will, subject to Part 3A project approval, guide management of any Aboriginal heritage evidence in lieu of a Section 90 Consent;

� Under the terms of the National Parks and Wildlife Act 1974 it is an offence to knowingly destroy, damage or deface an Aboriginal object without obtaining the prior written permission of the Director-General of DECC. Therefore, no activities or work should be undertaken within the Aboriginal site areas as described in this report and marked on Figure 1, in the absence of a valid Section 90 Consent or in lieu, Part 3A approval;

� Single copies of this report should be forwarded for comment to the Aboriginal stakeholders (Dungarn Consultancy and Nowra LALC); and

� After revision of the draft report with the responses of the Aboriginal community, three copies of the final report should be forwarded to:

Manager South Branch Environment Protection and Regulation Division Department of Environment and Conservation (NSW) PO Box 2115 Queanbeyan NSW 2620

After implementation of these management measures, it is concluded that the risk of residual impacts to Aboriginal heritage from the proposal will be very low.

7.14.2 European Heritage

A review of heritage schedules of SLEP 1985, the IREP No. 1, Councils’ Heritage Study

as well as a review of the National Trust register has revealed no known items of

European heritage value on the factory site.




Council’s Heritage Study does identify an item of environmental heritage on the

Company’s Environmental Farm, on Lot 23 DP 811233. This item is a weatherboard

and iron farm house which is dated to about 1910. The Heritage Study describes this

building as

“Weatherboard and galvanised iron cottage reflecting the influence of the Federation style on the local Victorian Georgian idiom. The traditional hipped roof form with encircling verandahs has been modified by the introduction of two projecting gables which effectively truncate the verandah, restricting it to two sides. In contrast to other nearby weatherboard cottages the structure is clad with broad edge moulded pine boards. Windows are simple 2x2 sash but those in the gabled projections reflect Federation style in the use of narrow flanking fixed lights. The building appears to be supported on brick piers. At the rear a single brick chimney defines the kitchen and adjacent skillion extension. The cottage is similar to urban forms such as Cambewarra Post Office.”

The Heritage Study assessed the significance of this structure as follows:

“A simple weatherboard cottage reflecting the transition of the late Victorian vernacular style towards the Federation style. Characteristic of small farmhouses erected on land made available by the subdivision of the Berry Estate c.1900. Contributes to the Berry-Bolong pastoral landscapes. Local significance (Shoalhaven District).”

This item however is not identified as an item of heritage significance by Council’s SLEP

1985 (which was recently updated in terms of heritage sites and provisions).

The factory site is located 2.0 kilometres to the south west and no works are envisaged

within the Environmental Farm within the vicinity of this building. Under the

circumstances it is considered that the project will have no significant impact on the

heritage significance of the building.




8.0 STATEMENT OF COMMITMENTS – ENVIRONMENTAL MANAGEMENT

This section of the EA provides a Statement of Commitments agreed to by Shoalhaven

Starches Pty Ltd outlining environmental management, mitigation and monitoring measures to

be implemented to minimise potential impacts associated with this proposal and having regard

to the findings of the assessment of Key Issues as outlined in Section 7.0 of this EA.

The following is a Statement of Commitments as proposed by this EA, and agreed to by

Shoalhaven Starches:

8.1 LEGISLATIVE REQUIREMENTS

All activities carried out on the site, and in relation to the project, would comply with the

relevant provisions of all relevant legislation and regulations, and would also comply with

relevant policies and guidelines relating to the construction and operation of the project

including, but not limited to, those detailed in Sections 8.1.1 and 8.1.2.

8.1.1 Legislation and Regulations

• Aboriginal and Torres Strait Islander Heritage Protection Act 1984.

• Contaminated Land Management Act 1997.

• Dangerous Goods Act 1975.

• Environment Protection and Biodiversity Conservation Act 1999.

• Environmental Planning and Assessment Act 1979.

• Environmental Planning and Assessment Regulations 2000.

• Environmentally Hazardous Chemicals Act 1985.

• Fisheries Management Act 1994.

• Fisheries Management Amendment Act 2001.

• Heritage Act 1977.

• Heritage Amendment Act 1998.

• Local Government Act 1993.

• National Parks and Wildlife Act 1974.

• National Parks and Wildlife Amendment Act 2002.

• Native Vegetation Act 2003.

• Native Vegetation Conservation Act 1997.

• Noxious Weeds Act 1993.

• Occupational Health and Safety Act 2000.

• Ozone Protection Act 1989.

• Pesticides Act 1999.

• Protection of the Environment Operations Act 1997.

• Protection of the Environment Administration Act 1997.

• Roads Act 1993.




• Rural Fires Act 1997.

• Soil Conservation Act 1938.

• Threatened Species Conservation Act 1995.

• Threatened Species Conservation Amendment Act 2002.

• Waste Avoidance and Resource Recovery Act 2001.

• Waste Recycling and Processing Corporation Act 2001.

• Water Act 1912; and

• Water Management Act 2000.

8.1.2 Policies and Guidelines

• Managing Urban Stormwater: Soils and Construction, NSW Department of Housing

(1998).

• Australian and New Zealand Guidelines for Fresh and Marine Water Quality,

Australian and New Zealand Environment and Conservation Council, and the

Agriculture and Resource Management Council of Australia and New Zealand

(2000).

• National Environment Protection Measures (NEPM) for Ambient Air Quality, NEPC

(1998);

• EPA/DECC Bunding and Spill Management Guidelines; and

• Industrial Noise Policy, DEC (1999).

8.2 APPROVALS, PERMITS AND LICENCES

All necessary approvals, permits and licences required by NSW legislation must be

obtained prior to construction commencing. Approvals, permits and licences that may be

necessary may include, but are not necessarily limited to:

• The Contractor and the Proponent are obliged to notify DEC when a pollution

incident occurs that causes or threatens ‘material harm’ to the environment, under

the Protection of the Environment Operations Act, 1997.

The Contractor and Proponent shall liaise with relevant government agencies to ensure

that all their requirements are met in relation to approvals, permits and licences. The

relevant government agencies include, but may not be limited to:

• Department of Planning for project approval;

• Department of Environment and Climate Change for potential impacts to water, air,

noise, waste, flora, fauna, aboriginal heritage issues, and works in or near

waterways; and




• Shoalhaven City Council for works within the road corridor.

All necessary licences, approvals and permits obtained by the Contractor and/or

Proponent must be complied with, maintained and renewed as necessary throughout the

duration of the works.

8.3 SPECIFIC COMMITMENTS

8.3.1 Construction Environmental Management Plan

The Contractor/Proponent would prepare and implement a Construction Environmental

Management Plan (CEMP). The CEMP would be prepared generally in accordance with

the framework, principles and requirements detailed in AS/NZS ISO 14001:2004:

Environmental management systems – Specification with guidance for use.

The CEMP would be developed prior to site activities commencing, and would be fully

implemented, maintained, reviewed, audited and updated throughout the construction

phase as may be required by the Conditions of Approval, or as otherwise directed.

In addition to the generic requirements of ISO/NZS 14001 the CEMP would address

and/or develop:

• All relevant Conditions of Approval and environmental requirements;

• All other environmental control measures, actions, procedures and activities

required to address all relevant legislation, regulations, guidelines and policies;

• Environmental monitoring programs, including the identification of monitoring

locations, equipment, methodologies, analytical requirements, quality trigger

levels/thresholds, and reporting mechanisms;

• Roles and responsibilities for the environmental management of the works;

• Environmental training requirements, procedures, and documentation; and

• A complaints management and community consultation/notification process.

The CEMP would document the key environmental management measures associated

with the construction phase of the project, which would include, but not necessarily be

limited to:

• General environmental management measures;

• Erosion and sediment control;

• Air quality (dust);




• Noise; and

• Waste and chemical management.

Further details on each key issue are provided in Section 8.0. Appropriate

environmental mitigation and control measures for each key issue are detailed in

Table 40 to Table 60.

8.3.2 General Environmental Management

Table 40

Environmental Management Framework Environmental Management Framework

Environmental Management Framework

All safeguard measures detailed in the Environmental Assessment and project approval would be applied to the project.

Environmental awareness training would be provided to all personnel (including all labourers/ plant operators/ supervisors and engineers), and would address, but not be limited to:

• Sedimentation and erosion control;

• Water quality control;

• Pollution control; and

• DECC requirements.

The training would commence at the start of construction and would continue as new personnel are engaged.

A register of environmental awareness training would be established and maintained at the site. The register would contain details of the type of training, personnel trained, training dates and qualifications of the trainer.

All necessary approvals, permits and licences required by NSW and Commonwealth legislation would be obtained prior to construction commencing. These approvals, permits and licences would be maintained and complied with during the construction period. Liaison would occur with the:

• Department of Environment and Climate Change (water, air, noise, waste, flora, fauna, aboriginal heritage issues, works near waterways); and

• Shoalhaven City Council (works within the road corridor).

to ensure all their requirements are met in relation to approvals, permits and licences.

All wastes would be transported by licensed waste management contractors and would be disposed of to an appropriately licensed waste management facility.

A register of public complaints would be established at time of construction commencing and maintained for the full duration of construction. The register would record details of complaints, complainant contact information and action taken to address complaints.

Any complaints received would be recorded and attended to promptly. On receiving a complaint, works would be reviewed to determine whether issues relating to the complaint could be avoided or minimised. Feedback would be provided to the complainant explaining what outcomes resulted.




8.3.3 Soil and Water Management

The potential impacts of construction activities on soil and water resources are generally

associated with the erosion of soils and subsequent discharge of sediments or turbid

runoff to watercourses, together with pollution associated with the spillage of fuels,

chemicals, and other materials into waterways.

The location of some of the construction activities immediately adjacent to the banks of

the Shoalhaven River, Bomaderry Creek and Abernethy’s Drain increases the risk of

potential impacts to the river occurring. Environmental control measures to minimise the

risk of discharges to the Shoalhaven River, are detailed in Table 41.

An Acid Sulphate Soils (ASS) assessment has been undertaken by Coffey Geotechnics.

ASS management would be undertaken, as required, in accordance with the

recommendations of the Coffey Geotechnics report. This is dealt with separately in

Section 8.3.18.

Table 41

Soil and Water management Measures Soil and Water Management Measures

Soil and Water Management Measures

Site-specific indicative Erosion and Sediment Control Plans (ESCPs) for the project are provided in Appendix A. The indicative ESCPs identify appropriate control measures and practices to prevent soil and erosion impacts, and discharges of turbid site runoff offsite or to the Shoalhaven River system. The ESCPs would be further developed by the proponent and contractor prior to construction commencing.

All erosion and sediment control measures detailed in the ESCPs would be implemented on site prior to construction commencing.

All erosion and sediment controls would be inspected by the Contractor/Proponent at a minimum of weekly intervals and within 24 hours of all rainfall events exceeding 10 mm in a 24-hour period. Regular routine maintenance would be undertaken to de-silt sediment basins and traps, replace damaged sediment control fences and other structures. A register of these inspections, maintenance and rainfall levels would be maintained. One person would have overall responsibility on site for erosion and sediment control issues.

Loss of suspended solids and sediment to the Shoalhaven River, Bomaderry Creek or Abernethy’s Drain would be prevented by using (where appropriate) reverse superelevation for any excavations near the banks of the watercourses, constructing berms along the edge of the site to prevent runoff to the river and installing silt fences along the property boundary with the river.

A silt fence would be installed between the various sites and the Shoalhaven River, Bomaderry Creek and Abernethy’s Drain along the entire perimeter of the construction area, to prevent suspended solids being transported off-site. The silt fence would be constructed in accordance with Standard Drawing SD 6-7, from the publication Managing Urban Stormwater: Soils and Construction, NSW Department of Housing (1998).

Where possible all site runoff would be collected and diverted to the site stormwater management system, which would then convey it to the Environmental Farm for treatment and irrigation, thereby preventing any off-site impacts.





Soil and Water Management Measures (continued)

The inlet grates of the site stormwater management system would be covered with geotextile to provide initial filtering of gross sediment pollutants before conveyance to the Environmental Farm. Alternatively, the grates could be protected by implementing the control measure detailed in Standard Drawing SD 6-9 (refer Appendix B), from the publication Managing Urban Stormwater: Soils and Construction, NSW Department of Housing (1998).

Works relating to drainage and sediment control would be completed promptly to minimise exposure time of disturbed areas.

Exposed areas of erodible material would be limited to those areas being actively worked.

Any material stockpiles on site would be designed and located to prevent any loss of sediment, or other materials, to the Shoalhaven River system in the event of heavy or prolonged rainfall

Temporary sediment control fences would be installed down slope of any stockpiles.

Stockpiles would not be located within 50 m of a watercourse, in accordance with NSW Department of Primary Industries (Fisheries) requirements.

In the event of a spillage of potentially harmful chemicals, fuels, oils or materials, the DECC would be contacted immediately, and contaminants would be immediately contained, removed, treated (if necessary) and disposed of in accordance with DECC requirements.

An incident/emergency spill plan would be developed. This would include measures to avoid spillages of fuels, chemicals, and fluids onto the floodplain and/or into any waterways. All personnel would be made aware of these measures. An emergency spill kit would be kept onsite at all times.

All fuels, chemicals, and liquids would be stored at least 50 m away from any waterways or drainage lines within an impervious bunded area designed in accordance with the EPA/DECC Bunding and Spill Management Guidelines.

All erosion and sediment control structures would be removed only after adequate stabilisation of disturbed surfaces is achieved.

Any wastewater generated from construction processes would be contained onsite and directed (where possible) to the site stormwater management system for conveyance to the Environmental Farm for treatment and irrigation. Where conveyance to the Environmental Farm is not possible, all stormwater would be appropriately treated to minimise the levels of suspended solids, oil and grease and pH being discharge to the environment. Any discharge to the environment would be managed in accordance with the conditions of the site Environment Protection Licence, and would be appropriately tested prior to being discharged.

The refuelling of plant and maintenance of machinery would be undertaken within impervious bunded areas within the compound sites, located at least 25 m away from watercourses or drainage lines.

Vehicle wash downs and/or concrete washouts would be undertaken within a designated bunded area designed to allow wash down water to pass through filter fabric and soak away, capturing concrete particles and other solids on the fabric for later disposal. The wash down areas and washouts would be located at least 25 m away from watercourses or drainage lines.

Shoalhaven Starches will commit to undertake a review of the of the factory site to identify and analyse areas of the factory site where bunding of storage vessels and areas is not provided. Based upon this “gaps” analysis an implementation strategy can be formulated which seeks to instigate bunding where it is necessary throughout the factory site. Such a strategy could be formalised in consultation with DECC and incorporated into a Pollution Reduction Program under the Company’s Environmental Protection Licence.




8.3.4 Noise and Vibration Management

The construction process would generate both noise from heavy plant and equipment.

The Proponent/Contractor would implement appropriate noise management measures

as detailed in the Environmental Assessment (EA) and as may be required by the

Conditions of Approval.

Shoalhaven Starches make the following commitments in terms of noise management:

Table 42

Noise and Vibration Management Measures – Construction Noise and Vibration Management Measures

Noise Management Measures – Construction

Appropriate noise mitigation measures would be developed and implemented throughout the construction process, including all commitments made in the EA, and required by the Conditions of Approval.

Unless otherwise agreed with the Director-General, construction and operation of the proposal would be undertaken as follows:

• Construction – Monday to Friday 7:00 am to 6:00 pm and Saturday 7:.00 am to 1:00 pm. No work on Sundays and Public Holidays.

• Operation – 24 hours per day, 7 days per week.

Construction activities may be conducted outside the hours detailed above provided that the activities are not audible at any residence beyond the boundary of the site.

Construction activities would be managed to comply with the Construction Site Noise Guidelines set out in Chapter 171 of the Environmental Noise Control Manual (ENCM) as follows:

The LA10,T noise levels emanating from the construction site shall not exceed the background levels by the following criteria, in the interval specified:

− 20 dB(A) for construction activity period up to 4 weeks

− 10 dB(A) for construction activity period over 4 weeks and up to 26 weeks.

− 5 dB(A) for construction activity period over 26 weeks.

Plant and equipment would be selected and operated with appropriate mufflers and noise controls and where practical work practices and plant selection would be considered so as to minimise noise impacts.

High efficiency mufflers would be used on all construction equipment and manufacturer’s noise control equipment would remain intact. All construction equipment would be well maintained and serviced.




Table 43

Noise Management Measures – Operations

Noise Management Measure - Operations

For this project the residential noise emission target is set at 15 dB(A) below the EPL target limits at the reference locations as follows:

The LA10 (15 minute) sound pressure level contribution generated from the Ethanol Upgrade project must not exceed the following levels when measured at or near the boundary of any residential premises:

− 23 dB(A) at locations in Terara on the south side of the Shoalhaven River.

− 23 dB(A) at locations in Nowra on the south side of the Shoalhaven River.

− 27 dB(A) at locations in Meroo Street, Bomaderry.

− 25 dB(A) at other locations in Bomaderry.

Shoalhaven Starches commits to designing and building the proposed works to ensure the proposal does not exceed the above emission targets.

In order to achieve these noise design targets, Shoalhaven Starches commits to the following noise control measures:

• Product Dryer − Equipment to be housed in a building that will be constructed of Ultrapanels having an Rw of not less than 35. The upper 3 floors of the building and the roof are to be constructed of material having an Rw of not less than 17 (Colourbond or similar).

Any equipment that has a sound power level above 80 dB(A) is to be enclosed in a separate room with the walls and ceiling/floor having an Rw of not less than 40.

• Fermenters − Transfer pumps are to be enclosed with material having an Rw of not less than 15.

• Fermenters – Cooling Towers – During night time period fan speed of the 6 cooling towers is to be reduced to 60% of full fan speed. Fan speed is to be automatically adjusted (computer or time clock controlled).

• Molecular Sieve − Molecular sieve pumps and compressors are to be enclosed with material having an Rw of not less than 35.

• Molecular Sieve – Cooling Towers − During night time period, fan speed of the 6 cooling towers is to be reduced to 60% of full fan speed. Fan speed reduction is to be automatically adjusted (computer or time clock controlled).

• Cooling Towers − During night time period, fan speed of the 6 cooling towers is to be reduced to 60% of full fan speed. Fan speed reduction is to be automatically adjusted (computer or time clock controlled).

Water pumps numbers 1 - 4 are to have noise control measures (or replaced) in order to have a sound pressure level of 68 dB(A) at 1 metre.

• DDG Dryers − The majority of the equipment will be housed in a building that will be constructed of Ultrapanels having an Rw of not less than 35.






Noise Management Measures – Operations

• DDG Pellet Plant − The majority of the equipment will be housed in a building that will be constructed of Ultrapanels having an Rw of not less than 35.


• Odour Scrubber − Equipment will be housed in a building (walls and ceilings/roof) that will be constructed of material having an Rw of not less than 35 such as Ultrapanels.

• Evaporator − The majority of the equipment will be housed in a building (walls and ceilings/roof) which has to be constructed of material of an Rw of not less than 25.

The two turbo fans are to be enclosed in a separate room with the walls and ceiling/floor having an Rw of not less than 40.

• Co-Generator − At this stage of the development application, sound level data for the Co-Generator is not available. However the maximum sound power level of 93 dB(A) from all discharges from the Co-Generator building has been derived to maintain compliance with the design criteria.

• Gas Fired Boiler − To maintain compliance with the design criteria the discharge of the duct is to achieve an attenuation of 25 dB(A) so that the sound pressure level from the discharge duct does not exceed 72 dB(A) at 1 metre.

• Packing Plant − All walls and the roof/ceiling is to be constructed of material having an Rw of not less than 35 dB(A).

• Container Loading Area

− The forklift that is used for the loading and stacking of containers is to have a maximum sound pressure level of 80 dB(A) at 1 metre.

− The northern end of the container loading area is to have a solid masonry wall not less than 8.5 metres in height and the western and eastern end of the container loading area is to have a solid masonry wall not less than 8 metres in height.

− There will be no train movements on the spur line that forms part of the container loading area between the night time period of 10:00 pm to 7:00 am.

− During the night time period (10:00 pm to 7:00 am) the forklift trucks will only stack two containers high at locations within 10 metres from the wall and only one container high above the ground for locations more than 10 metres from the wall.

− No loading of the train in the proposed container loading area will take place during the night time period.

• Blowers at Manildra Environmental Farm − The blowers will have enclosures that result in a sound pressure level of 70 dB(A) at 1 metre.

• Emergency Fire System − The fire pumps are only utilised for emergency and a maximum of 1 hour per week during the day time for testing purposes only, and do not form part of the EPA criteria under normal plant operations.




8.3.5 Traffic, Access and Parking

Christopher Stapleton Consulting Pty Ltd has prepared a detailed and independent

assessment of the access, traffic and parking issues associated with the Proposal,

utilising available data, design standards and traffic analysis models. Shoalhaven

Starches commits to the following actions (Table 44) to achieve appropriate transport

outcomes for the site.

Table 44

Traffic, Access and Parking

Traffic, Access and Parking

• Access Point 2 will be upgraded following approval of final design plans by the relevant local authorities. The upgrade will be implemented as part of the approved SSFM Project, and will be completed prior to commencement of operation of the approved Flour Mill Project. The design of this intersection is to be integrated with respect to the proposed pedestrian crossing of Abernethy’s Creek; the proposed pedestrian/product overhead bridge; and the vehicular access to the proposed Packing Plant.

• Access Point 3 will be upgraded following approval of final design plans by the relevant local authorities. The upgrade will be implemented as part of the approved SSFM Project, and completed prior to commencement of operation of the approved Flour Mill Project.

• A new left in only ingress driveway will be provided from Bolong Road to the packaging plant following approval of final design plans by the relevant local authorities.

• The packaging plant driveway to Railway Street will be upgraded to full compliance with the appropriate AS 2890.2:2002 design standards.

• The gates providing access to the primary Site car park (Access Point 4) will remain open at all times to allow for the separation of ingress and egress movements; this recommendation has already be implemented by Manildra.

• That rail movements continue to be – as far as practicable – scheduled outside of local peak periods, and specifically outside of the morning and afternoon commuter peak periods, though it is acknowledged that Manildra does not have direct control over the scheduling of rail movements.

• That Manildra continues to provide heavy vehicle drivers with information and training in regard to the use of the designated restricted access vehicle route by restricted access vehicles, and the availability of on-site parking areas.

• That Manildra works constructively with SCC, the RTA and local community through any future implementation of local heavy vehicle route changes; this may include changes to the use of the local industrial vehicle route and key regional routes.

• That Manildra provides additional on-site parking including 40 spaces within the Moorhouse maintenance workshop area, 34 spaces at the proposed Packing Plant site and 20 spaces east of the coal storage area (for contractors).




8.3.6 Air Quality Management

Construction activities have the potential to generate dust. Shoalhaven Starches

commits to managing potential dust and air quality issues during construction by

implementing appropriate control measures, including those detailed in Table 45.

Table 45

Air Quality Management Measures Air Quality Management Measures

Air Quality Management Measures

Appropriate air quality mitigation measures would be developed and implemented throughout the construction process, including all commitments made in the EA and required by the Conditions of Approval.

Regular on-site watering of dust-generating materials would be used to control dust generation during construction. Adequate dust suppression resources would be available on site to reduce dust emissions.ir Quality Management Measures

Additional measures implemented to reduce dust emissions during construction would include:

• Alternative timing of dust generating activities;

• Stopping of construction activities in very high wind conditions;

• Consideration of quickening of work in problem areas;

• Use of wind direction to advantage;

• Ensuring trucks are covered at all times when transporting materials;

• Stabilisation of exposed areas as quickly as possible and within 14 days after completion of works;

• Confining vehicle movements to designated areas and routes; and

• Appropriately located stockpile and compound sites.

The extent of exposed and unprotected areas would be limited by preserving existing groundcover (through staged clearing), and all disturbed areas would be stabilised as soon as possible.

Loads with the potential to generate dust would be covered during transportation on public roads.

Exhaust systems of construction plant, vehicles and machinery would be maintained in accordance with manufacturer’s specifications and the exhaust emissions would comply with the requirements of relevant legislation.

No open fires would be permitted on the project.

Stockpiles would be kept to a minimum.

Where practicable, specific areas of the construction site (eg. areas containing stockpiles) would be fenced with shade-cloth to minimise wind erosion and the transport of dust beyond the site boundary.

Any stockpiles with the capacity to cause dust would be dampened or covered to suppress dust.

When dust is visually detected, the frequency of watering would be increased. Dust generating activities would be reprogrammed to avoid periods of high wind velocity.





Air Quality Management Measures

If works are creating high levels of dust that are likely to cause discomfort to local residents or a safety hazard to work personnel, the works would be modified or stopped until the dust hazard is eliminated or has been reduced to an acceptable level. Tailgates would be secured during the operation of trucks and utes. All haulage vehicle loads would be covered while transporting material to and from the work area.

Machinery would be turned off, rather then left idling for long periods.

8.3.7 Odours

Based upon the air pollution emission inventory and dispersion modelling for the

proposed ethanol upgrade odour and particulates were assessed against legislated

maximum ground level concentrations. All constituents assessed over all relevant

averaging times were below their respective assessment criteria for the adopted

emission characteristics, with the exception of odour. Odour was found to be the critical

constituent for compliance with the DECC air quality impact criteria. As a result of these

findings and the conclusions of the Air Quality Assessment carried out by GHD Pty Ltd

Shoalhaven Starches commit to the following actions.

Table 46

Odours

Odours

Shoalhaven Starches commit to the odour control measures as detailed in Table 5-1 of the Air Quality Assessment and which are summaries in Table 7 of this EA.

Shoalhaven Starches also commit to expand on the Odour Management Plan as detailed in this EA and the Air Quality Assessment, by detailing procedures with respect to routine housekeeping/ductwork cleaning and assigning responsibility for these actions. The Odour Management Plan will also provide protocol in terms of outlining a program for such actions.

Shoalhaven Starches furthermore commit to treat waste water generated from factory process sequentially through anaerobic and aerobic digestion systems to be established within the existing approved wet weather storage Pond No. 7, and as described in Section 5.8.2 of the EA.

Furthermore Shoalhaven Starches will commit to the implementation of the above odour control measures in three stages, in a manner as detailed in Table 5-1 of the Air Quality Assessment prepared by GHD Pty Ltd and which is summarised in Table 7 of this EA.

The staging of the odour control implementation proposed by Shoalhaven Starches is based on the prioritisation of the odour sources as presented in Table 3-1 of the Air Quality Assessment prepared by GHD Pty Ltd.

The timing for each odour control stage will be as follows:

• Stage 1 – April 2009 (subject to date of approval) includes:

− duct high priority DDG (liquid and solid lines) odour sources to the bioscrubber;

− install wet-legs on key odour sources that are not ducted to the bioscrubber at this stage;





Odours

− clean starch and gluten dryer ductwork;

− improve factory housekeeping;

− pelletise DDG product; and

− decommission designated odour sources.

• Stage 2 – to reassess within 6 months of completion of Stage 1 and implementing Stage 2 odour controls as required, includes:

− duct medium priority odour sources to the bioscrubber; and

− investigate feasibility of directing individual starch and gluten dryer discharge points upwards and increasing stack heights;

• Stage 3 – if required, depending on outcomes at Stage 2, includes:

− duct individual starch and gluten dryer discharge points to a common tall stack (CTS);

− duct low priority odour sources to the bioscrubber.

To assess the outcomes of each stage of the odour management controls Shoalhaven Starches will undertake the following measures:

1. Following completion of each stage of odour control measures, a meeting will be held with the Community Consultation Group to ascertain whether members of the community have experienced improvement in terms of odours.

2. A review will also be undertaken of the number and nature of complaints received by the Company in connection with odours.

If following these measures it is evident that there is a reduction in the number of complaints; and the local Community Consultation Group indicate improvements, then works associated with subsequent stages will be deferred.

However if there is no demonstrated improvement, then odour monitoring will be undertaken to further evaluate odour control measures.

If as a result of this monitoring it is found that odours are still emanating from the site, works associated with subsequent stages of the odour management plan will be undertaken.

In terms of formulating procedures and establishing responsibility for undertaking routine housekeeping/ductwork cleaning it is proposed that these activities will be included in the Company’s maintenance program and would be undertaken and completed as programmed. It is envisaged that inspections would be undertaken monthly with cleaning every 3 months.

8.3.8 Greenhouse Gas Emissions

In order to minimise greenhouse gas emission (ie. those generated on the site)

Shoalhaven Starches commit to the following:




Table 47

Greenhouse Gas Emission

Greenhouse Gas Emission

Adoption of best available technology

The proposed plant will incorporate a gas fired co-generation plant. This represents the best available technology economically achievable to meet the heat and energy needs of the proposed plant.

Additional equipment for the proposed plant, such as fermenter tanks, cooling towers, dryers, evaporators will be designed to minimise energy use.

Greenhouse Gas Capture

The proposed new wastewater treatment system will include the 100% capture of biogas generated and will be re-used for energy generation. This will effectively reduce greenhouse gas emissions by 31,000 tonnes per annum, and will recover 260 TJ annually, further reducing Shoalhaven Starches consumption of fossil fuels.

Fuel use switching

Natural Gas

The proposed plant will mainly use natural gas as the primary fuel source. Natural gas produces

much lower greenhouse gas emissions than the amount of coal of equivalent energy.

Coal

Shoalhaven Starches regularly review the economic situation concerning energy costs. Shoalhaven Starches commit to continually reviewing and seriously considering the potential to convert the Company’s energy requirements from coal to natural gas subject to:

− The availability of local natural gas infrastructure.

− The capacity of the Eastern Gas pipeline.

− Concerns of over reliance on single energy sources.

Diesel

Shoalhaven Starches uses 660 KL of diesel fuel annually, and this volume will not change following the upgrade. Switching to a bio-diesel blend, emissions could be reduced. Shoalhaven Starches commit to reviewing this potential however at present they have no present plans to consider such a conversion.

8.3.9 Waste and Chemical Management

The potential environmental impacts associated with spillages of chemicals, fuels and

oils to both water and soils would be minimised through the implementation of detailed

control measures designed to minimise the risk of such spillages occurring. In addition,

appropriate waste management measures would be implemented to ensure that waste is

avoided, minimised or recycled wherever possible, or responsibly disposed of offsite.

Appropriate mitigation and management measures to which Shoalhaven Starches

commit are detailed in Table 48.




Table 48

Waste and Chemical Management Measures Waste and Chemical Management Measures

Waste and Chemical Management Measures

An incident emergency spill plan would be developed and implemented as required. This would include measures to avoid spillages of fuels, chemicals, and fluids into any waterways. All personnel would be made aware of these measures. An emergency spill kit would be kept onsite at all times.

Storage areas for fuels, oils and chemicals would be surrounded by impervious bund walls to contain any spillage. Bunds would be designed in accordance with the EPA/DECC Bunding and Spill Management Guidelines and would contain at least 110% of the volume of the largest container. Storage areas would not be located within 50 metres of any waterway, on slopes above 10%, or near areas of native vegetation. All precautions would be taken to eliminate fuel or other spills.

The storage of chemicals on site would comply with the requirements of relevant authorities (DECC and Workcover).

A schedule of all hazardous materials in use on the works would be maintained and recorded for the duration of the construction.

Refuelling operations would not be left unattended whilst refuelling is in progress. Refuelling of plant and maintenance would not occur within 25m of waterways or sensitive areas.

The refuelling of plant, and maintenance of machinery, would be undertaken within impervious bunded areas.

Should any spillage of fuels, oils, chemicals or other potentially hazardous/polluting materials occur during construction the DECC would be contacted immediately, and contaminants would be immediately contained, removed, treated (if necessary) and disposed of in accordance with DECC requirements.

All wastes would be transported by licensed waste management contractors and would be disposed of to an appropriately licensed waste management facility.

The construction site would be maintained in a clean and tidy condition. Covered bins would be provided for waste disposal.

The Resource Management Hierarchy principles of the WARR Act would be adopted as follows:

• Avoid unnecessary resource consumption as a priority;

• Avoidance would be followed by resource recovery (including reuse of materials, reprocessing, recycling, and energy recovery); and

• Disposal would be undertaken as a last resort.

In order to facilitate waste management arising from the proposal Shoalhaven Starches commit to the following actions:

• Waste Management Database is established to track volumes of waste being generated.

• Where they don’t already exist, the Environmental Manager, or their delegate, develop written agreements with all “waste” disposal companies for those wastes that are taken off-site for re-use, reprocessing / disposal. The agreement should specify, but not be limited to:

− The name of the company

− What materials / waste that are taken off-site

− Where material is being transported to.

− Disposal method – landfill, re-used, reprocessed etc.





Waste and Chemical Management Measures

− Pick-up interval

− Reporting requirements – eg. providing Shoalhaven Starches with monthly or quarterly reports on the volume of waste pickup.

− Records on the volume of waste pickup.

− Records / licences / permits allowing companies to transport and disposal of the waste.

• Maintaining copies of all written agreements.

Measures to avoid, reduce, re-use and recycle waste products including soil, pavement materials, concrete, and oils would be implemented.

If concrete agitator trucks are to be washed out on site, impermeable bunded areas would be constructed to contain wash out water and allow the concrete residue to settle. The concrete residue would be incorporated into the works or disposed of at a licensed waste or recycling facility.

All construction materials, surplus soils and wastes generated from the site would be stockpiled and stored at the site prior to reuse, recycling or disposal. Measures would be implemented to prevent any scouring or loss of stockpiled materials during flood events.

Wastes would not be stored for long periods during construction of the site. Empty drums of fuels, oils or chemicals and fluids would not be stored on site during construction.

Disposal of materials or equipment in the Shoalhaven River, Bomaderry Creek or Abernethy’s Drain would be strictly prohibited.

Materials or equipment that fall into or adjacent to the Shoalhaven River, Bomaderry Creek or Abernethy’s Drain would be recovered immediately.

Waste material generated would be reused or recycled where possible.

8.3.10 Waste Water and Irrigation Management

Table 49

Waste Water and Irrigation Management


Shoalhaven Starches commit to the installation of a full biological wastewater treatment plant to minimise the amount of bio-degradable organic substances in the combined effluent (“condensate” and “washdown” streams) from the Shoalhaven Starches plant. Full biological wastewater treatment will be implemented prior to the commencement of the upgrade to the ethanol production process. After biological treatment a further two tiers of physical filtration processes will be installed to enable treated water to be utilised for particular re-use applications.

The Waste Water Treatment Plant will include the establishment of a Bulk Volume Fermenter (BVF) as described in Section 7.3.2 of the EA. The BVF will be completely enclosed with a floating insulated cover to prevent the emanation of odours.

Waste water from the BVF will be directed to either:

• A Sulphur Oxidation (SO) basin. Waste water treated in the SO basin will be directed to the Environmental Farm (3.6 ML/day).






• A Membrane Bio-Reactor (MBR) and Reverse Osmosis (RO) Plant. Treated waste water from the MBR / RO Plant will be re-used in the factory processes (4.5 ML / day).

Routine micro-biological and pesticide / toxicity testing of treated water from the MBR / RO Plant will be undertaken to ensure that treated water complies with the potable water standards outlined in the NHMRC Drinking Water Guidelines 2004.

Wastewater with 100% retentate will be used for irrigation on the environmental farm.

Adverse changes will occur gradually and careful monitoring of the soil will provide an advance warning. Issues that will be important are the soil salinity and the ionic composition of the soil solution, especially calcium concentration. Better information on the detailed composition of the wastewater that is used for irrigation, and annual soil and pasture sampling of a few selected paddocks will also improve the predictive capabilities. If field experience shows an unacceptable increase in soil salinity or an adverse effect on pasture productivity the quantity of retentate irrigated may need to be reviewed and modified.

The following measures are to be implemented with any future Irrigation Management Plan for the Environmental Farm:

Scenario 1

•••• Monitor soil properties in irrigated paddocks in top 30 cm of profile (to guide management, especially use of fertilisers and irrigation regime).Apply nitrogen fertiliser after each cut of forage; about 100 kg N/ha at least twice in the first year, more in later years

•••• Apply potassium fertiliser after each cut (preferably as potassium nitrate, depending on cost, potassium chloride is second preference) at least 250 kg K /ha in first year, rising to 500kg K/ha after 3 years; soil monitoring data to be used as a guide here.

•••• Investigate use of lower rates of magnesium hydroxide in the wastewater treatment process

•••• Consider applying a leaching irrigation, if rainfall is low, to move excess magnesium out of the topsoil to the lower horizons.

8.3.11 Hazard and Risk Management

All possible safeguards would be employed to ensure that the potential for deflagration

of wheat and / or flour is minimised.

Table 50 outlines recommended management procedures and design considerations

that Shoalhaven Starches commits to implementing and incorporating into practices that

would prevent risk scenarios occurring.




Table 50

Hazard and Risk Management Measures

Hazard and Risk Management Measures

The off site risk assessment completed for the proposed ethanol production upgrade is in compliance with the DoP risk criteria given in HIPAP No. 4. However, it is recommended to identify opportunities during the design phase of the project to improve the safety of the process. This can be achieved through design reviews and appropriate safety studies.

The following actions will be implemented to improve the safety of the proposed upgrade:

1. Complete the Hazard and Operability (HAZOP) for the new plants i.e. co-generation, gas fired boiler and molecular sieve at the completion of the detail design;

2. Review the impact of the increased production capacity on the existing process units (vessels and pipes) with respect to mechanical integrity;

3. Consider completing a traffic risk assessment with respect to increased traffic movement associated with raw materials and ethanol movement to and from the site;

4. Review the fire fighting capability with respect to new plant and equipment such as the co-generation plant and gas fired boilers;

5. Review the emergency shutdown system and emergency procedures with respect to the new plants (co-generation and boiler).

8.3.12 Flooding

Detailed consideration needs to be given to flood hazard and structural assessment of

(with regard to velocity of floodwaters and impact by flood debris) the proposed

development.

In quantifying the flood hazard, Table 51 identifies the issues that Shoalhaven Starches

will need to consider as part of detailed engineering design prior to the issue of a

construction certificate for the development.

Table 51

Flood Hazard Issues

Flood Hazard

Shoalhaven Starches cannot directly negate the hydraulic impacts of the works it has constructed or proposed to construct. For example it is not possible to construct a wet weather storage or wastewater treatment pond of the required dimensions with no increases in flood level or construct plant or associated works which does not in some way obstruct a flow path (eg. railway spur line, container storage).

In order to compensate for the adverse impacts of the existing and proposed works, a range of management measures have been considered which will at least partially offset the potential increases in damages caused by the cumulative impacts of the existing and proposed works on the northern floodplain since 1990.

In addition to the above Shoalhaven Starches also commit to undertaking an assessment of the potential affect of future climate change may have on flooding impacts prior to exhibition of this EA. Such an assessment will be undertaken in accordance with the DECC “Floodplain Risk Management Guidelines – Practical Consideration of Climate Change”.




8.3.13 Riparian and Riverbank Stability


process within an active floodplain that has been amplified by the lack of healthy, diverse

and contiguous riparian vegetation along the foreshore of each waterway. It is unlikely

that major revegetation works within the riparian zone will arrest bank recession

occurring as a result of fluvial scour. However, increasing groundcover and promoting

binding root growth as close to the toe of the bank as close as possible may slow the

rate of bank recession. The success of revegetation as a means of stabilising areas

prone to recession is dependant on the physiological ability of plant species to bind the

soil. Most large trees have a root system reaching up to 3 m in depth and a lateral

extension similar to the width of the crown. Given these circumstances Shoalhaven

Starches commit to the following:

Table 52

Riparian and Riverbank Stability


Shoalhaven River

The bank of Shoalhaven River ranges between 2 - 5m with steep slopes due to continuous fluvial scour. The eastern section of the foreshore does not have an appropriate setback and is dominated by Coral trees and other weeds which further undermine bank stability. The effectiveness of revegetation works on the top of the bank will be limited by bank height as the root system of mature trees is unlikely to reach the watertable. The slope, changing flow direction and weed infestation will limit the effectiveness of revegetation works on the bank. Shoalhaven Starches therefore commit to:

• Planting fast growing native species at the top of the bank to slow surface erosion and allow time for the establishment of slower, deep rooted trees which will act to protect the bank, in part, in the future.

• Planting deep native rooted trees behind the bank along the western section (between Bomaderry and Abernethy’s Creek) and enhancement of understorey and groundcover species, with particular focus on known areas of erosion.

Bomaderry Creek

Bank stability along the frontage of the southern section is undermined by poor structural and floristic diversity, areas of exposed earth and weed infestation. The bank ranges from 1 – 3 m above the water surface and a number of large mature trees were recorded, indicating the presence of a binding root system potentially reaching the water table. Shoalhaven Starches therefore commit to the following enhancement measures to improve riparian health and bank stability, particularly in the southern section:

• Planting mangroves on the lower bank and sandy sediments at the mean high water mark.

• Revegetation of the mid and upper bank with native species in conjunction with weed control measures (discussed below).






Abernethy’s Creek

The riparian zone of Abernethy’s Creek is high degraded due to weed infestation and lack of an appropriate setback from the factory. Bank stability in the upper section has been undermined by the removal of vegetation and bank erosion along the waterline was evident. Tree planting along Abernethy’s Creek is problematic due to the lack of space and high modification associated with the factory, and prevalence of weeds. Shoalhaven Starches therefore commit to the following enhancement measures to improve bank stability and riparian health:

• Planting of canopy species at approx 5 – 10 m intervals along the top of the bank, where possible.

• Weed suppression until canopy species are of sufficient size to ‘shade out’ weed species.

• Weed control measures to prevent further infestation (complete removal will most likely reduce bank stability in the short to mid term).

• Revegetation of the western side of the creek, north of Bolong Rd, with native canopy, midstorey and groundlayer species.

• Effective dialogue will be required to reach an agreement with Shoalhaven City Council regarding ongoing access for dredging activities.

Broughton Creek

Sections of Broughton Creek have been subject to bank scour due to superelevated water level and flow associated with the outside edge of meanders, and further amplified by poor structural and floristic diversity. Unfortunately previous enhancement trails using mangroves have not been successful due to bank failure and burial of seedlings. Bank height is estimated at average between 2 – 3 m with an almost vertical slope. Significant areas are covered with dense Kikuyu grass, which is likely to out-compete new plantings with continued maintenance. Shoalhaven Starches therefore commit to the following enhancement measures to slow ongoing erosion leading to bank stabilisation:

• Planting fast growing native shrub species along the bank and canopy species behind the bank in areas prone to bank failure.

• Spot controlling Kikuyu grass to provide adequate space for native species to grow.

Shoalhaven Starches acknowledge that widespread spraying of Kikuyu is not recommended as it would reduce the cover and bank stabilisation provided by this species

8.3.14 Weed Management

Extensive weed infestations were identified along all of the waterways bordering or

traversing through the property including a number of noxious weeds listed under class 4

and 5 of the Shoalhaven Local Government Area. Plans of Management for the control

and eradication of class 4 weeds have been published by Council, and detail the

following actions that Shoalhaven Starches commit to undertaking:




Table 53

Weed Management

Weed Management

• Constant suppression of African Boxthorn and Blackberry.

• Suppression and removal of Large Leaf Privet and Small Leaf Privet from urban areas.

• Further clarification for privet identified onsite may be required to the zonings of 4(a) General Industrial and 7(f3) Environmental Protection Foreshores.

• Removal of Lantana where it supports local Council and Volunteers efforts.

The removal of African Boxthorn and Blackberry will be most effectively achieved by ‘spot’ spraying using appropriately registered herbicide due to the low number of individuals sighted throughout the site. The species was most prevalent in the riparian area of Bomaderry Creek. Shoalhaven Starches therefore commit to ongoing monitoring to ensure control measures are effective and weed species have not re-established.

Significant areas of lantana were identified onsite, with dense thickets recorded adjacent to Bomaderry Creek and in a number of locations along Broughton Creek. Shoalhaven Starches commit to removing some patches to improve overall ecosystem health and allow the re-establishment of midstorey and groundcover species. Removal of Lantana should be conducted in conjunction with understorey replanting and enhancement.

Lantana is shallow rooted and unlikely to contribute greatly to bank stability. The removal of Lantana from bank edges and slopes should allow deeper rooted native species the opportunity to establish and improve bank stability. Lantana is easily removed by cutting and mulching back into the ground. This method will provide some soil protection following weed removal to reduce both erosion and further weed infestation.

8.3.15 Stock Exclusion

Stock currently graze a small section of foreshore along Broughton Creek during flood

events (approx twice a year). Current grazing distances range between 5 to ~ 15 m from

the mean high water mark.

Table 54

Stock Exclusion

Stock Exclusion

Shoalhaven Starches commit to establishing a stock exclusion zone be established from the top of the bank to a minimum 15 m. This would provide sufficient area for the development of a sacrificial fast growing edge and longer term establishment of larger canopy species for long term bank stabilisation. In areas where 15 m exclusion is not possible, a small riparian zone will be established behind the bank to avoid browsing and trampling of newly planted species.

8.3.16 Vegetation Management Plan

Shoalhaven Starches commit to developing a Vegetation Management Plan (VMP) for

the factory site and Environmental Farm to ensure riparian areas are managed

appropriately and in accordance with strategic objectives. The VMP will outline

management zones and establish guidelines riparian management, focusing on the

required actions to carry out the above recommendations. In addition, the VMP will




incorporate site specific measures relating to personnel access, weed management,

incident management, ASS, surface drainage and erosion controls.

Table 55

Species list for Revegetation and Enhancement of Riparian Zones

Bank Position Vegetation

Layer Species

Rear of Bank Canopy Eucalyptus robusta, E. Botryoides, E. amplifolia, E. tereticornis, Casuarina glauca, Acacia mearnsii, Angophora floridunda

Midstorey Myoporum acuminatum, Glochidion ferdinandi, Rapanea variablis

Groundlayer Lomandra longifolia, Carex appressa, Gahnia clarkei, Dichondra repens, Centella asiatica, Tetragonia tetragonoides, Microlaena stipoids, Einadia hasata, Rhagodia candolleana

Top of Bank Canopy Casuarina glauca, Acacia mearnsii, Acacia maidenii, Melalueca stypheliodes, M. Linarifolia

Midstorey Myoporum acuminatum, Glochidion ferdinandi, Rapanea variablis, Gahnia clarkei

Groundlayer Lomandra longifolia, Carex appressa, Gahnia clarkei, Dichondra repens, Centella asiatica Juncus kraussii, Juncus usitatis, Commelina cyanea, Tetragonia tetragonoides, Microlaena stipoids, Einadia hasata, Rhagodia candolleana

On waterline (if possible)

Canopy Avicennia marina (high water mark), Casuarina glauca, Melalueca stypheliodes, M. Linarifolia

Midstorey Myoporum acuminatum

Groundlayer Lomandra longifolia, Carex appressa, Gahnia clarkei, Dichondra repens, Centella asiastica, Juncus kraussii, Juncus usitatis, Lobelia alata, Commelina cyanea, Baumea juncea, Persicaria decipiens, Tetragonia tetragonoides, Apium prostratum, Triglochin striata, Rhagodia candolleana

8.3.17 Visual Amenity

It is considered that the proposed works will not create a significant adverse visual

impact due principally to the existing significant industrial development on the site.

Shoalhaven Starches however commit to the following measures as outlined in Table 56

to assist in screening and further minimising visual impacts.




Table 56

Visual Impact Mitigation Measures

Visual Impact Mitigation Measures

• The existing screening vegetation around the site is effective, particularly along the river bank, however additional supplementary plantings of dense bands of native trees and shrubs along the southern boundary of the site with the river (particularly between the river and the proposed evaporator columns) would further reduce the visibility of the development. In this regard a landscape and revegetation plan should be prepared for that portion of the site zoned 7(f3) with suitable riparian vegetation and including trees which will grow to a height to soften the view of these works. Such a plan should be prepared prior to works commencing on the site.

• In order to reduce the visual impact and the proposed Fermenters, the northern and eastern boundaries of the site should be landscaped with a combination of trees and shrubs. Landscaping should also be incorporated between the packing plant / container loading yard to Bolong Road to soften the appearance of this development to Bolong Road. The abovementioned landscape and revegetation plan should also detail such landscaping measures.

• Where planting has already been established, measures should be taken to protect existing vegetation during the construction phase.

• In addition to landscaping, new structures can be constructed and treated to reduce visual impact. Where appropriate and possible, buildings and structures should be constructed of similar materials as those previously used on the site and be of a non-reflective nature. Colours should blend with existing structures on the site to ensure visual harmony. Consideration should be given to incorporating a cladding colour which will blend with the surrounding locality.

• The exterior elements of the proposed overhead pedestrian / product bridge across Bolong Road should be designed to enhance its architectural and visual qualities commensurate with this “gateway” site.

8.3.18 Site Contamination and Acid Sulphate Soils

Acid Sulphate Soil Management

Acid sulphate soil risk maps suggest that the majority of areas being assessed are in an

area with a low probability of acid sulphate soil occurrence. The area of the proposed

water treatment and filtration plant near the effluent ponds is closer or within a high risk

area. Field screening and laboratory results indicated that ASS were not likely to be

present in the central and eastern plant areas and fire service area. ASS are likely to be

encountered within the packing plant (particularly the lower lying areas, north and east)

and were confirmed in this assessment. For the remaining areas (western plant area,

gas facility, near Pond 7, and pipeline routes) ASS are likely to be sporadic. Shoalhaven

Starches makes the following commitment:




Table 57



An Acid Sulfate Soils Management Plan (ASSMP) will be prepared for the packing plant and areas of the site where soil disturbances are likely to intersect ASS. Depending on further details of the proposed development and level of disturbance, further assessment will be carried out to increase the confidence in the lateral and vertical extent of the ASS.

It is probable that acid sulphate soils could occur at depths beyond those assessed in the assessment carried out by Coffeys. Should the proposed depth of disturbance change or different soils be encountered, then this would need to be re-assessed.

Site Contamination

The results of the contamination assessment carried out by Coffeys identified seven

main potential AECs within the areas being the subject of this assessment based on the

past and present activities identified from the site history study. The AECs were noted

as having between a low and moderate likelihood of contamination.

In general, preliminary soil sampling in the majority of the areas assessed did not show

evidence of contamination.

Table 58

Site Contamination Assessment and Management

Site Contamination Assessment and Management

In light of the recommendations of Coffeys in terms of site contamination, Shoalhaven Starches will commit to engaging a suitably qualified consultant (such as Coffeys) to prepare a Scope of Works to investigate the best means of remediating asbestos contamination on this portion of the site. This Scope of Works will investigate which approach either:

• development of an Asbestos Removal Plan; or

• encapsulation.

Is the preferred approach for treating asbestos contamination on this site. This is the preferred approach as it will enable detailed construction plans to be formulated; and a detailed costing of the two alternatives to be considered.

Shoalhaven Starches also commit to ensuring that all contractors involved in construction works on the site are instructed that if there is any evidence of potential contamination (as evidenced by odorous soils, stained soils, unusually discoloured soils) then Coffey Environments should be contacted immediately to make an assessment of these soils for contamination.

Shoalhaven Starches also undertake to ensure that all excess soil that requires disposal offsite will be classified in accordance with the DECC (2008) Waste Classification Guidelines.

Shoalhaven Starches will also undertake to ensure that fill soils in the upper parts of the soil profile will be kept separate to underlying natural soils.

In terms of groundwater, Shoalhaven Starches in conjunction with a suitable qualified consultant will commit to appropriately testing groundwater if groundwater is intersected as part of any construction works.




8.3.19 Flora and Fauna

The Flora and Fauna Assessment prepared by KMA concludes that the proposed

upgrade will have little impact on native flora and fauna. There are no areas of high

conservation value on the site. The proposal is not likely to have an adverse impact on

species, populations and communities listed under the New South Wales Threatened

Species Conservation Act, 1995 and the Commonwealth Environment Protection and

Biodiversity Conservation Act, 1999; no threatened species, populations or communities

are known to occur on the subject land or are expected to occur there. The preparation

of a Species Impact Statement (SIS) nor referral to the Commonwealth Environment

Minister for approval is therefore not warranted.

Table 59

Flora and Fauna

Flora and Fauna

Shoalhaven Starches commits to the following actions as recommended by the Flora & Fauna Assessment prepared by KMA with respect to this proposal:

• As far as is practicable, given the presence of the factory, the verges of Abernethy’s Creek should be planted with native species.

• Appropriate screen plantings should be installed around the packing shed/loading area; local native species should be used for this purpose.

• Additional plantings should be made in the environmental protection zone near the Shoalhaven River.

• The list of local native species at Appendix 1 of the Flora and Fauna Assessment (Annexure E) should be utilised in the planting programs around the site, as identified above. The list is not exhaustive and it is expected that not all species be used.

8.3.20 Aboriginal Heritage

According to SEA the development area has either been totally impacted by recent land

use and has negligible heritage potential, or has been subject to high impacts and in

consideration of Aboriginal land use modelling, is of very low heritage potential. No

Aboriginal heritage sites are listed within the study area on any heritage registers or

planning instruments, although two isolated artefacts occur in the immediate vicinity of

the eastern end of the proposed pipeline routes, north of the existing Shoalhaven Paper

Mill (Figure 1). In the absence of appropriate management and mitigation measures, it is

concluded that the impacts of the proposal on Aboriginal heritage will be very low.

Shoalhaven Starches commits to the undertaking the following recommendations made

by SEA on the basis; of legal requirements including the NSW National Parks and




Wildlife Act 1974 and Environmental Planning and Assessment Act 1979; the results of

the investigation; and consultation with the local Aboriginal community:

Table 60

Aboriginal Heritage

Aboriginal Heritage

� Provisions relating to Aboriginal heritage will be included in an Environmental Management Plan for the project. These provisions will be formulated in consultation with the registered Aboriginal stakeholders and specify the policies and actions required to manage the potential impacts of the proposal on Aboriginal heritage after Part 3A approval is granted. The plan should include management procedures for previously unrecorded Aboriginal heritage evidence and skeletal remains (should such evidence be identified during construction), procedures for further Aboriginal consultation should such evidence be identified, and mitigation measures involving surface collection for the identified isolated artefact site APPM Isolated Find 1 (DECC #52-5-288 and 52-5-289) should it be subject to impacts. The plan will, subject to Part 3A project approval, guide management of any Aboriginal heritage evidence in lieu of a Section 90 Consent;

� Under the terms of the National Parks and Wildlife Act 1974 it is an offence to knowingly destroy, damage or deface an Aboriginal object without obtaining the prior written permission of the Director-General of DECC. Therefore, no activities or work will be undertaken within the Aboriginal site areas as described in this report and marked on Figure 1, in the absence of a valid Section 90 Consent or in lieu, Part 3A approval;

� Single copies of this report should be forwarded for comment to the Aboriginal stakeholders (Dungarn Consultancy and Nowra LALC); and

� After revision of the draft report with the responses of the Aboriginal community, three copies of the final report should be forwarded to:

Manager South Branch Environment Protection and Regulation Division Department of Environment and Conservation (NSW) PO Box 2115 Queanbeyan NSW 2620




9.0 CONCLUSION

Shoalhaven Starches is a member of the Manildra Group of companies. The Manildra Group

is a wholly Australian owned business and the largest processor of wheat in Australia. It

manufactures a wide range of wheat based products for food and industrial markets both

locally and internationally.

The Shoalhaven Starches factory located on Bolong Road, Bomaderry produces a range of

products for the food, beverage, confectionary, paper and motor transport industries including:

starch, gluten, glucose and ethanol.

The use of ethanol as a fuel (or fuel additive) has many benefits and as a result the Federal

and State Governments have introduced a range of initiatives to encourage the increased use

of ethanol as a fuel additive. The NSW Government has recently mandated the blending of

2% of ethanol into the total volume of petrol sold in NSW as a first step towards a10% ethanol

content by 2011.

As a result, the Manildra Group is planning to increase its ethanol production capacity to meet

the expected increase in demand for ethanol arising from these initiatives by upgrading the

existing ethanol plant at the subject site. Shoalhaven Starches plans to increase ethanol

production from the current approved 126 million litres per year to 300 million litres per year.


upgrades and an increase in the throughput of raw materials, principally flour and grain. The

proposal will include:

• the provision of an additional dryer for the starch/gluten plant;

• additional equipment and storage vessels for the ethanol plant including 3 additional

fermenters, additional cooling towers and molecular sieves;

• upgrades to the Stillage Recovery Plant including 6 additional Dried Distillers Grains

Syrup (DDGS) dryers; 10 decanters; chemical storage and two evaporators. The

proposal also includes the installation of a DDGS Pellet Plant within this part of the site;

and

• the establishment of a new packing plant, container loading area and a rail spur line. The

establishment of this facility on the northern side of Bolong Road will require the provision

of an overhead bridge structure to allow product and safe pedestrian movement across

Bolong Road.

In addition to the upgrade to the Company’s ethanol plant, Shoalhaven Starches also propose

to undertake comprehensive odour reduction measures for both the existing factory and




Environmental Farm sites and the works associated with this proposal and which have been

identified as part of an Environmental Audit prepared by GHD Pty Ltd.

The proposal also includes the biological treatment of waste waters from the factory site. It is

proposed to re-use over half the treated waste water within the factory processes and the

remainder irrigated onto the Company’s Environmental Farm.

The project also involves an upgrade to services to the site such as electric power, natural

gas, etc. The proposal includes the provision of an additional gas fired boiler and a gas fired

co-generation plant.

The application is one subject to Part 3A of the Environmental Planning & Assessment Act

1979. The Department of Planning has determined that the proposal is a Major Project for the

purposes of this legislation and the Minister for Planning is the consent authority. The

Director-General has issued requirements for the preparation of this Environmental

Assessment. This Environmental Assessment report has been prepared to address the issues

raised by the Director-General’s requirements for this proposal.

The preparation of this Environmental Assessment has also been undertaken following

consultation with relevant Government agencies, including:

• The Department of Environmental and Climate Change;

• The Department of Water and Energy;

• The Roads & Traffic Authority; and

• Shoalhaven City Council.

Community Consultation groups and Aboriginal stakeholders have also been consulted in the

preparation of this EA.

Following an assessment of the key issues associated with this proposal the Environmental

Assessment concludes that the proposal is suitable for the site and this locality. The

Environmental Assessment includes a Statement of Commitments outlining environmental

management, mitigation and monitoring measures that should be implemented to minimise

potential impacts associated with the proposal.

The Minister’s approval for the proposal is sought.

Stephen Richardson Town Planner, CPP, MPIA

Documents

Town Planning, Agricultural & Environmental Consultants T ...manildra.com.au/documents/community/2008 Ethanol... · Associate: Colin Stoddart, Cert. TCP (NSW), Ass. Dip. TCP, MPIA