Volume 1 Mt Piper Energy Recovery Project

The business of sustainability

Volume 1 Mt Piper Energy Recovery Project Response to Submissions Report

5 August 2020

FINAL

Project No.: 0436662

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Document details

Document title Mount Piper Energy Recovery Project

Document subtitle Response to Submissions Report

Project No. 0436662

Date 5 August 2020

Version 1.0

Author AA

Client Name EnergyAustralia Development Pty Ltd & Re.Group Pty Ltd

Document history

ERM approval to issue

Version Revision Author Reviewed by Name Date Comments

Draft 01 Amanda Antcliff

David Snashall David Snashall

22 July 2020

Final 01 Amanda Antcliff

David Snashall David Snashall

5 August 2020

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Signature Page

5 August 2020

Mount Piper Energy Recovery Project Response to Submissions Report

Amanda Antcliff Project Manager

David Snashall Senior Partner

Environmental Resources Management Australia Pty Ltd Level 15 309 Kent Street SYDNEY NSW 2000

© Copyright 2020 by ERM Worldwide Group Ltd and/or its affiliates (“ERM”). All rights reserved. No part of this work may be reproduced or transmitted in any form, or by any means, without the prior written permission of ERM.

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MOUNT PIPER ENERGY RECOVERY PROJECT Response to Submissions Report

CONTENTS

CONTENTS

EXECUTIVE SUMMARY ......................................................................................................................... I

1. INTRODUCTION .......................................................................................................................... 1 1.1 Project Overview ............................................................................................................................ 1 1.2 Approval Process ........................................................................................................................... 1 1.3 Response to Submissions Approach ............................................................................................. 2

1.3.1 Purpose ........................................................................................................................ 2 1.3.2 Methodology ................................................................................................................. 2 1.3.3 Structure ....................................................................................................................... 2

2. ANALYSIS OF SUBMISSIONS ................................................................................................... 6 2.1 Public exhibition of the EIS ............................................................................................................ 6 2.2 Overview of Submissions ............................................................................................................... 6 2.3 Community Submissions by Locality ............................................................................................. 8 2.4 Summary of Key Matters Raised in Community Submissions ....................................................... 8

2.4.1 Community Support ...................................................................................................... 8 2.4.2 Community Objections .................................................................................................. 9

3. ACTIONS TAKEN SINCE LODGEMENT OF THE PROJECT EIS ........................................... 11 3.1 Project Refinements .................................................................................................................... 11

3.1.1 Immobilisation Technology ......................................................................................... 11 3.1.2 Voluntary Planning Agreement ................................................................................... 11 3.1.3 Revised GHG Calculations ......................................................................................... 12 3.1.4 Photomontages of Plant .............................................................................................. 12

3.2 Additional or Updated Technical Assessments ............................................................................ 12 3.3 Stakeholder Engagement ............................................................................................................ 13

3.3.1 Community Information Session on EIS ..................................................................... 13 3.3.2 MPPS Community Consultative Committee (CCC) ..................................................... 14 3.3.3 Lithgow Council Meetings ........................................................................................... 14 3.3.4 Blue Mountains Council Meetings ............................................................................... 14 3.3.5 Project Website ........................................................................................................... 14 3.3.6 Regulatory Engagement ............................................................................................. 15

4. RESPONSES TO GOVERNMENT AGENCY SUBMISSIONS .................................................. 16

5. RESPONSES TO COMMUNITY SUBMISSIONS ...................................................................... 45

6. REVISED SUMMARY OF MANAGEMENT AND MITIGATION MEASURES .......................... 55

7. REFERENCES ........................................................................................................................... 63



CONTENTS

APPENDIX A SUBMISSIONS REGISTER APPENDIX B STAKEHOLDER ENGAGEMENT REGISTER APPENDIX C STAKEHOLDER ENGAGEMENT MATERIALS APPENDIX D UPDATED AIR QUALITY IMPACT ASSESSMENT APPENDIX E UPDATED HUMAN HEALTH RISK ASSESSMENT APPENDIX F FEEDSTOCK SUPPLY

F1 FEEDSTOCK SUPPLY ANALYSIS – COMPETING FACILITIES F2 FEEDSTOCK SUPPLY ANALYSIS – RDF FEEDSTOCK REPORT

APPENDIX G ASH VOLUME CONSIDERATIONS APPENDIX H ASH TREATMENT, IMMOBILISATION AND REUSE APPENDIX I SUPPLEMENTARY SOCIAL IMPACT ASSESSMENT APPENDIX J CONSTRUCTION HOURS CLARIFICATION APPENDIX K UPDATED TRAFFIC IMPACT ASSESSMENT APPENDIX L SIGNED LETTER OF OFFER – CONTRIBUTIONS APPENDIX M NSW EFW POLICY LIKE WASTE STREAMS COMPARSION APPENDIX N ENVIRONMENT PROTECTION LICENCE AND WASTE LEVY

CONSIDERATIONS APPENDIX O REVISED RISK ASSESSMENT APPENDIX P UPDATED PLANT LAYOUT APPENDIX Q UPDATED WASTE GENERATION AND MANAGEMENT STRATEGIES APPENDIX R UPDATED NOISE AND VIBRATION IMPACT ASSESSMENT APPENDIX S QA/QC PROCEDURES FOR 3RD PARTY SUPPLY CONTRACTS APPENDIX T NORBE ASSESSMENT: MUSIC MODELLING APPENDIX U EPL DISCHARGE POINT , LIMITS AND MONITORING APPENDIX V WASTE HIERARCHY AND CIRCULAR ECONOMY APPENDIX W REVISED GHG CALCULATIONS APPENDIX X PHOTOMONTAGES OF PLANT



CONTENTS

List of Tables

Table 1-1: ERP Project Components .................................................................................................... 1 Table 2-1: Breakdown of Submissions Received ................................................................................. 7 Table 2-2: Community Submissions by Locality ................................................................................... 8 Table 2-3: Key Matters raised in Community Submissions (Objections) .............................................. 9 Table 3-1: Additional and Updated Technical Assessments .............................................................. 12 Table 4-1: Department of Planning, Industry and Environment (DPIE) Submission Responses ....... 17 Table 4-2: DPIE and EPA Technical Advisor (ARUP) Submission Responses ................................. 20 Table 4-3: EPA Submission Response (Submission ID: 124049) ...................................................... 27 Table 4-4: DPIE Biodiversity and Conservation Division Submission Response

(Submission ID: 121159) .................................................................................................. 34 Table 4-5: Water NSW Submission Response (Submission ID: 121160) .......................................... 34 Table 4-6: Fire and Rescue NSW Submission Response (Submission ID: 121885) ......................... 35 Table 4-7: DPIE Division Water NSW Submission Response (Submission ID: 121160) ................... 35 Table 4-8: DPIE / NSW Health Technical Advisor on Human Health Risk (CDM Smith)

Submission Response ...................................................................................................... 35 Table 4-9: DPIE Water and Natural Resources Access Regulator Submission Response

(Submission ID: 124308) .................................................................................................. 41 Table 4-10: Transport for NSW Submission Response (Submission ID: 124211) .............................. 42 Table 4-11: Lithgow City Council Submission Response (Submission ID: 121866 and 124006) ....... 43 Table 4-12: Blue Mountains City Council Submission Response (Submission ID: 121816) ............... 43 Table 5-1: Submissions response to community submissions .......................................................... 45 Table 6-1: Revised Summary of Management and Mitigation Measures .......................................... 55

List of Figures

Figure 1-1: Regional Locality Plan ........................................................................................................ 4 Figure 1-2: Energy Recovery Project Layout ........................................................................................ 5 Figure 3-1: Images from the Project website and EIS Summary Flyer ............................................... 15 Figure 4-2: RDF Sorting Flowchart (EIS) ............................................................................................ 49

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EXECUTIVE SUMMARY

EXECUTIVE SUMMARY

This Submissions Report has been prepared for EnergyAustralia NSW Pty Ltd (EnergyAustralia) and Re.Group Pty Ltd (Re.Group) to respond to aspects raised during the public exhibition of the Environmental Impact Statement (EIS) for the Mount Piper Energy Recovery Project (the ‘Project’). The Project proposes an energy from waste plant using refuse derived fuel (RDF) situated at Mt Piper Power Station (MPPS) near Lithgow, NSW.

The Project meets the criteria of a State Significant Development (SSD) and hence an EIS was required to support an application to the NSW Department of Planning, Industry and Environment (DPIE). The EIS was placed on public exhibition between the period of 13 January 2020 and 28 February 2020 and was also considered by a range of government agencies. A decision on the Project will be made by either the DPIE or the Independent Planning Commission (IPC). Environmental Resources Management Australia Pty Ltd (ERM) was commissioned to prepare this Response to Submissions Report (RTS) with consideration of Guideline 5 of the Draft Environmental Impact Assessment Guidance Series (DPE, 2017)

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INTRODUCTION

1. INTRODUCTION

1.1 Project Overview

EnergyAustralia NSW Pty Ltd (EnergyAustralia) and Re.Group Pty Ltd (Re.Group) are proposing to construct and operate the Mt Piper Energy Recovery Project (ERP), an energy from waste (EfW) plant using refuse derived fuel (RDF) situated at the existing Mt Piper Power Station (MPPS) near Lithgow NSW (the ‘Project’). A locality plan is provided in Figure 1-1.

The Project has two main components, as summarised in Table 1-1. A Project Layout is detailed in Figure 1-2. A detailed description of the Project can be found in the EIS.

Table 1-1: ERP Project Components Project Component Description

The Plant The Plant is centred around a standalone RDF boiler facility, adjacent and connected via steam and condensate pipes to the existing Unit 2 coal fired boiler. The RDF boiler would use a modern combustion process and a dedicated emissions control system to produce steam for input to the MPPS. This would enable MPPS to improve the efficiency of coal usage and dispatch additional electricity to the grid. The RDF boiler has a nominal design throughput of 200,000 tonnes of RDF per annum and would support power generation of 30 MW. The steam generated by the Plant will be injected into the existing MPPS Unit 2 turbine, and will be converted into a total of 240,000 megawatt hours per year (MWh/a) of electricity, of which 80,000 MWh/a can be classed as renewable energy. The output from the boiler will augment the steam created in the MPPS coal fired boiler and will be used to generate electricity, augmenting the approved 1500 megawatt (MW) MPPS with a lower emissions fuel source.

Ash Placement Facility

A purpose built Ash Placement Facility would be constructed adjacent to the existing MPPS ash repositories to receive ash from the Project.

The Project will also be supported by a range of ancillary uses such as construction lay down areas, car parking and internal roads would all be located on the MPPS site. The Project will also utilise existing MPPS stormwater systems, security guardhouse and security fencing.

The Project would demonstrate the first use of hybrid renewable/fossil fuel EfW technology at an Australian power station. EfW technology is widely used, with many RDF-fired electricity generating plants operating internationally. Such energy recovery plants provide broad environmental and community benefits, which include reduced waste to landfill and reduced reliance on fossil fuels.

The Project represents a new stage in advanced resource recovery for NSW. Its purpose is to recover value, in the form of energy, from a resource that is currently disposed to landfill. Landfills create a range of environmental impacts including the generation of landfill gas (methane) which is a significant greenhouse gas (GHG), and potentially polluting wastewater known as leachate.

1.2 Approval Process

Approval for the Project is sought under the State Significant Development (SSD) provisions (Division 4.7) of Part 4 of the EP&A Act as it is classed as an SSD under of State Environmental Planning Policy (State and Regional Development) 2011.

In support of the SSD application, an Environmental Impact Statement (EIS) was prepared for the Project in accordance with the requirements of the Environmental Planning and Assessment Regulation 2000. The EIS was publicly exhibited between 13 January 2020 and 28 February 2020.

During the public exhibition period, 108 submissions were received from members of the public, community organisations and government agencies. Further, additional comments were received from DPIE and two technical advisors (ARUP and CDMSmith) commissioned by Government Agencies.



INTRODUCTION

As a result of the submissions received, further analysis and description of the potential environmental impacts of the development, as well as project refinements have been undertaken and are presented in this Response to Submissions Report (RTS).

Following receipt of this RTS, the Department of Planning, Industry and Environment (DPIE) will complete its assessment of the Project and prepare an assessment report, taking into consideration the EIS, the RTS and associated additional assessments, as well as submissions made during the public exhibition period. DPIE’s assessment report will be considered by the consent authority prior to the determination of the development application.

1.3 Response to Submissions Approach

1.3.1 Purpose This RTS report has been prepared to provide considered responses to the issues raised during the public exhibition period of the EIS in accordance with Section 4.15 of the Environmental Planning and Assessment Act 1979. The report will be submitted to DPIE so that the development application (SSD 8294) lodged by EnergyAustralia and Re.Group can be further assessed and determined. DPIE will forward the RTS to relevant government agencies for consideration and make publicly available via DPIE’s Major Projects website.

The RTS also provides further details of on-going stakeholder engagement activities that have been undertaken since the EIS was submitted in December 2019, including both agency and community engagement activities.

1.3.2 Methodology All submissions received were collated and categorised based on the following:

■ Public authority (government);

■ Individual public submissions:

- Unique submissions;

- Form letters;

- Modified form letters; and

■ Community organisations.

A form letter is a submission made by an individual but the wording of which is identical to other submissions. This often occurs when a community organisation asks its supporters to make a submission and supplies them with the text. Modified form letters were submissions which were substantially the same as other submissions, but which included some degree of modification or personalisation.

Each submission was reviewed and responses were prepared by Re.Group, EnergyAustralia and / or ERM, with relevant specialist technical input. All responses and additional technical assessments have been completed by the same study team that prepared the EIS.

1.3.3 Structure The structure of this report is as follows:

■ Chapter 1: Introduction

■ Chapter 2: Analysis of Submissions

■ Chapter 3: Actions taken since EIS exhibition

■ Chapter 4: Responses to Government Agency Submissions



INTRODUCTION

■ Chapter 5: Responses to public submissions

■ Chapter 6: Revised summary of management and mitigation measures

■ Appendices:

- Appendix A: Register of Community Submitters

- Appendix B: Stakeholder Engagement Register

- Appendix C: Stakeholder Engagement Materials

- Appendix D: Updated Air Quality Impact Assessment

- Appendix E: Updated Human Health Risk Assessment

- Appendix F: Waste Feedstock

• F.1: Feedstock Supply Analysis - Competing Facilities

• F.2: Updated Waste Feedstock Report

- Appendix G: Ash Volume Considerations

- Appendix H: Ash Treatment, Immobilisation and Reuse

- Appendix I: Social Impact Assessment

- Appendix J: Construction Hours Clarification

- Appendix K: Updated Traffic Impact Assessment

- Appendix L: Signed Letter of Offer – Contributions

- Appendix M: NSW EfW Policy Like Waste Streams Comparison

- Appendix N: Environment Protection Licence and Waste Levy Considerations

- Appendix O: Revised Risk Assessment

- Appendix P: Updated Plant Layout

- Appendix O: Updated Waste Generation and Management Strategies

- Appendix R: Updated Noise and Vibration Impact Assessment

- Appendix S: QA / QS Procedures for 3rd Party Supply Contracts

- Appendix T: NorBE Assessment MUSIC Modelling

- Appendix U: EPL Discharge Point, Limits and Monitoring

- Appendix V: Waste Hierarchy and Circular Economy

- Appendix W: Revised GHG Calculations Memo

- Appendix X: Photomontages of Plant

Mt Piper Power Station

!

ERP AshPlacement Facility

!

ERP Plant

WALLERAWANG

BLACKMANSFLAT

PORTLAND

LIDSDALE

BEN BULLENState Forest

BEN BULLENState Forest

B R AYS

LANE

ALBIONROAD

RANG

E ROAD

PIPERS FLAT ROAD

WOL

GAN

ROAD

NOON STREET

VIEW STREET

IAN HOLT DRIVE

05/12/20190436662m_EIS_G001_R11.mxd

A4

This figure may be based on third party data or data which has notbeen verified by ERM and it may not be to scale. Unless expresslyagreed otherwise, this figure is intended as a guide only and ERM doesnot warrant its accuracy.

Client:Drawn By:

Drawing No:Date: Drawing Size:

Reviewed By:

Mt Piper Energy Recovery

EnergyAustralia and Re.GroupGR AACoordinate System: GDA 1994 MGA Zone 56

Regional Locality Plan F1-1

0 500 1,000m [N

LegendMt Piper Property BoundaryProject SiteState ForestMajor RoadLocal RoadTrackRail Line

Source:Imagery : ESRI World Imagery - 15 Oct 2016GIS Base Data : NSW DFSI DCDB /DTDBLayout : Client Provided 22 Oct 2019Inset : Bing Maps

!(

Site Location

FRANKFORT ROAD

BOULDER ROAD

CASTLEREAGH HIGHWAY

09/07/20200436662m_RtS_G001_R0.mxd

A4

This figure may be based on third party data or data which has notbeen verified by ERM and it may not be to scale. Unless expresslyagreed otherwise, this figure is intended as a guide only and ERM doesnot warrant its accuracy.

Client:Drawn By:

Drawing No:Date: Drawing Size:

Reviewed By:

Mt Piper Energy Recovery

EnergyAustrala and Re.GroupGR AACoordinate System: GDA 1994 MGA Zone 56

Energy Recovery Project Layout F1-2

0 100 200 300m [N

LegendMt Piper Property BoundaryLamberts North Ash Placement AreaMt Piper Extension (MP 09_0119)(approximate boundary, not acted upon)

Proposed LayoutProject SiteProject Ancillary UsesProposed Ash Placement FacilityProposed Stormwater Pond RDF Truck RouteAsh Truck Route

Notes:Elevations for existing infrastructure based on groundelevation of 940m AHD derived from Wallerawang 2mDEM (NSW Gov, 2017)Elevations for existing ash repositories derived from sitesurvey - (MPA0719.dwg, received August 2019)

Source:Imagery : World View 2 Sept 2018Layout : Client Provided 22 Oct 2019Mt Piper Extension : Derived from Fig 3-1 (SKM, 2019)

ERP AshPlacement Facility

ERP Plant

Laydown Area

ExistingContractorCar Park

Mt PiperPower Station

Mt PiperCoal Stockpile

Mt PiperAsh Repository

!

Turbine Hall (980m AHD)

! Coal Bunker (996m AHD)

! Boilers (1025 m AHD)

!

Existing Stack (1190m AHD)

!

971 AHD!

944 AHD



ANALYSIS OF SUBMISSIONS

2. ANALYSIS OF SUBMISSIONS

2.1 Public exhibition of the EIS

The EIS was publicly exhibited between 13 January 2020 and 28 February 2020 at the following locations:

■ Lithgow City Council Administration Centre, Mort Street, Lithgow;

■ Portland Library, Williwa Street, Portland;

■ Wallerawang Library, Main Street, Wallerawang;

■ DPIE, Pitt Street, Sydney; and

■ DPIE’s online Major Projects register (electronic copy).

The community was further notified of the EIS exhibition period by the following methods:

■ the exhibition was advertised in the Lithgow Mercury and the Village Voice on Friday 10 January 2020;

■ email notification to online subscribers to Project notifications via DPIE’s major project website;

■ stakeholder updates were distributed by EnergyAustralia via email on 17 January 2020 and 12 February 2020 to anyone that had previously registered to receive further information relating to the Project (total stakeholder list approximately 220 people);

■ an update to MPPS staff was distributed by EnergyAustralia on 22 January 2020 (approximately 175 staff);

■ letter box drop completed by EnergyAustralia on 13, 14 and 17 February 2020 to approximately 3,000 homes in the Lithgow LGA;

■ advertisements in the Lithgow Mercury and Village Voice by EnergyAustralia on 13 February 2020 promoting the community feedback session (drop in) on the EIS;

■ a community drop in session to discuss the EIS was held on 18 February 2020 at Lithgow Library, Lithgow. The session was advertised via the letter box notification flyer and advertisements and attended by EnergyAustralia, Re.Group and EIS technical team; and

■ update on the ERP Project website (http://www.re-group.com/mtpiperenergyrecovery/).

2.2 Overview of Submissions

A total of 108 submissions on the Project were received from Government agencies, organisations and members of the public. DPIE and DPIE’s technical advisors also made comment on the EIS. The submissions are available on DPIE’s Major Projects website and are broken down as follows:

■ 93 public submissions: https://www.planningportal.nsw.gov.au/major-projects/project/11541/submissions/12921/3251

■ Six community organisation submissions: https://www.planningportal.nsw.gov.au/major-projects/project/11541/submissions/12931/3251

■ Nine Public Authority submissions: https://www.planningportal.nsw.gov.au/major-projects/project/11541/submissions/13111/3251

DPIE and government agency technical advisors (ARUP and CDM Smith) also made comment on the EIS: https://www.planningportal.nsw.gov.au/major-projects/project/11541

A breakdown of the submissions by type (support, object, comment) is detailed in Table 2-1.

http://www.re-group.com/mtpiperenergyrecovery/

https://www.planningportal.nsw.gov.au/major-projects/project/11541/submissions/12921/3251






https://www.planningportal.nsw.gov.au/major-projects/project/11541




Table 2-1: Breakdown of Submissions Received Type Object Support Comment Total

Public Authority* 1 1 7 9

Public** 26 4 2 32

Public** (form letter)

37 - - 61

Public** (modified form letter)

24 - -

Community Organisation 4 2 - 6

TOTAL 92 7 9 108

* Lithgow City Council submitted two responses, noting that Council did not have a position on the matter. The duplicate has been removed from these statistics. This figure excludes DPIE and government agency technical advisors comments. DPIE Water and NRAR submissions considered as one submission for the purpose of these statistics. ** The public submissions included duplicate submissions from four community members. These duplicates have been removed from these statistics.

Public and community submissions were received in the form of individual submissions, as well as submissions from community organisations. A total of 93 individual public submissions were received, of which 61 were a form letter or modified version of the form letter as detailed in Table 2-1 above.

A total of six submissions were received from the following community organisations:

■ Lithgow Environment Group Inc.;

■ Central West Media Pty Ltd;

■ Central West Environment Council;

■ Natural Conservation Council of NSW;

■ Mingaan Wiradjuri Aboriginal Corporation; and

■ The Colong Foundation for Wilderness Ltd.

A register of community and public submitters is provided in Appendix A.

Public authority submissions were received from:

■ DPIE Division of Resources and Geosciences;

■ DPIE Biodiversity and Conservation Division;

■ DPIE Water and Natural Resources Access Regulator (NRAR);

■ Water NSW;

■ Fire and Rescue NSW;

■ NSW Environment Protection Authority;

■ Transport for NSW, Roads and Maritime Services Division;

■ Lithgow City Council (letter advising they had no comment on the matter); and

■ Blue Mountains City Council.

DPIE provided a submission. ARUP provided comment in the role of technical advisor to DPIE and EPA. Further, CDM Smith also provided comment in the role of technical advisor to DPIE and NSW Health relating to the HHRA. NSW Health did not make a separate submission.

These are discussed further in Chapter 4.




2.3 Community Submissions by Locality

An analysis of submission by locality is detailed in Table 2-2.

Table 2-2: Community Submissions by Locality Submissions Lithgow LGA Blue Mountains

LGA Elsewhere TOTAL

Individual Submissions

Support 3 0 1 4

Comment 1 1 0 2

Object* 25 31 31* 87

Total 29 32 32 93

Community Organisation Submissions

Support 2 0 0 2

Comment 0 0 0 0

Object 1 0 3** 4

Total 3 0 3 6

* includes one individual submission as an objection where locality was not stated. ** Address stated on submission used in locality breakdown

An analysis of the 93 public and six community submissions identifies that:

■ 32% of all individual public submissions (including form letters) where from within the Lithgow LGA where the Project is located, 34% from the Blue Mountains LGA and the remaining 34% from elsewhere.

■ Of the 31 submissions from elsewhere (ie not Lithgow or Blue Mountains LGAs), four submissions were from interstate, including ACT (n=1), Northern Territory (n=1) and Queensland (n=2);

■ Form letters accounted for 40% and modified form letters accounted for 26% of all individual submissions received, for a combined total of 66% of all individual submissions. Of these 10% were from the Lithgow LGA, 43% from the Blue Mountains LGA and 47% from elsewhere.

■ Three out of four community organisation objections were organisations with an address on their submissions located outside of either the Lithgow or Blue Mountains LGAs.

2.4 Summary of Key Matters Raised in Community Submissions

2.4.1 Community Support Of the four public and two community organisation submissions in support of the Project, these submissions noted the following Project benefits:

■ diversion of waste from landfill and recovery of embedded energy to generate power;

■ sustainable power generation;

■ greenhouse gas benefits;

■ assist in economic transition by creation of a new industry which may lead to further commercial development and benefits to the region;

■ employment opportunities during construction and operation;




■ limited environmental impacts as defined in the EIS, requirements for continuous air monitoring and transparency in publishing monitoring results; and

■ alternative to mining.

2.4.2 Community Objections The key issues and their frequency raised in the community submissions are summarised in Table 2-3. Responses to the matters raised in community submissions are provided in Table 5-1.

Table 2-3: Key Matters raised in Community Submissions (Objections) Theme Matter raised Quantity*

Air quality and odour Odours from RDF 4

Impact of emissions geographically and air emission exceedances

16

Temperature Inversions and Air Quality Impact modelling 3

Stack height considerations 2

Air quality monitoring and management recommendations relating to the Project

7

Air quality monitoring and management recommendations relating to EnergyAustralia

1

Persistent Organic Pollutants (POPs) and contravention of the Stockholm Convention

5

Human health Health risks to the local community 32

Greenhouse gas Definition of the Project as ‘Clean energy’ 12

Greenhouse gas emissions 17

Traffic Impacts of RDF road haulage 21

Rail as alternative to road haulage 7

Waste inputs Concerns about RDF as a fuel source 9

Impacts on recycling and the waste hierarchy 19

Accepting RDF from Sydney/other regions 8

Ash management Ash management and environmental impacts 8

Water Water quality impacts to Cox’s River / Sydney Drinking Water Catchment

17

Noise Operational noise impacts 1

Noise modelling 1

Noise monitoring 1

Noise from truck movements for residents along the waste haulage route

6

Socio-economic Impacts to local economy 21

Social and lifestyle impacts 4

Property devaluation 3

Financial subsidises 7

Hazards and risk Fire risk 3

Engagement Engagement process by proponents and regulatory requirements

1

Alternative options Clean / Green energy investment and diversification 7




Theme Matter raised Quantity*

Efficiency of ERP 6

Recommendations for Waste Management without Waste to Energy

8

Use of coal as a fuel source 1

Statutory Framework State Significant Development classification 3

Federal and State Waste Programs and Strategies 2

Environment Protection Licence for the ERP and impacts on MPPS EPL

3

Project Description and Methodology

Project description and methodology 7

Cumulative Impacts Cumulative Impacts 1

*Proforma / modified proforma issues counted as one. Numbers do not correlate with the number of submissions received as submissions raised more than one issue in most cases.

Analysis of the submissions indicates the most common issues raised by objectors related to:

■ human health impacts on the local community;

■ impacts of RDF haulage;

■ impacts to the local economy;

■ impacts on recycling and the waste hierarchy;

■ impacts on the Sydney Drinking Water Catchment;

■ greenhouse gas emissions; and

■ air quality emissions.



ACTIONS TAKEN SINCE LODGEMENT OF THE PROJECT EIS

3. ACTIONS TAKEN SINCE LODGEMENT OF THE PROJECT EIS

3.1 Project Refinements

Since the completion of the EIS and following submissions on the EIS, further design and refinement has occurred with respect to:

■ the immobilisation technology proposed to treat the fly ash prior to disposal within the Ash Placement Facility;

■ future context and in principal agreement with Lithgow City Council of the Project’s contribution that will form the basis of a Voluntary Planning Agreement; and

■ revised GHG calculations to present the outcomes of review of the factors applied in the GHG assessment and reflecting the minimum GHG benefit as a result of the operation of the Project.

These refinements have not resulted in any material change to the project description nor development footprint, but rather provide further analysis and confirmation of the Project as presented in the EIS and Project commitments to contributions. These are discussed further below.

3.1.1 Immobilisation Technology Since the completion of the EIS and following submissions from DPIE, the EPA and DPIE’s technical advisor ARUP, further analysis of the immobilisation technology proposed to treat the fly ash prior to disposal within the Ash Placement Facility has been completed. Further information regarding immobilisation is provided in Appendix H.

The proponents have reviewed various available technologies within Australia and abroad, liaised with potential technology providers and subsequently shortlisted two suitable providers and identified a single preferred ash treatment technology.

The technology selected involves chemical immobilisation of leachable lead to form insoluble lead phosphate minerals, which is a proven methodology in similar applications. The process will utilise either phosphoric acid, triple-super-phosphate (TSP) or rock phosphate (RP) to immobilise the lead. pH and pH buffering capacity are managed to prevent contaminants remobilising with time. Cement is also required to convert the APCr and fly ash into an aggregated material and reduce dust potential.

From this they have been able to confirm the likely impacts of the process are consistent with the description in the EIS, as well as with clarifying the range of reagents that would be used and the storage quantities required by the Project. These have been considered and no material impacts or risks were identified.

As no formal engagement has been made, the proprietary details of the process are confidential in nature.

3.1.2 Voluntary Planning Agreement The proponents have advanced discussions with Lithgow City Council (Council) and reached in principal agreement with Council relating to Project developer contributions. A signed Letter of Offer between the proponents and Council has been reached, which will form the basis for the future preparation of a Voluntary Planning Agreement. The signed Letter of Offer is provided in Appendix L.

This letter indicates support by the proponents and Council in the Project contributing to the future development of a Lithgow Fuel Preparation Facility that would enable the community’s waste in the Lithgow area that is currently disposed to landfill, to be recovered and used to generate power. This would result in significant improvements to Council’s current resource recovery rates and waste management in the LGA. It is noted that Council and community members have raised interest in the ability to recover local waste to potentially provide a fuel source to this or other similar projects.




3.1.3 Revised GHG Calculations A review of the factors applied in the GHG assessment (presented in Appendix J of the EIS) has been undertaken relating to the RDF proposed to be used within the ERP. This review concluded that while the “FCC” factor (relating to carbon content of the waste) used in the calculations was low compared to the nominal RDF specifications for the Project design, the qualitative conclusions of the GHG assessment were accurate. However, for transparency and to avoid overstating the benefits of the Project, the Project Team has decided to take a more conservative view as to the GHG emission assessment.

The outcomes of the review, presented in Appendix W provide a more conservative analysis of the GHG emission assessment. The revised calculations present the outcomes of an exercise referencing an RDF composition that is intended to reflect the minimum GHG benefit as a result of the operation of the Project. The previous GHG calculations as presented in the EIS and revised GHG calculations are detailed further in Appendix W to provide a comparative analysis and increased level of conservatism in the assessment. Importantly both the original GHG assessment and the revised conservative assessment both demonstrate the net GHG benefit of the Project.

3.1.4 Photomontages of Plant To assist in understanding the bulk and scale of the Project in comparison to the existing MPPS, a series of photomontages of the Plant have been completed. These are presented in 0. These demonstrate that the Plant, including the stack, is significantly smaller in height, bulk and scale than the existing MPPS structures.

3.2 Additional or Updated Technical Assessments

To address issues raised by government agencies, DPIE, DPIE technical advisors and community submissions, the following additional or updated technical assessments have been completed since the EIS and form part of this RTS:

Table 3-1: Additional and Updated Technical Assessments Assessment Key Change / Update Location in RTS

Updated Air Quality Impact Assessment (AQIA)

Key updates to the AQIA report include: ■ an additional manufacturer’s guarantee case; ■ short term (1-hour) and long term (24 hour) results for regulatory

and manufacturer’s guarantee cases; ■ contemporaneous assessment of SO2; ■ all air impurities assessed for all three scenarios assessed; ■ sensitivity analysis; and ■ inclusion of CEMS data from MPPS and the Rüdersdorf

reference facility.

Appendix D

Updated Human Health Risk Assessment (HHRA)

Key updates to the HHRA report include: ■ consideration of drinking water exposure pathway and potential

impacts to the Sydney Drinking Water Catchment; and ■ incorporating changes from the AQIA into the HHRA report.

Appendix E

Updated Waste Feedstock Report

Key updates to the Waste Feedstock report include: ■ explanation of forecasts and assumptions used in the analysis; ■ discussion on the variability in waste growth rates for western

Sydney and average growth rates for each region provided; ■ further breakdown of RDF suitable wastes by LGA; ■ ratios of the available vs accessible waste; ■ commentary on the derivation of composition (impact of pre-

processing etc) and reference waste characterisations based on CSIRO reference data.

Appendix F




Assessment Key Change / Update Location in RTS

Supplementary Social Impact Assessment

A Supplementary Social Impact Assessment has been prepared which provides further analysis of social impacts, including potential impacts on the Blue Mountains and Lithgow area relating to amenity, tourism and impacts associated with truck movements and road safety, noise and air impacts.

Appendix I

Updated Traffic Impact Assessment

Updated Traffic Impact Assessment report which clarifies traffic generation volumes. Appendix K

Updated Noise and Vibration Impact Assessment

Key updates to the Noise and Vibration Impact Assessment report include: ■ revision and update to Project Noise Trigger Levels (PNTLs); ■ clarifications relating to: ■ Noise Enhancing Wind Analysis (NEWA) ■ sound power levels where equipment and/or machinery have

been modelled inside buildings or enclosures; ■ height of sources contained within the noise model; ■ assessment and application of NPI modifying factor (e.g. low

frequency); - road traffic noise daytime / night time split - out of standard hours construction activities - further details regarding the existing operational noise model

and modelling assumptions.

Appendix R

Revised GHG Calculations A more conservative analysis of the GHG emission assessment has

been completed presenting the outcomes of an exercise referencing an RDF composition that is intended to reflect the minimum GHG benefit as a result of the operation of the Project.

Appendix W

These updated technical assessment reports are further supplemented by specific responses to comments and issues raised in the agency and community submissions as detailed in Chapters 4 and 5 and within specialist appendices of this RTS report.

3.3 Stakeholder Engagement

During the preparation of the EIS, EnergyAustralia and Re.Group undertook a comprehensive program of engagement with the community and other key stakeholders. Since the lodgement of the EIS in early December 2019, continuing engagement with the community and Project stakeholders has been undertaken. This section summarises these actions, while a register can be found in full at Appendix B, and materials supporting the engagement provided in Appendix C.

3.3.1 Community Information Session on EIS A community information session was held during the EIS public exhibition period in order for the community to discuss and ask questions of the proponents and the EIS team relating to the outcomes of the EIS. The session was held 10:00 AM – 6:00 PM, Tuesday 18th February 2020 at Lithgow Library.

The community was notified of the session prior to the day through several methods, including advertisements in the local newspapers (Lithgow Mercury and the Village Voice), email to registered community members and stakeholders, and a letterbox drop to approximately 3,000 homes in the Lithgow LGA.

This session was attended by 27 community members and stakeholders.




3.3.2 MPPS Community Consultative Committee (CCC) Three MPPS CCC meetings have taken place since early December 2019. At each of these meetings, the CCC was updated on the status of the Project and the EIS and approval process. These meetings were held: 2 December 2019, 2 March 2020 and 1 June 2020.

These CCC meetings included a PowerPoint presentation to provide the CCC with an update of the Project, and to answer questions from CCC members. The PowerPoint presentations have been attached to the meeting minutes, provided in Appendix C.

3.3.3 Lithgow Council Meetings EnergyAustralia continues to engage generally monthly with Lithgow City Council to discuss a range of projects and activities at MPPS, including the Project. Since the lodgement of the EIS, meetings have been held with Council on:

■ 12 February 2020;

■ 19 February 2020, including site visit to MPPS;

■ 22 April 2020;

■ 28 April 2020;

■ 27 May 2020; and

■ 29 June 2020.

A key component of the engagement with Lithgow City Council has been discussions regarding the development of a Voluntary Planning Agreement (VPA). The proponents are seeking to enter in a VPA with Council in lieu of any other developer contributions. In discussion with Lithgow City Council, the concept is to provide equipment to process the community’s waste into RDF, so that material currently disposed to landfill can be recovered and used the generate power. The planning support and equipment the proponents can provide delivers significantly greater value than the equivalent cash contribution and can enable long-term, best practice outcomes for the management of waste in Lithgow LGA.

The proponents and Lithgow City Council have reached agreement in the form of a signed Letter of Offer, which is provided in Appendix L. The proponents will move forward with Lithgow City Council in preparing the VPA in accordance with DPIE guidance materials and based on the in-principle agreement detailed in the Letter of Offer.

3.3.4 Blue Mountains Council Meetings Since the lodgement of the EIS, meetings have been held with Blue Mountains City Council on:

■ 16 June 2020; and

■ 29 June 2020.

The primary purpose of the meetings was to proactively engage with Blue Mountains City Council relating to their submission on the EIS, and specific issues and concerns relating to the Project.

3.3.5 Project Website A Project micro-website has continued to be available to the community and can be found at: www.re-group.com/mtpiperenergyrecovery/.

It includes important information about the Project and its benefits, a summary of the outcomes of the EIS, project materials, important links, and an email address created specifically for the community.

Screenshots of the Project website and EIS summary brochure are illustrated below Figure 3-1. Appendix C provides copies of stakeholder engagement materials.





Figure 3-1: Images from the Project website and EIS Summary Flyer

3.3.6 Regulatory Engagement Since the lodgement of the EIS, several meetings and email correspondences have occurred between agencies and the Project Team. The following list provides a summary of this key regulatory engagement:

■ 17 April 2020: Meeting with DPIE and their technical advisor ARUP to discuss DPIE and ARUP comments on the EIS;

■ 24 April 2020: Meeting with DPIE, EPA and DPIE’s technical advisor ARUP to discuss comments relating to the air quality impact assessment;

■ 27 April 2020: Meeting with EPA and DPIE’s technical advisor ARUP to discuss waste and RDF related comments and proposed RTS approach;

■ 1 May 2020: meeting with TfNSW to discuss comments relating to transport of RDF to the site, the transport route and controls;

■ 24 June 2020: meeting with DPIE to clarify community submissions classification; and

■ 28 July 2020: meeting with EPA to discuss questions relating to licencing and the waste levy.



RESPONSES TO GOVERNMENT AGENCY SUBMISSIONS

4. RESPONSES TO GOVERNMENT AGENCY SUBMISSIONS

As noted in Section 2.2, the following NSW Government agencies provided comment on the EIS:

■ DPIE Division of Resources and Geosciences;

■ DPIE Biodiversity and Conservation Division;

■ DPIE Water and Natural Resources Access Regulator (NRAR);

■ Water NSW;

■ Fire and Rescue NSW;

■ NSW Environment Protection Authority;

■ Transport for NSW (TfNSW), Roads and Maritime Services Division;

■ Lithgow City Council (letter advising they had no comment on the matter); and

■ Blue Mountains City Council.

Of the government agency submissions received, TfNSW supported the Project, Blue Mountains Council objected to the Project, and all other agencies submitted comments.

DPIE provided a submission. ARUP provided comment in the role of technical advisor to DPIE and EPA. Further, CDM Smith also provided comment in the role of technical advisor to DPIE and NSW Health relating to the HHRA. NSW Health did not make a separate submission.

Each of the matters raised by these agencies and technical advisors have been addressed in Tables 4-1 to 4-12.




Table 4-1: Department of Planning, Industry and Environment (DPIE) Submission Responses Reference No.

Theme Submission Response

DPIE_1 Energy from Waste Policy

The Department concurs with the issues raised and additional information requests made by ARUP and the EPA: ■ additional information regarding reference facility emissions and waste fuel composition ■ demonstration of consistency with the resource recovery criteria (Table 1 of the EfW Policy) ■ demonstration of international best practice techniques with respect to:

- emission controls - arrangements for the receipt of waste (quality assurance/quality control) - management of residues from the energy recovery process (ash placement facility)

■ an air quality impact assessment (AQIA) in accordance with the EPA’s ‘Approved Methods for the Modelling and Assessment of Air Pollutants in NSW’

■ compliance with the technical criteria particularly with respect to monitoring.

These matters have been addressed individually in response to ARUP and EPA specific comments in the following tables. The AQIA has also been updated to address these issues. The updated AQIA is provided in Appendix D.

DPIE_2 Human Health Risk: Air Quality Impact Assessment Inputs

The EPA has raised several detailed issues regarding the AQIA. The HHRA must be revised to reflect any change to the air quality modelling for both the regulatory case and the expected case for each scenario considered in the HHRA.

The HHRA has been updated to incorporate changes made to the air quality modelling, including the regulatory case, expected case and the new guarantee case for each scenario. The updated assessment is provided in Appendix E.

DPIE_3 Human Health Risk: Sydney Drinking Water Catchment

The HHRA does not consider the potential for a person to drink polluted water. The risk of chemical substances entering Neubecks Creek has not been considered. Neubecks Creek is located within the northern portion of the Mount Piper Power Station (MPPS) site which is within the Upper Cox’s River Catchment. The Cox’s River is part of the Sydney Drinking Water Catchment area. Further consideration of any potential impacts on the Sydney Drinking Water Catchment is required.

The HHRA has been updated to consider drinking water exposure pathways, including potential impacts on the Sydney Drinking water Catchment. The updated assessment is provided in Appendix E. The updated assessment concluded that there will be no measurable impact on water quality within the catchment.

DPIE_4 Human Health Risk: Fine Particulates

Table 9 of the HHRA does not identify particulates less than PM2.5 as a substance considered in the facility emissions. Further analysis of the potential impacts of particulates less than PM2.5 is required, or justification provided for not providing any additional analysis.

PM 2.5 is listed in this table and is assessed throughout the HHRA. It is noted that PM2.5 includes all particles less than 2.5 microns in size. So it is considered that assessment of particulate matter less than 2.5 microns in size has been included in this HHRA. The air quality modelling evaluated both PM2.5 and PM10. It is noted that PM10 includes all particles 10 microns or less and PM2.5 includes all particles 2.5 microns or less. So all of the small particles addressed as PM2.5 are also considered in the PM10 assessment. This is also the case for other methods for evaluating particles such as PM1. It is not common practice to measure or model size groupings of particles other than PM2.5 and PM10. The health effects information related to these size classes also includes health effects that might be resulting from smaller particles like those that would be in the size class for PM1 for example. It is, therefore, considered that PM2.5 in particular adequately covers all the size classes.

DPIE_5 Cumulative Assessment of Waste Feedstock Availability

The RDF Feedstock Report (Appendix F of the EIS) does not consider other potential energy from waste facilities that may compete for the same sources of feedstock as the proposed facility, including (but not limited to): ■ Western Sydney Energy and Resource Recovery Facility (SSD 10395) ■ Botany Cogeneration Plant (SSD 10373) ■ Eastern Creek Energy from Waste Facility (SSD 6236 – currently under appeal). The RtS must include a detailed consideration of waste feedstock availability having regard to a worst case scenario of all the above facilities operating concurrently.

Further analysis of feedstock supply and competing facilities for the Project is provided in Appendix F.1 of this RTS report. The analysis considered proposed energy from waste facilities that would be competing for RDF or RDF-like fuels, and also considered proposed facilities producing RDF or RDF-like fuel.

DPIE_6 Ash Placement Facility

Additional information is required regarding the predicted volumes of ash residue with respect to the sizing of the proposed ash placement facility. Further justification is required for the 10% contingency that has been applied to the expected volumes of ash residues to inform landfill design given it is possible the treatment process may increase the volume of air pollution control residues (APCr) and fly ash by between 5% and 120%, depending on the selected technology. The proposed ash placement area is located within the Lamberts North ash facilities for the MPPS, approved under Project Approval 09_0186 (PA 09_0186). Additional consideration is required to determine whether: ■ there are any limitations within PA 09_0186 to undertaking the proposed new ash placement activities ■ the conditions of PA 09_0186 can be met ■ the project approval should be modified to permit the new activities within the Lamberts North ash

placement area, given some of the ash residues from the new facility will be classed as Restricted Solid Waste.

Further analysis and consideration of ash volumes for the ERP and interactions with the Lambert’s North Ash Repository approval is provided in Appendix G of this RTS report.




Reference No.


Additional information is also required to confirm the current capacity of the ash placement areas at Lamberts North and Lamberts South and how the construction of the proposed new ash placement area within Lamberts North will impact on the available ash placement capacity for the MPPS for the expected design life of the power station.

DPIE_7 Ash Treatment Facility

Further information is required regarding the proposed technology or process for the immobilisation of the combined fly ash and APCr waste stream to provide more certainty around the expected volumes of residues. This must include a consideration of any potential impacts arising from the proposed immobilisation/treatment technology and any proposed mitigation or management measures, if required.

Further analysis and consideration of ash treatment, immobilisation and reuse is provided in Appendix H of this RTS report.

DPIE_8 Local Character/Socio-Economic Impacts

Public submissions have raised concerns regarding the potential impacts on the local character of the Blue Mountains. The Department requests that a more detailed assessment of local character and social impacts be provided in a Social Impact Assessment which: ■ identifies and analyses the potential social impacts of the development, from the points of view of the

affected community / ies and other relevant stakeholders ■ assesses the significance of positive, negative, and cumulative social impacts considering likelihood,

extent, duration, severity / scale, sensitivity / importance, and level of concern / interest ■ includes mitigation measures for likely negative social impacts, and any proposed enhancement

measures ■ details how social impacts will be adaptively monitored and managed over time ■ details community benefits of the facility. The assessment of social and local character impacts should have regard to the Department’s ‘Local Character and Place Guideline’ (2019) and ‘Social Impact Assessment Guideline’ (2017).

Further analysis and consideration of local character and socio-economic impacts is provided in a Supplementary Social Impact Assessment, provided in Appendix I of this RTS report.

DPIE_9 Construction Hours In accordance with the ‘Interim Construction Noise Guideline’, the Applicant must demonstrate and justify a need to operate outside the recommended standard hours. The following additional information must be provided: ■ a construction schedule/timetable detailing the number and duration of extended hours ■ nature of activities to be undertaken ■ plant and equipment to be operated ■ number of construction workers required to be on-site ■ justification for the extended hours ■ an assessment of predicted impacts (supported by relevant technical studies as required) ■ details of proposed community notification ■ complaints management ■ proposed mitigation and management measures.

An indicative out of standard hours construction schedule has been prepared detailing construction activities that may occur outside of standard construction hours, predicted impacts in accordance with the Noise and Vibration Impact Assessment and justification for the proposed out of standard hours works. This is attached in Appendix J. This will be further refined following appointment of the Engineering, Procurement and Construction (EPC) contractor and will be detailed in the Construction Noise Management Plan to be prepared and submitted to DPIE prior to the commencement of construction, as detailed in Chapter 6 of this RTS.

DPIE_10 Construction Noise The Noise Impact Assessment concludes the construction noise impacts from Scenario 03a (General Construction of Infrastructure) and Scenario 06 (Establishment of Ash Placement Facility) are predicted to be above the Construction Noise Management Levels (NMLs) for the project. It is not clear whether some of these works will be conducted out of standard construction hours. The NIA states the impacts will only be experienced for limited periods, however, no detail is provided regarding the duration of such works or the times at which such works will be carried out. Additional information is required to clarify the duration and times of the various construction scenarios assessed in the NIA, whether works will be carried out within standard construction hours or outside these hours and further justification for any construction noise impacts above the NMLs. Construction planning should have regard to the advice provided by the EPA in its submission on the project that the Applicant is required to ensure that any construction activities that occur outside of recommended standard hours of work are below the NMLs described in the ‘Interim Construction Noise Guideline’ (DECC, 2009).

During preparation of the NVIA the duration of each construction activity was not confirmed. The NVIA provides worst-case predicted (Leq, 15 minute) noise levels for all assessment periods (i.e. standard construction hours and outside standard hours). The NVIA then provides recommendations in Section 7.1 outlining the following: ■ High impact noise generating work and activities (e.g. Impact Piling) or activities predicted to exceed

NMLs, should be limited to the ICNG, 2009 recommended standard hours (i.e. 7 AM to 6 PM Monday to Friday and 8 AM to 1 PM Saturdays), with no work on Sundays or public holidays. Any unforeseen work that is required outside the recommended standard hours must be suitably mitigated and managed with a goal of achieving noise management levels at all residential receptors or undertaken with agreement from the appropriate consent authority and any potentially affected neighbours.

■ Any construction activities that occur outside the recommended standard hours of work should remain below the Noise Management Levels described in this assessment (as per the ICNG).

Scenario 03a (General Construction of Infrastructure) and Scenario 06 (Establishment of Ash Placement Facility) are predicted to exceed NMLs during OOHW. Therefore, these activities should not be undertaken outside the recommended standard construction hours. It should be noted that Scenario 03b (General Construction of Infrastructure) provides an alternative scenario utilising “Bored Piling” instead of “Impact Piling”. Scenario 03b is not predicted to exceed NMLs during OOHW, therefore these works may be undertaken outside the recommended standard construction hours. As detailed in Section 16.5.1 and Chapter 25 of the EIS and as restated in Chapter 6 of this RTS, these requirements will be detailed in a Construction Noise Management Plan, to be prepared and submitted to DPIE for approval prior to the commencement of construction. The Construction Noise Management Plan will provide further detail on the duration and times of the various construction scenarios assessed in the NIA.




Reference No.


DPIE_11 Construction Traffic Table 4.4 of the Traffic Impact Assessment (Appendix M of the EIS) contains a discrepancy in the number trucks predicted during Month 15 of construction. The total number of concrete deliveries is estimated to be 46 trucks per day, however, the total number of deliveries estimated for month 15 is only reported to be 22 trucks per day. A revised estimation of construction traffic is required supported by a revised assessment of predicted construction traffic impacts.

Table 4.4 (now Table 4.5) of the TIA has been updated to correct this transcription error. The text below the table has also been updated to be consistent with the revised table. The updated TIA inclusive of this correction is provided in Appendix K of this RTS report. The correct total number of deliveries estimated for month 15, stage 2 earthworks and civil works is 52 trucks/day. The findings of the assessments do not change, with the assessment concluding that the construction truck volumes there would not be expected to impact the surrounding road network.

DPIE_12 Voluntary Planning Agreement

Additional details are required regarding the terms of any voluntary planning agreement. The Department’s preference is that any VPA is prepared in draft form prior to determination and executed prior to operation of the proposed development. A signed letter of offer which has been accepted by Council is required prior to determination.

The proponents have been actively engaging with Lithgow City Council relating to the development of a Voluntary Planning Agreement for the development. A signed letter of offer accepted by Lithgow City Council is provided in in Appendix L of this RTS report.




Table 4-2: DPIE and EPA Technical Advisor (ARUP) Submission Responses Reference No.


ARUP_1 Waste Feedstock The feedstock report does not outline detailed assumptions of modelling parameters and the datasets and figures used. These should be detailed to determine if they are appropriate and realistic, including the growth rates and generation rates used and how they have been derived.

An updated RDF Feedstock Report is provided in Appendix F.1 of this RTS report. The updated report includes: ■ explanation of forecasts and assumptions; ■ discussion on the variability in waste growth rates for western Sydney and average growth rates for

each region provided; ■ further breakdown of RDF suitable wastes by LGA; ■ ratios of the available vs accessible waste; and ■ commentary on the derivation of composition (impact of pre-processing etc) and reference waste

characterisations based on CSIRO reference data.

ARUP_2

The waste feedstock report lists councils which have contributed to the final quantity for available MSW feedstock, however the relevant resource recovery criteria as outlined in Table 1 of the NSW EfW policy are not applied to each council on an individual basis and thereby the report does not provide confidence that estimates of available RDF are justified.

ARUP_3 The waste feedstock report also does not consider competing EfW facilities within the Sydney region that are at various stages of development and could be competing for some of the same sources of feedstock should they become operational.

Further analysis of feedstock supply for the Project, including consideration of competing facilities for RDF is provided in Appendix F.2 of this RTS report.

ARUP_4 Further detail should be included to provide clear comparison to demonstrate how the nominated reference facility (the Rudersdorf EfW in Germany) treats ‘like waste streams’ as required under the NSW EfW policy.

Further consideration of the requirements of the NSW EfW Policy relating to ‘like waste streams’ and how the Project’s use of the Rudersdorf Reference Facility meets this test is detailed in Appendix M.

ARUP_5 Flu Gas Treatment The Proponent has modelled daily average emission values and therefore consideration of managing spikes in emissions should be considered (for example a short-term exceedance on a half hourly basis). Emission spikes occur as the waste composition varies. It is recommended the Proponent describe: ■ a) the maximum emission over an hour (or half hour) within the reference facility;

and ■ b) how the proposed ERP will react to emission spikes.

This issue is similar to EPA_1 and EPA_2. An updated AQIA report is provided in Appendix D. Specifically, the updated AQIA now includes modelling of short-term (hourly) modelling representative in-stack concentrations observed at the reference facility at Rudersdorf. These data were collated using Continuous Emissions Monitoring System (CEMS) data direct from the Rudersdorf facility. Further commentary and detail is provided on start-up and shut-down emissions profile within the updated AQIA.

ARUP_6 Ash Placement Facility

The EPR EIS document does not clearly outline if the proposed ash placement facility will operate under the existing MPPS licence conditions or if a new licence will be required. This lack of definition not only presents uncertainty regarding applicable NSW legislative provisions but should Schedule 1 Scheduled Activities of the NSW Protection of Environment Operations Act 1997 be applicable as relevant to Clause 39 Waste Disposal (application to land) this would define the ash placement facility as a Scheduled Waste Disposal Facility and this definition may carry NSW waste disposal levy implications for the site. Currently the EIS document does not discuss any NSW waste levy implications for the ERP.

Further consideration of the proposed licencing of the Project under the Protection of the Environment Operations Act 1997 and applicability of the waste levy to the Project is provided in Appendix N.

ARUP_7 The proposal indicates that the two ashes will be combined into a single ash stream and therefore an overall classification of hazardous waste for the stream is adopted prior to any treatment. Consideration of maintaining separation of these streams would provide flexibility for disposal, depending on testing of the material during commissioning.

As described in “Section 3.3 Ash Placement Facility" of the EIS, the quantity of fly ash that is collected at the second and third boiler pass is very small (less than 2% of total). While the collection point offers ability to segregate the boiler fly ash from the APCr, in practice, conveying and transporting this fine dust material will be challenging. Pending further testing during commissioning, it is likely that this ash will be difficult to transport to the Ash Placement Facility without treatment. Taking a conservative view of the characteristics of this ash, the proponent feels the two ashes should be mixed for better handling and treatment prior to placing in the Ash Placement Facility. The collection systems for the two streams are separate, so if separate disposal is warranted then a retrofit would be possible.

ARUP_8 No specific technology or process has been nominated for the immobilisation of the combined fly ash and APCr stream, therefore the impact assessment would benefit from describing the likely scenarios that the ash may be subject to (e.g. washing, leaching, stabilisation, solidification or vitrification).


ARUP_9 It is noted that higher order processes for the use of ash are only explored as an option for the impact on increase in anticipated ash volumes on the ash placement facility design - higher order uses for bottom ash material should be considered as a priority over disposal.


ARUP_10 Environmental Risk Management

For each ‘environmental aspect’ (e.g. air quality and odour, soils and water etc.) ‘potential impacts’ are listed for assessment. However, there is a lack of consistency and clear logic applied in the determination of ‘potential impacts’ included in this assessment. For example, some impacts listed define an impact, others list an operational aspect and others identify risks posed by activities. Clarity needs to be provided as to the approach of impact identification and description.

A revised Risk Assessment is provided in Appendix O.

ARUP_11 A number of ‘environmental aspects’ include a range of potential impacts classified under the same risk rating, thereby making it difficult to determine the justification for the risk rating selection as it is unlikely that consequence and likelihood is the same for all impacts included.





Reference No.


ARUP_12 From the assessment provided in the EIS it is not clear which defined risks require further assessment within the designated EIS chapter/appendices and there is no clear link between the risks identified and the mitigation or management measures. In addition, there is no justification or discussion provided for any risks or impacts omitted from the assessment. Further, a description of the existing environment is not presented in the waste chapter (chapter 13).


ARUP_13 SEARS Requirements

The proposed layout and loading procedure for bulk deliveries should be clarified. During a meeting held 27th April 2020 with the NSW EPA, DPIE (and ARUP, as DPIE’s technical advisor), ARUP clarified that their comment related to the RDF ‘unloading’ procedure. A revised version of Figure 3-2 from the EIS is attached in Appendix P. This provides clarification relating to the tipping bay and tipping hall. The description of the unloading area is found in Section 3.2.4.2 of the EIS, which states ■ the tipping hall will be an enclosed area for trucks to reverse up to the tipping bays; ■ the tipping bay is a section of the fuel storage bunker designed to receive the fuel, but separated from

the main section of the fuel bunker; ■ each tipping bay will be fitted with rapid opening and closing doors to minimise odour escape; and ■ for each delivery, the truck will manoeuvre into place at one of the tipping bay doors. The door will

open when the truck is detected, allowing the truck to discharge RDF into the tipping bay. The RDF cranes will lift and move the RDF from the tipping bay into the main section of the fuel bunker as required for mixing and storage, and to ensure the doors are clear for subsequent deliveries.

ARUP_14 Additional ash placement facilities / forward planning for disposal should be discussed. Further analysis and consideration of ash volumes for the ERP is provided in Appendix G of this RTS report. Further analysis and consideration of ash treatment, immobilisation and reuse is provided in Appendix H of this RTS report.

ARUP_15 It is recommended that the risk assessment approach and the summary table 9-5 is revised to integrate with initial risk levels aligned with appropriate mitigation measures and revised risk ratings (once mitigation has been implemented).


ARUP_16 It is recommended that integration of mitigation measures is clearly defined for each environmental aspect. A revised Risk Assessment is provided in Appendix O.

ARUP_17 There is inconsistency in the terminology used to present impacts and risks, this should be revised to make it clear how all potential risk levels have been derived.


ARUP_18 Risks should be split between operation and construction. A revised Risk Assessment is provided in Appendix O.

ARUP_19 It is unclear how combined risk ratings have been derived, further clarification is required on how this has been done.


ARUP_20 The assessment should be updated to include a description of the existing environment in terms of waste generation and management.

Chapter 13 of the EIS detailed waste outputs for the Project. As requested by ARUP, the commentary below provides a description of the ‘existing environment’ relating to waste at the site. The MPPS has existing waste ash placement facilities, the Mt Piper Ash Repository (MPAR) and the Lamberts North Ash Repository (LNAR) (the Ash Repositories). The Ash Repositories are approved to receive ash resulting from burning of coal for generation of power at the MPPS. The following types of ash are deposited at the Ash Repositories: ■ During the winter months, only Water Conditioned Ash (WCA) is deposited in both Ash Repositories.

The water currently used in conditioning WCA is sourced from the MPPS storm water settling ponds; and

■ During the summer months, Brine Conditioned Ash (BCA) is deposited above 946 metres Australia Height Datum (m AHD) at the MPAR only. Brine is derived from the evaporative cooling process in the cooling towers at the MPPS. As water evaporates from the cooling towers, the concentration of salts contained in the circulating water increases. Blowdown water from the cooling towers is transferred via storage ponds for treatment by the Springvale Water Treatment Project (SWTP), or the existing EnergyAustralia brine concentrators, where by the salt loading is further concentrated and separated from the blowdown water. The brine stream is then transferred to the existing Brine Waste Ponds for temporary storage prior to use in ash conditioning. The SWTP also produces a mixed salt and a dewatered lime salt which is transferred to either the crystalliser feed tank, or existing Brine Waste Ponds, prior to placement in approved areas of the MPAR. BCA placement has not yet commenced at the LNAR however it is allowed under certain condition in accordance with the current project approvals.




Reference No.


Brine or water are added to the ash to achieve approximately 15% moisture prior to placement. The moisture is intended to allow the ash to be more easily handled and to achieve desired compaction of placed ash. Brine is used to condition the ash as an alternative to other off-site disposal or treatment options. The Ash Repositories are managed and progressively capped in accordance with their respective and approved management plans. Further, MPPS generates a range of consumable waste types associated with the operational, maintenance and administrative functions of the power station. These wastes include a range of materials that are disposed in accordance with EPA guidelines, and materials that are recycled. This includes: ■ Materials disposed in accordance with EPA guidelines (including but not limited to): General wastes, oil

blankets, oi filters, chemicals, sharps, sanitary, tyres and oil contaminated water; and ■ Materials recycled (including but not limited to): cardboard and paper, waste oil, waste timber, metals,

drums, fluorescent lights, lead acid batteries, grease trap waste, toner cartridges, e-waste, plastics.

ARUP_21 Potential cumulative impacts from ash production in the event the ash repository cannot handle all volumes should be stated.

Further analysis and consideration of ash volumes for the ERP is provided in Appendix G of this RTS report.

ARUP_22 Assessment of potential waste impacts from the construction phase should be clearly included in the environmental risk assessment.


ARUP_23 Construction and operation dust management should be separated and assigned individual risk ratings. A revised Risk Assessment is provided in Appendix O.

ARUP_24 The number of truck movements required to transfer ash should be clarified and made consistent within the EIS documentation and between all assessments.

The number of truck movements associated with the transfer of ash from the Plant to the Ash Placement Facility is: ■ Bottom ash: 1 to 2 trucks per day (as detailed in Section 13.3.2.4 of the EIS) ■ Fly Ash: up to 1 truck per day (as detailed in Section 13.3.3.5 of the EIS) These truck movements were included within the relevant technical assessments.

ARUP_25 A clear outline of potential impact to groundwater and the management measures adopted should be provided.

The Project is not expected to result in any impact to groundwater at either the Plant or the Ash Placement Facility. Groundwater is present at depths well below the maximum depth of disturbance for the project and hence is not expected to be disturbed. At the Plant Area, all operations will be undertaken within buildings and on sealed areas. Any leachate generated at this stage would be recirculated into the boilers and vaporised. At the Ash Placement Area, the containment cells will be double lined with a specialised system which has been designed in accordance with NSW EPA Solid Waste Landfill Guidelines. The system separates leachate which may be generated by the containment cell from the underlying strata and facilitates removal to above ground storage tanks. The cell lining includes both a primary and secondary containment layer as a contingency in unlikely event that the primary layer is breached. There will be an ability to monitor the presence of leachate both above the primary and the secondary liners and leachate present will be removed in order to prevent the build-up of hydrostatic pressure. To monitor the ongoing condition of groundwater, a groundwater monitoring network will be installed down gradient of the Ash Placement Facility. The requirement for monitoring of groundwater will be formalised both in the site OEMP and EPL and will include (at minimum) monthly sampling for the first 12 months of operation and then quarterly (every 3 months) thereafter. The results undergo assessment against specified criteria, with the outcomes reported annually. In the event of any pollution event arising from the Project, the appropriate notifications will be made to the NSW EPA under the POEO Act. Further details on the groundwater monitoring program and groundwater impact mitigations are presented in Appendix C of the EIS.

ARUP_26 This potential impact categorised under ‘soils and water’ is very broad, and the risk of various aspects could differ i.e. risks of soil contamination might be more likely than groundwater contamination. These potential impacts should be separated out and assessed accordingly so it is clear how the risk rating has been derived.


ARUP_27 The traffic assessment should be updated to consider the impact on the transport network in the vicinity of the RDF consolidation point as well as the impact with additional light vehicle traffic and additional heavy vehicle traffic.

The Traffic Impact Assessment (Section 2.9) states that the bulk of the RDF to be processed at the Project Site is expected to derive from Western Sydney which has a number of EPA licensed resource recovery facilities. The TIA therefore considered traffic impacts associated with RDF transport from a consolidation point being the start of the M4 Western Motorway. Local traffic impacts associated with the future development of any specific RDF processing facilities would be subject to separate assessment during the planning approval process for those facilities and are out of scope for this application.




Reference No.


ARUP_28 The total emissions saving over the life of the ERP should be updated to reflect changes in NSW grid emissions intensity over time and relevant sections of the report and conclusions need to be revised and clarified.

An updated NSW grid emissions intensity factor has been incorporated into the calculation in Table 5.5 below from the GHG Assessment (Appendix J of the EIS):

Table 5‑5: Estimation of GHG emissions (substitution of grid electricity) (Updated GHG) Net Output

(MW) Operational hours

(per year) Net Electricity input into the grid (MWh per

year)

Emission factor for grid

electricity in NSW (t CO2-

e/MWh) 1

Substitution from main

electricity grid (t CO2-e / annum)

30 8,000 240,000 0.81 199,440

Note 1: Latest estimate provided in Table 7.2, NGER Technical Guidelines (DoEE, 2017)

It is acknowledged that there is a trend towards decarbonisation of the NSW grid. To account for the anticipated reduction for substitution of grid electricity for the facility over time, sensitivity analysis was performed. The scope 2 emission factor for grid electricity in NSW was plotted for the last 10 years of data is provided in Figure 5 1 of the GHG assessment (DoEE, 2017). From these data, a percentage reduction of the scope 2 emission factor per year was calculated based on a linear trend. It is acknowledged that the decarbonisation of the grid may accelerate consistent with the current NSW government’s commitment to net zero emissions from 2050, however for the purposes of the current exercise the emissions intensity of the grid has been adjusted year-on-year based on the historical trend. Using the reducing scope 2 emission factor for grid electricity in NSW, the quantity of GHG emissions diverted from the NSW electricity grid were calculated over a 25 year period as presented in in the revised GHG calculations provided in Appendix W, which indicates that the operation of the Project would potentially eliminate over 4.7Mt CO2-e over a 25 year period through substitution of grid electricity.

ARUP_29 A detailed, evidence-based and transparent explanation on how on expected ash generation volumes have been derived should be provided.

Further analysis and discussion on ash generation volumes is provided in Appendix G of this RTS report.

ARUP_30 The likely scenarios for immobilisation of the combined fly ash and APCr ash stream should be detailed and their impact on the ERP proposal defined. Furthermore, potential higher order uses should be explored within these scenarios.


ARUP_31 An evidence-based and transparent justification needs to be presented for the anticipated RDF composition. As explained in the response to ARUP_4 relating to ‘like waste streams’ (refer Appendix M), the design of the ERP does not depend on a specific composition for the RDF. The critical criteria for the design are the combustion parameters (calorific value, moisture content, ash content, etc) and elemental composition (maximum levels of chlorine, sulfur, etc). To develop the RDF specification, the proponents engaged in commercial in confidence discussions with waste processing facilities, equipment manufacturers, and engineers with experience in waste processing. Based on the confidential data provided by those companies, the proponents have formed a view that RDF can be produced to meet the specification. In Appendix F of the EIS (refer updated report in Appendix F.2 of this RTS): Waste Feedstock Report, Ricardo Australia made an independent assessment using publicly available data and came to similar conclusions. Specifically, Table 7 of section 4.3.1 of that report shows calculated values for the combustion parameters for unsorted MSW and an estimated composition based on reducing the wet organic material and non-combustible (high ash) fractions of the waste, resulting in values close to the design point of the ERP. Ricardo concludes: ■ With the removal of approximately 60% of the garden and food organics, either no longer present due

to the collection preferences of NSW EFW policy or via mechanical removal, and most inert materials, such as glass, masonry and other non-combustibles a comparable specification is achievable.

■ It is not possible for the proponents to provide the raw data and analysis of waste streams in existing waste processing facilities, as this is proprietary data belonging to those facilities. In most cases it has been gathered at significant expense, and is commercially confidential as making this data public would provide advantage to the competitors of those facilities.

■ Ultimately, it is a decision for the proponents to accept the commercial risk of sourcing RDF to match the design characteristics of the ERP. However, the proponents have provided to the DPIE a confidential aggregated summary of the expected RDF characteristics for the nominal design fuel.

ARUP_32 Table 4-4 needs to be revised to include an explicit comparison between reference facility waste input and the ERP anticipated waste input.

Table 4-4 of the EIS has been revised to include an explicit comparison between the Rudersdorf reference facility waste input and the ERP waste input. This is detailed in Appendix M.




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ARUP_33 Clarity should be provided on the Proponent’s plans to share monitoring data – will this be to the NSW EPA as well as made available publicly?

Monitoring data will be provided in accordance with the requirements of the EPA’s EfW Policy. This includes provision of monitoring data to the NSW EPA in real time format and provision of a weekly summary of continuous monitoring data and compliance with emissions limits published on the Project’s website. Further, provision of monitoring data will also meet the requirements of the EPL to be issued for the Project. This commitment has been incorporated into the updated management and mitigation measures detailed in Chapter 6 of this RTS.

ARUP_34 Clarity should be provided on plans for continuous measurements of combustion chamber parameters including temperature.

Section 3.2.6.6 of the EIS states the elements that will be measured and fed both to a monitoring system as required by legislation as well as used in the control system for various plant and equipment operation. This includes oxygen, water vapour, carbon dioxide, pressure, temperature and flue gas flow. The proponents confirm that the pressure and temperature measurements will be taken at various locations throughout the plant including the combustion chamber and will be used for process monitoring and control.

ARUP_35 It is understood no preferred technology provider has been selected at this stage, however it would be beneficial to provide further details about how support from the technology provider will be integrated into demonstration of POP trials.

Steinmüller Babcock Environment (SBE) has been selected as the preferred technology provider for this Project. SBE’s role in the project will include support for the commissioning of the equipment, which will include the POP trials. The overall Project commissioning will be the responsibility of the selected EPC contractor, however SBE is expected to have personnel in attendance for the commissioning period.

ARUP_36 Data from the nominated reference facility should be presented on TOC and LOI. The TOC content of the bottom ash from the Rudersdorf reference facility is not continuously measured. The limit value is < 3 %. During the performance test the following data was measured:

Date 18.07.2008 Bottom Ash Boiler ash

Loss on drying (105 °C) wt% 13,7 <0,1

LOI of dry Substance (550 °C) wt% 3,0 1,1

TOC wt% 0,3 0,3

Reference amount 5770 kg/h 729 kg/h

Sampling was performed according to LAGA PN98.

ARUP_37 Confirmation is required that auxiliary burners with direct link to the DCS and combustion control system are included within the design as it is not clear in the EIS.

The auxiliary burners are designed to be automatically put in service if the required flue gas temperature is not achieved during RDF combustion. The rate of firing and temperature setpoints are determined by the Burner Management System (BMS), which is part of the Distributed Control System (DCS).

ARUP_38 The NSW EPA should consider the NOx limits that will apply to the ERP and resultant requirements for emission abatement technology.

In the Best Available Techniques Assessment (Appendix E of the EIS) (Ricardo, 2019), ‘section 3.3.3.2 Control of NOx’, the proponents considered both SCR & SNCR system to treat the flue gas. Ricardo stated “Selective Catalytic Reduction (SCR) is an alternative process that can reduce NOx levels further than SNCR. However, it requires a catalyst to be able to operate as well as a reagent. Due to the costs and increased complexity (different temperature range, location of injection and catalyst etc) it is considered BAT to use SNCR.” Further, in section 4.1 of the BAT Assessment, Ricardo stated: “The SNCR system proposed would, therefore, appear to be the best choice in terms of meeting applicable emissions limits. A more costly SCR system is not justified, noting that the Air Quality Impact Assessment (AQIA) concludes that there would be no/minimal improvement on the environmental performance of the facility by reducing the NOx emissions to SCR levels.” The proponents agree with Ricardo’s assessment, and note that the Air Quality Impact Assessment (Appendix I of the EIS, now updated in Appendix D of this RTS) concluded that the NOx predictions were small and within respective criteria. Adopting an SCR system is unlikely to provide a material environmental benefit.

ARUP_39 The Proponent should consider use of a dry-wet system. Re.Group and EnergyAustralia engaged Steinmüller Babcock Environment GmbH (SBE), the technology provider, to compare different solutions for flue gas cleaning through modelling three options: ■ Scenario 1: Base case; ■ Scenario 2: Inclusion of a secondary wet scrubber (as suggested by Arup); and ■ Scenario 3: Option 2 with a heat exchanger to reheat the flue gas after the scrubber. The key differences between the options are: ■ Both Option 2 and Option 3 would reduce the SOx emission guarantee from 30 mg/m3 to 5 mg/m3 and

HCl guarantee from 6 mg/m3 to 2 mg/m3; ■ Both Option 2 and Option 3 would require increased water usage compared to the base case:

additional 64 ML/a for Option 2, 26 ML/a for Option 3; ■ Both Option 2 and Option 3 would increase parasitic load;




Reference No.


■ Option 3 would reduce the steam production; ■ Due to the parasitic load and steam reduction, Option 3 would reduce net power production by

approximately 6% (close to 2 MW). SBE, confirmed that a wet scrubber could give lower overall emission levels of HCl and SOx and it could be done without creating a waste water stream by reinjecting the scrubber water back into the furnace (which recycles the contaminants so they are eventually trapped by the lime and bag filter). However, SBE do not recommend the wet scrubber because: ■ As noted by Arup, this would increase water usage, which is not appropriate in a country prone to

drought. ■ The wet scrubber would increase parasitic load (due to increased pressure loss), reducing the overall

efficiency. ■ Further, the wet scrubber would reduce the exit temperature of the flue gas, reducing dispersion and

creating a visible plume of water vapour which would change the visual impact and community perception. Reheating the flue gas to counteract this would further reduce efficiency.

■ The fuel specification for the ERP specifies relatively low Sulfur and typical Chlorine concentrations compared to typical EfW facilities. This means the expected raw (untreated) flue gas contaminants are low, so the nominal averages of the conditioned semi-dry system in operation will be below the guarantee levels, and only a few times a day will the limit value be reached.

■ An additional scrubber might be recommended in case of very high SOx and HCl raw gas peaks, because the fuel was high in S and Cl, however this is not the case for the Project.

For the ERP, it is noted that: ■ Neither HCl nor SOx showed a material impact on the local air quality in the AQIA. While some SOx

exceedances were noted in the combined (background + Mt Piper + ERP) cases, this was wholly due to the MPPS contribution and the contribution of the ERP at this time was “effectively zero” according to the AQIA.

■ Option 2 is rejected due to the visible plume and lower exit velocity ■ Option 3 is rejected due to the water usage (water savings are specifically mentioned in the SEARs)

and reduced electricity production for no material benefit to the air quality - 26 ML of additional water usage is a 32% increase on the base case; - The 6% (2 MW) reduction in electricity would result in higher production from fossil fuel power

plants elsewhere on the grid, with associated air pollution and greenhouse impacts (and the older power plants in the NSW grid do not have modern air pollution controls like the ERP).

In conclusion: ■ The net impact of adding the wet scrubber compared to the base case would be:

- The ERP would use more water - Energy conversion to electricity will be reduced, undermining the requirement in the EfW Policy to

recover energy where practicable - More air pollution (including greenhouse gases) would be produced elsewhere in NSW - There would be a reduction in the absolute emissions from the ERP, but no material change to the

impact in the local airshed ■ On balance, this change would not provide increased environmental benefit and thus the dry/wet

scrubber combination would not be the Best Available Technique for this project.

ARUP_40 The Proponent should include consideration of emission spikes in their assessment. This comment is the same as ARUP_4 and has been considered in that response.

ARUP_41 The Proponent should confirm how combustion chamber temperature monitoring will be undertaken. Temperature is monitored in multiple locations, to ensure compliance with the minimum combustion temperatures and also for the optimisation of NOx emission control. This includes selected locations within the combustion chamber and boiler, and a grid measurement using pyrometers installed in a cross-section in the first pass of the boiler.

ARUP_42 The Proponent should confirm that monitoring practices and procedures will be in line with the Waste Incineration BREF. Currently the Proponent has only confirmed it will be in line with the requirements of the IED.

The WI BREF published in Q4 2019 represents international best practice. Under NSW EfW Policy Statement, facilities should be designed and operated in line with international best practice. BAT 4 of the WI BREF sets out monitoring requirements for emissions to air. The following phrase is applicable: BAT is to monitor channelled emissions to air with at least the frequency given in the table and in accordance with EN standards. If EN standards are not available, BAT is to use ISO, national or other international standards that ensure the provision of data of an equivalent scientific quality.




Reference No.


The Project will install equipment (a suitably designed CEMS system and suitably designed monitoring and sampling points) that would allow these measurements to be accurately taken in accordance with the relevant requirements of the NSW EPA. The proponents anticipate that the monitoring requirements will be expressed in the Environment Protection Licence for the facility, and refer to the requirements provided within the NSW EPA Energy from Waste Policy Statement (EPA, 2015) in conjunction with the Best Available Techniques Conclusions (BATC) for Waste Incineration (EU 2019).

ARUP_43 The Proponent should clarify how emissions will be monitored during start up and shut down. It is not clear how this will be achieved.

The Continuous Emission Monitoring system (CEMs) will be put in service prior to start up and will remain in service during start-up and shut-down providing required readings to various internal controls. The readings are available, however the emission values during start up and shut down do not form part of the manufacturer’s emission guarantees. It is expected that the values will generally be low as there will be no RDF combustion under such a scenario. The start up and shut down scenarios are considered further in the revised AQIA (Appendix D of this RTS).

ARUP_44 The feedstock assessment needs to be evidence-based and fully transparent with full details provided on modelling assumptions and parameters with each step of the derivation laid out in detail to provide justification for the quantities of RDF feedstock stated and how the resource recovery criteria are met.

An updated RDF Feedstock Report (Ricardo, 2020) is provided in Appendix F of this RTS report. The updated report includes: ■ explanation of forecasts and assumptions; ■ discussion on the variability in waste growth rates for western Sydney and average growth rates for

each region provided; ■ further breakdown of RDF suitable wastes by LGA; ■ ratios of the available vs accessible waste; ■ commentary on the derivation of composition (impact of pre-processing etc) and reference waste

characterisations based on CSIRO reference data.

ARUP_45 The feedstock assessment should also seek to consider the impact of competitors for the feedstock. Further analysis of feedstock supply for the Project, including consideration of competing facilities for RDF is provided in Appendix F of this RTS report.

ARUP_46 The Proponent needs to provide clarity regarding their intention for the environmental license for the ash placement facility license (revision to current license or new) and impacts of this. This also needs to present a clear consideration of potential liability for NSW waste disposal levy payments.

Further consideration of the proposed licencing of the Project under the Protection of the Environment Operation Act 1997 and applicability of the waste levy to the Project is provided in Appendix N.

ARUP_47 Higher order uses above disposal should be considered and discussed for all waste streams including construction waste.

An updated Waste Mitigation and Management Strategy table has been prepared which defines high order uses across the various waste streams to be generated by the Project during construction and operation. This is provided in Appendix Q.

ARUP_48 The PHA should include additional detail on the following aspects: integration with existing critical systems, chemical handling and storage, materials handling including transport and storage (particularly ash management), residual risk owners and items to be covered in the detailed design phase.

Integration: As detailed in the Preliminary Hazard Analysis (Appendix P of the EIS), integration between the ERP and the existing MPPS system consists of: (a) Boiler feed water received from MPPS; (b) Superheated steam exported to the MPPS; and (c) Firewater piping branched off from existing power station. With respect to this integration: ■ If boiler feed water is not received from the MPPS, the Energy Recovery Plant will shut down (low level

on Steam drum); ■ If the Energy Recovery Plant is shut down, MPPS reverts back to its current operation, i.e. no boiler

feed water export; ■ If superheated steam is not exported due to Energy Recovery Plant shutdown, MPPS reverts back to

its current operation; ■ There is no risk to MPPS if the Energy Recovery Plant is shutdown (completely independent plants);

and ■ The risk to the Energy Recovery Plant if boiler feed water is lost is short term steam production

interruption. No safety or environmental risk exists. This is further considered in HAZID Tables Item 6 in Appendix A of the PHA, which is located in Appendix P of the EIS. Chemical handling and storage: Details of chemical storage will be further refined during the detailed design phase of the Project. Note that none of the chemicals listed are dangerous goods and pose no significant hazards (this includes the chemicals proposed for the ash immobilisation), as further detailed in Appendix H of this RTS report. It is expected that a condition of consent will be a Final Hazard Analysis. The chemical storage details will be addressed at that time as design would have advanced further. Note that there are no safety and environmental impacts. Materials handling: Hazards of ash handling have been identified in Item 6 of the HAZID Table in Appendix A of the PHA, which is located in Appendix P of the EIS. Residual risk owners and items to be covered in the detailed design phase: The interfaces, and all operations of the ERP will be addressed in the detailed design phase.




Table 4-3: EPA Submission Response (Submission ID: 124049) Reference No.


EPA_1 Air Quality and Odour

The proponent is required to provide the pollutant air emission guarantees from SBE and present a revised Scenario 1: Regulatory Case emissions scenario based on the pollutant air emission guarantees.

An additional scenario ‘Scenario 3 - manufacturer’s guarantee case’ has been added to the AQIA that covers the short-term (1-hour) and long term (24-hour) emissions guarantees that have been provided by SBE. All of the emission guarantees detailed are at or below those adopted for the regulatory case and therefore comply with the NSW POEO emission limits. Refer to Section 8.2.1.3, Section 10.4 and 10.5 of the updated AQIA report, provided in Appendix D.

EPA_2 For the Regulatory Case emissions scenario the proponent must evaluate 24-hour and annual impacts from the ERP using emission concentrations on a 30 minute or hourly basis in accordance with the NSW regulatory framework.

The updated AQIA has split Scenario 1 (regulatory case) to evaluate predicted impacts using both 1 hour and 24 hour emission limits. The results are presented for all air impurities for all averaging periods in accordance with those regulated under the Approved Methods. The updated AQIA is provided in Appendix D.

EPA_3 The proponent clarify the reference facility stack concentrations and emission rates. The Project has selected a reference facility located at Rudersdorf in Germany. The Rudersdorf facility, which has been in operation since 2009, uses the equivalent Steinmüller Babcock Environment (SBE) moving grate technology, has similar capacity and Air Pollution Control. Additionally, over its operational life it has treated a wide range of wastes including RDF. The applicability of Rudersdorf as an appropriate reference facility is supported in the BAT Assessment (Ricardo, 2019; Appendix E of the EIS). The expected Case Air Quality Scenario referenced uses data from Rudersdorf for 2015, when its waste stream was most like that proposed for the Project, comprising 89% RDF. Appendix M of this RTS provides further consideration of the like waste streams and includes a waste input summary for the Rudersdorf Reference Facility (t/year) for the period 2012 – 2019 with a comparison to the Mt Piper ERP RDF. The proposed stack emission parameters for the ERP including flow rate and temperature, have also been compared with Rudersdorf’s Continuous Emission Monitoring System (CEMS) data measured between 2016 and 2018. A comparison of these data is shown in Figure 2.2 of the updated AQIA. It is seen that exhaust temperatures from the ERP are expected to be comparable with those measured at Rudersdorf. The flow rate of the ERP is anticipated to be higher due to the different thermal capacities of the plants. The higher flow rate at the ERP in turn has resulted in higher mass emission rate assumptions from this facility. Hourly CEMS data measured at Rudersdorf for 2016 to 2018 has also been reviewed. A summary of these hourly data sets is shown in the box and whisker plots in Figure 8.5 of the AQIA. Also shown are the in-stack concentration assumptions adopted for both the expected case and the regulatory case (see Section 8.2.1.1 of the AQIA). For all air quality metrics measured at Rudersdorf the adopted in-stack concentrations for the Project are considered to be a conservative estimate of the emissions that are expected to be released during the normal operation of the Project. The emission parameters adopted for the assessment are detailed in Section 9.4 and Table 9.1 of the AQIA. The updated AQIA is provided in Appendix D.

EPA_4 For each pollutant at the reference facility, maximum and average in-stack concentrations and emission rates are provided for 1-hour, 24-hour and annual averaging periods (where available).

The AQIA has split Scenario 1 (regulatory case), Scenario 2 (expected case) and Scenario 3 (manufacturer’s guarantee case) into emissions run at the 1 hour and 24 hour in-stack concentration averaging periods. The results are then presented for all air impurities for all averaging periods, including 1-hour, 24-hour and annual, in accordance with those regulated under the Approved Methods. The updated AQIA is provided in Appendix D.

EPA_5 The proponent provide all emission parameters for the reference facility. Hourly CEMS data measured at Rudersdorf for 2016 to 2018 are included in the AQIA. A summary of the hourly data sets is shown in the box and whisker plots in Figure 8.5 of the AQIA. Also shown are the in-stack concentration assumptions adopted within the expected case and the regulatory case. For all air quality metrics measured at Rudersdorf the adopted in-stack concentrations for the Project are considered to be conservative estimates of the emissions that are expected to be released during the normal operation of the Project.

EPA_6 The proponent must revise the AQIA to model and assess impacts from all air impurities in both modelled scenarios.

The AQIA has split Scenario 1 (regulatory case), Scenario 2 (expected case) and Scenario 3 (manufacturer’s guarantee case) into emissions run at the 1 hour and 24 hour limits. The results for are presented for all air impurities for all averaging periods in accordance with those regulated under the Approved Methods. The updated AQIA is provided in Appendix D.

EPA_7 Maximum emissions and maximum approved load capacity be modelled for both ERP scenarios, and that validation of emission rates for the MPPS be provided.

For the cumulative assessment, the existing emissions from the Mount Piper Power Station (MPPS) were included in the modelling. To conservatively represent operating emissions, the last five years of MPPS reported National Pollutant Inventory (NPI) emissions were sourced (Department of Environment and Energy, 2019). The average operating load of the last 10 years was 75%. To account for the MPPS source, the MPPS emissions were then scaled based on the operating load of the previous five years, 66%. This assumes a linear relationship between emissions and operating load. The adopted 75% load is considered a conservative estimate for recent operations at MPPS. Hourly output data from MPPS has been made available for 2019. It is noted that this may be considered an anomalous year




Reference No.


due to the turbine upgrade, however, this has been accounted for. The 2019 data set has then been compared with annual outputs for MPPS for the financial years 2013 to 2018 and is shown in Table 8.3 and Figure 8.5 of the updated AQIA, reproduced below. As shown, there is a general trend of decreasing power output from MPPS with more recent years showing output well below the 75% operating load assumed within this assessment.

AQIA Figure 8.5: Box and whisker plot of hourly output from MPPS for 2019 combined with annual output data for FY2013 – FY 2018.

EPA_8 The proponent provide actual emissions concentration data from monitoring and testing of point sources at the MPPS and demonstrate the assumed emission concentrations are consistent with licence conditions.

To provide a worst case cumulative emissions scenario the recently amended MPPS Environmental Protection Licence (EPL) limits have been considered for the cumulative component of Scenario 1 – regulatory case and Scenario 3 – manufacturer’s guarantee case. Nitrogen oxides and sulfur dioxide EPL limits were used to estimate emission contributions from MPPS and the remaining air quality metrics are based on the NPI annual load data annual emissions average from 2013 to 2019, as described above. For the Scenario 2 – expected case CEMS data for 2019 was used to estimate contributions from MPPS for NO2 and SO2. As the respective air quality metrics are the only available CEMS measured, the remaining air quality metrics are based on the NPI annual load data. More information on the MPPS emissions and inputs is provided in Section 8.2.2 and Section 9.4 of the updated AQIA. The updated AQIA is provided in Appendix D.

EPA_9 The proponent provide justification and validation of assumed emission parameters for the MPPS. For a cumulative assessment, the MPPS was modelled as a continuous emission source. The modelling parameters are presented in Table 9.2 of the AQIA. The adopted flow rates are considered a reasonable estimate of MPPS operations under a conservative 75% load as discussed in Section 8.2.2. The updated AQIA is provided in Appendix D.

EPA_10 The proponent investigate SO2 impacts further through a refined SO2 assessment. This assessment should include a contemporaneous assessment of SO2 impacts, evaluation of SO2 exceedances and provide a summary of the impacts as outlined in Table 11.3 of the Approved Methods for the Modelling and Assessment of Air Pollutants in NSW, which includes, as a minimum:

■ Time/date

■ ERP increment

■ MPPS increment

■ Adopted background

■ Cumulative (total) impact.

A detailed discussion of the SO2 exceedances is provided in Section 10.6 of the AQIA. This includes presentation of the impacts consistent with the approach detailed in Section 11.3 of the Approved Methods (ranked by background contribution, ERP increment and MPPS increment respectively). The updated AQIA is provided in Appendix D.

EPA_11 The proponent evaluate short term ammonia impacts for both modelled scenarios. For the Regulatory Case emissions scenario, the proponent must provide and model maximum ammonia emissions and compare predicted ground level concentrations to the EPA’s 1-hour average impact assessment criteria

Ammonia emissions have been assessed for all three scenarios investigated in the AQIA. The updated AQIA is provided in Appendix D.




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EPA_12 The proponent provide further information justifying all assumed Regulatory Case metal emission concentrations and rates from the proposed ERP

For aggregate metals groups, a speciation has now been provided based on the guidance on assessing group 3 metal stack emissions from incinerators published by the United Kingdom Environment Agency (UK EA, 2016). When a given metal was not previously detected within these data, i.e. Beryllium (Be), Selenium (Se) and Tin (Sn), 0.5% of the aggregate metals concentration was attributed to each of these metals (above the group total). Mercury was excluded from the exercise as it has its own regulatory limit of 1 hour average POEO limits for Mercury and its compounds. The metal compositions for each aggregate metals group are presented in Table 8.4 of the AQIA and reproduced below. When a metal was repeated in different groups the higher of the two in-stack concentrations was assumed. Table 8.4: Metals compositions for aggregate groups for Regulatory Case

Metal Cadmium & thallium and their compounds (total)

9 metals: Sb, As, Pb, Cr, Co, Cu, Mn, Ni and V and their compounds (total) (a)

13 metals: Sb, As, Pb, Be, Cd, Cr, Co, Mn, Hg, Ni, Se, Sn and V

As - 5.0% 5.0%

Be (b) - - 0.5%

Cd 85% - (c)

Co - 1.1% 1.1%

Cr - 18.4% 18.4%

Cu - 5.8% 5.8%

Mn - 12.0% 12.0%

Ni - 44.0% 44.0%

Pb - 10.1% 10.1%

Sb - 2.3% 2.3%

Se (b) - - 0.5%

Sn (b) - - 0.5%

Tl 15% - 0.5%

V - 1.2% 1.2%

TOTAL 100% 100% 101.9% (d)

Notes: (a) IED group metals proportioned using maximum percentage of the IED group 3 ELV reported in UK EA (2016)

(b) 0.5% contribution to the aggregate metals was assumed as these metals were not previously detected in reference monitoring data.

(c) Assumed to be the same as Manufacturer’s emissions Guarantee (Section 8.2.1.3 of AQIA).

(d) 3 non-detected metals each included at 0.5% above group total (100%) to avoid decreasing prevalence of detected metals,

difference in sum is due to rounding of compositions. It does not account for Mercury, which has its own IED emission limit.

EPA_13 The proponent must consider and present options for metal emissions that will achieve compliance the Group 6 POEO Clean Air Regulation emission limit and align with the SBE pollutant air emission guarantee

All metal emissions under all assessment scenarios are anticipated to achieve compliance with Group 6 POEO Clean Air Regulation emission limits and align with SBE pollutant air emission guarantees.

EPA_14 The proponent prepare a revised AQIA that assumes 100% NOx to NO2 conversion for annual average concentrations

For conservatism, the annual average NO2 predictions within the updated AQIA have adopted the 100% NOx to NO2 conversion methodology.

EPA_15 The proponent investigate the accuracy of their NOx conversion method Level 2 Ozone Limiting Method (OLM) has been adopted for the NOx to NO2 conversion for the maximum predicted 1 hour average NO2 concentrations for all scenarios. Further detail on the Ozone Limiting Method specific to the ERP Project is provided in Section 9.7 of the updated AQIA.

EPA_16 The corresponding NOx concentrations at receptors be provided together with predicted NO2 concentrations for both modelled scenarios

NOx concentrations have been provided in the results tables in Section 10 of the updated AQIA.




Reference No.


EPA_17 The proponent undertake and present in a revised AQIA a sensitivity analysis that evaluates the relationship between exit velocities, using a range of potential flow rates, and offsite impacts.

As part of this analysis, several additional atmospheric dispersion modelling runs have been undertaken for the ERP stack. A detailed sensitivity analysis is provided in Appendix B of the AQIA. A summary of the results is provided below. Based on this analysis, the maximum volumetric flow (condition E; MAX) is considered to provide a general worst case operating condition, generating the highest model predictions across maximum 1 hour average, 99.9th percentile 1 hour average, and annual averages. For the 24 hour average, the condition E prediction was estimated to be 9% lower than the grid maximum, whilst providing worst case predictions at all sensitive receptors. This indicates that condition E also represents the worst case flow condition for all averaging periods within the context of this assessment. On this basis, Condition E (MAX) is considered appropriate for application in the regulatory case assessment scenario.

EPA_18 The proponent confirm whether the flow rate used results in the worst offsite impacts and if it does not, revise and remodel both emission scenarios using the flow rate determined to cause the worst-case offsite impacts.

Refer to EPA_17 response above.

EPA_19 The proponent prepare a revised assessment which adequately considers emissions and impacts from start-up and shutdown and the use of a support fuel

In accordance with clause 52 of the POEO (Clean Air) Regulations emission limits do not apply during start up and shutdown. However, it is important to ensure that emissions are minimised during this period. Emission profiles for the reference facility (Rudersdorf in Germany) have been reviewed during start up and shut down. Detailed discussion on these data is provided in Section 8.1.1 of the AQIA. In view of the above, during start-up and shutdown the emissions peaks for NOx and CO are relatively short-lived and stabilise relatively quickly and efficiently. The updated AQIA is provided in Appendix D.

EPA_20 The proponent clarify why the MPPS does not contribute to 7- and 30- day HF impacts while contributing to 24-hour and 90-day impacts

The results tables for hydrogen fluoride have been updated for the 24 hour, 7 day, 30 day and 90 day averaging periods for all scenarios. Please refer to Section 10 of the updated AQIA (Appendix D).

EPA_ 21 The proponent clarify how many operating hours were modelled in each scenario and if only 8000 hours were modelled, how were the hours treated in the model

The Project will operate 24 hours a day, 7 days a week, with occasional offline periods for maintenance. The maintenance will include both planned shutdowns (initially these will be once a year, for a period not exceeding 3 weeks) and unplanned shutdowns in response to breakdowns or issues identified from plant monitoring. The suppliers of the Project technology have proposed an annual availability of 91.3%, which equates to 8,000 hours per year of operation. Notwithstanding the above, it is confirmed that the dispersion modelling has assumed that the ERP (and MPPS for cumulative assessment) is assumed to be operational for all hours (8,760 hours across the full calendar year modelled).

EPA_22 The proponent clarify the impacts for all pollutants and for all scenarios to remove any incorrect values, inconsistencies and ensure accurate impacts are presented for evaluation

Transcription errors have been addressed within the updated AQIA (Appendix D).

EPA_23 The proponent clearly provide details of the pollutants and operating parameters proposed to be continuously monitored to determine compliance with the NSW EPA Energy from Waste Policy Statement CEMS requirements and the BATC

The facility will include a Continuous Emissions Monitoring System (CEMS) that will operate in accordance with the NSW EPA Energy from Waste Policy Statement (EPA, 2015) in conjunction with the Best Available Techniques Conclusions (BATC) for Waste Incineration (EU 2019). The CEMS will include the monitoring of the parameters described in Table 3.1 of the updated AQIA (Appendix D), reproduced below: Table 3.1: Continuous Emissions Monitoring Parameters

Parameter Instrument Type CO, CO2, NO, NO2, HCl, H2O, SO2, NH3

Fourier Transformer InfraRed spectroscopy (FTIR)

Continuous

HF FTIR Continuous* O2 Zirconium Oxide method. Continuous TOC Flame ionization method Continuous Particulates Light deviation Continuous

It should be noted that due to the inherently low stack concentrations of HF, continuous measurements are subject to a poor signal to noise ratio. This is because HF is a highly reactive gas that is present only in low concentrations with stack measurements being at or near the detection limit of most methods and subsequently is subject to calibration issues. However, it is included for compliance with the NSW EPA Energy from Waste Policy Statement. For similar reasons to above, the continuous measurement of Mercury (Hg) is not recommended as part of the CEMS for the Project. Rather, the measurement of Hg, along with other heavy metals will be measured in




Reference No.


accordance with the NSW EPA Energy from Waste Policy Statement (EPA, 2015) via periodic emission testing.

EPA_24 The proponent consider conducting an odour assessment or adequately justify the absence of an odour assessment

The key potential source of odour from the Project will be from the RDF prior to combustion. As such, odour management measures are focused on managing the RDF. The fuel bunker has been sized for four and a half days storage of the design fuel. Three tipping bays are provided on the fuel bunker to allow for multiple truck dumping and distribution of RDF along the length of the bunker. A bay for the bale opener will be also provided. Each tipping bay will be fitted with rapid opening and closing doors to contain odours. The inward opening doors will open automatically when the presence of a truck is detected by an IR-optical sensor. An interlock will be provided between the bunker crane and the tipping bay doors to prevent the doors from opening when the crane is working in the area adjacent to the doors. For these operations, the design incorporates control of potential fugitive emissions by drawing furnace air from within the bunker such that a slight negative pressure will be maintained. Further detail on the odour management is detailed in Section 2.4.5 of the updated AQIA (Appendix D). On this basis, potential operational particulate, VOC and/or odour emissions from fuel bunker operations are considered negligible. The potential impact of emissions during inactive periods are anticipated to be low, due to the lack of active RDF operations, the fully sealed building with standalone ventilation system, and absence of sensitive receptors in close proximity to the ERP facility. Potential emissions during these periods should be managed through consideration of operational management practices such as depletion of open fuel stocks and general housekeeping. In view of the above, and in consideration of the distance between the project and the nearest sensitive receptors, the risk of adverse odour impacts is considered minimal and therefore has not been considered further in the updated AQIA.

EPA_25 The proponent consider and provide additional information on how the chlorine content in the RDF will be assessed on an ongoing basis and how received waste with greater than 1 % of chlorine will be managed, including the ability to raise gas temperature from the minimum of 850 °C to 1100 °C.

Successful and safe operation of the new boiler relies on the RDF being consistently within the design specification for the boiler. A draft Quality Assurance and Control Procedure (QA/QC) for the receipt and use of RDF for the Project has been prepared (refer Appendix G of the EIS). A component of the QA/QC procedure is to ensure that chlorine content remains below 1% of the RDF by weight. It is noted however that the design of the plant includes contingencies to handle short term incursions above 1% chlorine if the QA/QC controls fail. As noted within the NSW Energy from Waste Policy Statement (EPA 2015), if a waste has a content of more than 1% of halogenated organic substances, expressed as chlorine, the temperature should be raised to 1,100°C for at least 2 seconds after the last injection of air. The technology supplier confirms that this operating temperature is not incorporated within the current plant design, which is more consistent with a hazardous waste incinerator process. Rather, and as noted above, the facility relies upon the regulation of the feedstock to meet the requirements of the NSW Energy from Waste Policy Statement.

EPA_26 The proponent evaluate the variability in emissions from differing RDF compositions than the single composition ratio assumed in the AQIA

For design purposes, it is assumed that 50% of the RDF will be sourced from household waste collections (municipal solid waste, or MSW), and 50% of the fuel sourced from suitable types of commercial waste. In practice, the percentage from each source can vary from 0-100% without impact on the Project operations, due to the pre-processing required to meet the Project input specifications. Furthermore, it has been confirmed from the technology supplier that the emissions are expected to remain within the guarantee levels regardless of the source of the RDF, providing that the parameters (e.g. calorific value, sulphur content and chlorine content etc.) are within the design range of the plant. The composition and performance of the input parameters of the RDF are discussed in Section 2.4.1 of the updated AQIA (Appendix D). Importantly, the technology provider will guarantee the ability of the Air Pollution Control system to meet guarantee limits, explicitly modelled within the updated AQIA, under normal operating conditions providing the basic design parameters range is met.

EPA_27 The proponent clarify the proposed removal processes and efficiency of arsenic and cadmium control technology Arsenic (As) and cadmium (Cd) will be precipitated together with fly ash and reaction products in the bag house filter. Both elements are gaseous leaving the furnace. As the flue gas cools down in the boiler to < 200°C homogeneous nucleation on fly ash particle surfaces occurs.

EPA_28 The proponent confirm all air pollutants have been assessed against the correct Impact Assessment Criteria All air pollutants have been assessed in accordance with the Approved Methods within the updated AQIA.

EPA_29 Noise Emissions

Any approval of the proposal be made conditional on the production of a Traffic Management Plan which places emphasis on managing driver behaviour, specifically the minimisation of engine braking

The NVIA has been updated (refer Appendix R) to include a recommendation for the Project to prepare a Traffic Management Plan (TMP), with specific recommendations around managing driver behaviour including the minimisation of engine braking.

EPA_30 For Project Noise Trigger Levels: The proponent revises the NVIA to ensure that the project amenity level is defined in accordance with section 2.4 of the NPfI prior to conversion to Leq,15min level for the PNTL

The NVIA has been reviewed and the Project Noise Trigger Levels (PNTLs) have been updated accordingly. Updates have been made to commercial / Industrial criteria, and have not changed the outcomes of the NVIA (refer Appendix R).




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EPA_31 For Meteorological Conditions Assessment: The proponent is required to provide a justification that the meteorological data set used (Bathurst) is appropriate and representative of the local receivers potentially affected by the premises or alternatively amend the assessment based on meteorological data that better reflects conditions experience in the area.

A review of the meteorological data utilised for the NVIA has been undertaken. It is noted that the Noise Enhancing Wind Analysis (NEWA) prepared as part of the NVIA was undertaken using data from the on-site meteorological station. The Bathurst meteorological station was only used to provide representative historic annual mean meteorological information (e.g. humidity 78% and temperature 6.9C) to establish the noise model. Meteorological stations found in Lithgow did not have a suitable data set required to successfully prepare the noise model at the time of the assessment. However it is considered that humidity of 78% and temperature of 6.9C is representative of the receptors in the Project area (refer Appendix R).

EPA_32 For Operational Noise Modelling: The Proponent is required to provide details of how the noise model was validated using the existing data from the MPPS.

The NVIA was updated to provide further detail on how the existing operational noise model was estimated, based on historic noise monitoring data and reports. A summary of the historic noise monitoring data is now provided in Table 6.1 of the NVIA, which indicates that the predicted existing operational noise model was within 0.3 dBA of the average estimated site noise level at each historic monitoring location (refer Appendix R).

EPA_33 For Operational Noise Modelling: The proponent is required to provide an explanation of how meteorological conditions have been accounted for in the predictions made in section 2.6.1 of the NVIA and a justification that they are appropriate.

Table 2.1 of the NVIA has been updated to provide additional detail on how meteorological conditions have been calculated (refer Appendix R). Refer below: ■ Brüel & Kjær’s Predictor 7810 (Version 12.00) noise modelling software package was utilised to calculate

construction and operational noise levels using the ISO9613:2, 1996 noise propagation algorithms, international method for general purpose: 1/1 or 1/3 octaves in Hertz (Hz).

■ Meteorological corrections have been calculated via the CONCAWE method (Report no. 4/18, The propagation of noise from petroleum and petrochemical complexes to neighbouring communities, Prepared by C.J. Manning, M.Sc., M.I.O.A. Acoustic Technology Limited (Ref.AT 931), CONCAWE, Den Haag May 1981).

The meteorological conditions adopted for the assessment have been applied to modelling as per Fact Sheet D of the NPI, 2017.

EPA_34

For Operational Noise Modelling: The proponent is required to clarify the height of sources used in the noise modelling

The height of sources contained within the noise model has been reviewed. It is noted that emissions were modelled largely as emitting facades and/or roofs (where applicable), which has been clarified throughout relevant sections of the NVIA (Chapter 6) and appendices (Appendix D) of the NVIA (refer updated NVIA in Appendix R of this RTS report).

EPA_35 For Operational Noise Modelling: The proponent is required to clarify if the stack itself will be a noise source, and if not, what mitigation measures will be used to minimise its noise emission.

It is noted that the stack itself has not been included as a noise source, however the stack outlet has been modelled as a noise-emitting source at 70 m above ground height. This has been clarified in Appendix D of the NVIA (refer updated NVIA in Appendix R of this RTS report).

EPA_36 For Operational Noise Modelling: The proponent is required to clarify the requirements in chapter 6 and 7 for the equipment sound power levels which are required in order to meet the PNTLs

A review of Chapters 6 and 7 has been undertaken, and further clarity has now been provided around sound power levels where equipment and/or machinery was modelled inside buildings or enclosures, including details of noise level reductions across frequency bands. This information is now provided in Table 6.1 of the NVIA and Appendix D (refer updated NVIA in Appendix R of this RTS report).

EPA_37 For Operational Noise Modelling: The proponent is required to clarify if the modifying factor for low frequency noise as defined in Noise Policy for Industry (NPfI) Fact Sheet C has been appropriately calculated and applied where required.

A review of the NVIA was undertaken to clarify the assessment and application of NPI modifying factor (e.g. low frequency). The noise spectrum of predicted results for each receptor has been tested as per requirements of the NPI, 2017. No modifying factors were required for this assessment. Section 6.1 now states “Modifying factors (penalties) for annoying noise characteristics such as tonality and low frequency components etc. were considered as per the requirements of NPI, 2017. Based on the noise source data presented in this assessment and model outputs, penalties were not applied to the results in this assessment” (refer updated NVIA in Appendix R of this RTS report).

EPA_38 For Operational Noise Modelling: The proponent is required to review the sound power levels in order to ensure alignment with AS 2436 2010 and amend as appropriate.

A review of the NVIA was undertaken and further detail on modelling assumptions has now been included in Chapter 5, Chapter 6 and Appendix D. Noise modelling data has been adopted based on a combination of AS 2436 2010, the TfNSW CNVS and ERM Acoustics – Measured Lw Library (refer updated NVIA in Appendix R of this RTS report).




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EPA_39 For Road Traffic Noise Assessment: The proponent is required to clarify the assumptions used in the day and night volume split, and the volumes of both light and heavy vehicles associated with the project.

The road traffic noise assessment was reviewed, and further clarity provided around the split between daytime and night-time traffic volumes for both light and heavy vehicles. This is provided in Chapter 5 (Construction) and Chapter 6 (Operation). Construction Maximum: ■ 104 heavy vehicle movements + 270 light vehicle movements ■ Modelling has assumed a split of 85% / 15% (daytime/night-time) Operational Maximum: ■ 96 heavy vehicle movements + 24 light vehicle movements ■ Modelling has assumed a split of 98% / 2% (daytime/night-time) The updated Traffic Impact Assessment (Appendix K of this RTS report) was also reviewed to ensure the latest traffic volumes were included in the road traffic noise assessment. Additionally, the recommendations in the NVIA have been updated to ensure that a Traffic Management Plan be prepared by MPPS for both construction and operational traffic (see response to EPA_29). The updated NVIA is provided in Appendix R of this RTS report.

EPA_40 For Construction Noise Assessment: The proponent is required to ensure that any construction activities that occur outside of recommended standard hours of work are below the Noise Management Levels described in the Interim Construction Noise Guideline (DECC, 2009)

A review of the construction noise assessment was undertaken and updates to the NVIA have been made to include requirements that construction activities do not occur outside standard construction hours, unless works are below the relevant NMLs. Refer Section 7.1 of the NVIA. The following recommendations are included: ■ High impact noise generating work and activities (e.g. Impact Piling) or activities predicted to exceed

NMLs, should be limited to the ICNG, 2009 recommended standard hours (i.e. 7 AM to 6 PM Monday to Friday and 8 AM to 1 PM Saturdays), with no work on Sundays or public holidays. Any unforeseen work that is required outside the recommended standard hours must be suitably mitigated and managed with a goal of achieving noise management levels at all residential receptors or undertaken with agreement from the appropriate consent authority and any potentially affected neighbours.

■ Any construction activities that occur outside the recommended standard hours of work should remain below the Noise Management Levels described in this assessment (as per the ICNG).

The updated NVIA is provided in Appendix R of this RTS report.

EPA_41 Waste Management

The proponent is required to clarify how RDF generation, composition, supply and audit processes will be managed in 3rd party supply contracts in order to ensure the specified emissions performance of the ERP is met on a continuous basis.

The processes that will be applied to 3rd party RDF generators via supply contracts is detailed in the QA/QC procedures (Appendix G of the EIS). EPA requirements relating to this question were clarified during a meeting held 27 April 2020. On the basis of discussions during that meeting, further clarification has been provided in Appendix S of this RTS relating to aggregation of fuel input if one supplier is out of design range of the Plant, front end treatment to reduce metals content and sampling and testing frequency.

EPA_42 Any Approval of the proposal be made conditional on the inclusion of independent 3rd party certification of the ash repository construction, demonstrating compliance with the NSW Solid Waste Landfill Guidelines

Noted.

EPA_43 The proponent is required to clarify if and how the application of the waste levy will be applied to the material disposed of in the ash repository

Further consideration of the proposed licencing of the Project under the Protection of the Environment Operation Act 1997 and applicability of the waste levy to the Project is provided in Appendix N.

EPA_44 The proponent is required to clarify what measures will be used to manage RDF feedstock and RDF materials in order to prevent fugitive waste generation at any facilities used to process and handle those materials.

The management of RDF feedstock at generation facilities (i.e. source facilities) is out of scope of the Project and would be subject to relevant assessment under separate planning approval.

EPA_45 The proponent be required to provide details of how the ash will be stabilised in terms of the chemicals to be used and the proposed process


EPA_46 The proponent be required to prepare a new operational environmental management plan to cover the management of all of the ash and associated contaminated water within the Lamberts North Ash repository

The Project will be operated under a Joint Venture arrangement between EnergyAustralia and Re.Group, as detailed in Section 1.3.3 of the EIS. The Project will therefore be constructed and operated by a separate entity to MPPS. Project specific management plans will be prepared for the Project during construction and operation, inclusive of interactions with MPPS and the Lambert’s North Ash Repository, and in consultation with MPPS and the operator of Lambert’s North Ash Repository.

EPA_47 The proponent is required to include a Licenced Discharge Point and monitoring program in the proposal for any waters to be discharged from within the ash repository out into LNAR. This should include the setting of pollutant concentration limits to ensure pollution does not occur through any discharge

Proposed surface water discharge point, discharge limits and proposed surface water monitoring program are detailed in Appendix U.

EPA_48 The proponent is required to include Electrical Conductivity as a test parameter in any ground and surface water quality monitoring programs

Noted.

EPA_49 The proponent should provide a timeline for periodic reviews of available options for reuse of flyash in Australia. Further analysis and consideration of ash treatment, immobilisation and reuse is provided in Appendix H of this RTS report. This includes a commitment for a review of bottom ash reuse options every five years, as agreed with the EPA during a meeting held 24 April 2020.




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EPA_50 Administrative The proponent detail how it intends to split the project as proposed from the current EPL 13007 by providing information on proposed boundary changes, emissions and discharge limits and the delineation of ash management and associated contaminated water in the Lamberts North Ash Repository

It is intended that the Energy Recovery Project will operate under its own Environment Protection Licence. Further consideration of various licensing scenarios for the Project is discussed in Appendix N and follows discussions with the EPA at a meeting held on the 28 July 2020. Proposed surface water discharge point, discharge limits and surface water monitoring program for the Project are detailed in Appendix U. The ERP EPL will have its own discrete point emission source (ERP stack) with its corresponding CEMS / periodic monitoring requirements. It is anticipated that the emission limits for this point source will correspond to the in-stack concentration values presented in the Scenario 1 – Regulatory Case and/or Scenario 3 – Manufacturer’s Guarantee Case. While it is common that 1-hour emission limits are mandated in NSW, we present 24-hour emission limits which more accurately predict the performance of the selected technology, and which could be used in the event that EPA wish to provide limits over longer averaging periods consistent with the BREF.

Table 4-4: DPIE Biodiversity and Conservation Division Submission Response (Submission ID: 121159) Reference No.


DPIE BDC_1

Biodiversity It is noted that a BDAR waiver was granted on 7 November 2019 as it was determined that the proposed development is not likely to have any significant impact on biodiversity values. The project described in the EIS is as described in the BDAR waiver application. The Biodiversity Assessment Report accompanying the EIS states that no vegetation communities were present on the development site that are consistent with any plant community types under the BioNet Vegetation Classification and therefore no floristic plots were undertaken. It is noted that the proponents have undertaken their Aboriginal cultural heritage (ACH) due diligence and that the site has a long history of high impact activities and that archaeological material has not been identified on the site. BCD has no further comment to make regarding ACH or biodiversity impacts from this proposed development at this stage.

Noted.

Table 4-5: Water NSW Submission Response (Submission ID: 121160) Reference No.


Water NSW_1

NorBE Assessment The neutral or beneficial effect (NorBE) assessment in the Soil and Water Assessment (Appendix L, Chapter 6) is inadequate. However, Water NSW notes that water quality issues relating to potential contamination via ash placement and erosion sediment control plan are addressed in the previous chapters.

MUSIC modelling has been completed for the Energy Recovery Plant. The assessment, results and concept stormwater treatment plan are provided in Appendix T. Results of the MUSIC modelling demonstrate a beneficial result. The proposed stormwater management for the Energy Recovery Plant site (including 1.75 hectares of roof

area and additional hardstand area) does not include specific stormwater management measures other than clean/dirty water diversion. Stormwater quality modelling using MUSIC software is required to design the stormwater treatment for the increased impervious area for the proposal to demonstrate NorBE. Consequently, it cannot be determined whether the Energy Recovery Plant site has a neutral or beneficial effect on water quality.

Notwithstanding the concerns listed above, WaterNSW considers that the project would likely achieve NorBE, subject to the provision of MUSIC stormwater quality modelling for the Energy Recovery Plant site that meets the requirements of WaterNSW’s Current Recommended Practices (CRP) “Using MUSIC in Sydney Drinking Water Catchment” (WaterNSW 2019).

Water NSW_2

Requested Information

A MUSIC stormwater quality model for the Energy Recovery Plant site,

Water NSW_3

Soil and Water Management Plan and associated sub plans and monitoring programs including: ■ detailed erosion and sediment control plans for the Energy Recovery Plant site and Ash Management

Facility ■ detailed stormwater management plans based on MUSIC stormwater quality modelling outputs, and ■ leachate management plan

These will be prepared in consultation with WaterNSW prior to the commencement of construction / operations as per standard requirements for a SSD project approval. Revised Summary of Management and Mitigation Measures is provided in Chapter 6 of the RTS which specifies these requirements.




Table 4-6: Fire and Rescue NSW Submission Response (Submission ID: 121885) Reference No.


FRNSW_1 Fire Safety and Emergency Response

FRNSW have reviewed the Environmental Impact Statement (EIS) that was prepared in support of the development and will not be providing comment at this time as there is currently insufficient information available regarding the fire safety and emergency response management aspects of the project.

Noted. FRNSW to be further consulted during detailed design.

FRNSW_2 FRNSW request to be consulted during the design phase of the fire and life safety systems for the site and project.

Noted.

Table 4-7 DPIE Division Water NSW Submission Response (Submission ID: 121160) Reference No.


DPIE DR&G_1

N/A The Division has no issues to raise with the Project. Noted.

Table 4-8: DPIE / NSW Health Technical Advisor on Human Health Risk (CDM Smith) Submission Response Reference No.


CDM Smith_1

Human Health Risk Assessment

Three main emission sources are identified in the AQIA – road transport, the ERP plant and the ash placement facility. While all three areas are introduced in Section 2 of the HHRA, only the road transport and ERP plant are discussed in the HHRA for their potential impacts to air quality; it would appear a discussion on the Ash placement facility is warranted (even if qualitative similar to the road transport section).

This information has been added to the HHRA, which is provided in Appendix E.

CDM Smith_2

Exposure pathways have not considered the deposition to waterways; the ERP plant is located in a water supply catchment for Sydney therefore consideration should be given to this pathway. The assessment should include consideration of the pathway for completeness; if the pathway is considered to be complete is should be assessed consistently with other pathways in considering the incremental and cumulative exposure risks; either in a qualitative or a quantitative manner. Under State Environmental Planning Policy (Sydney Drinking Water Catchment) 2011, proposals need to be assessed to identify potential risks to water quality; developments must have a neutral or beneficial effect (NorBE) on water quality. Consider using the HHRA for risk characterisation from emissions to air resulting in deposition in the catchment for this assessment.

This assessment has been added into the HHRA. Deposition into rainwater tanks as well as into Neubecks Creek and the larger water body at the confluence of Neubecks Creek and Coxs River has been assessed and is detailed in Section 4.7.3 of the revised HHRA report, provided in Appendix E The assessment concluded that for the surface water bodies estimated changes in concentrations of the relevant substances (primarily naturally occurring substances) will be immeasurably small. For rainwater tanks in the most affected area, risks are extremely low.

CDM Smith_3

Has the baseline characterisation of the RDF been undertaken and available for review? Refer to the procedures or waste characterisation in EIS Appendix G RDF QA &QC. More information and discussion of the RFD would be beneficial. Consider connecting the discussion in this section better with EIS Appendix G RDF QA &QC

The baseline characterisation is discussed in the response to CDM Smith_43, below. Additional information on the RDF has been added to the HHRA (refer Appendix E).

CDM Smith_4

A section on the plant shut down and non-operational phase (e.g. shut-down for maintenance, emergency shutdown) is needed. The current descriptions centre on the operational state of the plane, however a description and consideration of emissions during these different operations stages is needed, including frequency and duration and emission and odour management. We note this is also not included in the AQIA.

In accordance with clause 52 POEO (Clean Air) Regulations emission limits do not apply during start up, regardless it is important to minimise emissions during this period. Emissions profiles during start up and shut down for a similar boiler have been reviewed. Detailed discussion on this data is provided in Section 8.1.1 of the AQIA, and the HHRA now includes a summary and cross-reference to the AQIA. The updated AQIA is provided in Appendix D. In view of the above, during start-up and shutdown the emissions peaks for NOx and CO are relatively short-lived and stabilise relatively quickly and efficiently. This is a similar comment to EPA_19.

CDM Smith_5

The report states “The material burning within the boiler will be held at 850°C for at least two seconds – long enough for destruction to occur….” A reference is not provided. A discussion of the efficiency of removal organic wastes in modern plants would be useful given community perceptions around dioxin emissions.

The reference corresponds to the requirements of the NSW Energy from Waste Policy Statement which reads “The gas resulting from the process should be raised, after the last injection of combustion air, in a controlled and homogenous fashion and even under the most unfavourable conditions to a minimum temperature of 850°C for at least 2 seconds”. This is consistent with design requirements adopted within the European Union (EU Industrial Emissions Directive) where Energy from Waste, and its associated performance metrics, has been a proven technology for several decades.




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CDM Smith_6

A figure showing the boundaries for the study area for the air quality model, the Lithgow region and NSW Western local health district would improve the readability of this section. Section 3.2 and Figure 7 seem disconnected. Sensitive receptor polygons and point sources are shown on the map, but it is not clear what the difference is. Land use zones are discussed in the text however not included on the figure, so it is difficult to connect the text and figure. Suggest updating the figure to improve readability. The figure is misleading as there are 15 sensitive receptor sites shown (this figure is from the EIS) and the AQIA uses 14 receptor locations, however only some of these overlap. The rational or benefit behind the two sets is not clear. We note the figure and text are from the main EIS.

Figure updated within the AQIA provided in Appendix D. Refer also to comments made in response to CDM Smith_41 below.

CDM Smith_7

The HHRA has relied upon the findings of the AQIA, and explicitly states that ‘No independent review of the AQIA has been undertaken. Hence, this assessment has relied on the data provided directly from the Air Quality Impact Assessment Team.’ Given the comments about the AQIA, the HHRA will need to be updated. There is benefit in coordinating with the air quality team to ensure the data and conceptualisation provided to the HHRA is fit for purpose and can achieve the objectives as set out in the SEARs.

The HHRA has been updated to reflect the outcomes of the updated AQIA. A meeting has been held between the two specialisms to ensure that the two disciplines have a consistent understanding of the dispersion model outcomes and their subsequent application. The updated AQIA and HHRA reports are provided in Appendix D and Appendix E respectively.

CDM Smith_8

The AQIA model uses the 14 Discrete Receptor Locations off site, however the site itself is an industrial facility - what about adult workers at the facility itself, and the potential for exposure in their work environment? The consideration for on-site adult workers is not clear. It is recognised the gridded approach would cover this somewhat, as the maximum value of the grid is discussed. It would be informative to identify where the maximum grid values are occurring – if they are in the work space for the facility this would be useful information to inform the site management for adult workers for instance. Two receptor groups warrant closer consideration in the discussion:

■ Adult workers at the MPPS - Have workplace exposure standards been considered, or impacts to adult workers at the site?

■ Recreational users in Ben Bullen forest should be considered as this forest is used for recreational outdoor activities and would be useful in communicating to the public.

■ We note Blackmans Flat has been adopted to represent adjacent commercial / industrial land use (as used in the HHRA).

Workplace exposure is beyond the scope of the AQIA which addresses environmental exposure / impacts. Safe working conditions are required as part of the Project specification and will be further considered throughout the design process and the operational phase, in accordance with the relevant Workplace Health & Safety legislation. Workplace exposure has been evaluated during technical investigations into stack height optimisation however is not the subject of an AQIA. With regards to Ben Bullen State Forest, the grid maximum concentrations are assessed against criteria for people living at that location, which also provides a conservative estimate of risk for people undertaking recreation in the forest. Visitors to the forest will have lower exposure times than residents. This has been noted in the updated HHRA, provided in Appendix E.

CDM Smith_9.1

There is a disconnect in the problem formulation between the fuel type and the COPC in the emissions to be considered. While the HHRA refers the AQIA report, the rationale behind the choice needs to be presented to the reader of the HHRA.

Additional information has been added to the HHRA, provided in Appendix E.

CDM Smith_9.2

What about the placement of materials in the ash placement facility? the ash placement facility is discussed as a source however the emission data is only for the ERP plant appears to have been modelled. It is unclear if the data from the AQIA includes potential emissions from this second operational area (and road transport), and if so, this should be directly acknowledged in the HHRA.

The potential for dust from the Ash Placement facility has been considered qualitatively within the Air Quality Impact Assessment. The ash will be either an appropriate moisture content to minimise dust generation (quenched bottom ash) or stabilised (fly ash) prior to any disposal, and as such does not represent a significant fugitive emission source. Dust will be managed via an Operational Environmental Management Plan. This is now also discussed in the HHRA (Appendix E).

CDM Smith_9.3

Confirm the assumption for NOx to NO2 conversation as being 100%. Appendix A indicates three different conversation ratios were used depending on the NOx/NO2 ratio. The EPA comments flagged this assumption and have requested the updated AQIA to use the NOx to NO2 conversation as 100%.

The AQIA has been updated to address EPA comments with respect to NOx to NO2 conversion. 100% conversion has been adopted within the annual NO2 assessment, and, consistent with NSW EPA Approved Methods guidance, the Ozone Limiting Method has been employed for short-term assessment of NO2 impacts. The HHRA has been updated with the figures from the revised AQIA (refer Appendix E).

CDM Smith_10

The HHRA does not consider the pathway for ingestion via drinking water. This issues was flagged by the DPIE comments. Drinking water is missing from the conceptual figure.

The dispersion modelling completed within the AQIA has now provided deposition predictions to the HHRA at locations representative of water catchments. As discussed above for CDM Smith 2, this has now been added into section 4.7.3 of the updated HHRA, refer Appendix E.

CDM Smith_11

Normal operating conditions are shown. The impact from a shut-down are not discussed. As shut downs are short term events, the comparison to the annual average may not be meaningful; there is values in comparing them to the shorter acute exposure times (e.g. 1-hour and 24-hour averages).

Start-up and shut-down emission profiles are discussed within the updated AQIA and referenced in the HHRA (refer Appendix E). It is not anticipated that these events will result in routine excursions above in-stack concentration limits, as the Air Pollution Control system will remain operational throughout under both scenarios, and with reduced fuel loads within the combustion system.




Reference No.


CDM Smith_12

Table 10-13 is the only assessment of localised impacts due to criteria pollutants. These tables present the maximum criteria pollutant concentrations. The question however of whether the proposed facility will impact on human health due to localised change in criteria pollutants has not been assessed. The key question that should be resolved within the HHRA is whether on any particular day in the modelling domain the air quality is impacted to the extent that the air quality index would impact local residents. DPIE and NSW Health have established process for assessing localised air quality (air quality index). The assessment should look at each day in the modelled year and assess whether the proposed facility changes the advice to the public then the frequency and magnitude of that change can drive the risk characterisation and assessment conclusions.

The AQIA presents predictions made at ‘grid maxima’ along with at sensitive receptor locations. These grid maxima represent the highest model prediction at any point within the model domain for all hours of the year of modelling (i.e. 8,760 individual scenarios). This enables the articulation of maximum exposure at any point in time and space, regardless of the location. The locations of grid maxima can be identified through the contour plots presented within the AQIA. They are universally located within a short distance from the Project boundary, within bushland settings.

CDM Smith_13

We note local residents may rely on rainwater tanks. This pathway should be considered in the multiple pathway exposures. Consideration to the Sydney Drinking Water Catchment should also be discussed.

Deposition predictions have been made within the atmospheric dispersion modelling and have been provided to the HHRA. Section 4.7.2 of the updated HHRA (Appendix E) addresses multiple pathway exposures, with additional consideration of deposition to waters discussed in Section 4.7.3 (including rainwater tanks and the Cox’s River Catchment). The HHRA report states that adding the risks estimated for domestic use of rainwater into the multiple exposure pathway assessment makes no difference to the total risk because the estimated risks are so small.

CDM Smith_14

Changes and variation in the RDF and what that could mean for emissions and HHRA outcomes warrants discussion; as the RDF composition will vary over time, and even vary year to year, the implications in changes to emissions levels need to be discussed (e.g. relate to the performance in Scenario 1: Regulatory Case). Further, the RDF supply facility may change over time, meaning the quality and supply of the RDF may change. The implications of this to the HHRA need to be discussed (e.g. there is a quality control procedure).

The individual constituents of any waste derived fuel, including RDF, will inevitably change over time due to multiple factors including societal attitudes to recycling / waste disposal, regulatory drivers and changes to packaging across the value chain. This is evidenced at every EfW facility with a long-term data set of waste composition during its operations. Indeed, the majority of EfW facilities operate on a fuel mix that is different in some way from the nominal characteristics assumed at the design stage. However, as evidenced within the updated AQIA, modern EfW facilities are able to demonstrate a reasonably homogenous emission output while waste streams are both heterogeneous and variable over time. This is since the Air Pollution Control system within a suitably designed, modern EfW facility is able to handle a high degree of variability in input (as evidenced within the wide range of fuel constituents that a technology provider is willing to guarantee their emissions performance against). This was discussed in Section 3.2.6.1 of the EIS. In the case of this Project, the manufacturer has confirmed the emissions guarantees apply for any fuel within the design range shown in Section 2.4 of the AQIA (refer Appendix D), not just the nominal design characteristics. This, along with the QA/QC procedures which will govern the RDF production, provides adequate assurance that changes in the waste stream will not result in fuel characteristics that vary outside of the range that the Air Pollution Control systems can manage.

CDM Smith_15

This section discusses the change in traffic but does not link the discussion to changes in air quality and health in the community. There is a recognised challenge given the linear emission corridor. However, there still needs to be a stronger connection in the discussion between the increase in emissions from vehicles and associated health impacts; the second part of the discussion appears missing.

The updated AQIA addresses additional traffic movements associated with the Project qualitatively. An evaluation of the traffic report indicates that additional traffic movements may increase annual average daily traffic values by approximately 1%. Such a change is not anticipated to result in a material difference in exposure to air quality metrics at nearby residences.

CDM Smith_16

Conclusions are appropriate for the content as provided in the report; however we recognise this might change based on the updated analysis. The mitigation measures in Table 41 refer to the ERP Plant and transport, and not to the Ash placement facility. It would useful to group the mitigations measures by each source (i.e. transportation to site, ERP Plant and Ash placement facility) for clarity; and to ensure all the emission sources are captured. Additional mitigation measure around the RDF supply source, and the RDF monitoring program (and QAQC) needs to be considered. Also, there is a reference to baled form of RDF being acceptable, however in Section 5 only sealed truck transport is mentioned. We note the main EIS refers to both sealed truck and bailed forms being transported to the site. This point should be clarified.

Conclusions within the HHRA have been updated (refer Appendix E. There is no change based on the updated analysis, other than the addition of an additional mitigation action to reflect the discussion of the Ash Placement Facility. Mitigating measures and commitments relating to the RDF supply and monitoring are covered elsewhere in the EIS and have not been repeated in the HHRA.

CDM Smith_17

The Australian approach to assessing dioxins is to evaluate total body burden and to compare this to a tolerable monthly intake (HHRA reference DEH 2005). The HHRA therefore should consider all incremental sources of exposure and add up the total intake (from the operation + background). DEH 2005 provides dioxin background intakes for Australians. US EPA 2009 should not be used for calculating dioxin inhalation reference concentration as the dioxin TMI is a total body burden and not a concentration x time intake. The extrapolation of TDI to RfC does not apply to dioxins.

Additional information has been added into Appendix B of the HHRA explaining the basis for the approach taken. Essentially consideration of body burden has been incorporated into the development of the PTMI recommended for use by JECFA and NHMRC. It is noted that exposure over years is most relevant for dioxins. Consideration of such longer periods has been included in the multiple pathway assessment and in the use of annual average data for inhalation exposures. In addition, there is no difference to the maths when dividing the PTMI by 30 to get a daily intake or accumulating the estimated intake of dioxins across a month.




Reference No.


CDM Smith_18

Air Quality Impact Assessment

Chapter titles are duplicated in the heading. ‘Energy Australia’ should be one word. Noted and amended.

CDM Smith_19

This document has been prepared to support a HHRA; however there appears some disconnect between the authors of the AQIA and the HHRA in terms of alignment over their approach for delivery of the two documents.

The AQIA has been prepared for regulatory stakeholders consistent with the NSW EPA's Approved Methods for the Modelling and Assessment of Air Pollutants in NSW. Additional inputs have been prepared to support the HHRA which has been completed by a third party specialist.

CDM Smith_20

The GHD landfill design report in the EIS (Appendix L Soil and Water Report) refers to an existing Air Quality Management and Monitoring Plan (AQMMP) for Lamberts North, however this does not get references in the report. Has this data been considered?

This is similar to CDM-Smith_38. Please refer to that response.

CDM Smith_21

How is exposure in the workplace air quality considered as part of the AQIA and more broadly the EIS? Clarification of how Workplace Exposure Standards might be considered is needed.

Workplace exposure is beyond the scope of the AQIA which addresses environmental exposure / impacts. Safe working conditions are required as part of the Project specification and will be further considered throughout the design process and the operational phase, in accordance with the relevant Workplace Health & Safety legislation.

CDM Smith_22

The document title Best Available Techniques (BAT) Reference Document for Waste Incineration was updated in 2019. Please review this document and ensure the key pollutants have been correctly identified. Ozone is listed in the NEPM but not included in the list of criteria. Rationale for omitting this needs to be provided.

The document title Best Available Techniques (BAT) Reference Document for Waste Incineration, updated in 2019, is now referenced in the AQIA. Ozone is a secondary pollutant; in this instance it is anticipated that it is adequately controlled through regulation of its precursors (NOx and VOCs). There is no requirement for a photochemical assessment within the SEARs. The NSW EPA has not flagged this as a deficiency.

CDM Smith_23

The exclusion of iodine, bromine and PCB is premature to assume the potential for inclusion can be managed by the RDF QAQC program, and that they are not present in the waste stream, in particular given the waste stream is high volume and heterogeneous. It is noted Chlorine is included in the regulatory case and this has an acceptance limit in the RDF. If these contaminants are considered low risk, at a minimum they should be included in the Proof of Performance trials, where the emissions can be monitoring and pollutants can be verified with the plant in operation. The baseline RDF characterisation data has not been reviewed or presented in the AQIA. Discussion and review of this data is recommended (refer to the EIS Appendix G RDF QA &QC). There are limits in the RDF specification, however the sampling strategy of a single composite sample per month would overlook particular sources of these elements.

Statement of commitment for monitoring of iodine, Bromine and PCBs during Proof of Performance trials is now detailed in Section 4.2 of the updated AQIA (Appendix D).

CDM Smith_24

In addition, what about emerging contaminants of concern? i.e. PFAS. PFAS is mentioned as requiring further assessment in the main EIS for the Ash Management (Section 13 of the EIS) however is not considered in the AQIA. The prevalence of PFAS in municipal waste warrants this group of chemicals to be considered. Discussion of the Best Available Techniques on handling PFAS should also be included as this contaminant group is likely to draw a lot of future attention if not considered at the planning stage.

It is expected that very low (background) levels of PFAS would be present in many waste streams, and therefore also present in the RDF. It is important to note that the Project does not intend to source PFAS-containing wastes (such as wastes from contaminated sites where PFAS-containing firefighting foams have been used) and so the risk from PFAS is low. It is understood that PFAS decompose with heat, starting at temperatures above 360°C. The combustion releases pyrolysis products that are potentially harmful to health including tetrafluoroethylene (C2F4), trifluoroacetic acid (CF3COOH), hydrogen fluoride (HF) and fluorophosgene (COF2). However, combustion temperatures are above >1,000°C in the furnace with an oxidising atmosphere, therefore a complete oxidation of the above pyrolysis products can take place (with the reaction products CO2, H2O and HF). The resulting acid gases are safely recovered in the fabric filter after reaction with injected lime. Trace amounts of unreacted products would be captured in the activated carbon. The destruction of trace amounts of PFAS within a WTE plant is thus an appropriate way to handle PFAS. It is a very different proposition to combusting these substances using appropriately designed Air Pollution Control as opposed to incineration in an open, uncontrolled fire. The risk of PFAS-related air quality impacts from the Project is therefore negligible. The risk of PFAS in the APCr or bottom ash from the Project was considered in the EIS (Appendix D).

CDM Smith_25

Odour is identified as a key decision point in the assessment; however it is not apparent how odour is addressed in the AQIA, or the rationale for not including it further in the discussion. For instance, if substances listed in Table 6-1 are being used to assess or represent odour, this needs to be made clear to the reader. The SEARs specifically requests the assessment of air quality and odour, however only an assessment of air quality appears to have been provided in this assessment report. It is noted the EPA review also flags this issue.

This has been addressed in response to EPA_24 and reproduced below: The key potential source of odour from the Project will be from the RDF prior to combustion. As such odour management measures are focused on managing the RDF. The fuel bunker has been sized for four and a half days storage of the design fuel. Three tipping bays are provided on the fuel bunker to allow for multiple truck dumping and distribution of RDF along the length of the bunker. A bay for the bale opener will be also provided. Each tipping bay will be fitted with rapid opening and closing doors to contain odours. The inward opening doors will open automatically when the presence of a truck is detected by an IR-optical sensor. An interlock will be provided between the bunker crane and the tipping bay doors to prevent the doors from opening when the crane is working in the area adjacent to the doors. For these operations, the design incorporates control of potential fugitive emissions by drawing furnace air from within the bunker such that a slight negative pressure will be maintained. Further detail on the odour




Reference No.


management is detailed in Section 2.4.5 of the updated AQIA (Appendix D). On this basis, potential operational particulate, VOC and/or odour emissions from fuel bunker operations are considered negligible. The potential impact of emissions during inactive periods are anticipated to be low, due to the lack of active RDF operations, the fully sealed building with standalone ventilation system and absence of sensitive receptors in close proximity to the ERP facility. Potential emissions during these periods should be managed through consideration of operational management practices such as depletion of open fuel stocks and general housekeeping. In view of the above, and in consideration of the distance between the project and the nearest sensitive receptors, the risk of adverse odour impacts is considered minimal and therefore has not been considered further in the updated AQIA.

CDM Smith_26

For the criteria documents reviewed, why are only NSW documents referenced? What about commonwealth documents (e.g. NEPM)? Bullet point 5 refers to a summary or relevant assessment criteria in that section; check the reference.

Criteria contained within the NSW EPA Approved Methods for the Modelling and Assessment of Air Pollutants in NSW meet or exceed the Ambient Air Quality NEPM.

CDM Smith_27

The GHD landfill design report in Appendix L (Soil and Water Report) refers to an existing Air Quality Management and Monitoring Plan (AQMMP) for Lamberts North, however this does not get mentioned in this report. Also, dust from the proposed ash placement facility does not get mentioned. If the site has an existing monitoring program, a discussion of this would build confidence the site can manage dust and particulate matter and demonstrate their ability to use dust management to mitigate risk to off-site air quality. Section 3.3. of the EIS states that Stage 1 of the development will include Ash treatment facility, landfill cells, leachate management system and dust suppression system. Including this information and expanding on the ash placement would be sufficient to address this pathway in the subsequent HHRA, and to present as rationale for not including in the emission estimate for the AQIA (subject to the outcome of the point above).

The potential for dust from the Ash Placement facility has been considered qualitatively within the Air Quality Impact Assessment. The ash will be either an appropriate moisture content to minimise dust generation (quenched bottom ash) or stabilised (fly ash) prior to any disposal, and as such does not represent a significant fugitive emission source. Dust will be managed via an Operational Environmental Management Plan.

CDM Smith_28

Is the station used for the MPPS Air Quality and Management Plan for Lamberts North the same station which is located at Blackmans Flat? Or this a different station? The rationale behind reporting the max, 99th and 90th percentiles for pollutants isn’t explain, nor do these results appear to be discussed in the text. The 90th percentile is only reported for some pollutants. Given the criteria in section 7 are for the 24 hour maximum and the average annual, the benefit of these extra statistics is unclear. If only post 2014 data is being used in the assessment, why include data from 2013 and 2014 in the tables and graphs? It would be clearer to only present the data used in decision making.

Assessment has been completed in accordance with NSW EPA Approved Methods, which requires the use of maximum background combined with maximum increment(s) within a cumulative assessment. Other percentiles are provided for context only, to provide the reader with a summary of the variability in the data relative to the maxima that are referenced.

CDM Smith_29

The use of Wallerawang (which is more urbanised) may explain why the PM10 readings are so high; however there may be other causal factors and further consideration to the high regional levels and frequency and distribution across the year would be beneficial. The question raised here is ‘How does the background air quality change across the year depending on the season and weather? What impact could this have on the risk characterisation?’. The data is noted to have been adjusted for the removal of data for bushfire affected days; however more information on the data cleaning is required. For example, how have dust storms and prescribed burns been accounted for?

Refer comments at CDM Smith_28. Regional events (bushfires / dust storms) have been identified within the data sets by exception (i.e. analysis of any exceedance days against publicly available data sources / satellite imagery). Such exceedances have been removed to enable an assessment against NSW EPA requirements to demonstrate ‘no additional exceedance’ within cumulative assessments.

CDM Smith_30

It would appear only emission data during the normal operating state has been considered. What about conditions during start-up / shut down procedures and during upset conditions? This scenario has not been discussed and a comparison of emission data not provided.

This has been addressed in response to EPA_19 and CDM Smith_11.

CDM Smith_31

The regulatory case scenario is based on the hypothetical scenario of the plant meeting the emission criteria, however rationale for this choice is not clear. Given that the regulatory process requires the best available techniques be implemented for such a project, the regulatory case would be the emission data from the technology, and not regulatory limits. This comment was also flagged in the EPA comments. The rationale behind this choice needs to be made clearer. The wording in this section is confusing and could be improved. the understanding of the scenarios and what is involved was not apparent until reading Section 10, (e.g. Table 10-1), when presented to a non-technical reader could prove challenging. Connection between the two section would improve the readability of the document.

This has been addressed in response to EPA_1 and EPA_2. In addition to the regulatory case scenario, and additional ‘manufacturer’s guarantee’ scenario has been provided within the updated AQIA. This scenario demonstrates where the technology provider is able to commit to emissions performance that exceeds the requirement of the NSW (and EU) regulations. It is the expectation of the proponent that their emissions performance will be mandated within their Environmental Protection Licence referencing the manufacturer’s guarantee scenario in-stack concentration values.

CDM Smith_32

Selecting 2015 as the representative year based on the 89% would appear to favourably select lower emission standards for particular COPC compared with other years, even though there is only a few % difference between them. Given the inherent variability and heterogeneity in the input waste stream, adopting a maximum value across a select range of years would more appropriately develop the worst case scenario from the dataset, and build more confidence in the analysis.

The comments provided in CDM Smith_14 are also relevant here. The updated AQIA now shows Continuous Emissions Monitoring System (CEMS) data from the Rudersdorf reference facility, alongside the values that have been adopted for the expected case. It can be seen that the values adopted are conservative relative to this data set which spans several years of observations within the Rudersdorf stack.




Reference No.


CDM Smith_33

Wind data for the period 2014 to 2018 was considered. The calendar year for 2018 was selected as its averages were similar frequency for long term statistics in recent meteorological data. However, given project life span (25 years +) and predicted climate induced changes to weather systems, a discussion point is warranted if this year is representative of changes in weather patterns over the project life span.

The AQIA has been completed in accordance with NSW EPA Approved Methods. As such, the assessment does not provide discussion as to changes in weather patterns over the next 25 years, as this is not instructive within a conventional AQIA. Reference to a full year of hourly meteorological observations is anticipated to capture dispersion conditions representative of the location within the 8,760 discrete scenarios evaluated. This is considered adequate to characterise the worst-case dispersion characteristics that may occur within the locality, regardless of any future changes in local meteorology.

CDM Smith_34

The SEARS states the AQIA must consider ‘impacts on the development on surrounding land users and sensitive receptors’ – however not all receptors and surrounding land users appear to have been captured. Discrete receptor locations were chosen using two approaches

■ Approach 1: Cartesian grid 250m

■ Approach 2: 14 discrete reference sites The combination of the two methods appears to provide a suitable spatial coverage across the study area’; however the rationale for study area extent and grid offset for the study area would be beneficial. For the HHRA the gridded location with the maximum concentration was subsequently used. The HHRA also relies upon the 14 reference sites. The HHRA divides these discrete reference sites into two groups based on land use – residential and commercial/ industrial. However, there are other key land uses in the area which not included on this list; for example adult workers at the MPPS itself, and recreational uses in the Ben Bullen National Park. As the HHRA realises upon this setup to present its assessment, an appropriate selection of all key land uses in the study area should be considered. Further, it would be good to include this categories by land use / receptor type into Table 9-3 and consider the connection into the HHRA. The figure label for Blackmans Flat is missing. Also, it is unclear if Blackmans Flat is intended to represent a residential or a commercial / industrial land use?

The AQIA (including receptor selection) has been completed in accordance with NSW EPA Approved Methods. Presentation of grid maxima allows the reader to evaluate impacts anywhere within the modelling domain. Comments made at CDM Smith_12 are applicable here. The use of contour plots showing maximum predictions spatially is instructive to allow the reader to evaluate impacts at discrete locations within the vicinity of the project. It is highlighted that contours represent the maximum predicted concentration across the entire modelling period (8,760 hours) and do not show a ‘snap shot’ of impacts at a given point in time.

CDM Smith_35

Table 10-6 to 10-9 doesn’t report the background concentration and the reporting is different to Tables 10-1 to 10- 5. No rationale for different reporting approach is provided or discussed.

The AQIA has been completed in accordance with NSW EPA Approved Methods. Consistent with the NSW Approved Methods, several (referred to as non-criteria) pollutants do not require cumulative assessment (i.e. consideration of background concentrations). This is since these non-criteria pollutants are not considered to be prevalent in the atmosphere and as such background concentrations are typically regarded as negligible.

CDM Smith_36

Suggest rewording the statement ‘Peak SO2 concentrations are anticipated to occur on land owned by a mining company immediately adjacent to the MPPS boundary and not a sensitive receptor’. The objective for the AQIA is to consider impact to both surrounding land use and sensitive receptors. The impacts of this elevated S02 to the adjacent site are not discussed. This statements fails to consider the workplace exposure standards for such emissions at the adjacent mine site to ensure the operation of the plant can provide and maintain suitable air quality for workers at and near the plant. Further, no consideration or discussion to the workplace air quality for the MPPS site itself is discussed, despite the modelling results identifying the highest concentrations can occur within and adjacent to the facility boundary. Adult workers at the site are an important receptor group and don’t appear to be given consideration in this AQIA.

This has been addressed in response to EPA_10. Assessment of workplace exposure is beyond the scope of the AQIA. Note that workplace AQ standards are typically less stringent than environmental exposure standards, often by an order of magnitude or more. This is since environmental criteria are designed to be protective of all of society (the young, frail, elderly, etc) as opposed to the working population.

CDM Smith_37

Odour is not mentioned in the conclusions; the SEARs specifically refers to ‘air quality and odour’, however the conclusions are focused on air quality only. Any mention of the word ‘odour’ drops out after Section 6 of the AQIA, with no further discussion or consideration (either qualitative or quantitative).

This has been addressed in response to EPA_25.

CDM Smith_38

The GHD landfill design report in the EIS (Appendix L Soil and Water Report) refers to an existing Air Quality Management and Monitoring Plan (AQMMP) for Lamberts North, however this does not get references in the report. A more effective mitigation measure would be to utilise and update the existing monitoring program.

The Project will operate under its own management and monitoring plans, separate to MPPS, however interfaces and interactions will be noted as relevant within respective management and monitoring programs. The Air Quality Management and Monitoring Plan (AQMMP) for Lamberts North will be considered during the preparation of the ERP Operational Environmental management plan (inclusive of air quality management for the Ash Placement Facility).

CDM Smith_39

The maximum grid concentration is referred to throughout the AQIA and forms a significant discussion point in the HHRA. However, from the figures provided it is not clear where the maximum location is on the map, or if and how that location changes by pollutant. It would be beneficial to include this location on all figures. Figures include a criterion value, however the guidelines or reference to the criterion is not included. This could be addressed by a reference to the appropriate table in the report. Where a criteria exceedance occurs, the same colour as the project site boundary is used (red); consider using different a colour.

Isopleth figures allow the reader to locate the grid maxima for the averaging period / pollutant in question.

CDM Smith_40

Main EIS Review: Criteria

What about workplace exposure standards for workers at the site? Where is consideration to workplace air quality in the broader EIS?

Workplace exposure is beyond the scope of the AQIA which addresses environmental exposure / impacts. Safe working conditions are required as part of the Project specification and will be further considered throughout the design process and the operational phase, in accordance with the relevant Workplace Health & Safety legislation.




Reference No.


CDM Smith_41

Main EIS Review: Project Locality

Sensitive receptors in Table 6-2 and Figure F6-1 do not align with the sensitive receptors in the AQIA and is potentially confusing. The HHRA document includes both sets of receptors, but only uses one of them.

Table 6-2 and Figure 6-1 of the EIS detail the location of the nearest sensitive receptors to the Project, being the location of dwellings nearest to the Project site and that are not owned by the proponents. These were identified as being representative of the closest residential dwelling receptors to the Project and were considered in the context of impact assessment for relevant technical assessments (for example the NVIA). Further, Figure 6-1 details the proximity of nearby residential and rural residential areas relative to the Project site, thereby providing context to the location of the Project to these areas and other locality features. As detailed in Section 10.2 of the EIS (which presents a summary of the AQIA), and Section 9.8 of the AQIA (refer revised AQIA, Appendix D of this RTS) the air quality model presented within the AQIA sets out a grid across the region of the Project, enabling air pollutant predictions at each point on the grid. In addition to the grid, 14 locality receptors were also included as a convenient basis for reviewing model results at location of specific interest, including localities such as Blackmans Flat, Springvale, Lidsdale, Angus Place, Marrangaroo, Wallerawang, Portland, Lithgow etc. These represent localities rather than specific residential receptors and have been included for the purposes of understanding the results of the AQIA on these localities. The use of both receptor types within the HHRA were in the context of: ■ Identifying the location of the nearest representative residential dwelling receptors; and ■ Using the outcomes of the AQIA modelling as technical inputs into the HHRA model.

CDM Smith_42

Main EIS Review: Operational Wastes

Characterisation of the ash stream for PFAS is noted and recommended. PFAS may be present at low concentration in the RFD, and this information should be used to inform environmental monitoring programs.

The Ash Management Study – Ash Characterisation and Assumptions Handbook (WSP, 2019) (provided in Appendix D of the EIS) discusses PFAS and the EPA’s ‘Addendum to the Waste Classification Guidelines (2014) Part 1: classifying waste’ (EPA, 2016) in response to the classification of per- and poly- fluoroalkyl substances (PFAS) as emerging contaminants. The Ash Management Study (WSP, 2019) notes that whilst PFAS analysis has not been included for reference plants to date: ■ the Project should achieve the EPA’s Addendum interim test values for specific contaminant

concentration (SSC) and leachable concentration using the toxicity leaching procedure (TCLP) for the most common PFAS compounds; and

■ only residual PFAS is likely to be encountered within the ash. The Ash Management Study recommends that PFAS analysis is undertaken during plant commissioning to confirm this assumption. This analysis will be undertaken during commissioning as recommended.

CDM Smith_43

Main EIS Review: RDF QA/QC Procedure

The procedure defines a standard approach for ensuring that RDF supplied to the Project meets the specified fuel requirements and relevant statutory regulations and policies including the NSW EfW policy. The sample plan indicates 20 composite samples are to be collected and analysed to assess the baseline for the project – however the results for this baseline assessment were not identified in the EIS. This information would reduce uncertainty in the HHRA. If there is a major change in the waste management policy in NSW that would result in the existing baseline assessment of the composition to become non-representative, should there be a trigger to establish a new baseline dataset and direction on who makes this decision? (e.g. plastic recycling import ban from China). changes in the waste composition have implications for the application of the HHRA.

The QA/QC Procedure provided in Appendix G of the EIS defines the standard approach to ensuring that RDF supplied to the Project meets the specified fuel requirements and relevant statutory regulations and policies including the NSW Energy from Waste Policy Statement. With respect to baseline sampling of the RDF, this will be undertaken as part of the RDF supply contracts prior to the commencement of RDF supply and has not been undertaken as part of the EIS. The processes and requirements of such testing is defined in the QA / QC procedure (Appendix G of the EIS). After the baseline assessment, the ongoing routine sampling should be sufficient to determine if there was a major change in the RDF due to an upstream change in the waste stream. It is not desirable to include a specific trigger to establish a new baseline as this would be very subjective (what is a “major change” in waste management policy? What if the change takes a significant time to percolate through the economy, such as a single use plastic ban? etc). Further information relating to 3rd party supply contract is provided in Appendix S of this RTS in response to EPA comments. This includes further discussion on aggregation of fuel input to meet design range requirements and front-end treatment processes to reduce metals content.

Table 4-9: DPIE Water and Natural Resources Access Regulator Submission Response (Submission ID: 124308) Reference No. Theme Submission Response

DPIE_W&NRAR Groundwater Access Licence

Should the project be required to dewater greater than 3ML/y of groundwater, then a Water Access Licence must be obtained.

Noted.




Table 4-10: Transport for NSW Submission Response (Submission ID: 124211) Reference No.


TFNSW_1 Traffic and Transport

No delivery of Refuse Derived Fuel (RDF) to the site during local school bus pick up and drop off times is permitted. Consultation was undertaken with TfNSW on 1 May 2020 to clarify the geographic context of this requirement. TfNSW confirm that the geographic context would be along the Castlereagh Highway taking into consideration the school bus pickup/drop off times for the schools within the Ben Bullen, Lidsdale, Lithgow area that would coincide with the haulage route. Evidence of this consultation is included in Appendix C.

TFNSW_2 The size of heavy vehicles delivering RDF to the site is required to be limited to 19m heavy vehicles Consultation was undertaken with TfNSW on 1 May 2020 to discuss implications of nominating 19m vehicles, particularly in the context of RDF is sourced from local or western sources where such limits may not apply, if rail transport becomes available, or if heavy vehicle restrictions otherwise change during the life of the Project. Following these discussions TfNSW agreed to the following ‘The size of heavy vehicles delivering RDF to the site will be limited to 19m heavy vehicles, unless otherwise approved by the Planning Secretary and Transport for NSW.’ Formal correspondence from TfNSW relating to this change is provided in Appendix C.

TFNSW_3 The maximum number of heavy vehicle movements is restricted to the site is 48 heavy vehicle a day during operation and 46 heavy vehicle movements during the construction period as set out within the Traffic Impact Assessment

Following review of Table 4.4 in the Traffic Impact Assessment (Appendix M of the EIS), a typographical-error was found which incorrectly stated that there will be maximum of 46 heavy vehicle movements during the construction period. Following review of the construction vehicle numbers, the maximum daily vehicle volumes should have been reported as 52 trucks per day (not 46). This has been corrected in the updated TIA attached in Appendix K. This does not change the outcomes of the TIA.

TFNSW_4 The primary haulage route is required to be the M4, Great Western Highway, Castlereagh Highway and Boulder Road. This is required to be the primary route as it identified as a heavy vehicle route and can accommodate the proposed 19m (B-double) heavy vehicles.

Noted.

TFNSW_5 Cover all heavy vehicle loads of refuse and other materials along the haulage route to the site and from the site.

Noted. The RDF will be sealed for transport, either packed in enclosed box trailers or as individually plastic wrapped bales, providing no opportunity for the escape of litter or odour.

TFNSW_6 No transportation of refuse materials on local roads in the Lithgow Local Government Area is to occur without prior consent from Lithgow City Council.

Noted. Relevant requirements will be incorporated into the Traffic Management Plan and Driver Code of Conduct.

TFNSW_7 Avoid using exhaust brakes, engine compression or 'jake' brakes near residential areas and noise-sensitive areas,

TFNSW_8 Comply with the Protection of the Environment Operations (Noise Control) Regulation 2017, Noted.

TFNSW_9 Ash and contaminated materials classified as hazardous or dangerous goods are to be transported to and from the site in accordance with the Protection of the Environment Operations (Waste) Regulations 2014,

Noted.

TFNSW_10 Transport for NSW requires the preparation of a Traffic Management Plan (TMP) and Driver Code of Conduct to satisfaction of Transport for NSW and Lithgow City Council prior to the commencement of works. The Traffic Management Plan (TMP) and Driver Code of Conduct to outline measures to manage traffic related issues associated with all phases of the development (e.g. deliveries, construction, operation, maintenance, decommissioning), any construction or excavated materials, machinery and personnel involved. The TMP is to detail the potential impacts associated with the development, the measures to be implemented, and the procedures to monitor and ensure compliance. The TMP is to address (but not be limited to): ■ Specific commitments for the provision and use of buses and car-pooling during construction to limit peak hourly

traffic in accordance with the approved Environmental Impact Statement (EIS) and conditions of consent. Plans and measures to manage the impacts of personal vehicle parking at pickup points (e.g. in towns) are to be detailed.

■ An enforceable policy for staff and contractors to use the designated commuter route in preference to back roads, where the journey is not unreasonably lengthened, as detailed in the approved EIS.

■ Details of origin, destination, quantity, size and frequency of vehicle movements associated with the development including those accessing and egressing the site.

■ Timings and staging of construction and operation of the development. ■ Existing and projected background traffic, peak hour volumes and types and their interaction with projected

development related traffic. ■ Loads, weights, lengths and number of movements of haulage and construction related vehicles including Over

Size Over Mass (OSOM) loads. ■ The management and coordination of construction and staff vehicle movements to the site and measures to limit

disruption to other motorists, including special OSOM management measures. ■ Scheduling of haulage vehicle movements to occur outside of daily commuter peak periods, local special event

times, school bus (both in rural and town areas) and school zone operating hours.

It is agreed that the preparation of a TMP and Driver Code of Conduct will be inclusive of all requirements outlined in TFNSW_10, noting engagement with TfNSW on 1 May 2020 whereby TfNSW clarified the geographic context to haulage vehicles restrictions was limited to along the Castlereagh Highway.




Reference No.


■ Active communication procedures for traffic such as school buses or haulage vehicles from other quarries, or near potential safety hazards.

■ Provide the haulage route for the transportation of hazardous waste to a licensed facility, ■ Scheduling of heavy vehicle movements to minimise convoy or platoon lengths. ■ Consideration to minimise the route length for road transport, particularly for OSOM loads. ■ Any OSOM will be the subject of separate permits through the National Heavy Vehicle Regulator. ■ The number of OSOM that will be required during the 32 month construction period, ■ Mitigation of local climate conditions that may affect road safety for vehicles used during construction, operation

and decommissioning of the facility (e.g. scheduling during daylight hours, or outside of fog, wet weather, ice or snow).

■ Transport of hazardous materials in accordance with the relevant transport codes. ■ Specific mitigation measures along the approved transport routes. Road and intersection improvement works are

to be completed prior to the commencement of on-site construction unless specifically approved otherwise in the conditions of consent.

■ Consultation and engagement with affected stakeholders, including regulatory authorities, landowners, businesses, bus operators and so forth.

■ Policies and procedures for addressing concerns raised by the community on project related matters. ■ Dust suppression and mitigation measures on public roads and within the site boundaries. ■ Toolbox meetings to facilitate continuous improvement initiatives and incident awareness. ■ Truckloads are to be covered at all times when being transported, to minimise dust and loss of material onto

roads which may form a traffic hazard. ■ Measures to ensure responsible fatigue management and discourage driving under the influence of alcohol

and/or drugs, dangers of mobile phone use and driving to the conditions, and adherence to posted speed limits.

Table 4-11: Lithgow City Council Submission Response (Submission ID: 121866 and 124006) Reference No. Theme Submission Response

LCC_1 N/A Council considered the matter at its Ordinary Meeting 24 February 2020. Following debate and consideration of amendments, which were lost, Council has no position on the matter at this time.

Noted.

* Lithgow City Council submitted two responses (one letter, one online lodgement), noting that Council did not have a position on the matter.

Table 4-12: Blue Mountains City Council Submission Response (Submission ID: 121816) Reference No.


BMCC_1 AQ impacts from Trucks

Council are in objection to the addition of between 52 and 96 additional truck movements per day to the Great Western Highway. This will contribute to NOx, SOx, CO and PM pollutions causing heath implications for those residents living along the highway.

The worst-case traffic scenario estimates 96 truck movements per day (5 days per week), resulting in localised diesel vehicle emissions with the air quality metrics of interest being NOx, CO, PM2.5, SOx and VOCs. These additional emission sources are anticipated to be negligible in view of the location with respect to the Great Western Highway. The additional truck movements associated with the Project results in a 1% increase of vehicles per day. Such a small change in vehicle numbers is anticipated to make a non-discernible difference in local air quality. Furthermore, not only are some of the closest residential residences situated in much closer proximity to the Great Western Highway, but the Great Western Highway is also located between the Project and the majority of these receptors.

BMCC_2 Noise and amenity impacts from trucks

The Blue Mountains is a world heritage area that is renowned for its natural beauty, wildlife and is valued by locals for its peace and tranquillity. The additional road traffic will cause negative implications to the amenity of the Blue Mountains particularly through significant increases to noise levels. This is compounded as the majority of transportation will occur during day time when the local attractions are primarily utilised.

The NVIA (refer updated assessment, Appendix P) assessed the impacts of road traffic associated with Project operations at the nearest residential receptors near the Castlereagh Highway. Based on the outcomes of the assessment, the introduction of Project operational road traffic is predicted to increase daytime noise levels by up to 0.6 dBA, and increase night-time noise levels by up to 0.3 dBA. Impacts on the Great Western Highway will be lower than those predicted on the Castlereagh Highway, as the existing road traffic environment of the Great Western Highway has much higher traffic volumes. As outlined in the Table 3.6 of the NVIA report, traffic surveys show that average daily traffic volumes on the Castlereagh Highway are 3,332 vehicles (with 11% Heavy Vehicles). Average daily traffic volumes on the Great Western Highway are 16,504 vehicles (with 19% Heavy Vehicles). This means that Project related traffic will have a smaller influence to traffic noise.




Reference No.


It is noted that differences in noise levels of less than approximately 2 dBA are generally imperceptible in practice and an increase of 2 dBA is hardly perceivable, if at all. Differences in noise levels are not considered substantial until around 5 dBA. The worst-case predicted noise level change identified in the NVIA are well below this 2 dBA perceptibility threshold. The introduction of the Project’s operational traffic is therefore unlikely to be perceptible, if at all.

BMCC_3 Any reduction to amenity may also have a detrimental effect on our economy through lost tourism. A Supplementary Social Impact Assessment has bene prepared and considered impacts on tourism. This is provided in Appendix I.

BMCC_4 Truck numbers The EIS is not clear around the number of truck movements during construction phase and its implications. Specifically Month 15, the report states that a maximum of 28 trucks per day will operate. This directly contradicts table 15-2 which show 46 trucks per day for concrete alone. This calls to question the accuracy and reliability of the transport section of the EIS.

Table 4.4 (now Table 4.5) of the TIA has been updated to correct this transcription error. The text below the table has also been updated to be consistent with the revised table. The updated TIA inclusive of this correction is provided in Appendix K of this RTS report. The correct total number of deliveries estimated for month 15, stage 2 earthworks and civil works is 52 trucks/day. The findings of the assessments do not change, with the assessment concluding that the construction truck volumes there would not be expected to impact the surrounding road network.

BMCC_5 Rail Transport Rail transport has been ruled out for the site despite the report highlighting that existing capacity exists on the rail network and that all truck movements over the GWH could be replaced with one train per day (which has capacity of 60 trucks). This option also offers fuel savings of 75%, with associated CO2e emission reductions. The negatives of rail have been unduly over stated and truck advantages over stated. One example being openly acknowledged in the detail of the EIS, is the advantage for truck movements which deliver ‘significantly shorter transit to and from Mt Piper land thus reduced cost’. The next section then goes on to concede that cycle time (transport time) for RFD is not particularly time sensitive. Further, the report does not appropriately consider the opportunity of adapting rail either via Energy Australia’s currently planned rail loop or utilising existing infrastructure for RDF transport. Instead opting to say ‘assumed 30% cost increase’, ‘considers’ and acknowledges it ‘has not been considered comparatively against the dedicated road option’. Council would like to see other transport alternatives to road be considered and analysed more accurately, in particular rail.

Lycopodium Infrastructure was engaged by EnergyAustralia and Re.Group to assess the viability of transporting RDF from Western Sydney to the MPPS by alternate modes of transport including rail haulage (refer Appendix B of the updated TIA, located within Appendix K of this RTS report) (Lycopodium Infrastructure, 2019). While the assessment found several advantages of rail haulage for the Project, a comparative assessment of road and rail transport options of RDF to the Project Site identified a number of disadvantages associated with the rail option, including: ■ significant cost increase given the requirement to bale and containerise the RDF; ■ road shuttles at the origin and destination points; ■ cycle time being significantly longer for rail; and ■ not being economically viable to operate a dedicated rail service, thereby being reliant on an existing

3rd party rail service to Bathurst. These findings mean the rail transport option could be unavailable if that existing service was discontinued, and also that rail transport would still require road transport to shuttle containers between the Bathurst terminal and the site, meaning that local traffic impacts could not be avoided. As such, the rail option presents multiple disadvantages without providing a significant environmental benefit. The assessment also considered the approved but not constructed Pipers Flat coal rail unloader and rail loop. The assessment determined that the coal unloader, conveyors and transfers would be designed and sized specifically to suit the material properties of thermal coal and not compatible with RDF handling requirements. The volume of RDF to be transported is not sufficient for a dedicated rail service to be established even if the coal unloader was modified to be able to receive and unload the RDF. Given the information presented in the EIS, more detailed analysis is unlikely to add additional benefit to the assessment of the Project.

BMCC_6 Circular Economy

Council is concerned that Energy Recovery can lead to the creation of a market mechanism that incentivises energy recovery over waste minimisation or recycling. This is currently playing out in some European markets. This presents a real risk in NSW given the lack of clear policy direction, long term strategic planning around recycling facilities, waste processing, energy recovery and waste disposal in NSW. These risks have not been identified and should be with mitigation measures.

The Project’s commitment to and operation under the NSW waste hierarchy is further discussed in Appendix V. This includes discussion on the differences between the NSW and European markets and regulatory settings.



RESPONSES TO COMMUNITY SUBMISSIONS

5. RESPONSES TO COMMUNITY SUBMISSIONS

Table 5-1 – Submissions response to community submissions Theme Subtheme Comment Response

Air Quality and Odour

Odours from RDF

Several public submissions raised concern about odours being possibly emitted from waste, including while in transit. One submission also raised that Portland has an existing odour issue which could be exacerbated by the Project.

As discussed in Section 3.2.4.1 of the EIS and Section 2.4.5 of the updated AQIA (refer Appendix D): ■ RDF is to be transported via fully sealed RDF bulk trailers. Where RDF is transported in baled form, these bales will be strapped and fully wrapped before being delivered

on curtain-sided (or ‘taut-liner’) trucks. As such, during transport, all waste will be fully sealed by baling and/or in sealed trucks. ■ The unloading of RDF will occur in a fully enclosed building, subject to negative air pressure in order to minimise escape of odour. ■ The truck bay doors will be automatic, with fast opening to allow entrance and exit of trucks. They will be closed whilst the truck is inside. ■ During normal plant operation combustion air will be sucked out of the bunker and fed to the furnace of the ERP. ■ During planned shutdown of the power plant for preventive works and/or repair of equipment, fuel reception will be interrupted and the combustion air system will be shut

down. In order to maintain a negative pressure in the RDF bunker, air will be extracted by a standalone exhaust ventilation system with filters installed on the roof of the bunker.

■ Bottom ash and air pollution control residues (APCr) do not have a major contribution to odour nuisance. While bottom ash could be stored almost anywhere outside without concern, the design of the plant includes an enclosed hopper for the bottom ash prior to loading trucks. The APCr are hygroscopic (i.e. the residues absorb water from the air) and need, prior to their stabilisation, to be protected from ambient conditions (by storing in a silo). However, even if exposed to air the APCr and bottom ash would not contribute to major odour nuisance.

In summary, management and mitigation measures associated with RDF to minimise potential for odour emissions include: ■ Delivery of RDF in enclosed vehicles. ■ Fully enclosed RDF bunker and tipping hall within the building, with fast acting roller doors on the RDF tipping bays. Doors will be closed when not in use. ■ Provision of an odour abatement system (inlet dust filters and carbon filtration system) to control odours during shutdown or breakdown. ■ Implementation of Operating Procedures and Waste Management and Handling Procedure for major planned maintenance activities, to ensure that waste is not loaded

into the RDF bunker while the plant is not operating. The Project will therefore not have a material contribution to odour nuisance in the immediate locality and thus will also not impact from an odour perspective more broadly on other areas including Portland and surrounding areas. Further detail on odour abatement is provided the Air Quality Impact Assessment (refer Appendix D).

Impact of emissions geographically and air emissions exceedances

Many public submissions raised concern about emissions polluting Lithgow, the Blue Mountains, and the Sydney Basin, including drinking catchments. In particular, submissions raised concern about the impacts caused by ash, emissions, chemical and organic compounds, and airshed contamination.

The AQIA considered potential air quality impacts associated with the construction and operation of the Project. The AQIA assessed a range of pollutant concentrations (refer Section 4.2 of the AQIA) across a 24 km by 24 km modelling domain (see Figure 9.6 of the Air Quality Impact Assessment, Appendix D). This area includes part of the Blue Mountains and the townships of Cullen Bullen, Portland, Angus Place, Springvale, Lidsdale, Wallerawang, Marrangaroo, Meadow Flat, Mount Lambie, Rydal, Bowenfels, Lithgow, Litton and any drinking water catchments within the model domain. On the basis of the analysis undertaken, the proposed level of emission control, and the use of continuous emission monitoring systems (CEMS) during operation, the potential for the Project to result in adverse air quality impacts is considered minor. The impact of emissions from the Project in areas further afield, such as the Sydney basin will be negligible due to the dispersion across such long distances. The updated AQIA is provided in Appendix D. Further analysis of the Project’s impact on the Sydney drinking water catchment is discussed in the updated Human Health Risk Assessment which is provided in Appendix E. The HHRA concluded that there will be no measurable impact on water quality within the catchment.

Submissions raised concerns regarding the identified exceedances of sulphur dioxide as stated in the AQIA.

The AQIA included a review of the existing ambient air quality recorded at two separate air quality monitoring stations. This review indicated that sulfur dioxide (SO2) concentrations were within ambient criteria since 2015, with a single exceedance of the 1 hour average criterion reported at Wallerawang in 2014. These data were then added to the atmospheric dispersion model predictions for SO2 impacts from both the ERP and the currently operating MPPS to provide a conservative estimation of cumulative impacts (i.e. combining contributions from all potential sources). This was then compared against EPA impact assessment criteria. The short term regulatory case (Scenario 1a) shows that there would potentially be up to nine hours during the modelled period (8,760 hours) where the maximum 1-hour SO2 concentrations are predicted to be above the impact assessment criterion of 570 µg/m3. This is also the case for the short term manufacturer’s guarantee case (Scenario 3a) as the adopted emission limits and MPPS emission were the same for both scenarios. For the expected case (Scenario 2) there are four hours per year where an exceedance is predicted to occur. It is important to highlight in this analysis the contribution of MPPS across all three scenarios, for all scenarios that the contribution of the ERP Project accounts for less than 0.01% of the total cumulative ground level concentration. The exceedances are also not as a result of high background concentrations, but rather the potential contribution from the currently operating MPPS. Finally, the fact that such predicted exceedances are not shown in the ambient air quality monitoring data is indicative that this assessment approach is conservative. This is discussed further in the AQIA provided in Appendix D.

Temperature inversions and air quality impact modelling

Several public submissions sought the phenomena of ‘temperature inversions’ to be investigated in additional air quality impact modelling.

The Air Quality Impact Assessment has used the NSW EPA-endorsed CALPUFF dispersion model to predict ground level concentrations of pollutants. CALPUFF is a dispersion model that can simulate the effects of time and three dimensional meteorological and accounts for wind shear, coastal interaction effects and temperature inversions. Analysis on the local meteorology is provided in Section 9.2 of the Air Quality Impact Assessment (Appendix D). A review of five years of meteorological data was completed as part of the AQIA and it was determined that 2018 would be a suitable and representative year for dispersion modelling. The modelling file for 2018 accounted for 8,760 hour of the year (100% complete) and therefore includes the full range of meteorological conditions, including temperature inversions, that occurred in 2018.




Theme Subtheme Comment Response

Stack height considerations

Public submissions raised concern about the proposed stack height and sought additional air quality impact modelling.

The AQIA modelling considers the stack height in its assessment. The modelling with the AQIA indicates that the height of the stack (70m) provides for sufficient dispersion such that all air quality metrics assessed in the air quality impact assessment emitted from the proposed ERP are compliant with the relevant NSW impact assessment criterion at that height. The AQIA is provided in Appendix D.

Air quality monitoring and management recommendations relating to the Project

Several public submissions made recommendations for additional monitoring and management measures which involve air quality. Recommendations included real-time monitoring of emissions, pollution abatement measures, and quantitative analysis of failure scenarios regarding the flue gas filter bag system.

The Project will undertake Continuous Emissions Monitoring System (CEMS) in accordance with the NSW EPA Energy from Waste Policy Statement (EPA, 2015) in conjunction with the Best Available Techniques Conclusions (BATC) for Waste Incineration. Monitoring data for the Project will be provided in accordance with the requirements of the EPA’s EfW Policy. This will include provision of monitoring data to the NSW EPA in real time format and provision of a weekly summary of continuous monitoring data and compliance with emissions limits published on the Project’s website. Further, provision of monitoring data will also meet the requirements of the EPL to be issued for the Project. With respect to failure scenarios, the technology provider’s scenario analysis considered potential failure modes, with a filter bag failure identified as an upset condition of interest. Noting this, the use of automated filter bag breakage detection in conjunction with remotely isolatable baghouse modules identified such events as likely to be short term (in the order of minutes), with minor elevation of emissions (e.g. concentrations double that of the standard, albeit on a shorter time frame). Air emissions abatement measures are described in detail in Section 3.2 of the Air Quality Impact Assessment (refer Appendix D).

Air quality monitoring and management recommendations relating to EnergyAustralia

One public submission demonstrated distrust that EnergyAustralia can adequately manage the emissions produced by the Project.

The Project will be built and operated by a Joint Venture arrangement between EnergyAustralia and Re.Group, as detailed in Section 1.3.3 of the EIS. The Project, if approved, will be subject to a range of conditions of consent as well as the requirements of an EPL which is also required to be sought and obtained prior to commencement of construction. As is standard for state significant developments, and as committed to by the Project in Chapter 25 of the EIS, as amended in Chapter 6 of the RTS, these requirements will include preparation of construction and operational environmental management plans and monitoring programs which will be required to be prepared in consultation with relevant regulators and to the satisfaction of the Secretary of DPIE. The EPL will also stipulate a range of emission limits and monitoring requirements that the Project will be legally bound to comply with and report compliance against. As discussed above there will also be a requirement that emissions data is made public on a regular basis.

Persistent Organic Pollutants (POPs) and contravention of the Stockholm Convention

Several public submissions raised concern that the Project will be a contravention of the Stockholm Convention.

The updated AQIA has considered Persistent Organic Pollutants (POPs) and the Stockholm Convention (refer Appendix D). The Stockholm Convention, which was adopted in 2001 and entered into force in 2004, requires its parties to take measures to eliminate or reduce the release of POPs into the environment. Australia, as well as all European nations, the United Kingdom, the United States and Japan are signatories to the convention (energy from waste (EfW)is common practice in all of these countries). The POPs of greatest relevance to EfW facilities are dioxins and furans. Dioxins and furans represent a group of substances that share chemical similarities and vary in degree of toxicity. Dioxins and furans are an unintentional by product formed and released from incomplete combustion processes or chemical reactions involving organic matter and chlorine. Among the industrial sources that can potentially release these chemicals are uncontrolled waste combustion, production of pulp and metallurgical industries. The Project demonstrates compliance with the provisions of the Stockholm Convention since it positively impacts on the dioxin pollution from waste management, and it was designed to ensure the use of best available techniques and best environmental practices. The Project also promotes dioxin abatement through the use of improved methods for flue gas cleaning, precipitation and adsorption of volatile pollutants and solid particles. Finally, the technology to be implemented in the Project ensures compliance with the EU emissions requirement of 0.1 ng/Nm3 for dioxins and furans, moreover that the concentration of dioxin in the residue is below the threshold for “low POP content”.

Human Health

Health risks to the local community

Many public submissions raised concern about the potential health risks associated with air emissions, including as a result of increased truck movements. Some submissions in particular raised concern that these emissions will accumulate in the food chain, while others raised that the Lithgow community are subject to high levels of respiratory and cardiovascular diseases.

RDF will be transported to the site via semi-trailer or B-double trucks. Worst case deliveries (based on 22 tonne payload on semi-trailers) will consist of 48 trucks per day (5 days per week), or 2 trucks per hour. Typical / ‘design’ conditions (based on 32 tonne payload on 19m B-doubles) will consist of 22 trucks per day (6 days per week), or around 1 truck per hour. In the context of the existing road network, this frequency is considered low, with negligible additional air quality impacts expected within local roads and the Project site. This is discussed within the updated AQIA within Appendix D. The HHRA considers potential impact to human health, and includes multiple pathway analysis, including food chain considerations. The assessment concluded there are no chronic risks of concern from exposure to pollutants from the facility via soil or ingestion of home grown produce and no acute or chronic inhalation exposure risks of concern. The updated HHRA assessment is provided in Appendix E.

Greenhouse Gas

Definition of the Project as ‘Clean Energy’

Several public submissions either questioned or opposed that the Project is a ‘clean energy project’ as a result of the Project producing emissions.

The classification of a technology as renewable (i.e. “green”) is not made by the proponents. It is a determination made by the Australian Government, consistent with Australia’s obligations under international agreements on climate change. This definition of renewable energy in Australia is governed by the Renewable Energy (Electricity) Act 2000 and the Renewable Energy (Electricity) Regulations 2001. The Act defines “biomass based components of municipal solid waste” as one of 19 permitted renewable energy sources. The Regulation defines this further as: biomass based components of municipal solid waste means the biomass based components of wastes that are directly sourced from, or eligible to be disposed of in, landfill or a waste transfer station that is licensed by a State or Territory government body or by a local government authority, but does not include biomass based components of wastes originating from: a. forestry or broadacre land clearing for agriculture, silviculture and horticulture operations; or b. fossil fuels.





c. biomass means organic matter other than fossilised biomass. Examples of biomass in the RDF include woody organics, paper, cardboard and some textiles. The Project proponents have estimated the biomass component of the RDF as providing 1/3 of the energy content, based on these definitions and the explanatory information provided by the Clean Energy Regulator. The methodology for calculating the renewable energy will be reviewed by the Clean Energy Regulator when the Project applies for Large-Scale Generation Credits (LGCs). There are currently 13 power stations accredited to produce renewable energy in Australia that have “biomass based components of municipal solid waste” as one of their registered fuel sources. The Greenhouse gas assessment assessed the Scope 1, 2 and 3 emissions associated with operation of the Project, adopting an emission estimation protocol typical of a National Greenhouse and Energy Reporting (NGER) annual emission estimation exercise. There are inherent GHG benefits associated with EfW projects, such as the ERP, that should be quantified and taken into consideration when assessing GHG emissions, and specifically include: ■ Substitution of (higher emission intensity) grid electricity - the quantity of GHG emissions diverted from the NSW electricity grid were calculated over a 25 year period

would potentially eliminate over 4.7Mt CO2-e. ■ Avoidance of landfilling - by removing biomass waste from the landfill, emissions of methane from the decomposition of waste are eliminated. The GHG emissions as a

result of diversion from landfill is estimated as 121,990 tonnes CO2-e / annum, assuming 50% of the methane produced is flared, as is common practice from landfill projects (refer revised GHG calculations provided in Appendix W.

When viewed holistically, there is a net benefit (i.e. reduction) in GHG emissions compared to the status quo through implementation of the Project.

Greenhouse Gas Emissions

Public submissions raised concern that the Project will be a major emitter of greenhouse gas emissions, including emissions produced by the truck haulage of the waste inputs. A submission claimed that waste to energy incinerators emit more greenhouse gas emissions per unit of energy than coal, oil, and gas.

Haulage of the waste inputs was accounted for in the Scope 3 emissions (Section 5.6 of the Greenhouse Gas Assessment. Emissions intensity of electricity generation is expressed as the rate of emissions (tonnes or kg of CO2-e) per net unit of electricity produced (MWh or kWh). The estimated emissions intensity for the proposed Project is 0.55 t CO2-e/MWh generated (value includes Scope 3 emissions from haulage, but excludes the GHG benefits discussed above). This emissions intensity may vary depending on the operating load at Mt Piper into which the steam from the Project is fed. As noted in Table 5‑5, the emissions intensity for the NSW grid is estimated to be 0.81 t CO2-e/MWh. On this basis, the Project’s emissions intensity is significantly less than the NSW grid, and greater again when compared with black coal fuelled power stations, such as MPPS. The GHG assessment is provided in Appendix J of the EIS. An additional technical memo regarding GHG emission estimation is included as Appendix W.

Traffic

Impacts of RDF road haulage

A number of public submissions raised concern about additional truck movements along the Great Western Highway, Bells Line of Road, and other roads, citing traffic, reduced safety, noise pollution, air pollution, odours, road network damage, and reduced tourism opportunities as the causes of concern.

Additional truck movements, traffic and safety: A Traffic Impact Assessment (TIA) was incorporated in the EIS, an updated version of which is provided in Appendix K of this RTS. As detailed in the TIA, the primary haulage route for the transport of RDF from Western Sydney to the Project site is on the M4 Motorway, Great Western Highway and Castlereagh Highway. As classified state roads, the function of these roads is to facilitate long distance, high volume traffic flows in an efficient manner from Sydney to western NSW. During the operational phase, the Project is estimated to generate 48 trucks (i.e. 96 truck movements) on a daily basis in the worst case scenario. The equates to no more than: ■ a 0.2% increase in daily vehicle movements along the M4 Motorway near Parramatta and Homebush, ■ a 1% increase in daily vehicle movements along the Great Western Highway near Hartley and Mt Victoria; and ■ a 2.9% increase in daily vehicle movements along the Castlereagh Highway. Under typical conditions it is expected to generate between 26 and 33 trucks per day, which

is an increase of 1.6 – 2.0% in vehicle flows on the Castlereagh Highway. This is considered to have a minor impact on the road network capacity.

Air quality and odour: The worst case 96 truck movements per day (5 days per week) will result in localised diesel vehicle emissions with the air quality metrics of interest being NOx, CO, PM2.5, SOx and VOCs. These additional emission sources are anticipated to be negligible in view of the location with respect to the Great Western Highway as the additional truck movements associated with the Project results in a 1% increase in vehicle flows per day near Hartley and Mt Victoria and a 2.9% increase in vehicle flows on Castlereagh Highway. Such a small change in vehicle numbers is anticipated to make a non-discernible difference in local air quality. The updated AQIA is provided in Appendix D. As detailed in the EIS and AQIA, the RDF will be sealed for transport, either packed in enclosed box trailers or as individually plastic wrapped bales, providing no opportunity for the escape of litter or odour. The RDF will be unloaded in an enclosed building subject to negative air pressure to further minimise the potential for odour.

Noise: The NVIA (refer updated assessment, Appendix P) assessed the impacts of road traffic associated with Project operations at the nearest residential receptors near the Castlereagh Highway. Based on the outcomes of the assessment, the introduction of Project operational road traffic is predicted to increase daytime noise levels by up to 0.6 dBA, and increase night-time noise levels by up to 0.3 dBA. Impacts on the Great Western Highway will be lower than those predicted on the Castlereagh Highway, as the existing road traffic environment of the Great Western Highway has much higher traffic volumes. As outlined in the Table 3.6 of the NVIA report, traffic surveys show that average daily traffic volumes on the Castlereagh Highway are 3,332 vehicles (with 11% Heavy Vehicles). Average daily traffic volumes on the Great Western Highway are 16,504 vehicles (with 19% Heavy Vehicles). This means that Project related traffic will have a smaller influence to traffic noise.





It is noted that differences in noise levels of less than approximately 2 dBA are generally imperceptible in practice and an increase of 2 dBA is hardly perceivable, if at all. Differences in noise levels are not considered substantial until around 5 dBA. The worst-case predicted noise level change identified in the NVIA are well below this 2 dBA perceptibility threshold. The introduction of the Project’s operational traffic is therefore unlikely to be perceptible, if at all.

Rail as alternative to road haulage

Several public submissions sought railway as an alternative to road haulage of waste inputs in order to reduce emissions and transport costs. Some submissions suggested that a rail unloading facility and a coal unloader should be constructed at the Project site. Another noted that there is an opportunity to haul waste using coal trains.

Lycopodium Infrastructure was engaged by EnergyAustralia and Re.Group to assess the viability of transporting RDF from Western Sydney to the MPPS by alternate modes of transport including rail haulage (refer Appendix B of the updated TIA, located within Appendix K of this RTS report) (Lycopodium Infrastructure, 2019). While the assessment found several advantages of rail haulage for the Project, a comparative assessment of road and rail transport options of RDF to the Project Site identified a number of disadvantages associated with the rail option, including: ■ significant cost increase given the requirement to bale and containerise the RDF; ■ road shuttles at the origin and destination points; ■ cycle time being significantly longer for rail; and ■ not being economically viable to operate a dedicated rail service, thereby being reliant on an existing 3rd party rail service to Bathurst. These findings mean the rail transport option could be unavailable if that existing service was discontinued, and also that rail transport would still require road transport to shuttle containers between the Bathurst terminal and the site, meaning that local traffic impacts could not be avoided. As such, the rail option presents multiple disadvantages without providing a significant environmental benefit. The assessment also considered the approved but not constructed Pipers Flat coal rail unloader and rail loop. The assessment determined that the coal unloader, conveyors and transfers would be designed and sized specifically to suit the material properties of thermal coal and not compatible with RDF handling requirements. The volume of RDF to be transported is not sufficient for a dedicated rail service to be established even if the coal unloader was modified to be able to receive and unload the RDF.

Waste Inputs

Concerns about RDF as a Fuel Source

Several public submissions raised concern of the environmental and health impacts of using RDF as a fuel source, while others sought clarification of its composition and how it will be managed. For example, a submission sought clarification of what fraction of the RDF will be classified as ‘miscellaneous waste’ and ‘other’, what prohibited wastes are included, such as hazardous waste and e-waste, and what percentage of miscellaneous waste may also include prohibited waste. Another submission sought clarification as to how hazardous and electrical waste will be removed from the feedstock.

RDF is a solid fuel engineered from unrecyclable waste that is currently disposed to landfill, like certain plastics, paper and textiles. RDF has roughly two-thirds the heat content of black coal. RDF is commonly used in EfW technologies and processes in the European Union and United States. The Plant is designed to utilise RDF which is recovered by processing Municipal Solid Waste (MSW) and commercial and industrial (C&I) wastes that would otherwise be disposed to landfill. For design purposes, it is assumed that 50% of the RDF will be sourced from MSW, and 50% sourced from suitable types of C&I waste. The typical constituents of RDF are detailed in Table 4.5 of the EIS. A photograph of RDF is provided in Photograph 9 of the EIS. In descriptive terms, RDF contains a large percentage of energy dense materials which do not have a route for recycling in Australia. These include film plastic (e.g. plastic bags), some hard plastics, textiles and timber, dirty cardboard and paper, and vegetation or food. The remainder of the RDF is non-target materials that cannot be separated due to efficiencies of sorting processes, including inert materials such as rocks, items made of mixed materials, and fine materials including dirt and fine organics. These non-target materials are typically less than 15% of the RDF composition. The following materials are not acceptable within the RDF: ■ Hazardous waste (as defined in the EPA’s waste classification guidelines); ■ Explosives; ■ Radioactive material; ■ Liquid waste and sludge; ■ Salts and chemical industry wastes; ■ Non shredded bulky waste; ■ Slaughter house waste and animal carcasses, animal flours and animal fat; ■ Medical waste; ■ Larger charges of inert material (eg stones, concrete, sand glass, metal); ■ Larger charges of automotive recycling residues; and ■ Larger charges of electrical waste. A draft Quality Assurance and Control Procedure for the receipt and use of RDF for the Project has been prepared (refer Appendix G of the EIS). All RDF suppliers will be required to comply with the QA/QC procedure. All RDF received by the Project will be pre-processed through processing facilities located at the source of the RDF which is likely to be Western Sydney, but may also be at other locations in NSW. The processing facilities are not the subject of this application. RDF production will come from the residual material after the recovery of recyclables and the separation of organic material for biological processing, if applicable. RDF will be a residual material after all practical steps have been taken to extract other valuable materials, in accordance with the waste hierarchy. A simplified sorting flowsheet was included in Figure 4-2 of the EIS and is reproduced below which details the process of RDF sorting. Further discussion on possible technologies and techniques for RDF production is provided in Appendix S





Figure 5-1 RDF Sorting Flowchart (EIS)

Impacts on recycling and the waste hierarchy

Public submissions raised that the RDF should be re-used and/or recycled instead of incinerated. Causal effects which were cited in the submissions included people producing more waste, reduction in materials which are recycled, and less community pressure on the packaging industry to produce less plastic waste.

The Project is committed to the NSW waste hierarchy which aims to encourage the most efficient use of resources and to reduce environmental harm. The hierarchy specifically identifies “recover energy” as an appropriate means of managing waste from which reuse and recycling opportunities have already been exhausted. This is waste which otherwise would go to landfill. RDF contains a large percentage of energy dense materials that is unrecyclable and is currently disposed to landfill in Australia. These include film plastic (e.g. plastic bags), some hard plastics, textiles and timber, or material that would be compostable or recyclable but is dirty or otherwise unsuitable for higher uses. The production of RDF will come from the residual material after the recovery of recyclables and the separation of organic material for biological processing, if applicable. Therefore, RDF will be a residual material after all practical steps have been taken to extract other valuable materials, in accordance with the NSW waste hierarchy. The Project will therefore not influence reduction, reuse and recycling efforts. Suppliers of RDF to the Project will be required to comply with the draft QA/QC Procedure provided in Appendix G of the EIS. Further consideration of how the Project aligns with the NSW Government’s a state-wide 20-Year Waste Strategy which is currently being prepared, including the Cleaning up Our Act: The Future for Waste and Resource Recovery in NSW Issues Paper released in March 2020 which is informing the strategy development, is detailed in Appendix V of the RTS.

Accepting RDF from Sydney/Other Regions

Several public submissions raised concern about accepting RDF from Sydney and other regions, and wanted to see more accountability and responsibility for regions to appropriately manage their own waste; or opportunities to use waste sourced from the Central Tablelands / Mid West region, such as Lithgow, Bathurst, Oberon and Mudgee.

A report was commissioned from Ricardo on the sources and suitability of waste for RDF titled Mount Piper RDF Feedstock Report, an update of which is attached as Appendix F of the RTS. The report identified in excess of 1,335,000 tonnes per annum of RDF could be manufactured under current policy requirements and within an economic transport catchment of the Project. This analysis includes 470,000 tonnes per annum of MSW and at least 865,000 tonnes per annum of C&I waste, which is currently being disposed to landfill and that would be suitable for making into RDF, from the markets in Sydney, the Hunter and the Illawarra. Re.Group will manage supply of RDF to the Project and RDF may be supplied from Re.Group owned facilities, or from other suppliers contracted to the Project. During the 20+ year life of the Project, the source of RDF may change, however the quality assurance and control processes will be imposed on each facility supplying RDF to the Project. These processes will include verification that each fuel preparation facility has the appropriate development approval and environment protection licences, and meets the resource recovery criteria defined in Table 1 of the EfW Policy. Ricardo notes that several major C&I resource recovery facilities were proposed and have been granted funding through the NSW Government’s Waste Less Recycle More (WLRM) program, including three very large C&I processing facilities proposed for Western Sydney (Veolia, Dial-a-Dump and Resource Co). The WLRM funded facilities have a total of 1.6 million tonnes per annum of throughput capacity. In addition, Ricardo notes a number of existing AWT facilities that are processing MSW in order to maximise the recovery of recyclable items. All of these existing facilities could potentially be modified to include RDF production capability as an add-on to the existing focus of maximising the recovery of materials prior to directing non-recyclable residuals to energy recovery. In addition to existing facilities that are already operational or approved to operate, Ricardo notes the opportunity to develop new facilities that could be readily designed to meet the RDF specification of the Project, while also maximising the recovery of material in accordance with the waste hierarchy adopted by the NSW EPA. While these new facilities would be subject to separate approvals processes and are not part of the SSD application, there is significant international precedent for the establishment of facilities purpose designed to make RDF to a defined specification. The location of these facilities will be driven by market and developer conditions. As part of the Project’s developer contributions, a Letter of Offer has been signed between the proponents and Lithgow City Council which describes the in principle agreement to the form that a future Voluntary Planning Agreement for the Project. The concept of the agreement is for the proponents, in lieu of developer contributions, to provide planning support and equipment to process the Lithgow LGA community’s waste into RDF, so that material currently disposed to landfill can be recovered and used to generate power. This will facilitate the use of locally derived waste as RDF that would otherwise go to landfill.





Ash Management

Ash management and environmental impacts

Several public submissions raised concern about bottom ash being buried in landfill, while other submissions raised concerns of fly ash causing negative environmental and health impacts (e.g. accumulating in the food chain, affecting water supply). Some submissions offered recommendations as to how the ash should be managed, for example, how it should be disposed of as intractable waste, or how it should be recycled.

Waste classification, treatment and disposal in NSW is subject to compliance with relevant EPA guidelines and requirements. The EIS considered the different treatment and disposal options for the ash generated by the Project including bottom ash, fly ash and Air Pollution Control Residues (APCr) in accordance with relevant guidance. This involved the waste being pre-classified using the process outlined in NSW EPA (2014) Waste Classification Guidelines Part 1: Classifying Waste by WSP (refer Appendix D of the EIS). The outcomes of the WSP (2019) waste classification exercise are discussed in Section 13.3 of the EIS, and include:

■ Based on the available information from the Reference Plant, WSP (2019) determined that the Bottom Ash waste stream produced by Project would likely be classified as “General Solid Waste” (GSW) under the NSW EPA guidelines;

■ The Fly Ash and APCr were classified separately by WSP (2019) and as a result the two ash types were classified under different classifications. Based on the available information from the Reference Plant, WSP (2019) determined that the Fly Ash from the Project would likely be classified as “Restricted Solid Waste” (RSW) under the NSW Waste Classification Guidelines based on lead concentrations exceeding RSW thresholds. However, the APCr would likely be classified as “Hazardous Waste” based on lead concentration (in particular leachability) exceeding Hazardous Waste Thresholds. Given that the Fly Ash and the APCr will be combined at the ERP, the two ash types require a single classification as a combined stream. The combined waste stream will be likely to attract the higher waste classification of “Hazardous Waste”. Due to the classification as Hazardous Waste, the material will require immobilisation prior to disposal as per the Waste Guidelines. Immobilisation of the waste will produce an ash product which has the characteristics enabling disposal as Restricted Solid Waste.

The Ash Placement Facility will incorporate cells for General Solid Waste and Restricted Solid Waste, and will be designed and constructed in general accordance with the NSW EPA (2016b) Solid Waste Landfill Guidelines. The Solid Waste Landfill Guidelines provide guidance on the design requirements for GSW and Restricted Solid Waste (RSW) cell linings to ensure appropriate protection of the underlying substrata is maintained based on the type of material which will be emplaced in the cell. The Project is not expected to result in any impact to groundwater at either the Plant or the Ash Placement Facility. Groundwater is present at depths well below the maximum depth of disturbance for the project and hence is not expected to be disturbed. At the Ash Placement Area, the containment cells will be double lined with a specialised system which has been designed in accordance with NSW EPA Solid Waste Landfill Guidelines. The system separates leachate which may be generated by the containment cell from the underlying strata and facilitates removal to above ground storage tanks. The cell lining includes both a primary and secondary containment layer as a contingency in unlikely event that the primary layer is breached. There will be an ability to monitor the presence of leachate both above the primary and the secondary liners and leachate present will be removed in order to prevent the build-up of hydrostatic pressure. As discussed in Section 5.6.1 of the EIS, an Ash Options Report was prepared by WSP (2017) to assess reuse, treatment and disposal options for the waste ash streams. That assessment found that reuse of bottom ash is relatively common in Europe where, after treatment, bottom ash aggregates are produced for use in civil works including landfill construction, and road and embankment construction. The report concluded that there is a great deal of uncertainty around the reuse of EfW ash in Australia, given that the technology is currently little used. Over time, as regulatory authorities and end users become more familiar with the characteristics of the materials, and the treatment technologies, then end use markets for treated ash may develop. Consideration has been given to reuse of the ash from this Project and this will remain an objective of the Project. However, the EIS does not consider reuse of this ash as base case and provision has been made for onsite disposal as stated above. The Project will continue to evaluate reuse options for that ash, and if proven viable, the bottom ash will potentially be re-used to produce construction material as occurs elsewhere in the world. A Commitment has been made to the management and mitigation measures outlined on Chapter 6 of the RTS, committing to a review of bottom ash reuse options to be undertaken on a 5-year cycle, and will consider the legal, regulatory, and market conditions as well as the suitability of the ash for various uses.

Water

Water Quality Impacts to Cox's River / Sydney Drinking Water Catchment

Many public submissions raised concern that emissions from the Project will contaminate Cox’s River and the Sydney Drinking Water Catchment. A submission noted that the Cox’s River currently has the highest salinity levels of all catchments in the Sydney Drinking Water Catchment, and that the Mount Piper Ash Emplacement area is leaching into the groundwater. Another submission suggested that a pipeline and pumping station be installed to direct all ground water from the site in times of high rainfall into Hunts Creek, as well as a wetland and filtration plant.

A Human Health Risk Assessment was completed and included in the EIS (updated HHRA is provided in Appendix E of the RTS). Deposition into rainwater tanks as well as into Neubecks Creek and the larger water body at the confluence of Neubecks Creek and Coxs River has been assessed and is detailed in Section 4.7.3 of the revised HHRA report, provided in Appendix E The assessment concluded that for the surface water bodies estimated changes in concentrations of the relevant substances (primarily naturally occurring substances) will be immeasurably small. The Project is not expected to result in any impact to groundwater at either the Plant or the Ash Placement Facility. Groundwater is present at depths well below the maximum depth of disturbance for the project and hence is not expected to be disturbed. At the Plant Area, all operations will be undertaken above ground on sealed areas. Any leachate generated at this stage would be recirculated into the boilers and vaporised. At the Ash Placement Area, the containment cells will be double lined with a specialised system which has been designed in accordance with NSW EPA Solid Waste Landfill Guidelines. The system separates leachate which may be generated by the containment cell from the underlying strata and facilitates removal to above ground storage tanks. The cell lining includes both a primary and secondary containment layer as a contingency in unlikely event that the primary layer is breached. There will be an ability to monitor the presence of leachate both above the primary and the secondary liners and leachate present will be removed in order to prevent the build-up of hydrostatic pressure. To monitor the ongoing condition of groundwater, a groundwater monitoring network will be installed down gradient of both the Plant and the Ash Placement Facility. The requirement for monitoring of groundwater will be formalised both in the site OEMP and EPL and will include (at minimum) monthly sampling for the first 12 months of operation and then quarterly (every 3 months) thereafter. The results undergo assessment against specified criteria, with the outcomes reported annually. In the event of any pollution event arising from the Project, the appropriate notifications will be made to the NSW EPA under the POEO Act. Further details on the groundwater monitoring program and groundwater impact mitigations are presented in Appendix C of the EIS. Consideration of the environmental compliance of the existing MPPS ash emplacement area is outside of scope of the EIS.





Noise

Operational noise impacts

A public submission raised concern that the operational noise emitted the Project will further exacerbate their physical and mental health which has suffered as a result of the operational noise emitted from Springvale Coal Services. A submission also cited that temperature inversions increases noise impacts.

Based on the findings of the operational noise assessment, all predicted Leq, 15minute (dBA) noise levels for existing and proposed operations are below the Project Noise trigger Levels (PNTLs) at all the identified residential receptors and are compliant with the NPI, 2017 for all assessment periods. All necessary mitigation measures documented in the NVIA are considered suitable to the magnitude and extent of the predicted impacts. They are designed to reduce noise levels and minimise impacts as far as is commonly feasible and reasonable to do so and practical to implement. It should also be noted that modifying factors (penalties) for annoying noise characteristics such as tonality and low frequency components etc. were considered as per the requirements of NPI, 2017. Based on the noise source data presented in this assessment and model outputs, penalties were not necessary and have not been applied to the results in this assessment. Noise modelling has also incorporated both standard meteorological conditions and noise-enhancing meteorological conditions as per requirements of the NSW Noise Policy for Industry (NPI, 2017). Noise enhancing meteorological conditions considered for the assessment include daytime and evening Pasquill–Gifford stability Category D conditions, light source-to-receiver winds (3 m/s) and a night-time stability Category F (temperature inversion) condition, light source-to-receiver winds (2 m/s).

Noise modelling

A public submission raised concern that Project will emit higher levels of noise as modelled in Noise and Vibration Impact Assessment.

Noise modelling undertaken as part of the NVIA has been conducted with due regard to and in accordance with the relevant standards, government guidelines and policies required to effectively calculate/predict propagation of noise. A consolidated set of recommendations has been established for the Project operations, as presented in Section 7.2 of the NVIA report. They are designed to minimise impacts as far as is commonly feasible and reasonable to do so and are structured to address the following key features: Safeguards: recommendations that ensure any changes to the proposed Project operations and associated activities/equipment are properly addressed and additional measures considered if they are required. Provisions for monitoring: recommendations for monitoring to occur in response to certain triggers, e.g. a noise complaint, so that operational noise emissions can be measured; compared to criteria and evaluated to confirm if the existing mitigation and management measures are sufficient, and if not what else can occur to reduce noise and minimise impacts. The Project will be subject to strict noise limits based on the outcomes and results of modelling and it is expected that noise compliance monitoring will be required under the Project’s Environmental Protection Licence.

Noise monitoring

A public submission raised that noise receptors should be in operation throughout the lifecycle of the project, as well 24/7 real time noise monitoring.

The EPL for the site will contain noise limits that the Project will need to comply with during operations. Compliance with these noise limits will be demonstrated via noise compliance monitoring at nearby receptors in accordance with the EPL requirements. The details (e.g. type / frequency) of monitoring required will be determined by the NSW government consent authority and will be outlined in the EPL.

Noise from truck movements for residents along the waste haulage route

Several public submissions raised concern about noise from truck movements for residents along the RDF haulage route

For road traffic noise, the BK Predictor 7810 (Version 12.00) software package was used but adopting the UK Calculation of Road Traffic Noise CoRTN calculative methods, as adapted to Australia conditions. A line source was utilised with vehicle flows and mixes input directly into the noise model. Based on the input traffic flows and mixes, this allowed for the calculation of noise levels at various receptor distances to quantify A-weighted decibels in the applicable Leq, 15hour Leq, 9 hour and Leq,1 hour parameters. The introduction of Project operational road traffic is predicted to increase daytime noise levels by up to 0.6 dBA, and increase night-time noise levels by up to 0.3 dBA. As outlined in the NSW Road Noise Policy (RNP, 2011), differences in noise levels of less than approximately 2 dBA are generally imperceptible in practice and an increase of 2 dBA is hardly perceivable, if at all.

Socio-economic

Impacts to local economy

Many public submissions raised concerns about impacts to the local economy, including loss of tourism, loss of local coal mining projects, decline in employment in the recycling sector, and reputational loss which will deter people from moving to the area, in particular the ‘tree-changers’. Several submissions also noted that a main attraction and opportunity for Lithgow is eco-tourism which the Project will undermine.

A Supplementary Social Impact Statement (SSIA) has been prepared and is attached as Appendix I to this RTS. It recognises the concerns raised about potential impacts on the attractiveness of the area for tourism visitation, and on residential amenity. It concludes that due to a range of characteristics the Project is unlikely to have actual impacts. These include: ■ The Project is located within the site of a major industrial complex, the MPPS. It will present as a small part of that complex ■ The Project has very limited visibility from locations outside the site ■ Residential and tourism and recreational locations are generally distant from the site ■ Increased traffic caused by the Project is relatively small compared to existing traffic flows However, it also recognised that, irrespective of the actual impacts there is concern that a waste project may generate a “stigma” which impacts the locality. This is addressed in the SSIA and additional mitigation measures are proposed. The Project will have no impact on coal mining in the area as MPPS will continue to require coal for its operations No loss of employment in the locality is anticipated due to the Project. It is expected to create employment as discussed in the EIS.

Social and lifestyle impacts

A few public submissions raised concern that the Project will have negative social and lifestyle impacts, including displacement as some community members do not want live within a vicinity to the Project. Another submission claimed that socially and economically disadvantaged community members will be most impacted.

The SSIA attached at Appendix I considers some of these issues, notably impacts on tourism attractiveness and residential amenity. Given the Project characteristics listed in the prior response above, the Project is not considered to have actual impacts that will harm these important values in either the immediate locality or the wider area. In terms of impacts on the disadvantaged in the community, the Project will create a range of employment opportunities which might benefit this segment, and no undue impact burdens are anticipated to be placed on them.





Property devaluation

A few public submissions raised concerns about property devaluation within the vicinity of the Project. A submission sought that EnergyAustralia purchase surrounding properties so willing residents could relocate.

Property devaluation can occur when properties are noticeably impacted by a project (ie through continuous noise impacts, or unsightly developments). Some may argue that stigma of an unwanted project could also impact on values, even without actual impacts. In this case the Project is located inside the site of and adjacent to a large industrial structure and process (MPPS) which has been operating for 25 years and will continue for many years. The Project itself will have virtually no noticeable impacts above those from MPPS. The issue of a stigma is discussed in the SSIA in Appendix I and it suggested that if this Project is publicly presented as an addition to MPPS, then little if any stigma is likely. As such the Project is not anticipated to have any impacts on property values in the surrounding area.

Financial subsidies

Several public submissions opposed the Project receiving financial subsidies from the Government, as they do not deem it to be a ‘green energy project’.

The classification of a technology as renewable (i.e. “green”) is not made by the proponents. It is a determination made by the Australian Government, consistent with Australia’s obligations under international agreements on climate change. This definition of renewable energy in Australia is governed by the Renewable Energy (Electricity) Act 2000 and the Renewable Energy (Electricity) Regulations 2001, as described above in the “Greenhouse Gas” theme. Government subsidies are a matter for the relevant government agencies and do not form part of the planning approval and environmental impact assessment process under the Environmental Planning and Assessment Act.

Hazards and Risk

Fire risk

A few public submissions raised concern about the risk of fire and explosion relating to the Project. Some commented that they believed that stockpiles of waste will pose a fire risk, others raised that accidents at the Project site may result in fire and explosions. Other submissions included that the Project may contribute to bushfire risk, and that the Project is located in the vicinity of a high risk fire prone area.

A Preliminary Hazard Assessment (PHA) was prepared to support the EIS (Appendix P of the EIS). The assessment found that there are only two process incidents (RDF bunker fire/explosion and ash fire), and that safeguards have been built into the design to minimise the severity of the incidents. None of the identified incidents have an impact outside the MPPS boundary and in fact, most of them have no impact outside the Project site. The PHA concluded that the Project does not pose a risk to the operations of the existing MPPS and that the proposed Project satisfies the qualitative risk criteria of Hazardous Indstry Planning Advisory Paper No.4, Risk Critria for Land Use Safety Planning (HIPAP No.4). A separate assessment of bush fire impacts (Chapter 22 of the EIS) considered the likelihood of a bush fire impacting the Project or spreading from the Project to surrounding properties. It noted that the Plant is not located on bushfire prone land and that the Ash Placement Facility is located within the bush fire buffer zone. It concluded that the site of the Plant is already a maintained landscape and constitutes a low bush fire hazard. The vegetation hazard that will most significantly influence bush fire behaviour are the large vegetated areas located over 100 m upslope to the west of the Plant site and the application of bush fire protection measures have been recommended as detailed in Section 22.4 of the EIS. The likelihood of a damaging bush fire impacting the Ash Placement Facility is considered low due to the ash having no combustible properties (based on the assumption that it has all been burnt out) and the area does not include any infrastructure requiring asset protection zones.

Engagement

Engagement process by proponent and regulatory requirements

Several public submissions raised issue with the planning and engagement process. While one submission raised that numerous concerns had not been adequately addressed at information sessions, another expressed concern that the Minister of Planning and Public Spaces had not directed that a public hearing be held to discuss the Project. Other submissions included criticisms of the democracy and transparency of the process.

As detailed in Chapter 8 of the EIS, and as updated in Chapter 2 of the RTS, Community and stakeholder engagement has been an integral component of the EIS preparation. As part of the refinement process for the Project and preparation of the EIS, consultation has been, and continues to be, undertaken with a range of stakeholders including various local and NSW Government agencies, the local community, special interest groups and neighbouring landholders. A range of engagement tools were deployed to engage with and seek input from the various stakeholders, including face to face meetings, presentations, site visits, newsletters / fact sheets, various community information sessions / drop in sessions, open day, website, community perception survey, feedback forms, emails and phone calls, and direct enquires and media engagement. Section 8.5 of the EIS details the key issues raised by stakeholders, provides a response to how the issues were addressed, and refers to the relevant section of the EIS where these issues where addressed. In accordance with the requirements of the Environmental Planning and Assessment Act 1979, stakeholders were also afforded the opportunity to review and make a submission on the EIS during the public exhibition period. The calling of a public hearing regarding the Project is a matter for the Minister under the relevant provisions of the Environmental Planning and Assessment Act 1979.

Alternative Options

Clean / green energy investment and diversification

Several public submissions expressed a preference for clean and green energy investment and diversification, with some noting that the Lithgow area is undergoing a transition from fossil fuel energy production to clean and green energy.

The Project will support MPPS to generate 30 MW of electricity at design conditions using the same amount of coal. The steam generated by the Project converts to approximately 240,000 megawatt hours of electricity per year (MWh/yr), of which 80,000 MWh/yr can be classed as renewable energy. The Project provides an alternate reliable, dispatchable, and partially renewable fuel source, helping to improve the efficiency of the NSW energy production and diversifying the fuel supply to MPPS to help secure its long-term future. There are also inherent GHG benefits associated with the ERP, including the quantity of GHG emissions diverted from the NSW electricity grid as a result of the Project were calculated over a 25 year period would potentially eliminate over 4.7Mt CO2-e, and divert from landfill an estimated 121,990 tonnes CO2-e / annum, thereby demonstrating a net benefit (i.e. reduction) in GHG emissions compared to the status quo through implementation of the Project. Further, the project is small in size and integrated with MPPS. As such, the Project does not prevent investment into other energy technologies, whether they are located in the Lithgow area or elsewhere in NSW.

Efficiency of ERP

A few public submissions criticised that the ERP is an ‘inefficient’ method of generating power.

RDF is a solid fuel engineered from unrecyclable waste that is currently disposed to landfill, like certain plastics, paper and textiles. RDF has roughly two-thirds the heat content of black coal. It is true that the efficiency of RDF boilers tends to be low compared to large coal-fired power stations, due to the lower heat content of the fuel and the efficiency gains that come with larger boilers and turbines. However, the ERP is superior to many other energy from waste proposals in that the integration with MPPS allows the more efficient conversion of steam into electricity, despite the small size of the Project. Further, when considered from a GHG point of view, the Project substitutes for the requirement for a more GHG intensive method of energy generation. Most of the electricity in the NSW grid currently originates from coal fired generation which has a high GHG intensity, whereas electricity generated on steam produced by the Project has a much lower (Scope 1-3) GHG intensity of 0.55 t CO2-e/MWh, being approximately 30% less than the current average for the NSW grid. In addition, the Project diverts waste away from disposal to a landfill, a significant source of methane, which is a significant GHG. Over a 25 year period, the Project would eliminate over 4.7 Mt CO2-e with these savings realised from substitution of grid electricity and landfill avoidance.





The Project will allow for the generation of an additional 30 MW electricity while using the same amount of coal, and provide co-benefits of reduced GHG generation, improved resource efficiency. and landfill avoidance. These combined benefits should be considered, rather than any single comparison figure.

Recommendations for waste management without waste to energy

Several public submissions provided recommendations for waste management without waste to energy. A reoccurring comment was that the waste inputs should be instead reduced, reused, and recycled, with some specifically referencing the ‘circular economy’ concept, and the NSW Waste Hierarchy. Additional public submission wanted to see the creation of a new industry in Australia which make products from recyclables, and more community education around recycling.

The Project is committed to the NSW waste hierarchy which aims to encourage the most efficient use of resources and to reduce environmental harm. The hierarchy specifically identifies “recover energy” as an appropriate means of managing waste from which reuse and recycling opportunities have already been exhausted. This is waste which otherwise would go to landfill. RDF contains a large percentage of energy dense materials that is unrecyclable and is currently disposed to landfill in Australia. These include film plastic (e.g. plastic bags), some hard plastics, textiles and timber, or material that would be compostable or recyclable but is dirty or otherwise unsuitable for higher uses. The production of RDF will come from the residual material after the recovery of recyclables and the separation of organic material for biological processing, if applicable. Therefore, RDF will be a residual material after all practical steps have been taken to extract other valuable materials, in accordance with the NSW waste hierarchy. The NSW Government is currently developing a state-wide 20-Year Waste Strategy which once completed, will frame a clear policy direction and long term strategic planning for all parts of the waste and resource recovery system in NSW, being waste avoidance, collection, sorting, processing, recycling and disposal. In March 2020, DPIE prepared Cleaning up Our Act: The Future for Waste and Resource Recovery in NSW, an Issues Paper to help shape the development of the 20-Year Waste Strategy which notes that ……’energy from waste facilities to provide an option for treating residual waste’. This is further discussed in Appendix V of the RTS report.

Use of coal as a fuel source

A public submission raised that an alternative fuel source is not needed as the Mount Piper Power Station already has strict controls on its emissions and is powered by a supply of “local clean coal”

MPPS is a key part of the NSW energy supply, as discussed in Chapter 2 of the EIS, and is expected to operate for a further 20+ years. The Project provides an additional reliable, dispatchable, and partially renewable fuel source, helping to improve the efficiency of the NSW energy production and diversifying the fuel supply to MPPS to help secure its long-term future. As an augmentation to MPPS rather than a replacement, the Project is not expected to impact the local coal industry.

Statutory Framework

State Significant Development Classification

A few public submissions questioned the Project’s classification as a SSD. One submission claimed that the classification was given to prevent ‘thorough review’ and ‘appropriate appeal processes’.

The SSD approval pathway for the Project is defined in legislation, being State Environmental Planning Policy (State and Regional Development (2011), as discussed in Chapter 7 of the EIS. A development application and environmental impact statement has been prepared and submitted in accordance with the requirements of the Environmental Planning and Assessment Act 1979.

Federal and State Programs and Strategies

A few public submissions raised that the Project will undermine federal and state programs and strategies such as the National Waste Policy, the Waste Less, Recycle More initiative, and the NSW Recycling and Zero Waste Strategy.

The National Waste Policy: Less Waste, More Resources 2018 provides a framework for collective action by business, communities and industry to 2030 and embodies a circular economy, shifting away from ‘take, make, use and dispose’ to a more circular approach where we maintain the value of resources for as long as possible. The policy supports Australia’s engagement in the United Nations’ Sustainable Development Goal 12 on responsible consumption and production, noting the importance of the waste hierarchy in the circular economy. The Policy recognises the role of energy recovery, stating ‘the value of resources and embodied energy in waste is now recognised’. The NSW EPA’s Waste Less, Recycle More initiative is a grants program facilitating improved waste recycling and assisting in meeting the NSW Waste Avoidance and Resource Recovery Strategy 2014-2021 targets. The funding for the program is currently to 2021. Funded programs include the Local Government Waste and Resource Recovery Program, Illegal Dumping Clean Up, Prevention and Enforcement Fund, Household Problem Waste Program, Waste and Recycling Infrastructure Fund, Organics Infrastructure Fund and Program, Litter Prevention and Enforcement Fund, Business Recycling Program, Recycling Innovation Fund and Heads of Asbestos Coordination Authorities Programs. As previously noted, the Project is committed to the NSW waste hierarchy which aims to encourage the most efficient use of resources and to reduce environmental harm, which are consistent with the National Waste Policy and the desired outcomes of the Waste Less, Recycle More funding initiative. As stated above, The NSW Government is currently developing a state-wide 20-Year Waste Strategy which once completed, will frame a clear policy direction and long term strategic planning for all parts of the waste and resource recovery system in NSW, being waste avoidance, collection, sorting, processing, recycling and disposal. By complying with the legislative provisions relating to waste management in NSW under the Waste Avoidance and Resource Recovery Act 2001 (WARR Act) and the NSW EPA Energy from Waste Policy Statement, the Project will not undermine waste reduction and higher order uses promoted in other strategies and programs.





Environmental Protection Licence for the ERP and impacts on MPPS EPL

A few public submissions noted the need for a review of the environmental protection license (EPL) of EPL 13007 if the Project is approved, stating that the MPPS Unit 2 would be classified as a Group 6 emission unit as a result of the project (currently classified as Group 4). Another submission wanted a condition that the Environmental Protection Authority (EPA) or another relevant government agency do a document review and onsite tests of emissions.

The ERP will operate independently from the MPPS and has its own defined operational controls. As such it will have its own EPL that meets, and indeed often exceeds, the emission limits mandated for Group 6 industries. The two projects will operate under separate EPLs and the variation to MPPS EPL will relate solely to excising the land for the ERP from its licence and MPPS will continue to be regulated by the EPA under its own EPL requirements. The Project includes a continuous emissions monitoring system (CEMS). The EPL will stipulate emissions limits and monitoring requirements which the Project will be required to comply with and report against.



Several public submissions raised concerns about the project description and methodology. Concerns raised include that the EIS did not describe the Project as an ‘incinerator’, claims that the Project’s methodology of predictive modelling is unreliable, and that the research undertaken was biased. Other comments raised that waste to energy project such as in Western Sydney had been rejected by the Independent Planning Commission in July 2018, and in Fyshwick, ACT.

The project description present in Chapter 3 of the EIS provides a thorough and accurate description of the Project, including the various components and processes of the ERP Plant, RDF handling, the combustion and boiler process, flue gas treatment, ash handling and management, interactions with MPPS and monitoring and control systems. Incineration typically implies combustion with the primary aim of destroying waste (for example, in a clinical waste incinerator) or uncontrolled combustion with no pollution control systems (i.e. in a backyard incinerator), neither of which is the case for the ERP Project. As described in Chapter 3 of the EIS, the Project includes the thermal processing of RDF, an engineered fuel, in a specifically designed boiler to create steam, which will then be added to the existing Unit 2 turbine at MPPS to generate electricity. The system will be subject to engineering controls, in built flue gas treatment system and a continuous emissions monitoring system. The technical assessments completed as part of the EIS, including various models, have been completed in accordance with relevant regulatory requirements and guidelines set by the various government regulators. The EIS has also been prepared in accordance with the Secretary’s Environmental Assessment Requirements issued by DPIE. The Project will be assessed on its merits in accordance with the provisions of the Environmental Planning and Assessment Act 1979, as have other waste to energy projects in NSW, and similar merit based assessments in other jurisdictions in Australia

Cumulative Impacts

Cumulative Impacts Submissions raised concerns regarding cumulative emissions, reliability of modelling and use of terminology and assessment outcomes.

Chapter 24 of the EIS considered cumulative impacts assessment with the Project with other existing or proposed development in the locality. This included cumulative considerations of the Project with proximal development (existing or proposed) including: existing MPPS operations, MPPS upgrade works, the approved Pipers Flat Rail Coal Unloader, Springvale Water Treatment Plant, Angus Place Extension Project, Springvale Colliery, Western Coal Services, Wallerawang Closure Project and the Neubeck Coal Project. As discussed in Chapter 24, cumulative impacts assessments were undertaken for the following key environmental aspects for the Project: ■ air quality; ■ human health; ■ greenhouse gas; ■ traffic; ■ noise; and ■ visual. The findings of these assessments are within the specialist technical reports, and as summarised in Chapter 24 of the EIS. All technical assessments including modelling are undertaken in accordance with government policy and guidelines to ensure reliability of the assessment outcomes. In the field of impact assessment using numerical modelling (i.e. prediction using computer simulation) it is important to contextualise results in terms of their potential risk and impact. As such, it is both necessary and instructive to provide the reader with commentary as to the anticipated likelihood of a given event.



REVISED SUMMARY OF MANAGEMENT AND MITIGATION MEASURES

6. REVISED SUMMARY OF MANAGEMENT AND MITIGATION MEASURES

Environmental management and mitigation measures, including requirements to prepare and issue specific management plans, have been identified to reduce and manage potential environmental impacts arising from the Project. These commitments have been informed by the mitigation measures recommended in the specialist assessments contained in Chapters 10 to 23 of the EIS (ERM, 2019). Table 25‑1 provides a revised summary of Project commitments identified to avoid, minimise and where necessary, offset the potential environmental impacts associated with the Project

Table 6-1: Revised Summary of Management and Mitigation Measures Aspect Potential Impact Mitigation Measures General Environmental and social ■ A Construction Environmental Management Plan (CEMP) will be prepared prior to the commencement of

construction. General Environmental and social ■ An Operational Environmental Management Plan (OEMP) will be prepared prior to the commencement of

operations. Community Environmental and social ■ Establish a CCC for the Project, either standalone or combined with the existing MPPS CCC. Air Quality Pollutants

Dust emissions The CEMP will incorporate measures for the management of potential air quality impacts during the construction period, specifically, the minimisation and control of dust emissions. ■ Proof of Performance (POP) Trials will be undertaken in accordance with the EfW Policy. ■ An Air Quality Management Plan will be prepared and incorporated into the OEMP. The Air Quality

Management Plan will include: - Mitigation and management measures of potential dust generation during ash handling and

emplacement activities; and - Relevant operational procedures for the minimisation of air emissions from the Project, including

managing odour emissions during RDF delivery and handling, maintenance and monitoring of emission control performance and implementation of continuous emission monitoring systems (CEMS).

- Compliance with the EfW Policy requirements, including at least two measurements per year of heavy metals, polycyclic aromatic hydrocarbons, and chlorinated dioxins and furans. One measurement at least every three months shall be carried out for the first 12 months of operation.

Greenhouse Gases Carbon emissions Pollutants

■ The Proponent is committed to make efforts to reduce energy consumption and increase inherent energy efficiency through the ongoing design process, during construction, as well as during the operational phase.




Aspect Potential Impact Mitigation Measures Human Health Impacts

Ingestion, Inhalation and Dermal exposure to chemical substance emissions.

■ A Continuous Emissions Monitoring System will be installed to monitor stack emissions on a continuous basis during operations.

■ Pollution control/flue gas equipment monitoring will be installed in the baghouse to allow a timely response to minimise flue gas emissions.

■ Transport procedures will be implemented, including: - RDF will be transported using enclosed trucks or in wrapped baled form; - RDF will be unloaded into the building housing tipping bays and storage bunker; - an interlock between operations within the RDF storage bunker and the tipping bay doors will operate to

minimise emissions from RDF handling; and - automated doors will be installed that rapidly open and close for each tipping bay area.

Waste Construction and operational waste streams

■ A Waste Management Plan will be implemented in the CEMP and OEMP respectively, including: - Waste generated through the construction stage and site maintenance will be transported from the

Project Site and disposed of in accordance with the Waste Classification Guidelines (NSW EPA 2014b); - Oily rags and spill cleanup material will be collected in regulated waste bins and transported by a

licenced regulated waste contractor to a licenced regulated waste receiver for disposal; - Scrap metal will be stored for periodic transportation off-site to applicable recycling facilities; - Pallets will be reused where possible. Where this is not possible they will be treated as general solid

waste; - Recyclable domestic waste will be stored in dedicated recycle bins for periodic transportation off-site to

licenced facilities; - Recyclable PPE will be stored in large industrial bins for periodic transportation off-site to applicable

recycling facilities; - Collected waste from portable toilets will be transported by a licenced regulated waste contractor to a

licenced regulated waste receiver for disposal; - Green waste will be reused onsite where possible or transported to a licenced waste facility for further

management; - Spoil generated through site earthworks will be repurposed for reuse on-site; - Wastewater generated will be transported from site and disposed of in accordance with the Waste

Classification Guidelines (NSW EPA 2014b); - Oily water will be separated. The cleaned water will be collected and reused through the recovered

water system on site. Collected oil will be transferred to a bunded waste oil container and transported by a licenced regulated waste contractor to a licenced regulated waste receiver for disposal;

- Procedures for sampling and testing of ash products. - Bottom Ash (classified as General Solid Waste) will be disposed within a GSW cell in the Ash Placement

Facility; and - Assuming treated fly ash and APCr are classified as Restricted Solid Waste, this waste stream will be

disposed within a RSW cell in the Ash Placement Facility.




Aspect Potential Impact Mitigation Measures ■ A Spill Management Plan will be prepared and implemented for any accidental spills, both onsite and offsite

and incorporated into the OEMP. ■ The Project will investigate opportunities in consultation with the Lithgow City Council and Blue Mountains

City Council to process waste for local communities either through back haul opportunities (to process local waste in facilities in Sydney) and/or local processing. Appropriate planning approvals will be sought if any local solutions eventuate.

Soils and Water Erosion and sediment Surface and groundwater quality

■ A Construction Soils and Water Management Plan will be prepared in consultation with WaterNSW and incorporated into the CEMP. This will include: - Construction Erosion and Sediment Control Plan

■ An Operational Soils and Water Management Plan will be prepared in consultation with WaterNSW and incorporated into the OEMP. This will include: - Erosion and Sediment Control Plan; - Stormwater Management Plans based on MUSIC stormwater quality modelling outputs; - Leachate Management Plan.

■ Management of the Ash Placement Facility will include: - Daily monitoring of inflow rates from the secondary leachate collection system within the RSW cell; and - Installation of an alarm system that will activate when the leachate level within the RSW well rises

greater that 300 mm. ■ A Pollution Incident Response Management Plan (PIRMP) will be prepared prior to the commencement of

operations. ■ A dedicated Water Quality Monitoring Program will be developed and implemented for the Project,

including both surface and groundwater monitoring. Traffic ■ The Project will implement a Driver Code of Conduct for truck drivers which is consistent with the Respect

our Code on Blue Mountains Roads (Blue Mountains City Council). ■ A RDF Spill Management Plan will be prepared should RDF spill during a transport incident. ■ A Construction Traffic Management Plan will be prepared which will include the management of Project

related truck movements on site.




Noise and Vibration Construction noise impacts Operational noise impacts

Construction Noise ■ A Construction Noise Management Plan will be prepared as part of the CEMP. It will address:

- High impact noise generating work and activities (e.g. impact piling) if required, will be limited to the recommended standard hours (i.e. 7 AM to 6 PM Monday to Friday and 8 AM to 1 PM Saturdays), with no work on Sundays or public holidays. Any unforeseen work that is required outside the recommended standard hours will be suitably mitigated and managed with a goal of achieving Noise Management Levels (NMLs) at all residential receptors or undertaken with agreement from the appropriate consent authority and any potentially affected neighbours; and

- During the construction design, appropriate plant, equipment and/or machinery for each task will be selected, and efficient work practices adopted to minimise the total construction period and the number of noise sources from the Project. During construction works, any equipment or machinery that is identified to be generating elevated noise levels will be stopped and removed from the site if required.

■ During the works: - the Project will avoid unnecessary noise due to idling diesel engines and fast engine speeds when

equipment can be powered down and/or lower speeds are sufficient; - drivers will be instructed to travel directly to the Project Site and avoid any extended periods of engine

idling at or near residential areas, especially at night; • mobile plant, equipment and/or machinery used on the Project will be in good condition, with

particular emphasis on exhaust silencers, covers on engines and transmissions and squeaking or rattling components. Excessively noisy machines will be repaired or removed; and

• all plant, equipment and vehicles movements will be optimised in a forward direction to avoid triggering motion alarms that are typically required when these items are used in reverse. Where it is possible tonal motion alarms will be replaced with broadband “squashed duck” motion alarms.

■ If any unforeseen night works must occur, activities with the potential to generate impulsive noise will be avoided. Any impulsive or transient noise events expected to exceed the sleep disturbance criteria at residential receptors will be strictly avoided at night.

■ Noise complaints will be logged and investigated. If persistent noise complaints are received, operator attended noise validation and compliance measurements will be undertaken to measure and compare the Project noise level contributions to a) the predicted values; and b) the Noise Management Levels presented in the Noise and Vibration Impact Assessment (NVIA). All Project noise levels will be measured in the absence of any influential source not associated with the Project. If the measured Project noise levels are above the predicted noise levels or Noise Management Levels, further mitigation and/or management measures will be considered. Operational Noise Safeguards:

■ An Operational Noise Management Plan will be prepared as part of the OEMP. It will address the following: - During equipment procurement, the Project will ensure that the noise emission sources will achieve

individual sound power (Lw) values provided in Appendix D of the NVIA (refer to NVIA Appendix N of the EIS);




Aspect Potential Impact Mitigation Measures - During detailed Project design/equipment procurement, the Project will ensure that the noise emission

sources that have been modelled within buildings / enclosures are actually constructed within buildings/enclosures in order to achieve the predicted noise levels presented in Table 16-7 of the NVIA;

- Where individual LW values cannot be achieved or building/enclosure designs change, the noise impact assessment will be updated to ensure that noise modelling accurately reflects the ‘as-built’ Project design; and

- If the updated predicted Project noise levels are above the PNTLs presented in the NVIA, further mitigation and/or management measures will be considered.

■ Within the first three months of operation, noise verification and compliance monitoring will be undertaken to measure and compare the Project noise level contributions (Leq, 15 minute in dBA) to a) the predicted values, and b) the PNTLs presented in the NVIA.

■ Where noise monitoring occurs, the following points will be considered: - Noise measurements will be undertaken at the potentially most affected receptor locations identified in

the NVIA (i.e. R04, R06 and R09); and - Project noise levels will be measured in the absence of any influential source not associated with the

Project. ■ If the measured Project noise levels are above the predicted noise levels or PNTLs presented in the NVIA,

further mitigation and/or management measures will be considered: - Noise complaints will be logged and investigated. If persistent noise complaints are received, operator

attended noise validation, and compliance measurements will be undertaken to measure and compare the Project noise level contributions to a) the predicted values; and b) the PNTLs presented in the NVIA.

Biosecurity Biosecurity hazard Hazard transfer

■ Relevant biosecurity hazard management measures will include a clean-up procedure within the RDF Spill Management Plan in the instance of a truck carrying RDF material were to be involved in a crash.

■ Compliance with the requirement of any Biosecurity Permit issued for the Project Hazards and Risks ■ All components of the Project will comply with the relevant requirements of the Building Code of Australia

(National Construction Code), Australian Standards and NFPA 850-2015 Recommended Practice for Fire Protection for Electric Generating Plants and High Voltage Direct Current Converter Stations (NFPA 850 standard).

■ Further consultation will be undertaken with FRNSW during the preparation of the technical specification for the fire detection and control system of the RDF bunker building.

■ A Traffic Management Plan will be prepared for Project truck movements on site ■ In areas of high exposure to truck movements, height indicators, high visibility painting, and bollards to

protect structures will be installed.




Aspect Potential Impact Mitigation Measures Biodiversity Potential direct or indirect

impacts to any threatened species, ecological communities, or habitat features.

■ The CEMP and OEMP will include:

- a Biodiversity and Weed Management Plan during the construction and operation phases of the Project that will detail requirements for construction fencing to ensure that related impacts are contained within the work areas; and

- traffic management requirements as traffic is a source of mortality for some species, speed limits will be established to reduce risk of fauna strikes.

Heritage Disturbance to any unknown items of aboriginal or non-aboriginal heritage.

■ Chance Finds Procedure: A Chance Finds Procedure will be developed and incorporated into the Construction and OEMPs for the Project to manage finds in the event of the discovery of any non-Aboriginal or Aboriginal artefact or material during Project construction and operation.

■ Cultural Heritage Induction: Aboriginal cultural heritage inductions for construction personnel and management staff will be undertaken. The induction will be prepared by a qualified heritage consultant, and endorsed by the Bathurst Local Aboriginal Land Council (LALC).

Bush fire Bush fire hazards Bush fire mitigation measures will include:

■ Maintaining a 20m wide defendable space around the perimeter of the Plant to the following specifications:

- no trees and shrubs; and - perimeter access track and external fence can be located within the zone.

■ Where possible, the distance between any landscape trees and the Plant will be increased.

■ Construction standards and design: The following measures will be implemented during construction that takes place between 1 November and 31 March (increased fire weather) or within any declared Fire Danger Period: - Appropriate permits for work during the Fire Danger Period will be obtained, and any conditions on

permits will be adhered to; - Adherence to restrictions on Total Fire Ban or days of high fire danger; - Fire extinguishers or firefighting equipment will be carried in vehicles; - Emergency communications equipment will be carried in vehicles; - Vehicles will keep to tracks whenever possible; - Smoking will be restricted to prescribed areas; - any perimeter road will be constructed as the first stage of development; - suitable fire fighting equipment (specific requirements to be confirmed in consultation with RFS) will be

present on site with at least two personnel trained in bush fire fighting; and




Aspect Potential Impact Mitigation Measures - on days when Very High fire danger or worse is forecast, the “fires near me” app will be checked for the

occurrence of any fires likely to threaten the Project Site.

■ Appropriate access standards: Two access points are provided into the Plant site. No traffic management devices will prohibit access by emergency services vehicles.

■ Adequate water supply and pressure: Water supply will be designed to provide filling points for fire tanker units near the Plant entrance. Hydrants will be provided in accordance with AS 2419.1:2017.

■ Bush fire Emergency Response Plan: A Bush Fire Emergency Response Plan will be prepared prior to the commencement of construction for the Plant that provides the following: - control and coordination arrangements for emergency response (eg evacuation procedures, emergency

assembly areas and procedures for response to hazards); - agreed roles and responsibilities of on-site personnel (eg equipment isolation, liaison, evacuation

management); - up-to-date contact details of site personnel and any relevant off-site personnel who could provide

technical support during an emergency; - a manifest (and safety data sheets) for any battery, diesel or other dangerous goods storage/handling,

including the class identification, quantity, type (bulk or packaged) and location; - appropriate material (including absorbent, neutralisers, equipment and personal protective equipment)

for the clean-up of spills is to be provided and available on-site; - clearly states work health safety risks and procedures to be followed by fire-fighters, including personal

protective clothing; and - any other risk control measures required to be followed by fire-fighters.

■ The Bush Fire Emergency Response Plan will be prepared with consideration of Australian Standard/ISO 31000 Risk management principles and guidelines and Australian Standard 3745: Planning for emergencies in facilities and the NSW Fire Safety in Waste Facilities Guideline (Fire and Rescue NSW, 2018).

■ The existing MPPS Bush Fire Management Plan (2018) will also be updated to account for the Plant and to reflect any changes due to the construction and operation of the Project within the MPPS context.




Aspect Potential Impact Mitigation Measures Socio-Economic Social and economic ■ A Construction Local Employment and Procurement Plan will be required in the Tenders for construction

of the Project. ■ Similarly, an Operational Local Employment and Procurement Plan will be developed for the Operational

Phase prior to commissioning that will include. - Employ Locally – Preference will be given to the employment of local staff where suitable skills are

available. This preference will be enshrined in the tendering and procurement procedures during the construction phase and adopted by the JV for the operational phase; and

- Buy Local – Similarly local procurement will be encouraged during construction and operations with a requirement to consider local suppliers where suitable quality and pricing can be achieved.

■ Apprenticeships and Training – The Project will directly or indirectly provide formal or on-the-job training and upskilling opportunity for the workforce, benefits of which may extend beyond the scope of this Project. EnergyAustralia currently has an apprenticeship program in place at the MPPS and will extend this program to include the Project where appropriate.

■ Workforce Code of Conduct – A workforce code of conduct will be developed and applied to the construction workforce to assist in managing any anti-social behaviour that may impact on the local community.

Decommissioning and Rehabilitation

■ A Decommissioning and Rehabilitation Plan will be prepared for the Project five years prior to closure.

Ash Management ■ A review of bottom ash reuse options will be undertaken on a 5-year cycle, and will consider the legal, regulatory, and market conditions as well as the suitability of the ash for various uses.

Monitoring ■ Monitoring data will be provided in accordance with the requirements of the EPA’s EfW Policy. This will include provision of monitoring data the NSW EPA in real time format and provision of a weekly summary of continuous monitoring data and compliance with emissions limits published on the Project’s website.

■ Further, provision of monitoring data will also meet the requirements of the EPL to be issued for the Project.



REFERENCES

7. REFERENCES

Blue Mountains City Council, n.d.. Respect Our Code on Blue Mountains Roads Charter. [Online] Available at: https://www.bmcc.nsw.gov.au/sites/default/files/docs/RoadRespect-factsheet-charter.pdf

Commonwealth of Australia (2018). National Waste Policy: Less waste, more resources, s.l.: s.n. EU (2019). Best available techniques (BAT) reference document for waste incineration, s.l.: s.n. Fire and Rescue NSW (2020). NSW Fire Safety in Waste Facilities Guideline, s.l.: s.n. NSW Department of Environment, Climate Change and Water NSW (2011). NSW Road Noise Policy,

s.l.: s.n. NSW Department of Planning and Environment (2011). Hazardous Industry Planning Advisory Paper

No. 4, s.l.: s.n. NSW Department of Planning and Environment (2017). Draft environmental impact assessment

guidance series: responding to submissions, s.l.: s.n. NSW Department of Planning, Industry and Environment (2020). Cleaning up our act: the future for

waste and resource recovery in NSW, Issues Paper, s.l.: s.n. NSW Environment Protection Authority (2015). NSW Energy from Waste Policy Statement, s.l.: s.n. NSW Environmental Protection Authority (2014a). NSW Waste Avoidance and Resource Recovery

Strategy 2014-2021, s.l.: s.n. NSW Environmental Protection Authority (2014b). Waste Classification Guidelines: Part 1 Classifying

Waste, s.l.: s.n. NSW Environmental Protection Authority (2016a). Addendum to the Waste Classification Guidelines -

Part 1 Classifying Waste, s.l.: s.n. NSW Environmental Protection Authority (2016b). Approved methods for the modelling and

assessment of air pollutants in New South Wales, s.l.: s.n. NSW Environmental Protection Authority (2016c). Environmental Guidelines: Solid waste landfills, s.l.:

s.n. NSW Environmental Protection Authority (2017). Noise Policy for Industry, s.l.: s.n. Steag (2018a). Umwelterklärung 2018 - Abfallverbrennungsanlage IKW Rüdersdorf. s.l.:Steag. Steag (2018b). August 10. IKW Rüdersdorf Presentation. Received through Electronic

Correspondance: RE: Mt Piper - Air Modelling Information (20/12/2018 5:07 PM), s.l.: s.n. Steag (2020). Abfallanlieferung in t nach Abfallschlüsseln. IKW Rüdersdorf GmbH, Bericht IKW

Rüdersdorf., s.l.: s.n. Vattenfall (2014). Umwelterklärung 2014 - Abfallverbrennungsanlage IKW Rüdersdorf. s.l.:Vattenfall. Vattenfall (2016). Umwelterklärung 2016 - Abfallverbrennungsanlage IKW Rüdersdorf. s.l.:Vattenfall. Vattenfall (2017). Umwelterklärung 2017 - Abfallverbrennungsanlage IKW Rüdersdorf. s.l.:Vattenfall. WSP (2019). Mt Piper ERP Ash Management Study - Ash characterisation and assumptions book,

Appendix D of EIS. [Online] Available at: https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=SSD-8294%2120191210T080237.401%20GMT

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Documents

Volume 1 Mt Piper Energy Recovery Project