NVIRONM ENTAL SSESSM ENT EPORT - Manildra Group
NVIRONM ENTAL SSESSM ENT EPORT - Manildra Group
NVIRONM ENTAL SSESSM ENT EPORT - Manildra Group
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Town Planning, Agricultural & Environmental ConsultantsE<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong> R<strong>EPORT</strong>E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong> R<strong>EPORT</strong>MAJOR PROJECT – PART 3AE<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANNING ANDA<strong>SSESSM</strong><strong>ENT</strong> ACT 1979PROPOSED ETHANOL PRODUCTION UPGRADEINCLUDING PROPOSED ODOUR REDUCTION ANDWASTE WATER TREATM<strong>ENT</strong> MEASURES FOREXISTING SHOALHAVEN STARCHES OPERATIONSSHOALHAVEN STARCHES (MANILDRA GROUP)BOLONG ROADBOMADERRYPrepared forSHOALHAVEN STARCHES PTY LTDAugust 2008COWMANSTODDARTPTYLTD
PROPOSED ETHANOL PRODUCTION UPGRADEINCLUDING PROPOSED ODOUR REDUCTIONAND WASTE WATER TREATM<strong>ENT</strong> MEASURESFOR EXISTING SHOALHAVEN STARCHES OPERATIONSSHOALHAVEN STARCHES (MANILDRA GROUP)BOLONG ROAD, BOMADERRYRef. 07/34Town Planning, Agricultural & Environmental ConsultantsPeter Cowman, B.Sc.Agr., M.A.I.A.S.T.Stephen Richardson, M.App.Sc., B.T.P., Grad. Dip. Env. Mgt, C.P.P., MPIAStuart Dixon, B.Urb & Reg Plan, C.P.P., MPIAAssociate: Colin Stoddart, Cert. TCP (NSW), Ass. Dip. TCP, MPIAThe Holt Centre, 31 Kinghorne Street, NowraTelephone (02) 4423 6198 (02) 4423 6199Fax (02) 4423 1569PO Box 738, Nowra NSW 2541www.cowmanstoddart.com.auEmail – info@cowmanstoddart.com.auC O W M A N S T O D D A R T P T Y L T D
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryCERTIFICATION OF E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong>PREPARED PURSUANT TO PART 3A OF THE E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANNINGAND A<strong>SSESSM</strong><strong>ENT</strong> ACT 1979E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong>PREPARED BYName:Qualifications:Address:S. D. RichardsonM. Appl. Sc., B.T.P., Grad. Dip. Env. Mgt,CPP, MPIACowman Stoddart Pty Ltd31 Kinghorne StreetNOWRA NSW 2541in respect ofPROJECT TO WHICH PART 3A APPLIESProponent Name:Proponent Address:Shoalhaven Starches Pty LtdLand to be developed: AddressLot No. DP/MPS, Vol/Fol etc.Bolong Road, BomaderryVarious parcelsProposed Development: Proposed ethanol production upgrade includingproposed odour reduction and waste water treatmentmeasures for existing Shoalhaven Starches operationsEnvironmental AssessmentAn Environmental Assessment is attachedCertificationI certify that I have prepared this environmentalassessment and to the best of our knowledge• It has been prepared in accordance with Section75E of the Environmental Planning andAssessment Act 1979,• The information contained in the environmentalAssessment is neither false nor misleading.Signature:Name:S. D. RichardsonDate: August, 2008Cowman Stoddart Pty Ltd Ref. 07/34 - August 08
CONT<strong>ENT</strong>S1.0 INTRODUCTION ................................................................................................11.1 BACKGROUND TO PROJECT............................................................................ 11.2 THE PROPOSAL.................................................................................................. 21.2.1 Environmental Audit........................................................................................ 31.3 PART 3A OF THE E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANNING& A<strong>SSESSM</strong><strong>ENT</strong> ACT 1979 ................................................................................ 32.0 BACKGROUND .................................................................................................52.1 PRODUCTION PROCESSES.............................................................................. 52.2 OPERATING WORKFORCE................................................................................ 62.2.1 Operations ...................................................................................................... 62.2.2 Workforce........................................................................................................ 62.3 RAW MATERIALS ................................................................................................ 72.4 HISTORY OF DEVELOPM<strong>ENT</strong> ON THE SITE ................................................... 83.0 THE SUBJECT SITE AND SURROUNDS .......................................................133.1 THE SITE AND ITS SURROUNDING LOCALITY............................................. 134.0 CONSULTATION .............................................................................................174.1 INTRODUCTION ................................................................................................ 174.2 PRELIMINARY E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong>......................................... 174.3 GOVERNM<strong>ENT</strong> AGENCY CONSULTATION.................................................... 174.4 COMMUNITY CONSULTATION ........................................................................ 184.5 REVIEW OF DRAFT E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong> ................................ 224.6 ABORIGINAL STAKEHOLDER CONSULTATION............................................ 225.0 THE PROPOSED DEVELOPM<strong>ENT</strong> .................................................................235.1 OBJECTIVES OF THE ETHANOL UPGRADE.................................................. 235.2 E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> AUDIT................................................................................. 235.3 JUSTIFICATION FOR PROJECT ...................................................................... 255.4 SUMMARY OF PROPOSAL .............................................................................. 285.5 THE STARCH PLANT ........................................................................................ 315.6 THE GRAIN PLANT............................................................................................ 32C O W M A N S T O D D A R T P T Y L T D
5.7 ETHANOL PLANT .............................................................................................. 325.8 WASTE WATER TREATM<strong>ENT</strong> AND DISPOSAL.............................................. 355.8.1 Stillage Recovery.......................................................................................... 355.8.2 Waste Water Disposal .................................................................................. 405.9 PROPOSED NEW PACKING PLANT ANDCONTAINER LOADING AREA .......................................................................... 455.10 ENERGY AND UTILITIES .................................................................................. 485.10.1 Energy........................................................................................................... 485.10.2 Water Supply ................................................................................................ 495.10.3 Pipelines ....................................................................................................... 506.0 STATUTORY APPROVAL CONTEXT.............................................................516.1 COMMONWEALTH LEGISLATION ................................................................... 516.1.1 Environment Protection & Biodiversity Conservation Act............................. 516.1.2 Commonwealth Aboriginal Heritage Legislation........................................... 536.2 STATE LEGISLATION........................................................................................ 546.2.1 Environmental Planning & Assessment (EP&A) Act 1979 ........................... 546.2.2 Threatened Species Conservation Act ......................................................... 596.2.3 Protection of the Environment Operations Act ............................................. 616.2.4 Water Management Act 2000....................................................................... 626.2.5 Native Vegetation Act 2003 .......................................................................... 626.2.6 The Roads Act 1993..................................................................................... 636.2.7 National Parks and Wildlife Act 1975 ........................................................... 646.3 STATE E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANNING POLICIES .......................................... 656.3.1 SEPP No. 14 - Coastal Wetlands ................................................................. 656.3.2 SEPP No. 33 - Hazardous and Offensive Development .............................. 666.3.3 SEPP No. 71 - Coastal Protection................................................................ 666.3.4 SEPP (Major Projects) 2005......................................................................... 686.3.5 SEPP (Infrastructure) 2007........................................................................... 686.3.6 NSW Coastal Policy...................................................................................... 706.3.7 Riparian Corridor Guidelines for Controlled Activities .................................. 716.3.8 Riparian Corridor Management Study Guidelines........................................ 72C O W M A N S T O D D A R T P T Y L T D
6.4 REGIONAL E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANS AND STRATEGIES........................... 736.4.1 Illawarra Regional Environmental Plan......................................................... 736.4.2 South Coast Regional Strategy .................................................................... 766.5 SHOALHAVEN LOCAL E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLAN 1985.................................. 786.6 DEVELOPM<strong>ENT</strong> CONTROL PLANS (DCPS) ................................................... 866.7 APPROVAL REGIME FOR PROJECT .............................................................. 907.0 KEY ISSUES ....................................................................................................917.1 AIR QUALITY (INCLUDING ODOUR) A<strong>SSESSM</strong><strong>ENT</strong> ..................................... 917.1.1 Environmental Audit...................................................................................... 927.1.2 Emissions Inventory...................................................................................... 967.1.3 Assessment of Air Quality Impacts............................................................. 1067.1.4 Conclusions ................................................................................................ 1247.2 GREENHOUSE GAS EMISSIONS .................................................................. 1267.2.1 Energy and Greenhouse Analysis .............................................................. 1277.2.2 Greenhouse Emission Reduction ............................................................... 1357.3 WASTEWATER TREATM<strong>ENT</strong>......................................................................... 1387.3.1 Existing Wastewater Treatment Processes................................................ 1387.3.2 Wastewater Treatment and Fitness for Purpose of Treated Effluent. ........ 1407.4 EFFLU<strong>ENT</strong> IRRIGATION AND STORAGE ..................................................... 1547.4.1 Local Environment ...................................................................................... 1547.4.2 Wastewater................................................................................................. 1557.4.3 Soil Salinity ................................................................................................. 1597.4.4 Plant nutrition.............................................................................................. 1677.4.5 Water Balance Analyses............................................................................. 1737.4.6 Irrigation Management Plan........................................................................ 1757.4.7 Implementation of Irrigation Program ......................................................... 1787.4.8 Summary and Conclusions......................................................................... 1817.5 WATER AND SOILS......................................................................................... 1837.5.1 Water Supply .............................................................................................. 1837.5.2 Stormwater Management ........................................................................... 1847.5.3 Acid Sulphate Soils..................................................................................... 1887.5.4 Contamination............................................................................................. 192C O W M A N S T O D D A R T P T Y L T D
7.6 NOISE ............................................................................................................... 1987.6.1 Ethanol Upgrade Acoustic Design Targets................................................. 1987.6.2 Acoustic Assessment.................................................................................. 2017.6.3 Construction Noise ..................................................................................... 2087.6.4 Conclusion .................................................................................................. 2107.7 TRANSPORT, ACCESS AND PARKING ........................................................ 2117.7.1 Local Traffic Network .................................................................................. 2117.7.2 Existing Traffic Summary............................................................................ 2147.7.3 Regional Access ......................................................................................... 2157.7.4 Site Access ................................................................................................. 2167.7.5 Pedestrian Access ...................................................................................... 2187.7.6 Traffic Generation ....................................................................................... 2197.7.7 Light Vehicle Trip Distribution..................................................................... 2207.7.8 Heavy Vehicle Trip Distribution................................................................... 2207.7.9 Rail Access ................................................................................................. 2237.7.10 Parking........................................................................................................ 2247.7.11 Council, RTA and Community Issues......................................................... 2257.7.12 Site Access ................................................................................................. 2307.7.13 Traffic Generation ....................................................................................... 2337.7.14 Future Intersection Performance ................................................................ 2367.7.15 Minimising General Traffic Impacts ............................................................ 2377.7.16 Parking........................................................................................................ 2397.7.17 Conclusions and Recommendations .......................................................... 2407.8 HAZARDS AND RISK....................................................................................... 2427.9 RIVER BANK STABILITY AND RIPARIAN MANAGEM<strong>ENT</strong>........................... 2487.9.1 Geomorphology .......................................................................................... 2487.9.2 Existing Riparian Health ............................................................................. 2517.9.3 Potential Impacts ........................................................................................ 2607.9.4 Conclusion .................................................................................................. 2627.9.5 Recommendations...................................................................................... 2637.10 FLOODING ....................................................................................................... 2667.10.1 Hydraulic Impacts ....................................................................................... 267C O W M A N S T O D D A R T P T Y L T D
7.10.2 Economic, Social and Environmental Impacts ........................................... 2787.10.3 Mitigation Measures.................................................................................... 2797.11 WASTE MANAGEM<strong>ENT</strong> .................................................................................. 2847.11.1 Legal and Regulatory Requirements .......................................................... 2847.11.2 Waste Identification and Classification ....................................................... 2857.11.3 Environmental Management Plan .............................................................. 2867.12 VISUAL IMPACT............................................................................................... 2917.13 FLORA AND FAUNA ........................................................................................ 3037.13.1 Description of the Vegetation...................................................................... 3037.13.2 Plant Species Recorded ............................................................................. 3047.13.3 Fauna Habitat ............................................................................................. 3057.13.4 Impact of the Proposed Upgrade................................................................ 3077.13.5 Conclusion and Recommendations of Flora and Fauna Assessment........ 3077.14 HERITAGE AND ARCHAEOLOGICAL ISSUES ............................................. 3087.14.1 Aboriginal Archaeology............................................................................... 3087.14.2 European Heritage...................................................................................... 3188.0 STATEM<strong>ENT</strong> OF COMMITM<strong>ENT</strong>S – E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> MANAGEM<strong>ENT</strong>..3208.1 LEGISLATIVE REQUIREM<strong>ENT</strong>S..................................................................... 3208.1.1 Legislation and Regulations........................................................................ 3208.1.2 Policies and Guidelines .............................................................................. 3218.2 APPROVALS, PERMITS AND LICENCES...................................................... 3218.3 SPECIFIC COMMITM<strong>ENT</strong>S............................................................................. 3228.3.1 Construction Environmental Management Plan ......................................... 3228.3.2 General Environmental Management......................................................... 3238.3.3 Soil and Water Management ...................................................................... 3248.3.4 Noise and Vibration Management .............................................................. 3268.3.5 Traffic, Access and Parking........................................................................ 3298.3.6 Air Quality Management ............................................................................. 3308.3.7 Odours ........................................................................................................ 3318.3.8 Greenhouse Gas Emissions....................................................................... 3328.3.9 Waste and Chemical Management ............................................................ 3338.3.10 Waste Water and Irrigation Management................................................... 3358.3.11 Hazard and Risk Management ................................................................... 336C O W M A N S T O D D A R T P T Y L T D
8.3.12 Flooding ...................................................................................................... 3378.3.13 Riparian and Riverbank Stability ................................................................ 3388.3.14 Weed Management .................................................................................... 3398.3.15 Stock Exclusion .......................................................................................... 3408.3.16 Vegetation Management Plan .................................................................... 3408.3.17 Visual Amenity ............................................................................................ 3418.3.18 Site Contamination and Acid Sulphate Soils .............................................. 3428.3.19 Flora and Fauna ......................................................................................... 3448.3.20 Aboriginal Heritage ..................................................................................... 3449.0 CONCLUSION................................................................................................346C O W M A N S T O D D A R T P T Y L T D
FIGURESFigure 1Figure 2Figure 3Site Locality PlanPlan of Existing Factory Site Depicting Existing Plantas well as Plant that has Previously been Approvedbut not Yet BuiltSite Plan Depicting Proposed Additions to Factory SiteFigure 4 Configuration of Wet Weather Storage Pond No. 7Figure 5Figure 6Figure 7Figure 8Figure 9Figure 10Figure 11Figure 12Figure 13Figure 14Figure 15Figure 16Figure 17Figure 18Figure 19Figure 20Figure 21Elevation Details of the Proposed Plant UpgradeFlow Chart Depicting the Proposal in Terms of the Processesat the SiteDiagram detailing the Water Treatment Process associatedwith the ProposalMass Balance and Process FlowPlanning Provisions Applying to the SiteFactory Odour Impact Model – Scenario A (Existing Factory)Factory Odour Impact Model – Scenario B(Existing Factory with Stage 1 Odour Control)Factory Odour Impact Model – Scenario C(Factory with Stage 1 Odour Control and Ethanol Upgrade)Factory Odour Impact Model – Scenario D(Factory with Stage 2 Odour Control and Ethanol Upgrade)Factory Odour Impact Model – Scenario E(Factory with Stage 3 Odour Control and Ethanol Upgrade)Factory Odour Impact Model – Scenario F(Existing Factory without DDG Plant)Factory and Environmental Farm Odour Impact Model– Scenario GMaximum Predicted Ground Level PM10 Concentrations(24-Hour Average)Flow Diagram Depicting the Proposed BVF/SO Basin SystemFlow Diagram Depicting the Proposed MBR/RO SystemDiagrammatic View of MBR/RO PlantThe Time Trend in the Root-Density Weighted EC ConcentrationsC O W M A N S T O D D A R T P T Y L T D
FIGURES (continued)Figure 22Figure 23Figure 24Figure 25Figure 26Figure 27Figure 28Figure 29Figure 30Figure 31Figure 32Figure 33Figure 34The relation between the mean annual EC w between 1995 and2007 and the corresponding annual percolation (A), irrigationvolume (B), and TDS load (C).The Monthly Irrigation Volumes in Dry, Medium and Wet MonthsAverage Distribution of Daily Irrigation Volumesfor the Last 3 YearsAcid Sulfate Soil Risk MapTransport Routes Around the SiteTraffic Access ArrangementsPlan identifying Car Parking over the Factory SiteIndividual Fatality Risk Profile for the Shoalhaven OperationAll Works Since 1990 Extreme FloodAll Works Since 1990 1% AEP FloodAll Works Since 1990 2% AEP FloodAll Works Since 1990 5% AEP FloodVantage Points for PlatesC O W M A N S T O D D A R T P T Y L T D
ANNEXURESAnnexure AAnnexure BAnnexure CAnnexure DAnnexure EAnnexure FAnnexure GDirector-General’s Requirements for the Preparationof this Environmental Assessment - AddressedGovernment Agency Requirements - AddressedGovernment Agency Submissions in responseto Draft Environmental AssessmentAboriginal Impact Assessmentprepared by South East Archaeology Pty LtdFlora & Fauna Assessmentprepared by Kevin Mills & AssociatesPreliminary Hazard Analysisprepared by GHD Pty LtdTraffic Impact Assessmentprepared by Christopher Stapleton Consulting Pty LtdAnnexure H NSW Coastal Policy 1997Compliance Checklist for the Preparationof Development ProposalsAnnexure IAnnexure JAnnexure KAnnexure LAnnexure MAnnexure NAnnexure O(i)Annexure O(ii)Riparian Assessmentprepared by Coffey Environments Pty LtdEnvironmental Site Assessmentprepared by Coffey Environments Pty LtdHydraulic, Economic and Social Impacts of Floodingprepared by Webb McKeown & Associates Pty LtdWaste Management Report, prepared byStephenson Environmental Management AustraliaAir Quality Assessment Reportprepared by GHD Pty LtdGreenhouse Gas Assessmentprepared by GHD Pty LtdAgronomic Investigations– Fitness for Purpose of Treated Wastewaterprepared by Dr John Murtagh, Roy Lawrie and Glenys LuggAgronomic Investigations– Fitness for Purpose of Treated WastewaterSupplementary Information including Monitoring Programprepared by Dr John Murtagh, Roy Lawrie and Glenys LuggC O W M A N S T O D D A R T P T Y L T D
ANNEXURES (continued)Annexure PAnnexure Q(i)Annexure Q(ii)Annexure REnvironmental Management Reportprepared by GHD Pty LtdAcoustical Assessmentprepared by The Acoustic <strong>Group</strong>Acoustic Assessment of Site Operationsprepared by The Acoustic <strong>Group</strong>Report on Community Consultationprepared by Twyford ConsultingC O W M A N S T O D D A R T P T Y L T D
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryEXECUTIVE SUMMARYShoalhaven Starches is a member of the <strong>Manildra</strong> <strong>Group</strong> of companies. The <strong>Manildra</strong> <strong>Group</strong>is a wholly Australian owned business and the largest processor of wheat in Australia. Itmanufactures a wide range of wheat based products for food and industrial markets bothlocally and internationally.The Shoalhaven Starches factory located on Bolong Road, Bomaderry produces a range ofproducts for the food, beverage, confectionary paper and motor transport industries including:starch, gluten, glucose and ethanol. During these processes, treated waste water is producedand spray irrigated onto pastures of the Company’s Environmental Farm, which comprisesover 1000 ha of land situated to the north of the factory site.In 2003 the Minister for Planning approved a development application (DA223) for theCompany’s Pollution Reduction Program No. 7. This approval which, included the extensionof the company’s irrigation of waste water onto additional farm lands, also enabled ethanolproduction at the plant to increase from 100 million litres per year to 126 million litres per year.The use of ethanol as a fuel (or fuel additive) has many benefits including:• it is a renewable fuel and lessens reliance on fossil fuels;• it reduces greenhouse gas emissions and other air pollutants such as carbon monoxideand particulates;• it reduces imports of oil and stimulates regional and local economies if produced locally.Given the above benefits, the Federal and State Governments have introduced a range ofinitiatives to encourage the increased use of ethanol as a fuel additive.The NSW Government has recently mandated the blending of 2% of ethanol into the totalvolume of petrol sold in NSW as a first step towards a10% ethanol content by 2011.As a result, the <strong>Manildra</strong> <strong>Group</strong> is planning to increase its ethanol production capacity to meetthe expected increase in demand for ethanol arising from these initiatives by upgrading theexisting ethanol plant, located at the Shoalhaven Starches Plant at Bomaderry.Shoalhaven Starches plans to increase ethanol production at its Bomaderry Plant from thecurrent approved 126 million litres per year to 300 million litres per year.To accomplish the increase in ethanol production, this proposal will require some plantupgrades and an increase in the throughput of raw materials, principally flour and grain.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08i
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe following additions and alterations are proposed to the existing factory site as part of theethanol upgrade:• the provision of an additional dryer for the starch/gluten plant;• additional equipment and storage vessels for the ethanol plant including 3 additionalfermenters, additional cooling towers and molecular sieves;• upgrades to the Stillage Recovery Plant including 6 additional Dried Distillers GrainsSyrup (DDGS) dryers; 10 decanters; chemical storage and two evaporators. Theproposal also includes the installation of a DDGS Pellet Plant within this part of the site;and,• the establishment of a new packing plant, container loading area and a rail spur line. Theestablishment of this facility on the northern side of Bolong Road will require the provisionof an overhead bridge structure to allow product and safe pedestrian movement acrossBolong Road.In addition to the upgrade to the Company’s ethanol plant, Shoalhaven Starches also proposeto undertake comprehensive odour reduction measures for both the existing factory site andthe works associated with this proposal. In 2006, the Land and Environment Court requiredShoalhaven Starches to engage a suitably qualified person to conduct a comprehensiveenvironmental audit of the factory and Environmental Farm. This environmental audit hasbeen completed (by GHD Pty Ltd). The audit report includes a number of recommendationsfor the implementation of works to the existing site, some of which require developmentapproval. These works have therefore been included with this project. The Department ofEnvironment and Climate Change (DECC) have advised that the recommendations of theaudit report will need to be implemented prior to the operation of the ethanol upgrade project.The proposal also includes the biological treatment of waste waters from the factory site. It isproposed to re-use over half the treated waste water within the factory processes and theremainder irrigated onto the Company’s Environmental Farm.The project will also involve an upgrade to services to the site such as electric power, naturalgas, etc. The proposal includes the provision of an additional gas fired boiler and a gas firedco-generation plant.The proposed development is a project within the terms of Part 3A of the EnvironmentalPlanning & Assessment Act 1979. It comes within Item 3 to Schedule 1 of the StateEnvironmental Planning Policy (Major Projects) 2005. In this regard, it is a developmenthaving a capital investment more than $30 million for the purpose of an agricultural produceindustry and food and beverage processing.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08ii
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe estimated capital cost of the expansion of the plant is approximately $200 million.The project will create an estimated peak construction workforce of up to 150 jobs during anestimated12 month construction phase. Operation of the upgraded plant will not only assist insustainably maintaining the existing workforce currently comprising around 250 directemployees; but will also create up to an estimated 25 additional direct on-going positions onthe site.The preparation of this Environmental Assessment has been undertaken following consultationwith relevant Government agencies, including:• The Department of Planning• The Department of Environmental and Climate Change.• The Department of Water and Energy• The Roads & Traffic Authority; and• Shoalhaven City Council.Community Consultation groups and Aboriginal stakeholders have been consulted.This Environmental Assessment has been prepared to address issues raised by therequirements of the Director-General of the Department of Planning as well as the issuesraised by government agencies and the local community.The Environmental Assessment (EA):• Considers relevant statutory and non-statutory requirements including the provisions ofState, Regional and Local planning provisions and strategies. The EA concludes theproposal is consistent with these planning strategies and provisions.• Assesses the impacts of the proposal on local air quality focussing on odours, particulateemissions and greenhouse gas emissions. The EA includes a comprehensive air qualityassessment that addresses issues pertaining to odours with specific reference to thetiming and implementation of the findings of the Environmental Audit. The assessmentidentifies odour sources and predicts odour emissions from the proposed expansion, andmodels the cumulative odour impacts at the closest residential premises and describesodour mitigation measures.In terms of air quality all particulate emissions following the upgrade were assessed to bewithin the limits prescribed by the relevant regulations. Modelling indicates that theimplementation of odour controls at the factory, and including the installation of awastewater treatment plant at the Environmental Farm will mitigate the potential for futureoffensive odours beyond the boundary of the premises.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08iii
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe Environmental Assessment:• Is also supported by a specific greenhouse gas assessment prepared by GHD whichincludes a quantitative analysis of the emissions of the project; and a qualitative analysis ofthe impacts of these emissions in accordance with the requirements of the AustralianGreenhouse Office’s “Factors and Methods Workbook” 2006. The assessment outlinesmeasures to reduce and/or offset emissions and includes an analysis of energy use.• Includes an acoustic assessment prepared by The Acoustic <strong>Group</strong>. This assessmentdetails the noise impacts of the existing factory, identifies the additional noise sourcesfrom the proposed expansion and assesses the cumulative noise impact at residencesboth during construction and operation. The assessment also examines operational trafficnoise (both road and rail). The EA concludes that the proposal will not result in noiselevels generated from the overall site exceeding existing Environmental ProtectionLicence requirements for the site.• Addresses water management issues with respect to the identification of water supply,consumption and waste streams. The EA details water supply including potable and nonpotableservices. In addition the EA describes the proposed waste water treatmentprocess for the existing facility and the proposed expansion. In this regard the proposalseeks to introduce biological treatment of wastewater generated from the factory which willenable over half of the treated wastewater to be re-used within the factory productionprocesses. The remainder will be irrigated onto the Company’s Environmental Farm. Thequality of the wastewater that will be irrigated will also be significantly improved from thatcurrently irrigated; and the overall quantity will be reduced. The EA is supported by anassessment prepared jointly by Agricultural Water Management; NSW Department ofPrimary Industries; and Shoalhaven Starches; which concludes the treated waste waterand retentate from the wastewater treatment process will be suitable for farm irrigation.• Includes an assessment of the proposal, carried out by Webb McKeown & Associates thatundertakes a flood risk analysis identifying impacts both in terms of the site and within thebroader locality. The EA concludes that the economic, social and environmental impactsassociated with increased flood levels associated with this proposal will not be significant.In order to compensate for any potential adverse impacts of the existing and proposedworks, a range of management measures have been proposed to mitigate these impactson the northern floodplain. .• Provides a Preliminary Hazard Analysis (PHA) prepared by GHD. The PHA wascompleted in accordance with State Environmental Planning Policy No. 33, HIPAP No. 6Guidelines for Hazard Analysis, and the Risk Criteria for Land Use Safety Planning givenCowman Stoddart Pty Ltd Ref. 07/34 - August 08iv
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrysupported by a Riparian Assessment prepared by Coffey Environments. This assessmentincludes recommendations for revegetation and enhancement works to improve bankstability. It is also recommended that Shoalhaven Starches develop and implement aVegetation Management Plan.• Examines the likelihood of occurrence of site contamination and acid sulphate soils; andincorporates measures to mitigate the affects associated with disturbing such soils. TheEA is supported by an assessment carried out by Coffey Environments investigating thepresence of site contamination and Acid Sulphate Soils.• Examines both non-Indigenous and Indigenous cultural heritage issues. The EA issupported by an Aboriginal Heritage Assessment prepared by South East Archaeology.This assessment concludes that the proposal will not have any significant impacts on anyitems of Aboriginal heritage.• Is also supported by Flora & Fauna Assessment prepared by Kevin Mills & Associates.This assessment, which includes an analysis of impacts on critical habitats, threatenedspecies, populations and ecological communities and their habitats, concludes that theproposal will not adversely impact threatened species or their habitats.Following an assessment of the key issues associated with this proposal, this EnvironmentalAssessment concludes that the proposal is suitable for the site and this locality. TheEnvironmental Assessment includes a Statement of Commitments outlining environmentalmanagement, mitigation and monitoring measures that should be implemented to minimisepotential impacts associated with the proposal.The Minister’s approval is sought for the proposal.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08vi
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry1.0 INTRODUCTION1.1 BACKGROUND TO PROJECTShoalhaven Starches is a member of the <strong>Manildra</strong> <strong>Group</strong> of companies. The <strong>Manildra</strong><strong>Group</strong> is a wholly Australian owned business and the largest processor of wheat inAustralia. It manufactures a wide range of wheat based products for food and industrialmarkets both locally and internationally.The Shoalhaven Starches factory located on Bolong Road, Bomaderry produces a rangeof products for the food, beverage, confectionary, paper and motor-transport industriesincluding: starch, glucose and ethanol. During these processes, treated waste water isproduced and spray irrigated onto pastures of the Company’s Environmental Farm,which comprises over 1000 ha of land situated to the north of the factory site.In 2003 the Minister for Planning approved a development application (DA223) for theCompany’s Pollution Reduction Program No. 7 and which included the extension of thecompany’s irrigation of treated waste water onto additional lands. This approval alsoenabled ethanol production at the plant to increase from 100 million litres per year to 126million litres per year.The use of ethanol as a fuel (or fuel additive) has many benefits including:• it is a renewable fuel and lessens reliance on fossil fuels;• it reduces greenhouse gas emissions and other air pollutants such as carbonmonoxide and particulates;• it reduces imports of oil and stimulates regional and local economies if producedlocally.Given the above benefits, the Federal and State Governments have introduced a rangeof initiatives to encourage the increased use of ethanol as a fuel additive.The NSW Government has recently mandated the blending of 2% of ethanol into thetotal volume of petrol sold in NSW as a first step towards a10% ethanol content by 2011.As a result, the <strong>Manildra</strong> <strong>Group</strong> is planning to increase its ethanol production capacity tomeet the expected increase in demand for ethanol arising from these initiatives byupgrading the existing ethanol plant, located at the Shoalhaven Starches factory atBomaderry.Shoalhaven Starches plan to increase ethanol production at its Bomaderry Plant fromthe current approved 126 million litres per year to 300 million litres per year. ToCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 1
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryaccomplish the increase in ethanol production will require some plant upgrades and anincrease in throughput of raw materials, principally flour and grain.In addition to the above, and following investigation of odour complaints in 2004, theDepartment of Environment and Climate Change (DECC) successfully prosecutedShoalhaven Starches in the Land and Environment Court in 2006 for the emission ofoffensive odours. The Land and Environment Court required Shoalhaven Starches toengage a suitably qualified person to prepare a comprehensive environmental audit ofthe facility and Environmental Farm. GHD Pty Ltd was subsequently engaged byShoalhaven Starches to undertake this audit. This audit has been completed and thereport has been submitted to the Court and the DECC. The audit recommended a rangeof measures to mitigate the potential for future offensive odours beyond the boundary.This proposal therefore includes those works recommended by this audit which requiredevelopment approval. Implementation of measures which do not require developmentapproval are currently underway.1.2 THE PROPOSALShoalhaven Starches plans to increase ethanol production at its Bomaderry plant fromthe current approved 126 million litres per year to 300 million litres per year.To accomplish the increase in ethanol production, this proposal will require some plantupgrades and an increase in processing of raw materials, principally flour and grain1. The following additions and alterations are proposed to the existing factory site aspart of the ethanol upgrade:• the provision of an additional dryer for the starch/gluten production plant;• additional equipment and storage capacity for the ethanol plant including3 additional fermenters, an additional molecular sieve and associatedadditional cooling towers;• upgrades to the Stillage Recovery Plant including 6 additional Dried DistillersGrains Syrup (DDGS) dryers; 10 decanters and chemical storage; and twoevaporators. The proposal will also include the installation of a DDGS PelletPlant within this part of the site;• the establishment of a new packing plant and container loading area (includingnew railway spur line). The establishment of the new packing plant on thenorthern side of Bolong road will require the construction of an overheadbridge structure to allow product and safe pedestrian movement acrossBolong Road.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 2
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry2. The proposal includes the biological treatment of waste waters from the factorysite. Over half the treated waste water will be re-used within the factory and theremainder will be irrigated onto the Company’s Environmental Farm. Thebiological treatment of factory waste water will require the adaption of WetWeather Storage Pond No. 7 currently under construction on the Company’sEnvironmental Farm.3. The project will also involve an upgrade to services to the site such as electricpower, natural gas, etc. The proposal includes the provision of an additional gasfired boiler and a gas fired co-generation plant.1.2.1 Environmental AuditFollowing investigation of odour complaints in 2004, DECC successfully prosecutedShoalhaven Starches in the Land and Environment Court in 2006 for the emission ofoffensive odours.The Land and Environment Court judgement of 2 November 2006 required ShoalhavenStarches to engage a suitably qualified person to conduct a comprehensiveenvironmental audit of the factory and Environmental Farm in order to identify andquantify all odours generated by the operations, and to provide recommendations for theimproved management of odours. Shoalhaven Starches engaged GHD Pty Ltd toconduct the environmental audit.This environmental audit has been completed and a report of the audit has beensubmitted to the Land and Environment Court and the DECC. The Audit Report includesa range of recommendations for improvements to the Shoalhaven Starches factory andEnvironmental Farm operations. In addition to which, the Company has agreed to aPlan and Timetable to implement the recommendations of the Environmental Audit.Many of the works associated with these recommendations do not require developmentapprovals and the Company has commenced to undertake these measures. A numberof the recommended works may require development approval. These works aretherefore included as part of this proposal. The recommendations of this Audit report willneed to be addressed prior to commencement of operation of the Ethanol Upgradeproject.1.3 PART 3A OF THE E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANNING & A<strong>SSESSM</strong><strong>ENT</strong> ACT 1979The proposed development is a project within the terms of Part 3A of the EnvironmentalPlanning & Assessment Act 1979. It comes within Item 3 to Schedule 1 of the StateEnvironmental Planning Policy (Major Projects) 2005. In this regard, it is a developmentCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 3
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryhaving a capital investment more than $30 million for the purpose of an agriculturalproduce industry and food and beverage processing (ethanol plant).The estimated capital cost of the expansion of the plant is approximately $200 million.The project will create an estimated peak construction workforce of up to 150 jobs duringan estimated 12 month construction phase. Operation of the upgraded plant will not onlyassist in sustainably maintaining the existing workforce at the plant currently comprisingaround 250 employees; but is also expected to create up to an estimated 25 additionalon-going positions on the site.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 4
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry2.0 BACKGROUND2.1 PRODUCTION PROCESSESThe production process at the Shoalhaven Starches plant has developed over a numberof years. Originally the plant was primarily concerned with the production of starch andgluten from flour. However the Company has pursued a number of technologicalinnovations particularly with respect to reducing the environmental impacts of theCompany’s operations. As a result Shoalhaven Starches has been moving towards a“closed” system of production. Essentially this entails the efficient use of end products toensure wastage is reduced to a minimum.The first step in the production process is the delivery of flour and grain, by rail, from theCompany’s flour mills at <strong>Manildra</strong>, Gunnedah and Narrandera. The trainloads arebrought into the plant via the switching yard at Bomaderry.The Company has received approval from the Minister for Planning for the erection of aflour mill on site to enable the milling of part of the Company’s flour requirements to beprocessed directly on the site. The remainder of the Company’s flour requirement willcontinue to be sourced from the Company’s off-site flour mills.Flour is transferred via storage to the “wet end” of the plant where fresh water is added.The subsequent mixing and separation process produces starch and gluten.The gluten is dried to enable it to be packaged and distributed as a high protein foodadditive for human consumption. This product is then taken from the site afterpackaging for both local and export markets. The wastage from the starch process isused for fermentation and distillation to produce ethanol.The starch that is separated from the flour is either dried or remains in liquid form. Thedried and liquid starch is sold to the paper and food industries. The starch is used forfood, cardboard, paper and other industrial purposes. The wastage from the liquidstarch process is used in the ethanol production process.Starch is also used in the production of syrups on the site. The syrups plant productsinclude glucose and brewer’s syrup. These are used for foods, chocolates,confectionery, beer, soft drinks and fruit juice. The syrups plant also has some wastagethat is used in the ethanol process.The wastage from the starch, gluten and syrup production processes are combined tofeed the fermentation and distillation stage of ethanol production. The outputs are fuelCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 5
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryand industrial grade ethanol. Industrial grade ethanol is used in producingpharmaceuticals, printer’s ink and methylated spirits.Ethanol production results in some solid and waste water wastage, which is processedthrough the stillage recovery process plant (which was approved as part of PRP No. 7 in2005). The waste solids are recovered as DDGS (Dried Distillers Grains Syrup), driedand sold as a high protein cattle feed with the remaining water used for irrigation. Thewaste water resulting from the ethanol production is pumped to holding tanks and pHcorrected, before being irrigated onto Shoalhaven Starches Environmental Farm to thenorth of Bolong Road. This farm land is used for fodder crops, pasture and cattlegrazing.2.2 OPERATING WORKFORCE2.2.1 OperationsThe existing factory operates 24 hours per day, 7 days a week, 365 days of the year.2.2.2 WorkforceThe plant employs a total of 250 staff, covering all components of production - operators,administrative personnel and maintenance staff. Employee breakdown and hours ofshifts are as follows:A total of around 250 employees Management, Technical & Administration 60Day Workers 60Shift Production (spread over 4 shifts) 130Hours of ShiftsPlant: 6:00 am to 6:00 pm - 30 employees6:00 pm to 6:00 am - 30 employeesDay – 7:00 am to 3:00 pm but variable60 employees, 50 Management,Technical & AdministrationFarm: 5:00 am to 5:00 pm - 2 employees5:00 pm to 5:00 am - 1 employee7:00 am to 3:00 pm - 3 employeesShift work at both the factory and farm is undertaken on a 2 day, 2 night and 4 day offbasis.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 6
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry2.4 HISTORY OF DEVELOPM<strong>ENT</strong> ON THE SITEShoalhaven Starches Pty Ltd is a member of the <strong>Manildra</strong> <strong>Group</strong> of Companies, a whollyAustralian owned business and the largest processor of wheat in Australia. The<strong>Manildra</strong> <strong>Group</strong> originated from the NSW country town of <strong>Manildra</strong> where a single flourmill was purchased in 1952.The Shoalhaven Starches wheat starch and gluten plant at Nowra was originallyconstructed in 1970. The <strong>Manildra</strong> flour mills, at <strong>Manildra</strong>, Narrandera and Gunnedah,supply the Shoalhaven Starches factory, which currently produces wheat starch, gluten,syrups and ethanol (industrial and fuel grades). The Shoalhaven Starches operationprovides direct on-site employment for 250 employees. Through the use of contractors italso indirectly creates employment for many more people in the local and regionaleconomies.In order to address the issue of waste water disposal, in 1984 Shoalhaven Starchesinstalled a spray irrigation system, using farmland it owned on the northern side ofBolong Road at Bomaderry.In June 1991, two storage ponds were built (Ponds No. 1 and 2) resulting in thecessation of waste water discharge to the Shoalhaven River.To further reduce product wastage, Shoalhaven Starches sought to use excess starchfor the production of ethanol. Ethanol production began at the Shoalhaven site in June1992.In 1994, the NSW Government approved the installation of a larger ethanol distillerywithin the existing site. The new distillery and its associated facilities enabled productionof ethanol to increase from 20 million litres per annum to a production capacity of 100million litres per year.Subsequent to this approval Shoalhaven City Council issued development consent for:• a protein isolate plant and DDGS Dryer; and• a sorghum grinding plant.Shoalhaven City Council issued development approval for the construction of a wetweather storage pond (Pond No. 6) on the 27th April 2001. At present, with thecompletion of Pond No. 6, Shoalhaven Starches has a combined waste water storagecapacity within the existing ponds of 925 ML. A further wet weather storage pond (PondNo. 7) was approved by the Minister for Planning on the 23 December 2002. Pond No. 7is currently under construction.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 8
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryOn the 1st June, 2001 the Minister for Urban Affairs & Planning, Dr Andrew RefshaugeMP, declared both the Shoalhaven Starches factory and Environmental Farm as beingState Significant Development for the purposes of the then Section 76A(7) of theEnvironmental Planning & Assessment Act. Under the provisions of this declaration, alldevelopment except “alterations and additions to existing development which, in theopinion of the Minister in consultation with Council, are of minor nature and do not to anysignificant extent change the scale, size, design or environmental impact of the existingdevelopment” requires the Minister’s consent.In 2003 the Minister for Planning issued development consent (D223) for ShoalhavenStarches Pollution Reduction Program (PRP) No. 7. This approval enabled theimplementation of the Company’s Waste Water Management Strategy, and essentiallysought to remove solids (suspended and soluble) from the Company’s waste water, priorto its irrigation on the Environmental Farm.This process, known as Stillage Recovery, essentially involved the introduction ofadditional decanters, the installation of an evaporation plant and additional dryers, toremove solids from the waste water. It is the remaining solids in the waste water thatwhen sprayed onto the Environmental Farm, or stored in the wet weather storage ponds,which have the potential to result in the generation of odours.The recovery of the suspended and soluble solids from the waste water could not beundertaken by the dryers in this process, without firstly providing additional coarsesolids. Additional coarse solids (grain) were required to be imported to the site.As a consequence of the additional grain, the starch contained in the grain resulted in aneed to increase ethanol production. This increase in ethanol production required theinstallation of additional fermenters, associated cooling towers and molecular sieves.The increase in ethanol production also resulted in an increase in waste water, whichwas required to be disposed on the environmental farm. In this regard this previousproposal also included an increase in waste water disposal area on the EnvironmentalFarm.The plant associated with this previous approval has now been substantially installedand commissioned.Shoalhaven Starches have subsequently recently received the following developmentapprovals:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 9
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• The establishment of a flour mill on the factory site. This proposal provides for thetransportation of wheat directly to the site by train for processing into industrial gradeflour for the use in the production of starch and gluten at the factory site.• An application pursuant to Section 96 of the Environmental Planning & AssessmentAct seeking to modify the development approval for the PRP No. 7 project to enablea DDGS Dryer to be installed in a slightly different location in the same building aspreviously approved; and the installation of an additional evaporator (a redundantpiece of equipment located at the Company’s Altona Plant in Victoria) to providestandby capacity for the existing evaporator plant when sections of the existing plantare out of service or cleaning.• A Section 96 modification application for a standby fermenter tank to be installed onthe site, to enable the existing fermenter tanks to be taken out of service formaintenance one at a time.The Department of Planning have indicated a preference for a single developmentapproval to cover the overall Shoalhaven Starches operations. This would requireShoalhaven Starches to surrender the existing approvals for the site; and theDepartment of Planning to issue a single approval for the overall site. Table 1 detailsthe various approvals associated with the Shoalhaven Starches site.ApprovalNumberTable 1Development & Building Approvals - Shoalhaven StarchesProjectConsentAuthorityDate of ApprovalBA 84/759 Brick & Colourbond Industrial Additions SCC 1984 17 AprilBA 84/556 Cliplock Industrial Building SCC 1984 17 AprilBA 84/555 Transformer Stands SCC 1984 8 JuneBA 86/814 Pump Shed Silo & Retention Pond SCC 1986 10 JuneBA 88/1466 Brick Store Room & Shed SCC 1988 16 JuneBA 88/0858 Three Metal Clad Storage Tanks SCC 1988 26 AprilBA 88/853 Three Metal Clad Storage Tanks SCC 1988 26 AprilBA 88/2450 Metal Clad Boiler House SCC 1988 9 SeptemberBA 89/735 Brick Veneer/Metal Clad Factory Addition SCC 1989 26 AprilBA 89/3315 Metal Clad Farm Shed SCC 1989 28 NovemberBA 89/922 Brick/Metal Clad Factory Alteration SCC 1989 7 JuneBA 90/4165 Storage Ponds (2 x 11ML) SCC 1990 4 DecemberBA 91/1241 Effluent Storage Pond (1 x 27ML) SCC 1991 15 MayBA 92/5295 Metal Clad Boiler House SCC 1992 1 DecemberCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 10
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryApprovalNumberBA 91/2384Table 1 (continued)ProjectEthanol Storage and Recovery Tanks, PumpHouse and Loading BayConsentAuthoritySCCDate of Approval1992 10 JanuaryBA 93/3246 Steel Factory Building (Packaging) SCC 1993 16 DecemberBA 93/2504 Additional Starch & Gluten Dryers SCC 199323 SeptemberBA 94/1887 Flour Unloading Facility SCC 1994 15 AugustBA 93/3333 Methanol/Gasoline Denaturant Storage SCC 1994 11 FebruaryBA 94/1353 Distillery & Fermentation Tanks SCC 1994 17 JuneBA 93/3334 Electrical Switch Room Alterations SCC 1994 27 JanuaryBA 94/1969 Saltwater Pumping Station SCC 1994 31 AugustBA 94/1593 Extension of Starch Process Wet End Area SCC 1994 5 SeptemberBA 94/0648 Horse Stable Complex SCC 1994 7 AprilBA96/2080 Industrial Building Extensions SCC 1996 4 NovemberBA 97/244 Stage2 DME Plant and Refining Columns SCC 1997 14 AprilBA 97/1871 Starch Tanks and Access Ways SCC 1997 14 NovemberBA 97/721 Tank Housing Structure for Glucose Plant SCC 1997 14 OctoberBA 97/419 Lime Silo SCC 1997 20 MarchBA 97/ 787Commercial Additions - Acid Storage Tankfor Waste TreatmentSCC1997 26 MayBA 98/2080 Temporary Office Building SCC 1998 10 JulyBA 97/721Glucose Tanks, Ion Exchange Tanks, Stairand WalkwaySCC1998 24 FebruaryBA/DA 94/1887 Flour Silos SCC 2001 13 FebruaryDA 85/2595 Retention Pond at Pump House SCC 1985 20 NovemberDA 88/3155DA 91/2178Ethanol Distillery Anaerobic FermentationFacility, Associated Storage Tanks and StaffCarparkingAlcohol Outloading and Storage Facilities;Associated Fire Fighting Facilities;Landscaping; CarparkingSCCSCC1989 22 August1991 2 OctoberDA 91/1166 Effluent Storage Pond (1x27ML) SCC 1991 26 AprilDA 92/1451 LPG Facility SCC 1992 15 MayDA 92/1776 Modifications to Ethanol Distillation Plant SCC 1992 28 JulyDA 92/1738 Extensions to Existing Boiling Plant Site SCC 1992 4 NovemberDA 93/2774 Relocation of Packaging Facilities SCC 1993 5 NovemberDA 95/1041 Temporary Saltwater Pump SCC 1995 22 MayDA 94/1904 Gluten Grinding Building SCC 1995 23 JanuaryDA 97/0176Construction of a Tank Housing Structure forthe refinement of GlucoseSCC1997 25 AugustDA 98/1457 Overhead Product Loading Tanks SCC 1998 27 AugustCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 11
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryApprovalNumberTable 1 (continued)ProjectDA 99/1764 Integrated Development - Installation of 55Tonne per hour Coal Fire BoilerConsentAuthoritySCCDate of Approval1999 1 SeptemberDA 99/1069 Effluent Storage Dam No 5 SCC 1999 3 MarchDA 99/3364Temporary Portable Office Building for TwoYearsSCC1999 3 NovemberDA 98/2004 No 4 Gluten Dryer SCC 1999 30 MarchDA 99/1663DA 99/1662DA 00/2682Commercial Building Extensions - 4 xAdditional Filter TanksStorage Shed for the Purposes of RuralIndustryPI Plant Including Dryers (to be constructedin 2 Stages)SCCSCCSCC1999 31 May1999 9 April2000 11 DecemberDA 002427 Sorghum Plant SCC 2000 15 DecemberDA 00/2489 Installation of Raw Water Line SCC 2000 15 SeptemberDA 00/2682Modification of Development Consent ProteinIsolate Plant Including Dryers (to beconstructed in 2 stages)SCC2001 21 MarchDA 00/3555 Proposed Effluent Storage Pond (Pond 6) SCC 2001 27 AprilDA 02-2205 Awning - Cover for Loading of Vehicles SCC 2002 3 JuneDA 03/4140 Remote Fire Monitoring System SCC 2004 3 MarchDA 07/2529 New Gas Meter Set SCC 2007 12 OctoberDS00/1187(BA/DA94/1887)DA 7/94Use of Existing Flour Silos for the purpose ofStorageStage 3 Ethanol Expansion and installation ofa spray irrigation system for wastewaterdisposal to farm north of factorySCC2001 13 FebruaryMP 25 May 1994DA 265-8-2002DA 265-8-2002DA 223-7-2002DA 391-11-2002(MOD-90-7-2006-i)DA 223-7-2002(MOD-61-7-2007)Proposed Construction and Operation ofEffluent Storage Pond No 7Modification for Construction and Operationof Pond 7PRP No. 7 - Installation of stillage recovery,expansion of grain, glucose, starch andethanol plants and extension ofenvironmental farm irrigation area.Modification to Cooling Towers on SlabFoundationRelocation of DDG No 4 Dryer andInstallation of additional evaporatorMPMPMPMPMP2002 23 December2008 11 February2003 6 March21 st January 20032007 10 July07_0021 Flour Mill MP 2007 4 OctoberNote:SCC – Shoalhaven City CouncilMP – Minister for PlanningCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 12
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry3.0 THE SUBJECT SITE AND SURROUNDS3.1 THE SITE AND ITS SURROUNDING LOCALITYThe Shoalhaven Starches factory site is situated on various allotments of land on BolongRoad, Bomaderry within the City of Shoalhaven. The factory site, which is located onthe south side of Bolong Road on the northern bank of the Shoalhaven River, has anarea of approximately 12.5 hectares (refer Plate 1). This proposal will also involve aportion of land that the Company owns located on the northern side of Bolong Road(Lot 5 DP 825808, Lot 2 DP 538285) and the adaptive conversion of the Wet WeatherStorage Pond No. 7 to biologically treat waste waters prior to re-use in the factoryprocesses on the site or irrigation on the Environmental Farm. Pond No. 7 is situatedupon Lot 1 DP 842231.The development concerns the following parcels of land:LotDeposited Plan (DP) No.A FP 334511B FP 334511B FP 3764941 3851451 83875362 1078788201 1062668A 371386Lot 142 10697585 8258082 5382891 842231The town of Bomaderry is located 0.5 km (approx.) to the west of the factory site, andthe Nowra urban area is situated 2.0 km to the south west of the site. The “RiverviewRoad” area of the Nowra Township is situated approximately 600 metres immediatelyopposite the factory site across the Shoalhaven River.The village of Terara is situated approximately 1.5 kilometres to the south east of thesite, across the Shoalhaven River. Pig Island is situated between the factory site andthe village of Terara and is currently used for dairy cattle grazing.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 13
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 1: Aerial view of Shoalhaven Starches factory site.There are a number of industrial land uses, which have developed on the strip of landbetween Bolong Road and the Shoalhaven River. Industrial activities include a metalfabrication factory, the Shoalhaven Starches site, Shoalhaven Dairy Co-op (AustralianCo-operative Foods Ltd) (now closed down) and the Shoalhaven Paper Mill (AustralianPapers). The industrial area is serviced by a privately owned railway spur line that runsfrom just north of the Nowra-Bomaderry station via the starch plant and Dairy Co-op tothe Paper Mill.The state railway terminates at Bomaderry Railway Station with a separate, privatelyowned spur line to the factory site. Shoalhaven City Council sewerage treatment worksis situated between the railway station and the factory.The Company also has an Environmental Farm located over 1000 hectares on thenorthern side of Bolong Road. This area is cleared grazing land and contains sprayirrigation lines and wet weather storage ponds (total capacity 925 Megalitres). Table 2provides further details of the wet weather pond system. There are at present 6 wetweather storage ponds on the farm that form part of the waste water managementsystem for the factory. A seventh pond approved in 2002 is currently in the process ofbeing constructed. The proposal will result in treated waste water from the factory site,currently directed to the Environmental Farm for irrigation, to be further treated within thispond under construction prior to its reuse within the factory or irrigated on the Farm.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 14
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 2Wet Weather Storage PondsPondStorage Capacity (ML)1 112 113 334 1255 2506 5007 (as approved) 220Total Capacity1140 MLFigure 4 provides a layout of the wet weather storage ponds.The Environmental Farm stretches over a broad area of the northern floodplain of theShoalhaven River, stretching from Bolong Road in the south towards Jaspers Brush inthe north. Apart from its use as the Environmental Farm, this broad floodplain area ismainly used for grazing (dairy cattle). The area comprises mainly large rural propertieswith isolated dwellings, although there is a clustering of rural residential developmentalong Jennings Lane (approximately 1 kilometre away) and Back Forest Road(approximately between 500 metres to 1.2 kilometres away) to the west of theEnvironmental Farm; and Jaspers Brush Road, approximately 1.2 kilometres to the northof the Environmental Farm. This proposal will result in a significant improvement in thequality of waste water diverted onto the Environmental Farm.Figure 1 is a site locality plan depicting the location of the factory site and EnvironmentalFarm as well as the surrounding locality.Figure 2 is a plan of the existing factory site depicting the layout of existing plant on thesite as well as plant that has been previously approved but not yet built.Plate 1 provides an aerial view over the factory site.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 15
Shoalhaven StarchesEnvironmental FarmFIGURE 1ShoalhavenStarches FactorySITE LOCALITY PLANSHOALHAVEN STARCHES PTY LTDFACTORY ANDE<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> FARMCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 16
FIGURE 2Figure 2: Plan of Existing Factory Site Depicting Existing Plant as well as Plant that has previously been approved by not yet built.
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry4.0 CONSULTATION4.1 INTRODUCTIONThe stakeholder consultation adopted through the Environmental Assessment processsought to provide a structured, transparent and open communication with keystakeholders including the local community. It enabled the dissemination of informationabout the project; and provided an opportunity for concerns raised by governmentagencies and the local community to be identified early and addressed in the EAprocess.4.2 PRELIMINARY E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong>A Preliminary Environmental Assessment was prepared for this proposal and wasreferred to the Department of Planning as part of the process for formulating theDirector-General’s requirements (DGRs) for this project. The Department forwarded thedocument to relevant government agencies including the Department of Environment &Climate Change, Department of Water & Energy, Roads and Traffic Authority andShoalhaven City Council seeking these agencies’ requirements for the preparation of theEA. These agency requirements formed the basis for the subsequent DGRs issued bythe Department.4.3 GOVERNM<strong>ENT</strong> AGENCY CONSULTATIONRelevant government agencies consulted during the EA process included:• Department of Planning;• Department of Environment and Climate Change• Department of Water & Energy• Roads and Traffic Authority• Shoalhaven City CouncilOn-going consultation was undertaken with government agencies listed above during thepreparation of this EA and associated technical reports. This included face to facemeetings, telephone discussions, written correspondence, as well as formal consultationto ensure the EA and its associated technical papers addressed the requirements of thevarious government agencies.Annexure A to the EA includes a table that outlines the Director-General’sRequirements (DGRs) for the 5 the preparation of this EA and details where each of theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 17
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryrequirements have been addressed in this EA. Annexure B to the EA includes tablesoutline the requirements of the above Government agencies and details where theserequirements have been addressed in the EA.4.4 COMMUNITY CONSULTATIONA community consultation program has been undertaken with the assistance of TwyfordConsultants and which included the following:• Several meetings with the Community Consultation <strong>Group</strong>. The CommunityConsultation <strong>Group</strong> was set up following and in accordance with the Minister’sapproval for the Pollution Reduction Program (PRP) No. 7 in 2003. The CommunityConsultation <strong>Group</strong> includes resident representatives from Nowra, Bomaderry,Terara and the ‘Backforest Road’ rural area to the east of the Company’sEnvironmental Farm.• Set up an exhibition of the proposal at the Shoalhaven Expo which was open to thepublic on Saturday 26 th July 2008. This included holding an open seminar forinterested persons.• Community briefing meetings with specific community groups including ShoalhavenBusiness Chamber Executive, Riverwatch, Australian Conservation Foundation,Shoalhaven River Alliance, Bomaderry Creek Landcare, Shoalhaven LandcareAssociation, Shoalhaven City Council (Councillors and senior staff), and the AreaConsultative Committee.• Advertisements in the local print media (South Coast Register) detailing theproposal and providing details where further information about the project could beobtained.• The preparation and distribution of a Community Newsletter providing details of theproject. This newsletter was distributed to residents within Bomaderry, Nowra,Terara and rural areas surrounding the facility and Environmental Farm. A total of5000 newsletters were printed, with 3700 distributed in the local area; with theremainder distributed to the Community Consultation <strong>Group</strong>; briefing meetings andthe Shoalhaven Expo.• Separate Fact Sheets were also prepared in terms of the proposed waste watertreatment plant; odour management plan; and ethanol upgrade project. These factsheets provided further information about these specific facets of the project.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 18
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• The <strong>Manildra</strong> website was also set up to provide details of the project includingaccess to the above Fact Sheets and details of where additional information couldbe obtained.• Twyford Consulting also established and staffed a 1800 telephone number to takecalls, questions and comments from the community.• Twyford Consulting also utilised their specialist community engagement databasesoftware (Darzin) to record input from the community.As a result of the community consultation program the following is a summary of theissues that were identified (with comments explaining where these issues are addressedin the EA documentation included). Annexure R to this EA is a report prepared byTwyford Consulting providing greater detail about the community consultation approachand issues that were raised.OdourThroughout the consultation process the issue of odour and odour control has been themost significant, both in terms of number of mentions, and the passion with which theyspoke about it. Members of the local community said that they have lived with odoursfrom the factory and the environmental farm for many years. For many of these people,the key issue for the proposed project is controlling the odours. A number of differentpeople and organisations throughout the consultation process indicated strong supportfor the project on the basis that it would resolve the long-running issue of odour. Severalasked how they could best indicate their support to for the project to the Department ofPlanning.CommentsThe EA is supported by an Odour Assessment and includes recommendations for odourmanagement controls to be implemented both in terms of the existing plant and theproposed upgrade works. This issue is addressed in detail in Section 7.1 of the EA andthe Air Quality (Odour) Assessment forms Annexure M to this EA.WaterThe next most significant issue is that of water use, treatment, irrigation, and the impactsof the proposed project on these. Unlike the issue of odour, water-related issuesgenerated more interest and curiosity than passion. People are interested in theproposed treatment of water, while they are more passionate about resolving odourissues. In many ways water issues relate back to the odour issue, as it is the existingCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 19
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrywater treatment regime that is responsible for some of the odour control problems.Issues related more specifically to water use and treatment included those concerningthe recycling of water, water extraction from the river, the volume of water purchasedfrom Council, whether the volume of water to be irrigated is to be increased ordecreased. Strong support was expressed for the proposal to recycle water. Someconcern was expressed about the potential impacts of continuing irrigation on the watertable.CommentsThe proposed development will result in a reduction in the level of potable water utilisedby the factory processes and will involve the introduction of a water treatment plant thatwill enable 4.5 ML of treated waste water to be reused in the factory processes. Thisissue is addressed in Section 7.3 and 7.5.1 of the EA.Issues relating to odours emanating from irrigation waters are discussed in Section 7.1and Annexure M to the EA.Section 7.4 of the EA addresses issues pertaining to the irrigation and storage of treatedwaste waters and the EA is supported by specific agronomic investigations (AnnexuresO(i) and O(ii)) which address the adequacy of treated waste water for irrigationpurposes.NoiseAnother issue that emerged was that of noise, primarily of the operation of the plant.Questions were asked about the manner in which noise would be controlled, particularlyfrom the proposed packing plant which is closer to residential areas than the existingfacility.CommentsNoise impacts associated with the construction and operation of the project arediscussed in Section 7.6 of the EA and the EA is supported by an Acoustic Assessmentincluded in Annexure Q(i) and an Acoustic Audit of the site in Annexure Q(ii).Ethanol ProductionA third important issue concerns the process by which ethanol is produced at the plant.There is a level of awareness in the community that ethanol in many parts of the world isproduced from grains such as corn and wheat, with a subsequent impact on foodavailability and pricing. There is concern that the process at the Shoalhaven Starchesfactory is similar. Members of the community are concerned that the proposal will useCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 20
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrymore grain, exacerbating the impacts of food for fuel production. The idea that ethanolproduction impacts food availability and prices appeared to generate higher levels ofconcern throughout the consultation than any issue apart from odour control.CommentsThis issue is discussed in terms of the justification of the proposal in Section 5.3 of theEA. In this regard it is important to note that unlike other ethanol producers who produceethanol directly from grain and thereby compete with other industrial users of grain suchas feed lots. At Shoalhaven Starches it is lower grade starch and wastage from thestarch, gluten and syrup production processes that when combined feed thefermentation and distillation stages of ethanol production. In this way ethanol producedat Shoalhaven Starches is a value added product processed from the Company’s wastestream.The primary purpose for the majority of raw materials delivered to the site is for theproduction of gluten and starch which are used in a range of industries including food,paper, cardboard, confectionery, soft drink, beer and other manufacturing industries.Traffic and TransportTraffic and transport issues arose during the consultation. Questions were asked aboutthe impact of truck and rail movements on local road and rail infrastructure.CommentsThe impacts of heavy vehicle movements associated with the proposed ethanol upgradeproject are addressed in Section 7.7 of the EA and Section 7.6 in terms of the amenityimpacts of heavy vehicle movements.Employment and EconomyAnother issue about which there was some discussion is that of economic impact andjob creation. The general feeling was overwhelmingly that the impact of the proposeddevelopment on the regional economy would be positive.CommentsSection 5.3 of the EA provides a justification for the project and including an outline ofthe positive economic effects that both the existing and proposed operations will have onthe local, and indeed regional and state economies. Section 2.2 outlines the existingoperating workforce of the site. These sections of the EA discuss the employmentgenerating nature of the project both in terms of construction and operation.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 21
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryVisual impact−−Visual impacts of existing and proposed plant are significant. Treeplanting would reduce it.Important that the bridge over Bolong Road is not an eyesoreCommentsSection 7.12 of the EA addressed the visual impacts of both the existing operations andproposed development and makes recommendations with respect to minimising thevisual impacts of the development. These recommendations are incorporated ascommitments to be undertaken by the Company in Section 8.3.17 of the EA.4.5 REVIEW OF DRAFT E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> A<strong>SSESSM</strong><strong>ENT</strong>In accordance with standard procedures a copy of the draft Environmental Assessmentreport (EA) document was referred to the Department of Planning (DoP) for review. TheDepartment referred this draft EA to the Department of Environment and ClimateChange (DECC), Roads & Traffic Authority, Department of Water and Energy (DWE)(previously DNR) and Shoalhaven City Council (SCC) for review.Annexure C to the EA outlines the issues raised by government agencies (DoP andDECC) received during the designated review period in terms of the draft EA and wherematters raised are outlined in the EA.4.6 ABORIGINAL STAKEHOLDER CONSULTATIONConsultation was carried out in accordance with DECC National Parks & Wildlife Act1974 - Part 6 Approvals - Interim Consultation Requirements for Applicants guidelines aspart of the Aboriginal Heritage Assessment carried out by South East Archaeology(Annexure D). This report included consultation with the Nowra Local Aboriginal LandCouncil and Jerrinja Consultants.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 22
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry5.0 THE PROPOSED DEVELOPM<strong>ENT</strong>5.1 OBJECTIVES OF THE ETHANOL UPGRADEThe use of ethanol as a motor vehicle fuel (or fuel additive) has many benefits including:• it is a renewable fuel and lessens reliance on fossil fuels;• it reduces greenhouse gas emissions and other air pollutants such as carbonmonoxide and particulates;• it reduces imports of oil and stimulates regional and local economies if producedlocally.The Federal and State Governments have introduced a range of initiatives to encouragethe increased use of ethanol as a fuel additive.The NSW Government has recently mandated the blending of 2% ethanol into the totalvolume of petrol sold in NSW as a first step towards a 10% ethanol content in 2011,The <strong>Manildra</strong> <strong>Group</strong> is planning to increase its ethanol production capacity to meet theexpected increase in demand for ethanol arising from the NSW Government’s timetablefor implementation of its further ethanol initiatives by upgrading its existing ethanol plant,located at the Shoalhaven Starches Plant at Bomaderry.Shoalhaven Starches plans to increase ethanol production at its Bomaderry plant fromthe current approved 126 million litres per year to 300 million litres per year and toundertake other plant upgrades at that facility to improve its overall competitiveness andenvironmental performance.5.2 E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> AUDITThe Land and Environment Court on the 2 November 2006 handed down a judgementthat required Shoalhaven Starches to engage a suitably qualified person to conduct acomprehensive audit of the factory and Environmental Farm in order to identify andquantify all odours generated by the operations, and to provide recommendations for theimproved management of odours. Shoalhaven Starches engaged GHD Pty Ltd toconduct the environmental audit.The objective of the environmental audit program was to address the requirements ofCondition 2 of Annexure B to the Land and Environment Court judgement of 2 November2006, which states:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 23
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(2) For the purposes of ensuring no offensive odours as defined by theProtection of the Environment Operations Act 1997 are emitted fromthe premises, the defendant must engage a suitably qualified expert orexperts to conduct an environmental audit that must:(a)(b)(c)(d)(e)(f)(g)(h)(i)(j)(k)(l)Identify and list every process, activity and substance stored orused at the premises that generates or has the potential togenerate odours.Benchmark each process and activity identified at (a) againstcomparable international best available technology and industrybest management practice relating to the control of odour fromthat process and activity.Identify and list every actual and every potential source ofoffensive odour at the premises. This must include all point,diffuse and fugitive sources.Identify for each odour source identified at (c) the cause orcauses of the odour.Quantify for each odour source identified at (c) the actual andpotential nature, strength and duration of occurrence of the odourin accordance with the publication “NSW DEC 2005 ApprovedMethods for the Sampling and Analysis of Air Pollutants in NSW”.Model for each odour source identified at (c) the impacts andpotential impacts of the odour at all sensitive receptors inaccordance with the publication “NSW DEC 2005 ApprovedMethods of the Modelling and Assessment of Air Pollutants inNSW”.Identify all available options to prevent the generation ofoffensive odour for each actual and potential odour sourceidentified at (c).Where at (g) prevention is not possible, identify all availableoptions to minimise the generation of offensive odour for eachactual and potential odour source identified at (c).Describe, quantify and model the likely environmental impacts ofimplementing each option identified at (g) and (h).State for each actual and potential odour source identified at (c),the preferred option for the prevention or minimisation of thegeneration of offensive odour from that source.Review the adequacy of policies, procedures, standards,practices and training at the premises in relation to environmentalperformance and in particular odour management. Where anyinadequacy is found to exist recommend options to address eachinadequacy.Produce an audit report that details all of the above.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 24
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe Environmental Audit has now been completed and submitted to the Land andEnvironment Court and DECC. The DECC have indicated that the recommendations ofthe audit will need to be undertaken prior to the commissioning of the Ethanol Upgradeproject. The proposed ethanol upgrade has been devised to integrate with the odourmanagement plan arising from the Environmental Audit.5.3 JUSTIFICATION FOR PROJECTAs outlined in Section 5.1 the use of ethanol as a motor vehicle fuel (or fuel additive) hasmany benefits including:• it is a renewable fuel and lessens reliance on fossil fuels;• it reduces greenhouse gas emissions and other air pollutants such as carbonmonoxide and particulates;• it reduces imports of oil and stimulates regional and local economies if producedlocally.Recognising these benefits, Federal and State Governments have introduced a range ofinitiatives to encourage the increased use of ethanol as a fuel additive. The NSWGovernment recently mandated the blending of 2% ethanol into the total volume of petrolsold in NSW as a first step towards a 10% ethanol content in 2011. This proposal seeksto meet the expected increase in demand for ethanol arising from the NSWGovernment’s timetable for implementation of its further ethanol initiatives.In doing so the project also seeks to implement an Odour Management Plan for thefactory site and Environmental Farm which has been based upon the findings of theEnvironmental Audit that has been undertaken for the site. The Odour ManagementPlan will seek to substantially reduce odours that are generated from the site. Theimplementation of the proposed Ethanol Upgrade Project will be integrated with theOdour Management Plan for the overall site.The proposal also includes a comprehensive Waste Water Treatment Plant that will havethe volumetric and operational capacity to treat the total waste water flow and organicload from the factory site. This plant will incorporate sequential anaerobic and aerobicdigestion facilities. This treatment process will enable over half of the waste watersgenerated by the site to be re-used within the factory processes. The remainder will beirrigated onto the Company’s Irrigation Farm.The ability to re-use treated waste waters within the factory process will result in asignificant reduction in demand in the amount of water (treated and raw water) that iscurrently imported to the site from the Council’s water system.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 25
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryIn addition, the amount of treated waste waters that will be required to be irrigated ontothe Environmental Farm will not only be able to be reduced, but the quality of the treatedwaste waters will be significantly improved. This will have the additional benefit ofreducing the potential for odours to be generated from the Environmental Farm.It should also be noted that methane generated from the anaerobic waste watertreatment processes within this plant will be re-directed and used as a heating fuel in theCompany’s boilers. This will reduce the amount of coal that will be required to be usedon site; thereby reducing greenhouse gas emissions that would otherwise be created.All the above measures will ensure the long term sustainability of the ShoalhavenStarches factory site at Bomaderry.As outlined in Section 5.1, flour that is transported and produced on the site is processedinto gluten and starch. Gluten is a high protein food additive for human consumption.Starch processed at the plant is a necessary ingredient used by food, paper, cardboardand other manufacturing industries.Starch is also used in the production of syrups on the site. The syrups plant productsinclude glucose and brewers syrup. These products are essential for the production offoods, confectionary, chocolate, soft drink, fruit juice and beer.In a broader strategic context the Shoalhaven Starches factory is a key supplier ofingredients to many industries within NSW. The products created at the ShoalhavenStarches Plant at Bomaderry are essential ingredients for a wide range of industrieswithin NSW and Australia. These industries depend significantly upon productsproduced at the Shoalhaven Starches Plant, products that are not in many casesproduced elsewhere. Were the Shoalhaven Starches plant to cease operations such acessation would have significant adverse implications to other industries within the Stateand Australia as a whole. This was one of the reasons why the NSW Government in1993 identified the Shoalhaven Starches Plant at Bomaderry as a State Significant Site.Other ethanol producers produce ethanol directly from grain and thereby compete withother users of grain such as food manufacturers and stock feed lots. At ShoalhavenStarches it is the lower grade starch and wastage from the starch, gluten and syrupproduction processes that when combined feed the fermentation and distillation stagesof ethanol production. In this way ethanol produced at Shoalhaven Starches is a valueadded product processed from the Company’s waste stream.As outlined above the primary purpose for the majority of raw materials delivered to thesite is for the production of gluten, starch and glucose which are used in a range ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 26
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryindustries including food, paper, cardboard, confectionery, soft drink, beer and othermanufacturing industries.The total raw material input (flour and grain) into the Shoalhaven Starches’ processesassociated with this proposal is equivalent to 1,155,000 t/a. Increasing the ShoalhavenStarches’ ethanol production to 300 ML per annum would be equivalent to 240,000 t/a.The remaining product output (starch, gluten, glucose and DDGS) would therefore beequivalent to approximately 955,000 t/a. The majority of production output from theShoalhaven Starches’ plant following the ethanol upgrade project will continue to involvefood related production. Ethanol production will involve only approximately 20% of thetotal production output from the Shoalhaven Starches’ plant.Clearly it is evident that unlike other ethanol producers which utilise food grain crops tosolely produce ethanol fuel – this proposal seeks to mainly produce food (and other)products from flour; with only a comparably small quantity of grain used directly toproduce ethanol. In effect the Shoalhaven Starches’ operations seek to value add alongtheir production processes, including the processing of what would otherwise be a wastestream into a valuable biofuel such as ethanol.Apart from the important role that the Shoalhaven Starches Plant plays in the NSWeconomy, the factory plays a particularly important role in the local Shoalhaven (andSouth Coast) economy. The Shoalhaven Starches factory site at Bomaderry directlyemploys 250 employees; with this project creating an estimated additional 25 ongoingpositions. It is also estimated that up to 150 jobs will be created for the estimated12 month construction phase.Such employment generation needs to be seen in a broader context with the recent lossof significant employers within the Shoalhaven including Gates Rubber at South Nowra,the recent closure of the Dairy Farmers Co-operative operations and the reduction inproduction (and also employment) at the Australian Paper Mill, (both operations situatedalong Bolong Road). Shoalhaven Starches is one of the few major employers within thisregion seeking to generate additional employment for the local economy.This project will ensure the on-going operations of the Shoalhaven Starches plant atBomaderry in a commercially and environmentally sustainable manner. In doing so theethanol upgrade project will be integrated into an Odour Management Plan for the site,that will result in significant reduction in odours that emanate from the site. The projectalso includes the implementation of a waste water treatment plant that will treat wastewaters to a higher quality standard where over half of the waste water treated will beCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 27
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryable to be re-used in the factory process on the site. The remainder will be able to beirrigated in a sustainable manner on the Company’s Environmental Farm.5.4 SUMMARY OF PROPOSALTable 3 below provides a summary of the proposed development.Factory ComponentTable 3Summary of ProposalProposed Works Associated withEthanol Upgrade ProjectExistingApprovedProductionStarch Plant Dryer, including grinder. 10,000 tonnes perweek flourprocessingGrain PlantEthanol PlantStillage Recovery(DDGS Plant)Packing PlantNil. Existing equipment hassufficient spare capacity.3 additional fermenters andassociated additional coolingtowers (2).Molecular sieves and associatedadditional cooling towers (2).6 additional DDGS Dryers (andassociated equipment including10 decanters).2 additional evaporators.Proposed extension to DDGSLoadout.2 additional storage tanks (15 mheight).Overhead Services GantryChemical Storage.DDGS Pellet Plant.Bioscrubber vessel.Motor Control Centre (MCC) Room.Additional Cooling Towers.Construct new Packing Plant andContainer Loading Facility on Lot 5DP 825808.Provide new additional rail siding(270 m long).Provide pedestrian and serviceoverbridge to connect packing plantsite to factory site.Weighbridge.3864 tonnes perweek (552tonnes/day)of grain126 ML p.a.ethanol2030 tonnes perweek DDGSProposedProduction20,000 tonnes perweek flourprocessing6720 tonnes perweek(960 tonnes perday) of grain300 ML p.a. ethanol6400 tonnes perweek DDGSProduction at the packing plant isdetermined upon the type and size ofpackaging and market demand.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 28
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 3 (continued)Factory ComponentProposed Works Associated withEthanol Upgrade ProjectExistingApprovedProductionProposedProductionEnvironmental FarmAdapt Approved Pond No. 7 as anAnaerobic and Aerobic WasteWater Treatment Pond comprising:Approximately 8.1ML per day.• Bulk Volume Fermenter (BVF)90 type reactor (90 MLcapacity).• Sulphide Oxidation (SO) Basin(103 ML) (irrigation water).• Membrane Bio-Reactor (MBR)(4 ML).• Reverse Osmosis (RO) (waterto be re-used in factory).Power GenerationGas-fired Boiler100 t/hGas-fired Co-generator40 MWPipelines• Proposed treated water pipelinefrom Paper Mill to site.• Proposed methane gas pipelinefrom Waste Water TreatmentPlant to factory.• Proposed electricity linebetween Waste WaterTreatment Plant and site.N/AN/A(Distance of above pipelines about2 km)• Proposed product pipelinebetween proposed PedestrianOverpass and Packing Plant.Fire System• Shed (pumps).• 2 water reservoir tanks(capacity 1.5 ML each).N/AN/AAs outlined in Section 5.2 of this EA the proposed ethanol upgrade project has beendevised to integrate with the odour management plan arising from the EnvironmentalAudit. These works will be discussed in greater detail in Section 7.1 of the EA. Table 4provides a brief summary of the proposed works outlined in the odour management planas they relate to each of the factory components, including those associated with theproposed ethanol upgrade.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 29
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 4Summary of Proposed Works associated with Odour Management ControlsFactory ComponentExisting FactoryDDG PlantDistilleryEthanolFlour MillGlucose PlantStarch PlantProposed Ethanol UpgradeDDG PlantEthanol PlantStarch Plant• Bioscrubber.Proposed Odour Control• Pellet Packing Plant.• Housekeeping actions (eg. ductwork cleaningand maintenance).• Installation of wet legs on tanks to condensatevapour emissions.• Improvements to industrial ventilation.• Curtains to be installed DDG loadout doors.Bioscrubbers (Stage 3 if required).• Decommissioning cooling towers.• Installation of wet legs on tanks to condensatevapour emissions.Improve dispersion from discharge points.Installation of wet legs on tanks to condensatevapour emissions.• Housekeeping actions (eg. ductwork cleaningand maintenance).• Improve dispersion from discharge points(such as gluten dryers, starch dryers).Bioscrubber.Improve dispersion from discharge points.Housekeeping actions (eg. ductwork cleaning andmaintenance).Figure 3 is a site plan depicting the proposed additions to the factory site.Figure 4 outlines the configuration of the wet weather storage pond No. 7 located on theCompany’s Environmental Farm and the proposed works associated with the wastewater treatment plant.Figure 5 includes elevation details of the proposed plant upgrade.Figure 6 provides a flow chart depicting the proposal in terms of the processes at thesite.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 30
Figure 3: Site plan depicting proposed additions to Factory site.FIGURE 3
Figure 4: Configuration of Wet Weather Storage Pond No. 7FIGURE 4
Figure 5: Elevation Details of the Proposed Plant Upgrade
Figure 6: Flow Chart Depicting the Proposal in Terms of the Processes at the Site.
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry5.5 THE STARCH PLANTFlour is pneumatically conveyed from storage bins to the starch plant, where the flour ismixed with water and separated into two components:(i)(ii)Gluten, which has a high protein content (about 75%) is sold to local and exportmarkets.Starch, which is processed and then directed to:(a)(b)(c)(d)dry starch markets, both local and export;domestic liquid starch markets;the glucose plant which processes the starch further to produce glucose andother products;the ethanol plant, where the starch is converted to sugars, which arefermented and distilled to produce ethanol.This proposal will require an increase in the amount of flour transferred to the site forprocessing from the current approved 10,000 tonnes per week to 15,000 tonnes perweek, in addition to the 5000 tonnes per week of flour to be produced on-site by theCompany’s previously approved flour millShoalhaven Starches indicate that existing plant within the starch and gluten productionplants; and approved flour mill, will be largely able to accommodate the increase in flourprocessing associated with this proposal.An additional dryer and grinder will need to be installed adjacent to the proposed DryerNo. 5 (approved under the previous PRP No. 7 approval). This dryer and grinder wouldhave similar throughput and operating parameters as the existing dryers.Air emissions from these processes would be ducted to and passed through fabric filters(located in a baghouse) to reduce particulate matter emissions before being dischargedvertically to air via a stack approximately 33 m above ground level (approximately 5 mabove the height of the supported building).Ductwork associated with these processes would be designed with consideration to thegood practice ductwork design and maintenance outlined in the Audit Report; inparticular, measures to minimise contamination in the ductwork in order to reduce thepotential for the generation of malodorous emissions.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 31
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry5.6 THE GRAIN PLANTWaste product from the starch, gluten and syrup production processes at the factory arecombined to feed the fermentation and distillation stage in the ethanol productionprocess. The outputs of the process are fuel and industrial grade ethanol. The residuefrom the ethanol process is directed to the Stillage Recovery Plant where the solids areremoved for high protein cattle feed and the clean water is directed to the EnvironmentalFarm for irrigation purposes.The distillery at Shoalhaven Starches is supplied feed material from 2 sources on thesite:• Starch from the starch plant; and• Crushed grain from the grain processing plant.These feed streams are fermented and distilled in the distillery. The product from thedistillery is ethanol. The by-products from this process are the remaining grain husksand “unfermentables” from the feed stream; carried by water.Grain is also used as a coarse fibre in the feed to the DDGS dryers as part of the stillagerecovery process to dry soluble solids recovered from waste water by evaporation. Ifinsufficient fibre is fed into the dryers, the moist syrup fed into the dryers cannot beadequately absorbed and the product becomes “sticky”. After a period the syrup sticksto the heating surface of the dryer resulting in a loss of drying capability.There is therefore a need to mix grain fibre into the syrup to ensure that the mixture issufficiently friable to enable the DDGS Dryers to operate efficiently.In order to enable sufficient grain for the increase in ethanol production at the site it isproposed to increase the intake of grain from the currently approved 552 tonnes per dayto 960 tonnes per day. According to Shoalhaven Starches existing plant and equipmentwill have sufficient spare capacity to accommodate this increase in grain intake.5.7 ETHANOL PLANTThe ethanol plant utilises waste from the starch, gluten and syrups sections of the plantto feed fermentation and distillation, which produces ethanol. In effect the ethanolproduction process comprises an integral component of the Company’s waste watertreatment process. An essential difference therefore between ethanol produced byShoalhaven Starches and ethanol produced by other producers, is the ethanol producedat Shoalhaven Starches is a value added product from the Company’s waste streamfrom the production of gluten and starch. The ethanol produced from waste starch doesCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 32
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrynot involve the diversion of grain from other markets (such as livestock feed). Indeed afurther value added product from the waste stream from the production processes at thePlant is dried DDGS which provides an alternative stock feed product. (This will bediscussed further in Section 5.8 of this EA.)The starch from the starch plant and grain crushed from the grain plant are mixed in thefermentation plant and the starch in this feedstock is converted to sugars, which are thenfermented to produce ethanol. The fermentation process is a natural process whereyeast converts the incoming sugars to ethanol. This process requires a residence timeof approximately 50 hours, which necessitates the use of large holding tanks calledfermenters, which allow time for the process to take place producing a “beer” to feed thedistillery.The distillery (refer Plate 2) separates the ethanol from the “beer” in the “beer” columnthen purifies the ethanol by passing it through rectification columns and molecular sieveswhich remove the remaining water, which is not removed by the “beer” column. Theethanol is then ready for sale.Plate 2: Existing Distillery and Cooling Towers.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 33
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryIn order to increase ethanol production from the current approved 126 megalitres perannum to 300 megalitres per annum Shoalhaven Starches envisage that much of theexisting and approved plant associated with the distillery will have sufficient sparecapacity to accommodate the increase in production. In order to increase productionhowever it will be necessary to install:• an additional 3 fermentation tanks;• additional cooling towers (4);• additional molecular sieves (2) and associated additional cooling towers (2).It is proposed to locate the three new fermentation tanks (each with a capacity of 3 ML)and associated cooling towers at the eastern extremity of the factory site, within thevicinity of existing approved fermenter tanks. (Refer Plate 3 – view of existingfermenters).Additional molecular sieves (refer Plate 4) with associated heat exchangers, pumps andcooling towers will be installed within the existing ethanol distillation plant structure,adjacent to existing molecular sieves. Molecular sieves receive industrial grade ethanolfrom the storage tanks, process it to fuel grade ethanol and then pump it back to storage.The molecular sieves essentially remove water content from the industrial grade ethanol.The new molecular sieves will operate in parallel with the existing molecular sieves.Plate 3: View of Existing Fermenters.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 34
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 4: View of existing Molecular Sieves.The additional fermenter tanks would be located next to the existing fermenter tanks.Each fermenter tank will be fitted with an exhaust stack (17 m above ground level) thatwill allow free vertical discharge.The proposed cooling towers will be located in an area away from potential sources ofcontamination and would only use fresh make-up cooling water. As such, odouremissions from these cooling towers are anticipated to be negligible.Due to the ethanol upgrade it is proposed to upgrade the site’s fire fighting system. Thisupgraded system will be sited on land directly opposite the ethanol plant and willcomprise a building to house pumps and 2 water tanks for water reserve supply. Eachtank will have a capacity of 1.5 ML.5.8 WASTE WATER TREATM<strong>ENT</strong> AND DISPOSAL5.8.1 Stillage RecoveryThe 2003 approval by the Minister for Planning of the Company’s Pollution ReductionProgram No. 7 introduced a Stillage Recovery process into the production process at theplant. Stillage recovery essentially seeks to improve the system whereby suspendedand soluble solids are removed from the Company’s waste water system.This process includes the use of decanters, evaporators and DDGS dryers.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 35
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryDecanters (refer Plate 5) are essentially mechanical separation devices, which operateby centrifugal separation process that separates out the unfermented suspended solidsin stillage, ie. the waste liquid left over from the distillation of ethanol. The increase inethanol production will require the installation of an additional 10 decanters in a newpurpose built building to the west of the site.Plate 5: DecanterEvaporators (refer Plate 6) are designed to reduce the water content of “thin” stillageafter it passes through the decanters and the coarse solids are removed. Theevaporators operate by mechanical vapour recompression. The thin stillage from thedecanters is fed into tubes within the evaporator and heated by recompressed steam.The water within the overflow is heated to a point where the water evaporates and isseparated from the remaining solids, which remain as syrup. The liquid (ie. condensate)is captured and directed to the Environmental Farm for irrigation.The existing and approved evaporation plant, according to Shoalhaven Starches, willlargely have sufficient capacity to accommodate the increase in production of ethanolassociated with this proposal. Only one additional evaporator will need to be erectedwithin the existing evaporation plant to accommodate this proposal.The syrup product is directed to DDGS dryers (refer Plate 7) for further drying. TheDDGS dryer is essentially a barrel in which a bundle of steam heated tubes are rotatedat low speed. Evaporator concentrate (syrup) and decanter concentrate (wet insolublesolids) are fed into one end of the barrel and traversed through to the other end byshovels. Heat from the tubes removes moisture.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 36
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 6: Existing Evaporator.Plate 7: Existing DryerCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 37
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryDried DDGS is removed from the barrel and conveyed to the storage room for furtherloading into trucks.The proposed increase in ethanol production at the plant will require 6 additional DDGSdryers with the associated 10 new decanters to be installed within the western portion ofthe site. It is expected that the new plant associated with the stillage recovery processwill increase dry product from the current approved 2030 tonnes per week to 6400tonnes per week.The six (6) new dryers and associated decanters will be fitted with the requiredequipment to meet statutory emission requirements for particulate and odour emissions.The product from the drying process results in a dry product that is sold for use as stockfeed.The increase in production of DDGS will require the existing DDGS load-out to beextended to enable the storage of the additional product.The proposed equipment would be housed in a new building located to the west of theexisting DDG plant area. The building would be maintained under slight negativepressure in order to minimise fugitive odour emissions from the building.Discharges to air from the dryers, decanters and associated equipment will be collectedand ducted to bioscrubbers for treatment. The bioscrubbers are to be situated adjacentthe building housing the dryers and associated equipment.The proposed evaporators are not, themselves, direct sources of odour emissionshowever, the condensate formed during the evaporation process is a potential odoursource. Hence, air emissions from the DDG (liquids-line) storage tanks handlingcondensate will also be ducted to the bioscrubber for treatment.Shoalhaven Starches also propose to install a DDGS Pellet Plant, which essentiallyseeks to provide the Company with a greater flexibility to meet market demand for thisproduct. It should also be noted that the installation of a DDGS Pellet Plant was one ofthe recommendations of the Environmental Audit on the basis that it would reducefugitive odour and dust emissions currently associated with the handling and storage ofthe granular DDG product.It is proposed to site the Pellet Plant partly adjacent the existing DDGS Dryer building.The plant will consist of a series of bins and mills to process the loose DDGS materialinto pellets.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 38
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe Pellet Plant will consist of:• A pellet mill, housed in an extension to the existing DDG storage area. The pelletmill machinery would include two discharges (through baghouses), each with adischarge rate of approximately 500 m 3 /min.• An internal mill conveyor under negative pressure and vented through a baghouseat a discharge rate of approximately 12 m 3 /min.• An enclosed product conveyor to transport the pelletised DDG from the pellet mill tothe existing DDG storage facility; and• A pellet out-load system, which would be aspirated through a baghouse with anominal discharge rate of approximately 20 m 3 /min.Given the potential for offensive odour emissions from the DDG plant process, airemissions from the above discharge points will be ducted to the bioscrubber via a fabricfilter before being discharged to air.Essentially the pellet plant will process granular DDGS material into pellets to betterenable this product to meet export demand. The existing granular DDGS material ismore suited to domestic markets. The processing of this granular material into pelletswill enable the Company to export this material overseas during periods when the localdemand for DDGS is reduced. This proposal essentially seeks to provide greaterflexibility for the processing of DDGS on the site to meet the demands of both the localand export markets.The additional benefit with the installation of a DDGS Pellet Plant is the anticipated rolethat such a plant will have in reducing odours that emanate from this part of the site.The Environmental Audit specifically recommended the installation of a DDGS PelletPlant.The Pellet Plant will provide an alternative means of processing the DDGS material thatis processed on the site into an alternative product for re-sale and re-use.Essentially DDGS from the DDGS Dryers that would otherwise be directed to the DDGSload out as granular material will be able to be re-directed to the Pellet Plant.In order to operate the additional plant it is proposed to construct an overhead gantrylinking the main factory site with the proposed additional plant at the DDGS site. Thisgantry will house piping for additional services required for the additional plant. Thisgantry is required as the provision of underground services is not practical due to:• The need to cross Abernethy’s Creek.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 39
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• The location of existing buildings and services within this area.• The service gantry includes steam pipes which should not be placed underground.Such pipework if placed underground would need to be placed in a tunnelconstruction which would not practically be possible to be sited through the subjectsite.A Motor Control Centre (MCC) is also proposed to be sited in this part of the complex.The MCC will house transformers and switch gear to provide power to this area.In addition to the proposed Pellet Plant, in accordance with the Company’s OdourManagement Plan prepared in response to the Environmental Audit, a number ofmeasures are initially proposed to reduce odours in the DDGS Plant including:• improving the DDG Dryer fume handling system;• covering or venting the condensate tank;• better housekeeping initiatives;• directing odour airstreams to a Bioscrubber.Not all of these measures require development approval. It is proposed to measure theeffectiveness of these measures. If these measures are found to be insufficient, furthermeasures as proposed by the Environmental Audit will be implemented.5.8.2 Waste Water DisposalThe increase in ethanol production will result in an increase in the volume of water usedin the upgraded plant processes and a subsequent increase in waste water.The Company has been investigating various options with respect to the treatment andre-use or disposal of additional waste water generated by the proposed ethanol upgrade.The Company proposes to treat its waste water sequentially through anaerobic andaerobic digestion systems located and incorporated within one of the existing wastewater storage ponds to fully treat all organic material and eliminate the odour generatingpotential. The proposal therefore seeks to adapt the approved Wet Weather StoragePond No. 7 located upon the Company’s Environmental Farm for this purpose – referPlate 8.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 40
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 8: Aerial view of proposed Waste Water Storage Ponds.Anaerobic digestion is a biological process whereby organic wastes are broken down bymicro-organisms adapted for life and growth in the absence of dissolved oxygen that isunder anaerobic conditions. These micro-organisms obtain oxygen for their lifeprocesses from the combined oxygen contained within the organic materials andconcomitantly generate a mixture of methane and carbon dioxide. So as the BOD isdigested, biogas containing energy-rich methane is produced. It is proposed to re-directthis biogas for use as an energy source in the Factory’s operations. The process set upin one of the ponds has been selected because of its ability to digest both dissolved andparticulate organic material. The large volume of the pond will also allow substantialfluctuations in both the quantity and quality of the incoming waste water to be averagedout. Anaerobic digestion is used as the first step of the overall digestion because it isable to handle high concentrations of organic material. This step will not eliminate all theorganic material but will reduce it to a level that can be further processed to almostcomplete removal by aerobic digestion.The preferred anaerobic digester format, a Bulk Volume Fermenter (BVF), will comprisea 90 ML lagoon/pond that will be completely covered with a gas tight floating cover.Infrastructure within the pond under the cover will facilitate the action of the anaerobicmicro-organisms responsible for digestion of the soluble and suspended organic matter.The average hydraulic residence time in the BVF will be about 10 days. Metabolism ofthe organic matter will generate a mixture of methane and carbon dioxide. A smallCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 41
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrynegative pressure will be maintained under the cover by continuously withdrawing thegas mixture (biogas) for use as an energy source.The BVF system was selected as it eliminates the need for any primary treatment suchas dissolved air flotation and can accept soluble and suspended organic solids producedat the factory. It will generate little waste sludge of its own, with the sludge/biomassgenerated being digested downstream by the aerobic system. The large size of the BVFand the volume of biomass provide a reactor that can absorb potential shock loadings ofpH, temperature or solids content. Biogas will be drawn off uniformly and continuouslyfor use in the boiler.Residual soluble organic matter in the effluent from the BVF is further removed underaerobic conditions by micro-organisms that metabolise this soluble organic matter togenerate biomass (microbial cells) and treated effluent. This process will occur in twoparallel systems, a Membrane Batch Reactor (MBR) and a sulphur oxidising (SO) basin.The aerobic digestion process utilises micro-organisms that can utilise low levels ofsoluble organic material as an energy source for life and growth. The consequence ofthis activity is the generation of carbon dioxide and insoluble biomass ( the bacterial cellsthemselves) while continually depleting the content of soluble organics from itssurroundings until there is little to none remaining. At this point the biomass can beremoved and the water released for disposal or re-use.It is proposed to modify the approved Pond No. 7 to enable the sequential anaerobic andaerobic processes. Residual volume will be used as additional wet weather storagecapacity. Pond 7 currently provides a storage capacity of 250 ML. It is proposed thatthe anaerobic digestion pond will be approximately 90ML and will be sealed over by afloating cover designed to eliminate air, to allow biogas collection underneath and toprevent odour from escaping to the environment. The aerobic digestion will occur in anadjacent 15 ML pond. To facilitate the whole process additionally an enclosed tank ofapproximately 4 ML will act as an initial receival buffer so that any fluctuations in qualityof in-feed that might be injurious to the anaerobic micro-organisms can be identified andaveraged before being delivered into the anaerobic digester. Another pondapproximately 10 ML capacity will act as a holding buffer for the fully treated waste waterprior to its release for in-factory use, and irrigation on the Environmental Farm, or use bythe Australia Paper Mill.Effluent from the MBR would be sent to the proposed Reverse Osmosis (RO) plant forfurther treatment prior to its reuse at the factory, with the biomass being returned to theBVF for digestion. The RO plant will consist of a two-train Koch module with a capacityCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 42
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryof up to 6 ML/day production of permeate (clean water) to be reused in the factory.A two-train model was chosen to allow water treatment to continue when one train isdown for cleaning and/or maintenance.The SO basin is a biological aerobic system that is designed to oxidise sulphur andhence minimise the formation of reduced sulphur compounds, which can be potentiallyodorous. The SO would be used for provide treated effluent to allow the sustainableirrigation of the existing pasture at the Environmental Farm. In addition, the SO basinallows for emergency treatment/storage of effluent from the BVF in the case ofbreakdowns of the MBR or the RO plant.Effluent from the SO basin and retentate from the RO plant would be used forsustainable irrigation of pasture at the Environmental Farm. Two spray irrigationsystems will be used at the Farm; traveller and pivot sprays. The pivot spray systemsare fitted with low mist nozzles.It is estimated that 70 cubic metres of biomass (4% solids) will be produced per day fromthe BVF, which would be readily disposed to land by spray irrigation in less than onehour during a given day.• An irrigation management plan for the operation of the Environmental Farm isaddressed in Section 7.4 of this EA.Figure 7 is a simple diagram detailing the water treatment process associated with theproposal.Figure 8 details a proposed water and waste water balance for the site following theethanol upgrade project.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 43
Figure 7: Diagram detailing the water treatment process associated with the proposal.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 44
Figure 8: Mass Balance and Process Flow
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry5.9 PROPOSED NEW PACKING PLANT AND CONTAINER LOADING AREAIt is also proposed to relocate the existing packing plant and its associated containerloading facilities from their current congested position within the existing factory complexto an undeveloped property owned by the <strong>Manildra</strong> <strong>Group</strong> of Companies on the northernside of Bolong Road (refer to Plate 9 – view of proposed packing plant). The propertycomprises two allotments: Lot 5 DP 825808 and Lot 2 DP 538289 (refer Plates 10and 11).The future use of the building containing the existing packing plant has yet to bedetermined.Plate 9: View of Proposed Packing PlantCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 45
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryShoalhaven Starchesfactory siteBolong RoadProposed PackingPlant sitePlate 10: Aerial view of site of proposed packing plant.Plate 11: Aerial photograph over proposed Packing Plant site.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 46
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe proposal will seek to erect a purpose designed and built factory building withdimensions of approximately 75 metres by 40 metres, and having a height ofapproximately 10 metres above ground level. This building will also contain two storagesilos located centrally within the Packing Plant building and with heights of approximately30 metres above ground level.In addition to the above it is proposed to relocate the Company’s container loadingfacility (associated with the packing plant) adjacent to the proposed new packing plant.This area will comprise dimensions of approximately 80 metres by about 80 metres, andwill comprise a bitumen sealed hard stand surface. A new railway spur line is alsoproposed to be extended from the existing railway to service this container loading area.It is also proposed to install a weighbridge on this site.It is proposed that dried gluten/starch will be pneumatically conveyed from the existingsite to the proposed new packing plant via an overhead bridge to cross Bolong Road.This dried material will be pneumatically conveyed and stored in the proposed silos. Thisoverhead bridge will also double as a pedestrian bridge to improve safety for pedestrianscrossing between the existing factory site and the packing plant site.The silos will feed the proposed new packing plant. The need for the new packing planthas largely arisen from the demands of the Company’s customers who are seekingimprovements to the sealing of the bags used for packaging. At present difficulties arisewith the current packing plant whereby bags are filled and weighed separately. Thisresults in damages to the seals of bags through the ‘double handling’ of bags; resultingin leakages.The existing system involves product being blown into bags, which also results in theescape of product resulting in product loss and dust generation.The new packing plant will overcome these difficulties as product will not be blown intobags, but rather mechanically packed. Furthermore, sealing and weighing operationswill be completed simultaneously resulting in a reduction in leakages.Overall the new packing plant will provide a more efficient packaging system with lessproduct loss and dust generation. Air emissions, in particular odour emissions, from thisplant are anticipated to be negligible.In addition the new system will result in a reduction of packaging materials. Under thecurrent system ‘3 ply’ paper bags are required to be used in packaging. The newpacking plant will be able to use ‘2 ply’ bags resulting in a 30% reduction in packagingmaterials.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 47
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryGiven the efficiency gains, the new packing plant will be able to meet the requirementsof the proposed production increases in starch and gluten, associated with this proposal.The existing packing plant would not be able to meet these requirements; it simply doesnot have the spare capacity.The new plant will have other advantages:• The existing plant is located within a heavily congested section of the factory. Thisarea has heavy truck; train; and forklift movements creating safety concerns foremployees. The new site will be significantly less congested.• The existing packing plant, as with the remainder of the factory, operates 24 hoursper day, seven days a week, 365 days of the year. It is not possible to close theexisting packing plant operations down while new plant is installed. The newpacking plant will enable existing operations to continue up until the new packingplant is commissioned.• With heavy vehicles entering the site by left turn only via Bolong Road the number ofheavy vehicle movements crossing Bolong Road will be reduced; thereby reducingthe traffic conflicts along this route.5.10 ENERGY AND UTILITIES5.10.1 EnergyBaseline (2006-2007) energy used at the Shoalhaven Starches‘ operations duringoperation are summarised as follows:• Coal − 2,835,000 Gigajoules per annum (GJ/a)• Natural gas − 168,536 GJ/a• Diesel on-site − 25,476 GJ/a• Electricity − 467,679 GJ/aThe total (gross) energy requirements for the plant following the upgrade proposal will beas follows:• Coal − 2,943,000 GJ/a• Natural gas − 6,800,000 GJ/a• Diesel on-site − 25,476 GJ/a• Electricity − 50,400 GJ/a(Reference – Greenhouse Gas Assessment – GHD Pty Ltd – Annexure N.)In order to accommodate this increase in energy requirements, the Company proposes:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 48
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• to install an additional gas-fired boiler; and• a gas-fired co-generation plant.Additional Gas-fired BoilerThe proposal includes an additional natural gas-fired boiler (20 MW) which would beused as a standby system should any coal-fired units fail or are used to supplement thesteam supply should the coal-fired boilers not meet demand.Co-generation PlantIt is also proposed to install a gas-fired co-generation plan, which would be used tosupply electricity and steam to the factory. Electric power using natural gas as fuelwould be generated using two gas turbine generators to deliver a net power output of35 MW.5.10.2 Water SupplyAs will be explained in greater detail in Section 5.10 of this EA, the proposal will result inan increase in water consumption at the plant to accommodate the upgrade. It isproposed however to reduce the amount of potable water used at the site; and insteadincrease the amount of raw water used at the site.A daily average of 8,300 kilolitres of water is used presently by Shoalhaven Starches fortheir total operations, comprising:• 5,100 KL from the municipal drinking water supply; and• 2,400 KL from a raw water supply provided by Shoalhaven City Council via apipeline from the Australian Paper Mill.The proposed upgrade of the facilities for increased production of ethanol and glutenand associated by-products will necessitate increased water usage; both potable waterfor processing flour and non-potable water for steam generation, cooling and other uses.After installation of the proposed Waste Water Treatment Plant and the availability oftreated water for re-use, daily water supply will comprise:• 4,000 KL of potable quality water;• 3,700 KL of raw water;• 4,500 KL of treated water for re-use.The Company will obtain 4000 KL of its potable water quality requirement fromShoalhaven City Council. The remaining 4,500 KL of potable water will be obtained fromCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 49
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrywater processed through the Waste Water Treatment Plant. The 3700 KL of raw waterwill come from the Paper Mill as is currently the case.5.10.3 PipelinesThe proposed upgrade will also require the following pipeline upgrades:• At present a raw water pipeline extends from the Australian Paper Mill to the site tosupply the Company’s raw water supply requirements. This pipeline may require tobe augmented with an additional pipeline to accommodate increased raw watervolume.• Methane will be generated from the proposed BVF reactor within the proposedwaste water treatment plant. It is proposed to capture this methane and direct it in apipeline back to the factory as a fuel in the boilers.• The Water Treatment Plant will also require the extension of an electricity linebetween the plant and the factory site.• The siting of the new packing plant on the northern side of Bolong Road willnecessitate the transfer of product from the factory to this site via an overheadbridge. This product will then be transferred by an overland pipeline between theoverhead bridge and the Packing Plant.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 50
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry6.0 STATUTORY APPROVAL CONTEXT6.1 COMMONWEALTH LEGISLATION6.1.1 Environment Protection & Biodiversity Conservation ActThe Commonwealth Environmental Protection and Biodiversity Conservation Act 1999specifies that approval is required from the Commonwealth Minister for the Environmentfor actions that have, will have or are likely to have a significant impact on a matter of“national environmental significance”, including:(i)(ii)(iii)(iv)(v)(vi)declared World Heritage Areas;declared RAMSAR wetlands;listed threatened species and ecological communities;listed migratory species;nuclear actions; andthe environment of Commonwealth marine areas.Actions on or outside Commonwealth land that have, will have or are likely to have asignificant impact on the environment on or outside Commonwealth land must also bereferred to the Commonwealth Minister for assessment and approval.The Department of Environment and Heritage (2005) has published guidelines to assistin determining whether an action will have or is likely to have a significant impact on amatter of national environmental significance and, hence, whether a referral should besubmitted to the Department for a decision by the Minister on whether assessment andapproval is required under the EPBC Act.The Guidelines state that, to make a decision as to whether or not to refer an action tothe Minister, you should consider the following questions:1. Are there matters of national environmental significance located in thearea of the proposed action?2. Considering the proposed action at its broadest scope, is therepotential for impacts on matters of national environmental significance?3. Are there any proposed measures to avoid or reduce impacts onmatters of national environ-mental significance?4. Are any impacts of the proposed action on matters of nationalenvironmental significance likely to be significant impacts?Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 51
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe Guidelines provide the following important definitions:"A significant impact is an impact which is important, notable, or of consequence,having regard to its context or intensity. Whether or not an action is likely to have asignificant impact depends upon the sensitivity, value, and quality of the environmentwhich is impacted, and upon the intensity, duration, magnitude and geographic extentof the impacts. You should consider all of these factors when determining whether anaction is likely to have a significant impact on matters of national environmentalsignificance.""To be likely, it is not necessary for a significant impact to have a greater then 50%chance of happening, it is sufficient if a significant impact on a matter of nationalenvironmental significance is a real or not remote chance or possibility.""Population, in relation to critically endangered, endangered or vulnerable, threatenedspecies, means:• a geographically distinct regional population, or collection of local populations; or• a regional population, or collection of local populations occurring within aparticular bioregion.""An important population is a population that is necessary for a species’ long-termsurvival and recovery. This may include populations that are:• key source populations either for breeding or dispersal;• populations that are necessary for maintaining genetic diversity; and/or• populations that are near the limit of the species' range."Habitat critical to the survival of a species refers to:• habitat identified in a recovery plan for the species as habitat critical for thosespecies or communities; and/or• habitat listed on the Register of Critical Habitat maintained by the Minister underthe Act; and/or• areas that are necessary:− for activities such as foraging, breeding, roosting, or dispersal,− for succession,− to maintain genetic diversity and long term evolutionary development, or− for the reintroduction of populations or recovery of the species."Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 52
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryA Flora and Fauna Assessment prepared by Kevin Mills & Associates (KMA) supportsthis EA (Annexure E). In relation to the provisions of this legislation KMA conclude:“The proposed upgrade is not likely to have a significant effect on anymatters of national environmental significance listed under the EnvironmentProtection and Biodiversity Conservation Act. Referral to the CommonwealthEnvironment Minister for approval is therefore not warranted.”Issues pertaining to the ecological impacts associated with this proposal are addressedin Section 7.13 of this EA.6.1.2 Commonwealth Aboriginal Heritage LegislationThe Aboriginal and Torres Strait Islander Heritage Protection Act, 1984, provides for theprotection of areas and objects which are of significance to Aboriginal people inaccordance with Aboriginal tradition. The Act allows Aboriginals to apply to the Ministerto seek protection for significant Aboriginal areas and objects. The Minister has broadpowers to make such a declaration should the Minister be satisfied that the area orobject is a significant Aboriginal area or object and is under immediate threat of injury ordesecration. An ‘emergency declaration’ can remain in force for up to thirty days. It isan offence under the Act to contravene a provision of a declaration. Provisions aremade for penalties of up to $50,000 for a corporation found guilty of contravening the Actand up to $10,000 and imprisonment for a maximum of five years, for a person foundguilty of contravening the Act.Under the Act, ‘Aboriginal tradition’ means:‘the body of traditions, observances, customs and beliefs of Aboriginalsgenerally or of a particular community or group of Aboriginals, and includessuch traditions, observances, customs or beliefs relating to particularpersons, areas, objects or relationships’ (Section 3).A ‘significant Aboriginal area’ refers to:An area of land or water in Australia being of ‘particular significance toAboriginals in accordance with Aboriginal tradition’ (Section 3).A ‘significant Aboriginal object’ refers to:An object (including Aboriginal remains) of ‘particular significance toAboriginals in accordance with Aboriginal traditions’ (Section 3).For the purposes of the Act, an area or object is considered to be injured or desecratedif:a) in the case of an area, it is used or treated in a manner inconsistentwith Aboriginal tradition; or the use or significance of the area inaccordance with Aboriginal tradition is adversely affected by reason ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 53
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryanything done in or near the area; or passage through or over, or entryupon the area by any person occurs in a manner inconsistent withAboriginal tradition; andb) in the case of an object, it is used or treated in a manner inconsistentwith Aboriginal tradition (Section 3).A national heritage system commenced on 1 January 2004, largely replacing theprevious Australian Heritage Commission Act 1975; its primary features under theamended Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)and the Australian Heritage Council Act 2003 include:• A National Heritage List of places of national heritage significance;• A Commonwealth Heritage List of heritage places owned or managed by theCommonwealth;• Creation of the Australian Heritage Council – an independent expert body to advisethe Minister on the listing and protection of heritage places; and• Continued management of the Register of the National Estate, a list of more than13,000 heritage places around Australia that has been compiled by the formerAustralian Heritage Commission since 1976.This EA is supported by an Aboriginal Heritage Assessment prepared by South EastArchaeology (Annexure D). This assessment identifies that the lands affected by theproject does not contain any heritage items registered for indigenous values under theAboriginal and Torres Strait Islander Heritage Protection Act 1984, EnvironmentalProtection and Biodiversity Conservation Act 1999 or the Australian Heritage Council Act2003.6.2 STATE LEGISLATION6.2.1 Environmental Planning & Assessment (EP&A) Act 1979Objects of the EP&A ActSection 5 of the Act outlines the objects of the Act as follows:5 ObjectsThe objects of this Act are:(a)to encourage:(i)the proper management, development and conservation ofnatural and artificial resources, including agricultural land, naturalareas, forests, minerals, water, cities, towns and villages for theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 54
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrypurpose of promoting the social and economic welfare of thecommunity and a better environment,(ii)(iii)(iv)(v)(vi)the promotion and co-ordination of the orderly and economic useand development of land,the protection, provision and co-ordination of communication andutility services,the provision of land for public purposes,the provision and co-ordination of community services andfacilities, andthe protection of the environment, including the protection andconservation of native animals and plants, including threatenedspecies, populations and ecological communities, and theirhabitats, and(vii) ecologically sustainable development, and(viii) the provision and maintenance of affordable housing, and(b)(c)to promote the sharing of the responsibility for environmental planningbetween the different levels of government in the State, andto provide increased opportunity for public involvement andparticipation in environmental planning and assessment.CommentsThe proposal is consistent with the above objects as:• The proposal seeks to increase ethanol production. Ethanol is a renewable fuel thatlessens reliance on fossil fuels.• It reduces greenhouse gas emissions and other air pollutants.• It reduces imports of oil and stimulates regional and local economics.• The proposal will sustainably maintain the existing workforce at the plant; andincrease employment for an additional 25 positions.• The proposal includes a comprehensive approach to the protection of theenvironment including odour reduction and the re-use of waste waters both withinfactory processes and for irrigation of farmland.Part 3A Major ProjectsThe introduction of Part 3A to the Environmental Planning & Assessment Act 1979; andthe introduction of State Environmental Planning Policy (Major Projects); brought about achange in the regime concerning the assessment of state significant development.Pursuant to Section 75B of the Act, development subject to the provisions of Part 3A ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 55
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythe Act includes development referred to within a State Environmental Planning Policy.The Minister for Planning is the consent authority for such development.State Environmental Planning Policy (Major Projects) supports the introduction ofPart 3A to the Act. Schedules 1 and 2 of this SEPP outline those developments that areessentially subject to the provisions of Part 3A of the Act.Schedule 1 SEPP (Major Projects)Schedule 1 of SEPP (Major Projects) outlines classes of development that, if in theopinion of the Minister, are declared to be projects to which Part 3A of the Act apply.<strong>Group</strong> 1 within this schedule outlines criteria for agricultural, timber and relatedindustries and includes:3 Agricultural produce industries and food and beverage processingDevelopment that employs 100 or more people or has a capital investmentvalue of more than $30 million for any of the following purposes:(a)(b)(c)abattoirs or meat packing, boning or products plants; milk or butterfactories; fish packing, processing, canning or marketing facilities;animal or pet feed; gelatine plants; tanneries; wool scouring or topping;rendering plants, orcotton gins; cotton seed mills; sugar mills; sugar refineries; grain millsor silo complexes; edible or essential oils processing; breweries;distilleries; ethanol plants; soft drink manufacture; fruit juice works;canning or bottling works; bakeries; small goods manufacture, cerealprocessing or margarine manufacturing, ororganic fertiliser plants or composting facilities or works.This proposal includes alterations and additions to an exiting ethanol plant that currentlyemploys 250 people. The proposed alterations and additions to the factory areestimated to involve a capital investment of approximately $200 million and will provideon-going employment for up to an additional 25 people in the operation of the plant.Schedule 2 SEPP (Major Projects)Schedule 2 of SEPP (Major Projects) also outlines those classes of developmentsituated within the coastal zone that are also deemed to be state significantdevelopment. This Schedule includes:1 Coastal areas(1) Development within the coastal zone for any of the following purposes:(a)(b)extractive industries,landfill facilities,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 56
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(c)(d)(e)mining that is designated development and that is wholly or partlyin a sensitive coastal location,marinas that are designated development and that are wholly orpartly in a sensitive coastal location,the following types of industries (other than mining or extractiveindustries) but only if they are:(i)(ii)designated development, andin the case of the metropolitan coastal zone—wholly orpartly in a sensitive coastal location:agricultural produce industries, bitumen pre-mixindustries, breweries or distilleries, cement works, ceramicor glass industries, chemical industries or works,chemical storage facilities, composting facilities or works,contaminated soil treatment works, crushing, grinding orseparating works, drum or container reconditioning works,electricity generating stations, livestock intensive industries,livestock processing industries, mineral processing ormetallurgical works, paper, pulp or pulp products industries,petroleum works, wood or timber milling or processingworks, or wood preservation works,The subject site is situated within the Coastal zone. The classes of developmentoutlined in bold above are applicable to the subject site.Relevant legislation and other approvalsApprovals under the eight Acts listed under Section 75U Clause 1 of the EP&A Act arenot required for developments identified as Major Projects. These Acts include:a) the concurrence under Part 3 of the Coastal Protection Act 1979 of theMinister administering that Part of the Act,(b)a permit under section 201, 205 or 219 of the Fisheries ManagementAct 1994,(c) an approval under Part 4, or an excavation permit under section 139,of the Heritage Act 1977,(d)(e)(f)(g)a permit under section 87 or a consent under section 90 of the NationalParks and Wildlife Act 1974,an authorisation referred to in section 12 of the Native Vegetation Act2003 (or under any Act to be repealed by that Act) to clear nativevegetation,a permit under Part 3A of the Rivers and Foreshores Improvement Act1948,a bush fire safety authority under section 100B of the Rural Fires Act1997,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 57
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(h)a water use approval under section 89, a water management workapproval under section 90 or an activity approval under section 91 ofthe Water Management Act 2000.Section 79C - Matters for ConsiderationSection 79C of the Act outlines that matters that must be evaluated or taken intoconsideration with respect to development applications. Section 79C outlines thefollowing:79C Evaluation(1) Matters for consideration-general. In determining a developmentapplication, a consent authority is to take into consideration such of thefollowing matters as are of relevance to the development the subject ofthe development application:(a)the provisions of:(i)(ii)(iii)any environmental planning instrument, andany draft environmental planning instrument that is or hasbeen placed on public exhibition and details of which havebeen notified to the consent authority (unless the Director-General has notified the consent authority that the makingof the draft instrument has been deferred indefinitely or hasnot been approved), andany development control plan, and(iiia) any planning agreement that has been entered into undersection 93F, or any draft planning agreement that adeveloper has offered to enter into under section 93F, and(iv)the regulations (to the extent that they prescribe matters forthe purposes of this paragraph),that apply to the land to which the development applicationrelates,(b)(c)(d)the likely impacts of that development, including environmentalimpacts on both the natural and built environments, and socialand economic impacts in the locality,the suitability of the site for the development,any submissions made in accordance with this Act or theregulations,(e) the public interest.CommentsThe above matters are addressed within the body of this EA.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 58
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry6.2.2 Threatened Species Conservation ActThe New South Wales Environmental Planning and Assessment Act 1979, as amendedby the Threatened Species Conservation Act 1995 and Threatened SpeciesConservation Amendment Act 2002, requires that various factors be taken into accountin deciding whether a proposed action, development or activity is likely to have asignificant effect on threatened species, populations or communities, or their habitatsand, hence, whether the preparation of a Species Impact Statement (SIS) is warranted.The TSC Amendment Act also specifies that any assessment guidelines issued by theMinister for the Environment be taken into account when making an assessment ofsignificance.The Department of Environment and Conservation published theguidelines in August 2005. Referred to as the Assessment of Significance Guidelines,they clarify technical terms and assist in the interpretation and application of the variousfactors.The Guidelines state that:"the revised factors maintain the same intent [as the Eight Part Test] butfocus consideration of the likely impacts in the context of the local rather thanthe regional environment as the long-term loss of biodiversity at all levelsarises primarily from the accumulation of losses and depletions ofpopulations at a local level. This is the broad principle underpinning the TSCAct, State and Federal biodiversity strategies and national agreements. Theconsideration of impacts at a local level is designed to make it easier for localgovernment to assess, and easier for applicants and consultants toundertake the Assessment of Significance because there is no longer a needto research regional and statewide information in considering potentialimpacts. Further consideration is required when a significant effect is likelyand is more appropriately considered when preparing a Species ImpactStatement.""When applying each factor, consideration must be given to all of the likelydirect and indirect impacts of the proposal. Direct impacts are those thatdirectly affect habitat and individuals and include but are not limited to acutedeath through predation, trampling, poisoning of the animal/plant itself andremoval of suitable habitat. Indirect impacts occur when project-relatedactivities affect resources in a manner other than a direct loss of theresource. A broad range of impacts need to be considered, for example,killing of species through starvation, exposure, predation, by domestic and/orferal animals, loss of breeding opportunities, loss of shade/shelter,deleterious changes in the water table, increased soil salinity, promotion oferosion, inhibition of nitrogen fixation, provision of suitable seed bed forexotic weed invasion, fertiliser drift, or increased human activity within ordirectly adjacent to sensitive habitat areas."Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 59
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry"Mitigating, ameliorative or compensatory measures proposed as part of theaction, development or activity should not be considered in determining thedegree of effect on threatened species, populations, or ecologicalcommunities, unless the measure has been proven successful for thatspecies in a similar situation.""In determining the nature and magnitude of an impact, it is important toconsider matters such as:• Pre-construction, construction and occupation/maintenance phases,• All on-site and off-site impacts, including location, installation, operationand maintenance of auxiliary infrastructure and fire management zones,• All direct and indirect impacts,• The frequency and duration of each known or likely impact/action,• The total impact which can be attributed to that action over the entiregeographic area affected, and over time,• The sensitivity of the receiving environment, and• The degree of confidence with which the impacts of the action areknown and understood.""Application of the precautionary principle requires that a lack of scientificcertainty about the potential impacts of an action does not in itself justify adecision that the action is not likely to have a significant impact. If theinformation is not available to conclusively determine that there will not be asignificant impact on the threatened species, population or ecologicalcommunity, or its habitat then it should be assumed that a significant impactis likely."The factors to be considered are as follows:(a)(b)(c)in the case of a threatened species, whether the action proposed islikely to have an adverse effect on the life cycle of the species suchthat a viable local population of the species is likely to be placed at riskof extinction;in the case of an endangered population, whether the action proposedis likely to have an adverse effect on the life cycle of the species thatconstitutes the endangered population such that a viable localpopulation of the species is likely to be placed at risk of extinction;in the case of an endangered ecological community or criticallyendangered ecological community, whether the action proposed;(i)is likely to have an adverse effect on the extent of the ecologicalcommunity such that its local occurrence is likely to be placed atrisk of extinction;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 60
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(ii)is likely to substantially and adversely modify the composition ofthe ecological community such that its occurrence is likely to beplaced at risk of extinction;(d)in relation to the habitat of a threatened species, population orecological community;(i)(ii)(iii)the extent to which habitat is likely to be removed or modified asa result of the action proposed;whether an area of habitat is likely to become fragmented orisolated from other areas of habitat as a result of the proposedaction;the importance of the habitat to be removed, modified,fragmented or isolated to the long-term survival of the species,population or ecological community in the locality;(e)(f)(g)whether the action proposed is likely to have an adverse effect oncritical habitat (either directly or indirectly);whether the action proposed is consistent with the objectives or actionsof a recovery plan or threat abatement plan;whether the action proposed constitutes or is part of a key threateningprocess or is likely to result in the operation of, or increase the impactof, a key threatening process.A Flora and Fauna Assessment prepared by Kevin Mills & Associates (KMA) supportsthis EA (Annexure E). In relation to the provisions of this legislation KMA conclude:“The proposed upgrade is not likely to have a significant effect on species,populations or communities listed under the Threatened SpeciesConservation Act 1995, or their habitats; hence, the preparation of a SpeciesImpact Statement (SIS) is not warranted.”Issues pertaining to the ecological impacts associated with this proposal are addressedin Section 7.13 of this EA.6.2.3 Protection of the Environment Operations ActThe existing development has an Environmental Protection Licence (EPL) under theProtection of the Environment Operations Act 1997 (POEO Act) (EPL No. 883). Thelicence imposes requirements in terms of:• discharges to air, water and land;• irrigation controls;• management of irrigation;• maintenance of irrigation reticulation;• odour control.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 61
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe proposal will necessitate the modification of the terms / provisions of this licence tobe reviewed.6.2.4 Water Management Act 2000The Water Management Act 2000 (WMA) brought into effect in February 2008 theprovision for controlled activities for certain types of developments and activities carriedout in or near a river, lake or estuary. The purpose of WMA 2000 is to providesustainable, integrated and comprehensive management of NSW State waters and aguide for water management activities (DNR, 2008).The NSW Department of Water and Energy (DWE) administers the WMA 2000 and hasdeveloped guidelines to assist applicants considering carrying out a controlled activity onwaterfront land. The guidelines provide information on the design and construction ofcontrolled activities and other mechanisms for the protection of waterfront land,including:• in-stream works;• laying pipes and cables in watercourses;• outlet structures;• riparian corridors;• Vegetation Management Plans;• watercourse crossings.Given the provisions of Section 75U of the EP&A Act (as outlined in Section 6.2.4 of thisEA) as the proposal constitutes a Major Project the need to obtain a controlled activityapproval pursuant to Section 91 of this Act is not required.6.2.5 Native Vegetation Act 2003The objectives of the Native Vegetation Conservation Act essentially relate to theconservation and management of native vegetation. The definition of “native vegetation”under the Act is quite broad, it includes; trees, understorey plants, groundcovers andplants occurring in a wetland. Under the provisions of Section 12 of the Act, the clearingof native vegetation (except under certain exemption and exclusion circumstances)requires to obtain an approval under this legislation from the relevant CatchmentManagement Authority.Pursuant to Section 5 of this Act certain land is excluded from the provisions of thislegislation including land within a zone designated “residential” (but not “rural-Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 62
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryresidential”), “village”, “township”, “industrial” or “business” under an environmentalplanning instrument. Works associated with the factory site and packing plant are zonedIndustrial 4(e) and is therefore excluded from the provisions of this legislation.Furthermore pursuant to Section 75U(e) of the EP&A Act, an approval under Section 12of this Act is not required to be obtained for a project affected by Part 3A of the EP&AAct.Under these circumstances this legislation does not apply to this proposal.6.2.6 The Roads Act 1993Section 138 of the Roads Act deals with works and structures within road reserves andstates:138 Works and structures(1) A person must not:(a)(b)(c)(d)(e)erect a structure or carry out a work in, on or over a public road,ordig up or disturb the surface of a public road, orremove or interfere with a structure, work or tree on a publicroad, orpump water into a public road from any land adjoining the road,orconnect a road (whether public or private) to a classified road,otherwise than with the consent of the appropriate roads authority.Maximum penalty: 10 penalty units.(2) A consent may not be given with respect to a classified road exceptwith the concurrence of the RTA.(3) If the applicant is a public authority, the roads authority and, in the caseof a classified road, the RTA must consult with the applicant beforedeciding whether or not to grant consent or concurrence.(4) This section applies to a roads authority and to any employee of aroads authority in the same way as it applies to any other person.(5) This section applies despite the provisions of any other Act or law tothe contrary, but does not apply to anything done under the provisionsof the Pipelines Act 1967 or under any other provision of an Act thatexpressly excludes the operation of this section.The current proposal does include the laying of pipework along and across BolongRoad, specifically in terms of water and gas (methane) pipelines between the site andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 63
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythe Paper Mill. In addition the proposal includes the provision of a pedestrian/productoverhead bridge over Bolong Road. These works are proposed to be undertaken alongand over Bolong Road. Such works will therefore necessitate approvals under Section138 of the Roads Act. This will also trigger the integrated development provisions of theEP&A Act.6.2.7 National Parks and Wildlife Act 1975The National Parks and Wildlife Act 1974 (as amended) provides the primary basis forthe legal protection and management of Aboriginal heritage sites within NSW.Implementation of the Aboriginal heritage provisions of this Act is the responsibility of theDepartment of Environment and Climate Change (NSW) (DECC). The rationale behindthe Act is to prevent unnecessary or unwarranted destruction of Aboriginal objects andto protect and conserve objects where such action is considered warranted.With the exception of some artefacts in collections, the Act generally defines allAboriginal objects to be the property of the Crown. The Act then provides variouscontrols for the protection, management and destruction of these objects. An ‘Aboriginalobject’ is defined as‘any deposit, object or material evidence (not being a handicraft made forsale) relating to the Aboriginal habitation of the area that comprises NewSouth Wales, being habitation before or concurrent with (or both) theoccupation of that area by persons of non-Aboriginal extraction, and includesAboriginal remains’ [Section 5(1)].’Under the terms of the National Parks and Wildlife Act 1974, it is an offence for a personto:• Knowingly destroy, damage or deface an Aboriginal object or place, or knowinglycause or permit the destruction, defacement or damage to an Aboriginal object orplace, without first obtaining the consent of the Director-General of DECC;• Disturb or excavate any land, or cause any land to be disturbed or excavated, forthe purpose of discovering an object, without first obtaining the consent of theDirector-General of DECC; and• Collect on any land an object that is the property of the Crown, other than an objectunder the control of the Australian Museum, without obtaining appropriateauthorisation from the Director-General of DECC.Under the National Parks and Wildlife Act 1974, ‘Aboriginal areas’ may also be declaredover private land, where Aboriginal objects or places are located, with the consent of theowner or occupier. The purpose of reserving land as an ‘Aboriginal area’ is to identify,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 64
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryprotect and conserve areas associated with a person, event or historical theme, orcontaining a building, place, object, feature or landscape of natural or culturalsignificance to Aboriginal people, or of importance in improving public understanding ofAboriginal culture and its development and transitions (Section 30K).Under Section 91AA of the Act, if the Director-General is of the opinion that any action isbeing, or is about to be carried out that is likely to significantly affect an Aboriginal objector Aboriginal place or any other item of cultural heritage situated on land reserved underthe Act, the Director-General may make a stop-work order for a period of 40 days.Under the Part 3A Major Project amendments to the Environmental Planning andAssessment Act 1979 (EP&A Act), subsequent to approval being granted, Section 90Consent to impact Aboriginal objects or a Section 87 Permit under the National Parksand Wildlife Act 1974 may not be required. In lieu however, a Part 3A applicationinvolving a Statement of Commitments outline proposed heritage management andmitigation measures must be approved. Also, under more recent Part 3A Major Projectamendments (Section 75U{4}), a Section 87 Permit may not be required for investigationof artefact deposits where the investigation is being undertaken for the purpose ofcomplying with an environmental assessment requirements issued in connection with anapplication for approval to carry out a project or for a concept plan for a project.6.3 STATE E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANNING POLICIESThe following State Environmental Planning Policies (SEPPs) are relevant to theconsideration of the proposed development:6.3.1 SEPP No. 14 - Coastal WetlandsThe aim of this policy is to “ensure that coastal wetlands are preserved and protected inthe environmental and economic interest of the state”.In respect of land to which this policy applies, development consent is required to:(a)(b)(c)(d)clear that land;construct a levee on that land;drain that land; orfill that land.One SEPP No. 14 wetland (No. 369) is located within the Company’s EnvironmentalFarm land located across Bolong Road to the north of the factory site. The worksassociated with this proposal however are not sited within the vicinity of this wetland.The provisions of this SEPP will therefore not apply to this proposal.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 65
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry6.3.2 SEPP No. 33 - Hazardous and Offensive DevelopmentThe Shoalhaven factory site comprises a “potentially hazardous industry” and “potentiallyoffensive industry” under the provisions of this SEPP. “Potential hazardous industry” asdefined by clause 3 of the SEPP means:““potentially hazardous industry" means a development for the purposes ofany industry which, if the development were to operate without employingany measures (including, for example, isolation from existing or likely futuredevelopment on other land) to reduce or minimise its impact in the locality oron the existing or likely future development on other land, would pose asignificant risk in relation to the locality:(a)(b)to human health, life or property, orto the biophysical environment,and includes a hazardous industry and a hazardous storage establishment.”Under the provisions of clause 12 of this SEPP any proposal involving a potentiallyhazardous industry must prepare a Preliminary Hazard Analysis in accordance with therelevant Circulars and Guidelines published by the Department of Planning.A Preliminary Hazard Analysis has been prepared for this project by GHD Pty Ltd andforms Annexure F to this EA. This matter is further addressed in Section 7.8 of this EA.6.3.3 SEPP No. 71 - Coastal ProtectionOn the 1 st November 2002 the State Government gazetted SEPP No. 71. This policy• “identifies State significant development in the coastal zone, and• requires development applications to carry out development in sensitivecoastal locations to be referred to the Director-General for comment, and• identifies master plan requirements for certain development in thecoastal zone.”The coastal zone has the same meaning as in the Coastal Protection Act 1979. This Actessentially maps the area of land and waters that lie to the west of coastal waters. Froma perusal of this mapping it is evident that the coastal zone covers the subject land.Under these circumstances, the subject site would be affected by the provisions of thisPolicy.The proposal is consistent with the objectives of the Policy and the matters forconsideration, as detailed in clause 8 of the Policy for the following reasons:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 66
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• The proposal does not affect or impinge on public access to or along the coastalforeshore. Given the nature of the bank of the Shoalhaven River which adjoins thesubject site there is little opportunity to provide public access along this foreshore.• The proposed works are situated within an industrial zoned area within the vicinity ofindustrial plant of a similar purpose, scale and height as that which is proposed andis therefore considered to be suitable development given its type, location anddesign.• The development will not result in any additional overshadowing of foreshore areascompared to that which currently occurs. The proposed works are of a height andscale that matches existing development on the site.• The scenic qualities of the area will not diminish (refer Section 7.12 of this EA).• The proposal will not lead to adverse impacts on threatened fauna and flora (referSection 6.2.2 of this EA).• The proposal does not propose any structures that are likely to impact on fish,marine vegetation or their habitats.• The site is not identified as a wildlife corridor.• It is considered that the proposal will not lead to conflict between land based andwater based coastal activities.• It is not anticipated that the proposal will impact on Aboriginal heritage (refer Section7.14.1 of this EA).In terms of the provisions of Part 4 of the SEPP (clauses 13 – 16) the followingcomments are made:• The proposed development will not impede or diminish public access to coastalforeshore areas. As outlined above given the nature of the bank of the ShoalhavenRiver which adjoins the subject site there is little opportunity to provide new publicaccess along this foreshore• The proposal includes a comprehensive waste water treatment plant to treat wastewaters associated with the project.• The development will not impact upon local stormwater quality (refer Section 7.5.2of this EA).The development is also not subject to the provisions of Part 5 (Master Plans) of theSEPP as the proposal does not seek to subdivide land.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 67
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry6.3.4 SEPP (Major Projects) 2005The aims of this Policy are as follows:(a)(b)(c)(d)(e)to identify development to which the development assessment andapproval process under Part 3A of the Act applies;to identify any such development that is a critical infrastructure projectfor the purposes of Part 3A of the Act;to facilitate the development, redevelopment or protection of importanturban, coastal and regional sites of economic, environmental or socialsignificance to the State so as to facilitate the orderly use, developmentor conservation of those State significant sites for the benefit of theState;to facilitate service delivery outcomes for a range of public servicesand to provide for the development of major sites for a public purposeor redevelopment of major sites no longer appropriate or suitable forpublic purposes;to rationalise and clarify the provisions making the Minister theapproval authority for development and sites of State significance, andto keep those provisions under review so that the approval process isdevolved to Councils when State planning objectives have beenachieved.This SEPP is addressed in Section 6.2.1 of this report. Essentially the Minister hasdeclared that this project is a Major Project pursuant to the provisions of Part 3A of theEP&A Act and SEPP (Major Projects) 2005. The provisions of this policy therefore applyto this project.6.3.5 SEPP (Infrastructure) 2007SEPP (Infrastructure) was made by the NSW Government on the 21 st December 2007.The stated aims of the SEPP are to facilitate the effective delivery of infrastructureacross the State by:(a)(b)(c)(d)improving regulatory certainty and efficiency through a consistentplanning regime for infrastructure and the provision of services, andproviding greater flexibility in the location of infrastructure and servicefacilities, andallowing for the efficient development, redevelopment or disposal ofsurplus government owned land, andidentifying the environmental assessment category into which differenttypes of infrastructure and services development fall (includingidentifying certain development of minimal environmental impact asexempt development), andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 68
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(e)(f)identifying matters to be considered in the assessment of developmentadjacent to particular types of infrastructure development, andproviding for consultation with relevant public authorities about certaindevelopment during the assessment process or prior to developmentcommencing.Division 17 of the SEPP relates to Roads and Traffic Clause 101 of the SEPP reads:101 Development with frontage to classified road(1) The objectives of this clause are:(a)(b)to ensure that new development does not compromise theeffective and ongoing operation and function of classified roads,andto prevent or reduce the potential impact of traffic noise andvehicle emission on development adjacent to classified roads.(2) The consent authority must not grant consent to development on landthat has a frontage to a classified road unless it is satisfied that:(a)(b)where practicable, vehicular access to the land is provided by aroad other than the classified road, andthe safety, efficiency and ongoing operation of the classified roadwill not be adversely affected by the development as a result of:(i)(ii)(iii)the design of the vehicular access to the land, orthe emission of smoke or dust from the development, orthe nature, volume or frequency of vehicles using theclassified road to gain access to the land, and(c)the development is of a type that is not sensitive to traffic noise orvehicle emissions, or is appropriately located and designed, orincludes measures, to ameliorate potential traffic noise or vehicleemissions within the site of the development arising from theadjacent classified road.Clause 104 of the SEPP reads:“104 Traffic-generating development(1) This clause applies to development specified in Column of Table toSchedule 3 that involves:(a)(b)new premises of the relevant size or capacity, oran enlargement or extension of existing premises, being analteration or addition of the relevant size or capacity.(2) In this clause, “relevant size or capacity” means:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 69
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(a)(b)in relation to development on a site that has direct vehicular orpedestrian access to any road – the size or capacity specifiedopposite that development in Column 2 of the Table toSchedule 3, orin relation to development on a site that has direct vehicular orpedestrian access to a classified road or to a road that connectsto a classified road where the access (measured along thealignment of the connecting road) is within 90 m of theconnection – the size or capacity specified opposite thatdevelopment in Column 3 of the Table to Schedule 3.(3) Before determining a development application for development towhich this clause applies, the consent authority must:(a)(b)give written notice of the application to the RTA within 7 daysafter the application is made, andtake into consideration:(i)(ii)any submission that the RTA provides in response to thatnotice within 21 days after the notice was given (unless,before the 21 days have passed, the RTA advises that itwill not be making a submission), andthe accessibility of the site concerned, including:(A)(B)the efficiency of movement of people and freight toand from the site and the extent of multi-purposetrips, andthe potential to minimise the need for travel by carand to maximise movement of freight in containers orbulk freight by rail, and(iii)any potential traffic safety, road congestion or parkingimplications of the development.(4) The consent authority must give the RTA a copy of the determinationof the application within 7 days after the determination is made.”Annexure G to this EA is a Traffic Assessment prepared by Christopher StapletonConsulting. Traffic issues are further addressed in Section 7.7 of this EA.6.3.6 NSW Coastal PolicyThe State Coastal Policy applies generally:• three nautical miles seaward of the mainland and offshore islands;• one kilometre landward of the open coast high water mark;• a distance of one kilometre around:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 70
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry⇒⇒all bays, estuaries, coastal lakes, lagoons and islands;tidal waters of coastal rivers to the limit of mangroves as defined by NSWFisheries (1985) maps or the tidal limit whichever is closer to the sea;• within the line on the maps being taken to the nearest cadastral boundary and/oreasily recognisable physical boundary, in consultation with coastal councils.The relevant objectives of the State Coastal Policy in terms of this proposal are:• To give the impacts of natural processes and hazards a high priority inthe planning and management of coastal areas;• To identify and protect areas of high natural or built aesthetic quality.• To design and locate development to complement the surroundingenvironment and to recognise good aesthetic qualities.• To effectively manage and conserve cultural heritage places, items andlandscapes.• To identify and facilitate opportunities for the sustainable developmentand use of resources.• To develop land use and management plans which ensure thesustainable development and use of resources.Annexure H to this EA includes a checklist addressing how the provisions of the CoastalPolicy apply to this proposal.6.3.7 Riparian Corridor Guidelines for Controlled ActivitiesDWE is required to assess the impact of a controlled activity to ensure that there will beminimal impact on waterfront land. The guidelines (DWE, 2008) define three ripariancorridor zones that should be considered when determining appropriate riparian corridorwidths for a controlled activity:1. A Core Riparian Zone (CRZ) is the land contained within and adjacentto the channel. The Department will seek to ensure that the CRZremains, or becomes vegetated, with fully structured native vegetation(including groundcovers, shrubs and trees). The width of the CRZ fromthe banks of the stream is determined by assessing the importanceand riparian functionality of the watercourse (Table 1), merits of the siteand long-term use of the land. There should be no infrastructure suchas roads, drainage, stormwater structures, services, etc. within theCRZ.2. A Vegetated Buffer (VB) protects the environmental integrity of theCRZ from week invasion, micro-climate changes, litter, trampling andpollution. There should be no infrastructure such as roads, drainage,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 71
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrystormwater structures, services, etc. within the VB. The recommendedwidth of the VB is 10 metres but this depends on merit issues.3. An Asset Protection Zone (APZ) is a requirement of the NSW RuralFire Service and is designed to protect assets (houses, buildings, etc.)from potential bushfire damage. The APZ is measured from the assetto the outer edge of the vegetated buffer (VB). The APZ shouldcontain cleared land which means that it can not be part of the CRZ orVB. The APZ must not result in clearing of the CRZ or VB.Infrastructure such as roads, drainage, stormwater structures, services,etc. can be located within APZs.DWE recommends riparian corridor widths for controlled activities be based onwatercourse order with consideration given to the merit of the site and any impacts of theproposed activity. DWE specified in the DG’s requirements for the Shoalhaven StarchesEthanol Plant expansion that watercourse classification and corridor widths are based onthe Riparian Corridor Management Study (RCMS) Guidelines developed by the formerDIPNR (2004).The EA is supported by an assessment prepared by Coffey Environments Pty Ltd whichaddresses the requirements of these guidelines. A copy of this assessment formsAnnexure I to this EA. Riparian corridor issues are discussed in Section 7.9 of the EA.6.3.8 Riparian Corridor Management Study GuidelinesThe RCMS Guidelines provides a stream classification system to identify minimumriparian corridor widths along watercourses. This body of work was initially developedfor the Wollongong LGA. The RCMS process has since been widely adopted andapplied to the Northwest and Southwest growth centres, other LGAs and land releasesites, and in the Riparian Corridor Guidelines for Controlled Activities of WMA 2000.The stream classification system of the RCMS process incorporates three categoriesthat reflect the environmental significance of watercourses.category and minimum riparian widths are as follows:1 Category 1 – Environmental CorridorThe purpose of eachPurpose: to protect and enhance ecological connectivity between key remnantnative vegetation within and between catchments and achieving all four keyobjectives.Minimum width: a CRZ of 40 m (measure from top of bank) along both sides of thewatercourse and a 10 m vegetated buffer zone.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 72
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry2 Category 2 – Terrestrial and Aquatic HabitatPurpose: to provide for a viable and robust node or reach of riparian habitat (bothaquatic and terrestrial) that would achieve key objectives one, two and three.Minimum width: a CRZ of 20 m (measure from top of bank) along both sides of thewatercourse and a 10 m vegetated buffer zone.3 Category 3 – Bank Stability and Water ControlPurpose: recognises the critical role of riparian vegetation for stabilising the bedand banks of watercourses and filtering catchment run-off and the contribution ofthis to overall catchment health and retention of land, thus achieving objectivesone and two.Minimum width: a CRZ of 10 m (measure from top of bank) along both sides of thewatercourse with no requirement for a buffer zone.The EA is supported by an assessment prepared by Coffey Environments Pty Ltd whichaddresses the requirements of these guidelines. A copy of this assessment formsAnnexure I to this EA. Riparian corridor issues are discussed in Section 7.9 of the EA.6.4 REGIONAL E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLANS AND STRATEGIES6.4.1 Illawarra Regional Environmental PlanThe subject site is affected by the provisions of the Illawarra Regional EnvironmentalPlan (IREP). The IREP was gazetted on 11 April 1986 and provides a statutoryframework that ensures that regional needs and interests are taken into account in localand state planning activities.The main purpose of the IREP is to provide a framework for the coordination ofresponsibilities between State and local government agencies, to ensure that:• the best use of land resources is achieved;• the quality of life, especially as it is affected by land use is maintained and wherepossible improved;• regional needs and interests are taken into account in local and state planning;• a stable and attractive climate exists for public and private investment.From a perusal of the plans which accompany the IREP it is evident that the subject landhas been identified as part of a large area of land in the Nowra / Bomaderry district withCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 73
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrylandscape or environmental attributes. Shoalhaven Starches Environmental Farm is alsoidentified as comprising largely land identified as prime crop and pasture land,Prime Crop and Pasture LandClause 12 of the IREP refers to the subdivision of land that is identified as prime cropand pasture land and states:12 Subdivision of land for agriculture(1) Where an environmental planning instrument provides that land, thewhole or any part of which is identified on the map as land of primecrop and pasture potential, may be subdivided to create an allotment ofless than 40 hectares to be used for the purpose of agriculture, beforegranting development consent to subdivide the land for that purposethe consent authority:(a)(b)shall consult with the Director-General of the Department ofAgriculture, andshall be satisfied that the land, when subdivided, will be capableof supporting, and will be used to support, a viable crop orpasture farming enterprise.Comment(2) For the purposes of subclause (1), intensive undercover livestockrearing, mushroom growing, hydroponic crop raising and similarenterprises not dependent upon the productive capacity of the soil arenot crop or pasture farming enterprises.(3) This clause does not apply to the land shown edged heavy black (otherthan the land bounded by a black line edged by a broken line) onSheet 1 of the map marked “Illawarra Regional Environmental Plan No2-Jamberoo Valley”, the original of which is deposited in the office ofthe Department, copies of which are deposited in the offices of theCouncils of the Municipalities of Kiama and ShellharbourThe provisions of this clause are not relevant to this proposal as the application does notseek to subdivide prime crop and pasture land.Land of Environmental AttributesThe “Illawarra Region Landscape and Environment Study” supports the Region Plan andprovides recommendations in terms of these attributes. The site is located within Unit 6– Shoalhaven Delta as identified by this study. The factory site is affected by theVe policy recommendation while the Environmental Farm is affected by the IIIf policyrecommendation of the “Illawarra Region Landscape and Environment Study”. Thesepolicy recommendations stipulate:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 74
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryVe - Built up corridor comprising existing village, non-urban 1(a) and Non-urban1(b) zones. No recommendations for change.IIIf - Prime crop and pasture land. Zoning should ensure agronomic andpastoral based enterprises only.The proposal is consistent with these recommendations.IndustryPart VI of the IREP is concerned with industry. Industrial objectives relevant to thisproposal are:48. The objective relating to industry are:(a)(b)(c)To ensure that there is sufficient industrially zoned land to meetindustrial needs.To encourage industries and other enterprises to locate withinthe region to diversify the economic base or act as stimuli to thelocal economy or both and so provide new employmentopportunities; andTo locate industrial land where it will meet the particularrequirements of industry while having a minimal adverse impacton the natural environment and the amenity of living areas.The IREP also states that adequate services must be available to meet the demands ofany industrial development, which may be permissible under the provisions of theCouncil’s Local Environmental PlanHigh Rise BuildingsUnder clause 139 of the IREP, provisions relating to high rise buildings are addressed:139(2) The consent authority shall not consent to a developmentapplication to erect a building or to alter an existing building byincreasing its height, where the building after erection or alterationwill have a height:(a)(b)in the case of land shown on the map as regional commercialcentre and land zoned 2(c) Residential “C” under WollongongLocal Environmental Plan No. 38 (other than that north ofBourke Street or Corrimal Street) of more than 20 metres; orin the case of other land in the Wollongong sub region and theShoalhaven sub region of more than 11 metres,without the concurrence of the Director.The IREP makes provision for the control of building heights. Specifically clause139(2)(b) requires the concurrence of the Director-General of Planning for consent toCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 75
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryerect a building where the building will have a height of more than 11 metres. Theproposal includes components, which are over 20 metres in height, and the Director-General of Planning’s concurrence is therefore required prior to the issuing of anyconsent for these aspects of this project.Clause 139(3) sets out the matters for consideration that the Director-General must takeinto consideration in granting concurrence under this clause, including:a) the height, scale, bulk and density of the proposed building;b) the external appearance and materials used on the exterior of theproposed building;c) the relationship of the proposed building to the streetscape orlandscape;d) the effect of the proposed building on public amenity, includingpedestrian amenity;e) the effect of the proposed development on wind patterns and windvelocity in public places;f) the effect of the proposed building on overshadowing of public places;g) the effect of the proposed building on views from public places;h) the effect of the proposed building on any items of the environmentalheritage in the vicinity; andi) the effect of reflections from the exterior of the proposed building onroads, public places and buildings in the vicinity.The scenic qualities of the site and visual impact of the proposed development are dealtwith in Section 7.12 of the EA.The construction and operation of the proposed development would not conflict with therelevant stated aims and provisions contained in the IREP and similarly, there are nofurther provisions of the IREP that affect the application.6.4.2 South Coast Regional StrategyThe primary purpose of the South Coast Regional Strategy is to ensure that adequateland is available and appropriately located to sustainably accommodate projectedhousing and employment needs for the South Coast Region for the next 25 years.In summary the aims of the strategy include:• Protect high value environments including pristine coastal lakes,estuaries, aquifers, threatened species, vegetation communities andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 76
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryhabitat corridors by ensuring that no new urban development occurs inthese important areas and their catchments.• Cater for a housing demand of up to 45,600 new dwellings by 2031 toaccommodate the additional 60,000 people expected in the Region overthe next 25 years.• Increase the amount of housing in existing centres to ensure the needsof future households are better met, in particular the needs of smallerhouseholds and an ageing population.• Prioritise and manage the release of future urban lands to ensure thatnew development occurs in and around existing well serviced centresand towns.• Use the recommendations of the Sensitive Urban Lands Panel to guidethe finalisation of the development form and environmental managementof the 17 ‘sensitive urban lands’.• Manage the environmental impact of settlement by focusing new urbandevelopment in existing identified growth areas such as Nowra-Bomaderry, Milton-Ulladulla, Batemans Bay and Bega.• Only consider additional development sites if it can be demonstrated thatthey satisfy the Sustainability Criteria (Appendix 1).• No new towns or villages will be supported unless compelling reasonsare presented and they can satisfy the Sustainability Criteria.• No new rural residential zones will be supported unless as part of anagreed structure plan or settlement strategy.• Ensure an adequate supply of land to support economic growth andprovide capacity to accommodate a projected 25,800 new jobs,particularly in the areas of finance, administration, business services,health, aged care and tourism.• Limit development in places constrained by coastal processes, flooding,wetlands, important primary industry resources and significant scenicand cultural landscapes.• Protect the cultural and Aboriginal heritage values and visual characterof rural and coastal towns and villages and surrounding landscapes.Where development or rezoning increases the need for State infrastructure,the Minister for Planning may require a contribution to the provision of suchinfrastructure, having regard to the State Infrastructure Strategy and equityconsiderations.Section 7 of the Strategy relates to “Economic development and employment growth”.This section of the strategy concerns in part the need to identify sufficient employmentand land capacity to provide for a projected 25,800 new jobs in the region andspecifically 14,400 within the Shoalhaven.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 77
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe identified “Actions” under the strategy deal essentially with the preparation of localenvironmental plans and the need for monitoring the supply of employment lands in theregion. The Strategy does not make any specific recommendations in terms of thedevelopment of industrial sites – such as that proposed by this application.6.5 SHOALHAVEN LOCAL E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong> PLAN 1985The Main Factory SiteThe majority of the existing Shoalhaven Starches Factory Site within which the ethanol,glucose, starch and grain plants are sited is zoned 4(e) Industrial (RestrictedDevelopment) under the provisions of Shoalhaven Local Environmental Plan 1985. Theobjective of this zone is:“...identify locations in existing industrial areas with development problemswhere special consideration will be required before development can beapproved.”Industrial development is permissible under the provisions of this zoning.The Proposed Packing Plant and Container StorageThe proposed Packing Plant and container storage are proposed to be sited upon Lot 2DP 538289 and Lot 5 DP 825808 Bolong Road, Bomaderry. This land is located alongthe northern side of Bolong Road directly opposite the existing factory and theCompany’s administration offices.These parcels of land are zoned Rural 1(g) and Industrial 4(e) (Restricted Development)pursuant to the provisions of SLEP 1985.The proposed Packing Plant and container storage area is proposed to be sited entirelyon Lot 5. This component is to be sited entirely within that part of the site zoned 4(e).As outlined above, industrial development is permissible under this zoning.The only works proposed within the Rural 1(g) zone are an access road and railway spurline. Roads are a permissible use within the 1(g) zone subject to consent.The proposed railway spur line is plant associated with the overall Shoalhaven Starches’factory complex.The Environmental Planning and Assessment Model Provisions 1980 (“the ModelProvisions”) are adopted by Shoalhaven Local Environmental Plan 1985 (subject to afew exemptions). Clause 35 and Schedule 1 of the Model Provisions outline thoseactivities that may be carried out without development approval, and includes:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 78
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry1. The carrying out by persons carrying on railway undertakings on landcomprised in their undertakings of:(a)(b)any development required in connection with the movement oftraffic by rail, including the construction, reconstruction,alteration, maintenance and repair of ways, works and plant, andthe erection within the limits of a railway station for any purpose,but excluding:(c)(d)(e)(f)the construction of new railways, railway stations and bridgesover roads,the erection, reconstruction and alteration of buildings forpurposes other than railway undertaking purposes outside thelimits of a railway station and the reconstruction or alteration soas materially to affect the design thereof of railway stations orbridges,the formation or alteration of any means of access to a road, andthe erection, reconstruction and alteration of buildings forpurposes other than railway purposes where such buildings havedirect access to a public place.As the rail spur line concerns development in connection with the movement of traffic byrail; and is not one of the listed exclusions as the proposal does not comprise:−−−a new railway, railway station or bridge;a new building;an access to a road.Under these circumstances this component of the proposal is subject to the provisions ofClause 35 of the Model Provisions.The Eastern Portion of the Site (Amendment No. 59)The eastern portion of the factory site, ie. that portion of the site to the east of theEthanol Distillery, is zoned Rural 1(g) under the provisions of SLEP 1985. This area ishowever affected by the provisions of an amendment to the SLEP 1985 (AmendmentNo. 59). The aim of this amending LEP is:“To protect the environment of the City of Shoalhaven by permittingdevelopment on the land to which this plan applies, for the purposes offacilities associated with the starch mill located on land adjoining the land towhich the plan applies that will improve the quality of processed water wastewater leaving the mill site.”Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 79
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe amending LEP enables:“the erection of facilities associated with a starch mill situated on theadjoining land, including a fire service tank and pumphouse, ethanol storageand recovery tanks and associated loading facilities and an employee carpark, provided that the Council is satisfied that:a) the capacity of the floodway to accommodate flood flows is maintained;andb) all structures are designed to withstand at least a 1 in 100 year flood;andc) all footings and foundations are protected against scouring erosion andundermining; andd) there will be adequate safeguards to contain and collect leaks andspillages.”The Far Eastern Portion of the SiteThe PRP No. 7 project (approved by the Minister for Planning in 2003) included aproposal to relocate an employee car park to an area to the east of what was then theexisting car park. This adjoining land is zoned Rural 1(g) Flood Liable under theprovisions of the Shoalhaven Local Environmental Plan 1985.The present ethanol upgrade proposal seeks to erect three fermentation tanks that willbe sited either wholly or partly within this area of the site.It is noted that “rural industry” is a permissible use within the Rural 1(g) zone. TheShoalhaven Local Environmental Plan 1985 adopts (with certain exceptions) theEnvironmental Planning & Assessment Model Provisions. Under the Model Provisions arural industry means the:“handling, treating, processing or packing of primary products and includesthe servicing in a workshop of plant or equipment used for rural purposes inthe locality.The proposed fermenters are plant associated with the overall Shoalhaven Starchesfactory complex. As outlined this factory complex processes wheat, other grains andflour to produce a range of products. Under these circumstances, such an activity wouldsit within the above definition and therefore the proposed fermenters, forming part of theShoalhaven Starches complex would be a permissible use within the Rural 1(g) zone asa “rural industry”.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 80
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryArea to West of Abernethy’s Creek (Amendment No. 171)That portion of the site which is situated to the west of Abernethy’s Creek is also zonedRural 1(g) Flood liable zone, as well as partly Environmental Protection 7(f3) ForeshoresProtection zone and partly 4(e) Industrial (Restricted Development) zone.The land is however affected by Amendment No 171 to SLEP 1985. The aims of thisamending LEP are to:“a)Provide for the expansion of an existing industrial operation which islocated on land adjoining the land to which this land applies, providedthe Shoalhaven City Council is satisfied that issues related to flooding,traffic impact, risk, noise, visual impact, the management of the riparianbuffer zone and the potential existence of acid sulphate soils havebeen addressed; andb) Acknowledge the importance of establishing an adequate riparianbuffer zone adjoining Bomaderry Creek and the Shoalhaven River byzoning an appropriate area Environmental Protection (F3) (ForeshoresProtection) zone under the City of Shoalhaven Local EnvironmentalPlan 1985.”This Amendment to SLEP permits the erection of facilities ancillary to the starch millsituated on adjoining land provided the consent authority is satisfied that issues relatingto flooding, traffic impact, risk, noise, visual impact, management of riparian buffer zoneand potential existence of acid sulphate soils have been addressed. This proposalseeks to locate additional evaporators and 6 additional DDGS Dryers (and associatedplant), extension to the approved DDG Loadout (PRP No. 7), additional evaporators,chemical storage, condensate defatting plant, DDGS Pellet Plant, and associatedbioscrubbers and gas fired co-generation plant in this part of the site. Given these usesare ancillary to the existing DDGS Plant located on this site, and forms part of the overallStarch Plant operations, such uses are permissible subject to development consent. Inthis regard the proposed gas-fired co-generation plant does not encroach into the 7(f3)zone that is situated along the foreshores of Bomaderry Creek and the ShoalhavenRiver under this plan amendment.Area North of Bolong Road - Proposed Fire System (Amendment No. 173)The proposal includes the siting of a fire system on Lot 142 DP 1069758, located on thenorth side of Bolong Road immediately opposite the factory site.This land is zoned Rural 1(g) flood liable and is also affected by Amendment No. 173.The aim of this amendment is:“To provide for the establishment of a carbon dioxide processing and storageplant on the subject land, provided the Shoalhaven City Council is satisfiedCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 81
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythat issues related to flooding, traffic impact, risk, noise visual impact,management of riparian buffer zone along Abernethy’s Creek and thepotential existence of acid sulphate soils have been addressed.”.The proposed fire system comprises an integral component of the overall development’sfire safety system associated with the overall Shoalhaven Starches’ factory complex(and including the adjoining carbon dioxide plant).It is noted that “rural industry” is a permissible use within the Rural 1(g) zone. TheShoalhaven Local Environmental Plan 1985 adopts (with certain exceptions) theEnvironmental Planning & Assessment Model Provisions. Under the Model Provisions arural industry means the:“handling, treating, processing or packing of primary products and includesthe servicing in a workshop of plant or equipment used for rural purposes inthe locality.”The proposed fire system is associated with the overall Shoalhaven Starches’ factorycomplex. As outlined the factory complex processes wheat, other grains and flour toproduce a range of products. Under these circumstances, such an activity would sitwithin the above definition and therefore the proposed fire system, forming part of theShoalhaven Starches’ complex would be a permissible use within the Rural 1(g) zone asa “rural industry”.The Environmental FarmThe land associated with the Environmental Farm is zoned Rural 1(g) Flood Liable underSLEP 1985. The objectives of the Rural 1(g) zone are:(a)(b)(c)(d)(e)to limit the erection of structures on land subject to periodic inundation,to ensure that dwelling-houses are erected on land subject to periodicinundation only in conjunction with agricultural use,to ensure that the effect of inundation is not increased throughdevelopment,to restrict development and how it is carried out so that its potential tohave an adverse impact on site and off site on acid sulfate soils isreduced or eliminated, andto conserve and maintain the productive potential of prime crop andpasture land.Activities involving waste treatment and disposal, in each case involving the use of waterare permissible subject to development consent. This proposal includes the adaptivere-use of part of the existing Pond No. 7 as an anaerobic and aerobic waste watertreatment plant. Such a use is therefore permissible within the 1(g) zone.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 82
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryEnvironmental Management ProvisionsThe following environmental management provisions of SLEP 1985 have relevance tothe proposal.Clause 26 (2) & (3) Soil, water and effluent management26 (2) In deciding whether arrangements for drainage of stormwater andother surface water and the treatment and disposal of effluent aresatisfactory, the Council must take into account whether theproposed systems can be accomplished in a manner which meetsthe following objectives:(a)(b)(c)(d)(e)(f)economical feasibility and practicality in terms of design,installation and maintenance,protection of public health,protection of surface water,protection of ground water,encouragement of the utilisation of wastewaters as a resourcerather than a waste for disposal, andprotection of community amenity.Comment(3) Despite any other provision of this plan, except clauses 2, 9 (3) and21 and the objectives of the zone in which development the subjectof this clause is proposed, the Council may consent to theconstruction of devices which, in the opinion of the Council, are tobe used principally for the purpose of soil and water management orwater pollution control.Stormwater management issues are discussed further in Section 7.5.2 of this EA.Clause 27 Development on acid sulfate soils26(1) This clause applies to land identified as having high probability to beaffected by acid sulfate soils on the map prepared by theDepartment of Land and Water Conservation entitled “ Acid SulfateSoil Risk Map ” dated December 1997 and available for publicinspection at the office of the Council.(2) Despite any other provision of this plan, the consent of the Councilis required for any development which involves or is likely to involve,through drainage, earthworks, or any other means, the exposure tothe atmosphere of any part of soil which contains iron pyrites withinland to which this clause applies.(3) The Council must not consent to development described insubclause (2) unless it is satisfied that measures can and will betaken to avoid or mitigate the actual or potential contamination ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 83
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryCommentwaterways in the vicinity of the land concerned by acid from acidsulfate soils.Acid Sulphate Soil mapping indicates the subject site is subject to a low probability forthe presence of acid sulphate soils. The provisions of this clause therefore do not applyto this proposal.The EA is supported by an Acid Sulphate Soil Assessment carried out by CoffeyEnvironments Pty Ltd and which forms Annexure J to this EA. This matter is furtherdiscussed in Section 7.5.3 of this EA.Clause 28 Danger of bush fire(1) The Council must not grant consent to the carrying out of developmenton bush fire prone land if it is of the opinion that:(a)the development may have a significant adverse effect on theimplementation of:(i)(ii)any strategies for bush fire hazard reduction or riskmanagement adopted by the Council, orany relevant provisions of the Act or the Rural Fires Act1997 , and(b)(c)the development, including the arrangements for access to andfrom the development, may constitute a significant threat to thelives of residents, visitors or emergency services personnel, andthe development may give rise to an increased demand foremergency services during bush fire events that will result in asignificant decrease in the ability of the emergency services toeffectively control major bush fires.Note: Section 146 of the Act provides that bush fire prone land is landrecorded by the Council as such on a map certified by theCommissioner of the NSW Rural Fire Service as a bush fire prone landmap for the area of the Council.(2) The Council must not grant consent to the carrying out of developmenton bush fire prone land unless it is satisfied that adequate measuresare proposed to avoid or mitigate the threat from bush fire, havingregard to:(a)(b)(c)the siting of the development, andthe design of, and the materials used in, any structures involvedin the development, andthe clearing of vegetation, andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 84
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(d)the provision of asset protection zones, landscaping and firecontrol aids (such as roads and water supplies).(3) Before deciding to grant consent to any development on bush fireprone land, the Council:(a)(b)must have regard to the requirements set out in Planning forBushfire Protection (ISBN 0 9585987 8 9) , prepared by Planning& Environment Services, NSW Rural Fire Service in co-operationwith the Department of Planning (as it then was), and publishedin December 2001, andmust be satisfied that those requirements will be met as far as ispracticable in the circumstances.CommentThe subject site is not mapped as being bushfire prone by mapping prepared byShoalhaven City Council. Given; the site is not mapped as being bushfire prone; and isa developed industrial site that adjoins the Shoalhaven River; this clause would notapply to this proposal.29 Development of flood liable land(1) Subject to subclause (2), the Council must not consent to the carryingout of development on land which, in its opinion, is flood liable.(2) The Council may consent to the carrying out of development on floodliable land if:(a)(b)(c)(d)the development is for a purpose ancillary or incidental to the useof land for the purpose of agriculture, orthe development comprises the extension or alteration of anexisting dwelling-house, orthe land is in any urban zone under this plan, orthe Council has received a flood assessment report, in relation tothe land, that addresses each of the matters referred to insubclause (3), and the Council is of the opinion that thedevelopment is feasible despite the land being flood liable.(3) In considering an application to which subclause (2) applies, theCouncil must make an assessment of:(a)(b)(c)the likely levels, velocity, sedimentation and debris carryingeffects of flooding,the structural sufficiency of any building the subject of theapplication and its ability to withstand flooding,the effect which the development, if carried out, will or is likely tohave on the flow characteristics of floodwaters,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 85
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(d)(e)whether or not access to the site will be possible during a flood,andthe likely increased demand for assistance from emergencyservices during a flood.Comment(4) In granting consent to a development application made pursuant tosubclause (2), the Council may impose conditions that set floor levels,require filling, structural changes or additions or require othermeasures to mitigate the effects of flooding or assist in emergencysituations.The EA is supported by a flood assessment report prepared by Webb McKeown Pty Ltdwhich forms Annexure K to this EA. Flooding issues are further discussed in Section7.10 of this EA.Figure 9 details the zoning provisions applying to the site.6.6 DEVELOPM<strong>ENT</strong> CONTROL PLANS (DCPs)DCP No. 18 – Car Parking GuidelinesCouncil’s Car Parking Guidelines, DCP 18, provides the requirements for on-site carparking for developments. In relation to this proposal, the Guidelines require parking atthe following rates outlined in Table 5.Table 5Car Parking Requirements under DCP 18Land UseGeneral Industry - FactoriesCouncil Requirement1 space per 100 m 2 gross floor area.Given the nature of this project, which involves the placement of large pieces of plantwithin buildings and therefore the size of buildings does not necessary correlate withemployee numbers and parking demand, the above parking rate is not really relevant tothis proposal. In this regard the works associated with this proposal will involve thefollowing approximate areas:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 86
Figure 9: Planning provisions applying to the Site.FIGURE 9
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 6Ethanol Upgrade Parking Assessment – DCP No.18Plant Approximate Area (m 2 )Starch Dryer 700 m 2Gas-fired Boiler 150 m 2Extension to DDGLoadoutEvaporatorBioscrubbersPellet PlantDDGS DryersMCC Room500 m 250 m 2200 m 2200 m 22400 m 2375 m 2Gas-fired Co-generator Plant 1000 m 2Chemical Storage 150 m 2Packing Plant 3000 m 2Fire Services 200 m 2Total Area 8925 m 2Based upon Council’s DCP requirements the development would require to provideabout 89 car parking spaces in addition to the existing situation.DCP No. 18 parking requirements however have little relevance to the specificrequirements of this project. The areas associated with this project relate mainly to thehousing of specific plant, which in most cases are of a significant size, and requirehousing for noise attenuation purposes. There is therefore no correlation between thescale of the works proposed and the likely number of employees that will be generatedby these works.Under these circumstances a site specific car parking assessment supports this proposaland is included in the Traffic Impact Assessment. This assessment addresses theparking requirements for the proposal in light of the likely additional employmentgenerated by the proposal.The EA is supported by a Traffic Impact Assessment prepared by Christopher StapletonConsulting (Annexure G). Parking requirements for the project are further addressed inSection 7.7 of this EA.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 87
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryDCP No. 93 − Controls Waste Minimisation and ManagementThis DCP requires that development applications consider the management andreduction of waste. A separate Waste Management Report accompanies the EA(Annexure L) prepared by Stephenson Environmental Management Australia. Thismatter is further addressed in Section 7.11 of this EA.DCP 106 – Floodplain ManagementThis DCP provides guidelines for development on flood prone land. The objectives ofthe DCP are as follows:“a)To minimise risk to human life and damage to property by controllingdevelopment on flood prone land;b) To ensure that developers and the community are conscious of thepotential flood hazard and consequent risk associated with the use anddevelopment of land within the floodplain;c) To establish guidelines for development on flood prone land havingregard to the NSW Flood Policy and NSW Floodplain DevelopmentManual (2005);d) To protect the integrity of floodplains and floodways;e) To ensure that all land uses and essential services are appropriatelysited and designed in recognition of all potential floods;f) To ensure that development on the floodplain does not adversely affectthe amenity or ecology of an area;g) To ensure that development on the floodplain complies with EcologicalSustainable Development principals and guidelines;h) To ensure that development on flood prone land does not place anunacceptable financial burden on landowners or the community; and,i) To control development and works within each floodplain having regardto the characteristics of each floodplain and the level of information thatis available for each floodplain, in particular the availability ofFloodplain Risk Management Studies and Plans prepared inaccordance with the NSW Floodplain Management Manual (2005).”Flooding impacts of the proposal are addressed in Section 7.10 of the EA. WebbMcKeown & Associates were engaged by Shoalhaven Starches to address thehydraulic, economic, social and environmental impacts of flooding associated with thisproposal. The report forms Annexure L to this EA.In terms of the provisions of DCP No. 106, Webb McKeown’s report makes the followingcomments:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 88
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry“It is noted that a Final Shoalhaven River Floodplain Risk Management Planhas not been issued but a Draft has been with Council for over 12 monthsand is in the last stages of being finalised. In light of this Webb McKeownhave assessed the flooding impacts associated with the proposed worksassuming that there is a current Floodplain Risk Management Plan for thestudy area.Determination of Relevant ControlsLand Use Category:Flood Planning Area:Industrial + Earthworks + Non-Urban OpenSpace(Taken from Draft Shoalhaven River FloodplainRisk Management Study.) High HazardFloodway adjacent to the bank of theShoalhaven River and High Hazard FloodStorage away from the bank.Compliance RequirementsThe following requirements need to be satisfied in order to comply with DCP106 – Floodplain Management. The responses are provided in Capitals andin Bold beneath.Floor Level of Buildings1% AEP + 0.5 m (Flood Planning Level)Shoalhaven Starches will undertake their own flood damage riskassessment for each building, taking into account the use of thebuilding, damage potential, access requirements and other suchinformation. These details will be addressed at the detail design stageand submitted with the construction certificate.Building ComponentsAny part of the building below the Flood Planning Level must be built of floodcompatible materials.These details will be addressed at the detail design stage andsubmitted with the construction certificate.Structural SoundnessAn appropriate Consulting Engineer’s Report must be provided stating thatthe building/structure can withstand floodwaters including debris andbuoyancy forces up to a 0.2% AEP event (or 1% AEP + 0.5 m whichever isthe higher).These details will be addressed at the detail design stage andsubmitted with the construction certificate.Flood AffectationAn appropriate Consulting Engineer’s Report is provided stating that thedevelopment will not increase flood hazard or flood damage to otherCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 89
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryproperties or adversely affect flood behaviour for a 5% AEP up to the PMPscenario.Documented as part of this present reportAccessReliable emergency vehicle and pedestrian access is required during a 1%AEP event.It is not possible to provide emergency access due to the low lyingnature of Bolong Road. Shoalhaven Starches has a flood evacuationplan (Appendix C) and this will ensure all staff are safely removed fromthe site prior to inundation.Flood Evacuation PlanAn Engineer’s Report must be provided demonstrating that permanent, failsafe, maintenance free measures are incorporated in the development toensure the timely, orderly and safe evacuation of people is possible from thearea and that it will not add significant cost and disruption to the communityor SES.Refer Shoalhaven Starches ‘Flood Evacuation Plan in Appendix C.Management and DesignThe applicant is to demonstrate that there is an area where hazardous andvaluable goods can be stored above the flood planning level.These details will be addressed at the detail design stage andsubmitted with the construction certificate.”6.7 APPROVAL REGIME FOR PROJECTAs outlined above in Section 6.2.1, the proposed development meets the criteria for aMajor Project under Part 3A of the EP&A Act and SEPP (Major Project) 2005. Theconsent authority for the project will be the Minister for Planning.In accordance with Part 3A of the EP&A Act, approvals listed under eight Acts listedunder Section 75U Clause 1 of the EP&A Act are not required.The existing development has an Environmental Protection Licence (EPL) under theProtection of the Environment Operations Act 1997 (POEO Act) (EPL No. 883). Theproposal is required to demonstrate that the proposal will be able to satisfy the existingrequirements of this licence.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 90
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.0 KEY ISSUESThe Director-General of Planning has issued requirements for the preparation of this EA,dated 2 nd May2008. These requirements were revised from those originally proposed on the17 th January 2008. The following section of the EA addresses those key issues as outlined inthe requirements of the Director-General of the Department of Planning for the EnvironmentalAssessment for this proposal. Annexure A to this EA provides a summary of therequirements and stipulates where within the EA the requirements are addressed.Annexure B provides a summary of the requirements of the relevant government agenciesand stipulates where within the EA these issues are addressed.7.1 AIR QUALITY (INCLUDING ODOUR) A<strong>SSESSM</strong><strong>ENT</strong>GHD Pty Ltd (GHD) was engaged by Shoalhaven Starches to conduct an air qualityimpact assessment. A copy of this assessment forms Annexure M to this EA. Thissection of the EA is based upon the findings of this assessment.The air quality assessment carried out by GHD demonstrates that:• adequate action will be taken to mitigate odour impact at the existing level ofproduction to achieve compliance with Section 129 of the Protection of theEnvironment Operations Act 1997 (POEO Act); and• the proposed upgrade to the facility will satisfy the requirements for potential airquality impacts, in particular offensive odour impact, on public health, amenity andthe environment.Air quality, and in particular odours, have long been an issue of contention with respectto the Shoalhaven Starches operation.Members of the community have made a number of complaints to Shoalhaven Starchesand the NSW Department of Environment and Climate Change (DECC; formerly knownas the Department of Environment and Conservation (DEC) and Environment ProtectionAgency (EPA)) regarding odours reported to have emanated from Shoalhaven Starchesoperations. Following investigation of odour complaints, DECC successfully prosecutedShoalhaven Starches in the Land and Environment Court for the emission of offensiveodours.The Land and Environment Court judgement of 2 November 2006 required ShoalhavenStarches to engage a suitably qualified person to conduct a comprehensiveenvironmental audit of the factory and environmental farm in order to identify andquantify all odours generated by the operations, and to provide recommendations for theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 91
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryimproved management of odours. Shoalhaven Starches engaged GHD to conduct theenvironmental audit.The environmental audit of odour sources at Shoalhaven Starches was conductedbetween December 2006 and June 2007. The audit considered the management ofprocesses, activities and substances stored or used at the premises that generate orhave the potential to generate odours.The findings of the “Shoalhaven Starches Environmental Audit – Odour Sources” (GHD,2007), hereinafter referred to as the ‘Audit Report’, form the basis of the data for theassessment prepared by GHD and which supports this EA, with additional informationcollected in the time since the Audit Report supplied by Shoalhaven Starches.Therefore, as an integral part of the proposed upgrade to the company’s Ethanol Plant,Shoalhaven Starches also propose to implement odour mitigation measures, identified inthe Audit Report, at the Environmental Farm and for both the existing factory site and theodour sources associated with the proposed ethanol upgrade operations.7.1.1 Environmental AuditOverview of the Audit ReportThe main processing and materials treatment areas at Shoalhaven Starches comprisethe starch plant, glucose plant, ethanol and distillation plant, DDG plant andenvironmental farm. Each of these plants was examined by GHD to identify processes,activities and substances stored that were potential sources of odour. The auditidentified 20 potential sources in the starch plant, 27 in the glucose plant, 36 in theethanol and distillation plants, 48 in the DDG plant and 18 at the environmental farm.Subsequent to the odour emission inventory and atmospheric dispersion model analysis,a list of principal sources was identified for further assessment within the audit. Thesewere distinguished by being the highest mass emission rate odour sources, sources witha very unpleasant hedonic tone and sources with the high potential to contribute toground level impact at sensitive receptors. This list of principal odour sources includedthe Environmental Farm (all odour sources) and 52 individual odour sources at thefactory.Odour Management PlanPotential odour control measures (prevention and minimisation) were identified for theprincipal sources of potentially offensive odour from the factory and the EnvironmentalFarm.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 92
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryOdour controls at the factory primarily involved improved housekeeping, collection andtreatment of emissions using biological treatment, and containment of fugitive emissionsfrom buildings by more complete enclosure of the buildings and application of a negativeair pressure.Long-term odour management strategies were identified for the Environmental Farm asa whole, which primarily involves installation of a biological (anaerobic and aerobic)wastewater treatment plant.The Air Quality Assessment Report prepared by GHD (Annexure M) prioritises odourmanagement target areas stemming from the Audit Report and the rationale behindeach ranking. The ranking forms the basis of the staged implementation of odourmitigation actions. Management of lower ranked sources (e.g. examples from theglucose and distillation plants) would yield such diminished returns on equipment orprocess modification, given the low relative contribution of each individual source, thatthat such modifications could not be reasonably justified.Odour Management for Principal Factory SourcesThe odour minimisation and control measures identified for implementation at theShoalhaven Starches factory include:• Improvements to atmospheric dispersion;• Improvements to industrial ventilation and housekeeping; and• Installation of a biological treatment system to treat significant odour sources.Atmospheric DispersionThe use of elevated emission points (stacks) can reduce odour concentration atdownwind ground level receptors because of atmospheric dispersion (ie. dilution withambient air).The technical framework document for the assessment and management of odour fromstationary sources in NSW (DEC, 2006) states that good control practice for any stackshould:• be high enough to minimise building downwash;• have a minimum exhaust velocity of 15 m/s to avoid stack-tip downwash;• have a final vertical discharge directed vertically upwards; and• have a free vertical discharge (ie. not have rain caps, which would restrict theupward flow).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 93
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThis form of odour control has been selected for principal odour sources that have a highvolume of exhaust emissions, which cannot be prevented or practically treated to reduceodour concentration, such as the gluten and starch dryer exhausts.Industrial VentilationDuctworkThe design and maintenance of the industrial ventilation system used to capture andtransport foul plant air to a downstream control system or discharge point is critical in thefood industry where putrescent contamination in the ductwork can lead to malodorousemissions. If these are exhausted untreated they add to the odour load on downstreamodour control systems.Cooling TowersIn response to the recommendations of the Audit Report, Shoalhaven Starches has putinto practice the following actions:• protection from potentially contaminating materials;• regular monitoring of cooling water and replacement of contaminated cooling water;• potable water or water from the new WWTP will be used in the cooling towers.Condensate will not be used.Fugitive Emissions from BuildingsSignificant fugitive odour emissions have been identified from the DDG Dryer buildingthat houses the existing DDG dryers and associated equipment.Shoalhaven Starches has taken steps to resize the DDG dryer fans to improve the fumecollection system that feeds foul air stream to boilers. Shoalhaven Starches anticipatesthat fugitive emissions from the DDG dryer building can be reduced by up to 90%.Biological Treatment SystemThe use of biological oxidation for odour control is well accepted in the foodmanufacturing industry. BioTrickling Filters (BTF) or BioScrubbers and BioFilters (BF)are types of biological systems.Odorous air streams will be collected in a stainless steel ducting system, which woulduse a combination of close hooding and hard piped connections to collect all selectedDDG odour source emissions and some additional dilution air. The air stream would befed via a venturi wet scrubbing system, which would fulfil two roles. Firstly, it wouldremove readily water-soluble compounds such as methanol, ethanol, propanol andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 94
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryparticulate matter and be discharged to the proposed wastewater treatment plan via atimed blowdown system. Secondly, it would cool and humidify the air streamconditioning it for the biological treatment system. The inlet air stream to the biologicaltreatment system would be controlled at a temperature of less than 40 o C by thehumidification of the air stream.The inlet conditions for the biological system are strict in terms of temperature, watercontent and particulate matter load.The cooling of the air stream would be achieved using a venturi scrubber.After conditioning, the foul air would be then treated using a BioTrickling Filter (BTF).The BTF uses immobilised bacteria in a scrubbing tower to oxidise the components ofthe air stream. The BTF uses an inorganic packing matrix and is able to purge theby-products of oxidation. Additional nutrients are added to the biological system asrequired.DDG Pelletiser PlantShoalhaven Starches proposes to install a pelletiser plant to pelletise existing granularDDG produced at the site as part of the ethanol plant upgrade works. The installation ofa pelletiser plant was one of the recommendations of the Audit Report on the basis thatit reduced fugitive odour and dust emissions currently associated with the handling andstorage of the granular DDG product.The Pellet Plant will be used to pelletise up to 100% of the existing DDG production,depending on market demand, and should better enable Shoalhaven Starches to targetexport opportunities.Air emissions from discharge points associated with the Pellet Plant will be ducted to thebioscrubber via a fabric filter before being discharged to air.An additional measure to reduce fugitive emissions from this plant area is the installationof plastic curtains on the doors to reduce the flow of air through the building.Shoalhaven Starches anticipates that fugitive emissions from the DDG storage areascan be reduced by up to 85%.Odour Management Plan for the Environmental FarmOdour management strategies were identified in the Audit Report for the EnvironmentalFarm as a whole. These primarily involved the installation of a biological (anaerobic andaerobic) wastewater treatment plant, re-use of treated wastewater within the factory; andirrigation of treated wastewater using low mist sprays.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 95
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe proposal includes biological treatment of wastewater from the factory site. A portionof the treated wastewater will be re-used within the factory and the surplus irrigated ontothe Environmental Farm.A Wastewater Treatment Plant (WWTP) will be constructed in stages at theEnvironmental Farm and will be associated with the storage ponds. The WWTP willhave sufficient volumetric and operational capability to treat the total flow and organicload received from the Shoalhaven Starches factory site. The WWTP will be constitutedby sequential anaerobic digestion and aerobic digestion facilities.Treated effluent from this system could be irrigated with low, if any, discernable odouremissions. Any discernible odours released during irrigation are expected to have anearthy or musty characteristic, which is likely to blend with the palette of odour typical ofthe surrounding rural/agricultural environment.7.1.2 Emissions InventoryAir emissions associated with the operation of the Shoalhaven Starches facility andproposed ethanol upgrade may include:• odour;• particulate matter; and• products of combustion.OdourOdour emanating from Shoalhaven Starches is comprised of a complex mixture ofprimarily odorous volatile organic compounds (VOC). VOC speciation data from a rangeof principal odour sources indicates that the individual VOCs within the mixture tend tobe classified under odour-based air quality criteria rather than toxicity-based. Therefore,for the purpose of the assessment carried out by GHD, VOC emissions from ShoalhavenStarches, except VOC emission associated with coal combustion, will be dealt withcollectively as odour.The objective of the odour emission rate (OER) inventory was to derive a worst-casesnapshot of odour emissions based on the available odour emission data. The primarysources of OER data include the OER dataset presented in the Audit Report and theresults of subsequent odour testing commission by Shoalhaven Starches in the period oftime between the completion of the Audit Report and the preparation of this report.In accordance with the Approved Methods for the Sampling and Analysis of AirPollutants in NSW, all OER data used in the assessment carried out by GHD wereCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 96
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderrySTAGE 1collected with consideration to the DECC OM-7, with all odour samples being analysedby an olfactometry laboratory that was NATA accredited for olfactometry to theAustralian Standard 4323.3 2001: Determination of odour concentration by dynamicolfactometry.FactoryA breakdown of the principal odour sources from the existing factory OER and proposedethanol upgrade at the different stages of odour control implementation is given inTable 5-1 of Annexure M to this EA.Table 7 below provides a summarised version of Table 5-1 of the Air QualityAssessment and outlines the overall proposed odour control measures and the relevantstaging of these measures.Table 7Summary – Odour Controls and Staging– Existing Factory and Proposed Ethanol UpgradePlant Odour Source Odour ControlExisting FactoryDDG (liquids)Feed dump tank, condensate tank, vent condenser,finish feed tank, finisher, pump, dryer feed tank, feedholding tank, CIP tank.DDG (Solids) • DDG product storage sheds.• Grounds and cooling towers.• DDG cooler and associated baghouses.• Decanter heat exchanger.• Decanter feed tanksDDG BuildingEthanol • Cooling towers.• Grain Retention Tank 2 / Feed to Distillery / FarmTank.Flour Cyclone and fabric filters. IDBIOPPHKBIORepairGlucose Enzyme tanks. WLStarch • No. 1 – 4 gluten dryers, No. 1, 3, 4, 5 starchdryers, spray dryer.• Kestair dryerWLIVDWLHKDCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 97
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 7 (continued)Plant Odour Source Odour ControlProposed Ethanol UpgradeDDGDDG tank vents/transfer cyclones (6 units) / DDGdryers/decanters (10 units) / Pelletiser Baghouse (2) /general ventilation.Ethanol Fermenters. IDStarch Gluten dryer / gluten grinder. HKSTAGE 2Existing FactorsDDG Condensor drain decanter (1 – 4) BIOEthanol Propagation tanks (1 – 5)Farm tanks.Glucose Enzyme tank BIOProposed Ethanol UpgradeDDG DDG tank vents IVSTAGE 3DDG Light Phase Tank BIODistilleryMolecular sieveVacuum DrumEthanol Jet cooker 2 + 4 / Jet cooler 1 – retention tank. BIOGlucose Drum vacuum receiver / ion exchange effluent tank /Cooker A + B Flash tanksStarchCooker A + B Flash tanksDry gluten binGluten Dryers 1 – 4Starch Dryers 1, 3, 4, 5Note: Odour control abbreviations used are as follows: BIO – bioscrubber, WL – wet-leg installed on tanks tocondense vapour emissions; D – decommissioned plant item; HK – housekeeping actions such as ductworkcleaning and maintenance; IV – industrial ventilation improvements; ID – improve dispersion from discharge points;PP – DDG pelletiser plant installation; CTS – common tall stack; Nil – no odour control at this stage.BIOBIOBIOBIOBIOCTSCTSBased upon the above it is evident that the majority of odour control measures willinvolve Stage 1 control measures.The staging of odour control implementation proposed by Shoalhaven Starches is basedon the prioritisation of the factory odour sources as presented in Table 3-1 of the AirQuality Assessment prepared by GHD (Annexure M).The timing for each odour control stage is as follows:• Stage 1 – April 2009 (subject to date of approval) includes:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 98
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry−−−−−−duct high priority DDG (liquid and solid lines) odour sources to the bioscrubber;install wet-legs on key odour sources that are not ducted to the bioscrubber atthis stage;clean starch and gluten dryer ductwork;improve factory housekeeping;pelletise DDG product; anddecommission designated odour sources.• Stage 2 – to reassess within 6 months of completion of Stage 1 and implementingStage 2 odour controls as required, includes:−−duct medium priority odour sources to the bioscrubber; andinvestigate feasibility of directing individual starch and gluten dryer dischargepoints upwards and increasing stack heights;• Stage 3 – if required, depending on outcomes at Stage 2, includes:−−duct individual starch and gluten dryer discharge points to a common tall stack(CTS);duct low priority odour sources to the bioscrubber.With the Stage 1 odour controls in place, treatment of potential sources of odourassociated with the proposed ethanol upgrade would be integrated with these odourcontrols.Shoalhaven Starches propose reassessment of the odour controls will involve thefollowing:1. Following completion of odour control stage implementation a meeting will be heldwith the community consultation group to ascertain whether members of thecommunity have experienced reduction in odours.2. A review will be undertaken of the number and nature of complaints received bythe Company in connection with odours.Depending upon the findings of the above measures, odour monitoring may benecessary to evaluate odour control measures.The OER data prepared by GHD show the following key features:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 99
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Odour emissions from the existing factory (468,105 OUm3/s) could be reduced up to66% (158,296 OU m 3 /s) after implementation of Stage 1 odour controls and up to75% (117,852 OU m 3 /s) after stage 2 odour controls. A significantly diminishedOER reduction is evident between Stage 2 and Stage 3, however, this does nottranslate into a diminished reduction in the potential for off-site odour impactbecause the primary action in Stage 3 is improved dispersion from the gluten andstarch dryers through the installation of a common tall stack or equivalent measure.• The ethanol upgrade results in an incremental increase to the factory OER ofapproximately 24% (or 49,583 OU m 3 /s) with Stage 1 odour controls. A similarincrement is evident for the other stages as a result of odour control for the ethanolupgrade being applied at the outset.• OERs for each existing factory source assigned to the bioscrubber total 79,594OU m 3 /s, 137,021 OU m 3 /s and 145,721 at Stages 1, 2 and 3, respectively. It isanticipated that the bioscrubber would achieve an odour removal efficiency of atleast 85%.• After the ethanol upgrade, the incremental increase to the bioscrubber load atStages 1, 2 and 3 is 14,238 OU m3/s, 16,363 OU m3/s and 16,363 OU m3/s,respectively; and• OERs for each individual source assigned to the common stack at Stage 3 total58,069 OU m 3 /s.Odour emission testing has not been previously conducted on the coal-fired boilerNo. 5/6 exhaust stack (EPA DP 35). Recent odour testing conducted to determine theodour destruction efficiency of the boiler, which is currently used to treat odorousemissions from the DDG dryers and transfer cyclones, indicated that the OER input fromthe DDG dryers and cyclones is less than the OER at the boiler exhaust. This resultsuggests that the coal-fired boiler exhaust gases are a source of odour emissions.Odour character tests suggest a combination of typical combustion type odourscharacteristics and low level DDG type odours. The measured OER for the boiler No.5/6 exhaust was 80,761 OU m 3 /s. Of this total, less than 10% can be attributed to theDDG sources that are ducted to the boiler for treatment because the total OER for theseDDG sources was determined to be 8,321 OU m 3 /s at the inlet to the boiler. Furthertests are being conducted to ascertain the DDG odour destruction efficiency of the boiler.As part of Stage 1 odour controls, Shoalhaven Starches has taken steps to resize DDGdryer fans to improve fume collection system that feeds foul air stream to boilers.Therefore, to account for this, reallocation of the odour emissions to a different releaseCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 100
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrypoint, 90% of the measured fugitive emissions from the DDG dryer building have beenadded to the odour emission load from the DDG dryer/cyclones of 8,321 OU m 3 /s to givea total of 71,775 OU m 3 /s (DDG odours) emitted from the boiler 5/6 stack at Stage 1.This is a conservative approach as it assumes an odour destruction efficiency of zero –this approach will be used until further information becomes available on the actualdestruction efficiency.Foul process air from the DDG dryers is not ducted to Boilers No. 2 or No. 4. Theseboilers were found to have OERs of 13,104 OU m 3 /s and 22,889 OU m 3 /s, respectively.Therefore, collectively, the three boiler exhaust stacks represent a significant proportionof the total factory OER (13,104 + 22,889 + 72,440 OU m 3 /s). However, these odouremissions do not represent a significant proportion of odour impact at ground level dueto the good dispersive characteristics of these discharge points (tall stacks with buoyantplumes) and the fact that the meteorological condition that would bring about maximumodour impact from the boiler stacks (unstable atmosphere) is opposite to the conditionsthat would result in maximum odour impact from the rest of the factory odour sources atground level or near ground plume release). Furthermore, the character of the odouremitted from the boilers is different from the factory odour, which further decreases therisk of cumulative odour impact. Therefore, for the purposes of this assessment, odoursemanating from the boilers as a result of coal-combustion have not been included in thedispersion modelling assessment.Environmental FarmThe clear condensates are pumped to storage ponds (Ponds No. 1, 2, 3, 5 and 6) at theEnvironmental Farm, where they are acidified with sulfuric acid to limit microbial activityand hence odour generation. The ‘dirty’ wastewater streams are, combined in the farmtank (located at the factory) and pumped to a partially covered pond for storage wherethey are acidified. Prior to wastewater disposal by irrigation on pasture at theEnvironmental Farm using spray irrigators (travellers or pivot sprays equipped with lowmist nozzles), lime is added in the mixer tank to wastewater drawn from the ponds toraise the pH.The majority of the emitted odours had a hedonic range from mildly pleasant to mildlyunpleasant, with the exception of the mixer tank vent (F1) and Pond 4 (F5), which hadvery unpleasant hedonic tones.In response to the recommendations of the Audit Report, Shoalhaven Starchesproposed to install and operate a wastewater treatment plant. Key components includedCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 101
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythe bulk volume fermenter (BVF), sulfur oxidising (SO) basin and membrane batchreactor (MBR) plant – refer to Section 7.3 of the EA for details on the WWTP.In deriving the OER inventory for before and after the WWTP installation, a typicalirrigation rate at the environmental farm of approximately 5 to 6 ML in a given day wasadopted. This was assumed to comprise the use of pivot irrigator No. 130 (equippedwith low mist nozzles) plus two small travellers and two large travellers.A breakdown of the odour sources from the existing operation at the EnvironmentalFarm before and after the installation of the proposed wastewater treatment plant isgiven in Table 8Table 8OER Inventory - Environmental FarmOdour Source <strong>Group</strong>OER before WWTP(OU m 3 /s)OER after WWTP(OU m 3 /s)Mixer tank 150,000 Nil 1Ponds 290,000 3,600 2Spray irrigation 540,000 Negligible 3Irrigated land 90,000 Negligible 3BVF − Negligible 4MBR plant 5 − 500SO Basin 6 − 23,400TOTAL 1,070,000 27,500123456Decommissioned with installation of WWTP.Treated effluent storage pond for new WWTP. Adopted specific OER = 0.1 OU/m 2 /s fortreated effluent ponds (assumed to be pond 5).ADI (the supplier of the WWTP) advised Shoalhaven Starches that the treated effluent fromthe SO basin could be irrigated with low, if any, discernable odour emissions. Any discernibleodours released during irrigation are expected to have an earthy or musty characteristics,which is likely to blend with the palette of odour typical of the surrounding rural/agriculturalenvironment.A small negative pressure will be maintained under the BVF cover so that the gas mixture(biogas) can be continuously drawn for use as an energy source.Adopted specific OER = 1.0 OU/m 2 /s for MBR plant with exposed surface area ofapproximately 500 m 2 .It is assumed that the surface of the SO basin would have an odour emission gradient rangingfrom 2.5 to 0.2 OU/m 2 /s. Adopted mean specific OER = 1.4 OU/m 2 /s, which was applied tothe exposed surface area of approximately 17,300 m 2 . A higher specific OER was adopted forthe SO basin than the MBR on the assumption that there would be less activated sludge in theSO basin to adsorb the odorous compounds.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 102
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe OER data presented in Table 8 show that odour emissions from the EnvironmentalFarm under normal operating conditions could be reduced by approximately 95% aftercommissioning of the proposed wastewater treatment plant.The proposed ethanol upgrade has been factored into the design of the proposedwastewater treatment system and, as such, no incremental increase in potential odourgeneration is expected as a result of the ethanol project.Particulate MatterThe term total suspended particulate (TSP) matter refers to airborne particles typicallyless than 50 microns (µm) in aerodynamic diameter. The fraction of suspended particlesthat is less than 10 µm is referred to as PM10.The primary source of particulate matter emissions at Shoalhaven Starches factory is thecoal-fired boilers used for steam generation. Coal ash from the boilers may either settleout in the boiler (bottom ash) or be entrained in the flue gas (fly ash). The secondarysource of this type of emissions are the significant material dryers, grinders and materialhandling units within the factory, which are equipped with fabric filters (baghouses) orwet-scrubbers to control emissions to air.Shoalhaven Starches also proposed to operate (stand-by) gas-fired boilers at thefactory. PM10 is emitted in very low amounts from natural gas combustion. Hence theinfrequent operation of these stand-by systems is not anticipated to result in a significantincrease to PM10 emissions or off-site impact.Fugitive emissions of TSP and PM10 have not been included in GHD’s assessment.GHD assumed that the application of standard dust mitigation measures (eg.housekeeping) would provide adequate control to minimise air quality impacts.The TSP and PM10 emission data show the following key features:• the ethanol upgrade results in a negligible (< 3% TSP, < 8% PM10) incrementalincrease to both PM10 and TSP emissions; and• the total TSP and PM10 emission rates are 13.3 g/s and 3.9 g/s, respectively.The Protection of the Environment Operations (Clean Air) Regulation 2002 prescribesthe maximum in-stack concentrations for commercial and industrial activities and plant.The results of GHD’s modelling indicate that boilers No. 2 and No. 4 do not meetregulations for in-stack TSP concentration. Shoalhaven Starches advised GHD thataction would be taken to clean and repair the existing emission control system (cyclone)and then re-test each boiler exhaust for compliance. If the tests were not satisfactory,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 103
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryinvestigations would be undertaken to i) install fabric filtration (baghouse) systems; or ii)install gas burners to replace the existing coal-fired boiler.The proposed gluten dryer and gluten grinder would be fitted with fabric filtration systemsthat would be able to achieve an in-stack concentration of < 10 mg/m 3 , which complieswith the Schedule 4 – <strong>Group</strong> 6 requirements of 20 mg/m 3 TSP.In-stack emission concentration data for the gas-fired boilers and turbines were notavailable for this assessment, however, it is anticipated that exhaust would be compliantwith the regulations mentioned above.Products of CombustionThe primary pollutants from coal and gas fired boilers are oxides of nitrogen (NO x ),formed by the high temperatures in the combustors, sulfur dioxide (SO 2 ), formed fromthe sulfur content of the fuel, VOCs, polycyclic aromatic hydrocarbons (PAH) and carbonmonoxide (CO), all formed by incomplete combustion of the fuel.The Protection of the Environment Operations (Clean Air) Regulation 2002 prescribesthe maximum in-stack concentrations for commercial and industrial activities and plant.According to GHD, in-stack emission concentration data for the proposed gas-fired boilerand turbines were not available for their assessment, however, GHD anticipate thatproposed boiler/turbine exhaust would be compliant with the regulations mentionedabove.ConstructionThe types of emissions to air during the construction process will primarily consist of:• dust emissions from both the mechanical disturbance and wind erosion of crustalmaterial; and• exhaust emissions from the range of motor vehicle and mobile plant required for theproject.The major potential dust sources during construction activity are expected to include:• clearance of vegetation, rock and soil material;• general surface earthworks and construction works;• top soil and soil handling (eg stockpiling, loading, dumping);• levelling and grading of soil surfaces;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 104
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• passage of construction and administrative vehicles over unsealed sections of roador localised unconsolidated soil surfaces; and• wind erosion of unstable/uncovered surfaces and stockpiles and otherunconsolidated surfaces.Recommended in-principle air quality mitigation measures to minimise potential impactson air quality during project construction include:• Site managers should be provided with daily weather updates that would containwarnings of the onset of strong winds. The site manager could then take steps topre-water construction areas and stockpiles before they are disturbed and continuewatering during any activities where fugitive dust may be produced;• Dry material should be watered prior to it being loaded for haulage;• Physical barriers should be constructed to act as windbreaks for the constructionsite or for stockpile areas;• Dust screens (eg. shade cloth) should be installed on construction site boundariesthat are adjacent to sensitive receptors;• Storage piles should be a suitable height, width and slope and placed in areasprotected from the wind and away from public places where possible. Spoilstockpiles should be water sprayed regularly and dry material stockpiles should becovered;• Existing vegetation should be retained where possible or re-vegetate cleared areasand stockpiles with fast growing species for rapid coverage to temporarily orpermanently stabilise soil;• Construction traffic should be controlled by designating specific routes for haulageand access. Vehicle speeds should be limited to 25 km/h;• All trucks hauling dirt, sand, soil or other loose materials to and from theconstruction site should be covered;• Material spillage on roads and pathways should be cleaned up immediately;• Earthmoving activities should be suspended during times of high winds, particularlywhen dust plumes are directed towards sensitive receptors; and• All construction vehicles, mobile plant and machinery should be maintained andoperated in accordance with the manufacturers’ specifications to minimise exhaustemissions.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 105
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.1.3 Assessment of Air Quality ImpactsThe air quality impact assessment criteria are applicable at the nearest existing or likelyfuture off-site sensitive receptors. The predicted incremental impact (predicted impactdue to Shoalhaven Starches operations) and the predicted total impact (incrementalimpact plus background) of each pollutant modelled by GHD are detailed as follows:OdourThe predicted odour impact for the existing factory under several operating scenarioswas examined by GHD to gain a better understanding of the predicted odour levels thatwould occur after implementing the nominated stages of odour control (ie. EnvironmentalFarm odour sources are not included in the models).The extent of interaction between the odour plumes emanating from the factory andEnvironmental Farm was also examined by GHD.FactoryOdour model simulations were conducted by GHD to predict the impact for each of thescenarios described in Table 9Table 9Odour Model ScenariosScenarioABCDEFScenario DescriptionFactory principal odour sources withexisting level of odour controlFactory principal odour sources withStage 1 odour controlFactory principal odour sources withStage 1 odour control plus ethanolupgrade odour sourcesFactory principal odour sources withStage 2 odour control plus ethanolupgrade odour sourcesFactory principal odour sources withStage 3 odour control plus ethanolupgrade odour sourcesFactory principal odour sources withexisting level of odour control minusDDG plant odour sourcesOdourControlEthanolUpgradeFigureExisting No 8Stage 1 No 9Stage 1 Yes 10Stage 2 Yes 11Stage 3 Yes 12Existing No 13For each scenario, the model odour predictions at each grid receptor were ranked fromhighest to lowest and the 88th highest (99%ile, 1-second average). Predictions at eachCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 106
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryreceptor were then contoured. These contours (or concentration isopleths) wereoverlaid upon a scaled aerial photograph of the area for interpretation and comparisonwith the odour criteria. The concentration contour plots for each odour model scenarioare presented in Figures 10 to 16.Table 10 summarises the results of the odour model scenarios, it shows the predictedodour concentration at the factory site boundary and at sensitive receptors in Nowra,North Nowra, Bomaderry and Terara.Table 10Odour Model Results - FactoryPredicted Ground Level Odour (OU, 99%ile, 1-sec. avg)Ref.Scenario DescriptionA Factory principal odoursources with existing levelof odour controlB Factory principal odoursources with Stage 1 odourcontrolC Factory principal odoursources with Stage 1 odourcontrol plus ethanolupgrade odour sourcesD Factory principal odoursources with Stage 2 odourcontrol plus ethanolupgrade odour sourcesE Factory principal odoursources with Stage 3 odourcontrol plus ethanolupgrade odour sourcesF Factory principal odoursources with existing levelof odour control minusDDG plant odour sourcesBomaderry(R1)N Nowra(R2)Nowra(R3)Terara(R4)Factory –westernboundary40 13 20 18 1005 3 5 5 ~ 206 3 5 5 ~ 203 2 3 3 ~ 102 1 < 2 < 2 ~ 55 2 5 5 ~The results presented in Table 6 are summarised as follows:Existing Odour Control – Scenario APredicted odour concentrations for the existing factory indicate that the 2 OU (99%ile,1-second average) criterion is not met at any of the receptors, with odour levels ofapproximately 40 OU on the southern fringes of Bomaderry and 20 OU on the northernfringes of Nowra (refer to Figure 10).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 107
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryStage 1 Odour Control – Scenario BA substantial reduction in off-site odour impact is clearly evident after implementation ofstage 1 odour control to the existing factory, with predicted odour levels in the range of3 to 5 OU at the closer sensitive receptors (refer to Figure 11).Stage 1 Odour Control Plus Ethanol Upgrade– Scenario CThe ethanol upgrade model results show a slight (~ 20%) increase to the predictedodour levels at the sensitive receptor at Bomaderry (R1) but did not show a significantincrease at the other receptors.These results suggest that, for the most part, application of stage 1 odour controls to thefactory has essentially countered the potential for significant incremental odour impact asa result of the proposed ethanol upgrade (refer to Figure 12).Stage 2 Odour Control Plus Ethanol Upgrade– Scenario DImplementation of stage 2 odour control results in a further decrease in predicted odourimpact but the predicted odour levels at the sensitive receptors are still above 2 OUcriterion at three of the four receptors (Figure 13).However, it is noteworthy that the predicted odour levels are the same or slightly lowerthan the predicted odour levels for Scenario F (Figure 15), which represents the factoryprior to the installation of the DDG plant.Stage 3 Odour Control Plus Ethanol Upgrade– Scenario EWith implementation of stage 3 odour control at the factory the 2 OU criterion is met atall sensitive receptors at Bomaderry, Terara, North Nowra and Nowra (refer toFigure 14).ImplicationsThe factory odour emissions can be a significant odour source contributing to off-siteodour impact, particularly in the residential areas immediately adjacent to the factory.A breakdown of the odour source contribution to the predicted ground level odourindicates that the DDG plant contributes the greatest (~ 50%) to the predicted odourimpact at receptors adjacent to the factory (Nowra, North Nowra, Bomaderry andTerara).Furthermore, the model results for the existing factory operation correspond with theodour complaint history over the last few years since installation of the DDG plant at thefactory. That history was marked by complaints from residents located in Bomaderryand Nowra. Prior to the installation of the DDG plant, odour complaints attributed to theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 108
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryfactory operation were infrequent. This supports the notion that, although it is likely thatthe nearby sensitive receptors did not experience a period that was free of odourimpacts with respect the factory operations without the DDG plant, the level of odourimpact was likely to have been inoffensive.Analysis of the odour source contribution to the predicted ground level odour afterimplementation of stage 1 odour control (Scenario C) indicates that the starch and glutendryers contribute approximately 30% to the predicted odour impact at receptors adjacentto the factory and up to 50% of the predicted odour level after the implementation ofstage 2 odour control (Scenario D). This equates to approximately 2 OU for each ofthese scenarios, which on its own indicates that odour emissions from these sources aresufficient to breach the odour criterion. However, the odour character (flour, dough,grain) and hedonic tone (ranging from mildly pleasant to mildly unpleasant) of theemissions from these sources is not likely to be considered offensive. Theunderstanding that odour complaints against the factory have not been directly attributedto the operation of these dryers supports this.Therefore, in light of the above, the staged approach to odour managementimplementation is merited in that progression to stage 3 odour control to meet the 2 OUcriterion, may not be warranted if the incidence of odour complaint is effectively mitigatedat Stage 1 or Stage 2.It should also be borne in mind that the 2 OU criterion was developed to limit odournuisance to acceptable levels. Modelling to determine compliance or otherwise to thecriterion according to GHD is a design tool rather than a regulatory tool, and theoverriding goal should be to minimise odour complaints rather than obtain technicalattainment of a derived criterion.Factory and Environmental FarmThe extent of interaction between the odour plumes emanating from the factory andEnvironmental Farm (wastewater treatment plant) was examined based on the odouremission estimates for the proposed wastewater treatment plant components (SO basin,MBR and treated effluent storage) at the Environmental Farm (refer to Sections 7.3) andfactory odour emissions after stage 1 odour control plus the ethanol upgrade(Scenario G).Figure 16 shows that there is not a significant increase to the predicted odour levels atthe selected receptors near the factory as a result of adding the odour emissions fromCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 109
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythe wastewater treatment plant into the model that represents the factory after stage 1odour control plus the ethanol upgrade (compared to scenario C in previous section).Figure 16 also shows that the 7 OU criterion would be achieved at the rural residenceslocated near the environmental farm. The 7 OU contour is confined within theEnvironmental Farm boundary except for a minor excursion over the southern boundary.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 110
Figure 10: Factory Odour Impact Model – Scenario A (Existing Factory)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 111
Figure 11: Factory Odour Impact Model – Scenario B (Existing Factory with Stage 1 Odour Control)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 112
Figure 12: Factory Odour Impact Model – Scenario C (Factory with Stage 1 Odour Control and Ethanol Upgrade)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 113
Figure 13: Factory Odour Impact Model – Scenario D (Factory with Stage 2 Odour Control and Ethanol UpgradeCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 114
Figure 14: Factory Odour Impact Model – Scenario E (Factory with Stage 3 Odour Control and Ethanol Upgrade)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 115
Figure 15: Factory Odour Impact Model – Scenario F (Existing Factory without DDG Plant)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 116
Figure 16: Factory and Environmental Farm Odour Impact Model – Scenario GCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 117
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryParticulate MatterThe air quality impacts of PM10 and TSP emissions from Shoalhaven Starches (includesethanol upgrade and stage 1 odour control) operation have been assessed usingatmospheric dispersion modelling.The impact of dust emissions principally relates to the potential effect on human healthon inhalation of particles in the air column, and it is the finer fraction (PM10) that havethe greater potential to cause respiratory health effects.A secondary effect relates to the deposition of the course fraction of TSP onto surfaces(eg. car roofs, clothes line at nearby receptors), which is an impact on amenity. Typical,depositions effects are confined to short ranges, as the settling velocity of the courseparticles is significant and drop out from the dust plume is local only.In GHD’s assessment the off-site in-air concentration of TSP and PM10 has beenmodelled so as to determine the off-site health risk to exposure to particular emissions.The amenity impacts of dust deposition is assumed to be confined within the siteboundary and surrounding industrial area and therefore has not been modelled. In anyevent, modelling of deposition rate requires particle size distribution data from eachsource and is unable to model wet deposition to any degree of accuracy.Table 11 provides a summary of the predicted incremental PM10 and TSPconcentrations at the nearest receptors.PollutantAveragingPeriodTable 11Odour Model Results - FactoryPredicted Incremental Ground Level Concentration(µg/m 3 )Bomaderry(R1)N Nowra(R2)Nowra(R3)PM10 24-hour 10 5 7 4Terara(R4)PM 10 Annual 1 0.5 0.5 0.75TSP Annual 2 1 1 1.5Table 11 shows that the predicted incremental impact at each sensitive receptor is atleast an order of magnitude below the PM10 criteria of 50 µg/m 3 (24-hour) and 30 µg/m 3(annual) and TSP criterion of 90 µg/m 3 (annual). Therefore, it is likely that impact ofemissions from the boilers and dryers on a day-to-day basis would be negligible.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 118
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryIt is also evident from the results in the above table that even with the addition of a PM10background level of 15 – 20 µg/m 3 , the total (cumulative) impact would still be well belowthe assessment criteria.Figure 17 shows the 24-hour average ground level concentration contours for particulatematter less than 10µm (PM10). The highest predicted concentration at the nearestreceptors is 10 µg/m 3 , which is 20% of the assessment criterion of 50 µg/m 3 .Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 119
Figure 17: Maximum Predicted Ground Level PM10 Concentrations (24-hour Average) (Aerial image sourced from Google Earth Pro 2007)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 120
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryProducts of CombustionNitrogen DioxideThe DECC Approved Methods outlines three approved methods for assessing theoxidation of nitrogen oxide to nitrogen dioxide in the atmosphere. Method 1 was used byGHD whereby it was assumed that 100% of the oxides of nitrogen emitted are convertedto nitrogen dioxide. There are two levels of assessment for this method:• Level 1 assessment: Maximum 1 hour predicted and maximum 1 hour backgroundnitrogen dioxide concentration; and• Level 2 Assessment: Contemporaneous 1-hour predicted and 1-hour backgroundnitrogen dioxide concentration.As contemporaneous site-specific background air quality data was not available, alevel 2 assessment could not be made.According to GHD, the maximum (100 percentile) predicted total (incremental plusbackground) impact for nitrogen dioxide would readily comply with the 1-hour and annualaverage criteria at the sensitive receivers.Sulphur DioxideAccording to GHD the maximum predicted ground level sulphur dioxide concentrationswere found to be well below the DECC criteria at the sensitive receptors.The DECC air quality criteria for sulphur dioxide also includes a short-term peakconcentration (10-minute average) limit of 712 µg/m 3 . Dispersion models, such asCALPUFF, use the power law expression to link short-term averaging at t minutes (t < 60minutes) to 1-hour average as (C t /C 60 ) = (60/t) 0.2 . Applying this relationship, underconservative assumptions, the peak 10-minute average ground level sulphur dioxideconcentration is expected to be approximately 1.5 times higher than the maximumpredicted 1-hour ground level concentration, which according to GHD at all receptors,would be readily compliant with the criterion.Carbon MonoxideAccording to GHD the maximum (100 percentile) predicted ground level carbonmonoxide concentrations were also found to be well below the DECC criteria at thesensitive receptors.The DECC air quality criteria for carbon monoxide also includes a short-term peakconcentration (15-minute average) limit of 100 mg/m 3 . According to GHD, the peakCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 121
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry15-minute average ground level carbon monoxide concentration is expected to beapproximately 1.3 times higher than the maximum predicted 1-hour ground levelconcentration, which, at all receptors, would be readily compliant with the criterion.Heavy MetalsA screening approach was used by GHD to assess compliance with the air qualityimpact assessment criteria for heavy metals. The aggregate mass emissions for Type 1heavy metals (antimony, arsenic, cadmium, lead and mercury) and Type 2 (beryllium,chromium, cobalt, manganese, nickel and selenium) were modelled and compared inturn against the criterion for each species. In affect in each simulation it is assumed byGHD that 100% of the aggregate is solely portioned to the metal concerned, which willobviously provide an overestimate of predicted impact for each individual heavy metalwithin each group.The maximum predicted (99.9 percentile, 1-hour average) ground level heavy metaltype 1 concentration, at the most exposed sensitive receptor (R1), was 0.00004 mg/m 3 ,which is lower than the respective air quality criteria for all constituents, except forcadmium at 0.000018 mg/m 3 . The maximum predicted (99.9 percentile, 1-hour average)ground level cadmium concentration at the most exposed sensitive receptor (R1) was0.0000009 mg/m 3 , which complies with the criterion.The maximum predicted (99.9 percentile, 1-hour average) ground level heavy metaltype 2 concentration, at the most exposed receptor (R1), was 0.000035 mg/m 3 , which islower than the respective air quality criteria for all constituents, except for beryllium at0.000004 mg/m 3 . The maximum predicted (99.9 percentile, 1-hour average) groundlevel beryllium concentration at the most exposed sensitive receptor (R1) was 0.000002mg/m 3 , which complies with the criterion.The DECC criteria also require consideration to be given to the maximum predictedground level concentration at and beyond the site boundary of the factory. According toGHD the maximum predicted (99.9 percentile, 1-hour average) ground levelconcentration for each heavy metal complies with the respective criteria at the factorysite boundary, except beryllium. However, the beryllium criterion is met within a distanceof less than 100 metres from the northwest site boundary.Emissions from boiler stack no. 2 and no. 4 make the greatest contribution to groundlevel impact near the site boundary. Stack emission test data for these boilers indicatesthat a significant proportion of the measured heavy metals are likely to be adsorbed tothe emitted particulate matter, therefore, improvements that will be made to theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 122
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryparticulate emission control systems on these boilers should also reduce the levels ofheavy metals emitted.VOCOrganic compounds emitted as minority products of fossil fuel (natural gas and coal)combustion may include:• Acetaldehyde;• Benzene;• Carbon disulphide;• Chloroform;• Cyanide;• Ethyl benzene;• Formaldehyde;• Methyl ethyl ketone;• Methyl methacrylate;• Phenol;• Toluene;• Styrene; and• Xylene.Speciated VOC emission data for the boiler exhaust emissions were not available forGHD’s assessment.Therefore, a screening approach was used to assess compliance with the air qualityimpact assessment criteria for the compounds listed above. Total VOCs were modelledby GHD using the total VOC mass emission rate and the predicted peak aggregate VOCground level concentration was determined. This value will obviously provide an overestimateof predicted impact for each individual compound.The maximum predicted (99.9 percentile, 1-hour average) ground level aggregate VOCconcentration, at and beyond the factory site boundary, was 0.017 mg/m 3 , which is lowerthan the respective DECC principal toxic air pollutant criteria for all the compounds listedabove.The maximum predicted (99.9 percentile, 1-hour average) ground level total VOC, at themost exposed sensitive receptor (R1), was 0.005 mg/m 3 , which shows that an evengreater margin of compliance would be achieved at the nearest sensitive receptor.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 123
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPAHAccording to GHD the maximum predicted (99.9 percentile, 1-hour average) ground leveltotal PAH concentration, at and beyond the factory site boundary, was 0.0011 µg/m 3 ,which is lower than the DECC PAH criterion of 0.4 µg/m 3 .The maximum predicted (99.9 percentile, 1-hour average) ground level total VOC, at themost exposed sensitive receptor (R1), was 0.00019 µg/m 3 , which is 0.05% of thecriterion – that is more than 1000-fold below the criterion at the most exposed receptor.7.1.4 ConclusionsThe air pollution emission inventory and dispersion modelling for the proposed ethanolupgrade has led to the following conclusions, as presented by GHD:• “In this assessment, odour, particulates and products of combustionwere assessed against DECC air quality impact assessment criteria. Allconstituents assessed over all relevant averaging times were below theirrespective assessment criteria for the adopted emission characteristics,with the exception of odour. Odour was found to be the criticalconstituent for compliance with the DECC air quality impact criteria;• The implementation of stage 1 odour controls to the factory wouldessentially counter the potential for significant incremental odour impactas a result of the proposed ethanol upgrade. Approximately 70% ofpotentially odorous emissions associated with the proposed ethanolupgrade would be treated using a bioscrubber. The remaining odouremissions would be subject to odour minimisation measures, whichinclude adequate dispersion and ventilation maintenance (e.g. ductworkcleaning) – refer to section 8.1.1;• Model results indicate that the implementation of stage 3 odour controlat the factory would be required to achieve compliance with the DECCdesign odour criterion of 2 OU at the nearest sensitive receptors.However, it was demonstrated that installation of a wastewater treatmentplant at the environmental farm and stage 2 or even stage 1 odourcontrol measures at the factory might sufficiently mitigate the potentialfor future offensive odour impact (e.g. odour complaints) – refer toSection 8.1.1; and• There is not a significant incremental increase to the predicted odourlevels at the receptors near the factory, when odour emissions from theproposed wastewater treatment plant at the environmental farm aretaken into consideration using the adopted emission characteristicsdetailed in the emission inventory. Furthermore, the model shows thatthe 7 OU odour criterion would be achieved at the rural residenceslocated near the environmental farm – refer to section 8.1.2.”It is evident from the findings and conclusions of the Air Quality Assessment carried outby GHD Pty Ltd that particulates and products of combustion associated with theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 124
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryproposed ethanol upgrade were found to be below the relevant assessment criteria forthe adopted emission characteristics.Odour however was found to be the critical constituent for compliance with DECC airquality impact criteria.In light of the findings and conclusions of the Air Quality Assessment, ShoalhavenStarches propose to integrate the Ethanol Production Upgrade with the OdourManagement Plan that has been developed for the site and which emanated from theEnvironmental Audit that GHD Pty Ltd has undertaken of the site.Shoalhaven Starches therefore commit to the odour control measures as detailed inTable 5-1 of the Air Quality Assessment and which are summarised in Table 7 ofthis EA.Shoalhaven Starches furthermore commit to treat waste water generated from factoryprocess sequentially through anaerobic and aerobic digestion systems to be establishedwithin the existing approved wet weather storage pond No. 7, and as described inSection 5.8.2 of the EA.Furthermore Shoalhaven Starches will commit to the implementation of the above odourcontrol measures in three stages, in a manner as detailed in Table 5-1 of the Air QualityAssessment prepared by GHD Pty Ltd and as summarised in Table 7 of this EA.The staging of the odour control implementation proposed by Shoalhaven Starches isbased on the prioritisation of the odour sources as presented in Table 3-1 of the AirQuality Assessment prepared by GHD Pty Ltd.The timing for each odour control stage will be as follows:• Stage 1 – December 2008;• Stage 2 – Reassess within 6 months of completion of Stage 1 and implement Stage2 as required; and• Stage 3 – if required, depending upon outcomes of Stage 2.To assess the outcomes of each stage of the odour management controls ShoalhavenStarches will undertake the following measures:1. Following completion of each stage of odour control measures, a meeting will beheld with the Community Consultation <strong>Group</strong> to ascertain whether members of thecommunity have experienced improvement in terms of odours.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 125
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry2. A review will also be undertaken of the number and nature of complaints receivedby the Company in connection with odours.If following these measures it is evident that there is a reduction in the number ofcomplaints; and the local Community Consultation <strong>Group</strong> indicate improvements, thenworks associated with subsequent stages will be deferred.However if there is no demonstrated improvement, then odour monitoring will beundertaken to further evaluate odour control measures.If as a result of this monitoring it is found that odours are still emanating from the site,works associated with subsequent stages of the odour management plan will beundertaken.7.2 GREENHOUSE GAS EMISSIONSGHD were engaged by Shoalhaven Starches to undertake a greenhouse assessment ofthe project. A copy of this assessment is included as Annexure N of this EA.The scope of this assessment has been based on the Director-General’s requirementsfor the environmental assessment of the Project:A full greenhouse gas assessment, including a quantitative analysis ofthe scope 1, 2 and 3 emissions of the project, and a qualitative analysisof the impacts of these emissions, in accordance with the requirementsof the Australian Greenhouse Office’s Factors and Methods Workbook2006;Evaluate the feasibility of measures to reduce and/or offset emissions,including an analysis of energy use.The methodology for conducting the assessment has been based on the Department ofPlanning’s Guidelines Energy and Greenhouse in EIA, August 2002 (the ‘Guidelines’).The Guidelines set out a systematic approach to the assessment of the energy andgreenhouse impacts associated with a proposal.The purpose of the greenhouse assessment carried out by GHD was to calculate theemissions of greenhouse gases associated with the proposed development, and tocompare these to the baseline scenario. In order to obtain a comprehensive estimate,emission sources were considered (both direct and indirect), associated with:• The construction of the new plant;• The preparation and acquisition of raw materials;• Transfer of major raw materials (including wheat) to Bomaderry by truck or train;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 126
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Energy and fuel used on site for the production of ethanol, starch, gluten and otherproducts, including grid electricity, natural gas, petroleum, diesel, etc;• Storage of products on site;• Waste disposal and wastewater treatment;• Transport of products from Shoalhaven Starches to depots, distributors andconsumers;• Usage of ethanol blend fuels; and• Final plant decommissioning.The emissions from these life cycle stages were then aggregated and compared to theno-change scenario of continuing to operate the current Shoalhaven Starches facility(without upgrade).The greenhouse assessment was prepared by GHD in accordance with the generalprinciples of:• The recognised international standard –The Greenhouse Gas Protocol, A CorporateAccounting and Reporting Standard developed by the World Business Council forSustainable Development (GHG Protocol);• Life Cycle Assessment principles (ISO 14040 series); and• The Department of Climate Change (DCC) National Greenhouse Accounts (NGA)Factors, 2008 (which replaces the Australian Greenhouse Office (AGO) Factors andMethods Workbook).These are considered to represent best practice in Australian greenhouse gasaccounting7.2.1 Energy and Greenhouse AnalysisEnergy Use ResultsBaseline, gross and net energy used during operation are summarised by GHD inTable 12.According to GHD total energy use at the Shoalhaven Starches site will increase by2.7 times current levels. The analysis shows that the primary energy source is thecombustion of natural gas (responsible for 94% of net energy use). The proposedethanol plant upgrade will include a cogeneration facility that will be powered by naturalgas and biogas captured from wastewater treatment. The large increase in natural gasCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 127
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryconsumption will be offset to some extent by a reduction in purchased electricity from thegrid. Following the upgrade, purchased electricity consumption will be cut to 11% ofbaseline usage.Transport energy use for raw materials and products account for 6% and 4% net energyuse respectively. The small increase in coal use for the proposed plant only accounts for2% of net energy use.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 128
Table 12Energy Use SummaryEnergySourceEnergyContentUnitsBaseline Energy Use(Existing Plant)Gross Energy UseExisting and Ethanol Upgrade)Net Energy Use(Upgrade Component)Consumption Units GJ/a Consumption Units GJ/a Consumption Units GJ/aScope 1Coal 27.0 GJ/t 105,000 t/a 2,835,000 109,000 t/a 2,943,000 4,000 t/a 108,000NaturalGas− 168,536 GJ/a 168,536 6,800,000 GJ/a 6,800,000 6,631,464 GJ/a 6,631,464Diesel− on-site38.6 GJ/kL 660 kL/a 25,476 660 kL/a 25,476 0 kL/a 0Scope 2Electricity(total)0.0036 GJ/kWh 129,910,812 kWh/a 467,679 14,000,000 kWh/a 50,400 -115,910,812 kWh/a -417,279Scope 3Diesel− Rawmaterialtransport38.6 GJ/kL 3,105 kL/a 119,834 14,870 kL/a 573,970 11,765 kL/a 454,136Diesel− Producttransport38.6 GJ/kL 13,315 kL/a 513,952 21,263 kL/a 820,740 7,948 kL/a 306,788Total 4,130,478 11,213,586 7,083,109Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 129
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryGreenhouse Emission ResultsThe results from the greenhouse assessment are summarised by GHD in Table 13below.Table 13Greenhouse Gas Emissions Assessment Results by Life Cycle Stage and ScopeLife Cycle StageBaselineEmissions 1GrossEmissions 2NetEmissions 3Units t CO2 - e/a t CO2-e/a t CO2 - e/a UncertaintyConstruction (annualised over30 years)0 302 302 HighRaw material supply 174,335 421,284 246,949 ModerateRaw material transport toBomaderry9,003 43,122 34,119 ModerateManufacture at Bomaderry 445,969 736, 709 290,740 LowProduct transportation 28,613 61,662 23,049 ModerateProduct usage -96,730 -461,842 -365,12 HighDecommissioning (annualisedover 30 years)0 -31 -31 HighTotal Emissions 667,920 1,263,088 749,257Total Credits -96,730 -461,882 -519,241Total 4 571,190 801,206 230,016Scope 1 emissions componentof totalScope 2 emissions componentof totalScope 3 emissions componentof totalNotes:Listed figures may not sum exactly to the totals due to rounding.1. Baseline emissions of the existing Shoalhaven Starches plant2. Gross emissions of the existing and new plant292,136 611,097 318,962115,621 12,460 -103,161163,433 177,649 14,2153. Net Emissions is calculated as gross emissions minus baseline emissions4. Total annual emissions based on annual Scope 1, 2 and Scope 3 emissions (including annualised construction anddecommissioning emissions).Baseline EmissionsThe total baseline emissions for the existing plant, based on the 2006/07 period, amountto 571,190 t CO2-e per annum. These emissions include the Scope 1, 2 and 3emissions associated with the production of ethanol and other products at the site, andthe upstream and downstream impacts. Construction and decommissioning are notCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 130
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryapplicable. If the proposed plant expansion were not to go ahead, the emissionsassociated with the baseline would continue into the future.Total Gross EmissionsTotal gross annual net emissions are calculated based on annual Scope 1, 2 and Scope3 emissions, excluding annualised construction and decommissioning emissions.Total gross annual emissions amount to 800,934 tonnes CO2-e compared to 571,190tonnes CO2-e for the existing plant (2006/07 baseline) – an increase of 229,745 tonnesCO2-e (40%). This compares well according to GHD with the total increase in energyusage of 2.7 times current levels and indicates that lower greenhouse intensity fuels arebeing used for the proposed plant.Total annual NSW emissions for 2006/2007 are 158.2 Mega-tonnes CO2-e. Theestimated additional annual emissions from the project account for approximately 0.15%of the state’s total emissions. The estimated total gross emissions (existing andupgrade) from the project account for approximately 0.5% of the total annual emissions.Total (net) project emissionsThe greenhouse assessment indicates total (net) project emissions of 230,016 tonnes ofCO2-e per year, including annualised emissions from the construction anddecommissioning stages of the project. Total estimated missions from the constructionand decommissioning stages have been annualised over a 30 year period.The project will result in a net increase of greenhouse gas emissions, even when thedownstream reduction as a result of replacing petroleum fuels with bioethanol is takeninto account (ie. the increased greenhouse gas emissions of the project will not becompletely offset by the reduced downstream emissions). The use of lower emissionsfuels at the plant will result in the products manufactured at the site having lowerassociated emissions intensities than they have currently (however the larger volumes tobe produced mean that the total emissions will increase).Table 13 shows the total emissions and total credits associated with the no change(baseline) scenario, the proposed development (gross) scenario and the differencebetween them (net). The total emissions figure is the sum of all of the positive emissionsassociated with the production across the life cycle.Positive emissions arise from the combustion of fuels, waste disposal, fugitive emissionsof greenhouse gases, etc. The total credits figure is the sum of all the emissions creditsthroughout the life cycle.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 131
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryEmissions credits arise from activities that result in a reduction of greenhouse gasemissions, such as the combustion of ethanol instead of petroleum fuel, the reuse orrecycling of resources instead of using virgin materials, etc. In the same way that thetotal emissions consider the upstream and downstream greenhouse gas emissionsassociated with the activities undertaken by Shoalhaven Starches, the total credits figureconsiders any upstream and downstream reduction in greenhouse gas emissions. Assuch, the total credits are subtracted from the total emissions to calculate the totalemissions associated with the production at Bomaderry, for each of the three consideredscenarios.The Guidelines indicate that the uncertainty associated with emissions should be stated.A qualitative assessment of uncertainty has been included in Table 13, based on theperceived accuracy of the data and emissions factors for each life cycle stage. The mostaccurate emission data is associated with manufacture.The most emissions intensive stage of the project is manufacturing at the Bomaderryproduction site.Total annual NSW emissions for 2006/2007 are 158.2 Mega-tonnes CO2-e (based onAGO ‘State and Territory Greenhouse Gas Inventories 2005 M arch 2007). Theestimated additional annual emissions from the project would account for approximately0.15% of the state’s total emissions.Fuel CombustionThe most emissions intensive stage of the project is manufacturing at the Bomaderryproduction site.Emissions due to product use are negative since they displace emissions due tocombustion of petrol, as indicated in Table 14.Table 14Combustion EmissionsParameter Value UnitsEthanol energy content 23.4 GJ/kLEnergy content petrol 34.2 GJ/kLPetrol EF 2.5 t CO2-e/kL1 kL ethanol replaces 0.684 kL petrolEmissions eliminated -1.711 t CO2-e/kL ethanolCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 132
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryMajor emission sourcesThe top ten annual net emission sources are listed in Table 15. It can be seen that thethree highest emission sources are:1. Natural gas combustion (58% of positive emissions);2. Flour production (15% of positive emissions);3. Grain production (9% of positive emissions).These emission sources are responsible for 82% of positive emissions. The total for theten highest sources captures 97% of positive emissions.RankingTable 15Top 10 Net Emission SourcesSourceEmissions(t CO2-e)Fraction of netpositive emissions1 Natural Gas 434,361 58.0%2 Flour production 115,208 15.4%3 Grain production 66,949 8.9%4 Millfeed production 29,880 4.0%5 Sugar transportation 28,632 3.8%6 Lime production 16,293 2.2%7 Sugar production 12,512 1.7%8 Coal combustion 10,055 1.3%9 Starch distribution 7,775 1.0%10 Stillage distribution 4,738Total 721,666 97.0%The top 3 credits in the net emissions inventory are:1. Replacement of petroleum with ethanol fuels;2. Reduction in electricity consumption;3. Wastewater treatment biogas capture.These emission sources are responsible for credits of 517,288 tCO2-e/a. The total of allthe credits are equivalent to 519,241 tCO2-e/a.Greenhouse IntensityGreenhouse intensity is normally expressed as the emissions per unit of production foroperational emissions only (based on current practice with DCC Greenhouse ChallengeCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 133
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryreporting requirements). The greenhouse intensity can be used to benchmark againstan organisation’s previous performance or across an industry sector.In summary, according to GHD net emissions intensity is lower than both the gross andbaseline emissions intensities. When compared to NGA average values for ethanolproduction, the Shoalhaven Starches values are considerably lower. The currentproduction emission intensity value is approximately 5% lower, and following theupgrade the intensity will be 16% lower. The net emissions intensity is approximately26% lower than the Australian average value. These differences should be consideredindicative only, since they fall within the uncertainty of the emissions intensity values.Best Practice Ethanol EmissionsIn Australia, fuel ethanol can be manufactured from a number of sources, includingwheat, sugar cane, molasses and wood waste, however, at present it is onlymanufactured on a commercial scale from the fermentation of sugars from wheat andmolasses. A large fraction of the total life cycle emissions associated with the productionof fuel ethanol arises from the production and processing of the major raw materialinputs. Significant savings are therefore achieved when a waste material from anotherprocess is utilised, rather than an agricultural input that is grown for the purpose.CSIRO (and partners) published a report in 2003 titled “Final Report (EV45A/2/F3C) tothe Australian Greenhouse Office on the Stage 2 study of Life-cycle Emissions Analysisof Alternative Fuels for Heavy Vehicles” which used life cycle assessment principles tocompare environmental indicators for a number of fuels.Best practice fuel ethanol production uses wood waste as the major raw material.Although ethanol produced from wood waste has a much lower emission intensity thanany of the other feedstocks, the production of ethanol in this way is still largely in theresearch and development stage, and there are no facilities in Australia that produceethanol in this way on a mass scale.The next best technology options are associated with the fermentation of wheat starchand wheat starch waste. Best practice in this sector also involves heat recovery fromwheat straw, with an emissions intensity of 0.8 t CO2-e/kL.The process currently undertaken by Shoalhaven Starches uses wheat starch waste asthe feedstock, although the proposed expansion will also ferment wheat grain andrefined sugar to produce ethanol. The emissions intensity of ethanol produced atShoalhaven Starches following the upgrade will be 0.96 t CO2-e/kL.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 134
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAlthough the Shoalhaven Starches process does not include (or propose to include) heatrecovery from the combustion of wheat waste, these materials are sold as a usefulproduct (animal feed), and are not wasted.Until ethanol production from wood waste becomes a commercial option, productionfrom wheat and wheat starch waste, such as the process carried out by ShoalhavenStarches, will represent the lowest emissions option in Australia.International processes and production have not been included in the assessment byGHD because growing conditions, and the markets for raw materials and processproducts and by products, vary considerably from Australian conditions, and as such, arenot considered to be comparable.7.2.2 Greenhouse Emission ReductionDirect Greenhouse Gas MinimisationAccording to GHD direct greenhouse gas emissions (ie. those generated on site) can beminimised at the Shoalhaven Starches site by:• Adoption of best available technology for fuel combustion;• Greenhouse gas capture and destruction; and• Switching from high-emissions to low-emissions fuels.Adoption of best available technologyThe proposed plant will incorporate a gas fired cogeneration plant. This representsaccording to GHD the best available technology economically achievable to meet theheat and energy needs of the proposed plant.Additional equipment for the proposed plant, such as fermentation tanks, cooling towers,dryers, evaporators, etc will be designed to minimise operational energy use.Greenhouse gas captureThe existing plant sends wastewater to a series of treatment ponds, where anaerobicdecomposition generates methane. This methane is not captured from the system andcontributes to greenhouse gas emissions (approximately 5% of current positiveemissions).The proposed plant incorporates a new wastewater treatment system where 100% ofbiogas generated is captured for energy generation. This will effectively reducegreenhouse emissions by 31,000 tonnes per annum, and will recover 260 TJ annually,further reducing Shoalhaven Starches’ consumption of fossil fuels.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 135
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryEmissions savings resulting from the energy recovery from biogas are taken into accountin the calculations. The combustion of the biogas has an emissions factor of zero tonnesof CO2-e per GJ and the fugitive emissions from the wastewater treatment plant are alsozero. If the biogas capture and energy recovery were not undertaken, emissions wouldbe considerably higher, since more natural gas would need to be purchased to meetenergy needs, and methane would be released from the wastewater treatment plant.These avoided emissions result in the products from the plant having lower emissionsintensities than they would otherwise.Fuel use switchingNatural gasThe proposed plant will mainly use natural gas as the primary fuel source. Natural gasproduces much lower greenhouse emissions than the amount of coal of equivalentenergy. Using natural gas in the proposed plant instead of coal saves approximately187,680 t CO2-e/a.CoalFollowing the plant expansion, 109 kt of coal will be used at Bomaderry (gross). Coal isa very emissions intensive fuel, and its use will create approximately 274,000 t CO2-e, or34% of all gross emissions. If the existing coal-fired boiler was replaced with a naturalgas fired boiler, emissions could be reduced by around 81,000 t CO2-e (a reduction of30% compared to the coal emissions, and 10% of the total gross emissions).Replacement of the coal-fired boiler has not been included in the current budget for theproposed plant.DieselShoalhaven Starches uses 660 kL of diesel fuel annually, and this volume will notchange following the upgrade. This results in annual emissions of approximately 1,910 tCO2-e. By switching to a biodiesel blend, emissions could be reduced. A 10% biodiesel(canola) blend would result in total emissions of 1,880 t CO2-e, a reduction of 30 t CO2-e annually, or 0.004% of gross emissions. Any changes would be insignificant.Indirect Greenhouse Gas MinimisationIndirect greenhouse gas emissions (ie. those generated off site as a result of ethanolproduction, such as electricity use) can be minimised at the Shoalhaven Starches siteby:• purchase of renewable energy (GreenPower); andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 136
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• using alternative feedstock.Purchasing 100% GreenPowerShoalhaven Starches current electricity consumption is 130 GWh. Following theupgrade, Shoalhaven Starches will reduce electricity consumption to 14 GWh purchasedfrom the grid. 14 GWh accounts for 14,840 t CO2-e, or 1.8% of total gross emissions.Purchasing 100% accredited renewable energy, such as GreenPower would removethese emissions from the inventory.GreenPower is, however, considerably more expensive than standard grid electricity,and is considerably more expensive than purchasing external greenhouse emissionsoffsets:• GreenPower costs approximately an additional 5 cents per kWh, which equates toan abatement cost of $47/ t CO2-e for NSW electricity; and• There are a number of external greenhouse gas emissions offsets available on themarket, which range in price from less than $10/ t CO2-e to more than $30/ t CO2-e.An average cost is approximately $15/t CO2-e.Following the proposed upgrade, switching to 100% GreenPower would cost anestimated $0.7 million annually for the entire site (plant, farm and wastewater treatmentplant). Offsetting electricity emissions through the purchase of offsets would cost anestimated $0.2 million annually (based on an assumed cost of $15/t CO2-e).While the purchase of external offsets can be counted against emissions from anysource, the use of GreenPower is limited to emissions associated with the use ofelectricity only. The cost to purchase GreenPower has not been included in the currentbudget for the proposed plant.Alternative feedstockOut of the top ten emission sources, five are due to embodied energy in raw materials(flour, grain, millfeed, lime and sugar), which account for 32% of net positive emissions.Other possible grain-based feedstocks will have similar order of magnitude emissions.The only feasible way to significantly reduce raw material emissions is by replacing grainand other premium agricultural products with waste products, which have much lowergreenhouse intensities. It is highly unlikely that there would be sufficient agriculturalwaste products available to manufacture 3 ML of ethanol. Importing waste products toBomaderry would also increase transportation emissions, since they would need to beCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 137
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrysourced more widely that the proposed raw materials, and since they are less effective,a greater quantity would be required. It is not feasible to switch process feedstocks.Offset Residual EmissionsOpportunities to offset residual greenhouse gas emissions include the following:Greenhouse offsets purchaseNet greenhouse emissions amount to 230,016 t CO2-e/a. These emissions could beoffset by purchasing greenhouse offsets or credits. There are a number of offset/creditproviders in the current marketplace, with an average offset cost of around $15/t CO2-e.Costs to offset 100% net emissions amount to approximately $3.5 million annually. (Thecost to offset 100% emissions by purchasing external offsets is currently significantlylower than purchasing GreenPower which would cost $0.7 million to offset only 2% ofemissions.) The cost to purchase offsets has not been included in the current budget forthe proposed plant.Plantation sinksAnother alternative is for Shoalhaven Starches to establish a tree plantation to offsetemissions at a nearby or remote location. Approximately four trees per year are requiredto offset one tonne of CO2-e, so a one million tree plantation (over 1,000 hectares)would be required to offset the net emissions from the proposed plant per year. Thisoption is not really feasible for Shoalhaven Starches as it is outside of core business andwould be more cost effective to purchase offsets from existing plantation providers thatare accredited under the DCC Greenhouse Friendly program or NSW Greenhouse GasReduction Scheme.Approximately 4,000 trees have been planted on the environmental farm, and anadditional 4,000 are planned, however, the order of magnitude of these plantings is fartoo small to have a significant impact on Shoalhaven Starches’ net emissions.7.3 WASTEWATER TREATM<strong>ENT</strong>7.3.1 Existing Wastewater Treatment ProcessesSince the 1980s and before cessation of effluent discharges to the river, ShoalhavenStarches has sought to value-add to their list of products from the residuals that resultfrom the primary process. The plant is a food production facility with raw material inputsof water and flour. These are mixed and after a separation process, starch (as slurry ordried) and gluten are extracted as products. Glucose syrup, brewers’ syrup andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 138
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrymaltodextrins also made from starch. The Environmental Farm (EF) was established forthe beneficial re-use of effluent through land application.Since 1995, ethanol has been recovered as a waste product from the starch, gluten andsyrups components of the plant and after distillation several grades for fuel, industry andbeverage applications are produced. All the starch is consumed from the liquid effluentstream. By 2001 the by-products from the fermentation process have also beencaptured for beneficial use. Carbon dioxide (CO 2 ) is harvested by BOC Gases and, afterscreening the liquid effluent, Shoalhaven Starches recovers the suspended solidsprincipally fibre, protein and yeast and produces DDG (dried distillers grain) as a stockfood. The remainder of the effluent stream is irrigated onto the EF.Since 2004 a new evaporation process, stillage recovery, approved by the Minister forPlanning in 2003, was introduced as a further addition to the Pollution ReductionProgram (PRP7) NSW EPA License 883. Through evaporation dissolved substances inthe clarified effluent are concentrated to a thick syrup, very high in BOD, comprisingmainly lactic and acetic acids, yeast protein and minor adjuncts from fermentation. Thissyrup is added to the recovered suspended solids and dried to yield Distillers DriedGrains Syrups (DDGS) which are used as stock feed. As a by-product from evaporation,a condensate is recovered which is more than 99% water although containing residual,steam-volatilised organic substances including low levels of fatty and odorous materials.Nevertheless, the condensate has considerable advantages for both retention, ifnecessary, and for irrigation.The importance of an efficient waste management system can not be emphasisedenough for a food manufacturer. Appropriate handling, processing and storage ofmaterials are included in the Good Manufacturing Practices (GMP) as part of the FoodSafety Policy that The <strong>Manildra</strong> <strong>Group</strong> of Companies maintains. Audits from internal,external, national and international companies, Industry Institutes and authorities areregular and essential to ensure product safety. Hazard Analysis and Critical ControlPoint (HACCP) based Food Safety Management systems are implemented, as arecleaner production principles.As part of Shoalhaven Starches commitment to cleaner production the company has arecord of one of the most efficient water users for this type of industry in the world. Forevery tonne of flour Shoalhaven Starches uses 3 tonne of water whereas similarindustries worldwide use as much as three times this amount. All production managersand staff are active in identifying water savings to reduce the environmental load, costand minimise effluent to the farm through improved water management.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 139
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryDespite significant expenditure committed over the past 25 years or so whichprogressively has resulted in significant reduction in pollutants in the effluent, effluentvolume and residual pollutants remain a limitation to further expansion of theShoalhaven Starches operation. Presently, total volume of effluent is approximately4.6 ML per day comprising about 3 ML per day of condensate with reduced organic loadplus 1 ML per day of “washdown” water that includes effluent contributions from severalprocesses and contains a higher level of organic substances. When favourable climateand soil conditions allow, the combined total effluent is irrigated (after addition of lime toachieve the required pH). If irrigation is not immediately possible then the condensateand washdown streams are stored separately. The washdown water is acidified withsulphuric acid and stored in a covered pond to prevent odour release until such time as itcan be irrigated.In order to further expand the ethanol production operations, it proposed to install a fullwaste water treatment plant that will minimise organic waste, eliminate odour, allowwater and biogas generation to be reused within the factory.7.3.2 Wastewater Treatment and Fitness for Purpose of Treated Effluent.The WWTP Proposed to be InstalledIt is proposed to install a full biological wastewater treatment plant to minimise theamount of bio-degradable organic substances in the combined effluent (“condensate”and “washdown” streams) from the Shoalhaven Starches plant. Full biologicalwastewater treatment will be implemented prior to the commencement of operation ofthe upgrade to the ethanol production process. After biological treatment a further twotiers of physical filtration processes will be installed to enable treated water to be utilisedfor particular re-use applications.Extensive data obtained over years of analysis of effluent sampling and volumerecording of various effluent streams has enabled a Shoalhaven Starches to determinethe average Chemical Oxygen Demand (COD) and Biological Oxygen Demand (BOD)for the combined effluent from the plant which will represent the in-feed to the WWTP.Maximum and minimum levels have also been determined to provide assurance thatWWTP design will more than meet the average and peak demands on the system.Detailed modelling and projections of increased water usage and increased effluentvolume generation with increasing production have been made by Shoalhaven Starchesto ensure that the proposed waste water treatment plant will have more than adequatecapacity to meet the maximum demand at the fully expanded status.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 140
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryProjections made on the basis of proposed increase in flour throughput and dataaccumulated by Shoalhaven Starches from designated sampling points according to theCompany’s EPL indicate that up to 8.10 ML / day of effluent may in-flow to the proposedWWTP containing current key pollutant concentrations at an average COD of 8000ppm,average BOD of 2800ppm, Total Suspended Solids (TSS) of 2700ppm, Total Nitrogen of44 ppm and Total Phosphorus of 20 ppm. The combined effluent will reach the WWTPwith a pH in the range 3.0 – 3.5.Magnesium hydroxide will be dosed into the effluent to neutralise the acidity with anestimated requirement of about 980 kg/day and temporarily stored in a 3 ML capacitybuffer tank to allow provision of a uniform feed to anaerobic digestion.To best absorb the range of volume flow and organic load a Bulk Volume Fermenter(BVF) type reactor is proposed with a capacity of 90 ML (providing an average residencetime of about 11 days). This facility together with the subsequent aerobic pond will besupplied by ADI Systems Inc., Canada. The COD and BOD of the out-flow from the BVFare projected to be reduced to 800 and 280 ppm, and the TSS to 270 ppm respectively.The BVF will be a completely enclosed lagoon having a floating insulated cover securedat the perimeter thereby preventing the emanation of odours. This will greatly amelioratethe odour emission from the effluent on the Farm in accordance with recommendationsof the GHD “Audit Report”.Plate 12 shows an example of the type of cover that will be installed with this componentof the proposal.Plate 12: Example of cover over BVFCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 141
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAnaerobic digestion of the organic substances contained in the in-feed to the BVF willgenerate 30,000 m 3 /day of biogas containing 65% methane. This will be drawn off thelagoon under mild negative pressure and piped to the Shoalhaven Starches plant fordirect usage as fuel, partially replacing natural gas for the provision of steam.It is proposed that out-flow from the BVF will be directed to one of two aerobic treatmentprocesses having regard to the quantities of water required to be treated and to thesubsequent purpose. Deodorisation and further reduction of BOD will be achieved byaeration followed by prolonged holding in a large volume Sulphide Oxidation (SO) basinhaving 103 ML capacity and an average holding time of 40 days. Out-flow from the SObasin is predicted to be reduced to about 70 ppm BOD and 240 ppm COD, and TSS of190 ppm. The suitability of this effluent for irrigation on the Environmental Farm isdiscussed further in Section 7.4 of this EA.Figure 18 is a flow diagram depicting the proposed BVF/SO Basin system.Plate 13 Is an aerial photograph taken over the pond complex located upon theShoalhaven Starches Environmental Farm. The pond shown under construction in thisphotograph is the pond associated with this proposal.Plate 13: Aerial photograph over pond complex.For re-use in the Shoalhaven Starches production plant, water must be treated to reduceCOD and BOD. A more effective method (of aerobic digestion of COD and BODtogether with separation of Suspended Solids is proposed by the installation andoperation of a Membrane Bio-Reactor (MBR). In this smaller tank configuration of onlyabout 4 ML, effluent from the BVF will be vigorously aerated for a shorter time toCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 142
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryextensively reduce the COD and BOD further reducing the potential for odorousemissions. When sufficiently reduced, treated water will be filtered throughmicrofiltration membranes under very low driving pressure, so the membranes becomeonly minimally fouled and can be effectively cleaned by regular, intermittent back-flush.Figure 19 is a flow diagram depicting the proposed MBR/RO system.Plate 14 provides a photograph of an example of MBR/RO plant while Figure 20provides a diagrammatic view of such a plant.Plate 14: Example of an MBR/RO plant.Systems using both flat-sheet and hollow-fibre membrane configurations have beenconsidered. The more modern and innovative hollow fibre configuration offered by TenixAlliance are proposed to be used due to lower power requirements and ease ofmaintenance. There is also industry acceptance of this approach with several majorinstallations operating successfully in Australia. Having the hollow fibres configured inbundles with central air release and bubble abrasion to keep the membrane surfaceclear provides greater efficiency and less power as the air only needs to operate 25% oftime.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 143
Figure 18: Flow diagram depicting the proposed BVF/SO Basin System.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 144
Figure 19: Flow diagram depicting the proposed MBR/RO System.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 145
Figure 20: Diagrammatic view of MBR/RO Plant.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 146
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTreated water discharged from the proposed MBR is estimated by Tenix (based uponhaving the performance of a similar installation at Joe White Maltings, Perth), to result inlevels of COD and BOD of 80 and 14 ppm respectively. The Total Suspended Solids(TSS) is estimated at 3 ppm and the Total Dissolved Solids (TDS) at 1106 ppm. TheTDS represents the sum of all ions. A significant level of magnesium will result from themagnesium hydroxide neutralisation of the feed to the BVF but most particularly a highlevel of bicarbonate ion is predicted to occur due to the neutral to alkaline conditions ofthe BVF and the large quantity of carbon dioxide being generated in the anaerobicdigestion process. The quality of this water is suited to re-use in the plant for severalnon-food applications including washdown, vapour scrubbing and cooling towerevaporation.To enable the re-use of the treated water in food operations, water must be potablestandard as defined by the NHMRC Drinking Water Guidelines 2004 in terms of bothchemical and microbiological content of the treated waste water. The approachproposed is in accordance with the recommendations of the Australian Guidelines forWater Recycling: Managing Health and Environmental Risks (Phase 2) Draft 2007 withthe provision of Multiple Barriers considered to be the foundation for ensuring safedrinking water. The proposed process provides microfiltration, reverse osmosis andchemical sanitation as three sequential barriers to microbial contamination of treatedwater for in-plant re-use.To achieve the required water quality it is proposed that the MBR out-flow (microfiltrationmembrane permeate) will be polished through a Reverse Osmosis (RO) membranesystem that will allow the chemical and microbiological standards to be achieved.A modern design from Koch-Puron using Mega-magnum large diameter spiral-woundmodules supplied through Tenix Alliance is proposed. Due to the large membrane areaaccommodated in each of the 18 inch diameter modules, the amount of pipework will bereduced and simplified, the footprint will be reduced, cleaning costs and chemicals willbe reduced and energy requirements will be reduced. Furthermore it has beendetermined that by using “loose RO” membranes the treated water will contain zero BODbut a low level of dissolved salts conforming with the Guidelines and appropriate to thefood application process in the plant. This facility has an advantage of being able tooperate at only 5 – 10 bar compared to 30 - 40 bar typically required for normal RO. Theconsequences will be reduced energy requirements, less noise from the mediumpressurepumps and more cost effective, lighter pipe construction. The RO plant will besized to enable supply of all of the water required for processing flour to starch, glutenand other products.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 147
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryRO membranes do not allow passage of micro-organisms through the membranes,therefore water permeating the membranes will be sterile. It is proposed however thatsome short term storage of the purified water will be necessary as a buffer to productionprocesses, introducing a low level of risk of microbiological contamination in the storedwater. To minimise this risk a chlorine or chlorine dioxide-based sanitation system willbe provided to ensure that the microbiological standards of the Drinking WaterGuidelines are met. E.coli (thermo tolerant coliforms) are used as indicators of faecalcontamination and hence the safety of water for drinking. Routine microbiological testingof the treated water will be undertaken to ensure that the required standard of absenceof E.coli in 100mL sample of water is continuously achieved.RO membranes allow only water and the smallest of organic chemical molecules suchas ethanol to permeate the membrane. It is proposed however to use more energyefficient, “loose RO” membranes that will allow the permeation of a small proportion ofsome ionic species. The Drinking Water Guidelines are particularly concerned withcontamination by toxic organic substances such as pesticides and inorganic substancessuch as heavy metals that may have a long term toxic effect. The only possible sourceof such pesticides in the industrial waste water from the plant would be through thewheat flour supplied to Shoalhaven Starches. The presence of pesticide residues isroutinely tested at the flour mills. The proposed RO membranes will provide a furthereffective barrier to ensure contamination of the treated water by organic residues doesnot occur.Analysis of effluent to the Environmental Farm has shown that levels of potentially toxicmetals are all below the limits for potable water in the Drinking Water. Projecting thatthese concentrations of dissolved substances pass through the BVF and MBR systemsto reach the RO membrane system, and with ionic rejections specified by the supplier tobe in excess of 75%, then the levels of potentially toxic metal ions in the RO permeatewill be substantially below the limits specified in the Drinking Water Guidelines.It is possible that a very low level of odour and/or flavour may be detectable in thetreated water permeating the RO membranes (as experienced in the Joe White Maltings,Perth, waste water treatment plant) although the feedstock to their MBR is significantlydifferent. In RO trials of evaporator condensate without prior anaerobic digestionconducted at Shoalhaven Starches, a very low residual odour / flavour level waseffectively treated with activated carbon treatment configured in cartridge format toeliminate any carbon leakage. Activated carbon treatment will be installed for eliminationCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 148
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryof odour and flavour in the treated water proposed for re-use in combination with foodmaterials.Prevention of Pollution of WatersThe proposed WWTP will accept and process the total effluent from the ShoalhavenStarches plant predicted to be on average 8.1 ML per day and with capacity toaccommodate predicted daily fluctuations.The WWTP will operate in conjunction with the existing storage ponds providing anadditional 196 ML of capacity in the buffer tank, BVF and SO basin.Routine operation of the Farm requires a minimum application of irrigation water. Thiswill be obtained primarily and directly with treated water from the SO basin and secondlyfrom the retentate from the RO plant. The total treated waste water available to theEnvironmental Farm is predicted to be 3.6 ML/ day.The WWTP will reduce the level of organics in all the primarily-treated waste water, andthrough secondary processing, enabling the re-use in plant of at least 55% of the effluentwater. The suitability of this effluent for irrigation on the Environmental Farm andcompliance with Section 120 of POEO Act 1997 has been considered and provided inSection 7.4 of this EA.Shoalhaven Starches predict the WWTP operating in conjunction with the storage pondswill enable the Shoalhaven Starches plant to operate at the proposed expanded rate.Wastewater Treatment OptionsShoalhaven Starches has carried out an extensive assessment of wastewater treatmentoptions.Extensive trials with MF and RO membrane systems identified options for re-processingand re-use of the large volume of evaporator condensate with low level organic load.Limitations encountered due to very low levels of fat and the difficulty in stripping thispointed to the necessity to fully digest the total organic load by anaerobic and aerobicprocesses.Anaerobic systems have been investigated including extensive discussions withpotential suppliers and inspection of relevant installations. This included considerationof “high-rate” systems using relatively low volumes under digestion with intense digestionfacility and “low-rate” systems having larger volumes with less intense digestion. Thelatter was selected for its ability to more readily absorb significant fluctuations in bothCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 149
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryvolume feed rate and organic load. Furthermore running costs will be lower and thelikelihood of odour emission will also be lower.Aerobic systems were also investigated in conjunction with projected re-use options bothin-plant and on-farm. Given the large volume of treated effluent to be produced from theBVF anaerobic digester requiring further aerobic treatment and in particular the highenergy cost associated with intense aeration, a two-tier system has been selected whichwill allow a proportion of the BVF output to be treated more economically to a qualitysuitable for irrigation purposes through a Sulphide Oxidation basin and a largerproportion to be treated through a Membrane Bio-Reactor to achieve reduction inorganic load to a level suitable for some in-plant applications. As an alternative to use ofan MBR, microfiltration (MF) membrane systems were also considered. MF would haveeffectively removed all suspended solids from the SO basin output but would not haveresulted in further digestion of residual BOD and may have been more expensive to runand maintain due to more dynamic filtration and the need for more frequent cleaning.To re-use the treated water for direct food processing operations, Drinking Waterstandards need to be achieved. Reverse Osmosis systems are widely used in watertreatment for polishing pre-treated water to achieve potable quality. Although ROsystems are now essentially standard operating facilities, there are still developments intechnology being made to achieve greater efficiency and reduced cost. RO systemsfrom several suppliers were considered. Furthermore, RO membranes are availablewith degrees of “tightness” that determines the effective rejection of dissolvedsubstances. For the food application required in Shoalhaven Starches plant a low levelof salt in the water is acceptable and may even be advantageous. The proposed systemcombines the latest in RO technology development, namely the use of “mega-magnum”large diameter modules for compactness and efficiency together with “loose RO”membranes requiring lower pressure to operate and so saving on energy and reducingnoise emanation from pumps.Issues Associated with the RetentateApplication of “loose” Reverse Osmosis to the polishing of the MBR output will result inapproximately 75% of the feed volume permeating the membrane and about 25% (or 1.5ML/day) being rejected as membrane concentrate (or “retentate”). Because hydratedions of different species are of different size their rates of diffusion and the extents towhich they are rejected differ. With between 75 and 98% rejection of the various ions,the concentration of each ion type in the concentrate is a consequence of the extent ofconcentration multiplied by the extent of rejection; the ionic content of the concentrate isCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 150
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryprojected to be about 3970ppm, being the sum of all ion types. However, more than halfof ionic content is bicarbonate which is inherently unstable. One option is to use a smallamount of acid to neutralise the alkaline bicarbonate ion decomposing it leaving lessthan 2000 ppm sum of ions principally those of sodium, magnesium, chloride andphosphate.Apart from the additional magnesium, the total concentration of ions in the combinedeffluent are not predicted to change from the present, therefore, the total predicted ionoutflow to the farm will increase in proportion to the increase in flour throughput in theShoalhaven Starches plant plus the additional magnesium.Several options have been investigated with respect to the disposal of the retentateincluding:1. ocean release;2. evaporation;3. disposal to Council’s sewerage system;4. river release;5. irrigation on to Environmental Farm.The following is a summary of the findings of these investigations.1. Ocean ReleaseTwo ocean release options have been tentatively considered.The first involves the provision of a pipeline from the plant to Shoalhaven Heads and thedirect disposal of the retentate to the ocean through a new ocean outfall.The initial difficulty with this option is the availability of suitable land to construct apipeline through to the ocean. Much of Seven Mile Beach for instance adjoins NationalPark. It would be unlikely that a commercial entity would be able to obtain the necessaryapprovals to construct a pipeline through National Park, notwithstanding theenvironmental implications for laying pipework through National Park.Other options are limited by Crown Land ownership; and subject to Aboriginal landclaims.In addition, pipeline routes may need to traverse environmentally sensitive landsincluding coastal wetlands; coastal dunal areas; or National Park. All options which wereconsidered inappropriate.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 151
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThis option would also necessitate a pipeline with a length of at least 13 – 15 kilometres;which would also involve a prohibitively costly construction.An alternative to creating a new ocean outfall at Shoalhaven Heads is to utilise theexisting sewerage ocean outfall at Culburra Beach. The existing outfall at Culburra hashad its role reduced since the implementation of the Shoalhaven Northern RegionalEffluent Management Scheme. This sewerage management scheme introduced theland application of treated effluent; that had previously been disposed through this oceanoutfall.As with the Shoalhaven Heads option described above, the major constraint fordisposing the retentate to this outfall would be the need to construct a pipeline systemthat would connect into this outfall. It is estimated this would involve a pipeline with adistance of approximately 25 kilometres – which would be prohibitively expensive.2. EvaporationAnother option considered involves evaporating the retentate to extract the salts withinthe retentate as solids. It is envisaged that evaporation would require three separateprocesses to be undertaken:1. The retentate stream would need to be concentrated into a liquor containing 20%TDS. The evaporation required to achieve this rate would be 60 tph.The capital investment necessary to achieve this rate of evaporation would be$8 million; and would involve power consumption of 2000 kw. Significantquantities of sulphuric acid would also be required to break down bicarbonatelevels.2. The second step in the process is to further concentrate the above brine toproduce a slurry of salts, to about 25% solid.This second phase would involve a further capital investment of $2.2 million andconsume 100 kw in power.3. The third phase in the process would involve filtering the above slurry to produce a‘cake’. Typically these salt cakes would contain 40% occluded brine. The cakewould be disposed to landfill. The capital investment to undertake this third systemis estimated to be $0.7 million and involve 22 kw of power consumption.It is evident from the above that evaporation presents several disadvantages:• The capital investment necessary to implement such a process is estimated to beover $10 million.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 152
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• In order to evaporate the retentate into a ‘cake’ product would require considerablepower consumption (and associated generation of greenhouse gas emissions).• At the end of the process the ‘cake’ is required to be disposed to landfill. This isestimated to create 24,000 tonnes of solids per annum. The trucking cost alone($250/tonne) is estimated to cost $6 million per year. Furthermore this rate of wastewould take up valuable landfill space.3. Disposal to Council’s SewerExtensive consultation has been undertaken between Shoalhaven Starches’representatives and Shoalhaven City Council with the view of exploring the disposal ofthe retentate directly into Council’s sewerage system.According to Shoalhaven City Council the main difficulty associated with the retentate isthe elevated levels of TDS (3456) associated with the retentate. These levels exceedthe limits imposed by the proposed extension of the Northern Regional EffluentManagement Scheme to which it is intended to extend to the Bomaderry STP. Councilis therefore unable to accept the retentate into its sewerage management system.4. River ReleaseShoalhaven Starches have also investigated the possibility of diluting the retentate anddisposing it directly into the Shoalhaven River.In carrying out this investigationShoalhaven Starches engaged the CSIRO to undertake a toxicity assessment of theretentate on estuarine biota. This assessment concluded:“The retentate was not acutely toxic to bacteria, amphipods or fish. Theretentate was of low toxicity in the two chronic tests, oyster larvaldevelopment and microalgal growth inhibition.It is possible that the toxicity observed in both chronic tests may be due tometals (copper and zinc) were present in the retentate at concentrations highenough to cause toxicity to both test species. Toxicity would depend on themetals being present in forms that are bioavailable to the test organisms.The estimated ‘safe’ dilution of retentate required to protect 95% of thespecies at the edge of the mixing zone in the Shoalhaven River (with 50%confidence) is 1:13. Thus the initial retentate dilution of 1:30 proposed by<strong>Manildra</strong> prior to river discharge, should be more than sufficient to achievethe “safe” dilution estimated in this study.”Notwithstanding the findings of this assessment that a ‘safe’ dilution could be achieved;the DECC in consultation with Shoalhaven Starches have consistently expressedreservations with respect to permitting river release of the retentate. Under thesecircumstances this option will not be further explored at this time.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 153
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry5. Irrigation to the Environmental FarmGiven the shortcomings associated with the above options the final option that has beeninvestigated with respect to disposal of the retentate is that of land application to theEnvironmental Farm; in conjunction with the treated waste waters not re-used in thefactory process. This option is further explored in Section 7.4 of the EA.7.4 EFFLU<strong>ENT</strong> IRRIGATION AND STORAGEThis section of the EAR is based upon a joint report prepared on behalf of ShoalhavenStarches by Dr John Murtagh (Agricultural Water Management), Mr Roy Lawrie (NSWDepartment of Primary Industries) and Glenys Lugg (Shoalhaven Starches Pty Ltd).A copy of this report forms Annexure O(i) to this EA. This report was prepared inresponse to the requirements of the DECC which required:• A full water balance that demonstrates a capacity of the project to avoidwater pollution.• A full irrigation management plan for the Environmental Farm,demonstrating the agronomic capacity of the land, soil, crop and climatecombination to sustainably assimilate the effluent.• Demonstrate that there is sufficient storage to prevent pollution of waterswhen prolonged wet weather prevents irrigation.7.4.1 Local EnvironmentThe monthly rainfall and evapotranspiration at Nowra are summarised in Table 16, andwere based on records from the Bureau of Meteorology. The rainfall records covered 68years from 1940 - 2007 and included a variety of wet and dry years.The panevaporation records were converted to potential rates of evapotranspiration from a mixedsummer-grass/ryegrass pasture by multiplying by appropriate pan and crop coefficients.Table 16Mean Monthly Rainfall and Potential EvapotranspirationMonth J F M A M J J A S O N D YrRain (mm/mth) 90 122 106 96 95 116 55 67 62 90 84 75 1057Evapotranspirationpasture (mm/mth)126 103 95 46 69 56 57 70 100 135 136 130 1123The annual rainfall distribution varied as follows:Driest 1/10 – dry Median 1/10 – wet Wettest515 mm 603 mm 977 mm 1634 mm 2248 mmCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 154
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPoints of note are:• The area receives a moderate rainfall that averages 1057 mm/yr;• Mean rainfall is less than potential evapotranspiration from July-January. Hence,these are the months when irrigation will be most needed, but variation in rainfallcan also create an irrigation demand in any month;• The depressed evapotranspiration in April allows for the effect of renovation beforeover sowing with ryegrass.The pasture evapotranspiration was based on a mixed summer-grass/ryegrass pastureand the higher water use of the ryegrass meant that the seasonal trend also reflectedthe changing species composition between the warmer and cooler months.7.4.2 WastewaterThree general classes of wastewater have been / will be used for irrigation on theenvironmental farm:• Wastewater from the starch production process before June 2004. This flow washeavily limed as part of the odour-control process. The wastewater during thisperiod is termed the pre-dryer wastewater.• From June 2004, some of the wastewater flow was processed through a DDG dryerto remove solids. It dramatically reduced the COD concentration and less lime wasadded to the wastewater. This gave the post-dryer wastewater.• The on-site treatment and reuse of some of the wastewater flow, as part of thecurrent ethanol production upgrade proposal, will cause another marked change incomposition of the wastewater. In addition, the composition of the irrigation waterwill depend on the blending of the waste flow from the sulphur oxidation (SO) pondand a proportion of retentate from the RO plant.With the implementation of the ethanol upgrade, wastewater flows that will be used forirrigation will come from two sources:• Some of the discharges from the sulphur oxidation (SO) basin, amounting to anaverage of 2.1 ML/d. A second discharge stream from the SO basin will directdischarges to a proposed wastewater treatment plant.• The wastewater treatment plant will produce a clean water flow and a retentate flowthat will contain most the water contaminants from the inflow. The retentate flow willaverage 1.5 ML/d and may be used for irrigation.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 155
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe study prepared by Murtagh, Lawrie & Lugg considered three options where none,half or all of the retentate was used for irrigation. Thus the total flow to the farm equalled2.1, 2.85 or 3.6 ML/d.Chemical Composition of WastewaterDetails of the chemical composition are given in Tables 17 and 18. The compositionduring the pre-dryer and post-dryer stages was provided by Shoalhaven Starches,except that the calcium concentration was increased to allow for the calcium hydroxidethat was added as a neutralising agent to the acidified wastewater.The pre-dryer wastewater had a very high nitrogen concentration, much of which was inorganic forms. Hence the nitrate concentration was less than might be expected on firstglance.The suggested composition after the upgrade was also provided by ShoalhavenStarches. It is emphasised that the post-upgrade composition is a tentative estimate. Itwas based on experiences in other plants and may not translate directly to the proposedupgraded plant.Two measures were used to quantify the total concentration of soluble components inthe wastewater:TDS: Total dissolved solids; the combined content of all soluble (pass through a 2 µmsieve) inorganic and organic substances. In the following, the TDS wasestimated by summing the concentrations of the various ions. This approach willintroduce a slight underestimate of the total concentration when minorcomponents are not included.EC:Electrical conductivity; a measure of the conductivity of a solution that is relatedto the TDS. Note that the relation between the two depends on the ioniccomposition. The EC is often used because of the ease of measurement, and asdiscussed later it provides the standard expression of soil salinity whenconsidering the effect on plant growth.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 156
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 17Some Chemical Constituents in Wastewater from Different ProcessesAnalyteUnitPre-dryerComposition of wastewater from:Post-dryerpH pH units ~9 9.1PostupgradeSO basinPostupgraderetentateTDS mg/L 4,802 2,090 1,323 4,399Ca ++ mg/L 2,469 1,042 8 24Mg ++ mg/L 97 17 122 470Na + mg/L 460 167 85 285K + mg/L 12 39CO 3-- -HCO 3- -SO 4- -mg/Lmg/L 850 2,991mg/L 384 23 91Cl - mg/L 800 230 105 392NO 3-PO 4+++mg/L 970 173 60 48mg/L 6 77 60 59Total N mg/L 35,000 39 41Total P mg/L 200 25 112Much of the magnesium in the post-upgrade wastewater will be introduced whenmagnesium hydroxide is added to the buffer tank as a pH stabilising agent. Based onexperience elsewhere, some uncertainty surrounds the continuing need for the treatmentto continue at the suggested level and lower amounts may suffice once the system hasstabilised. Also, other alkaline agents (eg soda ash) could be used at this step. Thepoint to be made here is that there is scope to reduce the magnesium inputs should themagnesium concentration in the soil prove to be a problem over time (see laterdiscussion).The current investigation by Murtagh et al. considered three options, where nil, 50% or100% of the retentate flow was mixed with the waste flow from the SO pond to providethe irrigation water. The resulting net composition of the irrigation water is given inTable 18.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 157
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 18The Net Chemical Composition of the Post-Upgrade IrrigationWater, with Three Proportions of Retentate in Wastewater BlendItemUnitProportion of retentate in wastewaterblendNilretentate50%retentate100%retentateComposition of wastewater blendTotal flow ML/d 2.1 2.85 3.6TDS mg/L 1,325 2,134 2,606TDS load * t/ha/yr 2.1 4.6 7.0Ca ++ mg/L 8 12 15Mg ++ mg/L 122 214 267Na + mg/L 85 138 168K + mg/L 12 19 23- -HCO 3- -SO 4mg/L 850 1413 1742mg/L 23 41 51Cl - mg/L 105 181 225-NO 3+++PO 4mg/L 60 57 55mg/L 60 60 60* The TDS load was calculated for a total irrigation area of 487ha.Points of note are:• The high TDS concentration that increased from 1,325 mg/L with no retentate inirrigation water to 2,606 mg/L with all the retentate in irrigation water;• The substantial reduction in the calcium concentration relative to the current andpast wastewater;• The increase in the magnesium concentration from 18 mg/L in the post-dryer(current) phase to 85-168 mg/L depending on the wastewater blend;• The large amount of bicarbonate in the future wastewater;• The marked reduction in sulphate.The consequences of using irrigation water with these compositions on the sustainabilityof the soil and plant growth are discussed in the next section.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 158
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.4.3 Soil SalinityThe main issue with soil salinity is the addition of solutes to the soil solution that canharm plants through their osmotic effect on water and nutrient uptake. In this context,the identification of the various solutes is important because of their varying ionicstrengths and behaviour in the soil solution.Past and Present Soil SalinityThe soils on the environmental farm were monitored over many years and the resultsinclude measurements of soil salinity down the soil profile. The 1995-2006 results aretabulated in the annual “Environmental Monitoring Reports” prepared by the NSWDepartment of Primary Industries. The 2007 results were obtained directly from RoyLawrie.The profile measurements were given as the EC in a 1:5 soil:water mixture and weretransformed as follows for purposes of the current investigation:• The various EC measurements from various depths within the upper 50 cm of thesoil profile were used to obtain a root-density weighted mean EC (EC w ). In doing so,the 5 measured values over the 50 cm range were weighted with a weight of five inthe uppermost sample (10 cm) ranging to a weight of one at 50 cm, which was thelowermost sample that was used. This was done to obtain the effective EC over themajor rooting zone, with the greatest weight applying to depths where roots weremost dense.• This gave the EC w values in Table 19. Since different paddocks were sampled ineach year and some had consistently lower EC concentrations than others,paddock-weighted EC w ’s were calculated for each paddock (Table 20 andFigure 21). The weight was the overall mean EC w divided by the mean for thatpaddock. It was done to counteract the effect of paddock differences on annualmeans given the intermittent sampling.Note that the paddock weighting was done to obtain better estimates of annual means,and only the annual means should be used for direct interpretation.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 159
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 19The Root-Density Weighted EC Concentrations (EC w )in Various Paddocks in Years when Samples were Taken21Levee38Backslope39SwampPaddock110P1EC w (dS/m)130P3140SoperAnnualmean1995 0.90 0.64 0.68 0.741996 1.19 1.1919971998 1.19 1.191999 0.14 0.70 0.65 1.43 1.08 0.802000 0.87 1.32 1.102001 0.55 0.95 0.752002 0.94 1.18 1.062003 1.17 2.23 1.702004 0.70 2.04 1.372005 0.90 1.16 1.032006 0.42 1.73 1.072007 0.28 1.24 0.76Paddockmean0.42 0.86 1.18 0.75 1.48 1.33 1.00Paddock 21 had the lowest EC w while paddocks 130 and 140 had the highest. Manyfactors could contribute to these differences including differences in soil hydraulicproperties, elevation, watertable influence and irrigation volumes. Given that the mainemphasis of the current investigation was to examine the annual change in EC with thechanging quality of the wastewater to estimate future trends, it was beyond the scope ofthe investigation to delve into these issues. Also a commentary on the soil ECmeasurements is provided in the annual monitoring reports.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 160
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 20The Root-Density Weighted and Paddock Weighted Mean EC Concentrationsin Various Paddocks, and Annual Means21Levee38Backslope39SwampPaddock110P1EC w (dS/m)130P3140SoperAnnualmean1995 1.05 0.85 0.46 0.791996 1.01 1.0119971998 1.01 1.011999 0.34 0.82 0.87 0.97 0.82 0.762000 1.17 0.90 1.032001 1.33 0.72 1.022002 1.09 1.00 1.052003 1.57 1.51 1.542004 1.68 1.54 1.612005 1.05 0.99 1.022006 0.56 1.17 0.872007 0.67 0.93 0.80* The paddock weight was the overall mean EC w (1.00 dS/m) divided by the mean EC w for eachpaddock given in Table 1.2.01.6EC W(dS/m)1.2Pre-dryersPostdryers0.80.41995199719992001200320052007YEARFigure 21: The Time Trend in the Root-Density Weighted EC Concentrations.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 161
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe results show:• High EC w values throughout the period.• Markedly higher values in 2003-2004.• An increase in the EC w from 1995 to 2003-2004 (pre-dryer phase), and a decline tohalf the peak value three years later in 2007 (post-dryer phase).• Some annual variation, with lower values in 1995 and 1999.Before the introduction of the DDG dryers, there was a slow increase in the EC w until2002, followed by a large increase during the next two years. It was not clear why thesudden increase occurred. The dryers were introduced in November 2003 but theirimpact on the quality of the irrigation water was delayed until much of the stored andheavily-limed wastewater was used. Hence the 2004 results were placed in the pre-dryerphase. Thereafter the EC w declined and was attributed to the considerable decline inthe wastewater TDS (Table 17).One explanation for the high EC w in 2003-2004 is that the heavily limed wastewatersimply maintained the relatively high EC w until 2002 and that some separate effectcaused the subsequent added increase. One suggestion is that the separate effectcame from the addition of settled solids from the bottom of dams to the irrigation waterduring these years. However the possible effect could not be verified by the chemicaltesting and hence was not allowed for in the estimation of the TDS loads.The various Environmental Monitoring Reports showed inconsistent patterns in thechange in soil salinity with depth, and suggested that the different patterns may berelated to soil type and elevation. One consistent result was that whenever the soil ECin the uppermost sample (10cm) exceeded 2 dS/m the soil salinity always declined withdepth. This was taken to indicate that the highest soil EC’s were caused by recent saltapplications.Factors Affecting Soil SalinityThis section describes attempts to relate the measured EC w values to various drivingfactors (independent variables) in order to understand why the soil salinity variedbetween years and in doing so obtain a relation that could be used to predict futuresalinity after the upgrade.Varying driving factors were investigated and some of the relationships that were testedare graphed in Figure 22.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 162
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry2.01.6ABCEC W(dS/m)1.20.8120.40 100 200 300PERCOLATION (mm/yr)2 3 4IRRIGATION (ML/ha/yr)0 5 10 15 20TDS LOAD (t/ha/yr)Figure 22: The relation between the mean annual EC w between 1995 and 2007and the corresponding annual percolation (A), irrigation volume (B),and TDS load (C). The circles and triangles indicate years when pre-dryerand post-dryer wastewater was used respectively.None of the relations properly explained the high EC w in 2003 and 2004, and asdiscussed below arguments can be developed to either include or exclude these valueswhen developing a predictor relation.The lack of a relation with percolation (Figure 22A) places the soil salinity in a differentclass to the common situation where the salinity is dominated by the soluble and mobilesodium and chloride ions. Under such conditions, and in contrast to the experience onthe Environmental Farm, the leaching of these ions causes a decline EC w when there ishigh rainfall and a high rate of percolation. The message that was drawn from the resultwas that the usual approach to examining soil salinity does not apply in this case.Similarly the irrigation volume alone did not explain the variation in soil salinity, but thecombination of irrigation volume and TDS concentration (the TDS load) was moresuccessful. Especially note that the two high values were placed at the high end of therange in TDS load in Figure 22C. Regression analysis was used to fit the two linesshown in Figure 22C using the EC w as the dependent variable and the TDS load as theindependent variables. The two high values were included when estimating line 1, butwere excluded for line 2.Two explanations can be advanced for the relation between the TDS load and EC w(Figure 22C)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 163
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• The high EC w values during 2003-04 were part of the general pattern of EC w duringthe per-dryer phase, and hence line 1 in Figure 22C best illustrates the trend forTDS load effects on EC w .• The high EC w values are outliers that represent a separate but unexplained effect. Ifso, line 2 best illustrates the TDS load effect.Both explanations accept that the TDS loads during the pre-dryer and post-dryer phasesacted similarly on EC w even though their composition varied somewhat (Table 17). Themain compositional difference was the higher calcium concentration in the pre-dryerwastewater. However, given the dominance of calcium ions in the soil by the time postdryerwastewater was used for irrigation, calcium related reactions in the soil and theireffect on the EC w would apply equally to both phases. Hence, a common relationbetween the TDS load and EC w in both phases was accepted.Given the lack of an explanation for the high EC w values in 2003-2004, line 1 whichincluded the high values, was taken as the basis for estimating future trends in EC w.Note that this relation only applies to a situation with overall high EC w values.Future Changes in Soil SalinityThe relation between TDS load and EC w that was derived above was used to estimatethe possible changes when post-upgrade wastewater was used for irrigation. It isrecognised that the following is a somewhat empirical analysis but past experience onthe Environmental Farm has shown that pasture production will continue under TDSloads that would be unacceptable under other circumstances. The key to explaining theEnvironmental Farm experience almost certainly lies with the chemical composition ofthe wastewater and soil solution but the processes that could occur in the soil are onlypartly understood. Hence a method was sought that built on the field experience overpast years.The expected TDS concentration in the post-upgrade wastewater will be 1,325 – 2,606mg/L depending on the proportion of retentate in irrigation water (Table 18). With theexpected irrigation volume, this will result in a TDS load of:• 2.1 t/ha/yr with no retentate in irrigation water;• 4.6 t/ha/yr with 50% retentate;• 7.0 t/ha/yr with 100% retentate.Fitting these loads to line 1 in Figure 2C gave expected EC w of:• 0.72 dS/m with no retentate;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 164
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• 0.81 dS/m with 50% retentate;• 0.91 dS/m with 100% retentate.In essence, the slope of line 1 in Figure 22C indicates that the effect of the annual loadof soluble salts on EC w was somewhat balanced by reactions within the soil thatremoved salts from the soil solution when the EC w was at a high level. Hence thepotential effect of the high TDS load was markedly ameliorated. In this regard, theprecipitation of calcium compounds would be important, but there would also be someabsorption by plants, net adsorption to soil, and leaching. Under these circumstances,since the post-upgrade TDS loads will be in the same general range or less, they shouldnot cause a deterioration in pasture productivity on the environmental farm, at least inthe short term while the chemical composition of the soil solution remained similar.Relevant issues in this regard are:• If no retentate was included in the irrigation water, the TDS load of 2.1 t/ha/yr wouldbe much less than past experience and could lead to a decline in soil salinity;• Even with 100% retentate in the irrigation water the TDS load of 7 t/ha/yr will be lessthan half the load during the pre-dryer phase;• The calcium concentrations will be important;• The post-upgrade irrigation water will contain a high proportion of bicarbonate ions.Given the existing high calcium concentration in the soil, some of the bicarbonatewill precipitate out of the soil solution. Also, the conductivity factor of bicarbonateions is only 19-39% of the factors for the more common cations in soil. Both effectswill tend to reduce the EC w ;The expected effects of other ions including magnesium on plant nutrition and growthare discussed elsewhere.The above projections rely heavily on the presence of surplus calcium ions in the soilsolution to promote precipitation. In this regard, it will be very important that the soilsalinity and calcium concentrations be monitored on an ongoing basis to both test theabove projections and to indicate longer term trends in soil salinity.Soil Salinity and Plant GrowthIn order to estimate the effect of EC w on plant growth it is necessary to convert this valuethat applies to a 1:5 soil:water mix to the equivalent in a more concentrated solution (soilpaste) that plants would experience in soil. The EC in a soil paste is abbreviated asECE. If the soil solution was dominated by the soluble sodium and chloride ions, aCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 165
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryconversion factor of 10 (with a sandy clay loam soil) would be used but a smaller factorapplies with the expected composition where precipitation will be enhanced at higherconcentrations.In the absence of information on the composition of the soil solution, conversion factorsof 4 and 6 were used in the following discussion. These roughly apply to soil solutionswhere the concentration of all salts in proportion to just the chloride salts, as quantifiedby the ratio of EC 1:5 to the EC due to chlorides, is between 100 to one and 10 to onerespectively. The corresponding expected ECEs with conversion factors of 4 and 6 are:• 3.2 – 4.8 dS/m current (2007);• 2.9 – 4.3 dS/m with post-upgrade irrigation using no retentate;• 3.2 – 4.9 dS/m with post-upgrade irrigation using 50% retentate;• 3.6 – 5.5 dS/m with post-upgrade irrigation using 100% retentate.The EPA Guidelines (2004) indicate that the productivity of ryegrass will not be affectedby an ECE up to 5.6 dS/m, and that it will decline by 10% at 6.9 dS/m. White clover,which is less tolerant, will suffer about a 25-48% reduction in productivity with 100%retentate, depending on which conversion factor is appropriate. Other publicationsindicate that kikuyu will suffer just a 2-8% reduction in productivity.Two points can be made about these conclusions:• The projected effects fit field experience where grass pastures have remainedproductive, but white clover has a limited presence;• The current and projected ECEs are approaching the upper limit for goodproductivity by pasture grasses.Recent monitoring reports (Environmental Farm: 2005 and 2006 EnvironmentalMonitoring Reports by R Lawrie and S Eldridge) have noted that that soil aggregatestability is satisfactory. There is a low risk that this situation will change with the postupgradewastewater, but ongoing monitoring will be essential especially if 100%retentate is used for irrigation, given the sodium and chloride concentrations in theretentate.The expected ECEs were based on the projected TDS concentrations, which are in thehigh range, and an irrigation volume which averaged out at a relatively low 1.6-2.7ML/ha/yr depending of the proportion of retentate that is used for irrigation. Shouldeither of these increase substantially, the pasture productivity could suffer from theconsequent increase in ECE.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 166
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryRecommendationMurtagh, Lawrie and Lugg in this regard make the following recommendations:“Based on just the salinity study, wastewater with 100% retentate could beused for irrigation on the environmental farm. This recommendation is madewith the proviso that the study was forced to use empirical analyses basedon past experience using wastewater of a different composition. If fieldexperience shows an unacceptable increase in soil salinity or an adverseeffect on pasture productivity the quantity of retentate may have to bemodified.Adverse changes will occur gradually and careful monitoring of the soil willprovide an advance warning. Issues that will be important are the soil salinityand the ionic composition of the soil solution, especially calciumconcentration. Better information on the detailed composition of thewastewater that is used for irrigation, and annual soil and pasture samplingof a few selected paddocks will also improve the predictive capabilities.”7.4.4 Plant nutritionThis section of the EA examines the nutrient levels on the Environmental Farm,considering both the past use of wastewater and the future use where the wastewaterwill contain varying proportions of retentate.Wastewater CharacteristicsTable 21Wastewater Characteristics Based on Two Sources of Information(Labelled 1 and 2 within the Table).Option N P K S Ca Mg1 a 57 26 ? 31.2*32/96 19.5 30.42 a 44 20 11 23*32/96 53(+ 121.3)1 b 209 96 ? 38.2 71.6 111.62 b 262 119 65.4 45.4 29.73 b 116 53 29 20 1317.8(+ 722)7.9(+ 722)abmg/lkg/ha per year and assumes irrigation area is 497 ha.The various elemental loads in wastewater (Table 21) were calculated with threealternative wastewater flow rates:1 = “combined flow” of 5ML/day taken from fax from Shoalhaven Starches dated11/2/08Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 167
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry2 = “total effluent” flow of 8.1 ML/day3 = total effluent for irrigation of 3.6 ML/dayComments on TableThere is reasonable agreement between the option 1 and option 2 estimates for N, P, S.However the Ca and Mg loads are less with option 2 relative to option 1, but this willhave little effect because:• the soil is loaded with calcium, and• the magnesium input is going to be much bigger.Both options 1 and 2 gave higher loads than option 3.The option 2 values were used for the following calculations, which included threescenarios.Scenario 1The farm gets all of the retentate: (this calculation is based on 2 b in the table).Scenario 2The farm gets half of the retentate: this will be calculated by subtracting 50% of theretentate nutrients from 2 b in the table.Scenario 3The farm gets none of the retentate: this will be calculated by subtracting all of theretentate nutrients from the 2 b figures.Retentate Calculations – Volume and Loading Rates1.5 ML/day over 497 ha = 1.1 ML/ha yearlyTable 22Nutrients in the Waste WaterN P K S Ca Mg1 mg/L 180*14/62 352*31/95 36 138*32/96 20 4702 kg/ha/year 44.7 126 39.6 50.6 22 5173 kg/ha/year 22.4 63 19.8 25.3 11 2591 = from flow sheet 7/2/082 = annual loading (per ha)3 = 50% of annual loading (per ha)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 168
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryNutrient Uptake by Irrigated RyegrassUsing the recent tissue analysis from Pivot 2 (Bay 5) (NSW DPI Report No.R07-00615-F-V3), (note this is real data; not something from a textbook) and yield ofpasture harvested (ie 60-68 bales/ha, 500kg per bale, 50% moisture), then in one yearthe pasture will take up the following amounts (kg/ha)Table 23Nutrient Uptake by Pasture (kg/ha/yr)N P K S Ca Mg497 71.4 662 36.5 84.8 25.7Compare this with the 3 scenarios in Table 25 that provides the projected annualnutrient balances.Table 24Nutrient Inputs (kg/ha/yr) for Scenarios 1, 2 and 3Scenario N P K S Ca Mg1 262 119 65.4 45.6 29.7 7402 262-22.4= 239.63 262-44.7= 217.3119-63= 56119-126= 065.4-19.8= 45.665.4-39.6= 25.845.6-25.3= 20.345.6-50.6 =029.7-11= 18.729.7-22 =7.7740-259= 481740-517= 223Scenario 1 (All retentate goes to the Farm)NPKSCaMgdeficit; 497 – 262 = 235 kg/ha N fertiliser neededsurplus; small, around 47 kg/ha – retention by soillarge deficit; about 600 kg/ha of K fertiliser needed after 1-2 yearssmall surplus; 10 kg/ha either retained as CaSO4 or lost to groundwatersmall deficit; huge store already in soilbig surplus; over 700 kg/ha will be retained by soil profile as exchangeable Mg,displacing other cations from topsoil, then other lower horizons. Plant nutritioncould be disturbed after say 5 years.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 169
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryScenario 2 (Half the retentate goes to the Farm)NPKSCaMgdeficit; 260 kg/ha N fertiliser neededdeficit; 15 kg/ha but huge store already in soilbig deficit; 615 kg/ha K fertiliser neededsmall deficit; 10 kg/ha can be obtained from soildeficit; 65 kg/ha can be obtained from soil for many yearsbig surplus; 455 kg/ha and while soil degradation likely it could take 10 yearsScenario 3 (No retentate goes to the Farm)NPKSCaMgdeficit; 280kg/ha N fertiliser neededdeficit; 70 kg/ha but huge store already in soilbig deficit; 61 kg/ha K fertiliser neededdeficit; 10 kg/ha which can probably come from soil storedeficit; 77 kg/ha which can come from soil for many yearsbig surplus; about 200 kg/ha but due to high Ca and K levels will not lead to soildegradation or nutrient imbalances if K fertiliser is added for at least 20 years.Soil Nutrient Levels Ca, Mg and KPrevious irrigation practices have greatly increased the soil nutrient levels since irrigationcommenced. Annual monitoring of surface soils and testing down the profile every threeyears has provided the following data.Table 25Exchangeable Cations [cmol(+)/kg] - Mostly Plant AvailableCa Mg K1 21 to 60 3 to 6 1.2 to 3 cmol(+)/kg2 40 4 2 cmol(+)/kg3 12800 640 1040 kg/ha4 -55 +716 -597 kg/ha1 Range of exchangeable cation concentrations in surface soils (0 - 10 cm depth).2 Typical figure in many paddocks.3 Estimated available nutrient content, kg/ha, 0 - 10 cm..4 Annual deficit or surplus as projected for Scenario 1.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 170
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryUnder Scenario 1 (all retentate going to irrigation), soil potassium levels will be depletedin less than 2 years, unless potassium fertiliser is applied.Rising magnesium levels will depress potassium uptake by the irrigated pastures unlesspotassium fertiliser is applied, probably after 1 year.After 3 years the exchangeable calcium/magnesium ratio, currently favourable for plantgrowth will start to fall below 2:1, potentially reducing growth. After 8 years the topsoilwill become dominated by exchangeable magnesium, increasing the risk of soilstructural degradation unless calcium is added (as lime or gypsum, or as calcium nitratefertiliser).These changes will be delayed if the paddocks are cultivated, incorporating the surfacesoil into the subsurface layers (to 20 or 30 cm).Soil Nutrient Levels – N, P and SNitrogenThe availability of these nutrients is largely controlled by the action of soil microorganismson the store of organic matter. The total amount of these nutrients is verylarge, due to the surplus built up under previous irrigation practices. Under Scenario 1,there will be a decrease of nitrogen levels, which will probably require supplementationwith nitrogen fertilisers especially in spring when pastures are growing rapidly.It is not possible to estimate accurately how much is needed, but the soil and plant tissuetesting can guide applications in future years.PhosphorusSoil phosphorus levels, both total and available, are high in the topsoil but decrease inthe subsurface layers. There will be a small annual surplus (47 kg/ha) under Scenario 1.Soil phosphorus sorption levels are falling in the surface soils, due to the very highadditions of P in previous years, but remain elevated in the subsoils. These deeperlayers are highly acidic and contain elevated concentrations of exchangeable aluminiumwhich boosts retention of phosphorus, reducing plant uptake and leaching. Monitoring ofsoil profiles for phosphorus sorption will indicate if downward P movement is excessive.(ie. beyond the rootzone).Levels of available (ie. mobile) phosphorus remain very low in irrigated subsoils aftermany years of receiving heavy phosphorus applications, mostly because of highP retention in the surface. Annual testing of surface soils shows that the P sorption ofthe 100 mm to 200 mm depth remains higher than the 0-100 mm depth (in 30 paddocksCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 171
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryover the last 3 years). The difference mainly arises because sorption is reduced bythese P levels.SulphurThere will be small sulphur surplus under Scenario 1. Sulphur is likely to be retained inthe soil as gypsum (calcium sulphate) due to the very high calcium levels. The contentof sulphate (and total sulphur) was high in most soils prior to irrigation.Detailed testing in 1996 of 36 profiles prior to the development of the centre pivotirrigation system, showed total S levels were high; in the topsoils due to elevated organicmatter contents, and in the subsoils due to the presence of acid sulphate soil layers.Levels of 0.1 or 0.2% total S are common. This is equivalent to 4000 kg/ha in the top30 cm or over 13000 kg/ha in the top metre of the profile (@ 0.1% S).Many decades of irrigation are needed if these high background levels are to increasesignificantly, or to have any influence on groundwater sulphate levels.It should be noted that there is considerable variation in nutrient levels across the farm,due to the differences in the history of previous irrigation. Paddocks with the longesthistory of use will be more able to withstand the changed wastewater characteristicsthan those that received less wastewater in the past.Recommendations for Management PlanMurtagh, Lawrie and Lugg make the following recommendations with respect to anIrrigation Management Plan:“Scenario 1• Monitor soil properties in irrigated paddocks in top 30 cm of profile (toguide management, especially use of fertilisers and irrigation regime).• Apply nitrogen fertiliser after each cut of forage; about 100 kg N/ha atleast twice in the first year, more in later years• Apply potassium fertiliser after each cut (preferably as potassium nitrate,depending on cost, potassium chloride is second preference) at least250 kg K /ha in first year, rising to 500kg K/ha after 3 years; soilmonitoring data to be used as a guide here.• Investigate use of lower rates of magnesium hydroxide in thewastewater treatment process• Consider applying a leaching irrigation, if rainfall is low, to move excessmagnesium out of the topsoil to the lower horizons.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 172
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryScenario 2 and Scenario 3• Monitor soil properties annually in irrigated paddocks in top 30 cm of theprofile.• Apply nitrogen fertiliser after each cut of forage at 100 kg N/ha t least 3times a year.• Apply potassium fertiliser after each cut (preferably as nitrate); ratedepends on soil test level, but may need 300 kg K/ha in first year andwill increase to 400 kg K/ha after 3 years.”As this proposal will involve 100% retentate being irrigated onto the Environmental Farm,Scenario 1 will apply to this project.7.4.5 Water Balance AnalysesThe proposal will result in wastewater either being re-used within the factory process orused for farm irrigation. Hence, there will be no discharges of wastewater to theShoalhaven River.In this regard, wet weather storages are used to hold surpluswastewater during periods of wet weather when the soil is too wet to irrigate.Previous investigations estimated the wet-weather storage requirements with awastewater flow of 4.6 ML/d.The present study examined the adequacy of theproposed storage arrangements with a flow of 2.1 – 3.6 ML/d depending on theproportion of retentate that is directed to farm irrigation. The aim was to establishwhether there was sufficient storage to prevent discharges under a range of rainfallconditions as represented by the historical rainfall at Nowra. As such, the emphasis inthis section is on the hydraulic components on the proposed reuse system, in contrast tothe chemical aspects that are discussed elsewhere.To do this, the H 2 OB water balance model was used to estimate the day to day changein the soil moisture level under varying degrees of wetness and hence when it was dryenough to irrigate. It did that by solving the water balance each day during the 68 yearsof rainfall records that were used in the analyses. The inflow of wastewater was thenbalanced against the outflow to irrigation, with the storages providing a bufferingcapacity.Values of key variables were as follows, with more details and broad capabilities of theH 2 OB model being described in Annexure O(i).• Wastewater flow of 2.1 ML/d with no retentate used for irrigation, increasing to3.6 ML/d with 100% reuse of retentate for irrigation;• Pasture irrigation with 238 ha under centre pivots and 276 ha with travellingirrigators; a total area of 514 ha;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 173
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Total available storage of 823 ML.Water Balance ResultsMean annual results are given in Table 26.Table 26The Reuse and Irrigation Volume with Different Proportions of Retentatein the Wastewater used for IrrigationProportion ofretentate (%)Wastewater flow(ML/d)Requiredstorage (ML)Reuse (%)Irrigation(ML/yr)0 2.1 401 100 72750 2.85 504 100 1004100 3.6 636 100 1274There was 100% reuse and no river discharges under all rainfall sequences in thehistorical record, provided the storage capacity was 401-636 ML, depending on thewastewater flow. As the available storage capacity will be 823 ML the 100% reuse waseasily obtained.The difference between the annual irrigation volume of 727 – 1274 ML/yr and the annualwastewater flow of 767 – 1315 ML/yr was accounted for by the net evaporation from thestorages.The pattern of monthly irrigation in months of different wetness are shown in Figure 23.2502.1 ML/d3.6 ML/dIRRIGATION (mm/mth)20015010050Median1/10-dry1/10-dryMedian1/10-wet0J F M A M J J A S O N DMONTH1/10-wetJ F M A M J J A S O N DMONTHFigure 23: The Monthly Irrigation Volumes in Dry, Medium and Wet Months.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 174
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryWith no retentate use, the daily wastewater flow of 2.1 ML/d equates to about 64ML/mth. Under median conditions, the irrigation volume was slightly less than thewastewater flow indicating that some wastewater would be stored until drier than medianconditions permitted more irrigation. Note also than even under very dry (1/10-dry)conditions the highest irrigation volume occurred in July, indicating that a shortage ofwater held back the irrigation volumes during the warmer months.When all the retentate was used, the increased flow supplied about 110 ML/mth. Aboutthe same amount was used under median conditions, and increased only under drierconditions when some water was available from the storages, especially during thecooler months.These results illustrate how the pasture will be underwatered during many months thatare drier than average.The main conclusion is that the existing storage capacity is more than sufficient toprovide wet-weather storage and thus avoid discharges to the river.7.4.6 Irrigation Management PlanSummaryThe Irrigation Management Plan addresses the impact of future irrigation activities at theEnvironmental Farm (EF). Included are soil effects, water quality, storage and recycling.Irrigation scheduling at the site was reviewed in 2003 investigating the current and otheravailable methods. Existing procedures developed specifically for the wastewaterinfrastructure were determined to be the most appropriate. The quality of thewastewater improved post 2004 so that irrigation and soil properties were improved.Further analysis of the irrigation data since then, has defined other importantcharacteristics such as a frequency distribution of irrigation volume and pumpingcapacity upgrades.Rainfall variation is the dominant limitation to the continuously operating business whichis dependent upon beneficial irrigation. Hence the irrigation scheme depends heavily onthe provision of adequate wet weather storage capacity to prevent discharges during wetweather.By entering into the next stage of water treatment and recovery, the Company will moveto a less weather dependent factory-operating status; will recover water for factory andagricultural reuse; will generate biogas for cleaner production and will minimise offensiveodours.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 175
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderrySite DescriptionThe Environmental Farm is 960 hectares of which approximately half is irrigated. Thespray irrigation infrastructure consists of seven centre pivots and 185 irrigationruns/transects for hydraulic propelled travelling irrigators.The underground network of poly pipe, which distributes the wastewater, isapproximately 44 kilometres in length. There are 4 main irrigation lines from whichlateral lines branch to licensed irrigation paddocks.The size of this irrigation enterprise determines the choice of the method to schedule theapplication of wastewater. Instrumentation which precisely measures the soil watercontent is specific to the location within a block and to the depth installed. Theselimitations, together with the cost of instrumentation of paddocks or even the number ofsoil types across the farm would outweigh the usefulness of such an exercise. Also sitespecific instruments are reliant upon the siting of equipment in a representative area ofthe paddock.Irrigation Scheduling and PracticesThe initial training in the 1980s for the irrigators employed by the Company was the soilmoisture deficit technique. This approach is to be enhanced by the use of the IRRICALCprogram giving a combination of meteorological data and visual inspection of paddocksto control irrigation.Comprehensive records are kept of the irrigation volumes that are applied to allpaddocks. An analysis of irrigation records since January 2003 has also confirmed theirrigation intervals for each paddock which is related to soil type.Three irrigation scheduling techniques were re-evaluated in 2005. They were currentpractice; including the use of the “IRRICALC” irrigation-scheduling software andevaporation deficit calculations. The exercise revealed that the experience of thepersonnel coupled with the chemical limitations of the wastewater provided the bestoutcome in terms of timeliness, efficiency, odour reduction and operational cost.Commercially available instrumentation and strategies are valuable learning tools.However, the time involved with potential re-siting, breakdowns and verificationmonitoring disadvantaged the efficiency of the operation. Ultimately the quality of thewastewater itself eliminated the commercially available techniques as specific practiceshad to be devised for the wastewater operation. The site specific evaporation deficitdata was useful as a backup.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 176
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderrySimple probe and physical inspection of each area could not be replaced by systemsthat are reliant upon assumptions of homogeneity of soil within a paddock. Experiencedscientific modellers have a verification process commonly known as “ground-truthing”such as pre-irrigation inspections.While there are various aids to assist with irrigation scheduling, it is more important thatthe irrigation area is inspected on a regular basis by experienced operators.The Company feels that this system of irrigation management is the best way toeffectively utilise the wastewater across the farm whilst avoiding the potential forenvironmental harm.Standard Operating Procedures (SOP) are being reviewed as machinery descriptionsare too specific. A more generic text will be substituted.Review of Irrigation LimitationsSince 2005, several major factors have had an effect upon the irrigation operation.• The condensate dominated wastewater has approximately 1% solids (including thelime adjustment).• The soil monitoring program since this change has recorded a stabilisation andsubsequent decreases for several important parameters.Limitations for the existing irrigation area are similar to the 2005 report. Coastal weatherpatterns are variable and even during the last three drought years, the effective irrigationperiod has been reduced by a quarter. See Figure 24.Rainfall variation is the dominant limitation to the continuously operating business whichis dependent upon beneficial irrigation. Hence the irrigation scheme depends heavily onthe provision of adequate wet weather storage capacity to prevent discharges during wetweather.Irrigation data collated and presented annually to the DECC, has been analysed.A frequency distribution chart of rounded daily volumes was generated for similarperiods for the last 3 years.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 177
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThree Year Average Distribution of Daily Irrigation Volumes12010080Frequency60402000 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23Irrigated Volume (ML)Figure 24: Average Distribution of Daily Irrigation Volumes for the Last 3 Years.To obtain a summary of the existing irrigation practices, the data was then averaged toreveal the following points.• Zero irrigation volumes exist for 100 days per year.• The effective irrigation year is 265 days.• The effective median irrigation volume is 5 ML per day.• Irrigation hours vary according to soil moisture and weather patterns.• Irrigations larger than 20 ML per day occur only 3 times per year.7.4.7 Implementation of Irrigation ProgramIn response to a request from the DECC, Murtagh, Lawrie & Lugg were engaged toconfirm how the irrigation program will be implemented, to provide details of the massbalance of various analytes in the waste water, and to detail the monitoring program thatwill confirm how the irrigation is affecting the Environmental Farm environment.A supplementary report addressing these matters forms Annexure O(ii) to this EA.According to this supplementary submission the mass balances showed that the balancebetween inputs from waste water and losses in silage that is harvested from theEnvironmental Farm would be:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 178
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Positive for phosphorus, magnesium, sodium, bicarbonate, chloride and sulphate.That is more of these analytes will be added than will be removed in silage.• Balanced for calcium.• Negative for nitrogen and potassium.Of the six analytes with a positive balance, only sodium and chloride are likely to stronglyleach and this, according to this supplementary submission, was viewed as desirable tolimit the development of soil salinity. Nor did they contribute to environmental harmbecause of the saline nature of the receiving waters and subsoil. Of the remaining fouranalytes, most if not all of the phosphorus, magnesium and bicarbonate will precipitate inthe soil, while some of the sulphate will precipitate or from acid and some might leach.Leaching sulphate will not be detectible because of the considerable quantity of sulphatecompounds and ions in the acid sulfate environment.The negative mass balances with nitrogen and potassium indicate that they will notleach and will not constitute an environmental risk, but will have implications for plantnutrition.The proposed monitoring program which is detailed in Annexure O(ii) includes:• Documenting the volume and chemical composition of the waste water to confirmthe mass of each analyte that will be added to the Environmental Farm.• Annual soil monitoring to determine the time trends in the concentration of thoseanalytes that re likely to accumulate in the soil, or to be important for plant nutrition.• Monitoring of the chemical composition of herbage to document the removal ofselected nutrients and the need for fertiliser use.• Monitoring groundwater to detect leaching of surplus magnesium, this being the onlyanalyte that is likely to leach and that is not already common in the receiving waters.Details are also provided of the remedial measures that should be implemented shouldthe various analytes accumulate to undesirable levels.Table 27 provides a checklist of the required actions for monitoring and related issues.It also details the sections in Annexures O(i) and O(ii) where more detail is provided.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 179
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 27Checklist – Required Actions for Monitoring and Related IssuesItem Reason Frequency How SectionWASTEWATERIrrigation volumeComposition– suite Ahigh concentrationComposition– suite Blow concentrationUsed in mass loadcalculationsAs used Flowmeters 4.1 Annexure O(i)Identify surplus Monthly ChemicalanalysesIdentify deficit andneed for fertiliserMonthlyChemicalanalyses4.1 Annexure O(i)4.1 Annexure O(i)SOILComposition– suite CDetect changes overtimeAnnualSoil cores(0 – 30 cm)4.2 Annexure O(i)Soil structure Maintain structure Annual Dispersion test 4.2 Annexure O(i)HERBAGE - HARVESTEDHarvested quantity Used in massremoval calculationsAt eachharvestBale count byaverage weight4.3 Annexure O(i)Composition– suite DMass removal andneed for fertiliserAll cuts(bulked)Chemical analysis4.3 Annexure O(i)HERBAGE - GRAZEDAnimal grazingdaysComposition− suite DGROUNDWATERComposition− suite EREMEDIATIONUsed in massremoval calculationsMass removal andneed for fertiliserDetect leaching dueto surplusResponse Correct undesirableeffectsOngoing Counts 4.3 Annexure O(i)AnnualLeaf plucks andchemical analysis4.3 Annexure O(i)Annual Chemical analysis 4.4 Annexure O(i)As required Recommendations 3 Annexure O(i)Suite A chem.. testing, high conc. – pH, EC, Mg, Na, HCO 3 , Cl, SO 4 .Suite B chem.. testing, low conc. – total N, total P, K, Ca.Suite C chem.. testing, soil – pH, EC, total P, K, (Exch. Ca, Mg, K, Na), soluble Na, Cl.Suite D chem.. testing, herbage – total N, P, K, Ca, Mg.Suite E chem.. testing, groundwater - MgCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 180
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 28 outlines the key issues for operational planning, and where details may befound in Annexures O(i) and O(ii).Table 28Key Issues for Operation PlanningItem Aim How SectionCrop types Maintain high productivity Continue with existingryegrass and kikuyupastures.Pasture productivity Maintain high productivity Use fertiliser andoverseeding as required.3 Annexure O(ii)Irrigation Avoid overwatering Deficit irrigation. 7.3 Annexure O(i)Soil qualityNutrient removalAvoid unacceptable saltaccumulationReduce accumulation ofsurplus analytes in soilMonitor and change inputsor outputs where required.Cut and removal ofherbage.4 Annexure O(ii)3 Annexure O(ii)7.4.8 Summary and ConclusionsWith the implementation of the ethanol upgrade, waste water flows that will be used forirrigation will come from two sources:• Some discharges from the SO basin amounting to an average of 2.1 ML/day.• The waste water treatment plant will produce a clean water flow and a retentate flowthat will contain most of the water contaminants from the inflow. The retentate flowwill average 1.5 ML/day.Shoalhaven Starches propose to use both of the above flows for irrigation onto theCompany’s Environmental Farm (including 100% of the retentate flow).The assessment by Murtagh, Lawrie and Lugg (Annexure O(i)) identifies that basedupon salinity, treated waste water, containing 100% retentate can be used for irrigationon the Company’s Environmental Farm.According to this assessment adverse changes will occur gradually and carefulmonitoring of the soil will provide advanced warning. If field experience identifies issuesarising in relation to soil salinity or adverse effect on pasture productivity themanagement practices associated with the irrigation of retentate may have to bereviewed.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 181
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryShoalhaven Starches therefore commit to undertaking a monitoring program of the soil(including soil salinity and the ionic composition of the soil solution, especially calciumconcentration). Such will include annual soil and pasture sampling of selected paddocksto improve predictive capabilities.In terms of an ongoing management plan for the irrigation of waste waters on theEnvironmental Farm, Shoalhaven Starches commit to the following:• Monitor soil properties in irrigated paddocks in top 30 cm of profile (toguide management, especially use of fertilisers and irrigation regime).• Apply nitrogen fertiliser after each cut of forage; about 100 kg N/ha atleast twice in the first year, more in later years.• Apply potassium fertiliser after each cut (preferably as potassium nitrate,depending on cost, potassium chloride is second preference) at least250 kg K/ha in first year, rising to 500 kg K/ha after 3 years; soilmonitoring data to be used as a guide here.• Investigate use of lower rates of magnesium hydroxide in the wastewater treatment process.• Consider applying a leaching irrigation, if rainfall is low, to move excessmagnesium out of the topsoil to the lower horizons.During prolong wet weather periods when the soil is too wet to irrigate there is a need toprovide wet weather storage for the treated waste waters. This is achieved in the WetWeather Storage Ponds.Annexure O(i) concludes, when all the retentate is used, the existing storage capacity ismore than sufficient to provide we-weather storage.The supplementary submission prepared by Murtagh, Lawrie & Lugg (Annexure O(ii)):confirms how the irrigation program will be implemented; provides details of the massbalance of various analytes in the waste water; and details the monitoring program thatwill demonstrate how irrigation is affecting the Environmental Farm environment.The proposed monitoring program includes:• Documenting the volume and chemical composition of the waste water to confirmthe mass of each analyte that will be added to the Farm.• Annual soil monitoring to determine the time trends in the concentration of thoseanalytes that are likely to accumulate in the soil, or to be important for plant nutrition.• Monitoring of the chemical composition of herbage to document the removal ofselected nutrients and the need for fertiliser use.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 182
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Monitoring groundwater to detect leaching of surplus magnesium, this being the onlyanalyte that is likely to leach and that is not already common in the receiving waters.Details are also provided of the remedial measures that should be implemented shouldthe various analytes accumulate to undesirable levels.7.5 WATER AND SOILS7.5.1 Water SupplyWater is used in the starch production process. Production of starch and protein (gluten)from wheat flour is a water-based mechanical separation process, which results in theproduction of an aqueous waste stream which contains residual fibre, soluble sugars,soluble protein and low-grade starch.It is common practice in the worldwide starch-gluten industry that up to 10 tonnes ofwater is required for each tonne of flour processed. Using technology developed atShoalhaven Starches, water consumption is approximately 3 tonnes per tonne of flourprocessed and equivalent to world’s best practice.A daily average of 8,300 kilolitres of water is used presently by Shoalhaven Starches fortheir total operations, comprising:• 5,100 KL from the municipal drinking water supply; and• 2,400 KL from a raw water supply provided by Shoalhaven City Council via apipeline from the Australian Paper Mill.The proposed upgrade of the facilities for increased production of ethanol and glutenand associated by-products will necessitate increased water usage; both potable waterfor processing flour and non-potable water for steam generation, cooling and other uses.After installation of the proposed Waste Water Treatment Plant and the availability oftreated water for re-use, daily water supply will comprise:• 4000 KL of potable quality water;• 3700 KL of raw water;• 4500 KL of treated water for re-use.The Company will obtain 4000 KL of potable quality water from the Shoalhaven CityCouncil. The remaining 4500 KL of potable water requirement will be obtained from thewaste water processed by the water treatment process associated with this proposal.The 3700 KL of raw water will come via the Australian Paper Mill as is currently the case.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 183
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryFigure 8 details a proposed water and waste water balance for the site following theethanol upgrade project.Water DischargesThe Shoalhaven Starches Factory and Environmental Farm are licensed premises underthe Protection of the Environment Operations Act. Waste water discharges from the siteare licensed by the DECC (EPL 883).The plant has a licensed outfall into the Shoalhaven River. The outfall point is a 50 cmdiameter metal pipe discharging at the end of an existing jetty. It also has a coolingwater discharge comprising a 50 cm diameter pipe which discharges onto a gabionspillway.Under the terms of the Company’s EPL water waste streams associated with the plantinclude:• river water passed through the boiler condensers and the primary side of the heatexchangers;• boiler water treatment plant regeneration waters; and• pH adjusted glucose plant ion exchange unit regeneration waters.7.5.2 Stormwater ManagementShoalhaven Starches engaged GHD Pty Ltd to examine stormwater management(including erosion and sediment controls) for this proposal. GHD’s report, titledEnvironmental Management Report, forms Annexure P to this EA. The followingsection of the EAR is based upon the findings of this report.7.5.2.1 Existing Stormwater Management SystemFactoryShoalhaven Starches’ existing site stormwater management system at the factory isdivided into three zones. The zones are:• Zone 1 – all site stormwater generated in this zone is collected and passed througha first flush pit to remove gross solids and pollutants prior to discharge to theShoalhaven River;• Zone 2 – all site stormwater generated in this area is collected in pits and drainagechannels and conveyed to the Environmental Farm where it is stored in dams priorto being irrigated. No stormwater from this zone is discharged to the ShoalhavenRiver; andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 184
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Zone 3 – all site stormwater generated by this area of the site is collected andpumped to the Environmental Farm during small storm events. Stormwater isdischarged to the Shoalhaven River system during heavy rainfall events.Pond No. 7 (Environmental Farm)Pond No. 7 at the Environmental Farm is located on relatively flat undevelopedagricultural land, several hundred metres away from the nearest major watercourse.The surrounding area has no formalised stormwater management system andrainfall/stormwater is managed through infiltration into the surrounding soils.Packing Plant LocationThe proposed location of the packing plant is currently undeveloped land and thereforehas no existing stormwater management system.Raw Water Pipeline RouteThe proposed raw water pipeline would be located within the boundary of theEnvironmental Farm, parallel to Bolong Road, would cross to the southern side ofBolong Road and through the Boweld property, before entering the Factory property andrunning adjacent to the railway. The route has no formalised stormwater managementsystem.7.5.2.2 Construction Stormwater ManagementFactoryZone 1The proposed additional fermenters and cooling towers would be located at the easternpart of the factory within Zone 1. Consequently all runoff generated at this locationduring construction works would be discharged to the Shoalhaven River following initialtreatment. Construction activities in this area would therefore require the implementationof strict construction environmental management measures to minimise the risk ofpollutants (including sediment, chemicals and oils/fuels) from being discharged to theriver. Detailed mitigation measures have therefore been proposed and outlined inSection 8.0 of the EA to contain stormwater runoff on site and to minimise the risks ofcontaminated discharges to the river.Zone 2The proposed additional molecular sieves and cooling towers would be located withinthe ethanol plant in the central part of the factory within Zone 2. Stormwater from thisarea would be conveyed to the Environmental Farm for treatment and irrigation.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 185
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAppropriate environmental management controls have been proposed for constructionworks in this zone to prevent contaminants being transported to the Environmental Farm(refer Section 7.5.2 of this EA).Zone 3The proposed additional starch dryer and gas-fired boiler would be located on the eastbank of Abernethy’s Drain within Zone 3. The proposed chemical storage facility,evaporator, DDG load-out extension, DDG pellet plant, cooling towers, bioscrubbers andco-generation plant would be located to the west of Abernethy’s Drain, also in Zone 3.Stormwater runoff generated at these locations by larger rainfall events would bedischarged to the Shoalhaven River.Construction activities in this area would require the implementation of strict constructionenvironmental management measures to minimise the risk of pollutants from beingdischarged to the Shoalhaven River or Abernethy’s Drain. Detailed erosion andsediment controls proposed for the works are provided in Section 7.5.2 of this EA.Pond No. 7 (Environmental Farm)The adaption works required to convert Pond No. 7 into the anaerobic and aerobic wastewater treatment plant are likely to be relatively minor civil works, including the installationof pipework, aeration blowers, tank covers, etc. These works would not be expected togenerate significant risk of pollution. However, the works should be conducted inaccordance with the Pond No. 7 Construction Environmental Management Plan (CEMP)prepared by GHD in 2007 for the bulk earthworks associated with construction of thepond.Packing Plant LocationStormwater generated during construction of the packing plant would flow to the existingswampy depression located to the north of the site. Appropriate constructionenvironmental management measures would be required to minimise the risk ofpollutants being discharged off site. Erosion and sediment controls proposed for theworks are detailed in Annexure P of this EA.Raw Water Pipeline RouteStormwater generated during construction of the raw water pipeline would generally beconfined to the trench and immediate surrounds. The construction area would generallybe surrounded by pasture or grassland with a low slope, which would act as a swale,enabling significant removal of any suspended solids.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 186
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.5.2.3 Operational Stormwater ManagementFactoryOperation of the proposed works would not alter the existing site stormwatermanagement system at the factory. The proposed works would also not be expected tosubstantially increase the volume of stormwater generated from the site as the bulk ofthe factory surface area is currently surfaced with bitumen or other relativelyimpermeable surface cover.The design of the individual components of the upgrade would incorporate relevantdesign guidance and stormwater management practices, including bunding (particularlyaround the chemical storage facility) to meet DECC requirements, and the appropriatecontainment, treatment and disposal/discharge of stormwater runoff generated by thenew works.The DECC have raised issue with respect to spills containment both in terms of theproposed works as well as the existing site.Within the central portion of the site, containing the ethanol distillery, starch plant andfermentation area, the Distillery is contained within a bunded area in accordance withrelevant Australian Standards. The eastern portion of the site contains ethanol storageand other loading facilities. The ethanol storage and recovery area are also containedwithin bunded areas in accordance with the relevant Australian Standards.There are instances however within the older developed areas within the factory sitewhere storage vessels and areas are not bunded in accordance with relevant AustralianStandards.Any new storage plant and equipment associated with the proposed ethanol upgradeproject will be bunded in accordance with relevant Australian Standards.It is also proposed however that Shoalhaven Starches will commit to undertake a reviewof the of the factory site to identify and analyse areas of the factory site where bunding ofstorage vessels and areas is not provided. Based upon this “gaps” analysis animplementation strategy can be formulated which seeks to instigate bunding where it isnecessary throughout the factory site. Such a strategy could be formalised inconsultation with DECC and incorporated into a Pollution Reduction Program under theCompany’s Environmental Protection Licence.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 187
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryEnvironmental FarmOperation of the proposed works would not alter the existing site stormwatermanagement system at the Environmental Farm, and would not be expected tosubstantially increase the volume of stormwater generated from the site.Packing Plant LocationOperation of the packing plant would be expected to increase stormwater generated atthe site when compared to its current undeveloped state.Stormwater generated from the packing plant site would drain to a first flush pit toremove gross solids and pollutants prior to being discharged to a soak-away located tothe north of the site. Following larger rainfall events it is anticipated that the soak-awaywould discharge to the existing swampy wetland.Raw Water Pipeline RouteThe pipeline trench would be restored and revegetated following completion ofconstruction. Operation of the pipeline would not be expected to generate stormwater.7.5.3 Acid Sulphate SoilsAcid Sulphate Soils (ASS) is naturally occurring soil and sediment containing ironsulphides which when exposed to oxygen can generate sulphuric acid. CoffeyEnvironments (“Coffeys”) were engaged by Shoalhaven Starches to undertake anenvironmental assessment of the site in germs of the presence of acid sulphate soils.A copy of Coffey’s assessment report forms Annexure J to this EA.According to Coffeys the Burrier/Berry 1:25,000 Acid Sulfate Soil Risk Map (1997)edition 2, prepared by the Department of Land and Water Conservation (DLWC),indicates the following for each of the investigation areas (refer Figure 25):• The Eastern and Western Plant Areas are generally located in areas with a lowprobability of ASS occurrence being described as elevated alluvial plains andlevees. ASS, if present, are considered to be sporadic in occurrence greater than3 m below the ground surface.• The Central Plant Areas and the proposed fire service facility are generally locatedin areas with a low probability of ASS occurrence being described as elevatedalluvial plains and levees. ASS, if present, are considered to be sporadic inoccurrence within 1 m of the ground surface and up to 3 m.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 188
FIGURE 25ACID SULFATE RISK MAP
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• The area encompassed by the proposed Packaging Plant is generally located inareas with a low probability of ASS occurrence being described as an elevatedalluvial plain. ASS, if present are considered to be sporadic in occurrence indicatedas occurring at depths at 1 m below the ground surface and up to 3 m.• The area of the proposed water treatment and filtration plant at the EnvironmentalFarm is located in an area with low and high probability of ASS occurrence. Areasof high probability are described as low alluvial plains, estuarine sand plains,estuarine swamps, backswamps and/or subpratidal flats. ASS, if present, areconsidered to be widespread or sporadic within 1 m of the ground surface with asevere environmental risk if disturbed. Areas of low probability are described aselevated alluvial plains and levees. ASS, if present, are considered to be sporadic inoccurrence between depths of 1 m and 3 m below the ground surface. The mapshows areas immediately north and northeast towards Broughton Creek, are highprobability ASS at depths near surface or within 1 m of the ground surface.• The proposed gas and water pipeline routes run through areas with a low probabilityof ASS occurrence, noted as alluvial plains and levees. ASS if present would occurbetween 1 m to > 3 m of the ground surface.• The map shows areas immediately to the south of the site within the river, as beingestuarine bottom sediments with a high probability of ASS occurrence. Areas witha high probability of ASS occurrence are also shown further to the north of the studyareas.Coffeys make the following findings in relation to Acid Sulphate Soils and this project:Central and Eastern Plant AreaSampling locations in this area recorded fill soils ranging from 0.6 m to 0.75 m comprisedof silty sands and some gravel (probably pavement materials) which were not indicativeof ASS. Underlying soils were typically described as topsoil/alluvial/estuarine silts withvarying proportions of clay and sand. No evidence of jarosite staining was noted at thelocations. A sulfidic type odour was noted below a depth of about 2.4m in boreholeCBH104. Screening results did not record a field pH below 4 or a pH below 3 afteroxidation with H 2 O 2 . Five samples were selected for testing using the (ChromiumReducible Sulfur) S CR method. The results are presented in Table LR9 within CoffeysAssessment and these did not suggest that the soils were ASS.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 189
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryWestern Plant AreaSampling locations in this area recorded fill soils ranging from 0 to 1.1 m comprisedmainly of gravels and sands (probably pavement materials) which were not indicative ofASS. Underlying soils were typically described as alluvial silts and clays. No evidenceof jarosite staining was noted at the locations. Screening results did not record a fieldpH below 4 or a pH below 3 after oxidation with H 2 O 2 . Results of sampling suggestacidity is non-sulphuric and therefore not considered to be an ASS. One samplesuggests that the soil in this horizon could be an actual ASS, but does not appear tohave capacity for further additional acid production.Proposed Packing PlantSampling locations in this area generally recorded topsoil/alluvial and estuarine soils.Estuarine soils were generally noted in the northern and eastern parts of this area whichare typically the lower lying parts. Typically stiffer alluvial soils were noted in the centraland southern parts of this area. The estuarine soils were typically dark grey and blackclayey silts whilst alluvial soils were typically sandy and silty clays.Field screening results generally recorded pH values greater than 4. After oxidation withH 2 O 2 , some samples recorded pH values below 3 which suggests the potential presenceof unoxidised sulphides.Laboratory results indicated Total Actual Acidity (TAA) values ranging between 22 m/tand 123 m/t suggesting soils are actual ASS. S CR results typically suggest that the soilsdo not have unoxidised sulfides that would lead to further oxidation, except for onesample. According to Coffeys, results also suggest that not all of the acidity is sulphuric,but sufficient sulphuric acidity is present to designate these soils as Actual ASS. Sampleresults for a test pit excavated near the southern end of the proposed footbridge overBolong Road did not indicate the presence of ASS.Proposed Fire Services and Gas FacilitySampling locations in this area generally recorded alluvial soils with some possibleestuarine soils deeper in the profile below about 1 m. Screening results showed field pHvalues greater than 4. After oxidation with H 2 O 2 , some samples recorded pH valuesbelow 3 which suggests the potential presence of unoxidised sulphides.The results from samples from the proposed fire service area tested using the S CRmethod noted TAA concentrations exceeding the action criteria and ranging between47 m/t and 63 m/t. Results for these samples suggest the acidity is mostly nonsulphuric.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 190
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderrySamples from the proposed gas facility were tested using the Suspended PeroxideOxidisable Combined Acidity and Sulphate (SPOCAS) method. TAA concentrationsexceeded the action criteria ranging between 51 m/t and 80 m/t. Oxidisable sulphurconcentrations for three out of the four samples tested recorded values between 0.04%and 0.07% which exceed the action criteria. These soils appear to be ASS.Proposed Water Treatment and Filtration Plant (area near Effluent Pond 7)One sampling location in this area generally recorded the presence of alluvial soils.Screening results showed field pH values greater than 4. Samples screened with H 2 O 2did not show a drop in pH below 3.One sample recorded a TAA concentration of 19 m/t which exceeds the action criteria.Soils in this general area have previously been assessed as part of the Pond 7construction and these soils have been managed as ASS.Proposed Pipeline Route Options (refer Figures 3 & 4)Option 1Boreholes drilled within the western half of the pipeline route for this option noted mainlythe presence of alluvial soils and also topsoil fill materials. As this area is a servicecorridor, some of the materials encountered could possibly be associated with formertrench backfill materials. A thin band of clayey silt logged as estuarine material wasobserved. Screening results for this section of pipeline generally recorded pH valuesgreater than 4. Samples indicated a pH drop below 3 after screening with H 2 O 2 . SomeASS could be encountered along this section but are likely to be sporadic.Option 2Test pits excavated in the western half of this route option typically encountered gravellyfill soils from 0.6 m to 0.9 m which were not indicative of ASS. Underlying soils werenoted as very stiff alluvial clays. Samples of the alluvial clays were tested using the S CRmethod and the results did not suggest the soils were ASS.The eastern part of this route encountered topsoil overlying stiff to very stiff alluvial clays.with a possible estuarine layer between 0.9 m and 1.1 m. Screening results indicatedfield pH values greater than 4 and pH values greater than 3 after oxidation. Selectedsamples tested using the S CR method did not suggest that the soils were ASS.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 191
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryConclusion – Acid Sulphate SoilsIn terms of the presence of Acid Sulphate Soils, Coffeys make the following conclusions:Acid sulphate soil risk maps suggest that the majority of areas beingassessed are in an area with a low probability of acid sulphate soiloccurrence. The area of the proposed water treatment and filtration plantnear the effluent ponds is closer or within a high risk area. Field screeningand laboratory results indicated that ASS were not likely to be present in thecentral and eastern plant areas and fire service area. ASS are likely to beencountered within the packing plant (particularly the lower lying areas, northand east) and were confirmed in this assessment. For the remaining areas(western plant area, gas facility, near Pond 7, and pipeline routes) ASS arelikely to be sporadic and possibly in lenses (if present).We would recommend that an Acid Sulfate Soils Management Plan(ASSMP) be prepared for the packing plant and areas of the site where soildisturbances are likely to intersect ASS. Depending on further details of theproposed development and level of disturbance, further assessment could becarried out to increase the confidence in the lateral and vertical extent of theASS.It is probable that acid sulphate soils could occur at depths beyond thoseassessed in this study.Should the proposed depth of disturbance change or different soils beencountered, then this would need to be re-assessed.Based upon the findings of the ASS assessment carried out by Coffeys, ShoalhavenStarches commit to preparing an Acid Sulphate Soils Management Plan for the proposedPacking Plant site; and any areas of the site where soil disturbance is likely to intersectwith ASS. In this regard Shoalhaven Starches have over the years gained considerableexperience with undertaking construction works on land with potential acid sulphatesoils.7.5.4 ContaminationCoffeys also undertook an assessment of the project site in terms of likely sitecontamination (Annexure J). The scope of work carried out by Coffeys included:• A site history and desk study to identify potential Areas of Environmental Concern(AECs) and Chemicals of Concern (COCs) including: a review of previous siteownership, review of available records held by <strong>Manildra</strong> and others, review ofSection 149 certificates, review of selected aerial photographs, holding interviewswith available people familiar with the history of the site, review of publishedgeological and topographic maps, ASS risk maps, a search of nearby groundwaterbores registered with the NSW Department of Water and Energy (DWE), review ofNSW Department of Environment and Climate Change (DECC) records for listing ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 192
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythe site, review of dangerous goods licences held for the site by NSW WorkCover,review of the relevant sections of previous reports and collation of this information;• A site walkover to visually assess potential sources of contamination, observesurrounding landuses, topography, drainage, nearby sensitive environments, andassess details of the site history and desk study to further assess potential AECsand COCs;• Collection of soil samples from boreholes, test pits and surface samples. Thesamples were also collected in duplicate and screened for Volatile OrganicCompounds (VOC) using a Photoionisation Detector (PID);• Carrying out field screening tests to check for ASS on selected soil samples;• Installation, development and sampling of one groundwater monitoring well;• Laboratory analysis of selected soil samples for a suite of potential COCs including:−−Total Petroleum Hydrocarbons (TPH), Benzene, Toluene, Ethylbenzene,Xylenes (BTEX), Polycyclic;Aromatic Hydrocarbons (PAH), heavy metals (arsenic, cadmium, chromium,copper, lead, mercury, nickel, zinc), Polychlorinated Biphenyls (PCB),Organochlorine Pesticides (OCP);− Organophosphorous Pesticides (OPP), pH and asbestos. Groundwatersamples were also analysed for biological parameters and nutrients;• Laboratory analysis of selected soil samples using the Suspended PeroxideCombined Acidity and Sulfate (SPOCAS) or the chromium reducible sulphur method(SCR) for purposes of Acid Sulfate Soils assessment;• Preparation of this report summarising the site history, results of fieldwork,presenting and interpreting analytical results and findings, comparing chemicalconcentrations to applicable guidelines, and making recommendations on the needfor further investigation and / or remediation and management with respect to sitecontamination.The results of the contamination assessment prepared by Coffeys identified seven mainpotential AECs within the areas being the subject of this assessment based on the pastand present activities identified from the site history study. The AECs were noted ashaving between a low and moderate likelihood of contamination.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 193
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryIn general, preliminary soil sampling in the majority of the areas assessed did not showevidence of contamination. Soil contamination was noted in the central western part ofthe proposed packing plant (Lot 5 DP 825808) in a relatively small area that appears tocontain some fill materials and ramping west towards the neighbouring properties. Thisarea recorded petroleum hydrocarbon contamination and asbestos contamination in theform of some fibre cement fragments. The asbestos identified could present a healthissue for users of the site and during redevelopment. According to Coffeys this part ofthe proposed packing plant requires further assessment and remediation/managementwith respect to the identified contamination.WorkCover NSW regards fibro in soil as ‘friable asbestos material’, that is ‘asbestosinappropriately buried (i.e. not in accordance to any environmental legislativerequirements) (Ref: WorkCover NSW: Your Guide to Working with Asbestos, Safetyguidelines and requirements for working with asbestos, dated 20 March 2003).When handling such materials the work must be carried out by appropriately qualifiedand licensed contractors in accordance with all relevant codes of practice and standardssuch as National Occupational Health and Safety Commission (2005): Code of Practicefor the Safe Removal of Asbestos (2nd Ed)[NOHSC:2002(2005)]. Excavated materialswith fibre cement will also be regarded as asbestos waste and require disposal to anappropriately licensed facility.Remediation of the asbestos contamination is likely to involve excavation and offsitedisposal of asbestos contaminated fill. The general steps in the process include:• Developing an Asbestos Removal Plan;• Removal of the affected materials under supervision of a suitably licensed AS1asbestos removal contractor;• Carrying out NATA accredited air monitoring throughout the duration of theremediation works;• Disposal of asbestos contaminated material to a waste facility licensed to acceptasbestos waste; and• Validation sampling of the resulting excavation.This would address the identified contamination issue with no further managementrequired.Depending on the volume of material assessed to be removed, this option can be costlydue to the relatively high disposal costs.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 194
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAn alternative form of management could involve encapsulation on site. Encapsulationmay be restricted due to the site development works including a basement excavation.Concentrations of the potential chemicals of concern tested in other parts of theassessment areas did not suggest evidence of soil contamination. There were someaccess restrictions in areas of the Shoalhaven Starches Plant due to the presence ofexisting infrastructure.Based on the results of this assessment, the potential forwidespread soil contamination that would preclude these areas from being redevelopedfor industrial landuse is considered to be low. Some relatively localised contaminationcould exist from previous activities (particularly within the Shoalhaven Starches Plant). Itis Coffey’s understanding that the amount of soil disturbance in the ShoalhavenStarches Plant areas is likely to be relatively limited and that structures would besupported on driven piles.According to Coffeys soils excavated from the site as part of site construction worksshould be appropriately managed.If any evidence of potential contamination isidentified such as odorous soils, stained, soils, unusually discoloured soil, etc. thenCoffeys should be contacted to make an assessment of these soils for contamination.Excess soil that requires disposal offsite should be appropriately classified based on theDECC (2008) Waste Classification Guidelines. If practical during construction, Coffeysrecommend that fill soils in the upper parts of the soil profile be kept separate tounderlying natural soils as these generally have a higher likelihood of being impacted.Elevated concentrations of zinc and lead were noted in groundwater sampled from onewell within the proposed packing plant site above drinking water and/or protection offreshwater aquatic ecosystem trigger values. At this stage the source of the zincconcentration is not known and could be associated with background concentrations.Groundwater across all the proposed upgrade areas was not assessed as part of thisstudy.It would generally appear that there is a low to moderate likelihood thatgroundwater is impacted at the sites. Further testing would be required to better assessthe groundwater for beneficial reuses, if this was necessary Coffeys would recommendthat if groundwater is intersected as part of construction works and requiresmanagement, that this groundwater be appropriately tested.Conclusion – Site ContaminationIn terms of site contamination and this project, Coffeys conclude:“The results of this contamination assessment identified seven main potentialAECs within the areas being the subject of this assessment based on thepast and present activities identified from the site history study. The AECsCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 195
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrywere noted as having between a low and moderate likelihood ofcontamination.In general, preliminary soil sampling in the majority of the areas assessed didnot show evidence of contamination. Soil contamination was noted in thecentral western part of the proposed packing plant (Lot 5 DP 825808) in arelatively small area that appears to contain some fill materials and rampingwest towards the neighbouring properties. This area recorded petroleumhydrocarbon contamination and asbestos contamination in the form of somefibre cement fragments. The asbestos identified could present a health issuefor users of the site and during redevelopment. This part of the proposedpacking plant requires further assessment and remediation/managementwith respect to the identified contamination.WorkCover NSW regards fibro in soil as ‘friable asbestos material’, that is‘asbestos inappropriately buried (i.e. not in accordance to any environmentallegislative requirements) (Ref: WorkCover NSW: Your Guide to Working withAsbestos, Safety guidelines and requirements for working with asbestos,dated 20 March 2003).When handling such materials the work must be carried out by appropriatelyqualified and licensed contractors in accordance with all relevant codes ofpractice and standards such as National Occupational Health and SafetyCommission (2005): Code of Practice for the Safe Removal of Asbestos (2ndEd) NOHSC:2002 (2005)]. Excavated materials with fibre cement will alsobe regarded as asbestos waste and require disposal to an appropriatelylicensed facility.Remediation of the asbestos contamination is likely to involve excavationand offsite disposal of asbestos contaminated fill. The general steps in theprocess include:• Developing an Asbestos Removal Plan;• Removal of the affected materials under supervision of a suitablylicensed AS1 asbestos removal contractor;• Carrying out NATA accredited air monitoring throughout the duration ofthe remediation works;• Disposal of asbestos contaminated material to a waste facility licensedto accept asbestos waste; and• Validation sampling of the resulting excavation.This would address the identified contamination issue with no furthermanagement required.Depending on the volume of material assessed to be removed, this optioncan be costly due to the relatively high disposal costs.An alternative form of management could involve encapsulation on site.Encapsulation may be restricted due to the site development works includinga basement excavation.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 196
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryConcentrations of the potential chemicals of concern tested in other parts ofthe assessment areas did not suggest evidence of soil contamination. Therewere some access restrictions in areas of the Shoalhaven Starches Plantdue to the presence of existing infrastructure. Based on the results of thisassessment, the potential for widespread soil contamination that wouldpreclude these areas from being redeveloped for industrial landuse isconsidered to be low. Some relatively localised contamination could existfrom previous activities (particularly within the Shoalhaven Starches Plant).We are of the understanding that the amount of soil disturbance in theShoalhaven Starches Plant areas is likely to be relatively limited and thatstructures would be supported on driven piles.Soils excavated from the site as part of site construction works should beappropriately managed. If any evidence of potential contamination isidentified such as odorous soils, stained, soils, unusually discoloured soil etc.then Coffey Environments should be contacted to make an assessment ofthese soils for contamination.Excess soil that requires disposal offsite should be appropriately classifiedbased on the DECC (2008) Waste Classification Guidelines. If practicalduring construction, we would recommend that fill soils in the upper parts ofthe soil profile be kept separate to underlying natural soils as these generallyhave a higher likelihood of being impacted.Elevated concentrations of zinc and lead were noted in groundwater sampledfrom one well within the proposed packing plant above drinking water and/orprotection of freshwater aquatic ecosystem trigger values. At this stage thesource of the zinc concentration is not known and could be associated withbackground concentrations. Groundwater across all the proposed upgradeareas was not assessed as part of this study. It would generally appear thatthere is a low to moderate likelihood that groundwater is impacted at thesites. Further testing would be required to better assess the groundwater forbeneficial reuses, if this was required. We would recommend that ifgroundwater is intersected as part of construction works and requiresmanagement, that this groundwater be appropriately tested.”In light of the recommendations of Coffeys in terms of site contamination, ShoalhavenStarches will commit to engaging a suitably qualified consultant (such as Coffeys) toprepare a Scope of Works to investigate the best means of remediating asbestoscontamination on this portion of the site. This Scope of Works will investigate whichapproach either:• development of an Asbestos Removal Plan; or• encapsulation.Is the preferred approach for treating asbestos contamination on this site. This is thepreferred approach as it will enable detailed construction plans to be considered; andenable a detailed costing of the two alternatives to be considered.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 197
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryShoalhaven Starches also commit to ensuring that all contractors involved inconstruction works on the site are instructed that if there is any evidence of potentialcontamination (as evidenced by odorous soils, stained soils, unusually discoloured soils)then Coffey Environments (or other suitably qualified consultant) will be contactedimmediately to make an assessment of these soils for contamination.Shoalhaven Starches also undertake to ensure that all excess soil that requires disposaloffsite will be classified in accordance with the DECC (2008) Waste ClassificationGuidelines.Shoalhaven Starches will also undertake to ensure that fill soils in the upper parts of thesoil profile will be kept separate to underlying natural soils.In terms of groundwater, Shoalhaven Starches in conjunction with a suitable qualifiedconsultant will commit to appropriately testing groundwater if groundwater is intersectedas part of any construction works.7.6 NOISEShoalhaven Starches engaged The Acoustic <strong>Group</strong> to undertake an acousticalassessment for the proposed ethanol upgrade. A copy of The Acoustic <strong>Group</strong>’s reportforms Annexure Q(i) to this EA. This section of the EA is based upon the findings ofthis assessment.7.6.1 Ethanol Upgrade Acoustic Design Targets7.6.1.1 Factory SiteThe Director-General of Planning’s requirements for this project required an audit of theexisting plant noise emission. This Audit was carried out by The Acoustic <strong>Group</strong> inMarch 2008. The Acoustic <strong>Group</strong> report (38.3849.R50 dated 5th June, 2008)(Annexure Q(ii) found compliance with noise conditions issued by the NSW EPA (nowpart of the DECC).The acoustic audit nominated noise criteria for the Ethanol Upgrade project, based uponthe Shoalhaven Starches Noise Reduction Program 7 (PRP7) and Chapter 12 of theEPA’s Industrial Noise Policy (INP).The current EPA Licence issued for the subject premises requires the company toachieve specific noise contribution levels at four reference residential boundariesnominated to the south and north as follows:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 198
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe LA 10(15 minute) sound pressure level contribution generated from the sitemust not exceed the following levels when measured at or near the boundaryof any residential premises:- 38 dB(A) at locations in Terara on the south side of the Shoalhaven River;- 38 dB(A) at locations in Nowra on the south side of the Shoalhaven River;- 42 dB(A) at locations in Meroo Street, Bomaderry; and- 40 dB(A) at other residential locations in Bomaderry.For this project based upon the findings of The Acoustic <strong>Group</strong>, the residential noiseemission target has been set at 15 dB(A) below the EPA Licence noise limits at thereference location targets so as to ensure the upgrade does not increase the site noiseemission levels. The noise emission targets for the project are therefore as follows:The LA 10 (15 minute ) sound pressure level contribution generated from theEthanol Upgrade must not exceed the following levels when measured at ornear the boundary of any residential premises:- 23 dB(A) at locations in Terara on the south side of the Shoalhaven River;- 23 dB(A) at locations in Nowra on the south side of the Shoalhaven River;- 27 dB(A) at locations in Meroo Street, Bomaderry; and- 25 dB(A) at other residential locations in Bomaderry.The noise design target, if taken as a L eq(15 minutes) goal 15 dB(A) below the EPA Licencecriteria, according to The Acoustic <strong>Group</strong> will ensure that the INP intrusive noise goal issatisfied with a significant safety margin.As the above noise limit is 15 dB below the License Conditions then compliance withthat criterion will result in the INP amenity noise target automatically being satisfiedaccording to The Acoustic <strong>Group</strong>.7.6.1.1 Traffic and Rail MovementsThere are four major routes that can be utilised by trucks to/from from the site. Route 1is west along Bolong Road and then north along the Princess Highway (19% of thetraffic). Route 2 is north along Railway Street then north along Meroo Road (58% of thetraffic). Route 3 is north along Railway Street then west along Cambewarra Road (16%of the traffic). Route 4 is along Bolong Road then south along the Princess Highway(7% of the traffic).During the night time (10:00 pm to 7:00 am) there will be a maximum of 19 additionaltruck movements in the night which averages out to 2 per hour. Therefore the mostCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 199
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryaffected residential location will be on Railway Street which can have a maximum of2 truck movements per hour during the night time.With respect to the day time (7:00 am to 10:00 pm), there will be a maximum of19 additional movements in the day which averages out to 1 per hour.With respect to train movements, there are currently at most two train movements duringthe night time period (one movement before midnight and one after midnight). On aweekly basis there are nine night time train movements per week (six movements beforemidnight and three movements after midnight) but not equally distributed throughout theweek, ie. not all days of the week have the two train movements during the night timeperiod. The proposal will not result in more than the current maximum of two trainmovements for each night time period. The proposal will generate a maximum of twotrain movements during the night time period for every day of the week. This will resulton a weekly basis fourteen night time train movements per week.The INP covers truck and rail movements whilst on the subject land, but such trafficmovements when external to the site fall under different criteria.For road traffic, the relevant guidelines are the NSW EPA’s Environmental Criteria forRoad Traffic Noise (“ECRTN”). The critical location with respect to additional traffic,according to The Acoustic <strong>Group</strong>, are the residences on Railway Street which in acousticterms can be classified as a collector road (whilst Cambewarra Road and Meroo Roadwould be classified as arterial/subarterial). Development type 8 (identified asdevelopments with potential to create additional traffic on collector road) in Table 1 of theECTN has a day time criterion of L eq(1hr) 60 dB(A) and a night time criterion of L eq(1hr) 55dB(A). Under the technical notes to the table, notes vii and ix proposes that traffic fromthe development should not lead to an increase in existing noise levels of more than 2dB.Existing rail traffic is assessed under the noise control guideline Chapter 163 of the NSWEPA’s Environmental Noise Control Manual (“ENCM”). This guideline sets out noiselevels in relation to rail movements as they may impact upon residential receivers. Thecriterion specifies a 24 hour L eq level of 60 dB(A) for existing operations with a maximumpassby level of 85 dB(A).In 2003 the Rail Infrastructure Corporation and the State Rail Authority issued an InterimGuideline For Councils which has a internal day time criterion of an L eq(1hr) 40 dB(A) andan internal night time criterion of an L eq(1hr) 35 dB(A) with all windows and doors closed.A typical attenuation from an external space into an internal space with all windows andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 200
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrydoors closed is 20-25 dB(A). On a conservative basis utilising the 20 dB(A) attenuationwill result in the external goal of an L eq(1hr) 60 dB(A) for the day time and an L eq(1hr)55 dB(A) for the night time.7.6.2 Acoustic Assessment7.6.2.1 The Factory SiteThe majority of equipment associated with this proposal that are of a high noise emissionare housed in concrete rooms with the external building envelope in colourbond orcomposite wall/roof systems. The proposal involves the following equipment:1 x Product Dryer (and its associated equipment)3 x Fermenters (with associated pumps and motors)6 x Additional Fermenter cooling towers1 x Molecular Sieve and associated 2 x cooling towers8 x Additional DDG cooling towers6 x DDG Dryers (and its associated equipment)1 x DDG Pellet Plant1 x Odour Scrubber1 x Evaporator1 x Co-Generator1 x Gas-fired Boiler1 x Packing PlantContainer Loading area (Forklift)9 x Blowers at the <strong>Manildra</strong> Environmental Farm2 x Emergency Fire System pumpsFor the purpose of assessing the noise controls associated with the nominated plant TheAcoustic <strong>Group</strong> have run the EM computer model for Shoalhaven Starches under neutralweather conditions to establish in-plant shielding and the attenuation to the referenceresidential locations.The manufacturer’s noise data for the various plant times has been expressed generallyin a dB(A) format rather than octave bands. For this ENM assessment The Acoustic<strong>Group</strong> utilised a broadband spectrum to derive the attenuation to residential referencelocations.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 201
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAccording to The Acoustic <strong>Group</strong>, analysis of the proposed plant items located withinbuildings without any additional noise control measures would exceed the overall EPAnoise limits and obviously the more stringent criteria nominated for the project.As a result of the analysis carried out by The Acoustic <strong>Group</strong> in order to meetcompliance with the residential design goals the following noise control measures arerequired, according to The Acoustic <strong>Group</strong>, to be implemented.Product DryerEquipment will be housed in a building that will be constructed of Ultrapanels having anRw of not less than 35. The upper 3 floors of the building and the roof is to beconstructed of material having an Rw of not less than 17 (Colorbond or similar).Equipment that has a sound power level above 80 dB(A) is to be enclosed in a separateroom with the walls and ceiling/floor having an Rw of not less than 40.FermentersNo additional noise control measures are necessary according to The Acoustic <strong>Group</strong>except for the transfer pumps which are to be enclosed with material having an Rw ofnot less than 15.Fermenters – Cooling TowersDuring the night time period, the fan speed of the 6 cooling towers is to be reduced to60% of full fan speed. The fan speed reduction is to be automatically adjusted(computer or time clock controlled) rather than by manual controls.Molecular SieveThe molecular sieve pumps and compressors associated with this proposal are to beenclosed with material having an Rw of not less than 35.Molecular Sieve – Cooling TowersDuring the night time period, the fan speed of the 6 cooling towers is to be reduced to60% of full fan speed. The fan speed reduction is to be automatically adjusted(computer or time clock controlled) rather than by manual controls.Cooling TowersDuring the night time period, the fan speed of the 6 cooling towers is to be reduced to60% of full fan speed. The fan speed reduction is to be automatically adjusted(computer or time clock controlled) rather than by manual controls.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 202
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryWater pumps numbers 1 - 4 are to have noise control measures (or replaced) in order tohave a sound pressure level of 68 dB(A) at 1 metre.DDG DryersThe majority of the equipment will be housed in a building that will be constructed ofUltrapanels having an Rw of not less than 35.Any equipment that has a sound power level above 90 dB(A) is to be enclosed in aseparate room with the walls and ceiling/floor having an Rw of not less than 40.DDG Pellet PlantThe majority of the equipment will be housed in a building that will be constructed ofUltrapanels having an Rw of not less than 35.Any equipment that has a sound power level above 90 dB(A) is to be enclosed in aseparate room with the walls and ceiling/floor having an Rw of not less than 40.Odour ScrubberThe equipment will be housed in a building (walls and ceilings/roof) that will beconstructed of material having an Rw of not less than 35 such as Ultrapanels.EvaporatorThe majority of the equipment will be housed in a building (walls and ceilings/roof) whichhas to be constructed of material of an Rw of not less than 25.The two turbo fans are to be enclosed in a separate room with the walls and ceiling/floorhaving an Rw of not less than 40.Co-GeneratorAt this stage of the development application, sound level data for the Co-Generator isnot available. However the maximum sound power level of 93 dB(A) from all dischargesfrom the Co-Generator building has been derived to maintain compliance with the designcriteria.Gas Fired BoilerThe Acoustic <strong>Group</strong> were provided with the sound power level of the discharge duct ofthe boiler. To maintain compliance with the design criteria the discharge of the duct is toachieve an attenuation of 25 dB(A) so that the sound pressure level from the dischargeduct does not exceed 72 dB(A) at 1 metre.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 203
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPacking PlantAll walls and the roof/ceiling of the packing plant is to be constructed of material havingan Rw of not less than 35 dB(A).Container Loading AreaThe forklift (new item) that is used for the loading and stacking of containers is to have amaximum sound pressure level of 80 dB(A) at 1 metre.The northern end of the container loading area is to have a solid masonry wall not lessthan 8.5 metres in height and the western and eastern end of the container loading areais to have a solid masonry wall not less than 8 metres in height.The Acoustic <strong>Group</strong> have been advised that there will be no train movements on thespur line that forms part of the container loading area between the night time period of10:00 pm to 7:00 am.As part of the management plan of the container loading area during the night timeperiod (10:00 pm to 7:00 am) the forklift trucks will only stack two containers high atlocations within 10 metres from the wall and only one container high above the groundfor locations more than 10 metres from the wall. No loading of the train in the proposedcontainer loading area will take place during the night time period.Blowers at <strong>Manildra</strong> Environmental FarmWith respect to the blowers, The Acoustic <strong>Group</strong> have been advised that they will haveenclosures that result in a sound pressure level of 70 dB(A) at 1 metre.Emergency Fire SystemThe fire pumps are only utilised for emergency and a maximum of 1 hour per weekduring the day time for testing purposes only, and do not form part of the EPA criteriaunder normal plant operations.With the above noise control measures, according to The Acoustic <strong>Group</strong>, the noisecontribution from this proposal will meet the design goals.7.6.2.2 Road TrafficWith respect to road traffic noise associated with the proposal the critical acoustic issueaccording to The Acoustic <strong>Group</strong> relates to truck movements during the night time periodof 10:00 pm to 7:00 am.Figure 26 nominates four traffic routes. Section 2.7 of the traffic impact assessmentcarried out by Christopher Stapleton Consulting identifies the percentage break up ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 204
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrytruck movements whilst Section 4.2 identifies that the proposal could generate up to anadditional 19 heavy vehicles per day (38 movements). Shoalhaven Starches advise thattheir planning regime has the additional truck movements evenly distributed throughoutthe day and night with the majority of the trucks seeking to travel to and from the north.Ambient noise levels were carried out by The Acoustic <strong>Group</strong> in connection with theprevious PRP7 project with the use of unattended loggers located adjacent to the truckroutes. These revealed ambient traffic Leq in the day time period significantly greaterthan that during the night time period. As the trucks will be evenly distributed throughoutthe day and night, any traffic noise contribution arising from the proposal would notapproach the EPA’s ECRTN criteria for the different road classifications in the day timeperiod, whilst night time movements are expected to generate some minor increases inthe traffic/ambient Leq levels.The EPA has a separate noise policy identified as Environmental Criteria for RoadTraffic Noise (“ECRTN”) which relates to road traffic movements. Table 1 of the ECRTNnominates criteria for different road classifications for noise emission level for daytimeand night time operations. Category 7 covers land use developments with potential tocreate additional traffic on existing freeway/arterials and nominates a daytime criteria of60 dB(A) Leq and a night time criterion of 55 dB(A). If either criterion is alreadyexceeded, the EPA place a specification that traffic arising from the development shouldnot lead to an increase in existing noise levels of more than 2 dB.EPA Road Traffic Development Category 8 is identified as a land use development withpotential to create additional traffic on collector roads, where the daytime criteria isexpressed as an L eq 60 dB(A) for a one hour period and night time criterion of L eq 55dB(A) (one hour). Again if either criterion is already exceeded, the traffic arising from thedevelopment should not lead to an increase in existing levels more than 2 dB.A guide to the terms used in Table 1, of the ECRTN, indicates that an existingfreeway/arterial road is a road that includes sub-arterial roads and is a road that handlesthrough traffic, with characteristically heavy and continuous traffic flows during peakperiods, where through traffic is passing through a locality bound for another locality.A collector road is defined as a road in a built-up area that collects local traffic leaving alocality and connects to a sub-arterial road. In the previous PRP7 application it wasconcluded that from the aerial maps for the area that Railway Street leading up toCambewarra Road could be considered a collector road or a subarterial road, howeverCambewarra Road, Meroo Road and Bolong Road (west of the development) wereCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 205
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryidentified as sub-arterial roads, and would be classified as freeway/arterial roads for thepurposes of the ECRTN.Therefore the criterion applied to the assessment of road traffic varies upon: roadclassification; whether the EPA criterion is already exceeded or not; and whether as aresult of a development the criteria would be exceeded.According to The Acoustic <strong>Group</strong>, Railway Street experiences the majority of night timetraffic (14 movements during the night). The traffic movements do not impact onresidential dwellings until the intersection of Railway Street and Cambewarra Road atthe railway overpass. For an equitable distribution of heavy vehicles, the residentialdwellings north of the railway bridge could experience an additional 14 truck movementsduring the night or 1.56 truck movements per hour.Ambient logger measurements conducted on the property immediately south ofCambewarra Road, but between Meroo Road and the railway line obtained a night timeL eq(9 hr) of 54.6 dB(A) thereby leading to an overall EPA noise limit for trucks of 56.6dB(A).Attended measurements during the day time found L eq(1 hr) levels greater than thatrecorded for the PRP7 project but individual truck movements similar to the valuesidentified in the PRP7 assessment.Attended measurements carried out by The Acoustic <strong>Group</strong> of heavy vehicle operationsat the intersection of Cambewarra Road and Railway Street found a mean soundexposure level (SEL) 85.3 dB(A) at the nearest residential boundary. If Railway Street isconsidered to be a collector road on the basis of two vehicle movements in any one hourwould result in a sound level contribution of 49.2 dB(A) at the residential facade whichwhen added to the existing night time ambient L eq(9 hr) of 54.6 dB(A) would result in anoverall L eq level of 55.7 dB(A) which complies with the EPA design target.If however the above intersection is to be ranked as a sub-arterial road, then it isnecessary to assess the resultant L eq level from the passage of 14 movements duringthe night that would result in an L eq(9 hr) contribution of 48.2 dB(A). This contribution whenadded to the existing L eq(9 hr) of 54.6 dB(A) would realise a total L eq level of 55.5 dB(A).This level satisfies the ECRTN requirements.Similarly, traffic movements on Meroo Road north of Cambewarra Road (route 2) wouldbe subject to an additional 11 truck movements throughout the night. Route 2 isdesignated as a sub-arterial road and therefore under the ECRTN is categorised as afreeway/arterial road. From an average SEL of 83.8 dB(A) at the residential boundary,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 206
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythe L eq (9 hr) contribution determined at the residential façade from the 11 truckmovements would be 45.6 dB(A). When added to a night time L eq level of 54.6 dB(A)results in a L eq level of 55.1 dB(A) which satisfies the ECRTN requirements.Similarly, traffic movements on Cambewarra Road (route 3) would be subject to anadditional 3 truck movements throughout the night. Route 3 is designated as a subarterialroad and therefore under the ECRTN is categorised as a freeway/arterial road.From an average SEL of 83.5 dB(A) at the residential boundary, the L eq (9 hr) contributiondetermined at the residential facade from the 3 truck movements would be 39.7 dB(A).When added to a night time L eq level of 55.8 dB(A) results in a L eq level of 55.8 dB(A)which satisfies the ECRTN requirements.7.6.2.3 Rail TrafficIn terms of additional rail traffic noise, a rail traffic noise assessment was carried out byThe Acoustic <strong>Group</strong> for the previous PRP7 project and the measurement results werepresented in the PRP7 acoustic assessment report prepared by Steven CooperAcoustics (report number 32.3849.R17:NSC dated December 2002).For the critical night time period, the subject proposal doesn’t use the packing plant spurline at night. Additional train movements arising from the proposal and the existing trainmovements during the night time period not exceed 2 movements (one departure andone arrival).The trains (when arriving from the north) would move onto the existing spur line (ie. willnot go into Bomaderry Station), crossing Railway Street and continue round at a slowspeed to enter the site. When departing, the train would cross Railway Street and thentravel along the spur line out onto the main line. The train then reverses back down themain line to a siding at Bomaderry Station where the train remains until its scheduleddeparture to Sydney.At the nearest residence to the railway line (Railway Street) the following soundexposure levels from the different train activities were derived:Activity SEL dB(A) L eq(1 hr) dB(A)Train crossing Bolong Road 77.7 42Train up onto main line and reverse to station 88.4 53Train arrived on main line 87.0 52Train departure on main line 81.2 46Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 207
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAll the above activities would not occur within a one hour period. Activities that could fitinto a one hour period would include a train arriving on the main line and crossingRailway Street; or the train crossing Railway Street and up to the main line and reversingto the station. On a worst case basis, the activities in one hour would be for the traincrossing Railway Street and up to the main line and reversing to the station resulting inan SEL of 88.4 dB(A) which is an external L eq(1hr) of 53 dB(A). This external level wouldfor closed window situation reduce an L eq(1hr) of 28-33 dB(A) and would therefore,according to The Acoustic <strong>Group</strong>, be below the Interim Guidelines for Rail Traffic Noise.7.6.3 Construction Noise7.6.3.1 Construction Noise Control GoalsConstruction noise is not controlled by the Company’s EPA Licence and utilises differentnoise indices to that for the operating plant.The current EPA Licence conditions relate to criteria derived from night time ambientmeasurements and the EPA Environmental Noise Control Manual (the “ENCM”) thatutilised the concept of an average maximum (L10) noise level versus the averageminimum (L90 background) level.Contained in the ENCM are a set of Noise Control Guidelines for various types of noiseemission sources. A Construction Site Noise Guideline is set out in Chapter 171 of theENCM and indicates the following criteria may be specified in a development consent orbuilding application:The L A10,T noise levels emanating from the construction site shall not exceedthe background levels by the following criteria, in the interval specified:- 20 dB(A) for construction activity period up to 4 weeks- 10 dB(A) for construction activity period over 4 weeks and up to 26weeks.- 5 dB(A) for construction activity period over 26 weeks.Time Restrictions of Monday to Friday, 7am to 6pm, and Saturday 7am to1pm if audible on residential premises and no construction work to take placeon Sundays or Public Holidays.The ENCM indicates the L A10,T sound pressure levels shall be measured or computed atany point within one metre of the boundary of the nearest affected residential premises.Measurements shall be made over a 10 to 15 minute interval (T), using the “fast”response of the sound level meter. The L A10,T is the A-weighted sound pressure levelwhich is exceeded for 10 percent of the time over the measurement interval T.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 208
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAs the sites associated with this proposal are already level, cleared ground the principalnoise emission construction activities for the erection of the buildings are associated withthe piling and foundation works associated with the proposed concrete slabs, andpouring of the slabs. This work is carried out on an infrequent basis. The construction ofthe buildings proper and fit out of the buildings generates significantly lower noise levels.Based on other construction projects at Shoalhaven Starches there will be piles driventhroughout the site of the various slabs, where such piles are driven by a pile driving rig.The total works associated with all the slabs will take a period of up to 4 months, being3 months for all the pile driving operations (occurring on an infrequent basis) and 1 weekfor the preparation/pouring of the slabs. Whilst pile driving operations will be undertakenover extended periods; the individual pile driving operations will occur over discrete shortperiods. The actual pouring of all the slabs will be conducted over a month.This same form of construction (including the driving of piles) has occurred on theShoalhaven Starches site over the last eleven years without receipt of any noisecomplaints.Due to the location of the various plant items being significantly removed from residentialpremises and the existing ambient levels, primarily as a result of traffic in the area,normal construction activities are not envisaged to create a noise impact. However, theproposed concrete foundation slabs requires the driving of piles (by a pile rig) into theground, which creates a greater level of noise than for normal building and excavationworks.On past experience, according to The Acoustic <strong>Group</strong>, it is not envisaged there would beany noise disturbance in relation to the piling operations for the proposed concrete slabs,if such operations were restricted to the daytime period.The Company has an ongoing building works program that has not given rise to anynoise complaints and as such the forming and pouring of the slab and any other siteworks associated with the subject application is not envisaged to generate any noiseimpacts.7.6.3.2 Noise Emission from Construction of the PlantIn order to consider the likelihood of noise emission from the proposed construction, TheAcoustic <strong>Group</strong> have utilised noise data from previous projects, as set out in below.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 209
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderrySound Power Noise Emission Levels of Plant Items – dB(A)Typical Plant Max. Noise Level Sound PowerItem or Equipment L 10 at 7 metres LevelBulldozer Caterpillar D7 88 113Front End Loader Wheeled 90 115Crane Truck Mounted 85 110Piling Hammer for piles 93 118The piling operations occur on an infrequent basis and are spread over a period of timewhich reduces the noise impact from the operations.Therefore other than the piling operations for the packing plant, all other constructionactivities would not exceed background +10 dB(A) and therefore would satisfy the EPAsecondary criterion of background +10 dB(A) for construction works less than 26 weeks.7.6.4 ConclusionThe Acoustical Assessment prepared by The Acoustic <strong>Group</strong> makes the followingconclusion with respect to this proposal.“An acoustical assessment of the proposed Ethanol Upgrade at theShoalhaven Starches plant has been undertaken with reference to the INPrequirements and the EPA Licence for the plant.A site noise audit was carried out in March 2008 and found compliance withnoise conditions issued by the EPA.For the proposed Ethanol Upgrade a design target of 15 dB(A) below theEPA Licence conditions at the residential reference locations has been usedso as to ensure the upgrade does not increase the current site noiseemission levels.Other than for day time construction activities, the critical period for noiseassessment is the night time period of 10 pm to 7 am where the ambientapproaches the EPA Licence limits.Various noise control measures (in terms of construction and management)are set out in the report above.An assessment of rail traffic movements during the night time periodrevealed compliance with the EPA rail traffic noise guidelines and the RICInterim Guidelines.An assessment of the additional truck movements as a result of the EthanolUpgrade project has revealed compliance with the EPA’s ECRTNrequirements.”It is evident from the Acoustic Assessment carried out by The Acoustic <strong>Group</strong> basedupon a site noise audit the existing operations comply with the noise requirements setCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 210
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryout in the Company’s EPL. This demonstrates Shoalhaven Starches’ ongoingcommitment to ensure its operations not only satisfy its EPL requirements, but alsominimise its impacts on the local community. The Company has over the years madesignificant investment to ensure its activities comply with these requirements.Based upon the findings of the noise audit, noise emission design targets have beendevised by The Acoustic <strong>Group</strong> for the proposed Ethanol Upgrade Project of 15 dB(A)below the EPL conditions at the residential reference location. This noise emissiondesign target will ensure the works associated with the upgrade will not increase thesite’s current noise emissions.In order to achieve these noise design targets the assessment carried out by TheAcoustic <strong>Group</strong> sets out specific noise control measures for the various plant involvedwith this proposal. These controls are set out in Section 7.6.2.1 of this EA.The Assessment also confirms that the additional heavy vehicle movements associatedwith the proposal will comply with the relevant DECC guidelines.The Acoustic Assessment also identifies that rail movements associated with theproposal will also comply with DECC guidelines, provided the Packing Plant railwaysiding/spur line is not used at night.In terms of construction activities, the main issue that arises with this proposal relates tonoise emissions from piling and foundation works. These works however are carried outon an infrequent basis during discrete periods during the construction period. This formof construction and foundation work has occurred over the site for many years withoutthe receipt of noise complaints.7.7 TRANSPORT, ACCESS AND PARKINGThe EA is supported by a Traffic Impact Assessment prepared by Christopher StapletonConsulting (CSC). A copy of this assessment the forms Annexure G to this EA. Thissection of the EA is based upon the findings of this Traffic Impact Assessment.7.7.1 Local Traffic NetworkThe Princes HighwayThe local traffic network is dominated by the Princes Highway, which provides primarynorth-south access through the north and south of Nowra. Through the majority of the‘local’ network shown in Figure 26, the Princes Highway has a speed limit of 70km/h, butthere are also local restrictions (School Zones) which reduce the speed limit during themorning commuter peak period and early afternoon commuter peak period..Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 211
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Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryNorth to Kiama,Wollongong, SydneyMossValeBomaderryIndustrialxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxCoastal RouteNorthxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxShoalhavenStarchesxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNowra CDB& SouthxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxMap reproduced with permission of UBD. Copyright Universal Publishers Pty Ltd DG 01-08Figure 26: Transport Routes Around the SiteCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 212
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe Princes Highway through the local network generally provides a minimum of4 lanes, with additional capacity at major junctions controlled by signalised intersectionsand high capacity roundabouts.With heavy vehicle limits on the coastal routes to the north (Route 293 – Bolong Road)the vast majority of heavy vehicle traffic from Bomaderry uses the Princes Highway forsub-regional and regional access, principally entering/departing the Princes Highway atMeroo Road and Bolong Road.According to CSC, the Princes Highway provides the following key intersections:• Princes Highway and Bolong Road (Signalised)• Princes Highway and Cambewarra Road (Roundabout)• Princes Highway and Meroo Road (Priority)• Princes Highway and Illaroo Road/Shoalhaven River BridgeRoute 293 (Bolong Road)An alternative to the Princes Highway for north-south traffic is provided by Bolong Road,which generally follows the coastline between Gerringong and Nowra. While heavyvehicle restrictions (5 t weight) apply north of Bomaderry, according to CSC the RTAhave determined that there is significant potential for new development to the north-eastof Nowra which would be serviced by Bolong Road.Bolong Road provides the following key intersections:• Princes Highway and Bolong Road (Signalised)• Bolong Road and Meroo Street (roundabout)• Bolong Road and Railway Street• Bolong Road and Site Access PointsAdditional Bomaderry RoutesRailway Street, Cambewarra Road and Meroo Road (north of Cambewarra Road) forman important access route through Bomaderry for local industrial developments,including the Shoalhaven Starches. Some weight/size restrictions apply to a smallsection of this route, specifically Railway Street south of Cambewarra Road to the publicweighbridge; Cambewarra Road; and Meroo Road between Cambewarra Road andMcIntyre Way.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 213
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAccording to CSC, these restrictions apply only to restricted access vehicles; whichmeans only vehicles over 19 m or over 50 t are prohibited from this small section of thelocal network. All vehicles under 19 m in length or 50 t in weight are permitted to usethis section of the network, while Railway Street (between Bolong Road and the publicweighbridge) and Meroo Road (north of McIntyre Way) are designated by the RTA forrestricted access vehicle routes for vehicles up to 26 m in length and over 50 t.Restricted access vehicles are also able to turn to and from Bolong Road to RailwayStreet for access to the weighbridge.7.7.2 Existing Traffic SummaryIntersectionsAccording to CSC, even under super-peak site and recreational design hour conditions,the key site and local intersections operate at a good - satisfactory level of service (LoS),with low average delays and significant spare capacity. The regional intersection of thePrinces Highway and Bolong Road experiences moderate delays and maintains anoverall LoS “B”; the worst delay (for the right hand turn from Bolong Road) isexperienced by very few vehicles; in turn, this low volume does not impact as greatly onthe left turning traffic flow, not on the opposed southbound movement (particularly in theAM peak hour).Critically, according to CSC, the proposal will not add to the flows at the intersection ofPrinces Highway and Bolong Road by more than a few vehicles in any peak hour, andwith consideration of the existing surveyed super-peak site conditions it is probable thatthe future generation of the site under standard operating conditions will actually belower than the generation used in this analysis of existing conditions.Bomaderry ‘Local’ FlowsThe traffic surveys – and specifically the heavy vehicle log undertaken by ShoalhavenStarches - clearly identify preferred heavy vehicle routes through Bomaderry for accessbetween Shoalhaven Starches (and other local industrial development) and the northand west (and specifically the Princes Highway north). It must be acknowledged that theoverwhelming majority of heavy vehicle using the local routes are fully entitled to do so.Notwithstanding, the log survey does indicate that a small number of AustRoads Class10 vehicles (generally restricted access vehicles) use this route; information is notavailable to indicate whether these vehicles exceeded the limits imposed on the route,but it is the view of CSC that this does occur occasionally.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 214
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryFinally, it is important to note that the traffic surveys – and specifically the survey of theBolong Road and Railway Street intersection - identify a heavy vehicle trip demand toother local industries located west of Shoalhaven Starches, ie. by no means isShoalhaven Starches the only generator of heavy vehicles in the local network, andspecifically along both the local industrial route and at the intersection of the PrincesHighway and Bolong Road.7.7.3 Regional AccessRegional access for the Site is provided via Bolong Road to the Princes Highway; fromthe Princes Highway, trips distribute to the north and south, as well as to the west (via anorthern route through Albion Park to the Hume Highway, or via Moss Vale). Lightvehicle trips disperse from the Site along all local routes, including Bolong Roadeastbound for trips to the north (via Gerroa).Heavy vehicles are not permitted to use Bolong Road (eastbound) for regional trips, andrestricted access vehicles are not permitted to use the Princes Highway south of Nowra,nor the central portion of the Bomaderry industrial access route.In general, heavy vehicles generated by Shoalhaven Starches use the following regionalroutes:North• Via Bolong Road, Railway Street, Cambewarra Road and Meroo Road to thePrinces Highway.• Via Bolong Road and the Princes Highway (generally restricted access vehiclesonly).South• Via Bolong Road and the Princes Highway south.• Via Bolong Road, Railway Street and Cambewarra Road (through Moss Vale).• Via Bolong Road and the Princes Highway north through Mount Ousley and Wilton(generally restricted access vehicles only).West• Via Bolong Road and the Princes Highway north (generally restricted accessvehicles only) through Mount Ousley and Wilton• Via Bolong Road, Railway Street and Cambewarra Road (through Moss Vale)Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 215
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe percentage distribution of heavy vehicle trips to each of these shows the dominanceof the local Bomaderry route for access to and from the north. CSC note also that indiscussions with Council it was agreed that generally the only vehicles using the routevia the Princes Highway and Bolong Road were restricted access vehicles, ie. in generalall other vehicles from both the Site and other local industrial Sites in Bomaderry travelvia the local industrial route (when travelling between Bolong Road and the north andwest).7.7.4 Site AccessVehicle access to the Site is provided via four separate access points to Bolong Road.Vehicle movements to these access points remain relatively constant throughout theweek; some small access changes occur at present when a train is stopped on-site,requiring vehicles to [occasionally] depart via a different access point, the proposal willprovide additional rail siding capacity on-site, which is expected to eliminate temporaryrerouting demand.It is also the case that at the time of that surveys were undertaken for the Traffic ImpactAssessment that construction work on-site resulted in some minor rerouting of trips.This resulted in significantly higher than normal daily flows at Access Point 1, as well asthe rerouting of some vehicles to Access Point 3. The standard access operatingconditions which will be reinstated following the current construction period are detailedbelow.Access Point 1 (Eastern)Access Point 1 is located at the eastern end of Shoalhaven Starches. The intersectionof this access point and Bolong Road is designed as a Type C intersection (as describedby AustRoads) and was developed after consultation with the RTA and Council as partof a past upgrade of the Site.The intersection design was specifically due to the access point being located in thevicinity of the transition point of speed zones in Bolong Road (60 km/h – 100 km/heastbound, 100 km/h – 60 km/h westbound), rather than significant traffic volume orsight distance issues.Traffic flows show clearly that flows are moderate, particularly to and from ShoalhavenStarches, and sight distance exceeds all design requirements in both directions.Access Point 1 provides for:• Ethanol trucks (arrival and departure).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 216
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Brewers trucks (arrival and departure).• Glucose trucks (arrival and departure).• Starch trucks (arrival and departure).Access Point 2 (Central)Access Point 2 is located to the east of the railway line, and directly adjacent to (east of)a drainage culvert (Abernethy’s Creek). This intersection does not provide sufficientwidth to allow an eastbound vehicle to pass a vehicle turning right into ShoalhavenStarches, and as such a turning vehicle can delay eastbound vehicles. Overall though,the intersection operates at a good LoS due to the low turning volumes, and the recentprovision of a pedestrian footbridge linking the pedestrian paths on the southern side ofBolong Road has significantly improved pedestrian (and general) safety.Council have referenced a previous consent condition for Shoalhaven Starches whichrequires that the intersection of Access Point 2 be upgraded to provide a Type Aintersection, ie. a design which would allow an eastbound vehicle to pass a vehicleturning right into the site. Final planning for this upgrade is currently underway, with adraft design provided in Appendix A of the Traffic Impact Assessment (Annexure G).Access Point 2 provides for:• Minor office and staff vehicle demand.• Brewers trucks (departure only).• Bulk starch (arrival and departure).• Glucose trucks (departure only).Access Point 3 (Western)Access Point 3 is located at the end of a spur that leads from the eastern portion of theShoalhaven Starches around behind smaller industrial units to a point adjacent (west) ofthe Cleary Bros Concrete site. The spur continues to an intersection with Bolong Road.This Type A intersection was recently upgraded, to provide a sealed pavement of theimmediate intersection and southern verge, in line with the recommendations of CSC2002 PRP7 Traffic Report.The access driveway from Bolong Road provides access to a small office and trainingbuilding, and to a small staff car park. Further to recent upgrade approvals, AccessPoint 3 provides heavy vehicle access to and from the rear of the primary Site (via thespur) and to staff car parking areas. Access Point 3 also provides access (egress) forCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 217
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythe adjacent Cleary Bros site; the driveway and intersection with Bolong Road thereforegenerates trips from the Site and from Cleary Bros.Access Point 3 provides for:• Staff vehicles (office, training and general staff arrival and departure).• Coal trucks (arrival and departure).• Stillage trucks (arrival and departure).• Cleary Bros trucks (departure and occasional arrival).Council have indicated a requirement for an extension of the sealed pavement at thisintersection, and greater definition of the Access Point 3 driveway itself. Final planningfor this upgrade is currently underway, with a draft design provided in Appendix A of theTraffic Impact Assessment (Annexure G).Access Point 4 (Car Park)<strong>Manildra</strong> has recently purchased the former "Moorehouse" industrial site, which islocated west of the railway spur off Bolong Road. The site was specifically purchased inorder to provide a central car parking location for staff, as well as ancillary storage andworkshop space.Access Point 4 provides separate ingress and egress driveways to Bolong Road. Bothdriveways operate at a good level of service due to the low turning demands and goodsight distance.Access Point 4 provides for:• Staff vehicle parking.• Minor service/workshop vehicle demands.In discussions between CSC and Council staff, no issues were raised in regard to theoperation of the Access Point 4 driveways, though the surveys provided by Councilindicate that at times one of the driveway gates was closed, necessitating ingress andegress from the same driveway.CSC notes that these minor intersections are not formally designed as Type Aintersections. CSC indicate that they have observed vehicles passing a turning vehicle(ingress driveway) as per a Type A intersection due to the width of the adjacent verge.7.7.5 Pedestrian AccessMost pedestrian access demand is met on-site, with simple connector links between theformal and informal parking areas and the primary work locations. Internally, most areasCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 218
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryof Shoalhaven Starches have fixed pedestrian walkways – these are generally areaswhere safety around heavy equipment and machinery is paramount. General accessdemand from the on-site parking areas is accommodated by internal roads andpathways. Pedestrian links between the western end of Shoalhaven Starches (offices,training parking areas) and the primary work areas east of Abernethy’s Creek have beenimproved through recent upgrade stages.A minor but constant pedestrian demand is also generated along Bolong Road, ademand which is not met by the current design of the carriageway (in the vicinity ofAccess Point 2, and Abernethy’s Creek); as a result, pedestrians walk on the edge of thecarriageway between the existing footpaths east and west of the Creek.This situation is currently in the process of being rectified by the development of apedestrian bridge adjacent to Bolong Road.7.7.6 Traffic GenerationCSC commissioned a series of surveys to properly define the traffic generation of theSite (and the local area). The survey locations and peak periods were fully discussedwith Council officers prior to their implementation.In summary, Shoalhaven Starches (ie. August 2007, standard generation plusconstruction generation) generated:• A weekday average of approximately 1,400 light vehicle trips.• A weekday average of approximately 300 heavy vehicle trips.• An AM commuter peak hour generation of 113 light vehicle trips and 40 heavyvehicle trips.• A PM commuter peak hour generation of 104 light vehicle trips and 11 heavy vehicletrips.The surveyed AM peak period generation therefore represents approximately 10% of thedaily generation, while the surveyed PM peak generation represents approximately 7%of daily generation. These percentages are entirely commensurate with a site thatoperates 24 hours a day, and specifically generates staff peaks outside of the commuterpeak periods (ie. major shift changes occur early in the morning and early in theafternoon). Additional interrogation of the traffic data provided by Council for the keyaccess points (Access Point 1 and Access Point 3) shows that the generation of heavyvehicles during the commuter peak hour across the week represents less than 10% ofdaily heavy vehicle generation.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 219
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryImportantly the survey period significantly overestimated the ‘standard’ generation of theSite, specifically due to the high number of construction and contractor vehicle trips thatwere occurring during the survey period.Based on standard staff numbers, visitor numbers, and what is a small inter-trip demand(where vehicles will simply drive from one access point to another via Bolong Road)CSC have estimated the following ‘standard’ operating traffic generation for the Site; thisincludes the additional ‘standard’ generation which will be generated following thecompletion of the current on-site upgrade works:• Approximately 800 – 900 light vehicle trips per day.• Approximately 150 heavy vehicle trips per day.These traffic flow figures are commensurate with traffic generation forecasts for the Sitefrom past upgrade proposal assessments.Notwithstanding, CSC has assessed the existing and future operations of the local trafficnetwork based on the higher surveyed figures that include the contractor/constructiondemand, and indeed these flows have also been factored (as per consultation withCouncil) to represent recreational peak flows. This provides for a super peak-generationassessment of the site, which in our opinion would therefore also provide an assessmentof future construction peak demands for this current proposal.7.7.7 Light Vehicle Trip DistributionLight vehicle trips (staff and visitors) distribute broadly to the following routes:• Bolong Road to the east (Shoalhaven Heads).• Bolong Road and the Princes Highway to the south (Nowra).• Bolong Road, Railway Street and Meroo Road to the north and Bomaderry.• Bolong Road, Railway Street and Cambewarra Road to the west and Bomaderry.While vehicle trips are concentrated at Shoalhaven Starches – and specifically at AccessPoint 3 and Access Point 4 – vehicles quickly disperse from Bolong Road via localroads. The majority of staff reside in the local Bomaderry and Nowra area.7.7.8 Heavy Vehicle Trip DistributionThe distribution of heavy trips to the local network has been raised by Council as animportant issue in the assessment of the upgrade proposal.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 220
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryGeneral Heavy Vehicle DistributionThe general distribution of trips to the local and regional road network can be determinedwith reference to the heavy vehicle log survey. The log shows the following generalheavy vehicle distribution over a 24 hour period:• 19% of trips utilise Route 1, Bolong Road and Princes Highway, for trips to and fromthe north.• 58% of trips utilise Route 2, Bolong Road, Railway Street, Cambewarra Road andMeroo Road to the Princes Highway for trips to and from the north.• 16% of trips utilise Route 3, Bolong Road, Railway Street and Cambewarra Road fortrips to and from the west.• 7% of trips utilise Route 4, Bolong Road and Princes Highway for trips to and fromthe south.Restricted Access Vehicle MovementsThe Site generates a number of types of heavy vehicles, being rigid trucks; semi-trailers;‘truck and dog” combinations; and “B-Doubles”.According to CSC there is evidence that a small number of restricted access vehiclesmay use the restricted route. Some 8 Class 10 vehicle trips were logged as utilisingRoute 2 for trips to and from the north over the survey week, and an additional 8 Class10 vehicle trips were logged as utilising Route 3 for trips to and from the west over thesurvey week. It is possible that a percentage of these vehicles exceeded the restrictedvehicle access limits.Shoalhaven Starches has policies in place which detail the routes required for restrictedaccess vehicles to access the Site; these policies specifically extend to privatecontractors. CSC acknowledges that these policies do not guarantee that the occasionalrestricted access vehicle will not use the local route to and from the Princes Highway.Notwithstanding, the heavy vehicle log and the results of the fixed countersstrongly indicate that there is no systemic use of the local routes by restrictedaccess vehicle generated by the Site, or indeed generated by other local industrialsites.VKT, Route Speed and General Transport CostsAn important issue in reviewing the current distribution of heavy vehicles through thelocal road network to the Princes Highway north of Bomaderry is the minimisation ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 221
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryvehicle kilometres travelled (VKT), and with it general emission and time costs, that thelocal routes provide.VKT is a measurement of total trip distance, and is normally associated with a relativetravel cost. VKT has become an increasingly important measurement of ‘impacts’associated with developments, and is a key consideration of the RTA, Department ofPlanning and Department of Transport. If a vehicle is required to change to a new routethat was (for example) 1 km longer than the existing route, there would not be anyimmediate indication of a cost increase. However, considering the cost per kilometre ofa trip and multiplying that cost over a year, the costs start to add up. Travel time, withconsideration of congestion and other limiting factors, is also relevant.Shoalhaven Starches’ generated vehicles – and specifically heavy vehicles - using thelocal route through Bomaderry (and particularly via Meroo Road) utilise this routebecause it is generally faster – particularly during commuter peak periods when flowsare heavier and School Zone restrictions are also in place along the Highway - andbecause it is shorter than the Princes Highway route by approximately 1.5km. If thesetrips, small in number as they are, were forced to use the Princes Highway route duringthese periods, there could be a resulting increase in costs per annum, as well asincreased time and emission costs.The most important efficiency strategy implemented at Shoalhaven Starches to reduceVKT – and indeed all traffic related costs and impacts - is the use of rail; this massivelyreduces the impacts of heavy vehicle generation of the Site, heavy vehicle movements inthe local area, and impacts at local intersections.CSC is of the opinion that the zoning of the Bomaderry industrial area by Councilspecifically consents to the movement of industrial vehicles through the local residentialareas; indeed, Meroo Road north of Cambewarra Road is specifically zoned by the RTAfor even restricted access vehicles. It is therefore unrealistic to suggest that the heavyvehicle traffic generated by these industrial sites be required to deviate significantly toavoid all residential areas. Further, it is not appropriate for the Site itself to beconsidered external to Bomaderry; it is an integral and longstanding facility inBomaderry, and therefore it is incorrect to suggest that heavy vehicle trips generated bythe Site along the local route are ‘through trips’ as stated by Council in correspondenceto the DoP.Finally, Christopher Stapleton Consulting Pty Ltd notes that the Department of Planningin its assessment of the Shoalhaven Starches Flour Mill upgrade construction stageCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 222
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(Report on the Assessment of Development Application No. DA-391-11-2002)specifically required that vehicles be routed by the local route:The Department is satisfied that the local road network would not besignificantly affected by construction traffic but recommends that truckmovements are undertaken, where practicable, outside peak hours and thatthe utilisation of the Bolong Road and Railway Street intersection ismaximised (in order to minimise use of the Bolong Road / Princes Highwayintersection which is busier).Notwithstanding, there is an obligation to maximise amenity for local residential, and ofcourse to ensure that the Proposal does not exacerbate impacts in the localarea/intersections. This is most critically achieved by a proposal that will generateonly up to 8 additional peak hour trips, and achieves the vast majority of itstransport task using rail.7.7.9 Rail AccessShoalhaven Starches transports the majority of its raw materials and export product viarail; this is one of the major benefits of the location of the subject site (by design), as itsignificantly reduces heavy vehicle movements that would otherwise be required.The Bolong Road level crossing is used by Shoalhaven Starches’ two rail operators totransport flour, containers, mill mix and sorghum to and from the Site. The currentnumber of trains servicing the Site is:• 7 Flour trains per week.• 2 Container trains per week.• 1 Sorghum or additional container train per week.Over the course of the year, trains transport approximately 700,000 tonnes of materialsand product to and from Shoalhaven Starches; this is the equivalent of some 28,000heavy vehicle loads, or 56,000 heavy vehicle trips per year that are not required due tothe provision of rail transport. On an average day, rail replaces approximately 200 heavyvehicle trips that would otherwise be generated in the local area.The weekly 10 inbound trains also generate 10 outbound train movements, therebytotalling 20 train movements each week. However, as the sidings currently available atShoalhaven Starches do not accommodate full trains (ie. the trains are longer than theavailable length of track on-site) there is currently a need to divide trains at Bolong Roadand leave parts of the train stowed between Railway Road and Bolong Road. Thisshunting requirement creates a further 20 – 30 rail movements (across Bolong Road)each week.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 223
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe total weekly rail usage of the Bolong Road Level Crossing is thereforeapproximately 40 – 50 rail movements per week, ie. 40 – 50 closures of Bolong Road tofacilitate the movement of trains.Shoalhaven Starches owns and maintains the lights and bells at Bolong Road as amajor risk management mitigation measure. Notwithstanding, Council in recent and pastcorrespondence relating to the Site have indicated a requirement for an upgrade of therailway crossing to provide boom-gates. Additionally, community representatives haverequested information relating to ability to extend the use of rail.7.7.10 ParkingShoalhaven Starches generates a peak parking demand through the day when it has afull complement of shift and day staff on-site, and (as is generally the case) there is alsoa small visitor demand. Based on observations by CSC and a review of the survey data,it is clear that there is a relatively minor amount of car sharing and virtually no othersignificant car driver reduction measures (ie. public transport) available.Based on these factors, CSC estimate that the peak parking demand of the Site duringstandard operating periods is between 160 to 180 spaces.The capacity of on-site parking has recently been augmented by the purchase of the“Moorehouse” site at Bolong Road; this area is now utilised as the primary (central) carparking, and provides capacity for approximately 110 vehicles. Along with otherdedicated parking areas, the total on-site parking provision exceeds 230 parking spaces.The standard operating parking demand has in recent times (and during the surveyperiod) been augmented by contractor parking, such that the construction super-peakdemand may be as high as 300 parking spaces. While areas around the Site have beenestablished by Shoalhaven Starches for parking to offset this temporary peak demand, itis apparent that off-site parking is (or at least until recently was) occurring.Parking off-site (on the Bolong Street verge adjacent to Access Point 1) was observedby CSC. This is contractor parking, the accommodation of which is provided by theon-site capacity and temporary parking areas, but which was still observed to beoccurring.Shoalhaven Starches have instructed all staff and contractors in regard to the availabilityof on-site parking. CSC also note that Council is determined to enforce the parkingrestrictions, a determination which CSC fully supports.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 224
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.7.11 Council, RTA and Community IssuesPrior to examining the specific details and potential impacts of the Proposal, it isimportant to review the comments of Council in their correspondence to the Departmentof Planning, in which they outline a number of issues (and specifically outstandingconditions) associated with earlier upgrade approvals for the Site, along with generalissues associated with the Proposal.These issues, along with comments provided by the RTA, are detailed in the recentDirector General Requirements (Annexure A).Shoalhaven City Council IssuesOutstanding ConditionsIt is acknowledged by Shoalhaven Starches that there are currently outstanding consentconditions in relation to past approvals for the Site. CSC is not aware of the reasons forthe non-compliance, but has examined each of the conditions detailed by Council.Pedestrian FootbridgeConditioned works (from earlier Site upgrade proposals) include a pedestrian footbridgeon the southern side of Bolong Road across Abernethy’s Creek.This condition has been addressed on an interim basis with the recent construction of atemporary pedestrian footbridge linking the existing footpaths either side of Abernethy’sdrain. The design and construction of the footbridge was completed followingconsultation and approval by Council. The provision of a permanent footbridge crossingwill need to be designed and integrated with the proposed upgrading works associatedwith Access 2.Access Point 2Conditioned works (from earlier Site upgrade proposals) at Access Point 2 include arequirement to increase the passing area at the intersection adjacent to Abernethy’sCreek, which in turn will require a widening of the culvert. Specifically, the conditionrequires full compliance with a Type A (AustRoads) design.CSC recommended the retention of access (two way) at Access Point 2 – andspecifically the retention of right hand turn access from Bolong Road - requires theimplementation of the upgrade design of the intersection, in line with the designapproved by the RTA and Council.This recommendation has been adopted by Shoalhaven Starches as part of theProposal, and is included in the current works for the recently approved Flour MillCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 225
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryProject. A revised draft design – provided to CSC by Allen Price & Associates on behalfof Shoalhaven Starches – is shown in Appendix A to the Traffic Assessment.Access Point 3An upgrade of the intersection of Access Point 3 at Bolong Road to provide a formalType A intersection was completed in 2003 but Council has indicated (incorrespondence) that the upgrade should be extended to include the driveway andadjacent shoulder seal to limit ongoing maintenance and safety related issues.It is the recommendation of CSC that a full seal of the carriageway should beimplemented which includes the eastbound passing verge; additionally, the accessdriveway for at least the distance from Bolong Road to the proposed controlled accesspoint to the site south of the Cleary Bros access point should be formalised, specificallyas a concrete driveway similar to the adjacent Cleary Bros entry driveway from BolongRoad.This recommendation has been adopted by Shoalhaven Starches as part of theProposal.Railway CrossingCouncil has indicated that there is an outstanding condition associated with an earlier(1990’s) upgrade proposal which required an upgrade of the railway crossing whentraffic flows and rail movements met the RTA warrants for boom gates; it is the opinion ofCouncil that such warrants are currently met.Based upon advice provided by Mr Glen Dawe, National Manager Rail Transport of the<strong>Manildra</strong> <strong>Group</strong>, boom gates are not currently required. This opinion is based on thefollowing:• Firstly, and most significantly, the Proposal will actually see a reduction in thenumber of rail movements at the crossing through the introduction of greater railcapacity (length) on-site south of Bolong Road, and siding capacity on the proposedpackaging plant site on the north side of Bolong Road.• The use of Bolong Road must also be considered in the light of the train operationswhich cross this level crossing: Trains approach the crossing and STOP. The crossings Lights and Bells, which have recently been upgraded to meetStandards, are then activated. Locomotives sound their Horn and are then escorted across the crossing.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 226
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry Train speed is walking pace, ie. less than 4 km/hr. As locomotives are in full view of road traffic in all directions with an approachvisibility of 250 metres, and are stationary before using the crossing, fullrecognition of impending rail usage of the crossing is available to all motorists. There are many examples elsewhere where rail movements exceed those atBolong Road and manual crossing protection solely is provided. <strong>Manildra</strong> owns and maintains the lights and bells at Bolong Road as a majorrisk management mitigation measure.According to CSC having regard to the available warrants, it is their opinion that thewarrants specifically refer to faster moving (ie. suburban) trains, and certainly notcircumstances where the movement is at such a slow pace, with good sight distance andaccompanied by lights and bells as for the existing crossing.Further details of the means by which the Proposal will actually reduce rail movementsat Bolong Road are provided below.Hannigans LaneCouncil has indicated that sight distances available at the Hannigans Lane Access to theEnvironmental Farm are marginally obstructed by adjacent foliage; while Council hasacknowledged that this is a minor issue, it is nonetheless the recommendation of CSCthat pruning (or the like) be undertaken to ensure that sight distances are provided. Thisrecommendation has been adopted by Shoalhaven Starches as part of the Proposal.Packaging Plant AccessBased upon discussions between CSC and Council staff, subsequent to the submissionsfrom SCC to the DoP and which formed the basis of the DGRs for the project, Councilhas indicated a preference for access to the packaging plant to be provided solely fromRailway Street, rather than the proposed one-way (heavy vehicle) system with egressvia Bolong Road (left turn in only) and egress to Railway Street.CSC would agree that where possible, access is better provided from an access roadsuch as Railway Street for all movements, particularly given Railway Street is alreadyused for predominantly industrial traffic. Notwithstanding, CSC support the Bolong Roadaccess proposal based on the provision of the safest and most efficient means ofproviding access to the packaging plant site while maintaining:• The capacity for rail movements and handling to be accommodated north of BolongRoad, and thereby allowing train movements across Bolong Road to be halved. ItCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 227
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrywould be all but impossible to provide this level of rail benefit while accommodatingthe turning paths required from a single access point to Railway Street.• An appropriate area for the operation of the large container forklift which will beemployed on the packaging plant site; the size of the site along with the handling,storage and rail requirements prevents the provision of suitable turning facilities forheavy vehicles entering from Railway Street.• Minimal impacts on existing traffic (in Bolong Road).CSC acknowledges that the proposal will introduce a new (very minor) access point toBolong Road. However, this left in only access point can be efficiently incorporated intothe design for the Access Point 2 upgrade, and will include a short deceleration lane.Most importantly, the access point will generate only 15 daily vehicle trips, with all heavyvehicle egress (along with staff ingress and egress) to Railway Street.Heavy Vehicles through BomaderryCouncil has over a number of years investigated the use of heavy vehicles in localroads, particularly along the local access routes between the local industrial areas andthe Princes Highway to the north-west. These specifically include Railway Street, MerooRoad and Cambewarra Road.CSC has identified the (albeit minimal) use of local routes by restricted access vehicles.This is not appropriate, and it will be imperative that Shoalhaven Starches furtheremphasise to drivers the required route via Bolong Road and the Princes Highway;enforcement may also be required, and would be supported by CSC.However, the local routes are entirely appropriate for the vast majority of vehicles(excluding restricted access vehicles) and provide efficient routing for the majority ofheavy vehicle trips, not only from the Site but from the broader Bomaderry industrialprecinct to the east of the residential areas. Indeed, these local routes provide the onlyaccess for a large number of the industrial sites in Bomaderry, and as such would bevirtually impossible to restrict.It is also recognised by CSC that the potential resulting increases (of additional localheavy vehicle restrictions) in traffic flows at the intersection of the Princes Highway &Bolong Road may reduce its performance, such that there would be a greater potentialfor multiple heavy vehicle movements blocking the southbound movement from BolongRoad (based on the current intersection geometry). This would in all probability requirean upgrade of the intersection – and specifically the widening of the westboundapproach to provide a lengthened right hand turn lane.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 228
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryCSC notes that Council has not raised any specific traffic capacity issues in relation tothe movement of heavy vehicles along the local routes, and that in consultation with theCommunity Consultation <strong>Group</strong> no specific issues were raised in regard to heavy vehiclemovements. Certainly, it is possible that there may be some general amenity concernsthat could be raised in a review of heavy vehicle movements, but no specific issues havebeen defined, and Council has provided no information relating to specific incidents orissues relating to heavy vehicles in the area.CSC acknowledges that the Proposal will introduce a new (very minor) access point toBolong Road. However, this left in only access point can be efficiently incorporated intothe design for the Access Point 2 upgrade, and will include a short deceleration lane.RTA IssuesThe RTA, in both their correspondence to the Department of Planning of January 2008and in our discussions has raised essentially the same issues as those raised byCouncil. These include:• The fulfilment of outstanding consent conditions relating to the Bolong Road accesspoints.• The proper design of those access points.• Any potential construction impacts.Significantly, the RTA expressed no significant issue with the local heavy vehicle route,or with the operation of local intersections.As with their consultation with Council, CSC has engaged fully with the RTA to ensurethat all local and site specific issues have been examined appropriately. From a regionaltraffic perspective, this has specifically included a review of future traffic flows along theprimary regional routes, and the establishment of an appropriate forecast horizon andaverage growth rate for the assessment.Community IssuesBased upon initial discussion with the Community Consultation <strong>Group</strong> the only trafficrelated issue was the potential use of rail to convey a greater proportion of materialsfrom the Site, and specifically a greater proportion of materials generated by the currentproposal. It is acknowledged that this request relates largely to residential amenity andthe movement of heavy vehicles (in general).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 229
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryIn responding to this issue, CSC notes that the current use of rail by ShoalhavenStarches allows for the removal of up to 200 heavy vehicle trips a day from local roads,and up to 56,000 heavy vehicle movements per year.For the current proposal, the overwhelming majority of additional materials and productwill also be transported by rail, resulting in up to 4 additional trains per week servicingthe Site; this is estimated to represent the equivalent of a further 20,000 heavy vehicletrips per year.The existing heavy vehicle trips generated by the Site are servicing end users not readilyor practicably accessed by rail. This includes the delivery of some materials to the Site,but more importantly the transportation of product to regional and interstate centreswhere the use of rail is not possible (due to the time demands of product storage).In the future, the transportation of materials and product to regional and interstate sitesnot readily accessible by rail will require 19 additional heavy vehicles per day, or thegeneration of 38 additional heavy vehicle trips.It is important to note that ‘back-loading’ – where a full train arrives and unloads, andthence is reloaded before departing – is not possible due to the different carriagerequirements for the transportation of materials as opposed to export product.Container trains are loaded in and out of Nowra. Trains coming in bring in emptycontainers and trains departing take loaded containers by rail to Port Botany for export;this reflects Government policy, which is seeking to achieve a rail market share of 25%for all Botany/Port related movements.7.7.12 Site AccessThe Site will retain the existing primary access points off Bolong Road, while thepackaging plant will require a new ingress (left in) only driveway from Bolong Road, andan upgraded of the existing access point off Railway Street. The design and operationof each of the access points is described below.Access Point 1With reference to the traffic generation estimates an additional 15 heavy vehicles(30 movements) will utilise Access Point 1 daily; while the surveyed contractor vehiclemovements will be removed by the time standard operation commence, CSC have intheir assessment retained the surveyed flows to provide a super-peak assessment whichin their opinion would represent significantly higher flows than under future standardCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 230
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryoperations. In their view this approach provides an appropriate approach, as it is difficultto envisage construction demands exceeding those experienced in August 2007.Shoalhaven Starches and CSC have on numerous occasions requested a review of thespeed limit provided in Bolong Road adjacent to Access Point 1. It is CSC’s view that itwould be appropriate to relocate the speed zone to the east, such that vehicles weretravelling at an urban speed (60 km/h) past the Site.According to CSC, Shoalhaven Starches should certainly be considered as part of theconsolidated urban environment. It is difficult to reconcile the significant speedreductions provided by the RTA and Council along other parts of the road network(including the Princes Highway) where speeds are reduced from 80 km/h or even100 km/h to 40 km/h or 50 km/h well outside of activity zones; yet at the Site, which isclearly designated as the start of the urban (Bomaderry) environment, it has not beenpossible to relocate the speed thresholds to the east.Access Point 2The proposal does not increase movements at Access Point 2; nonetheless, theoperation of Access Point 2 will be enhanced by the implementation of an upgradedType A intersection.Access Point 3An additional 4 heavy vehicles (8 movements) and 10 staff vehicles (20 movements) willutilise Access Point 3 daily in association with the ethanol upgrade; conversely,15 heavy vehicles (30 movements) and 5 staff vehicles (10 movements) will be removedfrom Access Point 3 daily through the development of the packaging plant, and thereforethe relocation of the current on-site packaging plant vehicle generation.In response to Council’s identification of the design issues at Access Point 3, CSC hasrecommended that the full carriageway (including the passing area on the northernverge) be sealed, and that a concrete driveway be constructed which extends south tothe entry point to the Site, which will be controlled by a boom gate.Access Point 4The capacity of the Access 4 car park is generally fully utilised at present, thoughadditional shift staff (outside of peak hours) would potentially be able to use the car park.As for Access Point 3, additional staff movements generated by the proposal will largelybe offset by the relocation of the packaging plant.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 231
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAccording to CSC this ingress point was at times also being used for egress. It was theobservation of Council staff that on some occasions the egress driveway gate wasclosed, requiring egress from the ‘ingress’ driveway. CSC notes that the intersectionsurveys did not record this occurring during the peak periods (presumably because bothingress and egress gates were open).It is the recommendation of CSC that both the ingress and egress gates be open at alltimes to allow for the separation of ingress and egress.Packaging Plant AccessAccess to the packaging plant is proposed via a one way system with ingress via BolongRoad (left turn in only) and egress to Railway Street.This access proposal has been adopted as it provides the greatest level of safety andefficiency for both vehicles generated to and past the access points, while retaining thecapacity on-site (packaging plant) to maximise operational safety and efficiency byremoving conflicts between heavy vehicles and forklifts servicing the container loadingarea adjacent to the proposed packing plant.The packaging plant access design proposal does not necessitate the provision of largeturning paths (on-site) such as would be required to accommodate heavy vehiclesaccessing the packaging plant solely from Railway Street. With a one-way system inplace between Bolong Road and Railway Street, the design provides for:• The accommodation of significant additional rail infrastructure, including siding,handling and loading facilities. By providing the means to split (and store) trainsnorth of Bolong Road (ie. on the packaging plant site) the Proposal will halve thenumber of rail movement across Bolong Road daily.• An appropriate area for the operation of the large container forklift, which will beemployed on the packaging plant site.• A restricted level of access provision (left turn in only for heavy vehicles only) thatwould not impact the existing Bolong Road traffic flows.CSC acknowledges that the proposal will introduce a new (very minor) access point toBolong Road. However, this left in only access point can be efficiently incorporated intothe design for the Access Point 2 upgrade, and will include an appropriately designeddeceleration lane. Most importantly, the access point will generate only 15 daily vehicletrips, with all egress (along with staff ingress and egress) to Railway Street.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 232
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAn existing driveway is located on the southern boundary of the packaging plant site toRailway Street; this driveway will be upgraded to conform to AS 2890.2:2002, specificallyto allow for the movement of heavy vehicles from the Site. Access for staff vehicles(ingress and egress) will also be provided via the Railway Street driveway.7.7.13 Traffic GenerationAs discussed above, the Proposal will see only a very minor increase in the lightand heavy vehicle traffic generation of the Site, with the majority of the extra (andexisting) transport task accomplished by rail.Rail TransportThe proposal will generate an additional 4 trains per week to the Site. The use of railalready saves the generation of up to 56,000 heavy vehicle trips per year. The provisionof 4 additional trains per week is estimated to eliminate some 20,000 heavy vehicle tripsper year, or 50 – 100 heavy vehicle trips daily.The new packaging plant (incorporating the packaging facility, warehouse and containerstorage area) will be served by a new siding between Railway Road and Bolong Road.This new facility, with its dedicated siding, will eliminate container related train andshunting movements from Bolong Road level crossing, ie. eliminate the existing demandfor access to the primary Bolong Road Site.Additionally, the rail siding capacity at the existing Site will include the lengthening of thecurrent siding and the creation of a new loop siding south of Bolong Road. This willeliminate the need for flour and sorghum trains to divide at Bolong Road to allow forunloading at their respective receival pits. As a result of these siding works, full trainswill be able to be accommodated on-site north of Bolong Road, and will have therequisite siding space to allow unloading without impinging on Bolong Road.The net result of these proposals will be a reduction in train movements across theBolong Road level crossing by up to 26 movements per week, including 8 – 10 fewercontainer movements (facilitated by the new packaging plant infrastructure) and 16 fewershunting movements (facilitated by the new Site rail siding infrastructure).Therefore while the Site will increase the amount of materials moved by train,thereby maintaining the minimum low heavy vehicle trip demand, the total usageof the Bolong Road level crossing will be 16 – 24 movements per week. Thisrepresents approximately a 50% reduction in the current crossings of BolongRoad.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 233
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe precise timing of these movements to and from the Site – therefore requiring aclosure of Bolong Road – are not known at this time, as the movements will requirescheduling with the rail network demands and are controlled by rail authorities andtherefore out of the control of Shoalhaven Starches. However, in CSC view the closureof Bolong Road for the short period of time for the train to cross wholly into the Site willcontinue to have no significant impact on flows in Bolong Road. CSC recommend thatthe movements – as far as possible – continue to occur outside of peak periods.Road Transport Demand and Staff TripsFor those materials and products not deliverable by rail, heavy vehicle transport will berequired. The proposal will marginally increase heavy vehicle and staff movements tothe Site, though these movements will be largely off-set by the relocation of thepackaging plant and its associated movements.The Site traffic generation will increase as follows:• An additional 30 daily ethanol heavy vehicle trips via Access Point 1. Based onexisting and future ethanol delivery vehicle demands, it is estimated thatapproximately 50% of these vehicles will be articulated vehicles, and 50% restrictedaccess vehicles.• An additional 8 daily DDG heavy vehicle trips to Access Point 3, offset entirely bythe relocation of 30 daily heavy vehicle trips rips to the proposed off-site packagingplant. Heavy vehicle trips to Access Point 3 would therefore decrease from currentlevels by 22 trips per day. Based on existing and future characteristics DDGdelivery vehicle demands, it is estimated that majority of these vehicles will bearticulated vehicles.• An additional 50 daily staff vehicle trips across Access Points 3 and 4, off-setsignificantly by the relocation of 30 daily packaging plant staff trips, (ie. a netincrease of approximately 20 trips daily).• A total of 30 -50 light vehicles and 30 heavy vehicles accessing the packaging plantdaily, with 15 heavy vehicle ingress trips daily from Bolong Road, and 15 heavyvehicle trips along with 30 - 50 staff trips daily to Railway Street. Based on existingand future packaging demands, it is estimated that the majority of these vehicles willbe articulated vehicles.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 234
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryFuture Daily TripsWith consideration of the additional traffic demands outlined above, the daily trafficgeneration of the primary Bolong Road Site will increase by a total of 8 heavy vehicletrips daily, and by 20 light vehicle trips daily.The total future traffic flow of the primary Bolong Road site would therefore increase toapproximately 920 light vehicle trips and 160 heavy vehicle trips daily under standardoperation periods.The packaging plant site will generate 30 heavy vehicle trips and 30 light vehicle tripsdaily.Future Peak Hour TripsWith reference to the existing peak hour movements and a review of distribution patterns(time) of the ethanol and DDG components of the existing Site (and indeed all heavyvehicle distribution patterns, which overwhelmingly show a propensity for trips outside ofthe peak periods as is standard based on operational peaks at a site operating 24 hoursa day), CSC has estimated that the proposal could generate an additional 8 vehicles tothe local network during a peak hour, including up to 4 heavy vehicles and 4 light (staff)vehicles).These generation characteristics tally also with the daily/hourly data breakdown from theclassifier counter surveys provided by SCC.Trip DistributionAs discussed above, the proposal will see additional heavy vehicle trips being generatedto Access Point 1 but a reduction in trips to Access Point 3; additional light vehicle tripswill also be generated to Access Point 4 and other on-site parking areas accessed fromAccess Point 3.Based on the peak periods and accounting for a small additional redistribution of staffparking trips and the other access points for general parking CSC has determined thefollowing distribution profile:• Access Point 1 would generate up to a maximum 4 additional heavy vehicle trips inthe peak hour, being 2 ingress and 2 egress trips.• Access Point 2 would generate no additional vehicle trips in the peak hour.• Access Point 3 would generate up to a maximum 2 additional light vehicle trips butup to 5 fewer heavy vehicle trip in the peak hour.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 235
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Access Point 4 would generate up to a maximum 2 additional light vehicle trips inthe peak hour.• The packaging plant access point in Bolong Road would generate up to 3 heavyvehicle trips and the Railway Street access point up to 2 heavy vehicle trips and 3light vehicle trips in the peak hour.Away from Shoalhaven Starches, the additional trips are expected to distribute to thelocal road network in an identical manner to the current distribution. With ethanoldeliveries utilising both articulated vehicles and restricted access vehicles, and DDGdeliveries primarily articulated vehicles, the potential exists for up to 2 restricted accessvehicles to be generated during a peak hour, ie. to be generated to the key regionalintersection of the Princes Highway and Bolong Road. The remaining trips would bedistributed via the local industrial route. CSC again notes that at present no more than asingle restricted access vehicle was surveyed making the critical right hand turnmovement from Bolong Road to the Princes Highway in any single hour.Staff vehicles will be distributed to the general local area via all available routes in thepeak hours, resulting in an additional 2 - 4 vehicles at the intersection of Bolong Streetand Railway Street, and 1 – 2 vehicles at the intersection of Princes Highway andBolong Road.7.7.14 Future Intersection PerformanceEven a cursory review of the additional traffic generation potential of the Proposalaccording to CSC strongly indicates that the Proposal will have little impact in andof itself on the future road network.The estimated maximum increase in peak hour traffic flows – a total of 8 vehicle trips – isdwarfed by the average annual increases in local flows such that the total additional tripsgenerated by the Proposal represent only a minor proportion of a single year’s averagegrowth in flows along Bolong Road.CSC notes that average growth forecasts are in themselves based on the additionalminor generation of local areas, as well as broader new generators; that annual growthis further based on a super-peak recreational flow that is appropriate for designpurposes, but significantly exceeds average weekday traffic flows.Additionally, CSC would again stress that the site generated traffic flows used in theirassessment are themselves a significant overstatement of standard operations, giventhat they include a large number of contractor vehicles working on earlier approved siteupgrades. The generation of these contractors alone during the survey periodCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 236
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryrepresents a significantly higher peak period generation than which would begenerated by the proposal, ie. the 'existing' conditions represent a Site generationsignificantly in excess of the standard operations upon which traffic impacts wouldgenerally be assessed, and significantly in excess of the standard operations which willprevail following the implementation of the Proposal works.Notwithstanding, CSC has examined the future intersection performance using SIDRA.Following advice from Council, CSC has in the analysis modelled a higher cycle time toreflect the operations of the RTA in accommodating additional traffic demands at keyregional intersections; the cycle time has been increased from 110 seconds to130 seconds for the critical AM peak hour.Additionally, the operations at the intersection of Bolong Road and Access Point 2 arebased on the provision of a Type A intersection as has been adopted by ShoalhavenStarches for this intersection.7.7.15 Minimising General Traffic ImpactsThe most important works to be undertaken by Shoalhaven Starches to minimise anypotential impacts arising from upgrades of the site are the outstanding upgrade works atAccess Point 2 and Access Point 3; these are critical to the provision of safe and efficientaccess for the Site into the future.The design of this intersection is to be integrated with respect to the proposedpedestrian crossing of Abernethy’s Creek; the proposed pedestrian/product overheadbridge; and the vehicular access to the proposed Packing Plant. A conceptual design forthe upgrading of each of the access points to proposed development is included inFigure 27.Additionally, the provision of new rail infrastructure will significantly reduce the demandfor rail movements across Bolong Road to the benefit of motorists.As discussed, Council has raised the potential of limiting or potentially excluding heavyvehicle from the local industrial route through Bomaderry.Council has in the past committed to heavy vehicle projects which have not eventuated.For example, a heavy vehicle bypass (along, we understand, the alignment of MerooRoad and then Railway Street) was proposed in the late 1990’s but has now beenabandoned. More recently, Council indicated a proposal to upgrade the pavementsurfaces along the route (for, we understand, noise attenuation and potentially somewidening benefits), but this project has yet to be confirmed. Council has alsoCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 237
Figure 27: Traffic Access ArrangementsFIGURE 27
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryacknowledged that it would be virtually impossible to impose load limits in the local roadsgiven that they service areas zoned for industrial development.It is the opinion of CSC that at this time there are no compelling reasons to impose suchrestrictions, particularly as these local routes are recognised and essential to theprovision of industrial access for the Bomaderry industrial precinct, which certainlyextends to the Site. Additionally:• There is no apparent mechanism by which it would be possible to limit the use of thelocal road by some industrial sites, yet retain their use by other industrial sites.• There would be potential impacts at the intersection of the Princes Highway andBolong Road due to an increase in the number of vehicles – and specifically heavyvehicles – making the right hand turn movement to the north. It is CSC’s opinionthat these impacts could be reduced by an upgrade of the intersection (increasingthe right hand turn lane capacity) but it would be unreasonable for Council to forcevehicles (from all local sites) to use this route and then impose costs on those siteoperators. Further, there is not currently in place any mechanism by which acontribution could be provided.• It is certainly the case that if the site traffic (or indeed traffic from any specificdevelopment) were to have a demonstrable impact, some action would be required.However, this is not the case; there is no evidence that the few additional tripsgenerated by this proposal have any significant impact on its operation, with themost significant potential for additional delay occurring simply as a result ofadditional traffic flows (average annual growth) along the Princes Highway andalong Bolong Road.It is the recommendation of CSC that Shoalhaven Starches commits to be involved inany future consultation with the RTA and Council that examines the use of heavyvehicles throughout the entire area, as it is certainly the case that Shoalhaven Starchesis a significant generator of heavy vehicle trips. However, it is inappropriate to suggestthat Shoalhaven Starches is the lone generator, with the traffic surveys clearly showing asignificant local heavy vehicle generation not directed to/from the site.It is further recommended by CSC that should additional studies relating to more generalamenity issues show that the additional trips generated by the Proposal do have animpact (on amenity) then additional impact minimisation measures must be assessed byShoalhaven Starches in consultation with Council, the RTA and the local community.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 238
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryFinally, CSC strongly support the enforcement of the existing restricted access vehicleroute restrictions. While there are transport benefits associated with the use of restrictedaccess vehicles, it is nonetheless the case that their operation along non-approvedroutes is inappropriate.7.7.16 ParkingFigure 28 provides a plan identifying car parking over the factory site. With theacquisition of the “Moorehouse” site, the provision of parking for the site has beensignificantly increased. The site currently provides approximately 259 formal parkingspaces, including:• 21 spaces in the Main Office area.• 12 spaces in the Project Office area.• 14 spaces to the rear of the Project Office.• 110 spaces in the “Moorehouse” maintenance workshop area car park accessedfrom Access Point 4.• 50 spaces in the DDG Loadout area.• 52 contractor parking spaces to the south west of the site.In this regard the following parking spaces are proposed to be provided:• Maintenance workshop area (“Moorehouse”) – 40 spaces;• Proposed Packing Plant – 34 spaces;• East of coal storage area – 20 spaces.Based on the above with an existing provision of 259 spaces and proposed additional 94spaces the Shoalhaven Starches’ site will be available to provide a total of 353 spaces,including both permanent and temporary contractor parking.CSC has estimated the current peak parking demand – based on staff on-site andminimal car driver reduction opportunities – at 180 parking spaces.While an additional 15 staff would be on-site at any one time (5 office staff and 10 shiftstaff) the Proposal will see 15 staff relocated to the new packaging plant, and as suchthere is unlikely to be any significant increase in on-site parking demand; the 353parking spaces to be provided on-site will provide in excess of peak demands.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 239
Figure 28: Plan identifying car parking over the Factory Site.FIGURE 28
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAccording to CSC the parking currently available on-site would also accommodate thebulk of additional demand that could be generated during super-peak periods, such asduring a construction period.Given that parking areas will therefore be available on-site in excess of the combineddemand of both standard staff requirements plus contractor requirements, there is noreason for parking to be generated off-site, and specifically in Bolong Road. CSC wouldsupport any enforcement initiatives aimed at eliminating any remnant parking demand inBolong Road in contravention of existing parking restrictions.7.7.17 Conclusions and RecommendationsChristopher Stapleton Consulting Pty Ltd has prepared a detailed and independentassessment of the access, traffic and parking issues associated with the Proposal,utilising available data, design standards and traffic analysis models. CSC concludethat:• <strong>Manildra</strong> is committed to the implementation of outstanding developmentconsent conditions. These include a significant upgrade of Access Point2 to full compliance with a Type A intersection, and incorporating apedestrian access bridge (recently completed); and a further upgrade ofAccess Point 3 to limit ongoing maintenance.• The Proposal will continue to utilise rail as a primary mode of transport,eliminating an additional demand for approximately 400 heavy vehicletrips per week. While the number of trains servicing the Site willincrease (by 4 trains), the packaging plant site on the northern side ofBolong Road, along with additional on-site railway siding capacity, willreduce movements across Bolong Road to approximately half currentthe levels, i.e. halve the number of closures of Bolong Road at theexisting railway crossing.• The Proposal will generate up to 88 additional vehicle trips daily(24 hours) to the local road network; the additional peak hour generationof the Proposal to the local road network would be up to 8 vehicle trips.These very minor traffic increases can be accommodated by the sameconditioned local road upgrades as required for the recent SSFMProject, and have no significant impact on the local traffic network.• The provision of a one-way access system from Bolong Road to RailwayStreet for heavy vehicles accessing the packaging plant is required toprovide for safe on-site access and handling, and to incorporate greaterrail capacity which in turn will reduce rail crossings of Bolong Road.• The utilisation of local industrial access routes by heavy vehicles isentirely appropriate and provides VKT, emission and time cost savings,as well as reducing impacts at key intersections.• Parking is provided on-site and for the packaging plant in excess of thepeak staff parking demand.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 240
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe Traffic Impact Assessment prepared by CSC makes the following recommendationsto achieve appropriate transport outcomes on the Site:i. Access Point 2 will be upgraded following approval of final designplans by the relevant local authorities. The upgrade will beimplemented as part of the approved SSFM Project, and completedprior to the commencement of the operations provided for by thisProposal.ii.iii.iv.Access Point 3 will be upgraded following approval of final designplans by the relevant local authorities. The upgrade will beimplemented as part of the approved SSFM Project, and completedprior to the commencement of the operations provided for by thisProposal.A new left in only ingress driveway will be provided from Bolong Roadto the packaging plant following approval of final design plans by therelevant local authorities.The packaging plant driveway to Railway Street will be upgraded to fullcompliance with the appropriate AS 2890.2:2002 design standards.v. The gates providing access to the primary Site car park (Access Point4) will remain open at all times to allow for the separation of ingressand egress movements; this recommendation has already beimplemented by <strong>Manildra</strong>.vi.vii.viii.That rail movements continue to be – as far as practicable – scheduledoutside of local peak periods, and specifically outside of the morningand afternoon commuter peak periods, though it is acknowledged that<strong>Manildra</strong> does not have direct control over the scheduling of railmovements.That <strong>Manildra</strong> continues to provide heavy vehicle drivers withinformation and training in regard to the use of the designatedrestricted access vehicle route by restricted access vehicles, and theavailability of on-site parking areas.That <strong>Manildra</strong> works constructively with SCC, the RTA and localcommunity through any future implementation of local heavy vehicleroute changes; this may include changes to the use of the localindustrial vehicle route and key regional routes.Following their assessment of the key issues associated with the proposal, and with theapplication of the recommendations outlined above, Christopher Stapleton ConsultingPty Ltd conclude that the proposal is supportable from an access, traffic and parkingperspective.Whilst CSC recommend that road upgrading works associated with Access Points 2and 3 are to be completed prior to the commencement of this project, ShoalhavenStarches, as discussed with staff from the Department of Planning, commit to completingCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 241
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrythese works prior to the commencement of operation of the approved Flour Mill project.This commitment is confirmed in Section 8.3.5 of this EA.7.8 HAZARDS AND RISKIn general, risk assessment of industrial developments follows 5 basic steps:• identification of potential hazards;• an evaluation of safeguards to minimise the chance of occurrence of the identifiedhazards and their impact;• an assessment of the magnitude of the consequences of the identified hazards;• an assessment of the likelihood of occurrence; and• an assessment of the risk by a combination of the consequences and likelihoodsand comparison with tolerability criteria.The Department of Planning has prepared a set of guidelines to help determine the levelrequired according to the nature of the development:• Multi-level Risk Assessment (MRA) describes the level and extent of the analysisreflecting the nature, scale, location of the proposed development;• Hazardous Industry Planning Advisory Paper (HIPAP) No. 6 provides guidelines onrequirements of the analysis;• Hazardous Industry Planning Advisory Paper (HIPAP) No. 4 provides the adoptedrisk criteria for land use planning decisions;• SEPP No. 33 provides a screening tool to determine whether a proposeddevelopment is hazardous and offensive, whether it requires a PHA, whether thePHA needs to be qualitative or quantitative and whether a detailed transportationstudy is required.Shoalhaven Starches engaged the services of GHD Pty Ltd to prepare a PreliminaryHazard Assessment (PHA) for the proposal. A copy of this PHA forms Annexure F tothis EA. This section of the EA is based upon the findings of this report.The PHA was completed in accordance with the screening criteria detailed in the StateEnvironmental Planning Policy (SEPP) 33 guideline of the then Department of UrbanAffairs and Planning (DUAP), now the DoP. The Hazard Assessment was completed inaccordance to Hazardous Industry Planning Advisory Paper (HIPAP) No. 6.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 242
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe major hazards identified in the PHA were included in the Quantitative RiskAssessment (QRA) which was completed using SAFETI (Software for the Assessment ofFire, Explosion, Toxic Impact) and the risk criteria given in HIPAP No. 4 for off-siteimpact.The QRA included the existing operation and the new hazards introduced by theproposed upgrade.Hazard IdentificationAccording to GHD the major hazards, introduced by the proposed upgrade, that havepotential for off-site impact are:• Co-generation Plant: potential for fire and explosion associated with natural gas;• Ethanol Loading Bay: Increased loading frequency associated with increasedethanol production leading to increased likelihood of release of ethanol due tohuman factors or mechanical failures;• Gas Fired Boiler (150 tph steam).The existing major hazards, included in the QRA, that have potential for off-site risk are:• Ethanol Storage Tank Farm: the storage capacity will not change;• Ethanol Loading Pump: will operate more frequently;• Distillation Units;• Molecular Sieves;• Gas Fired Boiler No. 2.The dust cloud explosion hazards are not included in this QRA. According to GHD aseparate risk assessment was completed for the dust cloud explosion during an earlierplant upgrade last year and was demonstrated not to have off-site impact.Frequency AnalysisThe failure frequencies of equipment were calculated by GHD using failure rate dataobtained from the UK Health and Safety Executive (HSE) for pipes and equipment. TheUK HSE data is derived from off-shore operations in a harsh environment and hence isconsidered to be conservative when applied to a clean on-shore process.Consequence AssessmentThermal radiation with respect to fire, and overpressure with respect to explosion,associated with ethanol and natural gas were assessed.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 243
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe ethanol fire was modelled as a pool fire and natural gas fire was modelled as a jetfire. Overpressure was modelled as a vapour cloud explosion with respect to ethanolvapour and natural gas.Risk AssessmentThe failure frequencies and consequences were combined in SAFETI to calculate therisk contours for the Shoalhaven facility.Individual Fatality Risk contours were calculated and overlaid on the map of theShoalhaven facility to show the impact zone. The Individual Risk results for thenominated risk criteria of HIPAP No. 4 are given below in Figure 29.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 244
Figure 29: Individual Fatality Risk Profile for the Shoalhaven Operation.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 245
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe risk calculated for the existing operation and the proposed upgrade of theShoalhaven facility according to GHD, is acceptable as the risk contours are incompliance with the nominated risk criteria of HIPAP No. 4. There are no sensitiveareas nearby the site affected by the operation.The key information from the Individual Fatality Risk profile are:• 50 x 10 -6 /yr risk contour around the ethanol production facility is within the siteboundary. The individual sites around the <strong>Manildra</strong> plant are not affected.• The 5 x 10 -6 /yr to 0.5 x 10 -6 /yr risk contours go over the Bolong Road but does notbreach the risk criteria.• The Cogeneration plant to be located in the south corner of the site does not breachany risk criteria.The off-site risk from the existing operation and the proposed modification is acceptableaccording to GHD. However, opportunities for risk reduction should be continuouslyreviewed and implemented.Societal RiskAccording to GHD, there are no residential or sensitive population close to the site to beaffected by a large incident on the site. The closest residential area is over 350 m awayto the west beyond the railway line.Injury RiskThe closest residential area is over 350 m away from the ethanol facility and themaximum distance from an explosion or fire is:• 4.7 kW/m 2 (70 m)• 7 kPa (110 m)Therefore according to GHD injury risk to people in the residential area is not possiblefrom a fire or explosion event in the ethanol facility.Property DamageThere are no hazardous industries close to the site according to GHD to causeescalation issue from an incident on the <strong>Manildra</strong> site.• The overpressure of 14 kPa does not extend more than 70 m from the ethanolfacility. The explosion overpressure (14 kPa) from the co-generation unit does notCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 246
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryexceed the boundary. Figures C1 and C2 in Appendix C of the PHA show theexplosion overpressure contours for the cogeneration unit and mol sieve.• The thermal radiation of 23 kW/m 2 does not extend beyond the site.The PHA prepared by GHD concludes:“The Quantitative Risk Assessment (QRA) as part of the Preliminary HazardAnalysis (PHA) was completed for the proposed Ethanol Facility upgrade atthe Shoalhaven site. The QRA incorporated the proposed ethanolproduction upgrade and the existing operation to show the total riskassociated with the site.The hazardous materials and hazardous operations that have potential for offsite impact were included in the QRA. The new hazards with potential for offsite impact introduced by the proposed upgrade are:• Cogeneration Plant; and• Increased ethanol loading frequency, as a result of doubling of ethanolproduction capacity, which increases the likelihood of release of ethanolin the loading bay.The PHA was completed in accordance with the State EnvironmentalPlanning Policy (SEPP) 33 guideline of NSW DUAP (now DoP) and HIPAPNo. 6 guideline for Hazard Analysis. The QRA was completed using the RiskCriteria for Land Use Safety Planning given in HIPAP No. 4.Individual Fatality Risk was calculated using SAFETI (Software for theAssessment of Fire, Explosion and Toxic Impact) and the risk isdemonstrated to be acceptable as all the risk contours are in compliance withthe nominated risk criteria of HIPAP No. 4.”The PHA prepared by GHD makes the following recommendations with respect to theproposed ethanol upgrade project:“The off site risk assessment completed for the proposed ethanol productionupgrade is in compliance with the DoP risk criteria given in HIPAP No. 4.However, it is recommended to identify opportunities during the designphase of the project to improve the safety of the process. This can beachieved through design reviews and appropriate safety studies.The following recommendations are made to improve the safety of theproposed upgrade:1. Complete the Hazard and Operability (HAZOP) for the new plants i.e.co-generation, gas fired boiler and mol sieve at the completion of thedetail design;2. Review the impact of the increased production capacity on the existingprocess units (vessels and pipes) with respect to mechanical integrity;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 247
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry3. Consider completing a traffic risk assessment with respect to increasedtraffic movement associated with raw materials and ethanol movementto and from the site;4. Review the fire fighting capability with respect to new plant andequipment such as the co-generation plant and gas fired boilers;5. Review the emergency shutdown system and emergency procedureswith respect to the new plants (co-generation and boiler).”7.9 RIVER BANK STABILITY AND RIPARIAN MANAGEM<strong>ENT</strong>Coffey Environments Pty Ltd were engaged by Shoalhaven Starches to:• detail potential impacts on river bank stability;• provide options for stabilisation works;• address riparian corridor issues including riparian corridor widths and revegetationworks.This section of the EAR is based upon the findings of this assessment. A copy of thisassessment forms Annexure I of this EAR.7.9.1 GeomorphologyThe site is situated on an active floodplain with small levees, minor depressions andbackwater swamps on alluvium deposits. The Soil Landscape Series Sheet 9028 (1993)Kiama indicates the floodplain landscape is level to gently undulating along river bedsand banks with flat to gently undulating terrace surfaces along the Shoalhaven River.Natural Geomorphological ProcessesFlow characteristicsShoalhaven floodplain is 6 -10 km wide, with minimal relief (approximately 5 m withslopes of less than 3%). Stream morphology and ecosystem characteristics are stronglyinfluenced by changing flow direction as a result of tidal saltwater inputs and freshwaterinputs after rainfall events.Shoalhaven RiverThe factory site abuts Shoalhaven River, which is characterised by small narrow terraceswith a relief of approximately 2 – 5 m. Spatial variation is uniform with a steady laminarflow and minimal surface roughness. According to Coffey Environments the River wasnot in flood and wind shear was minimal, giving a slight ripple effect on the surface of theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 248
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryriver. Water inflows were recorded between the factory and river at 0.45 m, indicating apresence of infiltration and interflow through the soil profile to groundwater.Bomaderry CreekBomaderry Creek flows through the township of Bomaderry and Nowra North beforeconverging with Shoalhaven River adjacent to the factory site. Spatial variation wasuniform with a steady laminar flow. The top of the bank ranged between 1 – 3 m fromthe surface. Water inflow was recorded at 0.45 m at the nearest borehole (CBH100)located between the existing Coal Pit and Bomaderry Creek.Abernethy’s CreekAbernethy’s Creek passes through the factory site before it converges with ShoalhavenRiver. It has been previously dredged and channelled and resembles an open drain,with hardened sections within the factory site. Bank heights range between 1 – 3 m.Spatial variation was uniform with a steady laminar flow, although it may becometurbulent during heavy rainfall as there are large rocks present in the streambed. Waterinflow was detected at 2.2 m.Broughton CreekBroughton Creek forms the eastern boundary of the Environmental Farm over a distanceof about 3.6 km. This section exhibits the typically characteristics of an activemeandering stream in alluvial floodplain deposits including scouring and deposition onmeanders, and evidence of meander cut-offs within the stream network. Spatialvariation was uniform with a steady laminar flow and bank heights ranged between 0 –3 m.Bank erosion and depositionBank erosion is related to two major types of processes: fluvial entrainment and theweakening and weathering of bank materials which enhance the potential for masswasting (Ritter et al., 2002). The weakening and weathering of bank materials isaccelerated by the lack of vegetative cover and binding root systems generallyassociated with structurally diverse ecosystems. Much of the floodplain, particularly inand around the factory site and environmental farm, has been previously cleared forpasture and dairy farming. Therefore natural bank erosion and deposition is likely tohave been influenced by human activities for some time.The floodplain is subject to scour, sheet and rill erosions during floods and may becovered by varying depths of alluvial materials as the floodwaters recede. Minor streambank recession and bank collapse was common, particularly in areas where vegetationCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 249
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryhas been removed. Bank materials would be transported down stream and eitherdeposited in the mouth of the estuary or carried out to sea during high rainfall and floodevents.Sediment deposition in Shoalhaven River occurs on the upstream side of Pig Island,adjacent to the factory site. Historical aerial photos show how the spit of Pig Island haschanged over the past 50 years. Deposition in this area has created deeper channelsalong the edges of the Shoalhaven River, encouraging scouring of the riverbank. It islikely that recent bank recession and collapses on the northern bank is attributable to theremoval of native riparian vegetation for the construction and operation of the factory sitein conjunction with the aforementioned scouring process.As the provision of appropriate foreshore riparian zones and setbacks were notimplemented during construction of the factory, bank stability has been underminedalong Shoalhaven River, and Abernethy’s and Bomaderry Creeks. Poor site planning,lack of riparian buffers, weed infestation, inappropriate plantings, reduced vegetationquality and cover, and channelling works, in addition to natural scouring, are all likely tohave contributed to riverbank recession in and around the factory site.Broughton Creek is located adjacent to the Environmental Farm. Broughton creek is anatural meandering stream traversing the Shoalhaven floodplain. Meander cut-offs wereidentified in the stream network, indicating significant entrainment and depositionassociated with relatively frequent flood events (approximately twice a year) over aprolonged period of time. Due to the low lying nature of the landscape, some meandercut-off currently exhibit characteristics normally associated with saline wetlands.Abernethy’s Creek has been significantly modified in the past as a flood mitigationmeasure and in more recent years to increase the angle and promote rapid stream flowfrom Shoalhaven Council’s waste water treatment plant to Shoalhaven River. The creekhas been channelled and straightened, and periodically dredged. Council recentlyauthorised the removal of a section of riparian vegetation to access the creek and carryout dredging operations. Consequently, the bank has been undercut along the watersurface due to the lack of a binding root structure.Soil ProfilesThe Shoalhaven floodplain is characterised by a complex soil pattern as a result ofnatural scouring and alluvial deposition. Alluvium consists of gravel, sand, silt and clayderived mainly from sandstone and shale overlying buried estuarine sediments(Hazelton, 1993).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 250
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryDominant soil materials include fine sandy loam to sandy loam and fine sandy clay tosandy clay in topsoil, over sandy clay and light to medium clay to heavy clay. Soilmaterial deposition sequences include levees and lower terraces up to 100 cm in depth,upper terraces up to 150 cm in depth, and point bar alluvial deposition up to 100 cm.Shoalhaven RiverAlluvium consisting of grey fine to medium clayey gravel with medium plasticity andtraces of fine grained sand, over brown-red silty sandy clay. Soils were wet and waterinflow was reached at 0.45 m.Bomaderry CreekAlluvium consisting of dark brown silty clay of medium plasticity with traces of rootlets,decreasing in plasticity at 0.7 m and turning to orange and brown mottled silty clay ofhigh plasticity at 3.3 m. Soil moisture was low in the upper profile, reaching plastic limitat 3.3 m.Abernethy’s CreekAlluvium consisting of fine to course grained sand with traces of medium grain gravel(reworked topsoil), over silty sand to 1.5 m. The B horizon consists of clayey silt with lowto medium plasticity, with traces of rootlets and an odour of sulphur at 2.2 m, and holesfor bio-turbation at 3 m. Soil moisture increased with depth with water inflow at 2.2 mand plastic limit was reached at 3 m.Geomorphological DiscontinuitiesNatural geomorphic processes in the Shoalhaven floodplain have been influenced byhuman settlement and activities since settlement. The floodplain and estuary hasnumber of urban settlements, including Nowra. Human activities include agriculture(primarily dairy farming), tourism, defence, and industry. Given the nature of land use onthe floodplain there are numerous geomorphic discontinues affecting stream flow andgeomorphic processes, water quality, aquatic ecosystems and riparian health.7.9.2 Existing Riparian HealthVegetationMuch of the remnant vegetation on the site had been removed prior to the developmentof the factory and environmental farm to make way for agriculture, particularly dairyfarming. It is most likely that the site was previously covered by at least two vegetationformations: Forested Wetlands and Saline Wetlands. The vegetation classes for theseCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 251
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryformations would have been Coastal Swamp Forest and Mangrove Swampsrespectively.Buffer zonesHealthy, vegetated riparian habitat is essential to the natural ecological functioning ofassociated watercourses. Riparian and riverine ecosystems function in an integratedfashion, whereby impoundment, channelisation and diversion of a watercourse mayinfluence the hydrological qualities of the riparian ecosystem and bank stability.Similarly, impacts to the riparian ecosystem such as vegetation clearing and stockgrazing can cause erosion of stream banks and enlargement of channels, thusinfluencing the functionality of the riverine ecosystem (National Research Council, 1992).A key factor in conserving the integrated functionality of riparian and riverine ecosystemsinvolves maintaining, or establishing, a healthy and adequate vegetated corridor.Guidelines for riparian corridors in NSW have been developed under the WMA Act 2000and are dependent on stream order classification (refer Sections 6.3.7 and 6.3.8).As part of the DG’s Requirements, DWE classified the watercourses that are adjacent to,or traversing the Shoalhaven Starches factory site and environmental farm and providedrecommended CRZ and vegetated buffers, outlined in Table 29.Table 29Watercourse classification and recommended buffer zonesWatercourseCategoryRecommendedCRZRecommendedVegetation BufferShoalhaven River Category 1 40 m 10 mBomaderry Creek Category 1 40 m 10 mBroughton Creek Category 1 40 m 10 mAbernethy’s Creek Category 2 20 m 10 mThe existing riparian buffers were calculated by Coffey Environments from satelliteimagery. Distances were taken at approximate 100 m intervals or where significantchanges were apparent. The results are provided in Table 30 and are indicative of thewidth of the canopy of the riparian zone only and not understorey cover. Vegetationhealth including structural and floristic diversity, tree maturity and weediness wasassessed during the site visit and is discussed in detail in the following section.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 252
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryWatercourseShoalhavenRiverBomaderryCreekCategoryTable 30Existing Riparian VegetationSpan ofriverbank(m)*Max.width(m)Min.width(m)Averagewidth(m)Span ofriparian veg. ≥recommendedCRZ (m)Category 1 920 91 0 32 98.4Category 1 509 91 11 33 72.5Broughton Creek Category 1 3600 70 0 19 312.6Abernethy’sCreekCategory 2 425 3 0 − 0* Total distance (m) of riverbank that is adjacent to or traversing the site.The existing core riparian zones and vegetated buffers for all the above watercourses donot meet the recommendations provided by DWE along the majority length of eachriverbank.Vegetation conditionShoalhaven RiverThe vegetation fronting Shoalhaven River to the confluence with Abernethy’s drainconsists of a number of mature remnant trees such as Eucalyptus botryoides andCasuarina glauca. Further downstream, the bank and upper bank is dominated byopportunistic colonisers, primarily coral trees Erythrina x sykesii that have establishedover the past 20 - 50 years. Three areas were devoid of a canopy: the outside bankedge at the mouth of Bomaderry Creek, the area near the No. 1 DDG Dryer, and theengineered rock wall. <strong>Manildra</strong> <strong>Group</strong> has revegetated the riparian zone around thecooling towers with overstorey species, although no understorey enhancementmeasures have been undertaken.Overall canopy demonstrated low floristic diversity and poor canopy structure along theriver frontage. The canopy above 10 m consisted of a few mature native trees along theupper bank between the confluence of Bomaderry Creek and Abernethy’s Creek. Thesetrees accounted for ~ 5% of foliage projective cover (FPC) along the riparian zone. Alow shrubby canopy (3 - 5m) was present behind the bank edge consisting of Blackwattle Acacia mernsii and Casuarina glauca, with some revegetated areas adjacent tothe cooling towers. The shrubby canopy accounts for 95% FPC, while the revegetatedarea possibly accounts for 15% FPC.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 253
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe midstorey was either absent or dominated by exotic species, particularly Lantanacamara.The groundlayer ranged from 100% to less than 5% cover depending on the overlyingcanopy composition. Along the river bank, exotic pasture species dominated, whereasunder the denser shrubby canopy the groundlayer was generally absent. In the areasthat had been revegetated the groundlayer consisted of exotic pasture species.Mature remnant trees along the River frontage were generally confined to the westernsection and ranged in age between 30 - 70 years. No significant hollows were detectedduring the site walkover. The remaining vegetation (shrubby canopy) appeared to bebetween 7-15 years old. No seedlings of canopy species were located indicatingminimal natural recruitment is occurring.The lower stratums have been subject to significant weed infestation with up to 20% ofthe midstorey and groundlayer consisting of exotic species.Bomaderry CreekA number of mature remnant trees were recorded along Bomaderry Creek to theconfluence with the Shoalhaven River. The lower stratums fronting Bomaderry Creek ishighly modified and has significant weed infestation. Lantana dominated the midstoreyand groundlayer space with up to 100% FPC in some areas. Access to the riverfrontage was restricted due to the thick weedy midstorey layer.The mature canopy trees greater than 10 m were evenly spaced or clumped along theupper bank edge. These trees accounted for ~20-25% FPC. A low shrubby canopy(3 - 5m) was present behind the bank edge which accounted for ~ 95% of FPC where itwas encountered. Overall the upper and lower canopy demonstrated moderate floristicdiversity and poor to moderate canopy structure.The midstorey was lacking in native species due to densely growing weed speciesincluding Lantana, African Boxthorn Lycium ferocissimum, Blackberry Rubus fruticosus,Asparagus asparagoides, Large Leaf Privet Ligstrum lucidum and Small Leaf PrivetLigstrum sinense. In several areas Lantana made up 100% FPC, while in others otherweeds competed for midstorey and groundlayer space.The groundlayer ranged from < 5% to 100% cover depending on the overlying canopycomposition. Along the riverbank, weed species dominated, whereas under the denseshrubby canopy the groundlayer was generally absent. The groundlayer in areas alongthe steep embankment, which possessed of a moderately natural canopy, consisted ofCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 254
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry~ 30% bare soil and 30 - 50% FPC by weed species. A few native species werepresent, however, overall native floristic diversity was considered poor.The remnant mature trees were generally ~ 30 - 70 years old. No significant hollowswere detected. The lower stratums appeared to be between 7 - 15 years. Seedlings ofnative species were located indicating some unassisted regeneration of the canopy wasoccurring.Abernethy’s CreekThe riparian area fronting Abernethy’s Creek has been either cleared of vegetation orhighly modified by human activities and/or weed infestation. The central portion islandscaped using non-indigenous native tree species. The southern portion hasundergone recent attempts to revegetate with endemic species with partial success.The northern portion on Shoalhaven Starches property has recently been cleared byShoalhaven City Council in order to dredge the streambed and relieve upstreamflooding. Revegetation has not been undertaken and natural recruitment has thus farbeen dominated by weed species.No mature remnant trees or shrubby canopy species were recorded along the creek line.The midstorey structure was very poor and limited to some low shrubby weed species(Lantana) and previously planted native trees such as Casuarinas in competition.Floristic diversity of native flora was very low with weed species outcompeting nativespecies, particularly in the southern section where exotic climbers were stranglingplanted trees.The groundlayer was dominated by exotic perennial shrubs and vines or exposed earth.Broughton CreekThe majority of riparian vegetation along Broughton Creek has been previously clearedfor pastoral agriculture and dairy farming. A thin discontinuous edge of riparianvegetation remains. This edge exhibits a patchy distribution of Saline Wetlandsformation (Mangrove Swamp) which is listed under SEPP No.14 Coastal Wetlands, withminor saltmarsh components. There were also some remnant Forested Wetland(Coastal Swamp Forest) components which at times were contiguous with otherremnants. Riparian works undertaken by <strong>Manildra</strong> included the establishment of a ‘hot’wire to fenceout stock located with the area, minor planting to promote mangrove(Avicennia marina) establishment and stabilise eroding banks.The canopy on the upper bank greater than 10 m in height consisted of mature isolatedor stands of Eucalypts, providing < 5% to 30 - 40% FPC. There were also discontinuousCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 255
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrystretches of mangrove swamp along the lower stream bank. These lower areas weredominated by mangrove canopy which accounted for ~ 50 - 65% FPC. Floristic diversitywas high in areas where a canopy existed. In comparison, diversity on exposed banksthat were actively eroding was found to be very poor.The midstorey was dependent on the depth of transect which varied considerably alongthe creek frontage (0 - 70m). Those areas were the depth of riparian vegetation wasequal or greater than 10 m displayed moderate to high structural and floristic diversity.Areas possessing only single trees or small clumps along actively eroding banksdisplayed little or no native midstorey development, with occasional low shrubby weedspresent. A few shrubby weed species were encountered in areas of mature trees on theupper bank. Areas of relatively diverse vegetation had been invaded by exotic climberswhich appeared to be increasing in numbers.Large areas along the creek frontage were dominated by the exotic pastoral perennialKikuyu grass Pennisetum clandestinum up to 1 m in height. In areas with good canopystructure, the groundlayer consisted of clumping perennials, low shrubs andherbaceous/grassy species. These areas were considered to have relatively highstructural and floristic diversity, important representative components of MangroveSwamp and Coastal Floodplain Wetland communities. Exposed earth was evident inareas undergoing period inundation, and on the face of eroding banks.The canopy species consisted of a few E. botryoides and E. botryoides x salinga,although the presence of seedlings indicated natural recruitment of casuarinasmangroves only. Similarly, mature specimens of Melaleuca stypheliodes andM. linariifolia were identified without any indications of recently recruited seedlings. Thisis most likely a result of the dominate Kikuyu grass on most areas of the upperembankment.Bank StabilityThe major cause of erosion occurring on site is from fluvial scour, a natural geomorphicprocess within an active floodplain. Fluvial scour on site has been amplified by the lackof healthy, diverse and contiguous riparian vegetation along the foreshore of eachwaterway. Bank stability is also influenced by surface gradients, soil type, and surfacedrainage characteristics of the factory facilities.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 256
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryShoalhaven RiverThe bank of the River adjacent to the factory has a known history of recession. Thefactory is located on the terraced bank of Shoalhaven River and is therefore subject tonatural scouring and channel expansion.A recent bank collapse occurred along a small section of the River adjacent to No. 1DDG Dryer. Given the proximity of the bank to the factory, immediate engineeringremediation was carried out. A stepped rock wall was constructed to breach the recededarea. Vegetative cover on the bank behind the wall is dominated by Kikuyu grass, whichwould limit the successful establishment of native species.The riparian zone between Abernethy’s Creek outflow and the eastern boundary of theproperty ranges from between 1 – 3 m from the top of the bank and is dominated bymature Coral trees. Sections of the foreshore dominated by Coral trees are of particularconcern for bank erosion and failure, especially as the distance between the river andthe factory is minimal.Evidence of further bank erosion was recorded near the Slurry Plant and GrainProcessing Plant. In both areas a small section of the upper bank had ‘sunk’ or ‘blownout’ within 1 – 2 m of the edge. Tensile cracking on the upper bank was evident near thenew rock wall. It is likely the bank directly behind the rock wall is now stable. Howeverthe bank on either side is prone to recession due to the lack of binding deep rootedvegetative cover and the eddying effect created by the wall.The foreshore of Shoalhaven River between the convergences of Bomaderry Creek andAbernethy’s Creek has less weed infestation and greater floristic and structural diversity,with small stands of mature Eucalypts. Nevertheless, evidence of bank erosion in theform of undercutting and slumping was recorded, particularly in areas where diverseunderstorey and groundcover species were absent and the bank is exposed.Surface runoff from the flat area where the proposed new facilities were beingassembled has resulted in shallow gully erosion (1 cm deep by 2 – 3 m wide) in the areaadjacent to the proposed new cooling tower. Evidence suggests the surface runoff iscutting back into the riparian bank. At present this is minor however it has the potentialto increase over time.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 257
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryBomaderry CreekThe majority of the upper bank of Bomaderry Creek is dominated by dense thickets ofimpenetrable Lantana. A number of mature casuarinas and acacias were present on thebank down to the waters edge. The understorey and groundlayer, where present, wasdominated by weed species including Lantana, Kikuyu grass and African Boxthorn.Evidence on a previously felled tree indicates bank undercutting and scouring may beoccurring on the lee side of each meander.Further downstream near the convergence with Shoalhaven River, the riparian zonebecomes more open. Near the mouth of the Creek, Kikuyu Grass dominates and thereis little overstorey. A ‘sandy’ edge has developed on the eastern side of BomaderryCreek where it meets Shoalhaven River, indicating sediment deposition is occurring.Notwithstanding, tensile cracking near the bank edge was recorded in this area. Furthercracking is likely given the lack of vegetative cover and exposure to the mechanics ofwetting and drying, particularly during flood events.A surface water outflow was identified in the area near the electrical easement, north ofthe proposed gas-fired co-generator. This area receives runoff from the western plantand showed evidence of sediment trapping using emplacement of hay bales. Underheavy rainfall, this area may be prone to minor surface erosion.Abernethy’s CreekThe riparian zone of Abernethy’s Creek is in very poor condition. The upper section,directly downstream of the Council operated waste water treatment plant was recentlydredged to minimise upstream flooding. Undercutting of the bank has occurred to amuch greater extent than the eastern side of the creek.The central section of the Creek is dominated by weed species, where present, withlarge patches of exposed earth along both sides of the bank. Medium sized rocks havebeen placed along the waters edge to minimise erosion with some success. Some bankhardening has been undertaken around the footings of the footbridges that have beenconstructed. These footings have provided opportunity for deposition of sediment anddebris carried downstream during high flows and flood events. Further, eddyingupstream of these deposits has been causing minor channel expansion.The lower section of Abernethy’s Creek is funnelled into a drain discharging intoShoalhaven River. The bank has a high diversity of introduced species with areas ofthick weedy undergrowth that limited access to the bank edge.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 258
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryBroughton CreekSeveral areas have been identified where erosion and bank failure had occurred. Areasof failure were generally consistent with riparian zones lacking structural and floristicdiversity, and occurred on the long edge of the meander bend. The major cause oferosion and bank failure is from fluvial scour, a natural geomorphic process within anactive floodplain that has been amplified by the lack of healthy, diverse and contiguousriparian vegetation along the foreshore of Broughton Creek.The unfenced Creek frontage is utilised for high ground grazing during flood events,approximately twice a year. This area has very little riparian vegetation with a fewjuvenile eucalypts and casuarinas, no understorey species and a groundlayer dominatedby Kikuyu grass, which is periodically slashed. Tensile cracking was common and onesection of the bank had recently slumped. Furthermore, several young trees had beenundercut and collapsed into the Creek.Further upstream, within the fenced area, a large Eucalypt had been undercut, fallinginto the creek. The riparian zone in this area was limited to a few mature trees,scattered shrubs and extensive covering of Kikuyu grass. The undercut tree waspositioned on the pinnacle of the meander bend. The exposed root system was boundwith clayey soil and water was observed in the resultant space, indicating reduced shearresistant due to an unstable saturated clay horizon as the precursor to tree collapse.Soil slumping was also recorded where the fence traverses the ‘point’ of a sharpmeander. Although one side of this area is well vegetation with many mature trees andgood floristic diversity in the lower stratums, the other side is dominated by Kikuyu grasswith the occasional mature tree. Slashing does not occur and Kikuyu grass is approx1 m high. Evidence suggests the lower bank may be prone to undercutting due to thelack of binding root system, exposed earth and the position of the meander.A surface drainage channel was identified at the closet point between Pivot No. 7 andBroughton Creek. Pivot No. 7 is enclosed by a swale approximately 0.3 - 0.5 m inheight, forcing irrigated water to infiltrate the surface. As such the drainage channel isonly likely to flow into Broughton Creek during periods of heavy and prolonged rainfalland flood events. Conversely, its presence may allow saltwater to intrude into the upperriparian zone. This exposed drain may be prone to erosive processes and salinisation.Areas of deposition along Broughton Creek adjacent to the Environmental Farm wereidentified as point bars on two major meanders. The outside bank edge of these pointbars are known areas of bank recession and failure due to the superelevated waterCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 259
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrysurface as the water channels around the meander. Given that Broughton Creektraverses the Shoalhaven floodplain for approximately 5 km before discharging intoShoalhaven River it is likely that further deposition occurs downstream in areas notincluded in the site investigation.Compliance with RCMS GuidelinesThe Department of Water and Energy (DWE) undertook a desktop review andcategorised all four waterways onsite in relation to RCMS Guidelines, as follows:Shoalhaven River Category 1 watercourseBomaderry Creek Category 1 watercourseBroughton Creek Category 1 watercourseAbernethy’s Creek Category 2 watercourseThe eastern section of Shoalhaven River and Abernethy’s Creek do not have theappropriate setbacks from the factory facilities and it is unlikely that an appropriateriparian zone can be established.The western section of Shoalhaven River and the lower section of Bomaderry Creek dohave appropriate setbacks and revegetation / enhancement works may help accordingto Coffey Environments improve the existing riparian vegetation.The riparian zone along Broughton Creek does, in a few places, meet the 40 m CRZrequirement and 10 m buffer zone. The existing riparian vegetation is not contiguousand quality varies significantly. Notwithstanding, adequate setbacks are availableaccording to Coffey Environments along the length of the Creek frontage.7.9.3 Potential ImpactsRiparian zoneThe proposed expansion is likely to involve the removal of vegetation where theproposed gas-fired co-generator has been sighted, which abuts the area zoned 7(f3).The approximate area of vegetation that would be removed would result in the loss of adense thicket of Black wattle. This thicket is nearing the end of its lifecycle and is slowlybeing invaded be Lantana. No other proposed facilities on the factory site have beensighted within the riparian zones and it is unlikely that any further removal of vegetationwill occur for the construction and/or operation of these facilities.None of the proposed new facilities are located within the vicinity of Broughton Creek.Consequently, further vegetation clearance along the frontage of Broughton Creek isCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 260
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryunlikely. The remaining riparian vegetation has been ‘hot’ wired for protection primarilyagainst stock grazing.Given the prevalence of weed species in the riparian zones of each waterway, there is ahigh likelihood that weed infestations will increase in intensity and spread to new areas.However, it is unlikely that the proposed new facilities will be a contributing factor. Weedinfestations are limited by dispersal rates and current site presence. The potential forfurther incursions along the foreshore of Bomaderry Creek and Shoalhaven River frommature seed producing noxious weeds is high unless control measures areimplemented.On the Environmental Farm the potential for weed species to recruit and establish islimited due to the extent and density of Kikuyu grass along the foreshore. There is thepotential for minor invasions of mature lantana, African Boxthorn and Privet in morefloristic and structurally diverse areas.Water quality on the farm may be an issue that adversely impacts on ecosystem healthin riparian zones. The proposed aerobic / anaerobic pond system will improve thequality and reduce the volume of wastewater to be irrigated into the Pivot No. 7.Wastewater will be treated to a higher level and become available for reuse in thefactory. As a result the volume and quality of water infiltrating Pivot No. 7 and flowing viasubsurface pathways into Broughton Creek should improve and is therefore not likely tofurther impact on riparian health.Bank StabilityThe proposed expansion is unlikely to impact further on bank stability within the Factorysite and Environmental Farm.According to Coffey Environments bank recession and failure was predominately a resultof fluvial scour and was most prominent in areas impacted by fast flow direction changesand with reduced riparian health. The proposed new facilities will not influence thesefluvial processes. Nevertheless, changes in soil moisture and engineered loads, andloss of further vegetation are all potential contributing factors to diminished bank stability.Table 31 outlines the proposed facilities within close proximity to a waterway. Given thefactory is located on an active floodplain the position of these facilities may increase theloading on the alluvial soils. The additional weight may cause the soil around thefootings to bulge, which may undermine slope stability if it occurs within close proximityof a stream bank. Further investigation will be required prior to construction of thesefacilities.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 261
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 31Proposed Facilities Close to a WaterwayProposed facility Waterway Approx. distance (m)Gas-fired co-generator Bomaderry Creek 20Chemical storage facility Abernethy’s Creek 10Dryer No. 5 Abernethy’s Creek 15The existing Stormwater Management System has the capacity to integrate with the newfacilities with the exception of the proposed packing plant, Raw-water Pipeline Routeand Pond No. 7 on the Environmental Farm (GHD, 2008). Appropriate stormwaterdrainage will be constructed for these facilities. It is therefore unlikely that the proposedfacilities will result in an increase in impervious surfaces or surface run-off, andcontribute to changing soil moisture conditions along stream banks. So long as theintegrity of bunds is maintained, stormwater collected within the factory site will becollected and diverted to either Shoalhaven River or the Environmental Farm fortreatment.The wetting and drying of soils along the banks of each waterway is therefore aconsequence of rainfall, flooding, surface run-off outside the bunds, sub-surface flows,or from pipes located outside of the bunded areas. These factors exist already and arenot likely to increase in severity as a result of the expansion.Notwithstanding, the potential for bank instability leading to failure is present undercurrent conditions as a result of fluvial scour, reduced ecosystem health and changingsoil moisture conditions.7.9.4 ConclusionWith respect to riverbank stability and riparian corridors Coffey Environments conclude:“The riparian zones of the four watercourses traversing or bordering theShoalhaven Starches site are in poor condition due to inappropriatesetbacks, weed infestation, inappropriate foreshore plantings (Coral trees),and widespread clearing. With the exception of the ‘spit’ betweenBomaderry Creek and Shoalhaven River and sections along Broughton, thevegetated riparian zones fail to meet the recommended buffer zones putforward by DWE.The onsite investigation revealed the overall condition of vegetation to bepoor with low structural and floristic diversity, and a high prevalence of weedspecies along all four watercourses. Remnant vegetation on BroughtonCreek did exhibit good ecosystem diversity in some isolated areas. SeveralCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 262
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrynoxious weeds were recorded and are expected to increase in intensity andspread without the implementation of control measures.Bank recession and failure was evident on Shoalhaven River and BroughtonCreek. Areas of recession were generally associated with fluvial scour onthe long edge of the meander and amplified by poor vegetation health andweed infestation. Slumping, undercutting and cracking was recorded,indicating further recession is likely.Given the degraded state of the riparian zones, it is unlikely that theproposed facilities will further impact on vegetation health or bank stability.Nevertheless, further investigation into engineer loads of facilities withinclose proximity of stream banks may be necessary. Furthermore, all newfacilities will need to be incorporated into the existing bunds or have newbunds constructed.Bank stability for Bomaderry, Abernethy’s and Broughton Creeks shouldimprove with the implementation of the recommendations provided in thefollowing section. Given the severity of fluvial scour occurring alongShoalhaven River, revegetation and enhancement is unlikely to preventfurther failures, although it may slow the rate of recession.7.9.5 RecommendationsThe major cause of erosion occurring on site is from fluvial scour, a natural geomorphicprocess within an active floodplain that has been amplified by the lack of healthy, diverseand contiguous riparian vegetation along the foreshore of each waterway. According toCoffeys it is unlikely that major revegetation works within the riparian zone will arrestbank recession occurring as a result of fluvial scour. However, increasing groundcoverand promoting binding root growth as close to the toe of the bank as close as possiblemay slow the rate of bank recession. The success of revegetation as a means ofstabilising areas prone to recession is dependant on the physiological ability of plantspecies to bind the soil. Most large trees have a root system reaching up to 3 m in depthand a lateral extension similar to the width of the crown.The following are specific recommendations made by Coffey Environments. ShoalhavenStarches commit to implementing these recommendations.Shoalhaven RiverThe bank of Shoalhaven River ranges between 2 - 5m with steep slopes due tocontinuous fluvial scour.The eastern section of the foreshore does not have anappropriate setback and is dominated by Coral trees and other weeds which furtherundermine bank stability. The effectiveness of revegetation works on the top of the bankwill be limited by bank height as the root system of mature trees is unlikely to reach thewatertable.The slope, changing flow direction and weed infestation will limit theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 263
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryeffectiveness of revegetation works on the bank. Given the limitations, recommendedactions for Shoalhaven River include:• Planting fast growing native species at the top of the bank to slowsurface erosion and allow time for the establishment of slower, deeprooted trees which will act to protect the bank, in part, in the future.• Planting deep native rooted trees behind the bank along the westernsection (between Bomaderry and Abernethy’s Creek) and enhancementof understorey and groundcover species, with particular focus on knownareas of erosion.Bomaderry CreekBank stability along the frontage of the southern section is undermined by poor structuraland floristic diversity, areas of exposed earth and weed infestation. The bank rangesfrom 1 – 3 m above the water surface and a number of large mature trees wererecorded, indicating the presence of a binding root system potentially reaching the watertable. Enhancement measures to improve riparian health and bank stability, particularlyin the southern section, include:• Planting mangroves on the lower bank and sandy sediments at themean high water mark.• Revegetation of the mid and upper bank with native species inconjunction with weed control measures (discussed below).Abernethy’s CreekThe riparian zone of Abernethy’s Creek is highly degraded due to weed infestation andlack of an appropriate setback from the factory. Bank stability in the upper section hasbeen undermined by the removal of vegetation and bank erosion along the waterlinewas evident. Tree planting along Abernethy’s Creek is problematic due to the lack ofspace and high modification associated with the factory, and prevalence of weeds.Enhancement measures to improve bank stability and riparian health include:• Planting of canopy species at approx 5 – 10 m intervals along the top ofthe bank, where possible.• Weed suppression until canopy species are of sufficient size to ‘shadeout’ weed species.• Weed control measures to prevent further infestation (complete removalwill most likely reduce bank stability in the short to mid term).• Revegetation of the western side of the creek, north of Bolong Rd, withnative canopy, midstorey and groundlayer species.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 264
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Effective dialogue will be required to reach an agreement withShoalhaven City Council regarding ongoing access for dredgingactivities.Broughton CreekSections of Broughton Creek have been subject to bank scour due to superelevatedwater level and flow associated with the outside edge of meanders, and further amplifiedby poor structural and floristic diversity. Unfortunately previous enhancement trails usingmangroves have not been successful due to bank failure and burial of seedlings. Bankheight is estimated at average between 2 – 3 m with an almost vertical slope. Significantareas are covered with dense Kikuyu grass, which is likely to out-compete new plantingswith continued maintenance. Enhancement measures to slow ongoing erosion leadingto bank stabilisation include:• Planting fast growing native shrub species along the bank and canopyspecies behind the bank in areas prone to bank failure.• Spot controlling Kikuyu grass to provide adequate space for nativespecies to grow.• Widespread spraying of Kikuyu is not recommended as it would reducethe cover and bank stabilisation provided by this species.Weed ManagementExtensive weed infestations were identified along all of the waterways bordering ortraversing through the property including a number of noxious weeds listed under class 4and 5 of the Shoalhaven Local Government Area. Plans of Management for the controland eradication of class 4 weeds have been published by Council, and detail thefollowing actions:• Constant suppression of African Boxthorn and Blackberry.• Suppression and removal of Large Leaf Privet and Small Leaf Privetfrom urban areas.• Further clarification for privet identified onsite may be required to thezonings of 4(a) General Industrial and 7(f3) Environmental ProtectionForeshores.• Removal of Lantana where it supports local Council and Volunteersefforts.The removal of African Boxthorn and Blackberry will be most effectively achieved by‘spot’ spraying using appropriately registered herbicide due to the low number ofindividuals sighted throughout the sight. The species was most prevalent in the riparianCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 265
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryarea of Bomaderry Creek. Ongoing monitoring will be required to ensure controlmeasures are effective and weed species have not re-established.Significant areas of lantana were identified onsite, with dense thickets recorded adjacentto Bomaderry Creek and in a number of locations along Broughton Creek. It isrecommended that some patches are removed to improve overall ecosystem health andallow the re-establishment of midstorey and groundcover species. Removal of Lantanashould be conducted in conjunction with understorey replanting and enhancement.Lantana is shallow rooted and unlikely to contribute greatly to bank stability. Theremoval of Lantana from bank edges and slopes should allow deeper rooted nativespecies the opportunity to establish and improve bank stability. Lantana is easilyremoved by cutting and mulching back into the ground. This method will provide somesoil protection following weed removal to reduce both erosion and further weedinfestation.Stock ExclusionStock currently graze a small section of foreshore along Broughton Creek during floodevents (approx twice a year). Current grazing distances range between 5 to ~ 15 m fromthe mean high water mark. It is recommended that a stock exclusion zone beestablished from the top of the bank to a minimum 15 m. This would provide sufficientarea for the development of a sacrificial fast growing edge and longer termestablishment of larger canopy species for long term bank stabilisation. In areas where15 m exclusion is not possible, a small riparian zone should be established behind thebank to avoid browsing and trampling of newly planted species.Vegetation Management PlanA vegetation management plan (VMP) for the factory site and environmental farm shouldbe developed to ensure riparian areas are managed appropriately and in accordancewith strategic objectives. The VMP should outline management zones and establishguidelines riparian management, focusing on the required actions to carryout the aboverecommendations. In addition, the VMP should incorporate site specific measuresrelating to personnel access, weed management, incident management, ASS, surfacedrainage and erosion controls.7.10 FLOODINGThe site is located on the northern bank of the Shoalhaven River adjacent to Abernethy’sCreek and on the southern side of Bolong Road. The site is within the 1% AnnualExceedance Probability (AEP) floodplain of the Shoalhaven River as defined in theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 266
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryLower Shoalhaven River Flood Study (April, 1990) which was prepared by Webb,McKeown & Associates (WM) for Public Works.During major rainfall events, runoff from the Shoalhaven River catchment enters the sitefrom the south and from the Bomaderry Creek catchment to the west. Once the banksof the Shoalhaven River and Bomaderry Creek are overtopped, floodwaters pass overthe site, between the existing plant and associated buildings and towards Bolong Road.Once Bolong is overtopped, floodwaters continue north, spreading out over the low-lyingfloodplain. Ultimately the floodwaters return back to the Shoalhaven River furtherdownstream of the site. The northern floodplain is also inundated from local catchmentrunoff directly entering the floodplain. The main contributor is Broughton Creek.The largest floods in recent times have been in August 1974, June 1975, March 1978and April 1988. These events would all have overtopped the river bank (in parts) andcaused overbank inundation. Of the four, the largest was March 1978 which reachedapproximately 5.0 m AHD near the site.In addition to the existing plant and associated buildings at the subject site, otherdevelopment is evident on the Shoalhaven River floodplain in the vicinity. This includesa concrete batching plant (Cleary Bros), a paper mill, the Dairy Farmers complex (nowclosed), the 5 wet weather storage ponds opposite the paper mill, and on the opposite(southern) river bank, the Riverview Road and Terara village flood protection levees.These developments on the floodplain have resulted in a reduction in the available flowarea and floodplain storage capacity during a major flood event.Webb McKeown & Associates have been engaged by Shoalhaven Starches toinvestigate the likely hydraulic, economic, social and environmental impact of flooding asa result of the proposed expansion. Webb McKeown & Associates report formsAnnexure K to this EA. This section of the EA is based upon the findings of thisassessment.7.10.1 Hydraulic ImpactsThe potential impacts of works within the floodplain on hydraulic characteristics aretwofold – firstly a loss of temporary floodplain storage volume and secondly a loss of flowarea. It is the loss of flow area which produces the greatest impact, as the area offloodplain storage lost due to all works since 1990, represents approximately less than1% of the total available floodplain storage area for the northern floodplain (say 3000+hectares).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 267
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe hydraulic assessment undertaken by Webb McKeown & Associates using the CELLModel established for the 1990 Lower Shoalhaven River Flood Study, prepared forPublic Works in April 1990 by Webb McKeown. Whilst more sophisticated computerprograms are now available the CELL Model is the most up to date hydraulic model ofthe Lower Shoalhaven River floodplain available and is capable of assessing the twoimpacts on hydraulic characteristics outlined above.The CELL Model was run for the Extreme, 1%, 2% and 5% AEP (Annual ExceedanceProbability) design events for three scenarios:• Existing conditions as at 1990.• Current development conditions, assumed to be Stage 2 Works plus construction ofPond No. 6 (already constructed), Pond No. 7 (under construction) and theproposed works at the plant outside the agreed envelope as part of the October2002 report.• Proposed development conditions as above PLUS the ethanol upgrade and odourreduction works proposed in 2008 (Figure 5).Hydraulic ImpactsHydraulic impacts can be subdivided into the following categories:• increase in water level,• increase in frequency of inundation,• increase in duration of flooding,• increase in extent of inundation at the perimeter of the floodplain,• increase in velocity of floodwaters across the floodplain.Increase in Water LevelAn increase in water level is probably the most obvious effect of works upon thefloodplain. A summary of design flood levels (1990 conditions) is provided in Table 32together with the cumulative impacts of all construction works since 1990, plus theproposed upgrade associated with this proposal.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 268
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryLocationShoalhaven StarchesPlant (Cell 26)Table 32Design Flood LevelsDesign Flood Level (mAHD)Relative Impact5% AEP 2% AEP 1% AEP Extreme4.2(0.11)Dairy Farmers (Cell 29) 3.8*Paper Mill (Cell 57) 3.8*Rural Area North ofBolong RoadNorth of Bolong Road andWest of ShoalhavenStarches Plant (Cell 4)South of Bolong Roadand West of ShoalhavenStarches Plant (Cell 18)3.8*3.8(0.04)5.0(0.02)4.8(0.10)4.5(0.02)4.5(0.02)4.5*4.6*5.4(0.03)5.3(0.07)5.1(0.04)5.0(0.05)5.0(0.04)5.0(0.03)5.8(0.04)7.3(0.08)7.2(0.07)7.2(0.08)7.1(0.10)7.2(0.08)7.8(0.08)Notes: The values in brackets represent the cumulative flood impacts (as indicated on Figures 8a, b, c &d) of works undertaken since 1990 (including all seven ponds and the proposed ethanol plant upgrade andodour reduction works).* indicates that the impact is equal to or less than ±0.01m.Small differences between the flood impacts indicated above and those published in previous reports byWebb McKeown may be evident due to slight changes in the hydraulic model structure and how the pondsand other works are represented.Figures 30 to 33 indicate the cumulative differences in flood level of all works on thefloodplain since 1990 (Stage 2 works, all ponds, as well as the proposed ethanol plantupgrade and odour reduction works). It is apparent that the proposed ethanol plantupgrade and odour reduction works will only marginally increase design flood levels(differences shown in boxes on Figures 30 to 33).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 269
Figure 30: All works since 1990 Extreme Flood.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 270
Figure 31: All Works Since 1990 1% AEP Flood.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 271
Figure 32: All works since 1990 2% AEP Flood.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 272
Figure 33: All works since 1990 5% AEP FloodCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 273
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe main impact of increasing flood levels is a greater depth of inundation of residentialand commercial/industrial floor levels.As part of the present study additional residential floor levels were obtained alongHannigans Lane and Edwards Avenue (refer Appendix B). The floor levels are:• No. 125 - 4.29 m AHD;• No. 190 - 4.15 m AHD;• No. 191 - 4.22 m AHD;• No. 219 - 3.54 m AHD;• cottage near Meadow Grove - 4.42 m AHD.According to Webb McKeown, No. 219 would be first inundated in a 5% AEP event withthe other buildings inundated in a flood between the 5% and 2% AEP event. In a 1%AEP event No. 219 would be inundated to a depth of 1.6 m and the others byapproximately 1 m. According to Webb McKeown in events up to and including the 1%AEP event the cumulative hydraulic impacts of the existing and proposed works on thefloodplain by Shoalhaven Starches have nil impact north of Edwards Avenue. Thusthese buildings are not adversely affected by the proposed works. In the Extreme eventNo. 125 could experience an increase of +0.02 m.Increase in Frequency of InundationAn increase in frequency of inundation occurs as a result of an increase in flood level.For example, a rise in flood level of 0.1 m within the 2% to 1% AEP flood range wouldrepresent an approximate 10 year increase in frequency of inundation (say from a 1 in70 year to a 1 in 60 year). This impact is of particular importance if flooding occurs morefrequently (say in less than a 5% AEP event) or has major implications such as closureof a road or factory. Bolong Road is first cut in approximately a 5% AEP event orsmaller. According to Webb McKeown however there is minimal impact in a 5% AEPevent and thus minimal increase in frequency of inundation of Bolong Road or thosebuildings first inundated in a 5% AEP event.Increase in Duration of InundationTable 33 provides an example of the increases in duration of inundation for thetransformer at the Paper Mill (floor at 4.5 m AHD). The location was chosen as itproduces the greatest cumulative increases in level.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 274
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 33Duration of Inundation for the Transformer at the Paper MillEventDuration ofinundationTransformer floor level of 4.5 m AHDIncrease in durationfollowing all workssince 1990% IncreaseExtreme Flood > 48 hours (estimate) 2 hours 4%1% AEP 16 hours ¾ hour 4%2% AEP Level just reaches4.5 m AHD5% AEP Level does not reach4.5 m AHDAccording to Wee McKeown, the results indicate that there is no significant increase inthe duration of inundation due to the cumulative effects of all works on the floodplainsince 1990.Increase in Extent of InundationThe northern floodplain is low lying land (ground levels at 2 m AHD or below) with noareas of high ground except around the perimeter. It is entirely inundated by floodwatersin say the 10% AEP event and greater. Thus any increase in flood level, caused bydevelopment, will only result in an increase in the extent of inundation around theperimeter of the floodplain. The increased area of inundation will vary between floodsand depends upon the grade of the topography at the perimeter and the length of theperimeter. A flat grade will result in a large increase in area, whilst a steep grade willresult in only a small increase.The assumed areal extent of inundation on the northern side of the Shoalhaven River issome 3000+ hectares (based upon mapping undertaken for the Draft Lower ShoalhavenFloodplain Risk Management Study).All of the works undertaken since 1990 have been located along Bolong Road and nearthe river. As the effects of development on the floodplain decreases with distance fromthe works, this means that a large part of the perimeter of the floodplain will not beaffected by an increase in flood level. Many parts of the perimeter are over eightkilometres away (near Berry) and as such will experience nil increase in flood level.Even the nearest edge of the floodplain at Bomaderry is still some two kilometres fromthe ponds which are the major contributors to an increase in flood level. For calculationCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 275
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrypurposes Webb McKeown assumed that three kilometres of perimeter will be affected inthe 1% AEP event by an increase of (say) 0.1 m (this is a conservative value with a morerealistic value of 0.03 m). Webb McKeown used Council’s Airborne Laser Scanning(ALS) data to estimate the lateral increase in flood extent (approximately 2 m) and thisindicates an areal increase of approximately 6000 m 2 .Increase in Velocity of FloodwatersComparison of velocities between different floodplain conditions is more complex thancomparison of peak levels. The main difference being that the peak flood velocity maynot necessarily occur at the same time as the peak flood height. More often than not itwill occur when floodwaters first enter an area at a time of very small flow. This velocityis generally not relevant for comparison purposes. A more appropriate velocity is thatwhich is experienced at peak flood height since, in combination with the deepestfloodwaters this is likely to represent the greatest flood hazard. Consequently theassessment has been made using peak height velocities. The CELL model provides theaverage velocity for a cross-section at peak flood height. It should be noted that localvelocities between obstructions may be higher than this average velocity.According to Webb McKeown, velocities are only available in the CELL Model at Weirsor Cross Sections. On the northern floodplain the cells are linked by Weirs and theaverage velocities were obtained at all relevant locations. The effect of the works at theplant on velocities cannot be accurately assessed using the CELL Model due to therelatively small scale of the proposed works. For this reason the study has focussed onthe area near the storage ponds.In summary according to Webb McKeown, the changes in velocity are largely confined tothe area in and around the ponds where flows have been re-directed as a result of the“barrier” caused by their construction. Elsewhere there are no significant changes invelocity.It should be noted that the majority of changes occur on land owned by ShoalhavenStarches. The main exceptions are on Bolong Road (Council owned) and on otherprivate ownerships (largely the Paper Mill). The effect of changes in velocity will havelittle impact on rural lands as it is unlikely that this will cause any increases in erosion ordamages. Along Hannigans Lane where five residential properties are located there is aslight reduction in velocity as a result of construction of the ponds.Immediately west of the Shoalhaven Starches plant there is no significant change inpeak velocity.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 276
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAccording to Webb McKeown:• Blocking of the flow path due to all the works at or near the Shoalhaven Starchesplant since 1990 have slightly increased flood levels in the immediate upstream areabut also results in less floodwaters entering the northern floodplain. This produces aslight reduction in the affectation caused by construction of the wet weather storageponds.• In the 5% AEP event (an event of similar magnitude to the March 1978 flood) thereis no increase in flood level (or consequent changes in extent of inundation etc.) asa result of the works constructed and proposed on the floodplain since 1990 at thePaper Mill or north of Bolong Road. There is an exception of + 0.11 m at theShoalhaven Starches plant itself, and + 0.02 m immediately west of the ShoalhavenStarches plant. This means that in the smaller more frequent events, up to a 5%AEP, the works on the floodplain have little impact. The main reason for this is thatthere is little flow across the northern floodplain in these events as the floodplainpredominantly acts as a flood storage area with only a small flow across the riverbank itself. In the smaller floods (up to the 5% AEP) the northern floodplain islargely filled by local catchment runoff and particularly from Broughton Creek. Inlarger events where flows breakout from the main river, the impacts become moresignificant. It should be noted that in the 5% AEP event the northern bank of theShoalhaven River is only just overtopped (at a few locations) and thus the impactsof the works on the floodplain for this event may produce anomalous results due tothe shallow depths.• In the 2% AEP event (approximately 0.7 m higher than the 5% AEP or March 1978flood) there is a maximum cumulative increase of + 0.10 m. This is confined to thearea near the Shoalhaven Starches plant with up to + 0.03 m elsewhere.• In the 1% AEP event (approximately 1.2 m higher than the 5% AEP or March 1978flood) the cumulative increases range from 0.03 m to 0.07 m within the locality of theShoalhaven Starches plant. There is no impact within the Shoalhaven River or theresidential areas to the south (Terara or Riverview Road).• Hazard is defined as the source of potential harm or a situation with a potential tocause loss. The works on the floodplain since 1990 have increased the hazard.However the extent of the increase is minor and does not add significantly to theexisting (pre 1990) high hazard (on account of the depth of inundation).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 277
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryDevelopment in a High Hazard AreaThe locations of the proposed works as part of the current proposal are primarilydetermined by the availability of land adjacent to the existing Shoalhaven Starches plant.There is no other suitable land available within the local area outside of a high hazardarea which can be used for the proposed purposes.Shoalhaven Starches has a Flood Evacuation Plan and this should ensure that theoccupants (and all other personnel at the plant) will be safely evacuated from thefloodplain prior to the flood peak arriving.7.10.2 Economic, Social and Environmental ImpactsAccording to Webb McKeown the economic impacts of the increases will vary fromproperty to property. In many cases, the buildings affected are already inundated beforeany increases in level occur. This means that the majority of flood damages havealready been incurred and any incremental increases in flood damages due to the workswill be relatively minor.The Paper Mill is inundated in a 5% AEP event (as occurred in March 1978) and theincrease in depth of inundation is only a small fraction of the total depth experienced atthe site. Some stock and equipment will be affected whilst for other fixtures there will beno increase in damages. Overall, it is considered that there will be an increase indamages, but it is likely to be only a small percentage of the total.The Dairy Farmers plant (now vacant) is raised some 1.2 m above the 1% AEP floodlevel and so will experience no inundation (or increases in flood damages) untilapproximately a 0.1 % AEP event.The frequency of closing a plant due to flooding is the greatest cost to the owners. Thetwo largest plants on the floodplain (excluding Shoalhaven Starches) are the Paper Milland Dairy Farmers. For both of these plants (and we presume Boweld) this occurs atthe 5% AEP (or a lower) level which is not affected by the cumulative increases.Social impacts according to Webb McKeown are closely tied to economic impacts butare most influenced by the occurrence of floods. Therefore once the area is evacuated(say a 5% AEP event), the social impacts do not increase significantly and are generallyunaffected by the cumulative increases.Environmental impacts associated with the increases in flood levels are negligibleaccording to Webb McKeown as there is little impact upon the duration of inundation,Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 278
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryand the increases in level represent only a very small percentage increase in overalldepth of flooding.Future DevelopmentThe effects of the impacts must also be considered in light of the possible future uses ofthe land. As far as one can foreshadow at this time, the majority of the northernfloodplain will remain as rural land as there is little opportunity for non flood compatibledevelopment due to the considerable depths of inundation and flood hazard. For theseareas the impacts on future users will be nil.There will undoubtedly be some further expansion or redevelopment within the existingthree major plants in the future, and the increases in flood levels due to the works mayrequire equipment or floors to be set at a higher level, assuming that the owners wishedto construct above a certain AEP. This might involve some additional expense(additional fill) to achieve this objective, but it is unlikely to be significant and in manycases (raising electrics) there will be no real increase.Climate ChangeWhilst not an issue raised in the formal Director-General’s Requirements for this projectit is noted that concern has been raised that any flooding assessment should also becognisant of the future potential for climate change. Such an assessment requiresfurther detailed modelling which Shoalhaven Starches undertakes to have prepared priorto the completion of the exhibition of this EA. Such an assessment will be undertaken inaccordance with the DECC “Floodplain Risk Management Guidelines – PracticalConsideration of Climate Change”.7.10.3 Mitigation MeasuresAccording to Webb McKeown the hydraulic impacts of the proposed ethanol upgradeand odour reduction works (increase in flood level, change in velocity or flow) cannot benegated by any sustainable means but the consequences of the impacts can beminimised.Flood management measures such as dredging the Shoalhaven River to increase thechannel’s capacity have been considered, but these are not environmentally suitable,socially acceptable or economically viable to negate or reduce the increases in floodlevels. Direct mitigation of economic damages through levees or flood proofing ofbuildings is also not viable. The main difficulty with levees lies in maintainingaccessibility to the buildings or area as well as internal drainage within the leveed areaand possible adverse hydraulic impacts elsewhere.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 279
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryProperty or response management are the most appropriate measures for addressingthe associated environmental, economic and social effects of the cumulative floodimpacts. The following provides a summary of possible mitigation measures.Modify the Proposed Design or Relocate the WorksProposed New Packing Plant and Container Loading Area – including Railway Spur LineThe packing plant and container loading area is located within a flood storage areawhich will have minimal restriction on flow paths. It is bounded to the west by highground, to the north by Council’s sewage plant and to the south by properties alongBolong Road. As far as possible the works are located away from Abernethy’s Drain.It is not possible to relocate or re-design the layout to further minimise the hydraulicimpact as these works must be close to the existing rail line.In conclusion the size, shape and general dimensions of the works have been designedto provide minimal hydraulic impact, whilst at the same time recognising the necessarysite requirements (adjacent to the rail line).Works at the PlantThe proposed new equipment is necessary for the continued growth of the plant. Due tosite constraints, it is not possible to alter the locations and designs to any significantextent in order to minimise the hydraulic impacts.Improve Flood Warning SystemThe Shoalhaven River has an ALERT flood warning system which is operated byCouncil and the Bureau of Meteorology. Discussions with the Paper Mill management(and indicated in their Emergency Flood Policy document) have confirmed theimportance of flood warning in reducing flood damages (move product, raise pumps). Ifthe flood warning system was improved (as proposed in the Riverview Road FloodplainManagement Plan) this would provide a benefit to all floodplain users. In doing so thisaction may reduce the potential increases in economic damages at the Paper Mill andelsewhere resulting from the increases in flood levels.There are a variety of ways of improving the ALERT system and these are documentedin the Riverview Road Floodplain Management Study and Plan. These measures wouldalso provide benefit to all other floodplain users.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 280
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryProvide or Improve Flood Emergency PlansAs noted previously, the Paper Mill already has an Emergency Plan. In discussions withthe management of the Paper Mill in 2001 it was apparent that improvements could bemade which may further reduce potential damages.The main improvement could be achieved by a re-examination of the workings of theplant and updating of the Emergency Plan. Survey of the motors/equipment would alsoassist in ensuring that the actions proposed in the plan accurately “target” the affectedareas in the most cost effective and timely manner. For example, the benefits of movingstock may far outweigh any other possible measure. However, there is also the possibleopportunity to introduce some flood preventative measures (raising switch gear, forexample). The feasibility of such proposals would need to be examined by a qualifiedmechanical/electrical expert. If these works were carried out they may eliminate theincreases in damages caused by the cumulative increases in flood levels.There is no Emergency Plan for Dairy Farmers and it is unlikely that providing such aplan would be of benefit on account of the low probability of the plant itself beinginundated and as the plant is presently vacant.It is unlikely that Emergency Plans for residential and small commercial premises wouldbe beneficial, due to the relatively high turnover rate, and as such it has not beenconsidered further.Provide Depth IndicatorsSigns indicating water depth can assist floodplain users in evacuating the floodplain. Ithas been noted that at present there are few along Bolong Road. Provision of suchsigns would assist in minimising future damages for all occupants along Bolong Roadand increase their awareness of the flood hazard.Improved Flood Awareness and PreparednessOne of the most beneficial means of reducing flood damages to existing buildings(residential, commercial and industrial) is to improve the awareness and preparedness ofthe occupants. There are a number of ways of undertaking such a scheme and theseare outlined in the Riverview Road Floodplain Management Plan. Funding of a schemewould assist in improving the community’s flood awareness and consequently reducingflood damages.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 281
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryDedication of a Floodway on the Northern BankThe DLWC (correspondences of 27th June 2002, 15th January 2001 and previous) hasproposed the idea of dedicating a “floodway” zone on the northern bank. This wouldprovide a “cap” on future development in the area and also ensure that present or anyfuture development does not impact upon the major flow paths in the area. This conceptwas examined by Webb McKeown as part of the investigation for Pond No. 6 (March2001) and the outcomes are summarised as follows.In order to examine the effects of further development along the river bank, a series ofhydraulic model simulations were undertaken as part of the studies for Pond No. 6. Theobjective was to use the hydraulic CELL Model to demonstrate that “beyond say a limitof 100 metres no further development should be permitted”, on account of the significantincrease in flood levels.The model results did not support the proposition that the river bank is a critical area forpreventing further development. A run simulating a 100 m wide barrier to flow (parallelto the river bank) immediately east of the Shoalhaven Starches plant indicated a± 0.01 m or less impact on river levels for the range of flood events (5% AEP toExtreme). The main reasons for this result are:• The northern river bank is relatively high (4.4 m to 5.4 m AHD) which means that thebank is only just overtopped (by a maximum of 0.3 m) in the 5% AEP event;• The northern river bank is some six kilometres long (Bomaderry to BroughtonCreek). 100 m represents less than 2% of the total distance.• There is a minor increase in flood level (0.01 m or less) in the Shoalhaven River asa result of the 100 m barrier. This consequently produces an increase in flow overthe remainder of the river bank (this can be a significant increase in total flow as theriver bank is relatively long) which partially compensates for the isolated loss ofoverflow area on the northern bank.• In the 1% AEP event a 100 m barrier will reduce the flow over the river bank at thislocation (Weir 109) by approximately 100 m 3 /s out of a total flow of 270 m 3 /s (37%reduction). However a 100 m 3 /s increase in flow in the Shoalhaven River representsonly 0.7% of the total flow of around 14 000 m 3 /s. This increase is easily spreadacross the 1 kilometre wide river resulting in the nominal increase in flood level of0.01 m or less. According to Webb McKeown the increases in flood level due to thestorage ponds were partially mitigated by reducing the flow into the northernfloodplain. Flood levels do rise in the Shoalhaven River but by less than 0.01 m.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 282
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• The main reasons for the impacts associated with the Storage Ponds (Nos. 1 to 7) isthat they occupy a relatively large waterway area in a 1% AEP event (say 3 m highand approximately 550 m long by 550 m wide), and together with a “flat” floodgradient this means that any increases are transmitted a long way upstream. Withinthe Shoalhaven River proper there is a much “steeper” flood gradient and anyimpacts dissipate within a shorter distance.From these preliminary results it is clear that dedication of a “floodway” zone isnecessary to prevent total “blocking” of the northern river bank. However, the resultsindicate that blocking (say) a 100 m wide strip, does not have a significant impact uponflood levels.The flow path across the northern river bank is the key control which determines howmuch of the floodwaters passing under Nowra Bridge enters the northern floodplain.The bank has the highest ground levels in the immediate area and thus any reduction inits capacity will reduce the ability of floodwaters to reach the overbank floodplain. Thedevelopments along Bolong Road, including the small commercial/industrial buildings inthe eastern part of Bomaderry, the Shoalhaven Starches, Dairy Farmers and Paper Millplants have all contributed to a reduction in the capacity of the flow path. Any furtherintense development along the river bank will need to be examined in detail. However,the ponds which are the main impediment to flows are all located some 500 m from theriver bank. Thus their impact on the flow paths from the river is negligible as thefloodwaters have largely dissipated once they cross Bolong Road.House RaisingHouse raising is a means by which the entire house can be raised (typically on piers)above the nominated flood levels. In this way flood damages within the house can beeliminated to the nominated level. However external damages and the risk to life inmoving to/from the house during a flood are not affected. This measure is really onlyappropriate for non-brick buildings on piers (preliminary inspection by Webb McKeownindicates that all buildings along Hannigans Lane may be suitable). The cost is typically$60,000 per building and this measure has been widely used throughout NSW. Itgenerally cannot be used for commercial/industrial buildings due to their size and as theyare typically on concrete slabs.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 283
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.11 WASTE MANAGEM<strong>ENT</strong>This section of the EA is based upon a Waste Management Report prepared byStephenson Environmental Management Australia (SEMA). A copy of this report formsAnnexure L to this EA. This report was prepared in response to the Director-General’srequirements for the preparation of this EA which required:“Waste Management – identify the quantity and type of all liquid and solidwaste generated at the site and how this waste would be handled, processedand if necessary disposed of.The purpose of the report prepared by SEMA is to describe the current waste generatedon the site and current disposal methods. Shoalhaven Starches already has an existingWaste Management Standard Operating Procedure in place as part of the company’squality system.The proposed expansion will see the current procedure/system amended whereappropriate to cope with the additional volume of waste.Shoalhaven Starches has a Quality System, which contains procedures relating toenvironmental aspects of the operation.The company is also in the process ofdeveloping and implementing an Environmental Management System (EMS) inaccordance with the International Standard ISO 14001.Where applicable, crossreferencingto these procedures has occurred within the Waste Management Reportprepared by SEMA.7.11.1 Legal and Regulatory RequirementsWaste Avoidance and Resource Recovery (WARR) Act 2001This Act seeks to encourage the most efficient use of resources and to reduceenvironmental harm in accordance with the principles of ecologically sustainabledevelopment. In addition the Act seeks to ensure that resource management optionsare considered against the waste hierarchy.Shoalhaven Starches has taken these principles into account when developing wastemanagement strategies.Protection of the Environment Operations Act 1997Shoalhaven Starches has been licensed by the NSW EPA, and now DECC, under theprovisions of the Protection of the Environment Operations Act 1997. The environmentprotection licence (No. 883) remains in force for the life of the Facility.Shoalhaven Starches must continue to comply with the conditions of the EPL.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 284
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.11.2 Waste Identification and ClassificationTypes, Volumes and ClassificationTable 34 summarises the solid waste generated from various areas of the operation,what waste can be generated and the classification in terms of the DECC Guidelines.Table 34Solid Waste Generated on SiteGluten PlantStarch PlantProcess AreaGluten and Starch PlantsEthanol and Distillation PlantsCoal Fired BoilersAll areas of the plant andEnvironmental FarmEnvironmental FarmWaste GeneratedReject wasteReject wasteDamaged and out of spec packed powered productDry product spillsWastes from Grain line and fermentersQuarantine wasteBoiler and fly ashCardboard and paperScrap Metal (Stainless and Black)Plastic wrapping and paper bagsTimberPlastic and metal drumsGeneral rubbishSettled SolidsAnalytical vialsTable 35 lists all the types of solid waste generated, which are not reprocessed in theproduction factory and their associated classification under the NSW EPA EnvironmentalGuidelines: Assessment, Classification & Management of Liquid and Non-Liquid Wastes(NSW, EPA, 1999).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 285
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 35Waste Classification of Materials Taken Off-site for DisposalType of WasteQuarantine wasteBoiler ashCardboard and paper productsScrap Metal (Stainless and Black)TimberPlastic drums and paleconsAnalytical vialsSettled SolidsWaste ClassificationLiquid and Non-Liquid HazardousInert/solid wasteNon-liquid solid wasteInert/ solid wasteInert/ solid wasteInert/ solid wasteHazardous – DG Class 8 – UN3264-1830Liquid-<strong>Group</strong> B Food Waste7.11.3 Environmental Management Plan7.11.3.1 Solid Waste ManagementShoalhaven Starches goal is to minimise the generation of solid waste on site and tohandle the waste that is generated in a manner that it will not pollute the environment.The Company’s performance objectives and targets are to:• avoid, minimise or recycle wherever possible, or responsibly dispose of waste;• maximise the re-use or recycling of wastes that are generated during construction.Shoalhaven Starches has adopted the Resource Management Hierarchy principles ofthe WARR Act which are as follows:• avoid unnecessary resource consumption as a priority;• avoidance would be followed by resource recovery (including reuse of materials,reprocessing, recycling and energy recovery); and• disposal would be taken as the last resort.Shoalhaven Starches has a Waste Management System procedure (SA-P-140) alreadyin place. This procedure outlines the waste to which the procedure applies and outlinesthe procedures of managing and disposing of the wastes generated at the factory site.SA-P-140 would be up-dated to include the elements of the proposed increase inethanol production and the associated activities if the development proceeds.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 286
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 36 is a summary of solid wastes that may be generated during the constructionperiod and how they will be managed or disposed of. The table also includes theexpected waste volumes to be generated as a result of the production increase. Theexact impact on waste volumes will not be known at this point in time, however a 40%increase across the board has been used.In order to facilitate waste management in the future the following recommendationsshould be implemented:• Waste Management Database is established to track volumes of waste beinggenerated.• Where they don’t already exist, the Environmental Manager, or their delegate,develop written agreements with all “waste” disposal companies for those wastesthat are taken off-site for reuse, reprocessing/disposal.The agreement should specify, but not be limited:−−−−−−−The name of company.What material/waste that are taking off-site.Where material is being transported to.Disposal method – landfill, reused, reprocessed, etc.Pickup interval.Reporting requirements – eg. providing Shoalhaven Starches with monthly orquarterly reports on the volume of waste pickup.Records/licences/permits allowing companies to transport and dispose of thewaste.• Maintaining copies of all written agreements.Shoalhaven Starches commit to implementing the above recommendations.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 287
Table 36Solid Waste Management – Wastes GeneratedProcess Area Waste generated Disposal MethodCurrent Approx.VolumeDisposed of Offsiteper WeekProposedApprox. VolumeDisposed ofOff-site perWeekGluten Plant Reject waste Reassigned or reprocessed within production plant Not applicable Not applicableStarch Plant Reject waste Reassigned or reprocessed within production plant Not applicable Not applicableDamaged and out of specpacked powdered productRecycled back at the beginning of the process at the Flour Loader Not applicable Not applicableGlucose Plant Carbon filteraid Used as an ingredient into DDGs 2 tonnes 2.8 tonnesGluten and StarchPlantsDry product spillsClean uncontaminated dry product is reprocessed through thefactory and slurry is sent to the fermentation plant.Not applicable Not applicableDamaged bags of starchDamage bags of starch are reprocessed through fermentationplant or for starch slurryNot applicable Not applicableDamaged bags of glutenDamaged bags of gluten are to be reprocessed through thededicated recycling hopper and recorded on the packing recordNot applicable Not applicableQuarantine wastePlaced in a designated contaminated waste bin. A designatedwaste company collects the material for ultimate disposalNot applicable Not applicableCoal Fired Boilers Boiler and fly ashPrimarily taken off site by a licensed commercial composter andlandscaper to be used as a horticultural compost ingredient.50 tonnes 70 tonnesAlso some of the ash is used by Shoalhaven Starches as a basefor roads, for new infrastructure and to be mixed with soil to leveldepressions in irrigation paddocks on the Environmental Farm.296 tonnes 414 tonnesCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 288
Table 36 (continued)Process Area Waste generated Disposal MethodCurrent Approx.VolumeDisposed of Offsiteper WeekProposedApprox. VolumeDisposed ofOff-site perWeekAll areas of the plantand farm includingmain store, office/lab,workshops andpacking operationCardboard and paper bagsMetalCollected in designated bins and collected by contractor forrecycling.Collected in designated bins and routinely recycled by themaintenance crew or sold to a commercial recycler.2.25 tonnes 3.15 tonnes6.2 tonnes 8.68 tonnesTimberTaking to local waste management centre to be crushed andprepared for reuseIncluded ingeneral wasteIncluded ingeneral wasteEmpty metal and plasticdrumsSold or gifted to accredited drum recycler16 drums 6.4 drumsPlastic Palecons Issued to DDG Syrup customers Nil − all used Nil − all usedGeneral rubbish (includingplastic wrapping, officepaper, timber)Collected in designated waste bins and taken off-site by localwaste contractor on a regular basis for disposal to landfill.23 tonnes 32 tonnesSoilStockpiled for transport to Environmental Farm for blending andused in farm levelling work.No records No recordsEnvironmental Farm Settled Solids in PondsSub-surface injection into grazing land as the solids are beneficialas a slow release fertiliserNot applicable Not applicableUsed as a nutrient additive on dry land pasture areas Not applicable Not applicableMachinery/Scrap metal Left on the Farm for sale or reuse in the future. 6.16 tonnes 8.6 tonnesEnvironmental Farm Analytical vials Returned to supplier 6.5 litres per year 9 litres per yearCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 289
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry7.11.3.2 Liquid Waste ManagementShoalhaven Starches goal is to minimise the generation of liquid waste on site and tohandle the waste that is generated in a manner that it will not pollute the environment.The Company’s performance objectives and targets are to:• Avoid, minimise or recycle wherever possible or responsibly dispose of waste• To maximise the re-use or recycling of liquid wastes that are generated• Ensure irrigation of the wastewater is sustainableShoalhaven Starches has adopted the Resource Management Hierarchy principles ofthe WARR Act which are as follows:• Avoid unnecessary resource consumption as a priority• Avoidance would be followed by resource recovery (including reuse of materials,reprocessing, recycling and energy recovery) and• Disposal would be taken as the last resort.Shoalhaven Starches has following plan/procedure/document in place to manage liquidwaste on the factory site and minimise potential for pollution:• Surface Water Management Plan• Cooling water release monitoring – EN-P-0050• <strong>Manildra</strong> <strong>Group</strong> – Shoalhaven Starches – Dangerous Goods. This documentcontains drawings showing the location, type and volumes of various dangerous andhazardous goods depots around the facility. It also contains the Dangerous GoodsMonitoring Plan.Shoalhaven Starches Environmental Farm personnel use the following StandardProcedures, Work Instructions and plans to operate and manage the farm:(1) EN-P-0020 – Filling Out and Using the Environmental Farm 24hr Report(2) EN-P-0090 – Environmental Farm – Pre Irrigation Checks(3) EN-P-0100 - Irrigation with Pivot Irrigators(4) EN-P-0110 – Irrigation with Travelling Irrigators(5) EN-P-0120 – Flushing Irrigation Lines and Pivots(6) EN-P-0160 – Odour Reduction at Irrigation Start-UpCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 290
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry(7) SA-P-140 – Waste Management System(8) EN-P-0150 – Acid Protocol for Effluent Storage Ponds.Table 37 summarises the liquid wastes currently generated, current disposal methodsand the volumes currently generated. It also includes the proposed current disposalmethods and volumes if ethanol production increases as proposed.Table 37Summary of Liquid WastesProcessAreaWastegeneratedCurrentDisposalMethodProposed DisposalMethodCurrentApprox.VolumeDisposed ofOff-siteProposedApprox.VolumeDisposed ofOff-siteEntire plantoperationsWashdownWaterPumped to theEnvironmentalFarm’s storageponds fordisposal viairrigationBiological wastewatertreatment plant andeither re-used in theplant, or diverted to theEnvironmental Farm forirrigation.1.24 ML perday2.25 ML perdayCondensatePumped to theEnvironmentalFarm’s storageponds fordisposal viairrigationBiological wastewatertreatment plant andeither re-used in theplant, or diverted to theEnvironmental Farm forirrigation.2.83 LM perday5.75 ML perdayRetentateBiological treatment anddisposal toEnvironmental Farm.Notapplicable1.5 ML perdayCODreagentReturned tosupplierReturned to supplier0.125 L perweek0.2 L perweek7.12 VISUAL IMPACTThe Shoalhaven Starches Factory Site is located on Bolong Road, one of the maingateway entrances to the Nowra/Bomaderry urban areas, and a significant tourist routealong this section of the South Coast.The Scenic Character and EnvironmentThe Shoalhaven Starches factory site is situated on Bolong Road, the gateway toBomaderry, within an area currently containing a mixture of rural and industrial landuses. These different land uses contrast with each other and result in a mixed visualcharacter.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 291
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe rural areas, much of which comprises the Shoalhaven Starches EnvironmentalFarm, are generally flat to gently undulating and planted with pasture grasses. Theseareas have a typical rural/agricultural character, common throughout the region. To thenorth and forming a background to the rural landscape are the timbered slopes of theCambewarra escarpment.The Shoalhaven City Council Heritage Study 1995 – 1998 prepared by Peter FreemanPty Ltd in association with JRC Planning Services identified the rural landscapes north ofthe Shoalhaven River as the Berry-Bolong Pastoral Landscape. This Study describedthis area as:“North of the Shoalhaven River the area is dominated by the closerelationship between the Princes Highway (formalised by Berry in1857/1858) and the railway (1893) which were instrumental in determiningthe location of new homesteads on Berry estate lands which resulted fromdrainage schemes implemented by Sir John Hay. In the foothills to thenorth-west, and towards Cambewarra, settlement patterns were in the maindetermined by the impact of Free Selection after 1861. Sub-zones includethe Cambewarra-Tapitallee area, Bellawongarah and the catchment areas ofBroughton Creek north of Berry. The latter are focused around communitieswhich developed outside the Berry Estate: Cambewarra, Tapitallee,Bundewallah, Woodhill and Broughton Vale. The scale and character aredependent on the distribution of small dairy farms, with internal and externalboundaries created by modified and natural vegetation (River Oaks), roads,creeks and property boundaries.Continuing dairy farms has contributed to the survival of the underlying latenineteenth and early twentieth century landscape patterns.”The Shoalhaven Starches factory complex is characterised by typical industrialstructures with an overall bulk and scale that dominates the surrounding locality. Thesite, despite being partially screened by vegetation along Bolong Road, the ShoalhavenRiver and Abernethy’s Creek visually dominates the locality.The development isparticularly exposed to view along Bolong Road. This view reveals some of the internalstructures within the site including recovery and storage tanks, car park, fermentationtanks and the Ethanol Plant. Overall the appearance of the site is typical of an industrialfacility of this nature.The most relevant vantage points from where the factory site is visible would include:The Princes Highway – views of the existing factory site are possible from selectedlocations along the Princes Highway north of Bomaderry, travelling in both a northerlyand southerly direction. Whilst the factory site is visible in the landscape, its overallvisual impact is reduced by virtue of the distance between the plant; the intermittentCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 292
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderrynature of the views; a rise in topography which screens the site from view; andvegetation.Burraga (Pig) Island – Burraga Island is situated in the middle of the Shoalhaven Riverand provides the closest vantage point to the southern boundary of the site. The islandhowever is privately owned and not accessible to the public. Vegetation screening alongthe riverbank adjacent to the site also reduces the visibility of the existing buildings andstructures.Bolong Road – Bolong Road runs along the frontage of the site. Views of the plant arepossible when travelling in both an easterly or westerly direction. Some attempts havebeen made to provide some tree planting along the boundaries to “soften” theappearance of the development. The existing building forms and structures are howeverclearly visible to motorists travelling along this stretch of Bolong Road.Nowra Bridge – The Nowra Bridge crosses the Shoalhaven River and provides limitedopportunities for views of the factory site. The dominant visual elements from the bridgeare the river, vegetation along the riverbanks and the escarpment. The visual impact ofthe factory site is reduced by distance as well as the bridge structure which permits onlyglimpses of the site.Bomaderry urban area – The existing plant is visible from a number of locations withinthe eastern outskirts of Bomaderry. Bomaderry is slightly elevated and some locationswithin the urban area do have extensive views of the site.Terara – Distant views of the Plant are possible from a number of vantage points in andaround the village of Terara on the southern bank of the River. The visual impact of thesite however is reduced by distance, the intervening landform of Burraga (Pig) Islandand the vegetated riverbanks.Riverview Road – Views of the site are available from residential development on thesouthern bank of the Shoalhaven River. Vegetation along both the northern andsouthern banks of the river partially screen the site from view.Cambewarra Lookout – Cambewarra lookout is a popular tourist lookout providingpanoramic views over the Shoalhaven floodplain and estuary. Shoalhaven Starches,like the other significant industrial sites, is visible from the lookout.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 293
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryVisual Impact of ProposalIn terms of visual impact of the proposed works on the factory site, there are essentially3 components: the installation of plant and structures within the existing factory site; theadditional buildings and plant to be sited with the DDGS Plant to the west of Abernethy’sCreek; and the proposed new packing plant and container loading area to the north ofBolong Road (including proposed pedestrian bridge and fire system)The proposed structures within the existing factory site are generally of a similar heightas the existing structures. The building forms, shapes and characteristics are alsosimilar to those that presently exist on the site, and will conform to the visual character ofthe site, ie. it is industrial development within an industrial setting.The development of the land to the west of Abernethy’s Creek will include additionalcooling towers; buildings housing dryers and associated equipment with an overallheight of approximately 20 metres; and gas co-generation plant (approximately15 metres maximum).The proposed packing plant and container loading area will be located on the northernside of Bolong Road and will have a height of 10 metres. The siting of the packing plantwill also include an overhead pedestrian / service bridge across Bolong Road to servicethis site. This bridge structure will comprise a height of 11.6 metres.The visual impact of these works from the identified vantage points (refer Figure 34) isdescribed as follows:The Princes HighwayThe Shoalhaven Starches factory is mainly visible from a section of the Princes Highwaybetween Boxsells Lane and Devitts Lane, Jaspers Brush (refer Plate 15). Due to theconfiguration of the highway and the siting of the factory, only southbound vehicles viewthe site. Vantage points along this section of the highway are 4.5 to 5.0 km from the site.The site becomes less exposed and is eventually obscured by a rise in topographyfurther south of Boxsells Lane.Given the distance form these vantage points the factory site is only barely visible. Therising topography upon which Bomaderry is sited screens the western portion of the site,as does intervening vegetation.Given the distance of these views, and the screening of the site attributed to terrain andvegetation it is considered the developments associated with this project will notadversely impact on views from these vantage points.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 294
5Shoalhaven StarchesEnvironmental Farm987 61011ShoalhavenStarches Factory12Figure 34: Vantage Points for Plates.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 295
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryBolong RoadThe existing factory site is clearly visible from Bolong Road by vehicles approachingfrom the east, and along the frontage of the site refer (Plate 16).Many of the proposed works associated with this proposal are located within the existingdeveloped portion of the existing factory site; and within proximity of similar designedand sized structures to that proposed. For instance the proposed additional Fermentersare sited adjacent to existing fermentation tanks; and the additional starch dryer, coolingtowers and molecular sieves are sited within the vicinity of similar structures.Works associated with the DDGS Plant sited to the west of Abernethy’s Creek will mainlyinvolve structures of a similar bulk and scale as existing structures within this part of thesite.These works will be partially screened from view along Bolong Road by virtue of existingdevelopment sited along the Bolong Road frontage. Where element intrude above theskyline of existing buildings they will be of a form similar to existing industrial structureswithin the vicinity. (Refer Plates 17 and 18.)The main components of the project that will be visible along Bolong Road will be thenew packing plant (and silos) and in particular the proposed overhead pedestrian /product bridge that will cross Bolong Road.The packing plant site is currently cleared. It adjoins a railway line, other industrialdevelopment and Councils’ Sewerage Treatment Works. This development will involvea substantial building with a height of 10 metres and silos with a height of just over30 metres. The site however is to a larger extent shielded from view from Bolong Roadby existing development.The proposed overhead pedestrian and product bridge will be clearly visible acrossBolong Road, Bolong Road is essentially a “gateway” into the Nowra / Bomaderry urbanarea.Shoalhaven City Council has resolved to give “In principle” support for this structure. Indoing so, however Council seeks the Company to agree to re-design the exteriorelements of the structure to improve its architectural and visual qualities commensuratewith a standard appropriate for the gateway to this urban area. The Company agrees toCouncil’s view in this regard; and will endeavour to work with Council in providing adesign which meets Council’s concerns in this regard.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 296
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 15: View of Shoalhaven Starches Factory from Princes Highway(within vicinity of Boxsells Lane). Factory stack barely visible from this vantage point.Plate 16: View of Shoalhaven Starches factory site from Bolong Roadfrom the east of the site.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 297
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 17: View from Bolong Road of Access Point 2.Plate 18: View from Bolong Road of the ‘Moorhouse’ site.Existing DDG plant is to rear of the ‘Moorhouse’ site.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 298
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryBomaderry Urban AreaThe township of Bomaderry is slightly elevated and some locations within this urban areahave extensive views of the site (refer Plate 19). The proposed works particularly thosewithin the existing factory site are however unlikely to be visually prominent from thesevantage points.The works to the west of Abernethy’s Creek however will be visible. These structureswill be similar in height to components of the existing factory site, and will be sited withinproximity of other industrial activities. In this way the vistas from these vantage pointswill not be significantly altered.Nowra BridgeThe view from Nowra Bridge to the east is mainly dominated by the river, riparianvegetation and the floodplain (refer Plate 20). The site is largely obscured by riversidevegetation. Works to the west of Abernethy’s Creek will be sited closer to this vantagepoint than the remainder of the factory complex, and these structures are likely toprotrude above the canopy of the vegetation along the river. These structures howeverwill be sited within the overall “silhouette” of the existing factory complex, and will notintrude into the existing skyline created by the existing factory.The remainder of the works associated with this proposal will not be visible from thisvantage point.Plate 19: View of Shoalhaven Starches factory site from corner ofMeroo Road and Cambewarra Road, BomaderryCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 299
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 20: View of Shoalhaven Starches factory site from Nowra Bridgeover the Shoalhaven RiverRiverview RoadThe main vantage point from where the proposed works to the west of Abernethy’sCreek will be visible will be from residences along Riverview Road directly south of thesite (refer Plate 21). This view is from a distance of about 750 metres. Riversidevegetation along both the northern and southern banks of the river will screen much ofthe site from view. In this way it is unlikely that the container storage will be visible fromthis vantage point.These works are likely to intrude above the tree canopy. This is the case with theexisting factory development. From this vantage point however, these works will besited within close proximity of the existing factory complex, and will be viewed within thiscontext.The other works associated with the proposal will not be visible from this vantage point.It is noted there are ‘gaps’ in the vegetation along the riverbank to the south of the site,and the proposed development may be visible through these ‘gaps’. There is, therefore,scope for supplementary landscaping and revegetation to take place along the riverbankadjoining the factory site to help soften or obscure views of the site, particularly from thisvantage point.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 300
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 21: View of Shoalhaven Starches factory site from Riverview Road area.TeraraThe village of Terara is approximately 1.5 kilometres from the factory. The proposedworks associated with this development will not be visible from this vantage point, mainlydue to vegetation along the riverbank (refer Plate 22).Cambewarra LookoutCambewarra Lookout is situated about 7 km to the northwest of the site. Views from thelookout are from an elevation over 620 m ASL, and encompass the Shoalhaven Riverfloodplain and the coast including Jervis Bay. Whilst the factory site is visible from thisvantage point, due to scale of the view, it would be extremely difficult to make out theworks associated with the project from this vantage point.Overall it is considered that the proposed works will not create a significant adversevisual impact due, principally, to the existing industrial development. There are howevermeasures which Shoalhaven Starches commit to implementing to assist in screeningand further minimising any visual impact.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 301
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryPlate 22: View of Shoalhaven Starches factory site from village of Terara.• The existing screening vegetation around the site is effective, particularly along theriver bank, however additional supplementary plantings of dense bands of nativetrees and shrubs along the southern boundary of the site with the river (particularlybetween the river and the proposed evaporator columns) would further reduce thevisibility of the development. In this regard a landscape and revegetation planshould be prepared for that portion of the site zoned 7(f3) with suitable riparianvegetation and including trees which will grow to a height to soften the view of theseworks. Such a plan should be prepared prior to works commencing on the site.• In order to reduce the visual impact and the proposed Fermenters, the northern andeastern boundaries of the site should be landscaped with a combination of trees andshrubs. Landscaping should also be incorporated between the packing plant /container loading yard to Bolong Road to soften the appearance of this developmentto Bolong Road. The abovementioned landscape and revegetation plan should alsodetail such landscaping measures.• Where planting has already been established, measures should be taken to protectexisting vegetation during the construction phase.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 302
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• In addition to landscaping, new structures can be constructed and treated to reducevisual impact. Where appropriate and possible, buildings and structures should beconstructed of similar materials as those previously used on the site and be of anon-reflective nature. Colours should blend with existing structures on the site toensure visual harmony. Consideration should be given to incorporating a claddingcolour which will blend with the surrounding locality.• The exterior elements of the proposed overhead pedestrian / product bridge acrossBolong Road should be re-designed to improve its architectural and visual qualitiescommensurate with this “gateway” site.7.13 FLORA AND FAUNAThe following section of the EA is based upon the findings of the Flora and FaunaAssessment prepared by Kevin Mills & Associates (KMA) and which is included asAnnexure E to this EA.7.13.1 Description of the Vegetationi. Factory SiteAccording to KMA no native vegetation occurs on the proposed ethanol upgrade sites atthe factory. Most of the sites have been cleared and sealed, and/or subjected to suchheavy use or traffic as to obliterate all vegetation, native or otherwise, except foroccasional weeds. The sites for the proposed water treatment / filtration plant and gasfiredco-generators, which are located about 50 metres and 70 metres from the northernbank of the Shoalhaven River, respectively, were found to be cleared land. A narrowriparian corridor augmented by recently planted trees stands between the edge of theriver and these sites.ii.Environmental FarmThe Shoalhaven Starches' Environmental Farm has been cleared and farmed for morethan a century. Located on the broad floodplain of the lower Shoalhaven River, much ofthe farm is irrigated with wastewater from the company’s plant. The paddocks havebeen pasture improved and grazed for many years, and native vegetation has almosttotally disappeared, except along the edge of Broughton Creek.iii.Packing plant, rail siding, etc.The site for the proposed packing plant, container loading area and associated accessroad and rail siding is on cleared land owned by Shoalhaven Starches on the northernside of Bolong Road. The site is in a cleared paddock dominated, according to KMA, byCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 303
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryKikuyu Grass Pennisetum clandestinum and other introduced species such as WhiteClover Trifolium repens, Mouse-eared Chickweed Cerastium glomeratum, Paddy'sLucerne Sida rhombifolia, Fireweed Senecio madagascariensis, Spear Thistle Cirsiumvulgare and Blackberry Rubus fruticosus. There are occasional Black Wattles Acaciamearnsii on the site.There are a few trees in the far southern part of the site and near Abernethy’s Creek onthe eastern edge of the site; these are mostly Black Wattle Acacia mearnsii.iv.Pipeline RouteThe proposed pipeline is from the eastwards along the northern side of Bolong Roadwithin freehold land, mainly owned by Shoalhaven Starches, to the factory site. Theroute is treeless, and according to KMA is dominated by a thick sward of Kikuyu GrassPennisetum clandestinum.v. Changes to Storage PondsThe area to be affected by alterations to the existing and approved wet weather storageponds (currently nearing completion) is cleared land use for grazing, a paddockdominated by Kikuyu Grass Pennisetum clandestinum and other introduced pasturespecies.7.13.2 Plant Species RecordedThe plant species recorded by KMA in the areas to be affected by the proposed workshave been listed below, in Table 38. Native plants are uncommon in those areasbecause of the long history of industrial use (on the factory site) and grazing (on theenvironmental farm). Mainly introduced plant species are present.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 304
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 38Plant SpeciesTaxonomic NameNative Plant SpeciesAcacia mearnsiiElaeocharis sphacelataHypolepis muelleriRanunculus inundatusIntroduced Plant SpeciesAgeratina adenophoraCerastium glomeratumCirsium vulgareHypochaeris radicataIpomoea indicaLantana camaraPaspalum urvilleiPennisetum clandestinumRubus fruticosus sp. agg.Senecio madagascariensisSida rhombifoliaTrifolium repensVerbena bonariensisCommon NameBlack WattleTall Spike-rushHarsh Ground FernRiver ButtercupCrofton WeedMouse-eared ChickweedSpear ThistleFlatweedMorning GloryLantanaVasey GrassKikuyu GrassBlackberryFireweedPaddy's LucerneWhite CloverPurpletop7.13.3 Fauna HabitatAccording to KMA there is little to attract native animals to the factory site, butShoalhaven Starches' Environmental Farm provides wetland habitat for a wide range ofwater birds. The fauna species that have been recorded by KMA on the ShoalhavenStarches land at Bomaderry have been listed below, in Table 39. All of the species wererecorded on the Environmental Farm during previous surveys by KMA. Only a fewspecies were observed during the current survey on the sites to be affected by theproposal upgrade; (see column 3 - Table 39). According to KMA this is not surprising,given the highly modified nature of the sites.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 305
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 39Fauna Species Recorded on Shoalhaven Starches’ Land, BomaderryCurrent SurveySpecies Taxonomic Name 2007/08MammalsBrown Hare*Lepus capensisCattle* Bos taurus XShort-beaked Echidna Tachyglossus aculeatusBirdsAustralian Magpie Gymnorhina tibicen XAustralian Pelican Pelecanus conspicillatusAustralian Raven Corvus coronoides XAustralian White Ibis Threskiornis molucca XAustralian Wood Duck Chenonetta jubataBlack-faced Cuckoo-shrike Coracina novaehollandiaeBlack-shouldered Kite Elanus axillarisBrown SonglarkCincloramphus cruralisCattle Egret* Ardea ibis XChestnut TealAnas castaneaCommon Mynah* Acridotheres tristis XCommon Starling* Sturnus vulgaris XDarterAnhinga melanogasterDollarbirdEurystomus orientalisEuropean Goldfinch Carduelis carduelisFairy MartinHirundo arielGalahCacatua roseicapillaGolden-headed Cisticola Cisticola exilisGreat CormorantPhalacrocorax carboGreat EgretArdea albaGrey ButcherbirdCracticus torquatusGrey FantailRhipidura fuliginosaGrey Shrike-thrush Colluricincla harmonica XGrey TealAnans gracilisHouse Sparrow* Passer domesticus XLittle Pied Cormorant Phalacrocorax melanoleucosMagpie-lark Grallina cyanoleuca XCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 306
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 39 (continued)Current SurveySpecies Taxonomic Name 2007/08Masked Lapwing Vanellus miles XOlive-backed Oriole Oriolus sagittatus XRainbow LorikeetRichard's PipitRock Dove*Sacred KingfisherSilver GullSpotted Turtle-Dove*Trichoglossus haematodusAnthus novaeseelandiaeColumba liviaTodiramphus sanctusLarus novaehollandiaeStreptopelia chinensisStraw-necked Ibis Threskiornis spinicollis XSuperb Fairy-wren Malurus cyaneus XWelcome Swallow Hirundo neoxena XWhite-bellied Sea-EagleWhite-faced HeronWhite-necked HeronWillie WagtailYellow ThornbillYellow-billed SpoonbillYellow-rumped ThornbillHaliaeetus leucogasterEgretta novaehollandiaeArdea pacificaRhipidura leucophrysAcanthiza nanaPlatalea flavipesAcanthiza chrysorrhoaFrogsCommon Eastern Froglet Crinia signifera X*Introduced species.7.13.4 Impact of the Proposed UpgradeImpact on Native Vegetation and Fauna HabitatAccording to KMA the proposed upgrade will have little impact on flora and fauna. Thesite has a low diversity of native plant species and, except for the ponds on theEnvironmental Farm, there is little to attract native animals.7.13.5 Conclusion and Recommendations of Flora and Fauna AssessmentThe Flora and Fauna Assessment prepared by KMA makes the following conclusion withrespect to this project:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 307
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe proposed upgrade will have little impact on native flora and fauna. Thereare no areas of high conservation value on the site. The proposal is not likelyto have an adverse impact on species, populations and communities listedunder the New South Wales Threatened Species Conservation Act, 1995and the Commonwealth Environment Protection and BiodiversityConservation Act, 1999; no threatened species, populations or communitiesare known to occur on the subject land or are expected to occur there. Thepreparation of a Species Impact Statement (SIS) nor referral to theCommonwealth Environment Minister for approval is therefore not warranted.The Flora & Fauna Assessment prepared by KMA makes the followingrecommendations with respect to this proposal:Recommendations1. As far as is practicable, given the presence of the factory, the verges ofAbernethy’s Creek should be planted with native species.2. Appropriate screen plantings should be installed around the packingshed/loading area; local native species should be used for thispurpose.3. Additional plantings should be made in the environmental protectionzone near the Shoalhaven River.4. The list of local native species at Appendix 1 should be utilised in theplanting programs around the site, as identified above. The list is notexhaustive and it is expected that not all species be used.Shoalhaven Starches commits to implementing the above recommendations.7.14 HERITAGE AND ARCHAEOLOGICAL ISSUES7.14.1 Aboriginal ArchaeologySouth East Archaeology (SEA) was engaged by Shoalhaven Starches to undertake areview of the potential Aboriginal heritage significance of the project site. Annexure D tothis EA is a copy of the Aboriginal Heritage Assessment report prepared by SEA inrelation to the likely impacts associated with this proposal on Aboriginal heritagesignificance.The principal aims of the Aboriginal heritage impact assessment were to:• Undertake research, register searches and an archaeological survey andconsultation with the Aboriginal community to identify and record any aboriginalheritage evidence, areas of potential evidence and cultural values within the studyarea;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 308
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Assess the potential impacts of the proposal upon any identified or potentialAboriginal heritage evidence or cultural values;• Assess the significance of any Aboriginal heritage evidence or cultural valuesidentified;• Provide details of any Aboriginal heritage evidence in accordance with Departmentof Environment and Climate Change (NSW) (DECC) requirements;• Consult with the local Aboriginal community as per the DECC policy entitled InterimCommunity Consultation Requirements for Applicants;• Present recommendations for the management of any identified Aboriginal heritageevidence, potential heritage resources or cultural values; and• Prepare a formal archaeological report to meet the requirements of DECC and DoP.The heritage investigation has proceeded by recourse to the archaeological andenvironmental background of the locality, followed by a field inspection undertaken withthe assistance of representatives of the registered Aboriginal stakeholders. Thisinvestigation was undertaken by an archaeologist (Peter Kuskie) with appropriatequalifications and experience in Aboriginal heritage, in accordance with the DoP andDECC requirements and guidelines.MethodologyDuring the initial stages of the investigation, research was conducted into theenvironmental, historical and archaeological background of the study area, and a searchwas undertaken of the DECC ‘Aboriginal Heritage Information Management System’ andother relevant heritage registers and planning instruments.Consultation and involvement of the Aboriginal community was undertaken as per therequirements of the DECC policy entitled Interim Community Consultation Requirementsfor Applicants.A survey has previously been undertaken of the eastern portion of the pipeline routescurrently under investigation, by Navin (1992). Navin (1992) investigated a 50 hectarearea for extensions to the Shoalhaven Paper Mill, and 22 hectares for the adjacentStarches storage ponds. A survey has also been undertaken by Kuskie (2002) ofproposed extensions to the Starches Factory, which incorporated a portion of the area atthe Starches Factory presently under investigation. The survey was undertaken on 18November 2002 with the assistance of the Nowra LALC and Shoalhaven AboriginalElders (Kuskie 2002).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 309
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryField inspection of the study area was undertaken on 30 January 2008 by Peter Kuskieof South East Archaeology, accompanied by Jason Davison of Dungarn Consultancy.Given the high extent of existing land use impacts that have rendered the potential forheritage evidence negligible in most portions of the study area, along with extremely lowsurface visibility due to grass cover in those portions of the study area not totallyimpacted by previous land use, the previous survey coverage (Navin 1992, Kuskie 2002)and the predictive model, minimal areas were inspected directly on foot. Much of theinspection consisted of visual reconnaissance, which encompassed the entire studyarea.Results and DiscussionThe survey by Kuskie (2002) covered much of the area at the Starches Factory presentlyunder investigation. A total area of 4,160 m 2 was inspected on the level-very gentle riverlevee on the western side of the Starches Factory and 2,240 m 2 on the levee on theeastern side of the Starches Factory. Subsequent works have been undertaken in theseareas and the present inspection confirmed that due to the extensive impacts, there isnegligible potential for Aboriginal heritage evidence in both of these areas, along with theother locations of proposed facilities within the Starches Factory.Visual inspection was made of the area of the proposed facilities on industrial landimmediately north of the Starches Factory and Bolong Road. This area has been highlyimpacted by earthworks, drainage works and other construction activities. Densepasture grasses limit surface visibility to virtually nil and therefore detailed survey wasnot undertaken. Given the formation history of this low-lying floodplain, it represents anenvironment context that has not been conducive to Aboriginal occupation. The onlyAboriginal use of this area is likely to have involved occasional exploitation ofsubsistence resources from marshes or swamps, for which negligible evidence could beanticipated to remain. In consideration of these factors, the potential for stone artefactsto occur in this area is assessed as very low and the potential for all other forms ofAboriginal heritage evidence to occur as negligible.Visual inspection was made of the margins of Bolong Road, alongside which water andgas pipelines may be installed to connect the Starches Factory with the storage pondsand Paper Mill. The verges of Bolong Road are vegetated by introduced grasses andhave been highly impacted by earthmoving works, road construction, drainage worksand essential services (pipelines, telecommunications cables and electricity). The densecover of grass substantially limits surface visibility. The high level of recent land useCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 310
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryimpacts in these areas has also reduced the potential for virtually all forms of Aboriginalheritage evidence to occur as negligible, or in the case of stone artefacts, very low.A survey has previously been undertaken of the eastern portion of the pipeline routescurrently under investigation, by Navin (1992). Navin (1992) investigated a 50 hectarearea for extensions to the Shoalhaven Paper Mill, and 22 hectares for the adjacentStarches storage ponds. Navin (1992) identified two isolated artefacts, a ground edgehatchet (APPM Isolated Find 1, DECC #52-5-288 and 52-5-289) listed twice on DECCAHIMS at AMG grid references 283650:6140940 and 283660:614092, and a brokenalluvial pebble (APPM Isolated Find 2, DECC #52-5-290) listed on DECC AHIMS atAMG grid reference 283500:6140900. The hatchet was identified within the wall of anartificial drainage channel on the northern side of Bolong Road, 0.3 metres below thepresent surface. Navin (1992) concluded that the item was not in situ. The hatchet wasmade from a fine-grained volcanic alluvial pebble, by bifacial grinding and minor unifacialflaking. The broken alluvial pebble was also located within a drainage channel on thenorthern side of Bolong Road and comprised a similar stone material. Both itemsappear to be located marginally adjacent to the proposed pipeline routes. The currentstatus of both items is uncertain.Navin (1992) interpreted this evidence as accurately reflecting the generally lowarchaeological sensitivity of the locality, with the possible use of the elevated river banks(levee) as an access corridor.No Aboriginal heritage evidence or cultural values were identified within the study areaduring the present archaeological investigation. As discussed above, due to the extentof recent land use impacts along with the topographical nature of the locality, thepotential for virtually all forms of Aboriginal heritage evidence (eg. scarred trees, carvedtrees, ceremonial sites, stone arrangements, rock shelters, lithic quarries) is negligible.In relation to the unobtrusive stone artefacts, although the levee may have served as acorridor for movement as identified by Navin (1992), the extent of ground disturbancerenders the potential for artefacts within the Starches Factory as negligible and within theadjacent industrial land and the margins of Bolong Road as very low. Although thepossible presence of a very low density of artefacts consistent with background discardcannot be discounted in areas not totally impacted by recent land use, there exists avery low potential for artefact deposits of sufficient integrity to be of research value.While people may have occasionally visited this portion of the study area, the resultingartefactual evidence is unlikely to be of sufficient nature, integrity, research potential orrepresentativeness to be of significance.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 311
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAboriginal ConsultationThe Aboriginal heritage assessment prepared by SEA involved a comprehensiveprogram of Aboriginal consultation that complies with the policy requirements of theDepartment of Environment and Climate Change (NSW) that were introduced on1 January 2005. These requirements are specified in the policy entitled InterimCommunity Consultation Requirements for Applicants and involve the followingprocedures:1) Providing written notification of the project to the Local Aboriginal Land Council,DECC, Registrar of Aboriginal Owners (Department of Aboriginal Affairs), NSWNative Title Services and relevant Local Councils, requesting that if they are awareof any Aboriginal persons/organisations who may wish to be consulted about theproject to provide such advice in writing, with a minimum of 10 day responseperiod;Compliance with Procedure #1 was achieved through correspondenceforwarded to the relevant organisations on 21 August 2007.Responses were received from the Office of the Registrar of theAboriginal Land Rights Act, Shoalhaven City Council and DECC.The Office of the Registrar of the Aboriginal Land Rights Act advisedthat there are no Registered Aboriginal Owners within this specificlocality. Shoalhaven City Council advised that the Jerrinja LALC,Nowra LALC and Ulladulla LALC should be contacted. DECC advisedthat in addition to Nowra LALC, the Jerrinja LALC, Jerrinja Consultants,South East Coast Gadu Elders Aboriginal Corporation, MerrimansLALC, Ulladulla LALC, South Coast Aboriginal and Elders and Friends<strong>Group</strong> Organisation and Mr Lionel P Mongta should be contacted (referto Appendix 2).2) Providing written notification of the project directly to those Aboriginalpersons/organisations that were identified in Step 1 above, requesting those whomay be interested in participating in the project to register their interest in writing,with a minimum 10 day response period.Compliance with Procedure #2 was achieved by writing to theorganisations nominated above by DECC and Shoalhaven City Councilwith an invitation register an interest as per the DECC policy. Non ofthese organisations registered an interest.3) Placing a media advertisement to the same effect in the local press requesting anyAboriginal persons/organisations who may be interested in participating in theproject to register their interest in writing, with a minimum 10 day response period;Compliance with Procedure #3 was achieved by placing anadvertisement in the Public Notices section of the Nowra South CoastCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 312
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryRegister on 24 August 2007, requesting any Aboriginalpersons/organisations who may be interested in participating in theproject to register their interest in writing. Mr Jason Davison ofDungarn Consultancy registered an interest. The client also elected tocontinue to involve the Nowra LALC in the assessment, even though aformal registration of interest was not received.4) Providing detailed information about the heritage impact assessment, including theproposed methodology, to the Aboriginal persons/organisations who registeredtheir interest in writing in Steps 1 – 3 above, with a minimum 21 day responseperiod for comments;5) Comments received from registered Aboriginal persons/organisations in Step 4,including information on areas of cultural significance, potential culturallyacceptable mitigation measures, the nature of the assessment methodology andany other relevant traditional knowledge or issues, must be considered in order tofinalise the assessment methodology;Compliance with Procedures “4 and 5 was achieved by writing to thetwo organisations that registered an interest or were considered to beregistered (Nowra LALC and Dungarn Consultancy) on 13 December2007 providing them with the proposed methodology for theassessment and requesting their comment. No comments werereceived.6) Field inspection in consultation with the registered Aboriginal stakeholders;Compliance with Procedure #6 was achieved by undertaking the fieldinspection in consultation with the registered Aboriginal stakeholders.The inspection was undertaken on 30 January 2008 by Peter Kuskie ofSouth East Archaeology, assisted by Mr Jason Davison of DungarnConsultancy. Despite prior arrangements, Mr Simms from the NowraLALC was unable to attend, but was satisfied for the inspection tocontinue in his absence.7) Notifying the registered Aboriginal stakeholders and the Local Aboriginal LandCouncil (even if not registered) of the availability of the draft Aboriginal heritageimpact assessment report and their comments invited; andCompliance with Procedure #7 is being achieved by providing copiesof the draft archaeological assessment report to the Nowra LALC andDungarn Consultancy with a request for their comment.8) Preparation of a final Aboriginal heritage impact assessment report that addressesand incorporates the input of the registered Aboriginal stakeholders.Compliance with Procedure #8 can be achieved through preparation ofa final Aboriginal heritage impact assessment report that addressesand incorporates any input received from the registered Aboriginalstakeholders. Comments received can be attached and theCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 313
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryconsultation database amended accordingly. Copies of the final reportcan be forwarded to the registered Aboriginal stakeholders.In addition to the consultation above, both the Nowra LALC and Shoalhaven Elders wereinvolved in an earlier investigation of the Starches Factory by Kuskie (2002) and theNowra LALC was involved in the previous investigation of the eastern end of the pipelineroutes by Navin (1992).Mitigation and Management StrategiesDevelopment may involve substantial impacts to the ground surface associated with theconstruction of facilities. However, according to SEA, much of the proposed works willoccur in locations that have already been totally impacted by recent land use and havenegligible heritage potential. The remainder of the area has also been subject to highimpacts and in consideration of Aboriginal land use modelling, is of very low heritagepotential. No Aboriginal heritage sites are listed within the study area on any heritageregisters or planning instruments, although two isolated artefacts are in the immediatevicinity of the eastern end of the pipeline routes north of the existing Paper Mill.General strategies for the management of the identified and potential Aboriginal heritageresources within the study area are presented below. A key consideration in selecting asuitable strategy is the recognition that Aboriginal heritage is of primary importance tothe local Aboriginal community, and that decisions about the management of the sitesshould be made in consultation with the registered Aboriginal stakeholders.Strategy A (Further Investigation)In circumstances where a site is identified, but the extent of the site, the nature of itscontents, its level of integrity and/or its level of significance cannot be adequatelyassessed solely through surface survey (generally because of conditions of low surfacevisibility or sediment deposition), sub-surface testing may be an appropriate strategy tofurther assess the site. Testing is also appropriate in locations where artefact or middendeposits are predicted to occur through application of a predictive model of site location,in order to identify whether such deposits exist and their nature, extent, integrity andsignificance.Test excavations can take the form of auger holes, shovel pits, mechanically excavatedtrenches or surface scrapes. A Section 87 Permit is generally required from DECC toundertake sub-surface testing, unless Part 3A approval has been granted and in lieu aStatement of Commitments outlining such measures has been approved. Approval of aSection 87 Permit can take up to eight weeks, following receipt by DECC of allnecessary information. A research design specifying the aims and methods is anCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 314
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryessential component of a Permit application and therefore requires approval from DECC.Consultation is also required with the relevant Aboriginal stakeholders as per the DECCpolicy entitled Interim Community Consultation Requirements for Applicants.This is a pro-active strategy, which should result in the identification, assessment andmanagement of the Aboriginal heritage resource prior to any development activityoccurring. Following assessment of each Aboriginal site, management strategies asoutlined below (B – E) can be applied.In relation to the proposed Starches upgrade, the inspection is consideredsatisfactory enough to present an effective assessment of the Aboriginalheritage resources potentially present within the study area. Testexcavations are unlikely to add significantly to the present assessment orlead to alternative management strategies, and on this basis, the imperativefor further investigation is considered to be very low.Strategy B: ConservationThe suitability of conservation as a management option has long been recognised. Thisstrategy is suitable for all heritage sites, but particularly those of high archaeologicalsignificance and/or high cultural significance. Conservation is also highly appropriate forspecific archaeological resources and environmental/cultural contexts, as part of aregional strategy aimed at conserving a representative sample of identified and potentialheritage resources.Options exist within development proposals that can be utilised for the conservationidentified or potential Aboriginal heritage resources, including exclusion of developmentfrom zones of high heritage significance or potential, or preservation of areas withinformal conservation zones.In relation to the proposed Starches upgrade, the imperative for specificconservation measures is limited by the small size of the proposed area ofimpact, high levels of existing ground disturbance, absence of identifiedheritage evidence of significance and the low potential for heritage evidenceto occur. In consideration of these factors, specific conservation measuresare not warranted.Strategy C: Mitigated Impact (Salvage)In circumstances where a site is of moderate or high significance within a local context,but the options for conservation are limited and the surface collection of artefacts orexcavation of deposits could yield benefits to the Aboriginal community and/or thearchaeological study of Aboriginal occupation, the strategy of salvage can beconsidered.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 315
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderrySalvage may include the collection of surface artefacts or systematic excavation ofartefact or midden deposits, normally as part of a Section 90 Consent obtained fromDECC. This strategy is the primary means of minimising impacts to Aboriginal heritagefrom development projects where the option of conservation is not feasible.The specific aims of any salvage project and the methodology could only be finalisedafter consultation with the registered Aboriginal stakeholders and DECC, in relation to anapplication for a Section 90 Consent. The application would need to address the viewsand policy and legislative requirements of these key stakeholders. Consultation isrequired with the relevant Aboriginal stakeholders as per the DECC policy entitledInterim Community Consultation Requirements for Applicants. Alternatively, if a Part 3Aapproval is granted, Section 90 Consent may be required but in lieu a Statement ofCommitments outlining proposed heritage management and mitigation measures mustbe approved.In relation to the proposed Starches upgrade, salvage measures are notwarranted unless impacts cannot be avoided to one of the two isolatedartefacts close to the project area (APPM Isolated Find 1). In this event, theground-edge hatched (Isolated Find 1), should be subject to surfacecollection if it is likely to be impacted and can be successfully relocated, asinitially recommended by Navin (1992).Strategy D: Unmitigated ImpactThe strategy of unmitigated impact involves the proponent making application to DECCfor a Section 90 Consent for any known Aboriginal objects that will be affected by aproposal. This Consent must normally be obtained prior to the commencement of worksaffecting the evidence, because all objects are protected under the terms of the NationalParks and Wildlife Act 1974. Alternatively, if a Part 3A approval is granted, Section 90Consent may not be required, but in lieu a Statement of Commitments outliningproposed heritage management and mitigation measures must be approved.The support of the registered Aboriginal stakeholders should be obtained, throughfurther liaison, for any Section 90 Consent application or Part 3A Statement ofCommitments. Consultation is required with the local Aboriginal community as per theDECC policy entitled Interim Community Consultation Requirements for Applicants.DECC guarantees to process applications within eight weeks, subject to receipt of allnecessary information. This strategy is typically suitable when a site is of low scientificsignificance, the local Aboriginal community holds no objections, and it is unfeasible toimplement any other strategy.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 316
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryIn relation to the proposed Starches upgrade, unmitigated impact is notwarranted unless impacts cannot be avoided to one of the two isolatedartefacts close to the project area (APPM Isolated Find 2) that does notrequire surface collection.Strategy E (Monitoring)An alternative strategy for zones where archaeological deposits are predicted to occur isto monitor construction, particularly any initial earthmoving and soil removal works, forthe presence of artefacts, shell or skeletal remains.Monitoring is the primary strategy for managing the possible occurrence of Aboriginalskeletal remains. Monitoring for the presence of shell and stone artefacts is also often ofvalue to the Aboriginal community, who may be seeking to identify and salvage materialthat was not visible on the surface during a preliminary study. The sieving of gradeddeposits is also a practical measure that enhances the benefits of monitoring forartefacts.Monitoring for artefacts (in preference to sub-surface testing) is not a widely acceptedmethod within the context of a scientific investigation, because it could result insubstantial and costly delays to construction, late revisions to development plans, and/orcause undesirable impacts to sites of cultural or scientific significance. However, whenDevelopment Consent is granted, monitoring for the presence of artefacts and otherfeatures during initial earthworks can be of scientific benefit and benefit to the Aboriginalcommunity. Monitoring undertaken in this circumstance may enable the identificationand retrieval of cultural evidence that may not otherwise have been recorded orsalvaged.In relation to the proposed Starches upgrade, monitoring is not warranted asthe potential for heritage evidence to occur is very low.RecommendationsAccording to SEA the development area has either been totally impacted by recent landuse and has negligible heritage potential, or has been subject to high impacts and inconsideration of Aboriginal land use modelling, is of very low heritage potential. NoAboriginal heritage sites are listed within the study area on any heritage registers orplanning instruments, although two isolated artefacts occur in the immediate vicinity ofthe eastern end of the proposed pipeline routes, north of the existing Shoalhaven PaperMill (Figure 1). In the absence of appropriate management and mitigation measures, itis concluded that the impacts of the proposal on Aboriginal heritage will be very low.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 317
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryThe following recommendations are made by SEA on the basis of legal requirementsincluding the NSW National Parks and Wildlife Act 1974 and Environmental Planningand Assessment Act 1979, the results of the investigation and consultation with the localAboriginal community. Shoalhaven Starches commits to implementing theserecommendations.Provisions relating to Aboriginal heritage should be included in anEnvironmental Management Plan for the project. These provisionsshould be formulated in consultation with the registered Aboriginalstakeholders and specify the policies and actions required to managethe potential impacts of the proposal on Aboriginal heritage after Part 3Aapproval is granted. The plan should include management proceduresfor previously unrecorded Aboriginal heritage evidence and skeletalremains (should such evidence be identified during construction),procedures for further Aboriginal consultation should such evidence beidentified, and mitigation measures involving surface collection for theidentified isolated artefact site APPM Isolated Find 1 (DECC #52-5-288and 52-5-289) should it be subject to impacts. The plan will, subject toPart 3A project approval, guide management of any Aboriginal heritageevidence in lieu of a Section 90 Consent;Under the terms of the National Parks and Wildlife Act 1974 it is anoffence to knowingly destroy, damage or deface an Aboriginal objectwithout obtaining the prior written permission of the Director-General ofDECC. Therefore, no activities or work should be undertaken within theAboriginal site areas as described in this report and marked on Figure 1,in the absence of a valid Section 90 Consent or in lieu, Part 3A approval;Single copies of this report should be forwarded for comment to theAboriginal stakeholders (Dungarn Consultancy and Nowra LALC); andAfter revision of the draft report with the responses of the Aboriginalcommunity, three copies of the final report should be forwarded to:ManagerSouth BranchEnvironment Protection and Regulation DivisionDepartment of Environment and Conservation (NSW)PO Box 2115Queanbeyan NSW 2620After implementation of these management measures, it is concluded thatthe risk of residual impacts to Aboriginal heritage from the proposal will bevery low.7.14.2 European HeritageA review of heritage schedules of SLEP 1985, the IREP No. 1, Councils’ Heritage Studyas well as a review of the National Trust register has revealed no known items ofEuropean heritage value on the factory site.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 318
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryCouncil’s Heritage Study does identify an item of environmental heritage on theCompany’s Environmental Farm, on Lot 23 DP 811233. This item is a weatherboardand iron farm house which is dated to about 1910. The Heritage Study describes thisbuilding as“Weatherboard and galvanised iron cottage reflecting the influence of theFederation style on the local Victorian Georgian idiom. The traditionalhipped roof form with encircling verandahs has been modified by theintroduction of two projecting gables which effectively truncate the verandah,restricting it to two sides. In contrast to other nearby weatherboard cottagesthe structure is clad with broad edge moulded pine boards. Windows aresimple 2x2 sash but those in the gabled projections reflect Federation style inthe use of narrow flanking fixed lights. The building appears to be supportedon brick piers. At the rear a single brick chimney defines the kitchen andadjacent skillion extension. The cottage is similar to urban forms such asCambewarra Post Office.”The Heritage Study assessed the significance of this structure as follows:“A simple weatherboard cottage reflecting the transition of the late Victorianvernacular style towards the Federation style. Characteristic of smallfarmhouses erected on land made available by the subdivision of the BerryEstate c.1900. Contributes to the Berry-Bolong pastoral landscapes. Localsignificance (Shoalhaven District).”This item however is not identified as an item of heritage significance by Council’s SLEP1985 (which was recently updated in terms of heritage sites and provisions).The factory site is located 2.0 kilometres to the south west and no works are envisagedwithin the Environmental Farm within the vicinity of this building.Under thecircumstances it is considered that the project will have no significant impact on theheritage significance of the building.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 319
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry8.0 STATEM<strong>ENT</strong> OF COMMITM<strong>ENT</strong>S – E<strong>NVIRONM</strong><strong><strong>ENT</strong>AL</strong>MANAGEM<strong>ENT</strong>This section of the EA provides a Statement of Commitments agreed to by ShoalhavenStarches Pty Ltd outlining environmental management, mitigation and monitoring measures tobe implemented to minimise potential impacts associated with this proposal and having regardto the findings of the assessment of Key Issues as outlined in Section 7.0 of this EA.The following is a Statement of Commitments as proposed by this EA, and agreed to byShoalhaven Starches:8.1 LEGISLATIVE REQUIREM<strong>ENT</strong>SAll activities carried out on the site, and in relation to the project, would comply with therelevant provisions of all relevant legislation and regulations, and would also comply withrelevant policies and guidelines relating to the construction and operation of the projectincluding, but not limited to, those detailed in Sections 8.1.1 and 8.1.2.8.1.1 Legislation and Regulations• Aboriginal and Torres Strait Islander Heritage Protection Act 1984.• Contaminated Land Management Act 1997.• Dangerous Goods Act 1975.• Environment Protection and Biodiversity Conservation Act 1999.• Environmental Planning and Assessment Act 1979.• Environmental Planning and Assessment Regulations 2000.• Environmentally Hazardous Chemicals Act 1985.• Fisheries Management Act 1994.• Fisheries Management Amendment Act 2001.• Heritage Act 1977.• Heritage Amendment Act 1998.• Local Government Act 1993.• National Parks and Wildlife Act 1974.• National Parks and Wildlife Amendment Act 2002.• Native Vegetation Act 2003.• Native Vegetation Conservation Act 1997.• Noxious Weeds Act 1993.• Occupational Health and Safety Act 2000.• Ozone Protection Act 1989.• Pesticides Act 1999.• Protection of the Environment Operations Act 1997.• Protection of the Environment Administration Act 1997.• Roads Act 1993.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 320
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Rural Fires Act 1997.• Soil Conservation Act 1938.• Threatened Species Conservation Act 1995.• Threatened Species Conservation Amendment Act 2002.• Waste Avoidance and Resource Recovery Act 2001.• Waste Recycling and Processing Corporation Act 2001.• Water Act 1912; and• Water Management Act 2000.8.1.2 Policies and Guidelines• Managing Urban Stormwater: Soils and Construction, NSW Department of Housing(1998).• Australian and New Zealand Guidelines for Fresh and Marine Water Quality,Australian and New Zealand Environment and Conservation Council, and theAgriculture and Resource Management Council of Australia and New Zealand(2000).• National Environment Protection Measures (NEPM) for Ambient Air Quality, NEPC(1998);• EPA/DECC Bunding and Spill Management Guidelines; and• Industrial Noise Policy, DEC (1999).8.2 APPROVALS, PERMITS AND LICENCESAll necessary approvals, permits and licences required by NSW legislation must beobtained prior to construction commencing. Approvals, permits and licences that may benecessary may include, but are not necessarily limited to:• The Contractor and the Proponent are obliged to notify DEC when a pollutionincident occurs that causes or threatens ‘material harm’ to the environment, underthe Protection of the Environment Operations Act, 1997.The Contractor and Proponent shall liaise with relevant government agencies to ensurethat all their requirements are met in relation to approvals, permits and licences. Therelevant government agencies include, but may not be limited to:• Department of Planning for project approval;• Department of Environment and Climate Change for potential impacts to water, air,noise, waste, flora, fauna, aboriginal heritage issues, and works in or nearwaterways; andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 321
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Shoalhaven City Council for works within the road corridor.All necessary licences, approvals and permits obtained by the Contractor and/orProponent must be complied with, maintained and renewed as necessary throughout theduration of the works.8.3 SPECIFIC COMMITM<strong>ENT</strong>S8.3.1 Construction Environmental Management PlanThe Contractor/Proponent would prepare and implement a Construction EnvironmentalManagement Plan (CEMP). The CEMP would be prepared generally in accordance withthe framework, principles and requirements detailed in AS/NZS ISO 14001:2004:Environmental management systems – Specification with guidance for use.The CEMP would be developed prior to site activities commencing, and would be fullyimplemented, maintained, reviewed, audited and updated throughout the constructionphase as may be required by the Conditions of Approval, or as otherwise directed.In addition to the generic requirements of ISO/NZS 14001 the CEMP would addressand/or develop:• All relevant Conditions of Approval and environmental requirements;• All other environmental control measures, actions, procedures and activitiesrequired to address all relevant legislation, regulations, guidelines and policies;• Environmental monitoring programs, including the identification of monitoringlocations, equipment, methodologies, analytical requirements, quality triggerlevels/thresholds, and reporting mechanisms;• Roles and responsibilities for the environmental management of the works;• Environmental training requirements, procedures, and documentation; and• A complaints management and community consultation/notification process.The CEMP would document the key environmental management measures associatedwith the construction phase of the project, which would include, but not necessarily belimited to:• General environmental management measures;• Erosion and sediment control;• Air quality (dust);Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 322
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry• Noise; and• Waste and chemical management.Further details on each key issue are provided in Section 8.0. Appropriateenvironmental mitigation and control measures for each key issue are detailed inTable 40 to Table 60.8.3.2 General Environmental ManagementTable 40Environmental Management FrameworkEnvironmental Management FrameworkEnvironmental Management FrameworkAll safeguard measures detailed in the Environmental Assessment and project approval wouldbe applied to the project.Environmental awareness training would be provided to all personnel (including all labourers/plant operators/ supervisors and engineers), and would address, but not be limited to:• Sedimentation and erosion control;• Water quality control;• Pollution control; and• DECC requirements.The training would commence at the start of construction and would continue as new personnelare engaged.A register of environmental awareness training would be established and maintained at the site.The register would contain details of the type of training, personnel trained, training dates andqualifications of the trainer.All necessary approvals, permits and licences required by NSW and Commonwealth legislationwould be obtained prior to construction commencing. These approvals, permits and licenceswould be maintained and complied with during the construction period. Liaison would occur withthe:• Department of Environment and Climate Change (water, air, noise, waste, flora, fauna,aboriginal heritage issues, works near waterways); and• Shoalhaven City Council (works within the road corridor).to ensure all their requirements are met in relation to approvals, permits and licences.All wastes would be transported by licensed waste management contractors and would bedisposed of to an appropriately licensed waste management facility.A register of public complaints would be established at time of construction commencing andmaintained for the full duration of construction. The register would record details of complaints,complainant contact information and action taken to address complaints.Any complaints received would be recorded and attended to promptly. On receiving acomplaint, works would be reviewed to determine whether issues relating to the complaint couldbe avoided or minimised. Feedback would be provided to the complainant explaining whatoutcomes resulted.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 323
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry8.3.3 Soil and Water ManagementThe potential impacts of construction activities on soil and water resources are generallyassociated with the erosion of soils and subsequent discharge of sediments or turbidrunoff to watercourses, together with pollution associated with the spillage of fuels,chemicals, and other materials into waterways.The location of some of the construction activities immediately adjacent to the banks ofthe Shoalhaven River, Bomaderry Creek and Abernethy’s Drain increases the risk ofpotential impacts to the river occurring. Environmental control measures to minimise therisk of discharges to the Shoalhaven River, are detailed in Table 41.An Acid Sulphate Soils (ASS) assessment has been undertaken by Coffey Geotechnics.ASS management would be undertaken, as required, in accordance with therecommendations of the Coffey Geotechnics report. This is dealt with separately inSection 8.3.18.Table 41Soil and Water management MeasuresSoil and Water Management MeasuresSoil and Water Management MeasuresSite-specific indicative Erosion and Sediment Control Plans (ESCPs) for the project are providedin Appendix A. The indicative ESCPs identify appropriate control measures and practices toprevent soil and erosion impacts, and discharges of turbid site runoff offsite or to the ShoalhavenRiver system. The ESCPs would be further developed by the proponent and contractor prior toconstruction commencing.All erosion and sediment control measures detailed in the ESCPs would be implemented on siteprior to construction commencing.All erosion and sediment controls would be inspected by the Contractor/Proponent at a minimumof weekly intervals and within 24 hours of all rainfall events exceeding 10 mm in a 24-hourperiod. Regular routine maintenance would be undertaken to de-silt sediment basins and traps,replace damaged sediment control fences and other structures. A register of these inspections,maintenance and rainfall levels would be maintained. One person would have overallresponsibility on site for erosion and sediment control issues.Loss of suspended solids and sediment to the Shoalhaven River, Bomaderry Creek orAbernethy’s Drain would be prevented by using (where appropriate) reverse superelevation forany excavations near the banks of the watercourses, constructing berms along the edge of thesite to prevent runoff to the river and installing silt fences along the property boundary with theriver.A silt fence would be installed between the various sites and the Shoalhaven River, BomaderryCreek and Abernethy’s Drain along the entire perimeter of the construction area, to preventsuspended solids being transported off-site. The silt fence would be constructed in accordancewith Standard Drawing SD 6-7, from the publication Managing Urban Stormwater: Soils andConstruction, NSW Department of Housing (1998).Where possible all site runoff would be collected and diverted to the site stormwatermanagement system, which would then convey it to the Environmental Farm for treatment andirrigation, thereby preventing any off-site impacts.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 324
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 41 (continued)Soil and Water Management Measures (continued)The inlet grates of the site stormwater management system would be covered with geotextile toprovide initial filtering of gross sediment pollutants before conveyance to the EnvironmentalFarm. Alternatively, the grates could be protected by implementing the control measure detailedin Standard Drawing SD 6-9 (refer Appendix B), from the publication Managing UrbanStormwater: Soils and Construction, NSW Department of Housing (1998).Works relating to drainage and sediment control would be completed promptly to minimiseexposure time of disturbed areas.Exposed areas of erodible material would be limited to those areas being actively worked.Any material stockpiles on site would be designed and located to prevent any loss of sediment,or other materials, to the Shoalhaven River system in the event of heavy or prolonged rainfallTemporary sediment control fences would be installed down slope of any stockpiles.Stockpiles would not be located within 50 m of a watercourse, in accordance with NSWDepartment of Primary Industries (Fisheries) requirements.In the event of a spillage of potentially harmful chemicals, fuels, oils or materials, the DECCwould be contacted immediately, and contaminants would be immediately contained, removed,treated (if necessary) and disposed of in accordance with DECC requirements.An incident/emergency spill plan would be developed. This would include measures to avoidspillages of fuels, chemicals, and fluids onto the floodplain and/or into any waterways. Allpersonnel would be made aware of these measures. An emergency spill kit would be keptonsite at all times.All fuels, chemicals, and liquids would be stored at least 50 m away from any waterways ordrainage lines within an impervious bunded area designed in accordance with the EPA/DECCBunding and Spill Management Guidelines.All erosion and sediment control structures would be removed only after adequate stabilisationof disturbed surfaces is achieved.Any wastewater generated from construction processes would be contained onsite and directed(where possible) to the site stormwater management system for conveyance to theEnvironmental Farm for treatment and irrigation. Where conveyance to the Environmental Farmis not possible, all stormwater would be appropriately treated to minimise the levels ofsuspended solids, oil and grease and pH being discharge to the environment. Any discharge tothe environment would be managed in accordance with the conditions of the site EnvironmentProtection Licence, and would be appropriately tested prior to being discharged.The refuelling of plant and maintenance of machinery would be undertaken within imperviousbunded areas within the compound sites, located at least 25 m away from watercourses ordrainage lines.Vehicle wash downs and/or concrete washouts would be undertaken within a designatedbunded area designed to allow wash down water to pass through filter fabric and soak away,capturing concrete particles and other solids on the fabric for later disposal. The wash downareas and washouts would be located at least 25 m away from watercourses or drainage lines.Shoalhaven Starches will commit to undertake a review of the of the factory site to identify andanalyse areas of the factory site where bunding of storage vessels and areas is not provided.Based upon this “gaps” analysis an implementation strategy can be formulated which seeks toinstigate bunding where it is necessary throughout the factory site. Such a strategy could beformalised in consultation with DECC and incorporated into a Pollution Reduction Programunder the Company’s Environmental Protection Licence.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 325
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry8.3.4 Noise and Vibration ManagementThe construction process would generate both noise from heavy plant and equipment.The Proponent/Contractor would implement appropriate noise management measuresas detailed in the Environmental Assessment (EA) and as may be required by theConditions of Approval.Shoalhaven Starches make the following commitments in terms of noise management:Table 42Noise and Vibration Management Measures – ConstructionNoise and Vibration Management MeasuresNoise Management Measures – ConstructionAppropriate noise mitigation measures would be developed and implemented throughout theconstruction process, including all commitments made in the EA, and required by the Conditionsof Approval.Unless otherwise agreed with the Director-General, construction and operation of the proposalwould be undertaken as follows:• Construction – Monday to Friday 7:00 am to 6:00 pm and Saturday 7:.00 am to 1:00 pm.No work on Sundays and Public Holidays.• Operation – 24 hours per day, 7 days per week.Construction activities may be conducted outside the hours detailed above provided that theactivities are not audible at any residence beyond the boundary of the site.Construction activities would be managed to comply with the Construction Site Noise Guidelinesset out in Chapter 171 of the Environmental Noise Control Manual (ENCM) as follows:The LA10,T noise levels emanating from the construction site shall not exceed the backgroundlevels by the following criteria, in the interval specified:− 20 dB(A) for construction activity period up to 4 weeks− 10 dB(A) for construction activity period over 4 weeks and up to 26 weeks.− 5 dB(A) for construction activity period over 26 weeks.Plant and equipment would be selected and operated with appropriate mufflers and noisecontrols and where practical work practices and plant selection would be considered so as tominimise noise impacts.High efficiency mufflers would be used on all construction equipment and manufacturer’s noisecontrol equipment would remain intact. All construction equipment would be well maintainedand serviced.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 326
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 43Noise Management Measures – OperationsNoise Management Measure - OperationsFor this project the residential noise emission target is set at 15 dB(A) below the EPL targetlimits at the reference locations as follows:The LA10 (15 minute) sound pressure level contribution generated from the Ethanol Upgradeproject must not exceed the following levels when measured at or near the boundary of anyresidential premises:− 23 dB(A) at locations in Terara on the south side of the Shoalhaven River.− 23 dB(A) at locations in Nowra on the south side of the Shoalhaven River.− 27 dB(A) at locations in Meroo Street, Bomaderry.− 25 dB(A) at other locations in Bomaderry.Shoalhaven Starches commits to designing and building the proposed works to ensure theproposal does not exceed the above emission targets.In order to achieve these noise design targets, Shoalhaven Starches commits to the followingnoise control measures:• Product Dryer − Equipment to be housed in a building that will be constructed ofUltrapanels having an Rw of not less than 35. The upper 3 floors of thebuilding and the roof are to be constructed of material having an Rw of notless than 17 (Colourbond or similar).• FermentersAny equipment that has a sound power level above 80 dB(A) is to beenclosed in a separate room with the walls and ceiling/floor having an Rwof not less than 40.− Transfer pumps are to be enclosed with material having an Rw of not lessthan 15.• Fermenters – Cooling Towers – During night time period fan speed of the 6 coolingtowers is to be reduced to 60% of full fan speed. Fan speed is to beautomatically adjusted (computer or time clock controlled).• Molecular Sieve − Molecular sieve pumps and compressors are to be enclosed withmaterial having an Rw of not less than 35.• Molecular Sieve – Cooling Towers − During night time period, fan speed of the 6 coolingtowers is to be reduced to 60% of full fan speed. Fan speed reduction is tobe automatically adjusted (computer or time clock controlled).• Cooling Towers − During night time period, fan speed of the 6 cooling towers is to bereduced to 60% of full fan speed. Fan speed reduction is to beautomatically adjusted (computer or time clock controlled).Water pumps numbers 1 - 4 are to have noise control measures (orreplaced) in order to have a sound pressure level of 68 dB(A) at 1 metre.• DDG Dryers − The majority of the equipment will be housed in a building that will beconstructed of Ultrapanels having an Rw of not less than 35.Any equipment that has a sound power level above 90 dB(A) is to beenclosed in a separate room with the walls and ceiling/floor having an Rwof not less than 40.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 327
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 43 (continued)Noise Management Measures – Operations• DDG Pellet Plant − The majority of the equipment will be housed in a building that will beconstructed of Ultrapanels having an Rw of not less than 35.Any equipment that has a sound power level above 90 dB(A) is to beenclosed in a separate room with the walls and ceiling/floor having an Rwof not less than 40.• Odour Scrubber − Equipment will be housed in a building (walls and ceilings/roof) that willbe constructed of material having an Rw of not less than 35 such asUltrapanels.• Evaporator −The majority of the equipment will be housed in a building (walls andceilings/roof) which has to be constructed of material of an Rw of not lessthan 25.The two turbo fans are to be enclosed in a separate room with the wallsand ceiling/floor having an Rw of not less than 40.• Co-Generator − At this stage of the development application, sound level data for the Co-Generator is not available. However the maximum sound power level of 93dB(A) from all discharges from the Co-Generator building has been derivedto maintain compliance with the design criteria.• Gas Fired Boiler − To maintain compliance with the design criteria the discharge of theduct is to achieve an attenuation of 25 dB(A) so that the sound pressurelevel from the discharge duct does not exceed 72 dB(A) at 1 metre.• Packing Plant − All walls and the roof/ceiling is to be constructed of material having an Rwof not less than 35 dB(A).• Container Loading Area−−−−−The forklift that is used for the loading and stacking of containers is tohave a maximum sound pressure level of 80 dB(A) at 1 metre.The northern end of the container loading area is to have a solidmasonry wall not less than 8.5 metres in height and the western andeastern end of the container loading area is to have a solid masonrywall not less than 8 metres in height.There will be no train movements on the spur line that forms part ofthe container loading area between the night time period of 10:00 pmto 7:00 am.During the night time period (10:00 pm to 7:00 am) the forklift truckswill only stack two containers high at locations within 10 metres fromthe wall and only one container high above the ground for locationsmore than 10 metres from the wall.No loading of the train in the proposed container loading area will takeplace during the night time period.• Blowers at <strong>Manildra</strong> Environmental Farm − The blowers will have enclosures that result ina sound pressure level of 70 dB(A) at 1 metre.• Emergency Fire System − The fire pumps are only utilised for emergency and a maximumof 1 hour per week during the day time for testing purposes only, and donot form part of the EPA criteria under normal plant operations.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 328
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry8.3.5 Traffic, Access and ParkingChristopher Stapleton Consulting Pty Ltd has prepared a detailed and independentassessment of the access, traffic and parking issues associated with the Proposal,utilising available data, design standards and traffic analysis models.ShoalhavenStarches commits to the following actions (Table 44) to achieve appropriate transportoutcomes for the site.Table 44Traffic, Access and ParkingTraffic, Access and Parking• Access Point 2 will be upgraded following approval of final design plans by the relevantlocal authorities. The upgrade will be implemented as part of the approved SSFM Project,and will be completed prior to commencement of operation of the approved Flour MillProject. The design of this intersection is to be integrated with respect to the proposedpedestrian crossing of Abernethy’s Creek; the proposed pedestrian/product overheadbridge; and the vehicular access to the proposed Packing Plant.• Access Point 3 will be upgraded following approval of final design plans by the relevantlocal authorities. The upgrade will be implemented as part of the approved SSFM Project,and completed prior to commencement of operation of the approved Flour Mill Project.• A new left in only ingress driveway will be provided from Bolong Road to the packagingplant following approval of final design plans by the relevant local authorities.• The packaging plant driveway to Railway Street will be upgraded to full compliance with theappropriate AS 2890.2:2002 design standards.• The gates providing access to the primary Site car park (Access Point 4) will remain openat all times to allow for the separation of ingress and egress movements; thisrecommendation has already be implemented by <strong>Manildra</strong>.• That rail movements continue to be – as far as practicable – scheduled outside of localpeak periods, and specifically outside of the morning and afternoon commuter peakperiods, though it is acknowledged that <strong>Manildra</strong> does not have direct control over thescheduling of rail movements.• That <strong>Manildra</strong> continues to provide heavy vehicle drivers with information and training inregard to the use of the designated restricted access vehicle route by restricted accessvehicles, and the availability of on-site parking areas.• That <strong>Manildra</strong> works constructively with SCC, the RTA and local community through anyfuture implementation of local heavy vehicle route changes; this may include changes tothe use of the local industrial vehicle route and key regional routes.• That <strong>Manildra</strong> provides additional on-site parking including 40 spaces within theMoorhouse maintenance workshop area, 34 spaces at the proposed Packing Plant site and20 spaces east of the coal storage area (for contractors).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 329
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry8.3.6 Air Quality ManagementConstruction activities have the potential to generate dust. Shoalhaven Starchescommits to managing potential dust and air quality issues during construction byimplementing appropriate control measures, including those detailed in Table 45.Table 45Air Quality Management MeasuresAir Quality Management MeasuresAir Quality Management MeasuresAppropriate air quality mitigation measures would be developed and implemented throughoutthe construction process, including all commitments made in the EA and required by theConditions of Approval.Regular on-site watering of dust-generating materials would be used to control dust generationduring construction. Adequate dust suppression resources would be available on site to reducedust emissions.ir Quality Management MeasuresAdditional measures implemented to reduce dust emissions during construction would include:• Alternative timing of dust generating activities;• Stopping of construction activities in very high wind conditions;• Consideration of quickening of work in problem areas;• Use of wind direction to advantage;• Ensuring trucks are covered at all times when transporting materials;• Stabilisation of exposed areas as quickly as possible and within 14 days after completion ofworks;• Confining vehicle movements to designated areas and routes; and• Appropriately located stockpile and compound sites.The extent of exposed and unprotected areas would be limited by preserving existinggroundcover (through staged clearing), and all disturbed areas would be stabilised as soon aspossible.Loads with the potential to generate dust would be covered during transportation on publicroads.Exhaust systems of construction plant, vehicles and machinery would be maintained inaccordance with manufacturer’s specifications and the exhaust emissions would comply with therequirements of relevant legislation.No open fires would be permitted on the project.Stockpiles would be kept to a minimum.Where practicable, specific areas of the construction site (eg. areas containing stockpiles) wouldbe fenced with shade-cloth to minimise wind erosion and the transport of dust beyond the siteboundary.Any stockpiles with the capacity to cause dust would be dampened or covered to suppress dust.When dust is visually detected, the frequency of watering would be increased. Dust generatingactivities would be reprogrammed to avoid periods of high wind velocity.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 330
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 45 (continued)Air Quality Management MeasuresIf works are creating high levels of dust that are likely to cause discomfort to local residents or asafety hazard to work personnel, the works would be modified or stopped until the dust hazard iseliminated or has been reduced to an acceptable level. Tailgates would be secured during theoperation of trucks and utes. All haulage vehicle loads would be covered while transportingmaterial to and from the work area.Machinery would be turned off, rather then left idling for long periods.8.3.7 OdoursBased upon the air pollution emission inventory and dispersion modelling for theproposed ethanol upgrade odour and particulates were assessed against legislatedmaximum ground level concentrations.All constituents assessed over all relevantaveraging times were below their respective assessment criteria for the adoptedemission characteristics, with the exception of odour. Odour was found to be the criticalconstituent for compliance with the DECC air quality impact criteria. As a result of thesefindings and the conclusions of the Air Quality Assessment carried out by GHD Pty LtdShoalhaven Starches commit to the following actions.Table 46OdoursOdoursShoalhaven Starches commit to the odour control measures as detailed in Table 5-1 of the AirQuality Assessment and which are summaries in Table 7 of this EA.Shoalhaven Starches also commit to expand on the Odour Management Plan as detailed in thisEA and the Air Quality Assessment, by detailing procedures with respect to routinehousekeeping/ductwork cleaning and assigning responsibility for these actions. The OdourManagement Plan will also provide protocol in terms of outlining a program for such actions.Shoalhaven Starches furthermore commit to treat waste water generated from factory processsequentially through anaerobic and aerobic digestion systems to be established within theexisting approved wet weather storage Pond No. 7, and as described in Section 5.8.2 of the EA.Furthermore Shoalhaven Starches will commit to the implementation of the above odour controlmeasures in three stages, in a manner as detailed in Table 5-1 of the Air Quality Assessmentprepared by GHD Pty Ltd and which is summarised in Table 7 of this EA.The staging of the odour control implementation proposed by Shoalhaven Starches is based onthe prioritisation of the odour sources as presented in Table 3-1 of the Air Quality Assessmentprepared by GHD Pty Ltd.The timing for each odour control stage will be as follows:• Stage 1 – April 2009 (subject to date of approval) includes:− duct high priority DDG (liquid and solid lines) odour sources to the bioscrubber;− install wet-legs on key odour sources that are not ducted to the bioscrubber at this stage;Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 331
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 46 (continued)− clean starch and gluten dryer ductwork;− improve factory housekeeping;− pelletise DDG product; andOdours− decommission designated odour sources.• Stage 2 – to reassess within 6 months of completion of Stage 1 and implementing Stage 2odour controls as required, includes:− duct medium priority odour sources to the bioscrubber; and− investigate feasibility of directing individual starch and gluten dryer discharge pointsupwards and increasing stack heights;• Stage 3 – if required, depending on outcomes at Stage 2, includes:− duct individual starch and gluten dryer discharge points to a common tall stack (CTS);− duct low priority odour sources to the bioscrubber.To assess the outcomes of each stage of the odour management controls Shoalhaven Starcheswill undertake the following measures:1. Following completion of each stage of odour control measures, a meeting will be held withthe Community Consultation <strong>Group</strong> to ascertain whether members of the community haveexperienced improvement in terms of odours.2. A review will also be undertaken of the number and nature of complaints received by theCompany in connection with odours.If following these measures it is evident that there is a reduction in the number of complaints;and the local Community Consultation <strong>Group</strong> indicate improvements, then works associated withsubsequent stages will be deferred.However if there is no demonstrated improvement, then odour monitoring will be undertaken tofurther evaluate odour control measures.If as a result of this monitoring it is found that odours are still emanating from the site, worksassociated with subsequent stages of the odour management plan will be undertaken.In terms of formulating procedures and establishing responsibility for undertaking routinehousekeeping/ductwork cleaning it is proposed that these activities will be included in theCompany’s maintenance program and would be undertaken and completed as programmed. Itis envisaged that inspections would be undertaken monthly with cleaning every 3 months.8.3.8 Greenhouse Gas EmissionsIn order to minimise greenhouse gas emission (ie. those generated on the site)Shoalhaven Starches commit to the following:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 332
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAdoption of best available technologyTable 47Greenhouse Gas EmissionGreenhouse Gas EmissionThe proposed plant will incorporate a gas fired co-generation plant. This represents the bestavailable technology economically achievable to meet the heat and energy needs of theproposed plant.Additional equipment for the proposed plant, such as fermenter tanks, cooling towers, dryers,evaporators will be designed to minimise energy use.Greenhouse Gas CaptureThe proposed new wastewater treatment system will include the 100% capture of biogasgenerated and will be re-used for energy generation. This will effectively reduce greenhousegas emissions by 31,000 tonnes per annum, and will recover 260 TJ annually, further reducingShoalhaven Starches consumption of fossil fuels.Fuel use switchingNatural GasThe proposed plant will mainly use natural gas as the primary fuel source. Natural gas producesmuch lower greenhouse gas emissions than the amount of coal of equivalent energy.CoalShoalhaven Starches regularly review the economic situation concerning energy costs.Shoalhaven Starches commit to continually reviewing and seriously considering the potential toconvert the Company’s energy requirements from coal to natural gas subject to:− The availability of local natural gas infrastructure.− The capacity of the Eastern Gas pipeline.− Concerns of over reliance on single energy sources.DieselShoalhaven Starches uses 660 KL of diesel fuel annually, and this volume will not changefollowing the upgrade. Switching to a bio-diesel blend, emissions could be reduced.Shoalhaven Starches commit to reviewing this potential however at present they have nopresent plans to consider such a conversion.8.3.9 Waste and Chemical ManagementThe potential environmental impacts associated with spillages of chemicals, fuels andoils to both water and soils would be minimised through the implementation of detailedcontrol measures designed to minimise the risk of such spillages occurring. In addition,appropriate waste management measures would be implemented to ensure that waste isavoided, minimised or recycled wherever possible, or responsibly disposed of offsite.Appropriate mitigation and management measures to which Shoalhaven Starchescommit are detailed in Table 48.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 333
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 48Waste and Chemical Management MeasuresWaste and Chemical Management MeasuresWaste and Chemical Management MeasuresAn incident emergency spill plan would be developed and implemented as required. This wouldinclude measures to avoid spillages of fuels, chemicals, and fluids into any waterways. Allpersonnel would be made aware of these measures. An emergency spill kit would be keptonsite at all times.Storage areas for fuels, oils and chemicals would be surrounded by impervious bund walls tocontain any spillage. Bunds would be designed in accordance with the EPA/DECC Bunding andSpill Management Guidelines and would contain at least 110% of the volume of the largestcontainer. Storage areas would not be located within 50 metres of any waterway, on slopesabove 10%, or near areas of native vegetation. All precautions would be taken to eliminate fuelor other spills.The storage of chemicals on site would comply with the requirements of relevant authorities(DECC and Workcover).A schedule of all hazardous materials in use on the works would be maintained and recorded forthe duration of the construction.Refuelling operations would not be left unattended whilst refuelling is in progress. Refuelling ofplant and maintenance would not occur within 25m of waterways or sensitive areas.The refuelling of plant, and maintenance of machinery, would be undertaken within imperviousbunded areas.Should any spillage of fuels, oils, chemicals or other potentially hazardous/polluting materialsoccur during construction the DECC would be contacted immediately, and contaminants wouldbe immediately contained, removed, treated (if necessary) and disposed of in accordance withDECC requirements.All wastes would be transported by licensed waste management contractors and would bedisposed of to an appropriately licensed waste management facility.The construction site would be maintained in a clean and tidy condition. Covered bins would beprovided for waste disposal.The Resource Management Hierarchy principles of the WARR Act would be adopted as follows:• Avoid unnecessary resource consumption as a priority;• Avoidance would be followed by resource recovery (including reuse of materials,reprocessing, recycling, and energy recovery); and• Disposal would be undertaken as a last resort.In order to facilitate waste management arising from the proposal Shoalhaven Starches committo the following actions:• Waste Management Database is established to track volumes of waste being generated.• Where they don’t already exist, the Environmental Manager, or their delegate, developwritten agreements with all “waste” disposal companies for those wastes that are taken offsitefor re-use, reprocessing / disposal. The agreement should specify, but not be limitedto:−−−−The name of the companyWhat materials / waste that are taken off-siteWhere material is being transported to.Disposal method – landfill, re-used, reprocessed etc.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 334
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry−−−−Pick-up intervalTable 48 (continued)Waste and Chemical Management MeasuresReporting requirements – eg. providing Shoalhaven Starches with monthly or quarterlyreports on the volume of waste pickup.Records on the volume of waste pickup.Records / licences / permits allowing companies to transport and disposal of thewaste.• Maintaining copies of all written agreements.Measures to avoid, reduce, re-use and recycle waste products including soil, pavementmaterials, concrete, and oils would be implemented.If concrete agitator trucks are to be washed out on site, impermeable bunded areas would beconstructed to contain wash out water and allow the concrete residue to settle. The concreteresidue would be incorporated into the works or disposed of at a licensed waste or recyclingfacility.All construction materials, surplus soils and wastes generated from the site would be stockpiledand stored at the site prior to reuse, recycling or disposal. Measures would be implemented toprevent any scouring or loss of stockpiled materials during flood events.Wastes would not be stored for long periods during construction of the site. Empty drums offuels, oils or chemicals and fluids would not be stored on site during construction.Disposal of materials or equipment in the Shoalhaven River, Bomaderry Creek or Abernethy’sDrain would be strictly prohibited.Materials or equipment that fall into or adjacent to the Shoalhaven River, Bomaderry Creek orAbernethy’s Drain would be recovered immediately.Waste material generated would be reused or recycled where possible.8.3.10 Waste Water and Irrigation ManagementTable 49Waste Water and Irrigation ManagementWaste Water and Irrigation ManagementShoalhaven Starches commit to the installation of a full biological wastewater treatment plant tominimise the amount of bio-degradable organic substances in the combined effluent(“condensate” and “washdown” streams) from the Shoalhaven Starches plant. Full biologicalwastewater treatment will be implemented prior to the commencement of the upgrade to theethanol production process. After biological treatment a further two tiers of physical filtrationprocesses will be installed to enable treated water to be utilised for particular re-useapplications.The Waste Water Treatment Plant will include the establishment of a Bulk Volume Fermenter(BVF) as described in Section 7.3.2 of the EA. The BVF will be completely enclosed with afloating insulated cover to prevent the emanation of odours.Waste water from the BVF will be directed to either:• A Sulphur Oxidation (SO) basin. Waste water treated in the SO basin will be directed to theEnvironmental Farm (3.6 ML/day).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 335
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 49 (continued)Waste Water and Irrigation Management• A Membrane Bio-Reactor (MBR) and Reverse Osmosis (RO) Plant. Treated waste waterfrom the MBR / RO Plant will be re-used in the factory processes (4.5 ML / day).Routine micro-biological and pesticide / toxicity testing of treated water from the MBR / RO Plantwill be undertaken to ensure that treated water complies with the potable water standardsoutlined in the NHMRC Drinking Water Guidelines 2004.Wastewater with 100% retentate will be used for irrigation on the environmental farm.Adverse changes will occur gradually and careful monitoring of the soil will provide an advancewarning. Issues that will be important are the soil salinity and the ionic composition of the soilsolution, especially calcium concentration. Better information on the detailed composition of thewastewater that is used for irrigation, and annual soil and pasture sampling of a few selectedpaddocks will also improve the predictive capabilities. If field experience shows an unacceptableincrease in soil salinity or an adverse effect on pasture productivity the quantity of retentateirrigated may need to be reviewed and modified.The following measures are to be implemented with any future Irrigation ManagementPlan for the Environmental Farm:Scenario 1• Monitor soil properties in irrigated paddocks in top 30 cm of profile (to guidemanagement, especially use of fertilisers and irrigation regime).Apply nitrogenfertiliser after each cut of forage; about 100 kg N/ha at least twice in the first year,more in later years• Apply potassium fertiliser after each cut (preferably as potassium nitrate, dependingon cost, potassium chloride is second preference) at least 250 kg K /ha in first year,rising to 500kg K/ha after 3 years; soil monitoring data to be used as a guide here.• Investigate use of lower rates of magnesium hydroxide in the wastewater treatmentprocess• Consider applying a leaching irrigation, if rainfall is low, to move excess magnesiumout of the topsoil to the lower horizons.8.3.11 Hazard and Risk ManagementAll possible safeguards would be employed to ensure that the potential for deflagrationof wheat and / or flour is minimised.Table 50 outlines recommended management procedures and design considerationsthat Shoalhaven Starches commits to implementing and incorporating into practices thatwould prevent risk scenarios occurring.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 336
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 50Hazard and Risk Management MeasuresHazard and Risk Management MeasuresThe off site risk assessment completed for the proposed ethanol production upgrade is incompliance with the DoP risk criteria given in HIPAP No. 4. However, it is recommended toidentify opportunities during the design phase of the project to improve the safety of theprocess. This can be achieved through design reviews and appropriate safety studies.The following actions will be implemented to improve the safety of the proposed upgrade:1. Complete the Hazard and Operability (HAZOP) for the new plants i.e. co-generation, gasfired boiler and molecular sieve at the completion of the detail design;2. Review the impact of the increased production capacity on the existing process units(vessels and pipes) with respect to mechanical integrity;3. Consider completing a traffic risk assessment with respect to increased traffic movementassociated with raw materials and ethanol movement to and from the site;4. Review the fire fighting capability with respect to new plant and equipment such as theco-generation plant and gas fired boilers;5. Review the emergency shutdown system and emergency procedures with respect to thenew plants (co-generation and boiler).8.3.12 FloodingDetailed consideration needs to be given to flood hazard and structural assessment of(with regard to velocity of floodwaters and impact by flood debris) the proposeddevelopment.In quantifying the flood hazard, Table 51 identifies the issues that Shoalhaven Starcheswill need to consider as part of detailed engineering design prior to the issue of aconstruction certificate for the development.Table 51Flood Hazard IssuesFlood HazardShoalhaven Starches cannot directly negate the hydraulic impacts of the works it hasconstructed or proposed to construct. For example it is not possible to construct a wet weatherstorage or wastewater treatment pond of the required dimensions with no increases in floodlevel or construct plant or associated works which does not in some way obstruct a flow path(eg. railway spur line, container storage).In order to compensate for the adverse impacts of the existing and proposed works, a range ofmanagement measures have been considered which will at least partially offset the potentialincreases in damages caused by the cumulative impacts of the existing and proposed works onthe northern floodplain since 1990.In addition to the above Shoalhaven Starches also commit to undertaking an assessment of thepotential affect of future climate change may have on flooding impacts prior to exhibition of thisEA. Such an assessment will be undertaken in accordance with the DECC “Floodplain RiskManagement Guidelines – Practical Consideration of Climate Change”.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 337
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry8.3.13 Riparian and Riverbank StabilityThe major cause of erosion occurring on site is from fluvial scour, a natural geomorphicprocess within an active floodplain that has been amplified by the lack of healthy, diverseand contiguous riparian vegetation along the foreshore of each waterway. It is unlikelythat major revegetation works within the riparian zone will arrest bank recessionoccurring as a result of fluvial scour. However, increasing groundcover and promotingbinding root growth as close to the toe of the bank as close as possible may slow therate of bank recession. The success of revegetation as a means of stabilising areasprone to recession is dependant on the physiological ability of plant species to bind thesoil. Most large trees have a root system reaching up to 3 m in depth and a lateralextension similar to the width of the crown. Given these circumstances ShoalhavenStarches commit to the following:Shoalhaven RiverTable 52Riparian and Riverbank StabilityRiparian and Riverbank StabilityThe bank of Shoalhaven River ranges between 2 - 5m with steep slopes due to continuousfluvial scour. The eastern section of the foreshore does not have an appropriate setback andis dominated by Coral trees and other weeds which further undermine bank stability. Theeffectiveness of revegetation works on the top of the bank will be limited by bank height as theroot system of mature trees is unlikely to reach the watertable. The slope, changing flowdirection and weed infestation will limit the effectiveness of revegetation works on the bank.Shoalhaven Starches therefore commit to:• Planting fast growing native species at the top of the bank to slow surface erosion andallow time for the establishment of slower, deep rooted trees which will act to protect thebank, in part, in the future.• Planting deep native rooted trees behind the bank along the western section (betweenBomaderry and Abernethy’s Creek) and enhancement of understorey and groundcoverspecies, with particular focus on known areas of erosion.Bomaderry CreekBank stability along the frontage of the southern section is undermined by poor structural andfloristic diversity, areas of exposed earth and weed infestation. The bank ranges from 1 – 3 mabove the water surface and a number of large mature trees were recorded, indicating thepresence of a binding root system potentially reaching the water table. Shoalhaven Starchestherefore commit to the following enhancement measures to improve riparian health and bankstability, particularly in the southern section:• Planting mangroves on the lower bank and sandy sediments at the mean high water mark.• Revegetation of the mid and upper bank with native species in conjunction with weed controlmeasures (discussed below).Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 338
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryAbernethy’s CreekTable 52 (continued)Riparian and Riverbank StabilityThe riparian zone of Abernethy’s Creek is high degraded due to weed infestation and lack ofan appropriate setback from the factory. Bank stability in the upper section has beenundermined by the removal of vegetation and bank erosion along the waterline was evident.Tree planting along Abernethy’s Creek is problematic due to the lack of space and highmodification associated with the factory, and prevalence of weeds. Shoalhaven Starchestherefore commit to the following enhancement measures to improve bank stability andriparian health:• Planting of canopy species at approx 5 – 10 m intervals along the top of the bank, wherepossible.• Weed suppression until canopy species are of sufficient size to ‘shade out’ weed species.• Weed control measures to prevent further infestation (complete removal will most likelyreduce bank stability in the short to mid term).• Revegetation of the western side of the creek, north of Bolong Rd, with native canopy,midstorey and groundlayer species.• Effective dialogue will be required to reach an agreement with Shoalhaven City Councilregarding ongoing access for dredging activities.Broughton CreekSections of Broughton Creek have been subject to bank scour due to superelevated waterlevel and flow associated with the outside edge of meanders, and further amplified by poorstructural and floristic diversity. Unfortunately previous enhancement trails using mangroveshave not been successful due to bank failure and burial of seedlings. Bank height is estimatedat average between 2 – 3 m with an almost vertical slope. Significant areas are covered withdense Kikuyu grass, which is likely to out-compete new plantings with continued maintenance.Shoalhaven Starches therefore commit to the following enhancement measures to slowongoing erosion leading to bank stabilisation:• Planting fast growing native shrub species along the bank and canopy species behind thebank in areas prone to bank failure.• Spot controlling Kikuyu grass to provide adequate space for native species to grow.Shoalhaven Starches acknowledge that widespread spraying of Kikuyu is not recommendedas it would reduce the cover and bank stabilisation provided by this species8.3.14 Weed ManagementExtensive weed infestations were identified along all of the waterways bordering ortraversing through the property including a number of noxious weeds listed under class 4and 5 of the Shoalhaven Local Government Area. Plans of Management for the controland eradication of class 4 weeds have been published by Council, and detail thefollowing actions that Shoalhaven Starches commit to undertaking:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 339
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 53Weed ManagementWeed Management• Constant suppression of African Boxthorn and Blackberry.• Suppression and removal of Large Leaf Privet and Small Leaf Privet from urban areas.• Further clarification for privet identified onsite may be required to the zonings of 4(a)General Industrial and 7(f3) Environmental Protection Foreshores.• Removal of Lantana where it supports local Council and Volunteers efforts.The removal of African Boxthorn and Blackberry will be most effectively achieved by ‘spot’spraying using appropriately registered herbicide due to the low number of individuals sightedthroughout the site. The species was most prevalent in the riparian area of Bomaderry Creek.Shoalhaven Starches therefore commit to ongoing monitoring to ensure control measures areeffective and weed species have not re-established.Significant areas of lantana were identified onsite, with dense thickets recorded adjacent toBomaderry Creek and in a number of locations along Broughton Creek. Shoalhaven Starchescommit to removing some patches to improve overall ecosystem health and allow the reestablishmentof midstorey and groundcover species. Removal of Lantana should beconducted in conjunction with understorey replanting and enhancement.Lantana is shallow rooted and unlikely to contribute greatly to bank stability. The removal ofLantana from bank edges and slopes should allow deeper rooted native species the opportunityto establish and improve bank stability. Lantana is easily removed by cutting and mulching backinto the ground. This method will provide some soil protection following weed removal to reduceboth erosion and further weed infestation.8.3.15 Stock ExclusionStock currently graze a small section of foreshore along Broughton Creek during floodevents (approx twice a year). Current grazing distances range between 5 to ~ 15 m fromthe mean high water mark.Table 54Stock ExclusionStock ExclusionShoalhaven Starches commit to establishing a stock exclusion zone be established from the topof the bank to a minimum 15 m. This would provide sufficient area for the development of asacrificial fast growing edge and longer term establishment of larger canopy species for longterm bank stabilisation. In areas where 15 m exclusion is not possible, a small riparian zone willbe established behind the bank to avoid browsing and trampling of newly planted species.8.3.16 Vegetation Management PlanShoalhaven Starches commit to developing a Vegetation Management Plan (VMP) forthe factory site and Environmental Farm to ensure riparian areas are managedappropriately and in accordance with strategic objectives. The VMP will outlinemanagement zones and establish guidelines riparian management, focusing on therequired actions to carry out the above recommendations. In addition, the VMP willCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 340
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderryincorporate site specific measures relating to personnel access, weed management,incident management, ASS, surface drainage and erosion controls.Bank PositionTable 55Species list for Revegetation and Enhancement of Riparian ZonesVegetationLayerSpeciesRear of Bank Canopy Eucalyptus robusta, E. Botryoides, E. amplifolia, E.tereticornis, Casuarina glauca, Acacia mearnsii, AngophorafloridundaMidstoreyMyoporum acuminatum, Glochidion ferdinandi, RapaneavariablisGroundlayer Lomandra longifolia, Carex appressa, Gahnia clarkei,Dichondra repens, Centella asiatica, Tetragonia tetragonoides,Microlaena stipoids, Einadia hasata, Rhagodia candolleanaTop of Bank Canopy Casuarina glauca, Acacia mearnsii, Acacia maidenii,Melalueca stypheliodes, M. LinarifoliaOn waterline(if possible)MidstoreyMyoporum acuminatum, Glochidion ferdinandi, Rapaneavariablis, Gahnia clarkeiGroundlayer Lomandra longifolia, Carex appressa, Gahnia clarkei,Dichondra repens, Centella asiatica Juncus kraussii, Juncususitatis, Commelina cyanea, Tetragonia tetragonoides,Microlaena stipoids, Einadia hasata, Rhagodia candolleanaCanopyMidstoreyAvicennia marina (high water mark), Casuarina glauca,Melalueca stypheliodes, M. LinarifoliaMyoporum acuminatumGroundlayer Lomandra longifolia, Carex appressa, Gahnia clarkei,Dichondra repens, Centella asiastica, Juncus kraussii, Juncususitatis, Lobelia alata, Commelina cyanea, Baumea juncea,Persicaria decipiens, Tetragonia tetragonoides, Apiumprostratum, Triglochin striata, Rhagodia candolleana8.3.17 Visual AmenityIt is considered that the proposed works will not create a significant adverse visualimpact due principally to the existing significant industrial development on the site.Shoalhaven Starches however commit to the following measures as outlined in Table 56to assist in screening and further minimising visual impacts.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 341
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 56Visual Impact Mitigation MeasuresVisual Impact Mitigation Measures• The existing screening vegetation around the site is effective, particularly along the riverbank, however additional supplementary plantings of dense bands of native trees andshrubs along the southern boundary of the site with the river (particularly between the riverand the proposed evaporator columns) would further reduce the visibility of thedevelopment. In this regard a landscape and revegetation plan should be prepared for thatportion of the site zoned 7(f3) with suitable riparian vegetation and including trees whichwill grow to a height to soften the view of these works. Such a plan should be preparedprior to works commencing on the site.• In order to reduce the visual impact and the proposed Fermenters, the northern andeastern boundaries of the site should be landscaped with a combination of trees andshrubs. Landscaping should also be incorporated between the packing plant / containerloading yard to Bolong Road to soften the appearance of this development to Bolong Road.The abovementioned landscape and revegetation plan should also detail such landscapingmeasures.• Where planting has already been established, measures should be taken to protectexisting vegetation during the construction phase.• In addition to landscaping, new structures can be constructed and treated to reduce visualimpact. Where appropriate and possible, buildings and structures should be constructed ofsimilar materials as those previously used on the site and be of a non-reflective nature.Colours should blend with existing structures on the site to ensure visual harmony.Consideration should be given to incorporating a cladding colour which will blend with thesurrounding locality.• The exterior elements of the proposed overhead pedestrian / product bridge across BolongRoad should be designed to enhance its architectural and visual qualities commensuratewith this “gateway” site.8.3.18 Site Contamination and Acid Sulphate SoilsAcid Sulphate Soil ManagementAcid sulphate soil risk maps suggest that the majority of areas being assessed are in anarea with a low probability of acid sulphate soil occurrence. The area of the proposedwater treatment and filtration plant near the effluent ponds is closer or within a high riskarea. Field screening and laboratory results indicated that ASS were not likely to bepresent in the central and eastern plant areas and fire service area. ASS are likely to beencountered within the packing plant (particularly the lower lying areas, north and east)and were confirmed in this assessment. For the remaining areas (western plant area,gas facility, near Pond 7, and pipeline routes) ASS are likely to be sporadic. ShoalhavenStarches makes the following commitment:Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 342
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryTable 57Acid Sulphate Soil ManagementAcid Sulphate Soil ManagementAn Acid Sulfate Soils Management Plan (ASSMP) will be prepared for the packing plantand areas of the site where soil disturbances are likely to intersect ASS. Depending onfurther details of the proposed development and level of disturbance, further assessmentwill be carried out to increase the confidence in the lateral and vertical extent of the ASS.It is probable that acid sulphate soils could occur at depths beyond those assessed in theassessment carried out by Coffeys. Should the proposed depth of disturbance change ordifferent soils be encountered, then this would need to be re-assessed.Site ContaminationThe results of the contamination assessment carried out by Coffeys identified sevenmain potential AECs within the areas being the subject of this assessment based on thepast and present activities identified from the site history study. The AECs were notedas having between a low and moderate likelihood of contamination.In general, preliminary soil sampling in the majority of the areas assessed did not showevidence of contamination.Table 58Site Contamination Assessment and ManagementSite Contamination Assessment and ManagementIn light of the recommendations of Coffeys in terms of site contamination, Shoalhaven Starcheswill commit to engaging a suitably qualified consultant (such as Coffeys) to prepare a Scope ofWorks to investigate the best means of remediating asbestos contamination on this portion ofthe site. This Scope of Works will investigate which approach either:• development of an Asbestos Removal Plan; or• encapsulation.Is the preferred approach for treating asbestos contamination on this site. This is the preferredapproach as it will enable detailed construction plans to be formulated; and a detailed costing ofthe two alternatives to be considered.Shoalhaven Starches also commit to ensuring that all contractors involved in construction workson the site are instructed that if there is any evidence of potential contamination (as evidencedby odorous soils, stained soils, unusually discoloured soils) then Coffey Environments should becontacted immediately to make an assessment of these soils for contamination.Shoalhaven Starches also undertake to ensure that all excess soil that requires disposal offsitewill be classified in accordance with the DECC (2008) Waste Classification Guidelines.Shoalhaven Starches will also undertake to ensure that fill soils in the upper parts of the soilprofile will be kept separate to underlying natural soils.In terms of groundwater, Shoalhaven Starches in conjunction with a suitable qualified consultantwill commit to appropriately testing groundwater if groundwater is intersected as part of anyconstruction works.Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 343
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry8.3.19 Flora and FaunaThe Flora and Fauna Assessment prepared by KMA concludes that the proposedupgrade will have little impact on native flora and fauna. There are no areas of highconservation value on the site. The proposal is not likely to have an adverse impact onspecies, populations and communities listed under the New South Wales ThreatenedSpecies Conservation Act, 1995 and the Commonwealth Environment Protection andBiodiversity Conservation Act, 1999; no threatened species, populations or communitiesare known to occur on the subject land or are expected to occur there. The preparationof a Species Impact Statement (SIS) nor referral to the Commonwealth EnvironmentMinister for approval is therefore not warranted.Table 59Flora and FaunaFlora and FaunaShoalhaven Starches commits to the following actions as recommended by the Flora & FaunaAssessment prepared by KMA with respect to this proposal:• As far as is practicable, given the presence of the factory, the verges of Abernethy’s Creekshould be planted with native species.• Appropriate screen plantings should be installed around the packing shed/loading area;local native species should be used for this purpose.• Additional plantings should be made in the environmental protection zone near theShoalhaven River.• The list of local native species at Appendix 1 of the Flora and Fauna Assessment(Annexure E) should be utilised in the planting programs around the site, as identifiedabove. The list is not exhaustive and it is expected that not all species be used.8.3.20 Aboriginal HeritageAccording to SEA the development area has either been totally impacted by recent landuse and has negligible heritage potential, or has been subject to high impacts and inconsideration of Aboriginal land use modelling, is of very low heritage potential. NoAboriginal heritage sites are listed within the study area on any heritage registers orplanning instruments, although two isolated artefacts occur in the immediate vicinity ofthe eastern end of the proposed pipeline routes, north of the existing Shoalhaven PaperMill (Figure 1). In the absence of appropriate management and mitigation measures, it isconcluded that the impacts of the proposal on Aboriginal heritage will be very low.Shoalhaven Starches commits to the undertaking the following recommendations madeby SEA on the basis; of legal requirements including the NSW National Parks andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 344
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryWildlife Act 1974 and Environmental Planning and Assessment Act 1979; the results ofthe investigation; and consultation with the local Aboriginal community:Table 60Aboriginal HeritageAboriginal HeritageProvisions relating to Aboriginal heritage will be included in an EnvironmentalManagement Plan for the project. These provisions will be formulated in consultation withthe registered Aboriginal stakeholders and specify the policies and actions required tomanage the potential impacts of the proposal on Aboriginal heritage after Part 3Aapproval is granted. The plan should include management procedures for previouslyunrecorded Aboriginal heritage evidence and skeletal remains (should such evidence beidentified during construction), procedures for further Aboriginal consultation should suchevidence be identified, and mitigation measures involving surface collection for theidentified isolated artefact site APPM Isolated Find 1 (DECC #52-5-288 and 52-5-289)should it be subject to impacts. The plan will, subject to Part 3A project approval, guidemanagement of any Aboriginal heritage evidence in lieu of a Section 90 Consent;Under the terms of the National Parks and Wildlife Act 1974 it is an offence to knowinglydestroy, damage or deface an Aboriginal object without obtaining the prior writtenpermission of the Director-General of DECC. Therefore, no activities or work will beundertaken within the Aboriginal site areas as described in this report and marked onFigure 1, in the absence of a valid Section 90 Consent or in lieu, Part 3A approval;Single copies of this report should be forwarded for comment to the Aboriginalstakeholders (Dungarn Consultancy and Nowra LALC); andAfter revision of the draft report with the responses of the Aboriginal community, threecopies of the final report should be forwarded to:ManagerSouth BranchEnvironment Protection and Regulation DivisionDepartment of Environment and Conservation (NSW)PO Box 2115Queanbeyan NSW 2620Cowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 345
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, Bomaderry9.0 CONCLUSIONShoalhaven Starches is a member of the <strong>Manildra</strong> <strong>Group</strong> of companies. The <strong>Manildra</strong> <strong>Group</strong>is a wholly Australian owned business and the largest processor of wheat in Australia. Itmanufactures a wide range of wheat based products for food and industrial markets bothlocally and internationally.The Shoalhaven Starches factory located on Bolong Road, Bomaderry produces a range ofproducts for the food, beverage, confectionary, paper and motor transport industries including:starch, gluten, glucose and ethanol.The use of ethanol as a fuel (or fuel additive) has many benefits and as a result the Federaland State Governments have introduced a range of initiatives to encourage the increased useof ethanol as a fuel additive. The NSW Government has recently mandated the blending of2% of ethanol into the total volume of petrol sold in NSW as a first step towards a10% ethanolcontent by 2011.As a result, the <strong>Manildra</strong> <strong>Group</strong> is planning to increase its ethanol production capacity to meetthe expected increase in demand for ethanol arising from these initiatives by upgrading theexisting ethanol plant at the subject site. Shoalhaven Starches plans to increase ethanolproduction from the current approved 126 million litres per year to 300 million litres per year.To accomplish the increase in ethanol production, this proposal will require some plantupgrades and an increase in the throughput of raw materials, principally flour and grain. Theproposal will include:• the provision of an additional dryer for the starch/gluten plant;• additional equipment and storage vessels for the ethanol plant including 3 additionalfermenters, additional cooling towers and molecular sieves;• upgrades to the Stillage Recovery Plant including 6 additional Dried Distillers GrainsSyrup (DDGS) dryers; 10 decanters; chemical storage and two evaporators. Theproposal also includes the installation of a DDGS Pellet Plant within this part of the site;and• the establishment of a new packing plant, container loading area and a rail spur line. Theestablishment of this facility on the northern side of Bolong Road will require the provisionof an overhead bridge structure to allow product and safe pedestrian movement acrossBolong Road.In addition to the upgrade to the Company’s ethanol plant, Shoalhaven Starches also proposeto undertake comprehensive odour reduction measures for both the existing factory andCowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 346
Environmental Assessment ReportShoalhaven Starches Pty LtdProposed Ethanol Production Upgrade, Bolong Road, BomaderryEnvironmental Farm sites and the works associated with this proposal and which have beenidentified as part of an Environmental Audit prepared by GHD Pty Ltd.The proposal also includes the biological treatment of waste waters from the factory site. It isproposed to re-use over half the treated waste water within the factory processes and theremainder irrigated onto the Company’s Environmental Farm.The project also involves an upgrade to services to the site such as electric power, naturalgas, etc. The proposal includes the provision of an additional gas fired boiler and a gas firedco-generation plant.The application is one subject to Part 3A of the Environmental Planning & Assessment Act1979. The Department of Planning has determined that the proposal is a Major Project for thepurposes of this legislation and the Minister for Planning is the consent authority. TheDirector-General has issued requirements for the preparation of this EnvironmentalAssessment. This Environmental Assessment report has been prepared to address the issuesraised by the Director-General’s requirements for this proposal.The preparation of this Environmental Assessment has also been undertaken followingconsultation with relevant Government agencies, including:• The Department of Environmental and Climate Change;• The Department of Water and Energy;• The Roads & Traffic Authority; and• Shoalhaven City Council.Community Consultation groups and Aboriginal stakeholders have also been consulted in thepreparation of this EA.Following an assessment of the key issues associated with this proposal the EnvironmentalAssessment concludes that the proposal is suitable for the site and this locality. TheEnvironmental Assessment includes a Statement of Commitments outlining environmentalmanagement, mitigation and monitoring measures that should be implemented to minimisepotential impacts associated with the proposal.The Minister’s approval for the proposal is sought.Stephen RichardsonTown Planner, CPP, MPIACowman Stoddart Pty Ltd Ref. 07/34 - August 08Page 347
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