Fingal Carbon Retort Devolatilisation Plantepa.tas.gov.au/documents/fingal carbon ear...

ENVIRONMENTAL ASSESSMENT REPORT

Fingal Carbon Retort Devolatilisation Plant

Fingal

Fingal Carbon Pty Ltd Report and recommendations of the EPA Division Department of Primary Industries, Parks, Water and Environment to the Board of the Environment Protection Authority March 2012

Environmental Assessment Report – Fingal Carbon Devolitilisation Plant

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Environmental Assessment Report Proponent Fingal Carbon Pty Ltd

Proposal Establishment of a Coal Devolatilisation Plant

Location Off the Esk Highway, Fingal

NELMS no. 8564

DA number 303/2011

File 112216

Document G:\EEO_Enviro_Ops\EAS_Assessments\EAS_Projects\Fingal Carbon\Fingal Carbon Devolatilisation Plant

Class of Assessment

2B

Assessment process milestones 17 March 2011 Notice of Intent submitted

21 April 2011 DPEMP Guidelines issued

7 December 2011 Permit application submitted to Council

7 December 2011 Application received by Board

10 December 2011 Start of public consultation period

16 January 2012 End of public consultation period

22 February 2012 Supplementary information submitted to Board


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Acronyms AMT Accepted Modern Technology

Board Board of the Environment Protection Authority

DPEMP Development Proposal and Environmental Management Plan

DPIPWE Department of Primary Industries, Parks, Water and Environment

EIA Environmental impact assessment

EMPC Act Environmental Management and Pollution Control Act 1994

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)

FCRP Fingal Coal Retort Project

LUPA Act Land Use Planning and Approvals Act 1993

SD Sustainable development


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Report summary This report contains an environmental assessment and recommendations to the Board of the Environment Protection Authority, in relation to the Fingal Carbon Pty Ltd proposal to construct and operate a coal devolatilisation plant at Fingal.

This report has been prepared by the EPA Division of the Department of Primary Industries, Parks, Water and Environment based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP) and DPEMP Supplement. The advice of relevant Government Agencies and the public has also been sought and considered as part of this assessment.

On 31 January 2012, the Director requested that the applicant submit supplementary information to address public, government agency (including DPIW) and Council comments on the DPEMP. The DPEMP supplementary information was submitted by the applicant on 22 February 2012. Background to the proposal and details of the assessment process are presented in Section 1 of this report. Section 2 describes the context of this assessment. Details of the proposal are contained in Section 3. Section 4 reviews the need for the proposal and considers the project, site and design alternatives. Section 5 summarises the public and Agency consultation process and the key issues raised in that process. The detailed evaluation of key issues is contained in Section 6. Section 7 identifies other environmental issues and the report conclusions are contained in Section 8.

Appendix 1 contains a tabular evaluation of other environmental issues referred to in Section 7. Appendix 2 contains a summary of issues raised in the consultation process. Appendix 3 contains recommended environmental permit conditions for the proposal. Attachment 2 of the recommended permit conditions contains the table of commitments from the DPEMP.


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Table of Contents

1 Approvals process ..................................................................................... 1

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

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

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

5 Public and agency consultation ................................................................. 8

6 Evaluation of key issues ............................................................................ 9

6.1 Atmospheric emissions ....................................................................................................... 9 6.2 Water Quality .................................................................................................................... 18

7 Other environmental issues ..................................................................... 20

8 Conclusions ............................................................................................. 21

9 References .............................................................................................. 22

10 Summary of appendices ....................................................................... 23

Appendix 1 Assessment of other environmental issues ........................................................ 24 Appendix 2 Summary of issues raised by public and agency submissions .......................... 30 Appendix 3 Proposed permit conditions ................................................................................ 31


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1 Approvals process An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Break O’ Day Council on 7 December 2011.

The proposal is defined as a ‘level 2 activity’ under Schedule 2 Subsection (1)(b) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being a coal processing works. Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The application was received by the Board on 7 December 2012.

As required by Section 27(1) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), the proponent submitted a Notice of Intent to the Board in relation to the proposal on 17 March 2011.

The Board required that additional information to support the proposal be provided in the form of a Development Proposal and Environmental Management Plan (DPEMP) prepared in accordance with guidelines issued by the Board in consultation with the Break O’Day Council. The final guidelines were issued to the proponent on 21 April 2011.

Several drafts of the DPEMP were submitted to the Department for comment prior to its formal submission. A final DPEMP was submitted to Council with the permit application. The DPEMP was released for public inspection for a 28-day period (plus holiday period) commencing on 10 December 2011. Advertisements were placed in the Examiner and on the EPA web site. The DPEMP was also referred at this time to relevant government agencies for comment. One public submission was received, however this was outside the advertising period.

On 31 January 2012, the Director requested that the proponent prepare a DPEMP Supplement to address public, government agency (including DPIPWE) and Council comments on the DPEMP. The DPEMP Supplement was submitted by the proponent on 22 February 2012.


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2 SD objectives and EIA principles The proposal must be considered by the Board in the context of the sustainable development objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) established by the EMPC Act. The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to protect the environment of Tasmania, and to further the RMPS and EMPCS objectives.

The Board must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment Principles defined in Section 74 of the EMPC Act.


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3 The proposal The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 2 of the DPEMP. Table 1: Summary of key proposal characteristics

Characteristic Description/quantities

Activity description Processing of 40,000 tonnes of coal per year, utilising a devolatilisation process and two coal retorts with stacks, to produce 25,000 tonnes per year of char. This includes quenching of char with water and tar being produced as a by-product.

The company, trading as Pacific Carbon, currently operate a devolatilisation plant in Newcastle Australia.

Location 5397 Esk Main Road, Fingal (CT 19740/1) as shown in Figure 1.

Land zoning Break O’ Day Planning Scheme - Rural

Land tenure Cornwall Coal Company

Site overview The site is located on the northern side of a ridge line. The site is built on an old coal tailings dam.

Surrounding area overview

The site is surrounded by hills to the south, east and west. State Forest is the predominant land use to the south. Cornwall Coal operate a coal mine approximately 600 metres to the south. The site is open to the north but is a few hundred metres higher than the Esk Highway. The nearest residences are on the outskirts of Fingal Township being approximately 1.3 km’s to the west.

Major equipment Two retorts with associated stacks (tar and diesel storage tanks, product conveyor, fans, cyclones and screens).

Other infrastructure Clay lined interceptor dam and settling pond.

Inputs

Water 8000 litres of water daily with 6000 litres being recirculated and 2000 supplied from the Cornwall Coal pipeline.

Energy Heat energy provided by the combustion of volatiles released from the coal, estimated electricity demand is 109,000 kW/hr/year, diesel fuel for plant start up.

Other raw materials Concrete for construction of hardstand areas. Coal and char product.

Wastes and emissions

Liquid Stormwater collected from hardstand areas. Processed water from quenching.

Processed water can include suspended solids; ammonia, nitrogen; phosphorous; oil and grease; faecal enterococci; Polycyclic Aromatic Hydrocarbons (PAHs); benzine-toluene-xylene (BTX); cyanide, phenols, creosote and Sulphur Carbon Nitrogen (SCN).

Atmospheric Atmospheric emissions leaving the stack, fly ash from the combustion process, coal dust, char dust and associated material that include:

odour; dust; particulates; sulphur dioxide (SO2); Polycyclic Aromatic Hydrocarbons (PAHs) as Benzo(a) pyrene; volatile organic compounds (VOCs) as n-pentane; oxides of nitrogen; carbon monoxide; ammonia and nitrogen dioxide.

Solid Fines from material handling and processing. Sewage effluent from toilets.

Noise Noise sources relating to the retort include the exhaust fans, burner fans and stack fans, the conveyor and sizing screen. Vehicle movement on and off the site.


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Operating hours The operation will run 24 hours a day. Workers will operate the plant in three eight hour shifts on Monday to Friday starting at 6:00 am, 2:00 pm and 10:00 pm. There will be two twelve hour shifts on Saturday and Sunday starting at 6:00 am and 6:00 pm.

Project timetable Commence once approvals in place and upon demand.

Figure 1: Proposed location (Figure 1 of the DPEMP).

Proposed retort facility

Fingal town centre


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Figure 2: Site plan (Figure 2 of the DPEMP).


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Figure 3: Process overview (Figure 5 of the DPEMP).


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4 Need for proposal and alternatives Char produced will be used for the smelting of manganese and other metals at Bell Bay by Tasmanian Electro Metallurgical Co Pty Ltd (TEMCO) situated at Bell Bay. It will be the first such plant in Tasmania. The DPEMP states that site selection was determined by the client having regard to an isolated plant location convenient to Cornwall Coal’s washery and local coal supply. Bell Bay was discounted for FCRP as it is physically remote from Cornwall Coal’s operations and the available workforce in Fingal. This is an important consideration as Fingal has a history of mining and industrial operations and therefore has a workforce which requires minimal training for the new operation. The DPEMP also states that the site selected is both cost effective to lease, on a site where its impact on surrounding land uses is limited, and is sufficiently disturbed so that it poses few if any environmental concerns. Also with the process of devolatilisation proposed it is most cost effective to process coal nearer its source without freighting it to Bell Bay, thus enabling lower tonnages to be sent via road and cartage. The DPEMP also explored a number of technologies available to supply TEMCO Bell Bay with carbon for metallurgical smelting. These are as follows:

Option 1: Coke produced from coke mills. Coke is almost pure carbon, very stable and ideal for metallurgical smelting. But coke is not produced in Tasmania and would need to be imported which defeats the primary goal of the project at Fingal which is to provide a Tasmanian supply of char.

Option 2: Semi coke produced from a coke mill. This is similar to coke but less processed. Largely used in China. Semi-coke consists of coal which has been treated with low temperature carbonization, just below that of the plastic zone, utilising a bituminous substance as a binder. It is then formed into briquettes and delivered to market. As it is not heat treated in the same manner as char it will be less effective in the smelting process at TEMCO Bell Bay as well as being more polluting due to its retained impurities and lower carbon content by volume.

Option 3: Graphite. This is the highest grade of coal and is excellent for transmitting energy. But it is difficult to ignite and according to Pacific Carbon very expensive to obtain. Mainly due to cost and availability considerations, graphites are not used as reductants (Sahajwalla, 2004). At this time graphite is not used for producing char anywhere in the world.

Option 4: Char production using bituminous black coal to achieve what is in effect ‘met coal’ (metallurgical coal). Readily obtainable in Tasmania, more cost effective than graphite to obtain, a proven product and utilising a proven technology.

Option 4 was decided on by TEMCO as the preferred option.


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5 Public and agency consultation A summary of the public representations and government agency/body submissions is contained in Appendix 2 of this report. The proponent’s response to those issues is contained in the DPEMP Supplement.

One representation was received outside the advertising period. The representors concerns will be considered in the assessment process, however at this stage it understood that they do not have appeal rights. The main issue raised in the representation was:

• Concern of the potential for significant sulphur smells that will impact on the natural values of the area.

The DPEMP was referred to a number of government agencies/bodies with an interest in the proposal. Responses were received from the following:

• Dept Health and Human Resources (Health);

• Dept of Infrastructure, Energy and Resources (DIER);

• Dept of Economic Development, Tourism and Arts (DED). Economic Development provided support to the project.

The following Divisions/Areas of the Department of Primary Industries, Parks, Water and Environment also provided submissions on the DPEMP:

• Policy and Conservation Assessment Branch (PCAB);

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

The proponent has also undertaken its own public consultation process involving consultation with:

• Officers from the EPA Division, Department of Primary Industries, Parks, Water and Environment – as environmental assessment authority;

• Officers from Break O’Day Council – as planning permit authority; • Department of Infrastructure Energy and Resources – as highway road authority; • Forestry Tasmania – common boundary neighbour to the west; • Mineral Resources Tasmania – processing of coal from local mining interests will be of

interest to MRT; • Louisa Rhodes and representatives of the Fingal Online Access Centre, Fingal Valley

Neighbourhood House; and • Fingal District Progress Committee – including meeting at Fingal for a full briefing on the

project.


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6 Evaluation of key issues The key environmental issues relevant to the proposal that were identified for detailed evaluation in this report were:

• Air quality and odour emissions

• Water

These issues are discussed individually in the following Sections. The table of commitments from the DPEMP is included in Attachment 3 of this report (Attachment 2 of the permit).

6.1 Atmospheric emissions

Description

The DPEMP identifies the following atmospheric pollutants resulting from the combustion of coal as being a concern, due to the potential health and environmental risks:

• Sulphur dioxide (SO2);

• Polycyclic Aromatic Hydrocarbons (PAHs) as Benzo(a) pyrene;

• Volatile Organic Compounds (VOCs) as n-pentane;

• Particulate matter of less than 10 microns equivalent aerodynamic diameter (PM10);

• Oxides of nitrogen (NOx);

• Carbon monoxide (CO);

• Ammonia (NH3);

• Nitrogen dioxide (NO2); and

• Odour.

The Fingal town centre is situated in the Fingal Valley, approximately 3.5 kilometres from the FCRP site. The nearest sensitive receptors identified in the DPEMP are on the outskirts of the town 1.5 km distant to the west of the site. The Environment Protection Policy (Air Quality) 2004 (Air EPP) sets design criteria for new point source emissions at ground level contaminant concentrations to be met at the boundary of the land upon which the activity is to be located, with compliance to be determined using an atmospheric plume dispersion model and a methodology approved by the Director. The atmospheric dispersion calculation should consider local terrain and meteorology, the effect on background concentrations, the contribution of adjacent sources and the need to preserve the capacity of the local environment to receive future emissions. In addition, the Air EPP requires that accepted modern technology (AMT) should be applied to reduce emissions to the greatest extent practicable. In-stack concentration limit guidelines are provided in the Policy. These are to be applied by default unless it is successfully argued by the proponent that alternative values more appropriately represent AMT in the circumstances.


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Atmospheric plume dispersion modelling

Plume dispersion modelling was conducted using the CALPUFF Gaussian Puff dispersion model (version 6.4.2). The modelling report is included as Appendix C to the DPEMP. General assumptions made in the application of the model are also listed in Appendix C.

A number of assumptions were made when configuring the model:

• Default options within the CALPUFF model were used; • Wherever possible, measured emissions from the Pacific Carbon parent plant in Newcastle

were used to characterise emissions from the proposed FCRP;

• In the absence of measured emissions data for particulates, appropriate published air emission factors for particulates have been applied; and

• The modelling assessment assumes the FCRP facility and ancillary activities such as vehicle movements and transfer operations operate for 365 days per annum.

The model requires a comprehensive suite of hourly meteorological data covering a one year period. The meteorological data file used was developed for Fingal, Tasmania for the year 2008. This data was deemed the most representative of the site available in a suitable form.

Background pollutant concentrations are used in the CALPUFF model to account for the contribution of other sources of contaminants in the area. The DPEMP states that under the National Environment Protection Measure for Air Quality (NEPM) it is anticipated that background air toxic concentrations are insignificant within the Fingal locality.

The 8 km by 8 km receptor grid used for the modelling was centred on the proposed Fingal Carbon Devolatilisation Plant, covering the region with grid points at 250 m intervals. The grid includes the Fingal Centre and the nearest receptors, both of which are to the west.

Modelling results and conclusions Maximum ground level concentrations (GLC) of the contaminants of concern were predicted to occur within or close to the site boundaries. The predicted maximum ground level concentrations are compared with the Air EPP design criteria in Table 2. Table 2: Predicted ground level concentrations of contaminants of concern and design criteria specified in the Air EPP Atmospheric contaminant

Averaging period

Maximum predicted ground level concentration beyond

lease boundaries (mg/m3

unless otherwise stated)

Air EPP design criterion (mg/m3 unless

otherwise stated)

Percentage of criterion

CO 8 hour 0.182 11.250 2

NO2 1 hour 0.257 0.328 78 PM10 24 hour 0.646 0.150 431 SO2 1 hour 0.078 0.570 14

VOC (as n-Pentane)

3 minute 0.005 60 0.01

PAH (as Benzo(a)pyrene)

1 hour 9.85X10-8 0.0004 0.02

NH3 3 minute 0.0134 0.60 2 Odour 1 hour 0.31 OU 2 OU 16

NB: Predicted concentrations are expressed at the 99.9th percentile peak for averaging times of one hour or less, and at the 100th percentile peak (maximum) for greater averaging times. The only exception to this is the odour predictions, which are expressed at the 99.5th percentile peak. The percentile levels used are all in accordance with those required by the Air EPP.


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It can be seen from the Table 2 that the predicted GLCs are well within the required design criteria for all contaminants except PM10. The DPEMP states that these predictions are worst case because of the conservative assumptions made in relation to modelling input parameters, as mentioned above. The EPA Division Air Modelling Specialist has reviewed the particulate emission factors used and considers them to be overly conservative, with the true values likely to be significantly lower.

As stated in the DPEMP the modelling is conservative because it is based on:

• The FCRP facility and ancillary activities such as vehicle movements and transfer operations being in operation 365 days per annum. However, the FCRP facility will not operate continuously over the 365 day period. Furthermore most ancillary activities will not operate over weekend periods.

• atmospheric dispersion modelling which assumes that the FCRP facility processes 73,000 tonne per annum (TPA) of washed coal under normal operation. This value is based upon continuous normal operation over a 365 day period. This will not occur due to scheduled retort and ancillary equipment maintenance. The facility is proposed to be approved to process 40,000 TPA.

• PM10 emissions from the char quenching process, which are based upon US EPA coke quenching emissions using clean water (Air Pollution Engineering Manual 1992). The applied US EPA coke quench emission factor is likely to overestimate actual FCRP char quench emissions because the method in which the coke is generally removed from the coke oven involves significantly more material handling and turbulence. Char removed from the FCRP retort is withdrawn in a steady controlled manner with minimal material turnover and mechanical handling.

Without further modelling it is difficult to estimate what the average predicted ground concentration beyond the lease boundary is however it would be significantly less than those stated in Table 2.

In-stack contaminant concentrations The contaminants for which AMT in-stack concentration limits may be applicable were considered in the Air Emissions Report (Appendix C of the DPEMP) to be particulate matter (reported as the equivalent term “total suspended particulates” in Appendix C) and NOx. As detailed in Appendix C, predicted worst case in-stack concentrations of these parameters, based on the stack tests used for plume dispersion modelling, are presented in Table 3 below. These are compared to AMT limits detailed in the air EPP.

Table 3: Predicted in-stack contamination concentrations and required AMT limits.

Contaminant Predicted in-stack concentrations (mg/Nm3)

AMT limit (mg/Nm3)

Oxides of nitrogen (as NO2) 413 2000

Total Particulate matter 5.2 (PM10) 100

It can be seen in Table 3 that in-stack concentrations are not likely to exceed AMT limit for oxides of nitrogen and particular matter.

The DPEMP states that overall performance of the stacks is largely determined by the effectiveness of the scrubbers, fans and ventilation system.


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Management measures

The following management commitments in relation to air emissions are made in the DPEMP:

• The combustion process effectively uses the heat and chemical composition of coal …thus, the most important means of collecting and treating wastes is the combustion process itself which will be subject to ongoing management by Fingal Carbon under an ongoing environmental management programme.

• Compliance with the Environment Protection Policy (Air Quality), DTAE, (2004) is to be achieved for all emissions including odour from the Fingal Carbon site with the exception of PM10 which is not to exceed the results identified in the report by Advitech (2011) which accompanied the DPEMP. The proponent is to actively reduce PM10 emissions during the life of project so as to achieve greater compliance with Tasmanian Air Quality Standards (Commitment 8).

• Dust management will be undertaken on site including but not limited to the following specific actions:

· The coal screen is to be fully enclosed; · The washed coal conveyor is to be enclosed on three sides to reduce dust and

other emissions; and · Water is to be applied via sprayers to all roadways to reduce dust generation on site

where wind conditions require (conditions to be set in EMP) (Commitment 8). • Spray water used to cool hot char is to be relatively clean and free of high concentrations of

contaminants. Quality to be monitored as per EMP (Commitment 9); and • Reduce fugitive emissions from pipes, valves, seals, tanks, and other infrastructure

components by regularly monitoring with vapour detection equipment and maintenance or replacement of components as needed in a prioritized manner (Commitment 10).

Submissions

No submissions were received.

Evaluation

Atmospheric plume dispersion modelling The plume dispersion modelling carried out predicts that the proposed devolatilisation plant will comply with all required design criteria except for PM10. The Air Modelling Specialist had the following comments to make in relation to the modelling methodology:

• The modeller was appropriately qualified and experienced; • The modelling software used was considered appropriate and the modelling assumptions

made were reasonable; • The meteorological file used was reasonable given the lack of site-specific data; • The terrain and receptor grids used, and the explicit identification of discrete receptors was

considered appropriate; • With the exception of particulates, the emission rates used within the model were

determined from measurements made at the Pacific Carbon plant in Newcastle; • In the absence of measured emissions data for particulates, appropriate published air

emission factors for particulates were applied; • Figure 4 provides a source apportionment for particulate emissions used within the model.

It shows that over 50 % of the particulates were assumed to be generated within the char quenching process with another 25 % from continuously occurring wind erosion from the


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product hopper. Both of these figures are estimates and are considered to significantly overestimate the likely emissions;

• Based on the output files for each model run, it was considered that in each case the model was appropriately and expertly configured and that model outputs were correctly quoted.

Therefore the modelling results obtained are accepted. The results thus comply with clause 11 (1) (d) of the Air EPP regarding design criteria and modelling; and

With the exception of PM10, the modelling results obtained were well within the required design criteria. Background contaminant concentrations were incorporated into the modelling calculations. The results therefore demonstrate that sufficient reserve capacity will be available within the surrounding airshed to allow for other reasonable emissions to that air shed, in compliance with clause 11 (1)(b) of the Air EPP.

Figure 4: Source apportionment for PM10 emissions used in the dispersion model (Derived from information contained within Appendix 2, Emissions Inventory, Air Quality Impact Assessment).

Stack emissions7%

Quenching54%

Truck unloading and loading

2%

Stockpile loading and unloading

7%

Loading coal hopper1%

Product hopper25%

Wheel generated dust2%

Coal conveyor0%

Wind erosion from stock piles

2%


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Exceedence of PM10 at the boundary The major concern with this proposal is whether it meets the requirements of the Air EPP, in particular Part 4 Managing Point Sources of Air Contaminants. Figure 5 shows that the predicted peak PM10

concentration beyond the lease area exceeds the Air EPP design criterion by a factor of 4.3. The exceedence occurs in the small region beyond the plant boundaries (the red areas). The nearest residential receptor (R1) is over 1 km away, and is predicted to experience a peak PM10 concentration of 1.9 μg/m3. This is significantly below the Air EPP Schedule 2 design criterion of 150 μg/m3. The nearest private land, the Malahide property, is situated 350 m to the north east and is heavily forested and steep (Figure 6). The exceedence zone is predicted to only marginally extend onto this property. There is State forest within approximately 150 m to the south east which then continues on for a number of kilometres. Cornwall Coal also has a mine approximately 550 m to the south on State forest land. The Cornwall Coal property that the coal devolution plant is located on extends to approximately 1200 metres. The particulate modelling is highly conservative, using emission factors that are greater than those expected in reality, and assuming that some emissions will be continuous rather than occurring intermittently as is expected. The model predicts ground level concentrations, on a grid of points covering the entire region, for each hour of the year. These results are then resolved into average concentrations for each day. The model then determines the predicted peak daily-mean concentrations at each point on the grid, thereby determining the ‘worst-case’ meteorological conditions for each location. It is important to understand that the peak prediction for one specific location will occur on an entirely different day and time and meteorological circumstances to that for another location. You would therefore never experience a single day where the pattern of dispersion exactly matches that predicted by the model. A key assumption in the modelling is that at each location the worst case meteorology will coincide with a period of peak emissions. In reality this is very unlikely to occur. In addition, for the vast majority of the time, atmospheric dispersion will not be particularly poor. The predicted concentrations for an average day will therefore be far lower than the peak concentrations, which are for the worst day of the year at each location. The extent and magnitude of the exceedence is therefore expected to be smaller than that presented in the DPEMP. Given the isolation and small area of the site, the extreme terrain and that the proposal is not expected to cause Environmental Nuisance or Harm, it would be difficult to justify requiring additional pollution control measures to be applied. However S11(1)(d) of the policy requires that predicted ground level concentrations of pollutants specified in Schedule 2 of the policy should not be exceeded “… at or beyond the boundary of the land on which the activity is located”. Modelling submitted as part of the assessment process indicates that this is not achieved in the case of this proposal. The air quality assessment indicates that PM10 will clearly exceed the criterion beyond the boundary of the proposal (as illustrated by the red area on the attached maps). Adjacent property (State forest) is within approximately 150 metres of the proposed retort, however there are no sensitive receptors close by.


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. Figure 5: Predicted peak daily-mean PM10 concentration, µg/m3

• Air EPP 24 hour PM10 design criterion = 150 µg/m3.

• Red area = exceedence zone; Black rectangle = site area.

• Peak GLC beyond site boundaries = 646 µg/m3 (431 % of Air EPP design criterion).

• Peak GLC at R1 (nearest residence) = 1.9 µg/m3.

• Peak GLC at R2 = 1.5 µg/m3.


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- Figure 6: Surrounding land use. The proposed site is contained within land owned by Cornwall Coal (the red hatched area). S11(1) (f) of the policy states that …

“If it is not possible with the application of best practice environmental management to comply with design criteria … at the boundary of the land on which the point source of pollution is located, the regulatory authority may permit the emission of the pollutants if it is satisfied that the emission will not-:

(i) put at risk the health of any person beyond the boundary of the land on which the point source of the pollution is located; (ii) allow the pollutant(s) to unreasonably interfere with the enjoyment of the environment by any person living or working beyond the boundary of the land on which the point source of the pollutant(s) is located; or (iii) otherwise cause serious or material environmental harm; or (iv) be exceeded outside commissioning, start-up or shutdown periods provided the regulatory authority has specified the conditions under which the excess emissions from such events are permitted;

and there is an ongoing commitment to a program of pollution reduction to reach compliance … as soon as reasonably practical”.

Points (i) to (iii) are achievable due to the remote location of the site. There is ambiguity when interpreting point (iv). It could be argued that it means:

A. design criteria can be exceeded outside of commissioning, start-up or shutdown periods as long as conditions are placed on the permit to manage these excess emissions; or alternatively that

Proposed site


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B. design criteria can be exceeded during commissioning, start-up or shutdown periods provided that conditions are placed to manage these excess emissions.

The final phrase in this section would require that there would be” … an ongoing commitment to the program of pollution reduction to reach compliance…as soon as reasonably practicable. This final phrase begins with an “and” so it applies in addition to the points (ii) to (iv) while point (iv) begins with an “or” which usually indicates an alternative rather than an additional requirement. However S9(3) of the policy also requires that “… regulatory controls and monitoring requirements applied to a point source of air pollution should be proportionate to the level of environmental risk posed by the emission of pollution from that source.” The obligation upon the EPA is to advance the Air EPP as best it can and this means advancing the aggregate of the objectives as best it can in the circumstances. Given the relatively remote location of the proposal, the conservative nature of the modelling, a commitment to ongoing improvements at the proposed coal devolatilisation plant, and most importantly that regulatory controls should be proportional to the level of environmental risk, it is concluded that the expected PM10 emissions from the site should meet the intent of the Environment Protection Policy (Air quality) 2004. On the basis of the atmospheric dispersion modelling conducted no ambient air monitoring requirements are considered necessary. Ambient monitoring for PM10, even though assisting in confirming the assumptions of modelling, would have marginal benefit considering the high financial and labour costs associated with monitoring, the location of the site and the conservative assumptions in the modelling.

Recommendations It is recommended that relevant management commitments outlined in the DPEMP and summarised above are included in the permit.

The following standard (generic) conditions are recommended for inclusion in the permit:

G1 Compliance with EMPCA and the EMP

G7 Notification prior to commencement

A1 Stack testing facilities

A2 Covering of vehicles

A3 Control of dust emissions

A4 Control of dust emissions during construction

A6 Odorous gases

A8 Emission limit exceedences M2 Dealing with samples obtained from monitoring

M3 Stack monitoring reports The following site-specific conditions are recommended for inclusion in the permit:

G8 Conduct of the activity in accordance with the commitments

A5 Stack emission limits

A7 Stack testing frequency

A9 Visible smoke emissions

M4 Environmental Monitoring Program


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6.2 Water Quality

Description

Processed effluent has the potential to cause ground and surface water pollution. Uncontrolled stormwater flow has the potential to cause erosion. Stormwater run-off has the potential to release sediment and other contaminants from the land.

Management measures

• The DPEMP states that acidic and caustic effluents from quenching, if this arises, should be neutralized prior to being outside the concrete bund area (such as a dust suppression water source). Advice from the proponent indicates that water disposal from quenching will not be required based on their current experiences. Pacific Carbon has found that the water used does not become sufficiently contaminated to warrant disposal due to filtration and dilution as well as evaporation in the quenching process.

• Design and locate coal storage facilities and associated leachate collection systems to prevent impacts to soil and water resources. Coal stockpile areas should be first covered with sacrificial coal chitter and surface runoff directed to areas for disposal via evaporation and/or infiltration into the coal chitter layer (Commitment 17).

• Stormwater from the concrete hardstand is to be conveyed to existing drains (or sump) and settling ponds for on-site recycling. The final design of the bund is to be provided to Council endorsed by suitably qualified engineer for its records and will meet AS1940:2004 (Commitment 18).

• Each retort is to be contained within a concrete plant bunding system to contain any environmental pollution and observe public health standards (Commitment 19).

• Water quality sampling and monitoring for any water discharged from the concrete bund area (settling pond) addressing pH, conductivity and total suspended solids, PAHs, BTX, NH3, CN, Phenol, SCN, oil, COD (part of commitment 6).

Submissions

DHHS (Health) advised that a stormwater management plan has not been submitted with the proposal and it is referred in the DPEMP that it will be submitted as a condition of approval. It is essential that a stormwater management plan and specification is submitted for approval. The plan should address how all effluents and stormwater are captured and treated from the retort facility, loading areas and roadways; and ensure there are no adverse impacts on the receiving catchment.

Evaluation

Health’s recommendation for the need for a stormwater management plan can be managed by other means such as through the Environmental Monitoring Program (condition M4). There are a number of volatiles from the process that could potentially impact upon groundwater/surface water. As long as these are contained on site as best as is practicable then the above management measures with effluent disposal conditions should be appropriate.

It is noted that the proponent has argued that there will be zero discharge of process waters and therefore conditions are a back-up in case of spillages, run-off from the product char, etc.

Industrial effluent in the concrete bunded retort area (including any stormwater overflow from the bunded tar storage area) will be monitored. This will ensure that any water within the sump collection point, that is subsequently used for dust suppression of the char stockpiles, meet standards as per condition E5 (effluent quality limits for discharge to the settling pond and interceptor dam).


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Further monitoring will also occur at the interceptor dam, which is a collection point for the outside bunded area. If emission limits are contravened then further management measures will need to be considered to ensure that ongoing exceedences do not occur. There are also a series of tailings dam below the site that can collect any excess contaminants if exceedences do occur.

It is also noted that setting permit limits for unique activities will always involve some uncertainty without the advantage of a proven history of operating data. Recommendations It is recommended that relevant management commitments outlined in the DPEMP and summarised above are included in the permit.

The following standard (generic) water conditions are recommended for inclusion in the permit:

E2 Perimeter drains E3 Stormwater E4 Design and maintenance of settling ponds

The following site-specific water conditions are recommended for inclusion in the permit:

G8 Commitments

E5 Effluent quality limits for discharge to the Settling Pond and Interceptor Dam

M1 Water monitoring requirement

M2 Dealing with samples obtained from monitoring

M4 Environmental Monitoring Program


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7 Other environmental issues In addition to the key issues, the following environmental issues are considered relevant to the proposal and have also been evaluated.

• Noise

• Waste management

• Effluent disposal

• Cultural and heritage

• Hazardous substances

• Fauna and flora

• Weed and Pathogen Management

• Off site impacts associated with transport to and from the activity

• Decommissioning and Rehabilitation

Details of this evaluation, along with recommended permit conditions, are contained in Appendix 1.


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9 References

Town and Country Planning Pty Ltd, December 2011 DPEMP for Fingal Carbon Retort, Coal Devolatilisation Plant, Duncan Road Fingal.

Town and Country Planning Pty Ltd, Supplementary Information, 22 February 2012.


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10 Summary of appendices Appendix 1 Assessment of other environmental issues

Appendix 2 Summary of issues raised by public and agency submissions

Appendix 3 Proposed permit conditions, includes DPEMP Commitments at Attachment 2.

Appendix 1


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Appendix 1 Assessment of other environmental issues

Issue 1 Noise Description of potential impacts Potential for noise impacts on surrounding residences from machinery, fans, pumps and vibrators, and traffic movements to and from the site. Management measures proposed in DPEMP

• All noise emission limits as set out by the EPA are to be met at the boundary of sensitive receiver sites (Commitment 11).

• Control of noise is to occur by limiting hours of operational loading and unloading to those specified in the application, namely haulage of washed coal to the site, material transfer activities and char dispatch on weekdays between 7am to 5 pm. Operation of the retorts is to be 24/7 (Commitment 12).

Public and agency comment No public or agency comment received. Evaluation The proposed management measures are considered acceptable. Because the activity is a 24 hour a day operation it is recommended that noise limits be placed on the operation as there may be the potential for air inversions to cause unanticipated tonal noise issues and therefore a numerical limit will assist in regulating the activity if necessary. Commitment 12 may not necessary need to be enforced as noise levels from this part of the activity are likely to be low at the nearest residence. Recommendation It is recommended that the proponent comply with standard condition N1 (noise nmission limits) and non standard condition G8 (commitments).

Issue 2 Waste management Description of potential impacts Potential contamination of surface waters, groundwater or land. Management measures proposed in EER

• Appropriate disposal of oil, solvents, reactant solutions, filters, used containers, oily rags, mineral spirits, activated carbon filters and oily sludge as per industry best practice (Commitment 13).

• Coal dust (and sludge, if generated) from coal storage and coal preparation should be dried and reused or recycled where feasible. Periodic removal to Cornwall Coal is required for incorporation in their coal stock or other suitable arrangements made as required (Commitment 14).

Public and agency comment No public or agency comment received. Evaluation The proposed management measures are considered acceptable. Recommendation It is recommended that the proponent comply with non standard condition G8 (commitments) and M4 (environmental monitoring program).

Appendix 1


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Issue 3 Effluent disposal Description of potential impacts Potential for sewage effluent to impact upon surface and groundwater. Management measures proposed in DPEMP All relevant permits are to be obtained from the Break O’Day Council for plumbing and installation of the wastewater system as detailed by GeoEnvironmental Solutions with this application. Public and agency comment No public or agency comment in relation to the potential for effluent to impact upon surface or groundwater. Evaluation It is considered that there is little potential for on-site treatment of sewage to impact on local surface or groundwater provided an approved wastewater treatment plant is installed and maintained in accordance with the manufacturer’s directions and that treated wastewater is disposed of in accordance with best practice environmental management. Recommendation It is recommended that the proponent be required to comply with non standard condition E1 (effluent disposal).

Issue 4 Cultural and Aboriginal heritage Description of potential impacts Loss of heritage issues in the lease area. Management measures proposed in DPEMP No management measures proposed. Public and agency comment No public or agency comment received. Evaluation As the proposed activity is on an old mine tailings dam no heritage values should be impacted. Recommendation There are no recommendations regarding heritage.

Appendix 1


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Issue 5 Hazardous substances Description of potential impacts Refuelling and machinery maintenance operations and tar storage/removal create the potential for spillage of environmentally hazardous materials. Management measures proposed in DPEMP

• All fuel, lubricants, coolant, waste oil and waste chemicals must be stored in an approved manner such as in drums or surface tanks with impervious bunds to contain spillage and located away from drainage lines (Commitment 20).

• The DPEMP states Liquid waste is largely limited to tar production, otherwise referred to as Naphter tar. This is notactually a waste, being instead a commercial product used in automobile car tyres and rubber -called commercially “carbon black”. Naphter tar will be generated at a maximum rate of 5 tonnes per day per retort where it will be stockpiled within 2 holding tanks (200 tonne capacity in total), retained within a bund. It is then periodically removed via tanker to customers.

• total tar generation is estimated to be 7.5 tonnes per day on average Tar storage and removal is to be undertaken in accordance with all relevant dangerous goods and occupational health and safety requirements (commitment 21).

Public and agency comment No public or agency comment received. Evaluation The proposed management measures are considered acceptable. Recommendation It is recommended that the proponent be required to comply with standard permit condition H1 (storage and handling of hazardous materials), H2 (spill kits) and non standard permit condition G8 (commitments).

Appendix 1


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Issue 6 Fauna and flora Description of potential impacts Loss of threatened species or habitat. Management measures proposed in DPEMP As stated in the DPEMP supplement:

• The proposed plant will be located entirely on a disused tailing dam and therefore Tasmanian Devil (Sarcophilus harrisii) habitat will not be impacted by the proposed plant.

• The irrigation area is not in virgin native bush, it is is disturbed land below the existing line of the disturbance (i.e. the large concrete drain) so little impact is likely.

• Commitment 24 makes a commitment to effectively manage weeds on site. Public and agency comment Policy and Conservation Branch (PCAB) advise

• Further detail as to whether the area is suitable for denning for Tasmanian Devils (Sarcophilus harrisii).

• Clarification is required as to the location of the sewerage as this may change the vegetation composition over time.

• Concerns were also raised by PCAB of possible impact of PM10 (does not meet EPP air policy requirement of schedule 1 at the boundary) on Fauna and Flora.

Evaluation PCAB is satisfied from the supplementary information provided that there is no suitable denning habitat for the Tasmanian Devil and that effluent should not impact upon fauna and flora. After further advice being received from the EPA Division Air modelling Specialist, PCAB is satisfied with comments made by the EPA’s Air Modelling specialist concerning PM10 and its low likelihood of adverse impacts to fauna and flora. Recommendation There are no recommendations regarding fauna and flora.

Appendix 1


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Issue 7 Weed and pathogen management Description of potential impacts Infestations of weeds such as gorse and pathogens could spread to neighbouring forests or other activities through truck movement. Management measures proposed in DPEMP

• Gorse will not be disturbed by the construction of the plant however the control of this infestation is desirable and a weed management plan is recommended by the proponent in the supplement.

• To effectively manage weeds on site the following actions are required. • All machinery that operates on the site should be washed down prior to entering and

leaving the site as per the “Tasmanian Washdown Guidelines for Weed and Disease Control’’.

• Any soil imported to the site should be from certified ‘clean’ sites or quarries. • If ground works are planned for the area where the current gorse infestation occurs

then the infestation should be controlled prior to construction works. This should involve the removal of mature plants and the foliage spraying of small plants or seedlings.

• Any machinery that works in the area where the gorse infestation occurs should be washed down at the site prior moving to another site (Commitment 24).

Public and agency comment PCAB recommends that a weed management and hygiene plan be developed for gorse (Ulex europaeus) to prevent its spread across the site and into other areas as required under the Weed Management Act 1999. This should include consideration of the “Keeping it Clean”, a Tasmanian field hygiene plan being adhered to during development activities to prevent the spread of gorse and other weeds. Evaluation PCAB supports the recommendation to develop a weed and hygiene management plan as part of the conditions of approval outlined in Annexure B. PCAB also supports the proponent’s commitment to adhere to the ‘Tasmanian Washdown Guidelines for Weed and Disease Control’ to ensure no spreading of weed seed across the site. Meeting the washdown requirements should deal with hygiene management adequately and a weed management plan is recommended. Recommendation It is recommended that the proponent be required to comply with standard condition OP1 (wash down guidelines) and non standard conditions G8 (commitments) and OP2 (weed management plan).

Appendix 1


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Issue 8 Off-site impacts associated with transport to and from the activity Description of potential impacts Increase in traffic on Duncan Road with potential conflict at points where heavy vehicles are entering and exiting the Esk main road. Potential for noise and dust from vehicle movement. Management measures proposed in DPEMP No management measures proposed. Public and agency comment No public or agency comment received. Evaluation Condition A1 requires the covering of loads exiting the site to manage dust. Noise and dust from transport is not likely to be an issue as the quarry is close to a major transport route. The suitability of traffic to be handled on the road network is a matter for DIER and Break o’Day Council. Recommendation It is recommended that the proponent be required to comply with standard condition A1 (covering of vehicles).

Issue 9 Decommissioning and Rehabilitation Description of potential impacts The Fingal Retort Site as a whole may pose an ongoing risk if all associated plant and equipment is not properly decommissioned. Management measures proposed in DPEMP Commitment 31 states that a preliminary Decommissioning and Rehabilitation Plan or Closure Plan will be prepared. This Plan will address the following:

• Removal of all structures comprising demountable buildings, retorts, holding tanks, conveyors, water storages, settling pond etc;

• Excavation and removal of the concrete hardstand and any building footings; • Removal of sacrificial coal chitter working surface; • Removal of bitumen storage tanks after decontamination; and • Methods of disposal of all waste, being either concrete, steel or other associated with

operations at FCRP; and should be prepared in consultation with Cornwall Coal who have rehabilitation obligations for the tailings dam upon which the retorts are situated.

Public and agency comment No public or agency comment was received. Evaluation It is considered necessary that the Director be informed if operations are to cease so that the plant decommissioning can be accounted for as part of any required site decommissioning procedures. Recommendation It is recommended that the proponent be required to comply with standard permit condition DC1 (rehabilitation and decommissioning), DC2 (decommissioning and rehabilitation plan) and non-standard condition G8 (commitments).

Appendix 2


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Appendix 2 Summary of issues raised by public and agency submissions A. Relevant Public Submissions Issue Comment Further Info.

req? Air Concerned of the potential for significant sulphur smells

that will impact on the natural values of the area. Y

B. Referral Agency Comments

Agency Additional information required Further Info. req?

Environmental

DPIWE – Policy and Conservation Assessment Branch (PCAB)

• Records indicate that the Tasmanian Devils (Sarcophilus harrisii) are within the footprint of the proposed development that are listed under the Threatened Species Protection Act 1995 and/or Environment Protection and Biodiversity Conservation Act 1999. Further detail as to whether the area is suitable for denning.

• A weed management plan is recommended due to the potential for weeds spreading to other sites. It is recommended that a weed management and hygiene plan be developed for gorse (Ulex europaeus) to prevent its spread across the site and into other areas as required under the Weed Management Act 1999. PCAB recommends that the “Keeping it Clean” A Tasmanian field hygiene plan be adhered to during development activities to prevent the spread of gorse and other weeds.

• Clarification is required as to the location of the sewerage as this may change the vegetation composition over time.

Y

Y

Y

Dept Health and Human Resources (Health)

• A stormwater management plan has not been submitted with the proposal and it is referred in the document that it will be submitted as a condition of approval. It is essential that a stormwater management plan and specification is submitted for approval. The plan should address how all effluents and stormwater are captured and treat from the retort facility, loading areas and roadways; and ensure there are no adverse impacts on the receiving catchment.

Y

Planning Dept of Infrastructure, Energy and Resources

• The TIA (Traffic Impact Assessment) has been assessed and the Signs and Road Markings would need upgrading as suggested.

N

Dept Economic Development, Tourism and Arts

• The Department welcomes the proposed development.

N

Appendix 3


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Appendix 3 Proposed permit conditions

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