Rescycle Pty Ltd - ELT Recycling Facility - Avoca – Development … Pty Ltd - End... · 2015. 12....

Rescycle Pty Ltd - ELT Recycling Facility - Avoca – Development Proposal and Environmental Management Plan

Prepared By: Barry Williams

Date: 7 December 2015

Issue Date Recipient Organisation

Incomplete Draft 21 October 2015 David Wessely Rescycle Pty Ltd

Draft 26 October 2015 Damien Blackwell Environment Protection Authority

Draft 2 13 November 2015 Damien Blackwell Environment Protection Authority

Final 4 December 2015 Damien Blackwell Environment Protection Authority

Final rev 7 December 2015 Damien Blackwell Environment Protection Authority

ELT Recycling Facility – DPEMP 7 December 2015

Integrated Land Management and Planning | Table of Contents 2

TABLE OF CONTENTS Table of Contents .................................................................................................................................... 2

Figures ..................................................................................................................................................... 6

Tables ...................................................................................................................................................... 6

Plates ....................................................................................................................................................... 6

Executive summary ................................................................................................................................. 7

1. Introduction .................................................................................................................................... 8

1.1 Background ............................................................................................................................. 8

1.2 Rescycle Pty Ltd ....................................................................................................................... 8

1.3 Consultants ............................................................................................................................. 9

1.4 Process .................................................................................................................................... 9

1.5 Proposed site .......................................................................................................................... 9

1.6 Environmental legislation ....................................................................................................... 9

2 Description of Proposal ................................................................................................................. 10

2.1 General .................................................................................................................................. 10

2.1.1 Transportation .............................................................................................................. 10

2.1.2 Shredding ...................................................................................................................... 10

2.1.3 Pyrolysis process ........................................................................................................... 10

2.1.4 Outputs ......................................................................................................................... 11

2.2 Construction .......................................................................................................................... 12

2.2.1 ELTs stockpiles............................................................................................................... 12

2.2.2 ELTs shredder ................................................................................................................ 13

2.2.3 Pyrolysis plant ............................................................................................................... 13

2.2.4 Amenities ...................................................................................................................... 13

2.2.5 Essential infrastructure ................................................................................................. 13

2.2.6 Schedule of works ......................................................................................................... 13

2.3 Commissioning ...................................................................................................................... 13

2.4 General Location Map ........................................................................................................... 14

2.5 Site Plan................................................................................................................................. 16

2.6 Off-site infrastructure ........................................................................................................... 18

3 Project Alternatives ....................................................................................................................... 18

4 Public Consultation ....................................................................................................................... 19

5 Existing Environment .................................................................................................................... 20

5.1 Planning Aspects ................................................................................................................... 20



5.1.1 Planning Scheme Objectives ......................................................................................... 20

5.1.2 Use Classes .................................................................................................................... 20

5.1.3 Land Use Zones ............................................................................................................. 20

5.1.4 E1 Bushfire-Prone Areas Code ...................................................................................... 20

5.1.5 E2 Potentially contaminated land code ........................................................................ 20

5.1.6 E6 Car-parking and Sustainable Transport Code .......................................................... 20

5.2 Environmental Aspects ......................................................................................................... 21

5.2.1 Natural Processes and Vulnerability ............................................................................. 22

5.2.2 Conservation reserves and wilderness areas ................................................................ 23

5.2.3 Significant Species, communities, natural values. ........................................................ 23

5.3 Socio-economic Aspects ....................................................................................................... 23

6 Potential Impacts and their Management .................................................................................... 25

6.1 AIR QUALITY ............................................................................................................................ 25

6.1.1 Existing conditions ........................................................................................................ 25

6.1.2 Performance requirements ........................................................................................... 25

6.1.3 Potential impacts .......................................................................................................... 25

6.1.4 Avoidance and mitigation measures ............................................................................. 26

6.1.5 Assessment of net impacts ........................................................................................... 28

6.2 Surface water quality ............................................................................................................ 32

6.2.1 Existing Conditions ........................................................................................................ 32



6.2.4 Avoidance and mitigation measures ............................................................................. 32


6.3 Groundwater ......................................................................................................................... 33


6.4 Noise emissions ..................................................................................................................... 33




6.4.4 Avoidance and mitigation ............................................................................................. 34


6.5 Waste management .............................................................................................................. 36





6.5.3 Potential Impacts .......................................................................................................... 36


6.5.5 Assessment of net Impacts ........................................................................................... 36

6.6 Dangerous goods and environmentally hazardous materials .............................................. 36






6.7 Biodiversity and natural values ............................................................................................. 38




6.8 Marine and coastal ............................................................................................................... 39

6.8.1 Existing Conditions ........................................................................................................ 39


6.9 Greenhouse gases and ozone depleting substances ............................................................ 39


6.10 Performance criteria ............................................................................................................. 39

6.10.1 Direct greenhouse gas (pyrolysis plant) ........................................................................ 39

6.10.2 Direct Greenhouse Gas (transport task) ....................................................................... 40

6.10.3 Indirect Greenhouse Gas .............................................................................................. 40

6.11 Heritage ................................................................................................................................. 41




6.12 Land use and development ................................................................................................... 42


6.13 Visual impact ......................................................................................................................... 43


6.13.2 Assessment of net impact ............................................................................................. 43

6.14 Socio-economic issues .......................................................................................................... 46



6.15 Health and safety issues ....................................................................................................... 46







6.16 Hazard analysis and risk assessment .................................................................................... 47



6.17 Fire risk .................................................................................................................................. 48


6.17.2 Performance criteria ..................................................................................................... 48




6.18 Infrastructure and off-site facilities ...................................................................................... 49



6.19 Environmental Management Systems .................................................................................. 50

6.20 Cumulative and interactive impacts ..................................................................................... 50

6.21 Traffic Impacts....................................................................................................................... 50


6.21.2 Performance Criteria ..................................................................................................... 50


7 Monitoring and review ................................................................................................................. 51

7.1 Air quality Monitoring ........................................................................................................... 51

7.2 Noise level monitoring .......................................................................................................... 51

7.3 Review ................................................................................................................................... 51

8 Decommissioning and rehabilitation ............................................................................................ 51

8.1 Decommissioning .................................................................................................................. 51

8.2 Rehabilitation ........................................................................................................................ 51

9 Commitments ............................................................................................................................... 52

10 Conclusion ................................................................................................................................. 53

11 References ................................................................................................................................ 54

12 Appendices ................................................................................................................................ 55


Integrated Land Management and Planning | Figures 6

FIGURES Figure 1- Schematic diagram of Major items of plant .......................................................................... 11

Figure 2: General Location Map 1 - Extract from 1:100 000 St Pauls Sheet 8414 ................................ 14

Figure 3: General Location Map 2 surrounding land use ...................................................................... 14

Figure 4: General Location Map 3 Land Use Zones............................................................................... 15

Figure 5: Site Plan aerial image showing surrounding land .................................................................. 16

Figure 6: Aerial Image showing Proposed general arrangement of the pyrolysis facility .................... 17

Figure 7: CEFV for St Pauls River ........................................................................................................... 38

TABLES Table 1 Proponent details ....................................................................................................................... 8

Table 2: Proposal details ......................................................................................................................... 8

Table 3: ELT Constituent products ........................................................................................................ 11

Table 4: Operation details ..................................................................................................................... 12

Table 5: description of the site ............................................................................................................. 21

Table 6: ABS Census data (2011) for Avoca .......................................................................................... 23

Table 7: Predicted compliance against air quality criteria .................................................................... 28

Table 8: Recommended maximum noise levels ................................................................................... 34

Table 9: Operating hours ...................................................................................................................... 35

Table 10: Heritage properties in the area ............................................................................................. 41

PLATES Plate 1: Entrance to site from Esk Main Rd Plate 2: Looking across development site ................... 22

Plate 3: Looking from development site to sawmill Plate 4: Looking along east boundary .............. 22

Plate 5: Site from Esk Main Rd eastbound Plate 6: Site from Esk Main Rd westbound ................... 22

Plate 7: Looking west at site frontage................................................................................................... 44

Plate 8: Looking west closer to access .................................................................................................. 44

Plate 9: Looking east at site frontage ................................................................................................... 45

Plate 10: Looking south at access road ................................................................................................. 45

Plate 11: saw dust fire underway during early site investigation. ........................................................ 48


Integrated Land Management and Planning | Executive summary 7

EXECUTIVE SUMMARY Rescycle Pty Ltd (Rescycle) is a new company that has purchased a ‘new technology’ pyrolysis plant for the purpose of establishing an End of Life Tyre (ELT) recycling facility. The sustainable disposal of ELTs is a challenge for communities around the world. Various alternative uses have been developed for shredded or chipped ELTs but still a significant proportion of ELTs go to landfill.

Rescycle selected Tasmania as a trial site as there is a well-documented problem with ELT disposal here and no current effective disposal solutions. Current disposal alternatives involve stockpiling and ultimately shredding and shipping to other states or disposal in landfill in Tasmania. Tasmania is an ideal site to test Rescycle’s business model as all tyres and shredded ELTs are shipped into and out of the state so the resource potential is fixed and controlled.

The site of the former Avoca Sawmill was selected for the trial site as it has a history of recent industrial use. The site is located close to the township of Avoca to enable convenient servicing and commuting for Operators. The site offers direct access to Esk Main Road, which is part of on the state’s freight network providing clear access to the major population centres and tyre retail facilities.

The Rescycle proposal is to shred the ELTs into a consistent feed stock for a pyrolysis digester that will cause the shredded ELTs to breakdown into constituent parts. The digesting process will liberate an amount of energy to power the process; steel will be recovered for recycling; ‘biochar1’ will be collected and sold and heavy oil will be recovered and sold as an alternative fuel for industry. Syngas will be given off and be flared off and residual gases will be processed through a wet scrubber.

The set up for the previous plant operated for 10 years on a variety of waste streams including ELTs. This plant will differ from the original plant in that the gases will be flared off and then passed through a wet scrubber to provide an extra level of confidence that atmospheric emission levels will be within acceptable standards.

The Avoca ELT Recycling Facility will be managed in a manner to ensure the actual tyre stockpiles will remain small and not exceed the size considered to be a small external storage facility by the General Guidelines for Rubber Tyre Storage. This will ensure ELTs do not remain in stockpile for extended periods and help minimise the environmental impacts. The small stockpiles and first strike firefighting capability will also minimise the risk of a damaging fire.

The Proponent has commissioned a series of specialist studies to demonstrate the plant’s capacity to operate at full production without causing an environmental nuisance. Studies include:

• Atmospheric emission modelling • Noise impact calculations • Business case • Hazard analysis and risk assessment • Bushfire Management Plan • Traffic Impact Assessment

These studies are summarised in the body of this report but are attached in full as appendices.

1 Biochar is black carbon residue produced by digesting organic material in an anaerobic process (pyrolysis)


Integrated Land Management and Planning | Introduction 8

1. INTRODUCTION TABLE 1 PROPONENT DETAILS

Proponent Rescycle Pty Ltd

ACN 168 787 611

Address 38 Merrimac Blvd

BROADBEACH WATERS Qld 4218

Postal Address PO Box 559

KINGS MEADOWS TAS 7249

Contact Mr David Wessely

Email [email protected]

Mobile 0488 764 696

TABLE 2: PROPOSAL DETAILS

Project Name ELT Recycling Facility

Address Esk Main Road, Avoca, Tas, 7213

Land owner Mr Francis O’Connor

Property ID 2883150

Certificate of Title 243096 / 1, 250729/2, 45/874

1.1 BACKGROUND Rescycle Pty Ltd (Rescycle) proposes establishing a facility to receive and process ‘end of life tyres (ELTs)’ into saleable products. The facility will utilise an anaerobic, pyrolysis process to convert End of Life (ELT) tyres into various products for market. Rescycle is a new company holding as a key asset a pyrolysis plant developed by Tox Free (Kwinana) Pty Ltd. This plant has a book value of $2 M and operated in Western Australia on various waste streams including ELTs.

1.2 RESCYCLE PTY LTD The Director of Rescycle brings with him considerable experience in business and practical industrial management.

David Wessley is the Executive Director and Chief Executive Officer. David has worked the mining industry throughout Australia for over 15 years. David’s experience includes all aspects of underground mining including personally held leases and contractual roles. With engineering knowledge and heavy machinery experience, David will play a pivotal role in ensuring the Avoca ELT recycling plant will operate at the highest standard.


Integrated Land Management and Planning | Introduction 9

1.3 CONSULTANTS Ken Falconer will consult for Rescycle Pty Ltd. Ken was involved with the technology for 25 years and has applied his expertise on the design, construction and operation of every “Tox Free” plant.

1.4 PROCESS The ELT processing facility consists of four basic elements:

1. Collection and transport of ELTs from existing stockpiles, mines and resellers around Tasmania.

2. Sorting, stockpiling and shredding ELTs into a suitable form to feed into the process stream. 3. Indirectly fired anaerobic closed loop pyrolytic digester to convert ELT’s into marketable

products. 4. Sale and distribution of the products including steel, biochar, heavy oil

1.5 PROPOSED SITE The Proponent selected the former sawmill site at Avoca because it has strategic benefits.

• The site is strategically located on a High Productivity Vehicle (HPV) route roughly equi-distant between Burnie and Hobart and closer to Launceston.

• The township of Avoca is close by which allows staff to access facilities in the township including parcel freight, for maintenance of equipment and shops for lunches and refreshments.

• The site is currently occupied by the now closed Avoca Sawmill. The proposed new operation will in some ways compensate the community for the loss of the sawmill operation.

1.6 ENVIRONMENTAL LEGISLATION The ELT Processing facility will be subject to the following legislation and policies:

• Land Use Planning and Approvals Act 1993 • Environmental Management and Pollution Control Act 1994 • Environmental Management and Pollution Control (Waste Management) Regulations 2010 • Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations

2010 • Environmental Management and Pollution Control (Distributed Atmospheric Emissions)

Regulations 2007 • Environmental Management and Pollution Control (Distributed Atmospheric Emissions)

Amendment Regulations 2010 • Water Management Act 1999 • State Policy on Water Quality Management (1997) • Environment Protection Policy (Air Quality) 2004 • Environment Protection Policy (Noise) 2009 • National Environmental Protection Council (Tasmania) Act (1995)


Integrated Land Management and Planning | Description of Proposal 10

2 DESCRIPTION OF PROPOSAL

2.1 GENERAL The Avoca ELT recycling operation is planned to occupy land at Avoca that was until recently the site of a sawmill operated by Mr Grant Richardson. The land is owned by Mr Francis O’Connor. It is proposed a parcel of land approximately 0.7 hectares in area be set aside to accommodate the pyrolysis plant. The plant will consist of an indirectly fired, vertical rotating retort into which the feed stock is introduced. Solids from the burner are delivered to the biochar hopper. Gases report to a high temperature filter. Particulate matter is delivered to the biochar hopper and steel and char and oil come out of the stream ready to recycle. The process gives off syngas which will be used to fire the burner. Any residual syngas will be flared off. The pyrolytic process is broadly illustrated in Figure 1.

The Avoca ELT recycling plant will be the first of its kind in Tasmania. Guidance documents and emission standards from various jurisdictions have been applied to ensure the design and management of this facility complies with Australian best practice.

• General Guidelines for Rubber Tyre Storage (South Australian Fire Authorities, July 2014) is applied to ensure that the ELT stockpiles are developed to facilitate easy access for fire suppression purposes.

• Emission criteria were applied from the NSW Industrial Noise Policy in the absence of specific Tasmanian noise amenity criteria.

The Avoca ELT recycling operation will consist of the following activities:

2.1.1 TRANSPORTATION

Trucks will deliver ELTs from historic stockpiles, retail outlets and industrial operations around the state. To efficiently transport the ELTs passenger ELTs are likely to be transported in light truck trailer combination vehicles. Larger truck and earthmoving equipment ELTs may be transported on flatbed trucks. The transport operation will be managed to ensure the volume of the ELT stockpile(s) at the site are minimised. ELTs are also likely to be sourced from remote locations including mines on Tasmania’s west coast.

2.1.2 SHREDDING

ELTs will be delivered whole or in shredded form. ELTs not already shredded will be shredded onsite. Large ELTs from trucks and heavy earthmoving equipment will be de-beaded prior to shredding by a mechanical shredder. Passenger ELTs will be shredded with the beads intact. The shredding operation will take place on a concrete paved work area protected on the north east side by a concrete block wall.

2.1.3 PYROLYSIS PROCESS

Shredded tyres will be fed into the indirectly fired, vertical rotating retort, which thermally volatilises them at a temperature of approximately 550 °C under oxygen depleted conditions. The 30 minute retention time for solids within the retort produces char, steel fragments, and a hydrocarbon-rich gas stream.

The biochar and steel are then separated, using a magnetic separator, for subsequent sale. The gas stream is filtered within the patented high temperature filter (HTF). This removes fine particles down to minus 0.01 microns at retort temperatures, providing a clean gas stream into the two-stage condenser. The HTF therefore eliminates the need for gas cooling prior to particle removal within a bag house. It therefore reduces both operating and capital costs.



The two stage condensing process cools the process gas down to 30 °C in the first stage and then to 7 °C in the second, separating it into a liquid distillate (which is collected for recycling), and a residual hydrocarbon-rich gas stream.

FIGURE 1- SCHEMATIC DIAGRAM OF MAJOR ITEMS OF PLANT

2.1.4 OUTPUTS

Although exact proportions vary ELTs are expected to break down into the following constituent products in approximately the proportions shown:

TABLE 3: ELT CONSTITUENT PRODUCTS

Constituent Proportion (%) Steel 24

Biochar 23 Heavy oil 28

Syngas 25

2.1.4.1 Steel

The de-beading operation will produce recyclable steel. There will be an amount of the steel within the carbon black from passenger car tyres. Steel will be stored in bins to deliver to a recycler.

END OF LIFE TYRES (ELTs)

SHREDDER

RETORT HIGH TEMP.

FILTER

MAGNETIC SEPARATOR

TWO STAGE CONDENSER

AFTERBURNER

RAPID QUENCH

SCRUBBER

STACK

HEAVY OIL FOR SALE

STEEL FOR SALE

BIOCHAR FOR SALE

DISTILLATE

GAS



2.1.4.2 Biochar

The process will produce biochar which is a marketable product and can be further processed to add greater value. Biochar is a relatively inert product that can be stored in drums for distribution and sale.

2.1.4.3 Heavy oil

The process will produce heavy oil. The recovery of this fuel oil is an advantage of the pyrolysis process over high temperature incineration. There are industries in Tasmania that use heavy oil as an alternative fuel. The heavy oil will be stored in storage tank with capacity less than 10 000 litres enclosed in bunds which meet Australian Standards for spill containment.

2.1.4.4 Syngas

The gas produced by the pyrolysis process is recycled back to power the retort. There is usually surplus gas generated, which can be used to drive an electrical power generation system. The Rescycle facility will ‘flare off’ any surplus gas.

TABLE 4: OPERATION DETAILS

Maximum annual production 16 000 tonnes of ELTs accepted

Operating hours

Pyrolysis plant (day) 24 hours

ELT shredding plant 7.00 am to 6.00 pm

Truck deliveries and dispatches 5.00 am to 10.00 pm

Loader operations 7.00 am to 6.00 pm

2.2 CONSTRUCTION

2.2.1 ELTS STOCKPILES

The Rescycle plant will consist of stockpile areas to store the ELTs received from the various collection points around the state. It is a requirement of safe ELT storage to exclude rainfall runoff and control wastewater (as a result of firefighting activities) to prevent an uncontrolled discharge to the environment.

To provide adequate access to firefighting equipment the ELT stockpiles should be no higher than 3 metres (m), no wider than 6 m and 20 m long (South Australian Fire Authorities, July 2014).

A single stockpile will accommodate around 1 500 ELTs and have a volume of around 375 cubic metres (m3). The stockpile will be located on a concrete slab approximately 8 m wide by 22 m long. The (bunded) stockpile slab will be designed to accommodate about 162 kilolitres. There will be two stockpiles giving a maximum stockpile volume of around 750 m3.



2.2.2 ELTS SHREDDER

The ELTs shredder process line will reduce the ELTs to rubber chips of a consistent size and shape to facilitate efficient and complete digestion in the pyrolysis plant. The ELTs shredder process line will be located on a concrete slab adjacent to the pyrolysis plant. The concrete slab will be around 28 m long by 10 m wide.

2.2.3 PYROLYSIS PLANT

The main components of the processing plant will be located on a second concrete slab with raised footings to support the equipment. This slab will be approximately 10 metres wide by 20 metres long.

2.2.4 AMENITIES

A third structure will contain the crib room, office and amenities for the workers at the plant. The ELTs stockpile area will be separated from any other structure existing or new by at least 20 metres.

2.2.5 ESSENTIAL INFRASTRUCTURE

The facility will have a hydrant system capable of delivering simultaneous hydrant flows to two outlets (10 litres per second each). A first strike firefighting capability will be provided with a hose reel able to reach all parts of the site, installed in accordance with AS 2441 – 2005 Installation of fire hose reels.

2.2.6 SCHEDULE OF WORKS

2.2.6.1 Preparation works

Following issue of the planning permit, ground works will commence to prepare for construction of the slabs and foundations. These works will take around two months to complete.

2.2.6.2 Mobilisation

A water connection will take water from the existing main to supply the hydrants on site. An electrical connection will be made from the transformer on the site to the facility. The equipment will be de-mobilised from the Western Australian site and shipped to this site. The equipment will be installed on suitably cured slabs and footings. These works are expected to take a further month to complete.

2.3 COMMISSIONING The equipment will be gradually commissioned over a period of 3 months using a small quantity of ELTs transported to the site for that purpose. Final commissioning to a fully operational plant is anticipated to take a further one month.



2.4 GENERAL LOCATION MAP

FIGURE 2: GENERAL LOCATION MAP 1 - EXTRACT FROM 1:100 000 ST PAULS SHEET 8414

FIGURE 3: GENERAL LOCATION MAP 2 SURROUNDING LAND USE

ELT Recycling Facility

To Conara Junction

To Fingal

k i d Residences at 4 to 10 St Pauls Pl

Private land CT 116751/1 (Farming) Private land CT 116751/1

(Farming)



FIGURE 4: GENERAL LOCATION MAP 3 LAND USE ZONES.

Northern Midlands Interim Planning Scheme 2013

(26. Rural Resource)

CT 243096/1

CT 243096/1 CT 250729/2

Avoca

St Pauls River

0 200 100

north

FIGURE 5 - SITE PLAN AERIAL IMAGE SHOWING SURROUNDING LAND

Date: 13 Nov 2015 Size: A3

28.0 m

18.0 m

15.0

m

Wire drawing Conveyor

Tyre cutter Conveyor Tyre shredder

Conveyor

Rubber crusher Shaking device

High temp furnace

Condensers

Quench tank

Retort

After burner

0 100

See Detail

Tyre Shredding Plant

Pyrolysis plant

Hydrant

Hydrant

Transformer

Existing access, culvert end walls replaced with mountable type. Access reconstructed to Tasmanian Municipal Standard Drawing TSD R05 V1.

Whole tyre stockpiles 6.0 x 20.0 x 3.0 m high on conc. slabs. Max. capacity 375 m3 each. Stockpiles separated by 20.0m clearway for fire service access Potential dust emission source or smoke emission in a stockpile fire scenario for a short duration

Pyrolysis plant and tyre shredding plant installed on concrete slabs to dimensions shown in details. Concrete block wall on NE side of tyre shredding and pyrolysis plants

Stack 15.0 m high Gaseous emission source

FIGURE 6 - AERIAL IMAGE SHOWING PROPOSED GENERAL ARRANGEMENT

Date: 13 Nov 2015 Size: A3

north

Flas

h ar

rest

or

Offi

ce /

am

eniti

es

Magnetic separator

9.0

m

3.0 m high concrete block wall

Compacted gravel surface on vehicle manoeuvring area Possible dust emission source

Heavy oil storage

LPG cylinder

Evacuation mustering point


Integrated Land Management and Planning | Project Alternatives 18

2.6 OFF-SITE INFRASTRUCTURE Main infrastructure needs for the Avoca ELT recycling plant are electricity, water supply and road transport access.

• The plant will require electricity for security lighting, task lighting for night time operation, to energise the ELTs shredder and to start the pyrolysis process. Three phase electricity is available from the pole-mounted the transformer located close to the sawmill building.

• Water supply is required to service the fire hydrants necessary to provide first strike capacity for the ELTs storage facility. An off take from an existing 63OD main located at the northeast corner of the property will provide the 20 litres/sec required for firefighting capability.

• The Rescycle ELT recycling facility will take ELT feed stock from around the state. ELTs will be delivered from existing stockpiles; from tyre resellers and from mines and quarries. ELTs will not constitute a heavy cartage task, but transport will most likely be by light combination trucks. Esk Main Road is a High Productivity Vehicle (HPV) route and ideally suited to the cartage task.

3 PROJECT ALTERNATIVES Rescycle developed out of an opportunity to purchase an underutilised waste to energy facility in Western Australia. The company operating the plant had developed interests in other regions of Western Australia and found the pyrolysis plant surplus to its needs.

With experience in mining, the Directors of Rescycle were aware of the significant problem of the disposal of End of Life Tyres both in industry and within the community generally. The pyrolysis plant offers a solution able to dispose of the ELTs in a clean and efficient way using the embodied energy in the ELTs to fuel the process and provides a series of product streams to supplement the income to the operator.

Tasmania was chosen for the initial start-up project as it offers a confined market place with quantifiable ELTs resource inputs and little opportunity for alternative disposal streams apart from shipping. Once the plant has been proven successful in Tasmania, similar plants can be established in other states around the country.

Avoca was chosen because it is located on a HPV route close to Launceston and equidistant between Hobart and Devonport. The transport part of the operation is significant and the central location has advantages at accessing markets. Avoca is also a town significantly affected by the downturn in the forest industry and would benefit from a new industry located nearby. The operator of the sawmill site, on which the pyrolysis plant is intended, has accepted a package from the government to exit the forest industry and hence will not operate again as a sawmill.

The site at Avoca in Tasmania is the result of a significant search involving other regions and other states.


Integrated Land Management and Planning | Public Consultation 19

4 PUBLIC CONSULTATION Rescycle has undertaken direct consultation with the following agencies and groups:

• Northern Midlands Council: Avoca is in the Northern Midlands Council municipal area and Council, as the planning authority, requires Rescycle to submit a Development Application to seek a permit to operate the facility. Representatives of the Northern Midlands Council have been consulted and have visited the site to evaluate the proposal.

• Environment Protection Authority: Incineration equipment with a capacity of burning 1 tonne or more of product per hour is classified as a Level 2 Activity under Schedule 2 (7)(a) of the Environmental Management and Pollution Control Act 1994. The environmental aspects of the proposal must be assessed by the Board of the Environment Protection Authority (EPA). Representatives of the EPA have been consulted and have visited the site to evaluate the proposal.

• The operator of the now mothballed sawmill and the landowner are long term residents within the Avoca community. The Directors of Rescycle attended a meeting of the Avoca, Royal George & Rossarden Local District Committee on the 22 of August 2014 to brief the community and take any questions regarding the proposal. Prior to the meeting the Northern Midlands Council and Rescycle Pty Ltd issued a media release outlining the ELT Recycling proposal.


Integrated Land Management and Planning | Existing Environment 20

5 EXISTING ENVIRONMENT The Avoca ELT recycling facility is located on the eastern approach to Avoca in central Tasmania. Avoca is located on the river flats to the South Esk River in a predominantly agricultural landscape. The hills and mountain ranges on the northern and southern side of the river valley were once the subject of substantial forestry operations and have mineral interests including coal extraction and processing.

The northern area of the parcel of land that will house the ELT facility is disused saw log and timber hard stand area for the now closed sawmill. The southern area is agricultural land periodically utilised for cropping.

5.1 PLANNING ASPECTS The Northern Midlands Council regulates these areas by applying the provisions in the Northern Midlands Interim Planning Scheme 2013 (scheme).

5.1.1 PLANNING SCHEME OBJECTIVES

Section 3.3 Industrial Strategy of the scheme identifies Northern Midlands, due to its central location as having potential to provide processing related industries in the region. The Rescycle proposal capitalises on the central location of Avoca to provide easy access to ELT’s from various sites around the state.

5.1.2 USE CLASSES

Section 8.2 of the scheme categorises development and uses into classes. The ELT Recycling Facility will be included in the Recycling and Waste Disposal use class according to Table 8.2 of the scheme.

5.1.3 LAND USE ZONES

Section 26 of the scheme relates to the Land Use Zone of the land on which the ELT Recycling Facility is proposed to be located. Section 26.1.1.1 states the zone is to provide for sustainable use or development, including opportunities for resource processing. It could be argued that rather than a waste product the Avoca facility will turn the ELTs (nominally a waste product) into a resource.

Table 26.2 Use Table of the scheme includes the Recycling and Waste Disposal use class in the ‘discretionary’ section. The Council can therefore issue a permit for the use if an assessment process determines the proposal has merit.

5.1.4 E1 BUSHFIRE-PRONE AREAS CODE

The agricultural land situated adjacent to the proposed facility site is classified as bushfire-prone. The Northern Midlands Council determined Code E1 will apply to this development due to the highly flammable nature of the ELTs stockpiles.

5.1.5 E2 POTENTIALLY CONTAMINATED LAND CODE

The Environment Protection Authority (EPA) lists a range of ‘Potentially Contaminating Activities’ that can give rise to contaminated land. The ELT Recycling Facility will be situated on a block of land that was the site for the Avoca sawmill until it closed down. The ELT Recycling Facility will be located on an area of land only ever used to stockpile logs prior to milling.

5.1.6 E6 CAR-PARKING AND SUSTAINABLE TRANSPORT CODE

This code requires ‘Uses’ to provide car-parking spaces in accordance with the provisions detailed in Table E6.1 Parking Space Requirements. According to this table, a Recycling and Waste Disposal use is to provide one space per 500 square metres of site area plus one space for each employee. The



Avoca ELT Recycling Facility is located on a 4000 square metre site and will have two employees. Therefore a total of 10 spaces will be provided.

5.2 ENVIRONMENTAL ASPECTS The land surrounding the site of the proposed facility is cultivated land, part of a large holding owned and operated by the owner of the land on which the ELT processing facility will be established.

Recent studies associated with the replacement of the St Pauls River Bridge show the widened road reserve on the frontage to the property has flora species listed under the Tasmanian Threatened Species Protection Act 1995. This proposal will not affect this area of vegetation and will not affect these plants.

TABLE 5: DESCRIPTION OF THE SITE

Climate data for nearest weather station – Fingal (Legge Street) 092012 (BOM, 2014)

Mean max. Temp. (0C) 17.8 Mean min. Temp. (0C) 5.3

Mean annual rainfall (mm) 610

Land capability The land is classified as class 4 land, well suited to grazing but which is limited to occasional cropping or a very restricted range of crops.

Geomorphology The land is elevated above the current level of St Pauls River close to the confluence with the South Esk River. The land will have been deposition areas including river flats that have been subsequently incised by the flow of the St Pauls River.

Geology The site is mapped as being underlain by Tertiary basalts and Quaternary deposits.

Soils Imperfectly drained soils above Tertiary bedrock. Very dark grey, loamy sand topsoils over brownish grey, loamy sand sediments on flat to undulating (0-10%) relict A2 horizons with much ferruginous gravel abruptly over yellowish brown, lake beds or terraces. coarse blocky, heavy clay subsoils with coarse red and white mottles increasing in abundance with depth, acid reaction trend (Dy, Dr).

Acid Sulphate risk

The southern half of the land parcel is mapped as having a low probability (6 – 70% chance of occurrence) of acid sulphate producing soil.

Aspect The development site is located in the south east corner of the existing Avoca Sawmill site. The land is level at an elevation of approximately 215 metres (AHD). The land falls slightly towards the east and west. Some 200 metres away towards the east the land falls steeply towards the St Pauls River.

Vegetation The site is fully cleared with a shelter belt of mature eucalypt trees to the east and a stand of screening pine trees to the north.

Geophysical data

The site is located within the Castle Cary Structure Landform, a block faulted structure extending from the Rossarden region south to the Buckland area.



PLATE 1: ENTRANCE TO SITE FROM ESK MAIN RD PLATE 2: LOOKING ACROSS DEVELOPMENT SITE

PLATE 3: LOOKING FROM DEVELOPMENT SITE TO SAWMILL PLATE 4: LOOKING ALONG EAST BOUNDARY

….

PLATE 5: SITE FROM ESK MAIN RD EASTBOUND PLATE 6: SITE FROM ESK MAIN RD WESTBOUND

5.2.1 NATURAL PROCESSES AND VULNERABILITY

The proposed ELT recycling site is cleared with trees screening on the north western and north eastern sides. The St Pauls River is subject to flooding in this location mainly as a result of flood



waters backing up from the confluence of St Pauls and The South Esk rivers. The 1929 flood level for the St Pauls River at Avoca was R.L. 201.472 metres. The one in one hundred year reoccurrence interval flood for the St Pauls River at Avoca is R. L. 196.900 metres. The lowest point on the development site is around 205 metres or 3.5 metres above the highest recorded flood.

5.2.2 CONSERVATION RESERVES AND WILDERNESS AREAS

There are no areas in the vicinity of the development listed as reserves or as having wilderness values.

5.2.3 SIGNIFICANT SPECIES, COMMUNITIES, NATURAL VALUES.

A flora and fauna study undertaken by an ecological consultant (North Barker Ecosystem Services, Feb 2015) included a study of the land adjacent to the development site and east. The report identifies examples of a threatened grass species located on the road reserve closer to the St Pauls River Bridge. The proposed works will have no impact on these plants.

5.3 SOCIO-ECONOMIC ASPECTS The 2011 census provides the flowing information on the township of Avoca (ABS, 2015).

TABLE 6: ABS CENSUS DATA (2011) FOR AVOCA

Criteria Avoca Tasmania Australia

Population 300 495 354 21 507 717

Median age 40 40 37

Unemployed 14.9 % 6.4 % 5.6 %

Occupation

Labourers 26 % 11.3 % 9.4 %

Managers 19.8 % 12.4 % 12.9 %

Machinery operators 12.5 % 6.7 % 6.6 %

Median family income (without children) $1 031 $1 771 $2 081

Median family income (with children) $1 333 $1 999 $2 310

Median rent $90 $200 $285

Median mortgage repayment $698 $1 300 $1 800

The community of Avoca and of the Fingal Valley more generally have been hit hard by the recent downturn in the forestry industry. The forests on either side of the valley contain thousands of hectares of Permanent Timber Production Zone forests. An active timber industry and Cement Australia’s coal mine near Fingal combined with agricultural producers to drive the economy in the region.



The Census data above shows the unemployment rate in Avoca was in 2011 more than twice the state average. There is likely to have been more redundancies from the coal mineand more contracting companies leaving the timber industry since 2011. The employment profile of Avoca shows the ELT recycling operation will require the skill set already well represented in the community. In 2011 Avoca had nearly twice the proportion of Operators / Drivers, Managers, and Labourers as the rest of the country. This employment mix is anticipated to be similar in 2015.

This new industry will be a considerable benefit to the region with direct employment, indirect employment of contractor / drivers and ‘spin offs’ in servicing and maintenance and original construction.


Integrated Land Management and Planning | Potential Impacts and their Management 25

6 POTENTIAL IMPACTS AND THEIR MANAGEMENT

6.1 AIR QUALITY

6.1.1 EXISTING CONDITIONS

The site for the Avoca ELT Recycling Facility was until recently the Avoca sawmill site. The sawmill would have used diesel driven log trucks and wheel loaders to handle the raw materials and burnt bark and other wood wastes as was generally the case with smaller sawmill operations.

6.1.2 PERFORMANCE REQUIREMENTS

Tasmania’s Environment Protection Policy (Air Quality) 2004 (Air EPP) requires that point and diffuse source emissions to air should not cause harm to environmental values such as;

• life, health and wellbeing of humans, • life, health and wellbeing of other life forms, • visual amenity, and • the useful life and aesthetic appearance of building property and materials.

Criteria from the Air EPP and the National Environmental Protection Measure for Ambient Air Quality (Air NEPM) were used to provide performance criteria for the atmospheric emissions from the Avoca ELT Recycling Facility.

6.1.3 POTENTIAL IMPACTS

The site for the proposed ELT Recycling Facility is close to the township of Avoca. The location is convenient for servicing needs and commuting for employees. Close proximity does, however, expose the people of Avoca to the potential danger of being adversely affected by atmospheric emissions from the plant.

The ELT Recycling Facility will use trucks to receive ELTs and a wheel loader to stack and move ELTs around on site. The pyrolysis plant will produce atmospheric emissions as a result of the process and more trucks will dispatch the products of the process. All these activities have the capacity to produce atmospheric emissions.

6.1.3.1 Emission sources (normal operation)

Trucks entering and exiting the site will travel over a sealed apron and then onto a gravel surface to manoeuvre to the stockpile pads. The load will be dumped or in the case of large ELTs, unloaded with the wheel loader. Paperwork will be completed and the truck will leave the site.

The wheel loader will operate during the day to stack ELTs in stockpiles to keep the area clear for traffic movements or to load the ELT shredder. The wheel loader will also collect bins containing waste steel from tyre beads and biochar from the retort.

Trucks and the wheel loader air emission locations include the gravel surface surrounding the stockpile pads, shedder plant and the pyrolysis plant. The likelihood of dust emissions will increase in dry and windy weather.

The ELTs will originate mainly from tyre resellers where they will most likely be stored in wire cages and kept relatively clean. Other ELTs may come from existing ELT stockpiles, and these are more likely to be dusty as are ELTs from mine sites and quarries. Air emission location for operations associated with dumping the ELTs will be on the stockpile pads.



The ELT shredder is unlikely to contribute to atmospheric emissions with a protocol to ensure that only clean ELTs are processed. The main source of atmospheric emissions is the pyrolysis plant. Under normal operating conditions the point emission source from this facility will be the stack.

The locations of the emission sources are displayed on the general arrangement plan Figure 6.

6.1.3.2 Emission sources (upset conditions)

There is potential for adverse events to confound normal operating controls and lead to atmospheric emissions outside acceptable limits:

• There have been instances where tyre stockpiles have caught fire. In this instance there will be smoke emitted from the stockpile until such time as the fire is extinguished.

• It is also possible the plant will fail under normal operation. A pipe joint or valve may fail causing an unpredicted and uncontrolled emission of gas from the circuit prior to the filter or wet scrubber.

6.1.4 AVOIDANCE AND MITIGATION MEASURES

6.1.4.1 Transport

Trucks entering and leaving the site will be restricted to a maximum speed of 15 km/hr minimising dust emissions. The trucks will be road compliant vehicles with proprietary emission control equipment minimising exhaust gases.

6.1.4.2 Wheel loader

The wheel loader will traffic mainly gravel surfaces surrounding the stockpile pads and the processing plants. The wheel loader will be restricted to a slow speed due to the short distances of travel minimising dust emissions. The operator will monitor the dust conditions from vehicle movements and apply water to suppress dust if there is a visible dust plume crossing the site boundary.

6.1.4.3 ELT shredding plant

A protocol will be adopted to receive ELTs from various locations. If from a potentially dirty source or where it is possible that excessive dirt or infestations of weeds or vermin are likely to accompany the ELTs, a system of acceptance will be invoked. Particularly dirty or infested loads will be rejected. Loads with minor contamination will be washed on the stockpile slab to remove dirt. The shredding plant will not cause dust emissions when running on clean ELTs. If windy conditions prevail and there is an amount of dust emanating from the shredder the operation can be temporarily curtailed or the ELTs dampened to mitigate the effect.

6.1.4.4 Pyrolysis plant

This configuration of pyrolysis plant operated in Western Australia on a variety of waste streams under permit conditions limiting air emissions for around 10 years A copy of the Western Australian EPA permit is included as Appendix 1. During this period of time there was limited experience with ELTs processing.

As part of this application the Proponent commissioned a comprehensive atmospheric emission modelling report to combine measured emission data from similar plants and estimated emission data from this plant with meteorological analysis for this site to predict the likely emission levels at various locations around the proposed facility.

The air dispersion modelling study used conservative mass emission rates determined in consultation with the EPA. A TAPM meteorological and prognostic dispersion model was applied to



determine hourly varying meteorology on a three dimensional grid for each hour of 2011. The modelled meteorology was used to drive the prognostic dispersion model simulating dispersion of emissions from the exhaust stack. The model predictions were assessed against the more stringent Air NEPM standards rather than the Tasmanian Air EPP where possible. Deliberate conservatism was applied at each step of the study to compensate for uncertainty in the estimated mass emission rates. This report is included as Appendix 2.

6.1.4.5 Upset events

The ELT Recycling Facility will have a plumbed ‘first strike’ fire suppression capability to enable operators to quickly extinguish a fire before it takes hold. This will ensure that any emission will be for the shortest duration possible. The stockpiles will be small (no more than 375 cubic metres), limiting the scale of any fire and configured to facilitate unrestricted access to firefighting equipment. Avoca has a fire station that can respond promptly to any calls.

The major pieces of equipment making up the pyrolysis plant originate from a plant that operated in Western Australia under the guidance of a Western Australian EPA permit. The pipe work, connections rapid quench and gas scrubber will be new ‘off the shelf’ equipment. The plant will be attended by at least one operator at all times.

A failure within the plant will trigger a pressure drop alarm, which will alert the operator. An emergency shutdown procedure will be invoked and the plant will be immediately shut down. An operating procedure will be developed and communicated for an emergency shut-down. Rescycle will develop a full set of operating procedures during the commissioning process that will be specific to this plant. Other similar pyrolysis plants are in operation at other sites and the operating procedures will be similar in content to these. An example of the operating manual for a similar pyrolysis plant, which is likely to the model for the Avoca Plant, is included as Appendix 3. The operating manual for this plant in its previous configuration in Western Australia has a similar format. The Table of Contents to this document is included as Appendix 4.

A failure within the plant will trigger an alarm to prompt the operator to intervene to shut-down the plant. In addition the plant will commence an automatic shutdown sequence that will not require an operator’s intervention. The automatic shutdown sequence will take between 15 and 20 minutes to complete.

If the failure has resulted in an uncontrolled emission that may be harmful the Operator will initiate an emergency evacuation procedure that includes notification of residences in the vicinity of the plant that may be affected. The full emergency procedure will be developed during commissioning of the plant; the preliminary document is included under Section 6.16 as Appendix 8.

6.1.4.6 Commissioning

Prior to operating the new plant there is a HAZOP conducted where the process is reviewed for any weaknesses. These are addressed prior to the plant operating. When it is determined that the plant can operate safely and effectively the plant is operated on inert materials to simulate the conditions to be encountered. A review is done at the completion of these trial runs and if it is deemed safe and prudent to do so the plant is trailed with the introduction of real feed. After a run of 8 hours the plant is again shutdown and samples taken during the run are analysed to ensure that the plant is operating as anticipated. If all is satisfactory then the plant is deemed safe to operate and production will begin. If areas of concern are met at any point in this process then the concern is addressed and the process begins again.



6.1.5 ASSESSMENT OF NET IMPACTS

The Air Quality Study (Power, Oct 2015 (A)) used data from various sources including plant configuration information on the original pyrolysis set up in Western Australia to estimate the likely atmospheric emissions from the plant running at the maximum production rate of 2 tonnes per hour. The study compared the estimated likely emissions of the various contaminants against the relevant air quality criteria sourced from both the Air EPP and the Air NEPM

The predicted maximum atmospheric emissions calculated at the boundary of the premises and at any residence are compared against the acceptable air quality criteria for the likely contaminants and tabulated below:

TABLE 7: PREDICTED COMPLIANCE AGAINST AIR QUALITY CRITERIA

Parameter Criterion (µg/m3)

Predicted max, beyond boundary

(µg/m3)

Predicted max.at any residence

(µg/m3)

Factor of Safety

Criterion source

SO2 1-hour max. 572 249 167 2.3 Air EPP & Air NEPM

NO2 1-hour max. 246 98 66 2.5 Air NEPM

SO2 24-hour max. 229 85 37 2.7 Air NEPM

SO2 1-year mean 57 9 2 6.1 Air NEPM

NO2 1-year mean 62 4 1 17 Air NEPM

PM10 24-hour max. 50 2 1 30 Air NEPM

HCl 3-minute max. 200 1 0.4 304 Air EPP

Dioxins & Furans 3-minute max.

3.7 x 10-6 7.2 x 10-9 4.8 x 10-11 514 Air EPP

CO 8-hour max. 11 250 2 2 5082 Air EPP & Air NEPM

A level of uncertainty exists in the exact performance of the ELT recycling facility operating on solely ELTs as a product stream. For this reason the ambient air quality study has been conservative in the assumptions applied particularly relating to sulphur dioxide emissions as this was considered to be the contaminant with the greatest potential for concern.

The results of the ambient air quality study show that the plant will comply with the accepted air quality criteria with a factor of safety exceeding 2 providing the plant functions as anticipated including effective performance of all pollution abatement equipment. The following figures are extracted from the ambient air quality study and show the predicted concentrations of what are believed to be the critical contaminants at various locations surrounding the facility:



FIGURE 7: PREDICTED 1-HOUR MAXIMUM NO2 CONCENTRATION (µG/M3)

FIGURE 8: PREDICTED 1-HOUR MAXIMUM NO2 CONCENTRATION (µG/M3)



FIGURE 9: PREDICTED MAXIMUM 24-HOUR MAXIMUM CONCENTRATION (µG/M3)

FIGURE 10: PREDICTED 24-HOUR MAXIMUM TSP (PARTICLES) CONCENTRATION (µG/M3)



Figures above are derived from (Power, Oct 2015 (A)) included in this document as Appendix 2. The full report should be consulted to understand the derivation and context to these figures.

Rescycle will undertake stack testing during the commissioning phase of the installation. The results of the stack tests will be compared to the mass emission rate results predicted by the study. If the actual results exceed the performance criteria extra controls will be applied until the stack test results comply.

Rescycle will establish the plant in such a manner that additional measures to control air emissions can be easily and inexpensively applied should the plant not perform as predicted:

• The major components will be founded to allow for additional or oversized filters to be installed.

• The foundations for the 15 metre high stack will be designed to accommodate a 25 metre high stack in case extra height is require to facilitate dispersion.

Once the commissioning phase is complete the Proponent will adjust the equipment and add new control equipment if required to ensure acceptable emission standards are met.

During normal operation Rescycle operators will monitor the plant and any fugitive emissions including dust from the gravel surfaces and apply controls as required.

Rescycle will establish a protocol to accept or reject ELTs from various sources to ensure that contaminants including dirt are not introduced to the site.

Upset events such as a fire in the ELT stockpile will be of a small scale and quickly extinguished due to the thoughtful layout and design of the stockpiles.

An equipment failure is unpredictable but an operator will be in attendance while the plant is operating and will have an emergency shut-down procedure to follow to ensure that any emission will be small scale. If the operator fails to initiate an emergency shutdown the plant will automatically shut down if abnormal conditions exist.

The detailed modelling shows it is highly unlikely the ELT Recycling Plant will cause an adverse impact on air quality for the people of Avoca with the emission control equipment installed and commissioned as stipulated in this document, even while running at maximum production.

In the unlikely event that an abnormal condition arises that may cause an environmental emission, automated fail safe alarms and shutdown procedures will compliment emergency evacuation and alert procedures to keep workers and the community safe.

Item Commitment Responsible When

1. An acceptance protocol will be introduced for sources supplying ELTs with the potential to be contaminated with dirt weeds or vermin.

Operator At all times

2. Dust emissions will be monitored and surfaces dampened if a visible dust plume is observed crossing the boundary


3. The plant will be installed with provision to install additional emission control infrastructure if required.

Operator During construction

4. Stack tests will be undertaken during commissioning to test compliance with atmospheric emission standards

Operator During commissioning

5. If emission standards are not met, additional emission control equipment will be installed to make the plant compliant.




6. A comprehensive set of operating procedures will be written and made available for operators describing the compliant arrangement of the plant equipment


7. A gas leak from the plant will trigger a pressure drop alarm and invoke an emergency shutdown procedure and an emergency response procedure.


6.2 SURFACE WATER QUALITY


The site for the proposed development is currently a disused sawmill site. The majority of the area has a light gravel surface allowing the majority of rainfall to infiltrate into the ground. Only a small, heavily trafficked portion of the site’s area is sufficiently compacted to cause rainfall to run off. Rainfall run off from the site currently migrates through an open channel into the table drain on the Esk Main Road - road reserve and along to the St Pauls River.


Tasmania’s State Policy on Water Quality Management 1999 requires that point and diffuse source emissions to surface and groundwater should not cause harm to environmental values such as;

• the protection of aquatic ecosystems; • recreational water quality and aesthetics; • raw water for town drinking water supply; • agricultural water uses, and • industrial water supply.

The development should also be consistent with the objective and requirements of the Water Management Act 1999, the Sate Policy on Water Quality Management 1997 and the State Stormwater Strategy 2010.


The wet scrubber will consume between 60 and 100 litres of water per hour of operation. The majority of this water is ‘makeup’ water to account for evaporation. Reagents are added to the water and are controlled via pH probe which maintains the scrubber water at a neutral state. The addition of both base and acid reagents will cause the water to gradually accumulate salts.

The ELT Recycling Facility will have equipment components that must be founded on concrete slabs. The ELTs stockpiles will be founded on concrete slabs. These new impermeable surfaces will decrease the opportunity for rainfall to infiltrate and hence increase run off from the site.

A critical potential impact will occur as a result of a fire in the ELTs stockpiles. In this scenario a substantial volume of water is likely to be applied to supress the fire. This water and potentially included foam and burnt ELTs ash and effluent will pose a threat to the drains off site and St Pauls River.

6.2.4 AVOIDANCE AND MITIGATION MEASURES

The spent water from the wet scrubber is originally stored and tested to determine if any residual contaminants are present. Under normal operating conditions this water is simply salty water similar in composition to salt water and can be discharged into the stormwater system. There is no sewer or



stormwater connection available at this site. The spent scrubber water will be discharged into site drainage

The Avoca ELT Recycling Facility will program the operation to keep a minimal amount of ELTs in stockpile at any one time. The maximum total stockpile volume is intended to be no more than 8 days of continuous plant operation. It is possible to control the rate of delivery of ELTs from the various sources by close management. The maximum stockpiled volume will be 750 cubic metres (m3) housed in two stockpiles each 20 metres (m) long by 6 m wide and 3 m high. This size of ELTs storage is classified as a small storage facility by the South Australian Fire Authorities Guidelines (South Australian Fire Authorities, July 2014).

By restricting the size of the stockpile the volume of run off can be readily contained by providing a bunded water storage capacity. This bunded capacity will keep the water emanating from the ELT stockpiles separate to the water coming from other impervious surfaces. The bunded capacity will be achieved by placing kerb around the concrete slabs and a pit with a valve on the outlet. The capacity of the bunded area will be about 162 kilolitres.

The minor volume of water anticipated from other impervious surfaces will drain to ground and infiltrate into the land surface.


The development is expected to make only a small change in the rainfall runoff conditions and hence is very unlikely to pose a threat to the water quality in the St Pauls River. A substantial threat arising from the potential for a tyre fire and run off from fire suppression activities is effectively mitigated by the containment of the firefighting water in the bunded capacity of the concrete slabs.


8. The plant and stockpile layout will be compliant with the ‘Tyre Storage Guidelines’ for a ‘small external facility’.

Operator Construction

9. The ELT stockpiles will be situated on concrete slabs that have a bund capacity to retain water from firefighting activities.


6.3 GROUNDWATER The proposed ELT Recycling Facility will cause concrete slabs to be placed over land totalling 800 square metres. A further 4 000 metres will have an improved gravel surface. The balance of the land (2 hectares) will not be affected. There are no plans to excavate at significant depth or install bores.


Minimal impacts on the surface of the land and minor interruption to surface water flows and groundwater recharge are anticipated.

6.4 NOISE EMISSIONS


The site selected for the Avoca ELTs Recycling Facility until recently housed the Avoca sawmill. The sawmill operation would have included activities not dissimilar to the ELTs recycling in that:

• Deliveries would have been made using log trucks.



• Logs would have been stockpiled and moved around on site with a wheel loader. • Logs would have been processed using a sawmill. • Timber would have been stockpiled in racks waiting dispatch.

Since the sawmill closed the operator has been parking trucks on the land and has been collecting fire wood and using a mechanical log splitter to produce fire wood for his own and others use. The site has not been abandoned and activities are occurring on site most days.

There are two residents that live across the Esk Main Road from the proposed facility. There are a further six residences located within one kilometre of the facility. Details of the location and separation distances from these and other residences are included in the Noise Study (Power, M, Oct 2015 (B))


The Proponent will be required to operate the ELT recycling plant in such a manner that noise levels in the community and in particular at neighbouring residences do not exceed acceptable standards. Acceptable standards for this industrial operation are derived from the NSW Industrial Noise Policy (EPA -NSW, Jan 2000).

TABLE 8: RECOMMENDED MAXIMUM NOISE LEVELS

Recommended LAeq Noise Level (dB(A))

Receptor Time of Day Hours Acceptable Recommended Max.

Rural residence

Day 7.00 am to 6.00 pm 55 60

Evening 6.00 pm to 10.00 pm 45 50

Night 10.00 pm to 7.00 am 40 45

Shoulder 5.00 pam to 7.00 am 48 53


If the ELT recycling operation was to generate more noise than the previous sawmill operation it is possible residents closest to the site may be adversely affected. A substantial change with this new operation is that the pyrolysis plant is able to operate 24 hours when at full production. As a result there is potential to adversely affect the amenity of local residents if the plant makes a significant amount of noise at night.

6.4.4 AVOIDANCE AND MITIGATION

To quantify the noise produced by the plant the Proponent engaged a noise specialist to conduct a noise study to model the noise impacts of the plant at various locations where residences are situated. This study appears in this document as Appendix 5.

With reference to this report, the wheel loader and trucks delivering the ELTs are forecast to produce the majority of noise. Noise from other sources including the tyre shredder and the pyrolysis plant will be attenuated by the construction of a screening wall. To ensure noise arising from deliveries and subsequent stacking of the stockpiles doesn’t disturb local residents these



activities will occur during the daytime period and shoulder period. Noise associated with the operation of the pyrolysis plant only will continue during the night time period.

TABLE 9: OPERATING HOURS

Operating Hours

Activity Shoulder Day Evening Night

6.00 am to 7.00 am

7.00 am to 6.00 pm

6.00 pm to 10.00 pm

10.00 pm to 6.00 am

Pyrolysis plant

ELTs shredder

Truck – deliveries and dispatch

Wheel loader – stacking and servicing product bins

The site specific noise study undertaken for this proposal finds the residence likely to experience the highest noise exposure is the property located at 2455 Esk Main Road (Grant Street). This property is located around 240 metres away from the pyrolysis plant. The predicted sound pressure level likely to be perceived at this residence during the shoulder period is 52 dB(A), just under the maximum shoulder criterion of 53 dB(A).

The Proponent has agreed to install a concrete block noise wall on the eastern side of the pyrolysis and ELT shredding plant which is expected to substantially attenuate noise emanating from these facilities.

The Proponent will undertake noise monitoring during commissioning of the plant. The arrangement of the plant allows for special noise attenuation installations to be added if noise monitoring shows acceptable noise levels at neighbouring properties will be exceeded.


The noise study found sound pressure levels able to be attributed to the ELT Recycling Facility should remain within acceptable guidelines. Actual sound pressure levels emitted by the plant will be recorded during commissioning. If it appears sound pressure levels in the community (resulting from normal plant operation) will exceed acceptable levels, then positive control measures will be introduced to limit the noise impacts on neighbours.


10. A concrete block wall will be constructed on the eastern side of the shredder and pyrolysis plant to attenuate noise


11. Sound pressure levels will be recorded during commissioning to test whether actual noise levels are within acceptable limits.

Operator Commissioning

12. If actual sound pressure levels recorded exceed acceptable limits then controls will be implemented.




6.5 WASTE MANAGEMENT


The existing site operations are confined to occasional fire wood collection and storage. There may be small quantities of bark and sawdust and other wood wastes associated with this operation. These activities are undertaken by others and do not form part of this proposal.


Waste handling and storage will be managed in accordance with the hierarchy of waste control. The hierarchy of waste control is arranged in decreasing order of desirability:

• avoidance; • recycling / reclamation; • re-use; • treatment to reduce potentially adverse impacts; and • disposal.

The Tasmanian EPA administers regulations controlling the handling transport and storage of waste within the state under the Environmental Management and Pollution Control (Waste Management) Regulations 2010.


It is possible other substances may be delivered to the site amongst the ELTs. These substances may prove to be environmentally damaging.


Rescycle will provide a waste skip bin on site to cater for typical wastes including; cardboard and plastic packaging that may inadvertently come with a ELT delivery. The bin will be collected periodically by a waste management contractor. All waste materials not processed in the ELT waste stream will be deposited in the skip bin for off-site disposal to a registered refuse disposal site.


Responsible off-site disposal of all superfluous waste products will ensure the site remains clear of damaging waste products.


13. Any unsolicited waste products delivered with the ELTs will be disposed of offsite at an appropriate refuse disposal site.

Operator Operation

6.6 DANGEROUS GOODS AND ENVIRONMENTALLY HAZARDOUS MATERIALS


The existing site operations are confined to occasional fire wood collection and storage. There may be small quantities of fuel and lubricating oils stored on site to support this operation. These activities are undertaken by others and do not form part of this proposal.




ELTs are considered to be a Controlled Waste under the National Environment Protection (Movement of Controlled Waste between States and Territories) Measure, Schedule A List 1. The Tasmanian EPA has adopted this categorisation of Controlled Waste and identifies Tyres as Controlled waste Code T140. Rescycle will market the biochar, heavy oil and scrap steel arising from the recycling operation within Tasmania. The Tasmanian EPA, however, has regulations controlling the handling transport and storage of controlled waste within the state under the Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations 2010.

One of the products of ELT processing will be heavy oil (distillate), liberated as the shredded tyres are digested. This product will be stored in a single storage tank of 5000 litres capacity and made available for offsite dispatch to buyers. The storage facility will be installed in accordance with AS 1940-2004 The Storage and Handling of Flammable and Combustible Liquids. The Proponent will ensure any transport of the heavy oil will occur in accordance with the Australian Code for the Transport of Dangerous Goods by Road and Rail.

The pyrolysis plant will use the gaseous emissions from the digesting process to fuel the burner. LPG will be used to ignite the burner at start-up of the operation. The LPG will be stored on site in a 210 kg storage cylinder established in accordance with AS 4332-2004 Storage and handling of gases in cylinders.


Controlled Wastes are so classified because they can have a deleterious environmental effect if not handled correctly. Stockpiled ELTs can be a fire risk, as they gradually degrade hydrocarbons and their robust shape provides an environment attractive to mosquitos and vermin.

The site wheel loader will be refuelled using a ute mounted refuelling facility. No diesel fuel storage facility will be installed for this operation.


The Avoca ELT Recycling Facility will manage the delivery of ELTs to ensure the total stockpiled quantity of ELTs is less than 750 m3 or a maximum of 8 days continuous operation of the pyrolysis plant. The quick turnaround of the ELT stockpiles will ensure ELTs are not held in storage long enough to commence breaking down or for mosquitos or vermin to colonise the stockpiles.

The ELT stockpiles will be established on bunded concrete slabs able to capture any discharge arising from the ELTs. A valve on the sump collecting water from the bunded slabs will allow stormwater runoff to be held if contamination occurs. Such effluent may then be pumped out for off-site disposal to an authorised refuse disposal site.

The heavy oil storage facility will be established in a proprietary bunded container, with a capacity of 110 percent of the tank’s storage capacity.

The ute used to refuel the loader will also have a hydrocarbon spill kit to immediately clean up any spills that might occur during refuelling. A fuel spill in this case will be most likely as a result of overfilling and be less than 10 litres in volume.


Dangerous goods and environmentally hazardous materials will be stored and handled on site in accordance with the appropriate codes and standards and are not anticipated to pose a hazard to the environment or the community of Avoca.




14. Hazardous substances including heavy fuel oil will be stored in facilities constructed in accordance with the relevant Australian Standards.

Operator Construction & operation

6.7 BIODIVERSITY AND NATURAL VALUES


The proposal site has been substantially modified and is now either gravel surface or introduced pasture grass from the farm land surrounding the site. A shelter belt of eucalypts has been planted along the fence line on the north eastern side. A shelter belt of pine trees has been retained on the northern side. There are records of threatened flora species located on the riparian area closer to the confluence of the St Pauls and South Esk rivers.

The site is over 200 metres away from the St Pauls River but the runoff from the site will eventually drain to the St Pauls River. The Conservation of Freshwater Ecosystem Values Database (DPIPWE (A), 2015) ranks St Pauls River in the vicinity of the Esk Main Road Bridge as having a ‘Conservation Management Priority’ of Very High. The ‘Naturalness Category’ is Low with a ‘Naturalness Score’ of 0.5, the ‘Land Tenure Security’ is Low and the ‘Integrated Conservation Value’ is High.

The bed of the St Pauls River in this location is affected by willow roots and previous bridge construction activities. Water from this location passes into the South Esk River which provides irrigation water for downstream agricultural producers.

Centre point - E: 558848m N: 5374208m Scale (map width): 6612m GDA94 Zone 55

FIGURE 11: CEFV FOR ST PAULS RIVER

Legend:

Conservation management Priority Potential 1

Wetlands VH H M L




Neither the establishment nor operation of the ELT Recycling Facility should impact on natural values, including the health of the St Pauls or South Esk rivers. Legislative requirements include compliance with the Tasmanian State Policy on Water Quality Management 1997 and the Environmental Management and Pollution Control Act 1994 It is also necessary to ensure the proposal does not impact on threatened species listed under the state Threatened Species Protection Act 1995 and federally under the Environment Protection and Biodiversity Conservation Act 1999.


The vegetation cover at the Avoca sawmill site has been substantially modified from its natural state. There are no natural values associated with this site and hence it is highly unlikely establishment or operation of the ELT Recycling Facility will have any measureable impact on natural values.

6.8 MARINE AND COASTAL


The proposal site is located over 45 kilometres away from coastal areas and any water effects must travel at least 60 kilometres through the course of the South Esk River to the Tamar River before draining into Bass Strait in the north.


It is considered implausible either establishment or operation of an ELT Recycling Facility at Avoca can have an effect on coastal or marine areas either directly or indirectly.

6.9 GREENHOUSE GASES AND OZONE DEPLETING SUBSTANCES


The Avoca ELT Recycling Facility will have emission control equipment to ensure the pyrolysis plant will not emit pollutants at levels which may be harmful to the health of workers or the community of Avoca.

6.10 PERFORMANCE CRITERIA The current annual threshold for greenhouse gas emissions (GHG) from a single facility that will trigger the National Greenhouse and Energy Reporting Act 2007 is 25 kilo-tonnes (kt) of CO2 equivalent gas (Clean Energy Regulator, 2015).

6.10.1 DIRECT GREENHOUSE GAS (PYROLYSIS PLANT)

The LPG used to ignite the retort will only be used to initiate the process and the plant is designed to operate for significant periods continuously. The amount of LPG used in the operation will be insignificant for the purposes of calculating GHG emissions.

The pyrolysis plant will be assumed to operate as a combustion engine using ELTs as fuel. The common breakdown of processed ELTs to products gives the following proportions (Robertson, 2015):

• Steel - 24.0% • Char – 22.8%



• Oil - 28.0% • Gas – 25.2%

The gas proportion will be assumed to be the source of GHG emissions.

From the current GHG Emission Factors (Department of the Environment, August 2015) the energy content of tyres is 26.3 Giga Joules/tonne (GJ/t) - Table 1: Fuel combustion emission factors – solid fuels and certain coal based products.

Emission factors are; CO2 - 81.6 kg CO2-e/GJ, CH4 - 0.02 kg CO2-e/GJ, N2O – 0.20 kg CO2-e/GJ.

At maximum production the plant will process around 16 000 tonnes (t) per annum, of which 25.23% will be converted to gas which in turn is combusted

Therefore total annual gas emissions combusted in the retort will be 4 036 t.

The direct GHG emissions will be:

4.036 x 26.3 x 81.6 = 8 661 t CO2

4.036 x 26.3 x 0.02 = 2.1 t CH4

4.036 x 26.3 x 0.20 = 21.2 t N2O

Total = 8 684 t CO2-e

6.10.2 DIRECT GREENHOUSE GAS (TRANSPORT TASK)

The transport task to deliver the ELTs to the plant will be accounted for in this operation.

At full production an annual total of 32 000 m3 of ELTs will be delivered at a rate of approximately 30 m3 per truck load. The cartage task will be 1 100 truckloads or 2 200 trips with an average distance of 100 kilometres. It is assumed the trucks will consume on average 1 litre of diesel per kilometre travelled.

The wheel loader will consume approximately 10 litres of diesel per hour operation. It is likely that the wheel loader will be used for 4 hour per day 5 days per week. The wheel loader will contribute around 10 000 litres to the total consumed supporting the facility.

Total diesel fuel consumed for this task is (2 200 x 100) + 10 000 = 230 000 litres

Diesel fuel energy content is 38.6 Giga Joules per kilolitre (GJ/kL) - Table 4 Fuel consumption emission factors – fuels used for transport energy purposes.

Emission factors are; CO2 - 69.9 kg CO2-e/GJ, CH4 - 0.10 kg CO2-e/GJ, N2O – 0.50 kg CO2-e/GJ.

The annual direct GHG emissions for transport will be:

230 x 38.6 x 69.9 = 620.6 t CO2

230 x 38.6 x 0.10 = 0.89 t CH4

230 x 38.6 x 0.50 = 4.44 t N2O

Total = 625.9 t CO2-e

6.10.3 INDIRECT GREENHOUSE GAS

There are other gases that do not absorb infrared radiation but can still contribute to the greenhouse effect.



6.10.3.1 CO - Carbon Monoxide

CO does not absorb infrared radiation directly and as such is not a greenhouse gas. CO can contribute to an increase in greenhouse gases concentrations by reacting with other atmospheric chemicals such as the hydroxyl radical (·OH) that would otherwise help to destroy other greenhouse gases. (GHG Online, 2015)

6.10.3.2 SO2 – Sulphur Dioxide

SO2 contributes to the formation of aerosols able to directly and indirectly affect warming and cooling in the earth‘s atmosphere. The overall effect of SO2 in the atmosphere is not well quantified; it may have an overall warming or cooling effect.

Given the uncertainties associated with the ‘greenhouse behaviours’ contributions of CO and SO2, their contributions to indirect GHG emissions will be ignored for this calculation. The total GHG contribution by this facility when operating at full production will be the arithmetic sum of the direct GHG contributions, namely:

Annual GHG emissions 8 684 + 626 = 9 310 t CO2-e

The total is below the threshold level of 25 kt, hence Rescycle is not anticipated to need to report under the National Greenhouse and Energy Reporting Act 2007.

6.11 HERITAGE


6.11.1.1 European heritage

The properties below are listed on the Tasmanian Heritage Register and are within 1.5 km of the proposed ELT recycling operation.

TABLE 10: HERITAGE PROPERTIES IN THE AREA

Place ID Name Address Status Distance from facility (m)

4873 House 23-27 Arthur Street Permanently Registered

640

4875 Marlborough (Blenheim) House 3 Blenheim Street Permanently Registered

570

4879 Former St Thomas' Rectory Stieglitz Street Permanently Registered

275

4880 St Thomas' Anglican Church 9 Falmouth Street Permanently Registered

475

4883 Bona Vista 75 Story Creek Road Permanently Registered

1 490



Former St Thomas’ Rectory

The only property in close proximity to the proposed Avoca ELT Recycling Facility is the former St Thomas’ Rectory on Stieglitz Road. This property is described below:

Statement of Significance: This site is of historic heritage significance because its townscape associations are regarded as important to the communitys sense of place. The former St ThomasRectory is of historic heritage significance because of its ability to demonstrate the principal characteristics of a single storey brick Victorian Georgian rectory. These characteristics are found in the external form, construction methods and the detailing, both externally and internally.

Description: Built of colonial brick the house while appearing as single storey has a substantial basement and sunken garden. The front doorway has a semi-circular arch and substantial decorative surround. There is a four panel front door with radial fanlight. The windows in the front facade are unusually large for the period.

6.11.1.2 Aboriginal cultural heritage

The site selected for this proposal has been previously cleared and a fly-ash type material has been placed as a unsealed pavement over the entire area. If Aboriginal cultural artefacts were present they would have been completely concealed by these previous works.


An Unanticipated Discovery Plan procedure will be followed if, during the course of the establishment works, an item or site is revealed that is suspected of having Aboriginal cultural heritage significance.


The former St Thomas rectory is on the opposite side of the Esk Main Road. Esk Main Road is a designated Heavy Production Vehicle Route, a Heavy Mass Limit Route and one of Tasmania’s Strategic Freight Routes. A small number of additional light loaded vehicles will be turning into the Avoca ELT Recycling Facility as a result of the proposed operation. These vehicles will approach primarily from the major centres of Burnie, Launceston and Hobart. It is considered highly unlikely the modest increase in traffic movements associated with this proposal will adversely affect this heritage listed property.

6.12 LAND USE AND DEVELOPMENT


6.12.1.1 Industrial The development site is part of a site previously used to operate the Avoca sawmill. The sawmill operator does not plan to re-establish the sawmill operation and hence does not require the proposed area of land for logs and timber stockpiles.

6.12.1.2 Agricultural The surrounding land is used for agricultural production. Rich basaltic soils and irrigation allows a variety of crops to flourish on this land, though the land is classified as Class 4 capability (DPIPWE (B), 2015). The sawmill site has been excluded from the farm development plan and the farm’s capability is not impeded by the site remaining unavailable for agricultural production.



6.12.1.3 Transport The Esk Main Road runs along the northern boundary of the site. The Esk Main Road is a designated freight route and will not be compromised by the extra traffic associated with this development (see Traffic Impact Assessment included in this document as Appendix 7.

6.12.1.4 Residential There are two residences on the opposite side of the Esk Main Road to the proposed development. The land here has a land use zone status of Rural Resource. Residential uses are only permitted in the Rural Resource Zone if for existing uses or discretionary for a single dwelling. Land on the opposite side of the St Paul’s River has residences and is zoned Low Density Residential. There is a minimum lot size of one hectare in this zone. The existing lots along St Pauls Place are already less than the minimum lot size and hence will not be subdivided.

The introduction of the Avoca ELT Recycling Facility is not expected to adversely affect neighbouring landowners’ capacity to use this land.

6.12.1.5 Tourism The Esk Main Road is a major tourist route for travellers to and from the east coast. The townships of Fingal and Avoca are pleasant stops along the way and provide fuel and food shops to refresh travellers. The proposed development is well screened by existing trees from vantage points in Avoca and from the Esk Main Road.

The establishment of the Avoca ELT Recycling Facility is not expected to have an adverse impact on tourists’ enjoyment of the town.

6.13 VISUAL IMPACT


The Avoca sawmill has an avenue of mature Radiata pine trees growing along the front boundary fence which screen the site from the Esk Main Road. Another shelter belt of eucalypts has been planted along the north east boundary of the site. This shelter belt screens the site for vantage points to the east.

6.13.2 ASSESSMENT OF NET IMPACT

The original tree plantings will not be disturbed and will continue to effectively screen the ELT Recycling Facility from public observation points on the Esk Main Road and from Avoca.



PLATE 7: LOOKING WEST AT SITE FRONTAGE

PLATE 8: LOOKING WEST CLOSER TO ACCESS



PLATE 9: LOOKING EAST AT SITE FRONTAGE

PLATE 10: LOOKING SOUTH AT ACCESS ROAD




15. The stands of trees along road reserve boundary and the eastern fence line will be retained to provide a visual screen.


6.14 SOCIO-ECONOMIC ISSUES The economic business case is explained in the prospectus provided for the proposal. This document is included as Appendix 6.


Avoca is a small town existing as a business centre for agricultural industries and servicing passing trade from freight transport and tourism. In the past the timber industry provided employment and the local sawmill would have provided employment directly and for contractors servicing and carting logs. The other centres in the Fingal Valley support other industries, namely coal mining near Fingal and east coast tourism attractions at St Marys. The demise of the timber industry has disproportionally affected Avoca compared to the other local towns.


The Avoca ELT Recycling Facility is forecast to have a modest positive impact on the economic situation in Avoca by providing a small amount of employment in the areas best suited to the skills/ expertise of the local population; see Section 5.3.

6.15 HEALTH AND SAFETY ISSUES


The development site is accessed only from a public area through a boom gate on the entrance road. The rest of this boundary is fenced as are the other boundaries with private land.

The equipment used for the two major processes will have moving, turning shafts and potentially pinch points not dissimilar to the former sawmill operation. The pyrolysis plant will introduce a high temperature vessel and flame that will ‘flare off’ excess volatile gases.


The construction phase of the establishment process will comprise standard construction activities including several concrete pours, cartage to setup the various vessels and equipment as well as block laying and limited roofing. All these activities carry inherent risk of workplace injuries.

The facility can pose a danger to the general public if unrestricted access to the operating equipment was allowed.

Operating equipment can pose a threat to the employees consistent with other industrial styles of operation.


During construction the site will be secured to ensure only contracted employees engaged on the construction work have access.



Once operational the site will be secured behind a locked boom gate (if unattended) and will be monitored at all other times. The close proximity to the Esk Main Road means passive surveillance is usually effective in ensuring anyone attempting to gain access to the site will be observed by passing traffic.

The equipment will be set up on site with contemporary standards of guarding for all moving parts and with the provision of access ladders and walkways to all routine maintenance and servicing points.

The site will have an induction training procedure to ensure all employees and registered visitors who must access the equipment have a thorough knowledge of the health and safety hazards associated with the equipment.


The Proponent has kept the risk to the public as low as possible by locating the Avoca ELT Recycling Facility in an easily secured and observed location. Risks would most likely be higher if the plant was located on a remote and isolated site where people could approach it unobserved.

The plant equipment is around ten years old but this installation will be new and all guarding and covers will be installed to contemporary standards providing the best arrangement for employee safety.


16. All equipment will be installed in compliance with contemporary industrial access and guarding installation standards.


6.16 HAZARD ANALYSIS AND RISK ASSESSMENT


A detailed Hazard Analysis and Risk Assessment was undertaken for all phases of the Avoca ELT Recycling Facility from establishment, through commissioning, operation and decommissioning. The assessment is included as Appendix 7.


The hazard analysis and risk assessment found the risk rating of two specific hazards could be lowered to the moderate range. The risk rating of all other hazards could be lowered to the low range.

The two remaining hazards in the moderate range are:

• Excessive atmospheric emissions impact on neighbouring residents. Without controls this hazard is in the extreme range because the likelihood is almost certain. It is possible to achieve a final risk rating of moderate because of the pyrolysis plant design, the addition of emission control equipment and ability to add more equipment if required. These measures make an uncontrolled, excessive emission unlikely.

• Fire in tyre stockpile produces excessive atmospheric emissions. A range of controls have been applied to manage this risk. Achieving a final risk rating of moderate is as a result of the Proponent’s approach to receiving ELTs to ensure the stockpiles remain small and under the threshold classified by the General Guidelines for Rubber Tyre Storage as a small storage facility.



As these hazards remain in the moderate range the Site Manager has a responsibility to ensure mitigation and management controls are applied and maintained.

During commissioning the Operator will develop and maintain a series of Standard Operating Procedures to manage the equipment in a safe manner. A preliminary Emergency Response Plan is included as Appendix 8 as an example.

6.17 FIRE RISK


The Avoca sawmill would most likely have routinely burnt wood waste and saw dust as a normal part of its operation, a practice that continued at least until work on this proposal commenced.

PLATE 11: SAW DUST FIRE UNDERWAY DURING EARLY SITE INVESTIGATION.

Another potential danger is from wildfire attacking the facility from surrounding farm land on the boundary or the facility causes the farmland to catch fire/ ignite.

6.17.2 PERFORMANCE CRITERIA

The facility will be designed and run to be compliant with the Fire Service Act 1979 and the Work Health and Safety Act 2012.


There is a significant danger posed by fire in a facility where tyres are stored and processed. A fire in a tyre stockpile in Longford started on 15 Feb 2012 and was extinguished on 17 Feb 2012. Apart from the risk of the fire ‘getting away’ there were significant issues in the township with air quality associated with the acrid smoke. It was estimated the tyre stockpile contained around 12 000 tyres (EPA Division, May 2012).

The consequences of a wildfire attacking the facility can be severe with flammable liquids stored onsite, the pyrolysis process utilising contained flammable gases and the tyre stockpiles vulnerable. It is also possible the facility could provide an ignition source for a grassfire in the paddocks across the boundary.




The Avoca ELT Recycling Facility will be managed to ensure the ELTs are not stored in stockpiles for lengthy periods. The arrangement of stockpiles will accord with the General Guidelines for Rubber Tyre Storage (South Australian Fire Authorities, July 2014) for an Outdoor Storage Facility 3.1 Small Storage Facilities. There will be two stockpiles, each will be a maximum of 20 m long by 6 m wide and 3 m high having capacity of 1 500 ELTs or 375 m3.

This volume of ELTs in two distinct stockpiles provides easy access for firefighters to isolate and extinguish any fire. Access is also enhanced by separating the stockpiles by 20 metres and keeping a clear distance from the ends of the stockpiles of at least 12 metres.

There will be two fire hydrants installed on the site to provide first strike firefighting capability to contain any fire until such time as the regular firefighters arrive at the site. Avoca has a fire station located in Churchill Street.

The danger posed by a grassfire attack from the farm land neighbouring the facility is addressed in the Bushfire Management Plan included in this document as Appendix 9. The recommendations of the Bushfire Management Plan have informed the layout of the facility.


The arrangement of the Avoca ELT Recycling Facility has been informed by the General Guidelines for Rubber Tyre Storage. This and by adopting the recommendations of the Bushfire Management Plan designed specifically for this site have reduced the risk of fire from all sources to as low as is reasonably practical for a ELTs processing facility.


17. A first strike firefighting capability will be maintained on site and the operators will be trained in its use.


6.18 INFRASTRUCTURE AND OFF-SITE FACILITIES


The development site is serviced with good road access and sight distances on the intersection with Esk Main Road. Esk Main Road is a regional freight route and hence is designed and maintained to carry freight.

Three phase electricity is connected to the site and a transformer is installed on the pole giving ample electrical capacity to operate the plant..

Reticulated water is supplied to the site with adequate capacity to service two fire hydrants with 10 litres per second delivery simultaneously.


The Avoca ELT Recycling Facility will not exceed the supply capability of electrical or water supply infrastructure. The Traffic Impact Assessment (Section 6.21) demonstrates the impact of the extra truck movements on Esk Main Road will be negligible.


Integrated Land Management and Planning | Monitoring and review 50

6.19 ENVIRONMENTAL MANAGEMENT SYSTEMS This proposal includes new emission control equipment not used in the plant previously. These new components will provide an extra level of confidence the plant will generate atmospheric emissions well below acceptable limits. New equipment, however, means the original operating procedures will not be consistent for this new configuration of plant.

The Proponent will develop a series of operating procedures during the commissioning process to guide operators about how to run the facility efficiently and within the agreed limits for environmental emissions. The Proponent will develop an induction manual to specify the procedures and responses to incidents and emergencies which may be encountered during the operation of the plant.

6.20 CUMULATIVE AND INTERACTIVE IMPACTS The only predicted cumulative impact foreseen is the additional transport task associated with this proposal on the existing freight load on Esk Main Road. The Traffic Impact Assessment states the operation will add, on average, one additional truck movement per hour on top of the existing 70 movements. The TIA further notes this extra load will not cause the efficient carrying capacity of Esk Main Road to be exceeded.

6.21 TRAFFIC IMPACTS


The Avoca ELT Recycling Facility will be serviced by an access road intersecting with Esk Main Road. Esk Main Road is classified as a Category 3 – Regional Access Road under the Tasmanian State Road Hierarchy.

6.21.2 PERFORMANCE CRITERIA

To evaluate the traffic impacts associated with the proposed development the Proponent commissioned a Traffic Impact Assessment (TIA). The TIA was prepared in accordance with the requirements of Code E4 of the Northern Midlands Interim Planning Scheme 2013 and appears in this document as Appendix 10.


The TIA found access arrangements with regard to the speed environment and sight distances are adequate. There should be improvement works to seal the existing access to meet commercial access standards in accordance with Tasmanian Municipal Standard Drawing TSD R05 V1.

The additional truck movements associated with tyre delivery and product dispatch were found to not have any significant adverse impacts on the surrounding road network in terms of efficient carrying capacity or road safety.


18. The access road junction with Esk main Road will be improved to meet Tasmanian Municipal Standard Drawing TSD R05 V1.



Integrated Land Management and Planning | Monitoring and review 51

7 MONITORING AND REVIEW The equipment arrangement proposed for the Avoca ELT Recycling Facility will differ from the arrangement previously operated in Western Australia. Extra emission control equipment has been added to the process circuit. The emission levels expected from this plant are well below acceptable standards. As this is a new arrangement of equipment the commissioning process will be critical in understanding how to run the plant to operate efficiently and with the least emission of pollutants.

7.1 AIR QUALITY MONITORING A series of stack tests will be conducted during commissioning to ensure the emission of certain contaminants is within acceptable standards. A record of these tests will be complied to provide proof the plant under normal operating conditions can maintain emission levels within acceptable standards.

7.2 NOISE LEVEL MONITORING Sound pressure levels produced by the plant under various operating conditions will be recorded during the commissioning of the plant. A record of these tests will be compiled to produce proof the plant can run under various operating conditions while maintaining sound pressure levels within acceptable parameters.

7.3 REVIEW The results of the commissioning air quality monitoring and the noise monitoring will be compiled and presented to the EPA at completion of the Commissioning Stage. An analysis of the monitoring results will inform further monitoring and reporting requirements for the plant.

8 DECOMMISSIONING AND REHABILITATION At the end of the useful life of the plant it is likely individual components will still have a market value and will be sold off either individually or as a process line lot.

8.1 DECOMMISSIONING The decommissioning process will essentially be the reverse of the commissioning process, the major steps will be:

• Clear all vessels and pipelines of products, clean and remove products or waste to either sale or disposal at appropriate sites.

• Isolate electrical power and water from equipment and terminate supply connections. • Dis-assemble major equipment pieces and load onto float transport for cartage to sale

destination. • Break out concrete foundations and slabs if either of the other site tenant or the landowner

do not wish to retain the foundations for other purposes. • Cart waste products to an appropriate disposal facility. • Apply new gravel to the site and spread and compact to re-establish a trafficable surface.

8.2 REHABILITATION To restore the site to its pre-development condition the Proponent will be required to re-establish a gravel trafficable surface. This work will occur if other site tenants and the landowner do not wish to retain any site infrastructure.


Integrated Land Management and Planning | Commitments 52

9 COMMITMENTS Item Commitment Responsible When

1. An acceptance protocol will be introduced for sources supplying ELTs with the potential to be contaminated with dirt weeds or vermin.


2. Dust emissions will be monitored and surfaces dampened if a visible dust plume is observed crossing the boundary.


3. The plant will be installed with provision to install additional emission control infrastructure if required.

Operator During construction

4. Stack tests will be undertaken during commissioning to prove compliance with atmospheric emission standards.


5. If emission standards are not met additional emission control equipment will be installed to make the plant compliant.


6. A comprehensive set of operating procedures will be written and made available for operators describing this arrangement of the plant equipment .


7. A gas leak from the plant will trigger a pressure drop alarm and invoke an emergency shutdown procedure and an emergency response procedure.


8. The plant and stockpile layout will be compliant with the ‘Tyre Storage Guidelines’ for a ‘small external facility’.


9. The ELTs stockpiles will be situated on concrete slabs that have a bund capacity to retain water from firefighting activities.


10. A concrete block wall will be constructed on the eastern side of the shredder and pyrolysis plant to attenuate noise.


11. Sound pressure level recording will be undertaken during commissioning to demonstrate that actual noise levels are within acceptable limits.


12. If actual sound pressure levels recorded exceed acceptable limits controls will be implemented.


13. Any unsolicited waste products delivered with the ELTs will be disposed of offsite at an appropriate refuse disposal site.

Operator Operation

14. Hazardous substances including oil will be stored in facilities constructed in accordance with the relevant Australian Standards.


15. The stand of trees along road reserve boundary and the eastern fence line will be retained to provide a visual screen.


16. All equipment will be installed in compliance with contemporary industrial access and guarding installation standards.


17. A first strike firefighting capability will be maintained on site and the operators will be trained in its use.


18. The access road junction with Esk main Road will be improved to meet Tasmanian Municipal Standard Drawing TSD R05 V1.



Integrated Land Management and Planning | 53

10 CONCLUSION This document, along with a number of specialist studies, demonstrate the Avoca ELT Recycling Facility will be able to recycle up to 16 000 tonnes of ELTs and convert them to energy, and products that can be further recycled or ‘on sold’. The successful operation of the Tasmanian trial site will provide a model for more ELT recycling sites throughout the country and perhaps overseas.


Integrated Land Management and Planning | 54

11 REFERENCES

ABS. (2015, October 8). 2011 Census Quick Stats - Avoca (Tas.). Retrieved October 8, 2015, from Australian Bureau of Statistics: http://www.censusdata.abs.gov.au/census_services/getproduct/census/2011/quickstat/SSC60012?opendocument&navpos=220

BOM. (2014, July 24). Climate Statistics for Australian Locations. Retrieved July 24, 2014, from Australian Government - Bureau of Meteorology: http://www.bom.gov.au/climate/averages/tables/cw_092012.shtml

Clean Energy Regulator. (2015, October 15). Reporting thresholds. Retrieved October 15, 2015, from National Greenhouse and Energy Reporting: http://www.cleanenergyregulator.gov.au/NGER/Reporting-cycle/Assess-your-obligations/Reporting-thresholds

Department of the Environment. (August 2015). National Greenhouse Accounts Factors. Canberra: Commonwealth of Australia.

DPIPWE (A). (2015, September 2). Site Examination: Conservation Management Priorities (CMP). Retrieved September 2, 2015, from WIST Water Information System of Tasmania: http://wrt.tas.gov.au/wist/ui#fopt

DPIPWE (B). (2015, November 12). LIST Map. Retrieved November 12, 2015, from The LIST: http://maps.thelist.tas.gov.au/listmap/app/list/map

EPA Division. (May 2012). The tyre-depot fire at Longford Tasmania, 15-17 February 2012. Hobart: online - Environment Protection Authority.

EPA -NSW. (Jan 2000). NSW Industrial Noise Policy. Sydney South: Environment Protection Authority.

GHG Online. (2015, July 13). Other Indirect Greenhouse Gases. Retrieved October 12, 2015, from GHG Online: http://www.ghgonline.org/index.htm

North Barker Ecosystem Services. (Feb 2015). Esk Main Rd - St Pauls River Bridge and Fingal Culvert B3169 Replacements and potential impacts on Fingal Culvert 892 Flora and Fauna Habitat Suvery. Longford: unpublshed avaiable on NMC Website.

Northern Midlands Council. (2013). Northern Midlands Interim Planning Scheme 2013. Longford: Northern Midlands Council.

Power, M. (Oct 2015 (B)). Rescycle Pty Ltd - Avoca End of Life Tyre Recycling Facility - Ambient Noise Study. St Leonards: unpublished.

Power, M. (Oct 2015 (A)). Rescycle Pty Ltd Avoca End of Life Tyre Recycling Facility-Ambient Air Quality Study. St Leonards: unpublished.

Robertson, S. (2015, October 15). email. (B. Williams, Interviewer)

South Australian Fire Authorities. (July 2014). Built Environs Section Guideline N0. 13 - General Guidlines for Rubber Tyre Storage. Adelaide: Metropolitan Fire Service.


Integrated Land Management and Planning | Appendices 55

12 APPENDICES

APPENDIX 1 – TOXFREE KWINANA PERMIT


Integrated Land Management and Planning | Appendices

APPENDIX 2 – AMBIENT AIR STUDY



APPENDIX 3 – EXAMPLE OPERATING MANUAL



APPENDIX 4 – TOX FREE KWINANA OPERATING MANUAL TABLE OF CONTENTS



APPENDIX 5 – AMBIENT NOISE STUDY



APPENDIX 6 – BUSINESS CASE - PROSPECTUS



APPENDIX 7 – HAZARD ANALYSIS



APPENDIX 8 – EMERGENCY RESPONSE PLAN - PRELIMINARY



APPENDIX 9 – BUSHFIRE STUDY



APPENDIX 10 – TRAFFIC IMPACT ASSESSMENT

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