berrima cement works - major projects

BORAL LAND AND PROPERTY GROUP Build Something Great TM

Berrima Cement Works Statement of Environmental Effects Isotainer Loading Operations Modification August 2019 Section 4.55(1A) Modification Application

19 August 2019 1

Control Sheet

Document Information

Document name Berrima Cement Works Mod 12 SEE

Document file name 190702 Berrima Cement Mod 12 SEE

Document location

G:\066 PD&E\NSW\Projects\Berrima Cement\Approvals\Development application\DA 401-11-2002-i (Kiln 6)\13. MOD 12 (Isotainer)

Change History

Author Title

Date Change Description Version

Christopher Colusso Graduate Planner

Draft for review 1

Adnan Voloder Planning & Development Manager

1 JUL 10 Action review changes and finalise report 2


19 AUG 19 Action review changes and finalise report – SM comments

3

Review

Reviewer Title

Approval Date Change

(Y/N)


2 JUL 19

Greg Johnson Berrima Cement Works

2 JUL 19

Sally Munk Principal Planning Officer - DPIE

18 JUL 19

Authorisation

Authorised by Title Approval Date

Kate Jackson Regional Manager NSW/ACT

Distribution:

Distributed to Date Department / Section

Sally Munk Department of Planning & Environment

Berrima Cement Works Boral Cement

This report and all material contained within it is subject to Australian copyright law, and is the property of Boral Limited. Other than in accordance with the Copyright Act 1969 or the report, no material from the report may, in any form or by any means, be reproduced, distributed, stored in a retrieval system or transmitted, other than with the written consent of Boral Limited or its subsidiaries.

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Contents

Control Sheet ........................................................................................................................ 1

1. Introduction ................................................................................................................... 3

1.1 Project overview .................................................................................................... 3

1.2 The applicant .......................................................................................................... 4

2. Site location and context .............................................................................................. 4

2.1 Site location ............................................................................................................ 4

2.2 Land use designation and zoning ........................................................................ 4

3. Existing operations ....................................................................................................... 6

4. Proposed modification .................................................................................................. 6

4.1 Isotainer Filling Process ....................................................................................... 6

4.2 Construction ........................................................................................................... 8

4.3 Justification .......................................................................................................... 10

5. Legislative context ...................................................................................................... 11

5.1 Environmental Planning and Assessment Act 1979 ........................................ 11

5.2 Protection of the Environment Operations Act 1997 ........................................ 11

5.1.1 Modification approval pathway ....................................................................... 11

5.1.2 Environmental impact ..................................................................................... 12

5.1.3 Substantially the same development .............................................................. 12

6. Environmental assessment ........................................................................................ 14

6.1 Construction phase impacts ............................................................................... 14

6.1.1 Noise and vibration ......................................................................................... 14

6.1.2 Traffic .............................................................................................................. 14

6.1.3 Air quality ........................................................................................................ 14

6.1.3 Waste .............................................................................................................. 14

6.2 Operational phase impacts ................................................................................. 14

6.2.1 Noise ............................................................................................................... 14

6.2.2 Traffic .............................................................................................................. 18

6.2.3 Air quality ........................................................................................................ 19

6.2.4 Greenhouse gas ............................................................................................. 19

6.2.5 Visual impact .................................................................................................. 19

7. Consultation ................................................................................................................ 21

8. Conclusion ................................................................................................................... 21

Appendix A ......................................................................................................................... 22

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1. Introduction

1.1 Project overview

Boral Cement Limited (formerly known as Blue Circle Southern Cement Ltd, (hereafter ‘Boral’) operates the New Berrima Cement Works (the facility) in the Wingecarribe local government area (LGA). Operating since 1929 the site produces an array of cement products for use in domestic and international construction markets.

The facility operates subject to two development consents issued by the Department of Planning and Environment (DPE), namely; DA 401-11-2002 (Kiln 6, May 2003); and DA 85-4-2005 (Mill 7, Aug 2005). The development consent for DA 401-11-2002 has been modified ten times. The site is also subject to an Environment Protection Licence (EPL 1689) issued by the NSW Environment Protection Authority (EPA).

MOD 10 of DA-401-11-2002, sought for the approval to use Solid Waste Derived Fuels (SWDF) as an energy source and the construction of a SWDF storage shed and kiln feeding system, was approved in April 2019.

Mod 11 of DA 401-11-2002, the latest modification, seeks the approval for the use of HiCal50 materials during start up and shut down processes of the Kiln; when blended with coal. This application is currently being assessed by the DPE. The approval history of the facility is summarized in Table 1.1 below.

Table 1.1 Modification approval history for Site

Date Approval

Particulars Mod No.

Reference

26 September 2005 1 MOD 2-1-2004 Use of non-standard fuels

22 September 2006 2 MOD 109-9-2006 Removal of hazardous waste prohibition

13 February 2007 3 MOD 12-2-2007 Trial use of tyre chips

24 April 2008 4 MOD 4 Varying usage of coke fines

31 August 2009 5 MOD 5 Coal deliveries by rail

20 June 2012 6 MOD 6 Stockpiling of coal for sale and transport

16 April 2012 7 MOD 7 Trial and use of blast furnace slag

5 August 2012 8 MOD 8 Administrative changes to align DA and EPL

5 October 2016 9 MOD 9 Receipt and use of up to 100,000 tpa of SWDFs

11 April 2019 10 MOD 10 Modification to SWDF storage shed dimensions

Expected August 2019 11 MOD 11 HiCal50 Modification for Startup/Shutdown

Boral submits this application pursuant to Section 4.55 (1A) of the Environmental Planning and Assessment Act 1979 (EP&A Act) to modify State Significant Development (SSD) DA 401-11-2002. The proposed modification includes:

Loading, unloading, storage and filling of isotainer containers on the land, for the purposes of transporting cement; and

sundry improvements to the proposed storage area, and internal truck route on the site to facilitate the filling of isotainers from the existing and currently operating filling station.

No other operational changes are proposed as part of the modification.

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1.2 The applicant

The proponent and owner of the Cement Works is Boral Cement Limited, formerly known as Blue Circle Southern Cement Ltd., which is a wholly owned subsidiary of Boral Limited. Boral is an international building and construction materials group, headquartered in North Sydney, Australia. Boral’s competitive position is underpinned by being a market leader in cement and construction materials in Australasia, the Boral USG Joint Venture plasterboard business in Australia and Asia, and cladding and roof tiles in the USA. Boral Australia employs over 5,000 employees in its quarry, concrete, asphalt, concrete placing and cement operations. The business is a major supplier of products to the dwelling, commercial construction, and roads and engineering markets. In NSW, Boral has over 180 operations which include cement works, quarries, sand pits, recycling facilities, and asphalt and concrete plants. These operations produce a range of products including cement, concrete aggregates, crushed rock, cement, asphalt, and sealing aggregates, road base materials, sand and gravels for the Australian construction materials industry.

2. Site location and context

2.1 Site location

The facility is located south of New Berrima in the Southern Highlands of NSW in the Wingecarribee LGA (Figure 2.1). Access is via Taylor Avenue, which connects the facility with the Hume Highway, approximately 2.5km to the west.

The facility is located on Boral owned land, which comprises approximately 135 ha. The area to the south east of the Cement Works between New Berrima and Moss Vale is part of the Moss Vale Enterprise Corridor (MVEC) set aside for employment generating development under the Wingecarribee Local Environmental Plan 2010 (Wingecarribee LEP).

The closest residential zone to the works site is located in New Berrima, approximately 650m north of the No 6 kiln stack at the closest points. Residential zones are also located in New Berrima, approximately 2,150m north of the No. 6 kiln stack. New Berrima residential area is flanked to the south and east by “Private Recreation” areas.

The area subject to this modification is located toward the center of the operations area, located over 280m from the nearest residential receiver. All activities proposed as part of this operation are to be contained within the site.

2.2 Land use designation and zoning

The site is situated within the Wingecarribe LGA and is zoned Heavy Industrial (IN3). The land to the immediate east and south is zoned General Industrial (IN1).

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Figure 2.1 Regional context

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3. Existing operations

Operating since 1929, the Berrima Cement Works produces up to 1.56 million tonnes of cement clinker (rolling average) for sale directly or for conversion into cement for sale in NSW, the ACT and internationally. These products are transported via road, rail and sea via Port Kembla.

The facility operates one kiln and two cement mills, along with ancillary storage and stockpile facilities. Cement manufacture is an energy intensive process due to the high temperatures required to produce clinker. To fuel this process, the site uses a range of fuel sources including coal; gas; diesel; and SWDFs.

Distribution of cement product currently occurs via road and rail, using a range of cement storage methods, including road based cement tankers carrying 49m3 of cement per truck. Delivery by road involves empty tanker vehicles being filled at the site, allowing for statewide distribution. A similar methodology is used for rail distribution; however rail deliveries are a more effective means of mass distribution of cementitious products.

Isotainers are also currently transported by road, however these activities do not involve the removal of the isotainer from the truck, as these vehicles are filled using the same methodology as for cement tankers.

4. Proposed modification

The proposed modification involves: loading, unloading, storage and filling of isotainer containers on the land, for the

purposes of transporting cement via rail; and sundry improvements to the proposed storage area, and internal truck route on the

site to facilitate the filling of isotainers from the existing and currently operating filling station.

A modification of DA-401-11-2002 is being sought to include an additional clause within the set of conditions provided in condition 1.2 of the development consent.

The set of conditions provided in condition 1.2 seek to regulate the ‘Scope of Development’ for the site, and includes the relevant assessment documentation provided with each subsequent modification sought.

This modification seeks to formalise the isotainer activities on the site and proposes a new condition proceeding condition 1.21(r), as follows:

r) MOD 12 for the commencement of isotainer loading activities in accordance with accompanying documents, namely the Statement of Environmental Effects entitled ‘Isotainer Loading Operations Modification’ dated July 2019 and prepared by Boral Cement Limited.

4.1 Isotainer Filling Process

Isotainers are tank-like vessels that are encompassed within a standardised rectangular frame, which are of a similar dimension to a shipping container. The standardised dimensions allow the isotainers to be moved on various means of transport, including rail, road and sea. An image of a typical isotainer is provided below, in Figure 4.1.1.

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Figure 4.1.1 Typical Isotainer to be utlised as part of the project

An empty isotainer weighs three tonnes and can carry up to 28 tonnes of product (the same amount as a tanker). Product can be discharged from the isotainer at one tonne per minute, and they are currently used on some Boral trucks within the road transport fleet.

The proposed isotainer filling process will be as follows:

train arrives to site with flat-bed cars, with approximately 56 empty isotainer containers;

isotainers unloaded from the train, using a ‘reach stacker’ (a large forklift with a special lifting arm) which places the isotainers in the stack area waiting to be loaded onto a truck for filling;

trucks will transport the isotainers to the existing filling station at the Cement works site, and return the isotainers to the stack/loading area;

full isotainers loaded onto the train, to allow for distribution. Trucks involved in the movement of the isotainers will use internal roads between the isotainer loading operations stack area and filing area and will not leave the cement works. The rate of movement of the isotainers will be approximately one every 15-minutes, during day-shift only. A truck will be used for this loading process, with the isotainers loaded and unloaded from the truck with a reach stacker. A figure showing a typical reach stacker is given in Figure 4.1.2.

Figure 4.1.2 Typical reach-stacker to be utlised as part of the project

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Trains will consist of 28 flat-bed wagons with 2 isotainers per wagon. It is proposed that there will be 3 of these isotainer trains per week. Each train will arrive at the site carrying empty isotainers. This would equate to 168 isotainers being handled at the site, during the course of a typical week, facilitated through the extra six rail movements per week – three arriving and three departing. Time slots for these movements are yet to be established. These empty isotainers will be unloaded and the train reloaded with full isotainers over a 6 hour period, between 4pm and 10pm; according to the arrival of the train to the site. The same reach-stacker used to unload and load the trucks at the terminal, will be used to unload and load the trains. Truck activities at the site, facilitating the filling process of the empty isotainers, will occur between 8am and 4pm. The key truck and reach-stacker activity routes within the site are demonstrated in the follow image, being Figure 4.1.3.

Figure 4.1.3 Truck movement paths used in the computer noise model calculations The isotainer loading operations will allow increased rail despatch of cement from the site while reducing the number of road transport movements by 100 tankers per week on average.

4.2 Construction Construction activities will include the preparation of the isotainer storage area, to ensure a level and sealed surface is provided for the loading/unloading activities, and appropriate drainage infrastructure to manage surface water run-off and link it to the existing site’s water management system. The internal road route is currently hardstand, and will not require any alterations, and thereby the total area of hardstand will not be increased; and there will be no increase in surface water run-off as a result of this proposal for the internal road network. The isotainer storage area is covered by partial hardstand, and will be further sealed to ensure a stable surface is provided; providing a total 2,500m2 storage area.

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Construction is anticipated to take less than 2 weeks, commencing after modification approval is granted. Construction activities would be limited to normal working hours and the anticipated maximum number of construction staff on site at any one time would be 10. A surface water management plan will be provided subsequent to approval being received for the project, and prior to the commencement of works at the site. The proposed isotainer loading area is illustrated below in Figure 4.2.1 and 4.2.2.

Figure 4.2.1 Site Plan

Figure 4.2.2 Site Operational Plan

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The plant and equipment that would be required for the construction works is similar to that employed during the course of Mod 9 and Mod 10 works, and is provided in Table 4.3 below.

Table 4.3 Required construction plant and equipment

Concrete agitator truck(s) Grader Flat top truck 10t tip truck 25t capacity excavator D4 dozer 10t road roller

Much of this equipment is currently located and operates at the site; thereby impacts from continuing use are considered to be negligible. Section 3.2 of the attached noise and vibration assessment deals with the specific impacts attributed to these activities. No external vehicle movements will be associated with the proposed construction activities. 4.3 Justification

The proposed introduction of isotainer activities on the site is needed to facilitate a more effective use of the existing rail infrastructure on the site, while incorporating new mass volume delivery systems for transportation across the state.

Isotainers transported on rail will have the potential to reduce the site’s reliance on road based methods for delivery of mass volumes of cement, thereby reducing Boral’s overall carbon footprint, and providing more efficient long range deliveries without impacting the existing road networks.

At peak operating capacity, isotainer deliveries could transport between 100,000 – 400,000 tonnes per year of cement by rail, potentially replacing between 150,000 – 200,000 tonnes per year, delivered by road (or approximately 148 trucks per week).

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5. Legislative context

5.1 Environmental Planning and Assessment Act 1979

The Cement Works was approved under Part 4 of the EP&A Act in May 2003. The current modification is being presented as a 4.55(1A) modification, which is discussed in Section 5.1.1 of this report.

The proposed modification has been assessed against key aspects of the original application and development consent. As the proposed modification will involve minimal environmental impact, as demonstrated through the Recognition Research Environmental Noise Assessment attached to this application, the proposal is acceptable as a modification under 4.55(1A).

The changes proposed to the consent through this modification application will not substantially change the operations at the site, nor will it result in a substantial deviation from what was originally approved. The operations at the site will remain substantially the same, notwithstanding the alteration to vehicle movements within the site, to fill the isotainers, and associated rail movements to distribute the isotainers across the state.

As the proposed modification involves minimal environmental impact, as demonstrated in the attached technical assessment, the potential for environmental impact attributed to the proposal is considered negligible; and is thereby permissible under 4.55(1A). 5.2 Protection of the Environment Operations Act 1997

The Cement Works operates under Environment Protection Licence 1698 issued under the Protection of the Environment Operations Act 1997 (POEO Act) for the Scheduled activities of cement production, extractive activity and recovery of general waste.

There are no conditions in the licence which require alteration to accommodate the proposed activities. 5.1.1 Modification approval pathway Given the nature of the proposed modification, it is recommended that this modification be assessed pursuant to section 4.55 (1A) of the EP&A Act. The particulars of the relevant section are reproduced below.

(1A) Modifications involving minimal environmental impact

A consent authority may, on application being made by the applicant or any other person entitled to act on a consent granted by the consent authority and subject to and in accordance with the regulations, modify the consent if:

(a) it is satisfied that the proposed modification is of minimal environmental impact, and (b) it is satisfied that the development to which the consent as modified relates is

substantially the same development as the development for which the consent was originally granted and before that consent as originally granted was modified (if at all), and

(c) it has notified the application in accordance with: (i) the regulations, if the regulations so require, or (ii) a development control plan, if the consent authority is a council that has made

a development control plan that requires the notification or advertising of applications for modification of a development consent, and

(d) it has considered any submissions made concerning the proposed modification within

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any period prescribed by the regulations or provided by the development control plan, as the case may be.

Subsections (1), (2) and (5) do not apply to such a modification.

5.1.2 Environmental impact

Environmental impacts associated with the proposed are minimal and are discussed in Section 6.

5.1.3 Substantially the same development

In order to draw a conclusion as to whether a proposal is substantially the same development as approved, a proponent must have regard to the following considerations which have been established through decisions of the NSWLEC:

1. “Substantially” means “essentially or materially” or “having the same essence”.1

The proposed introduction of rail based isotainer loading activities is entirely in line with current operations; being the creation and distribution of cement related products. Vehicles currently transporting cement product on many instances utilize isotainers, instead of traditional tankers to distribute cement across the state. The overall production of the site is not proposed to change, no are any changes proposed to operational hours or the times at which trains are to operate on the site.

2. A development can still be substantially the same even if the development as modified involves land that was not the subject of the original consent (provided that the consent authority is satisfied that the proposal is substantially the same).2

3. If the development as modified, involves an “additional and distinct land use”, it is not substantially the same development.3

The proposal does not involve an additional and distinct land use. The proposed activities would be wholly contained in lot 1 DP 1017008, which forms a part of the facility’s project approval, and be located toward the center of the allotment.

4. Notwithstanding the above, development as modified would not necessarily be substantially the same solely because it was for precisely the same use as that for which consent was originally granted.

5. To determine whether something is ‘‘substantially the same’’ requires a comparative task between the whole development as originally approved and the development as proposed to be modified. In order for the proposal to be ‘‘substantially the same’’, the comparative task must:

(i) result in a finding that the modified development is ‘‘essentially or materially’’ the same;

(ii) appreciate the qualitative and quantitative differences in their proper context; and

6. In addition to the physical difference, consider the environmental impacts of proposed Modification Applications to approved developments.4,5

7. The results of the comparative task ‘‘does not eclipse or cause to be eclipsed a particular feature of the development, particularly if that feature is found to be important, material or essential.”6

1 Vacik Pty Limited v Penrith City Council (1992) NSWLEC 8 2 Scrap Realty Pty Limited v Botany Bay City Council [2008] NSWLEC 333 3 Vacik Pty Limited v Penrith City Council (1992) NSWLEC 8

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A comparative task has been undertaken at Table 5.1. The proposal is considered to be complimentary to the existing operations on the site, and would allow Boral to distribute cement products on a mass scale through a more efficient means, well within the limitations originally imposed.

The proposal is therefore within the scope of Section 4.55 (1A) as the proposed activities are of minimal environmental impact and are substantially the same development as the development from which consent was originally granted.

Table 5.1 Comparative task

Approved (MOD 11) Proposed (MOD 12)

Operations

Clinker production 1.56 million tonnes per annum No change

Hours of operation 24 hours and day, 7 days a week. No change

Site personnel 150 No change

Total truck movements per day

317 No change

Table 5.1 Comparative task continued

Approved (MOD 11) Proposed (MOD 12)

Environmental impacts

Noise

Condition 3.3 requires the operator to design, construct, operate and maintain the facility and to not exceed maximum allowable noise contributions limits prescribed at Table 2.

Noise impacts associated with the proposed loading processes have been modelled, and shown to have a minimal impact.

Traffic

Up to 317 trucks trips per day during the typical 12-hour working weekday and up to 100 truck trips per day during a typical 6-hour working Saturday.

No change

Air quality

Condition 3.7, 3.7A, 3.8, and 3.9 require the operator to maintain air quality mitigation measures and control dust emissions.

Dust management is a requirement of EPL 1698.

The facility conducts ambient air/dust monitoring.

No change

Greenhouse Gas

No conditions relating to greenhouse gas emissions.

The facility undertakes monitory of stack emissions.

No change

Visual Impact No visual amenity related conditions provided.

No change – the loading process is proposed to be conducted toward the centre of the site, using existing infrastructure.

Waste Conditions 3.17, 3.17A, 3.17AB, 3.17AC, 3.17AD, 3.17AE, 3.17B, and 3.17C relate to waste.

No change

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6. Environmental assessment

6.1 Construction phase impacts

6.1.1 Noise and vibration An Environmental Noise Assessment for the proposed development has been prepared and is included at Appendix A. The report finds that the noise levels from the construction of the project are predicted to be compliant with criteria at all residential receivers. Additionally, no impacts from vibration during construction works are expected.

6.1.2 Traffic

Construction activities of the proposed isotainer handling area would generate no construction traffic beyond the limits of the site. Thereby the proposed clearing and sealing of the handling area would not create a traffic impact on the region.

6.1.3 Air quality

The Project has the potential to generate dust emissions during construction from material handling, vehicle movements and windblown dust generated from exposed areas and stockpiles. The potential dust impacts from these activities are difficult to accurately quantify as they are short in duration and sporadic.

It is unlikely that there would be any significant or prolonged air quality impact off-site as the construction activities would occur for a short period and appropriate dust mitigation measures would be implemented during construction.

Furthermore the existing approval contains relevant dust mitigation measures which will be implemented to ensure no impacts will arise as a result of the proposed activities; See condition 3.7, 3.7A, 3.8, and 3.9 which require the operator to maintain air quality mitigation measures and control dust emissions.

6.1.3 Waste

Site preparation activities would involve a minimal amount of earthworks with any surplus spoil being reused on site. Construction waste would be minimal and will be managed in accordance with the contractor’s construction management plan with a requirement to minimise waste generation through avoidance, reuse and recycling, with appropriate segregation, and disposal of residual waste to appropriate offsite licensed facilities.

6.2 Operational phase impacts

6.2.1 Management Plans

It is noted that operations at the site are currently managed through formalized site management and operations plans, being OEMP’s, to ensure operational phase impacts associated with the numerous activities on the site are controlled. Upon approval being received for the project, a review of the existing management plans will be completed, and updates implemented where appropriate, to ensure the operational phase impacts of the proposal are appropriately reflected in the sites documentation. It is noted however that the substantive controls required for the proposal will be contained within this SEE document, which will become an incorporated document to the sites already operating approval.

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6.2.2 Noise

Potential noise impacts from the operation of isotainer loading activities were modelled and assessed under the Environmental Noise Assessment prepared in support of this modification. Operational noise limits for the facility are contained at DA 401-11-2002 condition 3.3 and are reproduced in Table 6.3.

Table 6.3 Operational noise targets – Condition 3.3

Receiver Location Daya

LAeq(15 minute) Eveningb

LAeq(15 minute) Nightc

LAeq(15 minute)

4 Melbourne Street 37 37 37

Chelsey Park Farm 30 30 30

Candowie Farm 37 37 37

It is noted however that the noise contributions specified in Table 2 are to be interpreted as contributions from the new and upgraded components forming part of cement works upgrade only, and not as noise limits for the site as a whole.

Five scenarios were considered in detail in the noise impact assessment, however only two of these scenarios (scenarios 1 and 3) are considered most likely to occur. Each scenario represents the following activities:

Scenario 1: Truck only model delivering 30 isotainers to the storage area per 8-hour shift (Daytime period 8am-4pm Monday – Friday).

Scenario 2: Train loading 56 isotainers from the storage area to the train per 5-hour period (Daytime only 1pm – 6pm Monday, Wednesday and Friday).

Scenario 3: Train loading 36 isotainers from the storage area to the Train per 3-hour period (Evening only 6pm – 9pm), with movement of locomotives done in this time period. It is assumed that the remaining 18 isotainers for the train consist are loaded to the train during the 2-hour period (Daytime 4pm – 6pm).

Scenario 4: Train loading 36 isotainers from the storage area to the train per 3 hour period (Evening only 6pm – 9pm) with movement of locomotives done outside of this time period. It is assumed that the remaining 18 isotainers for the train consist are loaded to the train during the 2 hour period (Daytime 4pm – 6pm).

Scenario 5: Train loaded directly from truck to train, 30 per 8 hour shift (Daytime 8am – 4pm Monday, Wednesday, Friday) and the remaining 26 isotainers loaded directly from the stack per 8 hour shift (Day period 8am – 4pm Monday, Wednesday, Friday).

Scenario 1 reflects the currently operating activities at the site, being the truck only delivery scenario. Scenarios 2, 4 and 5 are considered to be impracticable based on the likely rail slot approval timeframe (being after 4pm, before 10pm), the amount of time taken to unload and load the trains at the site, whilst having regard to the most efficient utilization of the rail line.

Table 6.4 below summarises the impact assessment.

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Table 6.4 Summary of Scenarios and Timing

The impact assessment’s noise modelling concluded that operational noise associated with the isotainer loading activities would cause a minimal impact on the total noise emissions from the operation of the site.

The modelling illustrates that noise impacts at the nearest residential receivers remain well within the proposed Pollution Reduction Program (PRP-7), which are being developed as a control measure for the site more generally; beyond the operational noise targets provided in condition 3.3 of the existing consent.

The following table outlines the relevant noise levels contained in the PRP, whilst having regard to the NIPI 2017. Table 6.5 Comparison of PRP to NPI 2017

The table above illustrated that the NPI 2017 levels, provide higher noise levels than that within the PRP; especially when looking at the amenity noise criteria. All project scenarios are less than the PRP criteria, which are generally more stringent than the criteria provided in the NPI 2017. There is no instance where a predicted noise level is within 3db of the recommended PSNL; which would be construed as a negligible impact. If you were to make a comparison between the maximum allowable noise contribution limits provided in the existing approval (which again are not relevant for the proposal), a comparison between the limit for 4 Melbourne Street, and the projected noise scenarios, would find a negligible impact (equal to or less than 3db).

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The current PRP-7 contains the following recommended Project Specific Noise Levels (PSNLs) for each receiver location, with the modelled impacts for Scenario (SCN) 1 and 3 provided in the last 2 columns to the very right. Table 6.6 Summary of Scenario Noise Levels and PSNL Levels

Receiver Location

Period Recommended PSNL LAeq.period

SCN 1 SCN 2 SCN 3 SCN 4 SCN 5

Taylor Avenue near Adelaide St

Day 48 41 39 39 37 40 Evening 44 N/A N/A 37 39 N/A

Night 43 N/A N/A N/A N/A N/A 4 Melbourne St Day 46 40 38 38 37 38

Evening 42 N/A N/A 37 38 N/A Night 40 N/A N/A N/A N/A N/A

12 Brisbane St Day 46 39 37 37 35 37 Evening 44 N/A N/A 35 37 N/A

Night 40 N/A N/A N/A N/A N/A Difference from highest LAeq.period in dB 6 8 5 4 8 Compliance achieved

*Note – noise levels attributed to each scenario reflect the ‘Loco idle continuously’ case, which presents marginally higher noise levels than the ‘loco move in 15 minute period’ case in some instances.

Table 6.6 illustrates that all modelled scenarios will comply with the proposed PSNL levels to be applied to the site. The following noise contours illustrate the impacts.

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The introduction of additional rail movements at the site, associated with the isotainer activities, have been factored into the scenario analysis provided above, and have been considered more generally in the noise assessment report. Page 25 of the report considers the noise impacts associated with the rail service, having regard to the likely travel speed of the train, at a distance of 25km from the site. Trackside noise levels are expected to increase by 0.8db, at its worst during the night time period, with a 24 hour average increase of 0.6db, demonstrated in the following table. Table 6.7 Calculated trackside noise levels using CoRN (UK)

The increases identified above are considered to be negligible. With regard to rail movements on site, the noise assessment report identifies that a beneficial mitigation measure to enhance the level of compliance, notwithstanding the fact the proposal complies with all noise limits as demonstrated above, is that operations consider relocation of the locomotive to the eastern end of the train to normally occur as soon as possible after arrival during daytime, and try to avoid movements in evening or night-time periods. This measure will be taken into account in the course of train slot selection, and will be expressed as a preference in the selection methodology. More generally, the site will endeavor to execute rail activities earlier in the day, where feasible. In summary, the potential noise impact from the proposed isotainer activities are considered to be minimal and will be within the propose PRP for the site, and consent noise limits for the site.

6.2.3 Traffic

The introduction of isotainer loading and dispatch activities by rail from the site could have the benefit of reducing the sites overall traffic impact to the immediate area, as well as the wider region more generally. At peak operations, isotainer deliveries could transport between 100,000 – 400,000 tonnes per year of cement by rail, potentially replacing between 150,000 – 200,000 tonnes per year, delivered by road (or approximately 148 trucks per week).

At this point in time, it is not proposed to reduce the overall dispatch levels of cement via road, until the proposed rail deliveries are proven to be sufficient to adequately address the demand for cement.

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6.2.4 Air quality

Potential air quality impacts associated with the isotainer loading process are considered to be minimal. Isotainer filling practices will remain the same, in line with current procedures and control measures. Increased vehicle movements on the site could create an increase to potential dust sources, however existing conditions on the approval mandate that such matters be appropriately managed. These conditions include conditions 3.7 through to 3.10 dealing with onsite emissions, management of dust from coal stock piles, and most relevantly, conditions dealing with dust generated as a result of truck movements.

It can therefore be concluded that there would be no effective change to off-site local air quality impacts as a result of the proposal.

6.2.5 Greenhouse gas

A greenhouse gas assessment was not undertaken as the proposed modification will not have an impact on greenhouse gas emissions out of the facility. The proposal could allow for a reduction of road based deliveries, however this is not currently proposed.

6.2.6 Visual impact

The proposed isotainer handling area, as well as the filling route is well screened from residential dwellings and public spaces by local undulating landforms and tree cover within the facility and across portions of the landscape surrounding the facility.

The proposed handling area would be located toward the centre of the site, as shown in the following figure. This area is well screened to sensitive receptors, by established mature vegetation along the property boundary of the site at Taylor Avenue, and within the site. The storage area is also located downslope from Taylor Avenue, as illustrated in the following figure.

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Figure 6.2 Vegetation Screening and Slope Illustration

Figure 6.3 Proposed Isotainer Handling Area

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7. Consultation

The proposed modification was focused upon as part of one of the Cement Works’ regular community meetings held on 6 December 2018, with a comprehensive explanation of what an isotainer is and their potential effects on logistics afforded to attendees. The explanation was generally well received with no issues or concerns raised at the time. To ensure the presented information reached a broader range of stakeholders, it was also placed upon the Berrima Cement Works website during January 2019. As one further assurance the use and potential advantages of isotainers had been conveyed to the local community, the presented information was included once more in a community newsletter distributed during June 2019. None of these activities has drawn further comment. The proposed modification was also introduced to the DPE on 18 October 2018 and again in February 2019 over the phone. Boral’s representative provided a brief description of the proposed modification and confirmed DPE’s requirements for assessment. Given the relatively minor nature of the modification, seeking to alter already existing operations on the site, the potential reduction in the reliance on road based deliveries, with unloading to occur a significant distance from any potential sensitive receivers, further consultation was not considered to be necessary. Impacts are generally confined to the boundaries of the site.

8. Conclusion

This SEE has been prepared in accordance with Part 4 of the EP&A Act to support a modification application by Boral for the introduction of isotainer loading processes at the site. This SEE has described the site, its environs, the proposal, and provides an assessment of the relevant matters of consideration under section 4.55 (1A) of the Act. This proposed modification is justified on economic, social and environmental grounds and is consistent with the objectives of the EP&A Act. The proposed modification would not result in significant environmental impacts to the local road network or nearby sensitive receivers. The proposal is considered to be in the public interest as it would allow for the continued effective operation of the Berrima Cement Works, a key industrial facility supporting direct workforce of up to 150 employees, and facilitate mass transport of product from the site, with a potential reduction in truck movements leaving the site for the same purpose. In light of the above, Boral recommends that the consent authority approve the proposal.

Appendix A

Environmental Noise Assessment – Recognition Research January 2019

berrima cement works - major projects

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