The following extract of an email from Genevieve Seed at the NSW Dept Planning has been posted for the benefit of the community.
From: Gen Seed <email@example.com>
Date: 19 July 2019 11:02:35 am AEST
Subject: RE: Recycling Concrete Crushing Batching Plant Brandy Hill Quarry
Please find below the answers to your questions of last week.
As a lot of these questions related to the existing and proposed operation, I sought some input from Hanson for confirmation of my understanding.
The responses to your questions are as follows (in italics):
- The proponent states in RW Corkery & Co response letter to the CCC dated 18 January 2019 that a Concrete Batching Plant and Concrete Crushing plant for recycling activities will be limited to 20,000 tonnes of material each year. Please clarify if 20,000 tonnes is the accurate figure?
Yes. The Expansion Project is seeking to import 20,000 tonnes of concrete waste. The Project is also seeking to produce and dispatch 15,000m3 of pre-mixed concrete per annum.
- Can this number be increased in the next 30 years?
If this amount was approved, it could not be increased without a modification to the consent. This would be subject to a merit assessment.
- Once issued with a licence, what would have to occur for the plant to cease operating?
If consent is granted, the plant could operate until the nominated end of life date.
- What are the hours of operation for all activities including ancillary activities for the Concrete Recycling and Batching Plant? What days will all Concrete Recycling and Batching and ancillary activities be operating?
The proposed hours of operation for Concrete Recycling and Batching Plant are:
– Monday to Saturday 5:00am to 10:00pm
– No operation on Sundays or public holidays
- Has this recycling activity already started?
No – there is currently no concrete batching or recycling facility on the site.
- What is the total number of truck movements in and out of BHQ site per year for a 20,000 tonne Batching and Recycling plant?
Once operating, the concrete batching activities would require a maximum of 11 laden deliveries per day (22 movements) of sand and cementitious materials.
Deliveries of concrete washout material would most likely occur as backloads from the delivery of aggregate material. That is, trucks would transport this material on their way back to the Quarry. It is estimated that this process would require no more than 20 loads per week however this would vary significantly.
These proposed truck movements have been included in the overall proposed traffic limits of the Expansion application.
- Please list in dot point all the chemicals that are used in a Concrete Batching and Recycling plant?
There are no chemicals used in concrete recycling other than those required for maintenance of the equipment used.
Concrete batching requires mixing of aggregates, sand and water with cement or cementitious materials to produce concrete. The only chemicals used in this process are admixtures/activators required for special batching requests. These chemicals are commonly used to retard concrete setting or improve the concrete for use in particular settings such as reducing corrosion potential in marine environments.
- Please list in dot point all toxic or hazardous materials related to Concrete Recycling and Batching Plant?
– Diesel fuel
– Small volumes of oils, lubricants or greases.
– Cementitious materials including cement or fly ash (see discussion at question 14 below).
– Admixtures / activators
– Concrete itself is considered potentially corrosive (when uncured/hardened).
All material that is classified as potentially hazardous would be transported, transferred and stored in accordance with the Australian Standards and manufacturers’ specifications (requiring bunded storage to capture 110% of the storage capacity).
Material safety data sheets would be accessible for all chemicals used / stored on site.
- Will the Recycling Crusher be enclosed? How will Hanson enclose the Recycling Crusher?
Yes. The mobile crushing equipment would be housed in an enclosed unit that provides a degree of dust mitigation. Hanson would enclose the mobile crushing unit on three sides using shipping containers and a cover. This is not as effective as the sheeting that would be used for the fixed processing equipment, however this type of enclosure is not possible for mobile equipment.
- What is the process when the Mobile Crusher needs to be relocated?
Mobile crushing units are commonly loaded on to a flatbed truck or transport float. If the equipment is track mounted in would be moved within the Quarry without loading.
- If the Crusher is relocated, what process will occur to ensure the real time monitoring on site for noise and dust is relevant in the new location?
The mobile crushing unit would likely remain in the same position as presented in the Quarry layout figures. If the equipment needs to be relocated for some reason, it would still remain within the Processing and Stockpiling Area as this is the only location where there would be sufficient space for the equipment to operate. The change in location is not likely to change dust generation and dispersion to the extent that monitoring locations would need to be changed. However, Hanson has advised it would continue to liaise with the community throughout the life of the development to ensure that any impacts identified by the community are addressed and mitigated.
- Does Hanson currently import and use Sand and Coal Ash/Fly Ash in their Concrete production?
Yes at other Hanson concrete batching plants, but not currently at the Brandy Hill Quarry.
- Did Hanson use Ash from Coal Fired Station in 2012 and if so, why wasn’t the neighbours informed that these materials were being imported to the BHQ site?
Yes, Hanson participated in a field trail to inform research into the use of this waste material (bottom ash) as a replacement for fine sand materials. More information on this trial can be found here https://www.quarrymagazine.com/Article/2662/Coal-power-station-waste-as-a-fine-aggregate-replacement-in-concrete.
The trial involved pouring a small concrete slab (10m3) and then testing the concrete properties (slumping, strength and shrinkage). The use of ash materials from coal-fired power generation is common as a replacement for cement in concrete production, but this trial was seeking a replacement for fine sand materials using the larger bottom ash. The material was not stored at the Quarry for a significant period and only imported once. The risk of environmental impact was considered negligible and therefore there was no need to discuss this activity with neighbours. This activity may be compared to the pouring of a concrete driveway at any residence in Brandy Hill.
- Will Coal Ash that comes from coal-fired electric power plants be used at the Brandy Hill Quarry site in the processing of the 20,000 tonnes being imported to the site?
Hanson has advised me that they do intend to import fly ash as part of the Expansion Project. However, there is no information on this within in existing documentation for the proposal, and I know I have advised you previously that this did not form part of their proposal.
On this basis, I have requested further information from Hanson in relation to this matter, including what is being proposed and how it will be managed.
To get a bit more information about this material, I contacted the EPA for a discussion. They advised me that importing this material does not form part of an ‘Environment Protection License’ but is regulated by a Resource Recovery Order and Exemption issued in 2014 (see link below).
I understand that to use this material, the supplier must ensure that it meets a certain chemical composition.
This is something we will be carefully considering when the Amended RTS comes in, and I appreciate you bringing this to our attention.
- Recently Dam levels at Brandy Hill Quarry have been extremely low due to extremely low rainfall. What measures does Hanson take to ensure adequate dust suppression when they are running out of water?
Hanson advised it has not experienced the low dam levels reported here. However, if water in the Western Dam was getting low, Hanson would import water (using tanker supply) to ensure that the water cart can continue dust suppression. This has not been required in past operations.
- Who is responsible on site to evaluate dust, what is the current process for measuring dust?
The quarry manager is responsible for managing dust on site.
The EPA regulates all forms of pollution including dust, noise, water quality and blasting through the Quarry’s Environment Protection Licence. Currently, deposited dust is monitored at the Quarry boundary at three locations. Hanson also have a particulate matter monitor located to the south of the Quarry. This monitoring is not required under the Quarry’s existing Environment Protection Licence but is used by Hanson to inform dust management at the Quarry. It is expected that dust monitoring would increase under the Expansion Project, if approved.
- What scientific activities does Hanson BHQ undertake currently to ensure dust is not harming wildlife and farmed animals, fauna, flora and human residents on tank water?
Hanson advised that it undertakes monitoring in accordance with the requirements of the EPA. Hanson advised that it recently completed a program of water quality testing in water tanks in the vicinity of the Quarry and found that all tank water was suitable for drinking.
The Department will carefully consider the potential air quality impacts in its assessment of the application.
- In relation to the rock being crushed on site – what is the rock composition BHQ is blasting and crushing?
The rock being extracted at the Quarry is predominantly ignimbrite which is overlain by sandstone, mudstone and conglomerate to the south of the Quarry Site.
- What testing and monitoring of residents over the past 30 years has been conducted? What monitoring and studies have occurred for current and former staff from previous operators? How can you prove that the rock they have been breathing in has not harmed their health?
I do not believe Hanson has undertaken monitoring of residents or staff respiratory health. This would be a difficult system to implement particularly as people are exposed to all different levels of particulates. It is also difficult to determine the level that particulates affect respiratory health in comparison to other emissions (ie smoke). Research on the health effects of particulate matter is evolving and NSW Health have some interesting information of this. https://www.health.nsw.gov.au/environment/air/Pages/particulate-matter.aspx
- The community is concerned about the impact on the heritage listed; 3 Bridges, the Woodville Store, and the historical Stone Church and Hall at Woodville. Has there been a study on numbers of movements currently? Has the impact from vibration on these buildings been considered? Has the owners of these premises been consulted regarding the expansion proposal?
Hanson has advised that the quarry currently uses the route that requires trucks to cross the heritage listed wooden bridges and to pass the Woodville Store and the Church and Hall at Woodville. Hanson consider that there is unlikely to be significant additional impacts from transport activities at these locations, as it does not intend to increase the maximum hourly number of dispatches from the site.
Drivers are made aware of the locations of the heritage bridges and the load limits and single lane requirements for their use.
Hanson has assessed potential blast vibration impacts from the operation and determined that vibration from blasting was not likely to cause structural damage at the closest residences to the Quarry. The blast assessment concludes that vibration from blasting would not impact the Woodville Store or the Church and Hall at Woodville as these are at a greater distance from the operation.
The Department will carefully consider the heritage and blasting impacts of the proposal in its assessment of the application.
- Residents rely on a variety of food produced in this area along with healthy native forests for honey production along with tourism activities. Industrial activities of this nature may significantly jeopardise commercial, primary producers, and non-commercial barter opportunities and any Organic Licenses for this community. Has there been any review on the validity and academic rigour of the Key Insights report on the surrounding rural communities impacted such as Butterwick, Dunns Creek, Woodville/Seaham? The report seems to only focus on the more built up areas of Brandy Hill, the village of Seaham and the row of houses in Nelsons Plains?
I understand the social impact assessment may have focused on the areas of Brandy Hill and Seaham based on their proximity to the extractive operation and proposed haulage route. The proposal’s potential to impact broader primary production in the area is likely to be related to groundwater drawdown and downstream surface water quality impacts.
The Department is carefully considering these impacts in its assessment of the proposal.
I hope this information is of assistance.
Please note that when Hanson responded to me about some of these questions, they advised that they are happy to meet any resident on site or in person. They also advised they would conduct a site visit for discussion of existing operations. I understand if this does not appeal to you but thought it important that you know the offer is there.