HVO South (MOD 6) - Ammonium Nitrate Emulsion Plant

As per attached letter

As the proponent has addressed water issues in the modification report, specifically that water for the modular ANE plant will be sourced from existing HVO water licences and no extraction of groundwater or surface water is proposed by the modification, DPIE Water and NRAR have no further comments at this stage.

See attached comments.

The Hunter Valley Gliding Club (HVGC) owns and operates an airfield used regularly for recreational gliding predominantly on weekends and by various commercial aviation operators during the week. The HVGC is an adjoining property to the Location B nominated in the HVO South MOD 6 - Ammonium Nitrate Emulsion Plant Modification Application.
The objection is on the following basis:
1) The document states in Table 7 (page 83/163) that the ANO store is 848m from the HVGC runway versus an allowable distance of 846m when in actual fact the Location B ANO plant is approximately 760m from the edge of the runway. We believe this to be incorrect.
2) The document apparently deliberately distorts the projection of the Protected Works class B radii circle (page 34/163) for Location B to avoid showing encroachment onto the HVGC runway. We believe this to be incorrect.
3) The report does not make any consideration to the risk to aircraft movements in the vicinity by the ANO plant or risks by aircraft to the ANO plant. Aircraft regularly fly over the proposed Location B at an altitude of 200m to 300m (in accordance with Civil Aviation Safety Authority procedures) which is inside of the Protected Works Class A area when a hemispherical projection is applied rather than the current surface fixed Protected Works area. In other words, the trajectory of an explosion at the facility will be projected vertically upwards unimpeded. It could be reasonable to assume that if an explosion was to occur with aircraft in the vicinity loss of life would result.
4) On page 54/163 Sect 8.2, for Location A the document recognises the risks to passing motorists "should the future realignment of Lemington Rd be approved" and hence preparedness to relocate the ANO plant from Location A to Location B to mitigate this risk, however as stated above there is no recognition of the risks to aircraft at Location B.
Refer attached image showing the skewed Protected Works circles and the actual distance to the HVGC runway.
We request that the application document is independently validated and corrections made as appropriate.
The HVGC is willing to discuss the above matters further with the development proponent as need be.

I wish to object to the project. This plant should is too close and should be be positioned further away from the residences of Maison Dieu, it is also close to the Hunter River. The existing plant is visible to all residences of Maison Dieu and will be worse of a night with increased lighting. Moving the plant further away from residences would be more pleasing.

Please be informed that the collective TfNSW submission (CR2021/003678) has been submitted via our RMS account in this instance. Should you require any further information, please contact [email protected] . Thank you.

DPIE Crown Lands has no comments for this proposal.

See attached letter.