MOD 1 - Building Height Increase

Please see the attached response

The Environment, Energy and Science Group of DPIE have no comments on this modification.

Please see attached.

Hi Nathan,

Thanks for our discussion last week on this MOD on SSD 7709 MPW Stage 2.

As discussed, it is understood that the MOD is to accommodate a Woolworths Retail and Distribution Centre at 2 southern most warehouses in MPW Stage 2. These warehouses will be storing dangerous goods (DG) above the SEPP 33 thresholds in the Department’s SEPP 33. As such, a preliminary hazard analysis (PHA) [EA Appendix 15] was submitted.

In noting from EA Section 3.2 that the Applicant intends to modify condition B176, it would be critical for the Applicant to clearly identify the subject warehouse in a consistent manner within all the relevant documents and plans. This would allow the condition be modified to allow for the subject warehouses to store DG within the limits specified in the PHA. If the Applicant intends to store DG above SEPP 33 thresholds in other warehouses in future, condition B176 needs to be modified progressively for the relevant PHAs to be submitted pre-approval. This approach is in-line with the proper application of SEPP 33, requiring a PHA to be submitted during environmental assessments and not post-approval.

Clear identification of the warehouses is also critical to ensure that the PHA has been conducted in context of the other land uses surrounding the subject warehouses. These other land uses, although may be within SSD 7709, are still considered off-site risk receptors in context of the Department’s HIPAP No. 4. In this sense, we expect an analysis of full warehouse fires be performed in the PHA for the subject warehouses to demonstrate impacts to adjacent land uses, if any. We note that the analysis for full warehouse fire was not included in the current PHA, referring to PHA Section 4.14.1.

Moreover, we note that the current PHA did not assess the cumulative risk from both subject warehouses to surrounding land uses against the Department’s HIPAP 4 land use safety risk criteria. Although we note that likelihoods are analysed in terms of probability in various sections in the PHA, the cumulative risk analysis was not clearly analysed in terms of frequency per year which is the basis of the HIPAP 4 criteria (i.e. 50 x 10-6 chances per year for individual fatality risk at industrial land uses).

Considering the above, we request the following information to enable a detailed review of the PHA. Further information may be requested after considering the responses during the detailed review.

1. clear plans/diagrams indicating:
a. the location of the subject warehouses in context of the other warehouses within SSD 7709 and other land uses around SSD 7709;
b. the location of all dangerous goods and hazardous chemicals storages (class and maximum quantities) within the site plans of the subject warehouses and verify that this storage arrangement would be able to comply with all relevant Australian Standards.
c. consequence areas and risk contours bases on plans/diagrams a and b above.

2. analysis for full warehouse fire for the subject warehouses, including analysis if toxic combustion products from this fire in view of the range of dangerous goods classes to be stored within the warehouses.

3. revise the probabilistic risk analysis in the PHA to be consistent with the Department’s HIPAP 4 frequency-based land uses safety risk criteria and assess the cumulative risk from both subject warehouses to surrounding land uses against HIPAP 4.

Thanks.

Please see attached document

Please refer to the attached