Modification 14 Waste Shredding

I am writing to express my strong objection to LEC10397-1995-Mod-14 Modification 14 Waste Shredding, proposed by Weston Aluminium. As a concerned member of the community, I find several critical issues with this proposal that need immediate attention.
To begin, I would like to address the lack of community consultation conducted by the proponent. Despite claims that the impact on the community would be minor, many residents, including myself, remain unaware of the project's details due to inadequate engagement efforts. Proper community consultation is crucial to ensure that the concerns and preferences of the affected residents are considered and addressed.
Furthermore, I question whether this project can genuinely be classified as a "modification" given the significant changes in its nature. The closure of the Kurri Hydro Aluminium Smelter and the Tomago Aluminium Smelter establishing its own "dross" plant indicates that the original purpose of the facility is no longer applicable. This misclassification should be carefully reviewed to ensure accurate representation.
Moreover, the Modification Report downplays the materials that could be received as “general solid waste (non-putrescible)”. The EPA classification of "general solid waste (non-putrescible)" encompasses a much broader range of materials, some of which may have potential environmental impacts. The community is concerned about the long-term implications of these materials and seeks transparency regarding all waste types that could be imported to the site.
In addition, the proposed project appears to conflict with the NSW Waste and Sustainable Materials Strategy 2041, which aims to achieve an 80% average recovery rate from all waste streams by 2030. The figures presented in the Modification Report indicate that the majority of the waste will be sent to landfill, raising questions about its compliance with the state's waste management goals.
The fire risk associated with the project is also a significant concern. The increase in surface area resulting from shredding significantly elevates the risk of fires on-site. Given the history of fires at the facility and the potential for rapid fire spread, adequate fire protection measures must be put in place.
Additionally, I am troubled by the portrayal of the certified Integrated Management System (IMS) as a positive factor in relation to safety onsite and risk mitigation. The EPA's improvement notice in 2021 suggests that the IMS may not have been effective in preventing serious issues. This raises doubts about the reliability of WA's IMS and standard operating procedures (SOPs), which are crucial for ensuring the safety of the community and the environment.
Moreover, the handling of a new waste stream requires transparent procedures. Specific procedures tailored to this new waste stream should be established and made transparent during the approval process to ensure safety and compliance.
As a community facing socio-economic challenges, we deserve a transparent and responsible approach to industrial developments. It is crucial that the relevant Government agencies, such as the Planning Department and the EPA, carry out their responsibilities effectively to safeguard the health and environment of our community.
I strongly urge the Planning Department to conduct a thorough assessment of this modification application, taking into account the concerns raised in this submission. Our community's well-being depends on sound decision-making that prioritizes safety, sustainability, and responsible development practices.
Thank you for your attention to this matter.
Sincerely,
Victoria Davies

This is not something that is needed this close to residential areas, aswell as this company's poor control over what they are currently doing

This plant should never have been approved in the first place, due to its proximity to existing homes and schools, etc. The fact that 79 conditions were attached to the original approval indicates this fact. Then within a short time of operating, the operator sought and received a substantial reduction on the number of conditions. Over the years of operation there have been modifications to operations and approvals, breaches and incidents including significant under-estimating of risks, and unanswered questions, Much has been made in some quarters about the employment that this plant has generated but this really has been minimal at best,
Another concern I have is regarding the waste to be sent to landfill: there is quite a bit contained in the application about how the proposed shredding will reduce the amount going to landfill and the recovery of resources but I did not see in the application any details about where this waste would be sent, It is stated that the roads to be used for receiving and sending out processed materials will be Mitchell Avenue, Government Road, Hart Road, and the Hunter Expressway so perhaps one can assume that no waste will be sent to the Cessnock Council Waste Management Facility. However, I have found that it is dangerous to assume anything, having seen too many surprises pop up in the past.
I object to this proposal. I don't trust the operator and I don't trust some of the information used to justify this application.

Please see my attached objection.

I am writing to strongly object to LEC10397-1995-Mod-14 Modification 14 Waste Shredding , proposed by Weston Aluminium. While I acknowledge and accept the Department's disclaimer and declaration in relation to this submission, there are several significant issues with this proposal that need to be addressed.
Firstly, there has been a lack of community consultation by the proponent. Despite claims that the impact on the community would be minor, many locals remain unaware of the project's details due to insufficient engagement efforts. Proper community consultation is crucial to ensure that the concerns and preferences of the affected residents are adequately addressed.
Secondly, I question whether this project can genuinely be classified as a "modification" given the changes in its nature. With the closure of the Kurri Hydro Aluminium Smelter and the Tomago Aluminium Smelter establishing its own "dross" plant, it is clear that the original intention of the plant's operation is no longer applicable. This misclassification needs to be thoroughly reviewed.
Additionally, the Modification Report downplays the materials that could be received as “general solid waste (non-putrescible)”. The EPA classification of "general solid waste (non-putrescible)" encompasses a much broader range of materials, including those with potential environmental impacts. The community is concerned about the long-term implications and seeks transparency regarding all materials that could be imported to the site.
Moreover, the proposed project appears to conflict with the NSW Waste and Sustainable Materials Strategy 2041, which aims to achieve an 80% average recovery rate from all waste streams by 2030. The figures presented in the Modification Report indicate that the majority of the waste will be sent to landfill, undermining the state's waste management goals.
I would also like to raise serious concerns about the fire risk associated with the project. The increase in surface area resulting from shredding significantly elevates the risk of fires on-site. Given the history of fires at the facility and the potential for rapid fire spread, proper fire protection measures are of utmost importance.
In light of these concerns, I urge the those responsible to conduct a thorough assessment of this modification application. The health, safety, and environmental well-being of the community should be prioritized over short-term gains. Adequate measures must be taken to prevent any potential adverse impacts from this proposed modification.
Furthermore, I am troubled by the certified Integrated Management System (IMS) portrayed as a positive factor in relation to safety onsite and risk mitigation. While the IMS may be audited annually, the EPA's improvement notice in 2021 suggests that it may not have been effective in preventing serious issues. This raises doubts about the reliability of WA's IMS and standard operating procedures (SOPs).
Additionally, the handling of a new waste stream requires transparent procedures. Specific procedures tailored to this new waste stream should be established and made transparent during the approval process to ensure safety and compliance. E.g. Screening of a new waste stream as it enters the facility.
As a community facing socio-economic challenges, we deserve a transparent and responsible approach to industrial developments. It is crucial that the relevant Government agencies, such as the Planning Department and the EPA, carry out their responsibilities effectively to safeguard the health and environment of our community.
I urge the Planning Department to carefully consider these objections and the additional concerns raised in this submission. Our community's welfare depends on sound decision-making that addresses our concerns and ensures sustainable and responsible development practices.
Thank you for your attention to this matter.
Sincerely,
Graeme Davies

I think the expansion of services provided by Weston aluminium is a great addition to their business. Expanding the facility is a positive step in the right direction for a more integrated waste management facility. It is centrally located to major road infrastructure. It will provide economic benefits and jobs to the local community. I am in support of this proposal.

The smell of this plant is already putrid and it’s a health concern and too let them burn / shred or dispose of any more rubbish will affect the atmosphere and environment. Also the health of the general public will be severely impacted.

I live within 500 meters of this facility, i strongly object to the current submission based on lack and open disclosure, and transparency. I am concerned at their inability to maintain s secure safe sight with the alleged arson attack resulting in a very large hand sanitizer fire resulting in closure of our local high school, home owners being told to stay inside shutting down airconditioning and forcing residents to stay inside own home. I have severe asthma and was heavily impacter with respiratory compromise staying home snd inside.
A second fire was visible within the last month, I personally witnessed black smoke coming out from under a roof resulting in multiple fire brigade attendance .
The impact this facility will have on local wildlife, the threat of possibly run off from the tailings dam will have a devastating impact on wild life as well as degradation of the land surrounding this facility.
The fall out from incineration concerns me with my home grown vegetables snd chicken eggs becoming z toxic possibility to all that consume these.
They could nit maintain a secure sight then lied about it and what else are they nit telling us. This area has elderly, small children and babies, young families as well as numerous workers in very close proximity.
This needs to be removed from the residential area and relocated, even uf it is zoned fir it.
The risk of incidents occurring with transportation of these chemicals could result in a major environmental disaster due to numerous accidents on the corner of government road and tenth street . Its a highly bust unsafe intersection leading up to a dangerous round about

I object to this project for multiple reasons. I believe that there has been inadequate community consultation, general solid waste (non putrescible) is listed in the report as very benign items but when listed on the EPA site it could be items such as wood waste, building waste, oil filters, solid waste collected from stormwater drains, which is much broader than "cosmetics, sunglasses, clothing, pharmaceuticals, medical devices/instruments, handbags, etc." listed in the report. I am concerned for the air quality in the area considering the wide array of waste proposed to be shredded. I also oppose to this proposal due to the high chance of fire from the shredding process itself. The report mentions the potential of fire, and considering the site has had a major fire on 14th November 2021 and other fires on 26th January 2023 and 3rd July 2023, and has applied to process other hazardous and flammable waste, processing more waste by a shredding process which could cause a fire on site is concerning. I do not believe this proposal should go ahead. Throughout this modification and the separate State Significant Development put forward by Weston Aluminium, I believe that Weston Aluminium has made inadequate sincere attempts to engage with the community who, according to Bureau of Statistics data recently released shows Kurri to be the 590th most disadvantaged postcode area in NSW and Weston to be the 582nd. People in our community are aware of the potential impacts of these developments, but have more going on in their lives to worry about and should not have to keep fighting to live in a healthy environment. I urge you to recommend against this development.

I wish to express my objection to LEC10397-1995-Mod-14 Modification 14 Waste Shredding.
The modification states “Receipt, storage and shredding of up to 20,000 tonnes per annum of general solid waste including off-specification, damaged, mis-labelled, recalled, expired, unused or surplus consumer products”. I do not believe that there is enough clarity in the modification regarding what general solid wastes will be stored and processed. To simply say “including” is not good enough. As a nearby resident, I object to an open-ended statement that could allow storage and processing any number of materials, and I believe that to demonstrate an open and transparent development process, Weston Aluminium should provide a finite list of the wastes that they intend to process.
Below is from the EPA NSW website and I believe demonstrates that more clarity needs to be provided.
“The following wastes (other than special waste, liquid waste, hazardous waste, restricted
solid waste or general solid waste (putrescible)) are pre-classified as ‘general solid waste
(non-putrescible)’:General solid waste (non-putrescible)
The following wastes (other than special waste, liquid waste, hazardous waste, restricted
solid waste or general solid waste (putrescible)) are pre-classified as ‘general solid waste
(non-putrescible)’:
• glass, plastic, rubber, plasterboard, ceramics, bricks, concrete or metal
• paper or cardboard
• household waste from municipal clean-up that does not contain food waste
• waste collected by, or on behalf of, local councils from street sweepings
• grit, sediment, litter and gross pollutants collected in, and removed from, stormwater
treatment devices and/or stormwater management systems, that has been dewatered
so that they do not contain free liquids
• grit and screenings from potable water and water reticulation plants that has been
dewatered so that it does not contain free liquids
• garden waste
• wood waste
• waste contaminated with lead (including lead paint waste) from residential premises or
educational or child care institutions
www.epa.nsw.gov.au 5
• containers, previously containing dangerous goods, from which residues have been
removed by washing3 or vacuuming
• drained oil filters (mechanically crushed), rags and oil-absorbent materials that only
contain non-volatile petroleum hydrocarbons and do not contain free liquids
• drained motor oil containers that do not contain free liquids
• non-putrescible vegetative waste from agriculture, silviculture or horticulture
• building cavity dust waste removed from residential premises or educational or child
care institutions, being waste that is packaged securely to prevent dust emissions and
direct contact
• synthetic fibre waste (from materials such as fibreglass, polyesters and other plastics)
being waste that is packaged securely to prevent dust emissions, but excluding
asbestos waste
• virgin excavated natural material
• building and demolition waste
• asphalt waste (including asphalt resulting from road construction and waterproofing works)
• biosolids categorised as unrestricted use, or restricted use 1, 2 or 3, in accordance with
the criteria set out in the Biosolids Guidelines (EPA 2000)
• cured concrete waste from a batch plant
• fully cured and set thermosetting polymers and fibre-reinforcing resins
• fully cured and dried residues of resins, glues, paints, coatings and inks
• any mixture of the wastes referred to above.
In assessing whether waste has been pre-classified as general solid waste
(non-putrescible), the following definitions apply:
Building and demolition waste means unsegregated material (other than material
containing asbestos waste or liquid waste) that results from:
• the demolition, erection, construction, refurbishment or alteration of buildings other than
- chemical works
- mineral processing works
- container reconditioning works
- waste treatment facilities
• the construction, replacement, repair or alteration of infrastructure development such as
roads, tunnels, sewage, water, electricity, telecommunications and airports
and includes materials such as:
• bricks, concrete, paper, plastics, glass and metal
• timber, including unsegregated timber, that may contain timber treated with chemicals
such as copper chrome arsenate (CCA), high temperature creosote (HTC), pigmented
emulsified creosote (PEC) and light organic solvent preservative (LOSP)
but does not include excavated soil (for example, soil excavated to level off a site prior to
construction or to enable foundations to be laid or infrastructure to be constructed).
Garden waste means waste that consists of branches, grass, leaves, plants, loppings, tree
trunks, tree stumps and similar materials, and includes any mixture of those materials.
3 The cleaning method must be as good as or better than the triple-rinsing method outlined in
Appendix 2.6 www.epa.nsw.gov.au
Virgin excavated natural material means natural material (such as clay, gravel, sand, soil
or rock fines):
• that has been excavated or quarried from areas that are not contaminated with
manufactured chemicals, or with process residues, as a result of industrial, commercial,
mining or agricultural activities
• that does not contain sulfidic ores or soils, or any other waste,
and includes excavated natural material that meets such criteria for virgin excavated natural
material as may be approved from time to time by a notice published in the NSW
Government Gazette.
Wood waste means sawdust, timber offcuts, wooden crates, wooden packaging, wooden
pallets, wood shavings and similar materials, and includes any mixture of those materials,
but does not include wood treated with chemicals such as copper chrome arsenate (CCA),
high temperature creosote (HTC), pigmented emulsified creosote (PEC) and light organic
solvent preservative (LOSP).”

Searching the internet using search terms “industrial shredder fire” returns many examples of the fire risk inherent in waste shredding processes. Given the well documented history of fire incidents at Weston Aluminium, I object to another serious fire source being added to their operations.