Woodlawn Advanced Energy Recovery Centre

I have read and listened to all propaganda provided in Veolias submission regarding how safe this proposed ARC is to the environment and human health and I remain totally unconvinced as to its suitability to its proposed location. The location is entirely based on convenience (easy access to the rubbish) and financial considerations. Veolia's current operations at Woodlawn have already breached safety guidelines on numerous occasions to the detriment of local residents. Yet Veolia expect people residing closeby to trust them to provide truthful predictions as to the levels of proposed pollutants emitted from this facility. For these reasons I am totally opposed to this development.

I live in Bungendore with my young family and I strongly object to Veolia's proposed incinerator in Tarago, NSW.

Waste incineration is in direct contrast to the NSW State Government's Net Zero and emissions reductions targets, further contributing to climate change. It will also be to the detriment of Australia's international obligations and targets to reduce greenhouse gas emissions.

The proposed toxic incinerator will also create an unsafe local environment due to the pollution emitted. It is also reduces the incentive for recycling and promotes poor use or limited resources.

Why are Veolia looking to build toxic waste incineration facilities now, when the rest of the world is moving away from them due to the scientifically proven negative impact on citizen's health, emissions and the environment? This technology is obsolete and detrimental in all aspects.

There are a number of further reasons for my objection, such as:
- the proposed project is inconsistent with the NSW State Government's Net Zero target
- the proposed project is inconsistent with the Federal Government's Net Zero target
- the proposed incinerator will emit significant greenhouse gases contributing to climate change
- innappropriate use of resources
- reduces recycling rates
- promotes single use and a throw-away mentality
- is not renewable (essentially greenwashing)
- will contaminate the surrounding land, air, water and groundwater, of which Veolia has already breached numerous times with its existing facility
- will significantly impact air quality of the surrounding region and release numerous toxic pollutants
- will destroy the local agriculture based economy as produce will not be suitable for consumption
- Veolia's track record is dismal in the 15 years of operating the existing Woodlawn facility, incurring multiple infringements, withholding information under freedom of information requests, and continuing to pollute the local environment

The only beneficiary of this waste incinerator is Veolia. It will only exacerbate existing problems and will be looked upon by future generations as a selfish and short-term choice if allowed to proceed.

I oppose the Woodlawn Advanced Energy Recovery Centre's plan for a waste-to-energy incinerator project at Tarago, NSW for several reasons:
• The incinerator will emit toxic air pollution 24 hours a day 365 days a year and will spread through the region to Goulburn, Canberra, Braidwood, Bungendore, Murrumbateman, Gunning, Yass and more . . .
• This pollution (including toxic heavy metal particulates and persistent organic particulates) will impact seriously on the health of our communities
• Water supplies and food will be contaminated. I live in the lake region and in a direct line of winds that move from the incinerator site. I rely completely on rainwater for all household use and am concerned that my water supplies will be contaminated by the toxic air pollution from the incinerator. This will affect the health of my family, my neighbours, surrounding communities and all those who visit us.
• Prime agricultural land surrounds the site and hundreds of rural residential developments are situated here as well. All will be adversely impacted by the incinerator project
• The impact on our children, grandchildren and their children will continue over the years because of the accumulating chemicals from the incinerator which will remain in the surrounding environment.
I fiercely oppose the project.
Sincerely
Elizabeth Cameron Wilson

I object we are on tank water and grow and eat our own food. I do not want these toxins in the air contaminationing my farm. Also there are so many trucks bringing rubbish to woodlawn fron canberra and sydney and there is no thought given to the locals travelling these roads to work and have to put up with these trucks and the damage they cause to the roads. Tarago and surrounds it tired of being sydneys electricity generator with woodlawn and the windmills. Have it in Sydney or canberra where the rubbish is anyway.

1. The hierarchy of waste treatment under the EfW Policy Statement is laudable, however the rider which effectively permits EfW ...when recovery of material is... 'not financially viable'...( or technically feasible) does not include the externalities implicit in full life of product/packaging. This problem should be dealt with by a full life cycle charge at a producer/importer/wholesale level fully costing recovery, not by simply burning the problem.
2. The Chlorine emissions sampling clearly demonstrates the non homogenous nature or MSW and to a lesser extend C&I waste. When incineration cannot be optimised as the input is not homogenous, the recombination possibilities are too risky to contemplate. Filtration 'in the stack' is not sufficiently effective.
3. Suez were prevented from building a not dissimilar plant by the timely legislation prohibiting such plants in urban environments. Are we really saying what's not ok in a city is on in the country (where there are less complaints/easier politics)?
4. Veolia are a well run and experienced organisation. They access the best experts money can buy, they design and incorporate processes to minimise risk, error and environmental damage. Despite this I have had direct experience - thankfully rectified with intervention from the EPA and LGA, of 3 layers of due process in waste transfer, storage and disposal avoided by Veolia's operators 'on the ground' resulting in environmental damage. Simply put: even though it may look good on paper - they can't be trusted. the bloke driving the front end loader can always find a shortcut. This causes environmental damage.
5. The GHG emissions under ARC (sic) are unnecessarily high compared to BAU.
6. Burning waste isn't the solution. Full resource recovery is. The solution is to price the externality as the current failure to recover/re purpose/cycle soft plastics demonstrates.
8. The (e)220,000 MWh input to the grid may have value but it is not renewable and there are however less polluting ways to achieve this than burning MSW etc.
7. Please note I have visited the site (and other waste facilities).

I object to the creation of hte waste incinerator at Woodlawn mine, Tarago. I have lived here 15 years and as a family, we already suffer the ill effects of the Waste station, as the smells find their way to our rural home, becoming quite offensive smelling at times, over the years I have noticed an unsual residue blown in through my window onto my window sills inside my home, as we have strong winds in this area, and am concerned about the impact that has has on the rainwater collected for drinking from my roof and I do not doubt that further toxins would from the proposed woodlawn incinerator would make their way into my home, and water tanks, clothing, machinery, cars, plants. I have lived through bushfires and dust storms and am well aware of how far fine particles can travel., literally 100s of kilometres. I have no interest in sufferring any further the ill effects of having rubbish from major cities burnt in my home town. I find it degrading to us rural people that we should literally be the garbage dump for cities and a more ecologically friendly option should be sought.

I am a Local Farmer, Rural Real Estate Agent and Valuer in the Goulburn and Tarago region. I understand that in July 2018, the Eastern Creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission as not being in the public interest. The reasons for this rejection included concerns about safety, insufficient evidence that the pollution control technologies would be capable of managing emissions, concern about the relationship between air quality impacts and water quality impacts, the possibility of adverse environmental outcomes, and concern about site suitability and human health impacts. Since then, the NSW Government has banned toxic waste incinerators in Sydney due to the risk to human health. The risks have not changed since that decision back in 2018 – this project must also be rejected - If they aren’t safe for Sydney then they aren’t safe for Tarago.
The Tarago and Goulburn regions are part of a growth corridor between Sydney and Canberra. The popularity of the area (as being clean and green) for anyone wanting to relocate out of city localities, either permanently or for lifestyle purposes will be seriously diminished. We are also located within the Sydney Catchment area, with the potential to damage waterways and ecology in the catchment areas. Added to these reasons is the further financial burden placed on local land holders, who will be financially disadvantaged by lower land values and may impact any 'organic' certification status and therefore business profitability. There are far more suitable locations for this type of development west of the Great Dividing Range.

I object to having toxic incinerators burning rubbish and polluting the air quality we breathe.
This is not the way forward, this is backward thinking.
Australia is better than this! Stop killing our planet!

I object to this proposal based on the following:

1. This blocks the opportunity to implement a circular economy framework which will reuse, recycle and repurpose waste in a cleaner process than incineration
2. NSW Government should be leading best practice in waste management, not going backwards to the industrial pollution management of the mid 1900's
3. NSW residents do not want toxic air and particle pollution which will have immediate and long term damage on health, agriculture and waste management practices.

Do not approve this or any other form of Incinerator in NSW.

Your decision will be your legacy to all current and future residents in NSW.

JUDITH LEVITT

I am a resident of the southern tablelands (in Crookwell), and regularly travel down through this area, and specifically to Braidwood.

Frankly, I am stunned that the proposal for an incinerator in Tarago is not some kind of joke. In this day and age, the idea of burning waste to produce toxic gases and CO2 is just insane.

There appear to be several additional risks brought about by this proposal, and I am particularly concerned with how solid waste will be retained without the risk of groundwater contamination. Around the state in recent years, commercial sites such as mines which hold waste at ground level have seen tailings dams overflow and damaging spill released into the environment.

The idea that this is some sort of renewable energy project is frankly an insult.

Finally, this is such a great part of the state, and there will be future uses for this land. Veolia is not a trustworthy operator, its existing facility does not uniformly run within its license conditions.

This horrible proposal does not have any community support.

This project should not be allowed for many reasons which include the total negative impact on the greater and local environment. Its impacts have already been recognised as damaging and dismissed by several countries overseas and also by the NSW Independent Planning Commission. The recognition of its impact on the environment should be sufficient reasons for its rejection, especially with the universal acknowledgement for the need to reduce emissions and the disaster which climate change is causing. This area is a thriving agricultural area whose residents will suffer from the health issues and pollution damage which this project will create. Please do not allow it.

My name is Ainslee Elise French and I live in Lower Boro, and I strongly object to Veolia’s proposed incinerator being built in Tarago.

There are existing issues not yet addressed by Veolia being investigated at the same site, including persistent odours that can be observed near my home - there are regular EPA complaints that have not yet been addressed.
I am 18kms away from the existing facility, and I do not believe that the NSW Government has considered how detrimental the existing issues of the site are, without compounding the problem by adding another project.

Reports have shown that the Sydney's waste shipped to Veolia's Woodlawn facility has increased over time, this has occurred despite the ongoing issues being reported by the community.
There has been no engagement with residents like myself who are outside of the Tarago township. Despite the ongoing impact to our quality of life, the lack of growth in land value or the risk to the environment.

Based on my current experience, I feel strongly that Veolia will not be capable of managing the incinerator project effectively.

In July 2018, the Eastern Creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission as not being in the public interest. The very valid reasons included concerns about safety, insufficient evidence that the pollution control technologies would be capable of managing emissions, concern about the relationship between air quality impacts and water quality impacts, the possibility of adverse environmental outcomes, and concern about site suitability and human health impacts.
I am of the understanding that from 2018 onwards, the NSW Government has banned toxic waste incinerators in Sydney due to the risk to human health.
I can find no studies or research collateral to support any changes to the risks that informed the NSW government decision since that decision in 2018 – If a waste incinerator is not considered safe for Sydney then the project should not be considered safe for Tarago.

Our Community is small and widespread, but the project proposal ignores the surrounding land is high in agricultural use including animals raised for food, animal feed crops and food for human consumption.
The long term affects and impacts to our community and the communities and people we feed cannot be understated, I am against the incinerator project being implemented in Tarago. I am against the incinerator project being considered at all in NSW.
I am grateful for the opportunity to voice my opposition to the project, and hope desperately that the project is halted.

Respectfully,
Ainslee French
Resident, Lower Boro

My name is Laura Bardell and I live in Bungendore, NSW with my family which includes two small children. I strongly object to Veolia’s proposed incinerator being built in Tarago.

I believe that Veolia’s toxic industrial waste incinerator will cause enormous long term environmental damage in the region, while also creating precedent for other incinerators to be established, causing further environmental destruction.

There are many valid reasons for my objection they include but are not limited to the following
The Incinerator will create toxic air pollution that will be emitted 24 hours a day, 365 days a year which will blow across the region, these toxic air pollutants include; acid gases, toxic heavy metal particulates (mercury, lead cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). Which have been shown not only to have environmental impacts as they build up in soil, water, crops and animals, but health impacts for the communities living around incinerators. Being linked to decreased lung function, cardiac disease and death. Food that is contaminated with these pollutants that will spread across the region can cause cancer, miscarriage, infant death developmental delays and other reproductive concerns.
In 2019, academics from the Australian National University Medical School, the Public Health Association of Australia, and Council of Academic Public Health Institutions Australia completed a systematic review of the health impacts of waste incineration, which was published in the Australian and New Zealand Journal of Public Health in 2022 and referenced by the NSW Government Chief Scientist and Engineer in his report to the NSW Minister for Environment that same year. This report concluded that “there is insufficient evidence to conclude that any incinerator is safe” and in particular “contamination of food and ingestion of pollutants is a significant risk pathway for both nearby and distant residents”.
And whilst safety standards may be put in place with the intention of protecting the community the proposed incinerator will exceed NSW government safety standards for air emissions during start-up, shut-down and many other ‘non-standard’ operating conditions. While Veolia’s overseas incinerators often exceed safety standards and Veolia has a track record locally for failing to comply with license conditions at their existing Woodlawn facility. This in itself should be sound enough reason to reject this proposal, even with safety measures in place this incinerator causes toxic emissions and environmental emissions that are unacceptable.

I also do not agree with the characterisation of waste incineration as renewable energy generation, nor that it will reduce greenhouse emissions or reliance on fossil fuels. Unlike wind and solar generated power, waste doesn’t come from infinite natural processes. It is sourced from finite resources – minerals, fossil fuels and forests that are cut down at an unsustainable rate. Plastic is a petroleum by-product. Burning it is the same as burning fossil fuel and produces similar emissions. And this incinerator will contribute to climate change by emitting 140,000 tonnes of greenhouse gases (CO2) each year. To approve the project is inconsistent with the NSW government commitment to Net 0 emissions by 2030. There is also a disenstivisotion for recycling and incinerators have been shown to reduce recycling rates, particularly as local councils become locked into long-term contracts requiring them to supply consistent volumes of waste for incineration over decades. They are incompatible with a circular economy – they replace one waste stream (municipal/commercial/industrial waste) with contaminated ash.
Additionally, this project simply isn’t necessary - at current volumes (which Veolia have stated they are not seeking to increase) the existing Woodlawn landfill has a remaining useful life of 25 years. Implementation of the NSW Government’s circular economy policies will reduce volumes of residual waste, which will extend that life even longer. There is no need to divert one-third of waste received by Veolia in Tarago to an incinerator which will pollute the region when there is sufficient capacity already in their existing landfill which captures methane emissions to fuel/power generator that create and supply electricity to the grid.

In July 2018, the Eastern Creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission as not being in the public interest. The reasons included concerns about safety, insufficient evidence that the pollution control technologies would be capable of managing emissions, concern about the relationship between air quality impacts and water quality impacts, the possibility of adverse environmental outcomes, and concern about site suitability and human health impacts. Since then, the NSW Government has banned toxic waste incinerators in Sydney due to the risk to human health. The risks have not changed since that decision back in 2018 – this project must also be rejected - If they aren’t safe for Sydney then they aren’t safe for Tarago.

I am concerned for the health and wellbeing of my children and future generations who wish to call the southern tablelands home, environmentally unsafe projects can not go ahead and must be stopped before it is too late.

I strongly object to Veolia’s proposed waste incinerator being built in Tarago.

The NSW Government acknowledges in its own Energy from Waste Infrastructure Plan that waste incinerators negatively impact human health. Veolia acknowledges toxic pollutants from their proposed incinerator will exceed the NSW Government's safety standards for air emissions - so why are we even considering this!

Plume modelling shows emissions will spread across our entire region. This includes prime agricultural land and many residential areas that rely on tank water for drinking, grow their own veges and eat eggs from backyard hens. Contamination from incinerator toxins can cause serious health issues and chemicals will accumulate in the environment, soil, crops, groundwater and animals. The NSW Chief Scientist advises that new incinerators should be located away from areas of food production and food grown near an incinerator should be avoided.

The Eastern Creek (Sydney) waste incinerator was rejected by the Independent Planning Commission in 2018. Since then, the NSW Government has banned toxic waste incinerators in Sydney due to the risk to human health. If they aren’t safe for Sydney then they aren’t safe for the many thousands of people who live Tarago, Canberra, Collector, Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and surrounding areas.

Furthermore, Veolia’s track record proves they cannot be trusted! Veolia’s overseas incinerators often exceed safety standards and Veolia has failed to comply with license conditions at their existing Woodlawn facility and has been issues with fines and prevention notice by the EPA.

My name is Julie Stalley. I live on Lumley Road in Tarago and strongly object to Veolia building a waste incinerator in Tarago.
In my opinion, the output from Veolia’s massive waste incinerator will be detrimental to the health of all those in the area, both people and animals, and will also contaminate our soil and water.
If approved, this incinerator will contribute to climate change by emitting 140,000 tonnes of greenhouse gases (CO2) each year. To approve the project is inconsistent with the NSW government commitment to Net 0 emissions by 2030.

Dear Sir/Madam
Veolia’s incinerator proposal will emit toxic air pollution 24 hours a day, 365 days a year for 25 years, which will spread throughout the region from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and more.
Pollution from the proposed incinerator will includes acid gases, toxic heavy metal particulates (mercury, lead cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). Particulate pollution can lead to decreased lung function, cardiac disease and death. In addition to polluting the air, dioxins and furans will accumulate in the surrounding environment over time in soil and water and are absorbed by plants, crops and animals.


Food contaminated by incinerator toxins can cause cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and respiratory impairment.
The proposal will create 2.2million tonnes of toxic waste ash, including 380,000 tonnes of air pollution control residue (fly ash) which is classified as hazardous waste by the Environmental Protection Authority (EPA). All of this will be dumped on site, risking further contamination of soil and groundwater as well as the Sydney water catchment. Veolia’s track record of polluting local groundwaters (recognised by EPA prevention notice in October 2022) proves they cannot be trusted to safely manage such toxic outputs.


This incinerator will impact the health of our children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment. It is an intergenerational burden and legacy which cannot be allowed to go ahead.


The NSW Government acknowledges in its own Energy from Waste Infrastructure Plan that waste incinerators impact human health stating “Populations can still experience health impacts when emissions are below the national standards, and for some common air pollutants, there is no safe threshold of impact”.
In 2019, academics from the Australian National University Medical School, the Public Health Association of Australia, and Council of Academic Public Health Institutions Australia completed a systematic review of the health impacts of waste incineration, which was published in the Australian and New Zealand Journal of Public Health in 20202 and referenced by the NSW Government Chief Scientist and Engineer in his report to the NSW Minister for Environment that same year. This report concluded that “there is insufficient evidence to conclude that any incinerator is safe” and in particular “contamination of food and ingestion of pollutants is a significant risk pathway for both nearby and distant residents”.


The proposal has already caused significant detrimental negative impact to surrounding communities’ mental health by increasing anxiety and depression. This will only be increased if the project goes ahead as those living nearby continue to stress about when their health will start to show the impacts of the pollution from the facility, or having to stay indoors.
The proposed incinerator will exceed NSW government safety standards for air emissions during start-up, shut-down and many other ‘non-standard’ operating conditions. Veolia’s overseas incinerators often exceed safety standards and Veolia has a track record locally for failing to comply with license conditions at their existing Woodlawn facility.


Waste incineration is not recycling and contributes to climate change
​
I do not agree with the characterisation of waste incineration as renewable energy generation, nor that it will reduce greenhouse emissions or reliance on fossil fuels. Unlike wind and solar generated power, waste doesn’t come from infinite natural processes. It is sourced from finite resources – minerals, fossil fuels and forests that are cut down at an unsustainable rate. Plastic is a petroleum by-product. Burning it is the same as burning fossil fuel and produces similar emissions.
Veolia’s claims that incineration is better than landfill due to methane emissions is flawed as it ignores the fact that methane produced from their landfill is captured which prevents it from entering the atmosphere. They also utilise this to generate power which is pumped into the grid. This process is much better for the environment as it does not produce the CO2, air pollution and toxic ash by-products an incinerator does.


This incinerator will contribute to climate change by emitting 140,000 tonnes of greenhouse gases (CO2) each year. To approve the project is inconsistent with the NSW government commitment to Net 0 emissions by 2030.


Incinerators reduce recycling rates by destroying discarded products and creating a disincentive to local councils by locking them into long-term contracts requiring them to supply consistent volumes of waste for incineration over decades. They are incompatible with a circular economy – they replace one waste stream (municipal/commercial/industrial waste) with contaminated ash.

Economic impact
​This project is in direct conflict with alternative development and growth in the local area. Maintenance of successful local agricultural businesses, along with increased growth in rural- residential developments expected over the next 10-20 years will sustainably increase the size and diversity of the local community, supporting local businesses, volunteer organisations such as the NSW RFS, CWA and local schools. In contrast this proposal would risk the viability of local agricultural businesses, reduce existing residential developments as families move away due to the health and environmental pollution, and put a halt to any further long-term local business development or growth in rural residential developments as the area.


It is clear there are limited economic benefits to the community from this project. Despite claims made by Veolia in the EIS, there are only a very small number of ongoing jobs created and required in order to manage and maintain the incinerator once constructed. Most of these workers will not reside in the local impacted community and would commute from either Goulburn, Bungendore or Canberra. The creation of this small number of jobs would in no way make up for the negative economic impact of reduced local population due to impacted families moving away, and halt to future growth which will result in pressure put on the viability of local businesses, schools and community organisations.


Employment rates in the local region are high – the jobs this project proposes aren’t needed in the local economy and there simply aren’t the people to fill them. It would likely both steal employees away from existing regional businesses struggling in the current economic environment and utilise significant numbers of fly-in fly-out (FIFO) employees who take and spend their money back home away from the local region. There also simply isn’t enough housing in the local area for these proposed workers – there are currently no vacant rental properties in Tarago, so any workers would be forced to surrounding towns again resulting in no economic benefit to the local area which is most impacted.
There are no requirements for jobs and growth in Goulburn Mulwaree to justify this proposal. The Department of Regional NSW has not listed this LGA as requiring significant investment, nor is it included in any of its Special Activation Precincts or Regional Job precincts. The unemployment rate in this region is lower than both the state and national unemployment rates.

I have documented by concerns in the attached PDF file

I, Cassandra Thomas-Smith object to Veolia’s proposed incinerator being built in Tarago. I have had a property on Cullulla Rd, Lower Boro for over 20 years (and still have). This has been a beautiful place for our children to be exposed to and we are looking forward to the same thing for our children’s children.
I object to Veolia’s toxic industrial waste incinerator as it will pollute the air and waterways. Veolia have a history of ineffective management of their responsibilities and the governing authorities have not been able to effectively control this.

I do not have confidence that there is sufficient scientific knowledge and understanding of the proposed process to ensure that emissions and pollutants would be maintained below safe levels for local residents, safe levels for food grown in the wider region, and would ensure that catchment water quality is maintained.
If incinerator emissions can confidently be predicted to be safe, it would clearly be better for the environment, for road safety, and for operational costs, to reduce haulage by locating the processing plant close to the source of product, ie in Sydney. Haulage itself introduces a wide range of environmental impacts related to fossil fuel use, truck emissions and risk of accidental pollution.
If emissions are not safe, it would still be better to locate the processing plant close to Sydney, where residents have easier access to a wider range of health services to treat and manage any issues that arise.
It is not fair to place the health of people living in regional areas at further risk while at the same time failing to adequately support the regional health system and services.
Regional residents of NSW deserve equal health rights to city residents of NSW.

I wish to object to the proposed waste-to-energy plant at Tarago on the following grounds:-

Section 1: Emissions of dangerous chemicals into the environment.
Section 2: The decision to guarantee a supply of suitable waste to the incinerator for the next 25 years.
Section 3: Insufficient attention given to safeguarding an adequate supply of water for the plant’s operations.
Section 4: The lack of consideration given to the hazard of asbestos entering the incinerator feedstock.

Section 1.
The presence of chemicals known as Dioxins and Furans in the feedstock to the incinerator is of particular concern. Dioxins are described as persistent environmental pollutants or POPs by the World Health Organization. They are highly toxic and can cause reproductive and developmental problems as well as causing cancer, according to the WHO. According to the Government of Canada the most toxic Furan is tetrachlorodibenzo-p-doxin or simply TDD. According to the Government of Canada the biggest source of dioxins and furans in Canada is the large scale burning of municipal waste and medical waste. Clearly these chemical pollutants in Australia also pose a considerable threat to the local community and plant operators. However the EIS makes no mention of the actions which would take place if/when an ‘accidental’ release of dioxins or furans above the safe level occurs. The concerns associated with the release of these pollutants are elaborated upon below.

-at what point will the EPA be advised?
- what provision is there for an independent evaluation of the seriousness of the release?
- how can the general public trust Veolia to report a leak or release of noxious gases when previous leaks from the site have been notified to the EPA by the local community before Veolia has taken action
- how will Veolia ensure the Continuous Emissions Monitoring System (CEMS) is functioning correctly? This is not a trivial question as there are many documented examples of serious industrial incidents which can be attributed to operator error. A notable case being Buncefield 11/12/2005, when operators trusted the readings on the monitoring equipment although experience should have told them there was a problem and a huge explosion resulted in the injury of forty people. www.hse.gov.uk/comah/buncefield/
- will root cause analysis be made of any incident and reported to the local community via the media?
- who will audit ‘near misses’?
- how will the local community be notified in the event of a serious release of dioxins or furans and at what point will they be instructed not to sell eggs, vegetables etc which will have been contaminated by the fall-out?
- how will Veolia compensate local farmers in the event of fall-out?
- how will Veolia monitor employee behaviour so that the risk of contamination is minimised ie. how will ‘human error’ be mitigated
- how will Veolia prove they are complying with the Standard at all times?
- the EIS makes no mention of Veolia having an Incident Management System
- how many EPA inspectors/officers will be policing the Plant at any one time?
-
Section 2
Veolia have been assured of a continuous supply of waste for the next 25 years. The NSW Government plan to recycle all virgin plastic by 2040. Other improvements in recycling will be made by that time. What plans are in place to satisfy the contracted waste stream? Will a shortage of “suitable feedstock” in the future mean bringing waste from other cities with the increased risk of accidents and accompanying pollution from trucks etc.? The EIS states that incinerating waste supports the circular economy, I do not agree because the need for incinerator feedstock will be a disincentive to reprocessing and recycling waste. See Zero Waste Europe: The hidden costs of incineration: the case of Madeira and Azores Case Study January 2019 https://zerowasteeurope.eu/downloads/the-hidden-costs-of- incineration-the-case-of-madeira-and-azores/ This case study found that recycling of domestic waste was almost non-existent as the local council struggled to meet the demands for feedstock of the incinerator. Also https://www.wastedive.com/news/wheelabrator-baltimore-lawsuit-contract-dispute/552762/ where the waste handling company is suing Baltimore County USA for $32 million for failing to fulfil the contract for the supply of feedstock.

3. The EIS states that 245 kL of water per day are required for the Plant which will be met by stormwater or groundwater from the Willeroo borefield. In the event that Climate Change causes a long-lasting drought with higher than usual temperatures, where will the water come from if the bores are dry? Bore MB6 is now considered to be a dry bore so it is feasible that other could also dry up. What measures have Veolia taken to ensure safety in the event of the required amount of water not being available?

4. EIS Section 3.5.6 Management of By-products
No mention is made in the EIS of how asbestos will be dealt with. It is now widely accepted that all types of asbestos are inherently dangerous if small dust like particles are breathed into the lungs where they can cause asbestosis, malignant mesothelioma , lung cancer, ovarian cancer, laryngeal cancer and other serious diseases. (www. asbestos.com). Crocidolite asbestos, or Brown asbestos, was mined in Australia and was used in a variety of construction materials such as ceiling tiles, cement sheets, building insulation and fireproofing applications. It is therefore probable that this hazardous waste material will be found in both household and industrial waste brought to the plant, despite best efforts of the waste handling plants in Sydney in trying to separate it before its transportation to Tarago. It is therefore certain that there will be occasions when the asbestos waste will enter the incinerator. Asbestos requires a very high temperature of 1200oC to fuse the fibres into glass beads; unfortunately this will not take place in the Tarago incinerator as its maximum is 850 to 950C.
This would mean fibres could be in the bottom ash which is destined to be spread on the landfill. That would be a hazard to employees at the site as it only needs a few fibres blown in the wind to enter the lungs, and just a few fibres can be enough to cause a problem several years later.