*11 MEWTI]EN1.0 ]FIkITiIiLlTI

LIRAY V!?TAL PROTECTMN

I Ru tOUl —r'••-

AMENDMENT TO PRESTIGE BRICK WORKS

PROPOSAL TO RE—DEVELOP THE MIDLAND

ABATTOIR FOR A HIGH TECHNOLOGY

BRICK WORKS.

DoE Information Centre

IIll IIll II III II IIIII 009180

OCTOBER 1987

666.7 1ct83 SD CONSULTANTS

(941.1) Consulting Engineers, Town Planners & Project Managers.

U

_ TiI[EN]FIILITiIIi LIAWV

ENVIRUil

TAL p;', I MOUIT i boLRTH

AMEI%JDMENT TO PRESTIGE BRICK WORKS

PROPOSAL TO RE-DEVELOP THE MIDLAND

ABATTOIR FOR A HIGH TECHNOLOGY

BRICK WORKS.

OCTOBER 1987

F.J. Bryant, H App Sc (Eng). Gred.Dip.Eng.. A.l,T.Eng.. L.G.E., M.l.E.Aust

L. Saraceni, 8,A,(Urb. & Reg.Std.).. Grad.Dip.LJrb. & Reg.Plan..

Grad.Dip.Bus & Admin.. HR.A.P.i., A.A.I.M..

Mun.Plan.Cert.

J .A.L. Kotula, B.E.(Hons). H.I.E.Aust. - -

Suite 6, 2 Canning Highway South Perth, W.A. 6151. Telephone (09) 474 1366 Fax (09) 367 3231.

Your ref.

October 23,, .1987 Our ref.

U

ItOk~-~ :

SD CONSULTANTS PTY. LTD. As Trustee for theBSD Unit Trust

Consulting Engineers, Town Planners & Project Managers (Incorporated in Western Australia)

MrBACarbon Chairman Environmental Protection Authority BP House 1 Mount Street Perth 6000

Dear Sir

Re: NOTICE OF INTENT - 1X)DIFICATION TO PROPOSAL BY PRESTIGE BRICK TO REDEVELOP THE MIDLAND ABATrOIR SITE FOR A HIGH TECHNOLOGY BRICKWORKS - SWAN LOCATION 10802 MIDLAND ROAD, MIDLAND.

In response to your requirement in relation to the above proposal please find enclosed our Notice of mt nt for consideration by your Authority.

Your will note from the findings of the Notice of Intent that the modifications proposed will have a minimal and acceptable impact on the environment.

In order to assist the Authority in finalising its assessment as soon as possible, ten (10) copies have been forwarded for circulation within the Environmental Protection Authority.

Should you have any queries, or require clarification in relation to the matters raised would you please contact this office.

Yours faithfully

ceni Director

ASSOCIATED OFFICES— MEL-BOUPNE - SYDNEY - ADELAIDE - MILDugA

TABLE OF CONTENTS

PAGE NO.

SIJMMARY 1

1.0 INTRODUCTION 2

2.0 DESCRIPTION OF MODIFIED PROPOSAL 4

3.0 THE EXISTING ENVIRONMENT 5

3.1 Landuse Patterns and Zonings 5 3.2 The Helena River and Flood Plain 6 3.3 Climatic Characteristics 6 3.4 Air Quality 3.5 Noise Characteristics 7 3.6 Visual Characteristics 7

4.0 IMPACT OF THE AMENDED PROPOSAL COMPARFJ) TO 8 THE INITIAL PROPOSAL

4.1 Dispersion of Fluorides 8 4.2 Noise Impact 10

4.2.1 Relocation of Brick Plant and Kiln 10 4.2.2 Relocation of Clay Stockpiles 10

4.3 Drainage and Clay Stockpile Management 11 4.3.1 Drainage 11 4.3.2 Clay Stockpile Management 12

4.4 Other Impacts and Environmental Management 13

5.0 CONCLUSION 15

APPENDIX 1 16

APPENDIX 2 20

U

TABLE OF PLANS

PLAN NO. PLAN

1 LOCALITY PLAN

2 TITLED PARTICULARS

3 LAND REQUIREMENTS AND DEVELOPMENT STRATEGY MIDLAND ABATTOIR SITE. LAYOUT AS APPROVED SEPTEMBER, 1987.

4 LAND REQUIREMENTS AND DEVELOPMENT STRATEGY MIDLAND ABATTOIR SITE. AMENDED LAYOUT.

5 LANDUSE PATTERN

6 ISOPLETHS FOR GROUND LEVEL CONCENTRATIONS OF FLUORIDES

7 NOISE MONITORING LOCATIONS

TABLE OF TABLES

TABLE NO. TABLE

1 NOISE MONITORING LOCATION 1

2 NOISE MONITORING LOCATION 2

U

SIJMMARY

On September 1, 1987 the Environmental Protection Authority (EPA)

approved a proposal by Pilsley Investments Pty Ltd trading as Prestige

Brick for the establishment of a high technology brickworks on the

former Midland Abattoir site. This Notice of Intent has been prepared

to outline the environmental implications of the minor modification

proposed to the original development.

The modification proposed involve the relocation of the brick plant

and kiln building to a location approximately 130 metres north of that

proposed in the original Public Environmental Report. The

modification also involves the relocation of the clay stockpile area

and deletion of a 10 metreby approximately 210 metre long wide strip

of flood plain land which was required for the original proposal.

The level of fluoride concentrations at ground level and the total

area of dispersion will not change as a result of the relocation of

the brick plant and kiln building. Only minor changes will result in

relation to the location of the isopleths and consequently the type

of landuses involved. In this case the impact will femain

approximately the same as the original approved proposal and can be

concluded as having a negligible and acceptable impact on the

"natural" and "human" environment due to the relatively low level of

fluoride distribution and ground level concentrations.

The level of noise generated by the operation of the brickworks, with

the brick plant and kiln building and stockpile area in their

modified locations will also result in negligible and acceptable

impact on the environment.

The proposed minor modification will also contribute to the

enhancement of the "natural" environment as intrusion onto the flood

plain of the Helena River will be reduced.

All the other operational aspects of the proposal will also result in

a negligible and acceptable impact on the environment as they will

remain relatively unchanged from the original proposal which has been

approved by the Environmental Protection Authority.

U

1.

1.0 INTRODUCIION

On September 1, 1987 the Environmental Protection Authority approved a

proposal by Pilsley Investments Pty Ltd (trading as Prestige Brick) for the

establishment of a high technology brickworks on the former Midland

Abattoir site. (See Plan Nos 1 and 2 for location details and title

particulars). The following Notice of Intent has been prepared for the

purpose of detailing and evaluating the environmental implications of the

minor modifications now proposed.

The modifications involve the relocation of the existing former coolroom

building which is proposed to house the brick plant and kiln to a more

central position within the site, approximately 130 metres further north.

The modifications also involve the relocation of the proposed clay

stockpile area and the deletion of an additional 10 metre by 210 metre long

strip of land along the Helena River flood plain which was requested

during the Public Environmental Report and approved by the Environmental

Protection Authority. These proposed changes are clearly illustrated by a

comparison of Plan No 3 with Plan No 4.

As part of the Environmental Protection Authority's approval process, the

original proposal required a Notice of Intent followed by a Public

Environmental Report which was released for a review period of 10 weeks, in

which time it was advertised and submissions were invited from the public

and government agencies. The submissions received were considered by the

Environmental Protection Authority and the findings published in a report

entitled "Report and Recommendations of the Environmental Protection

Authority" (Bulletin 289, July 1987). This report sunimarised the concerns

raised in the submissions during the review period and proposed eight

recommendations to be satisfied by Prestige Brick in order to ensure there

would be a negligible impact on the environment. These recommendations

have been included as Appendix 1 of this Notice of Intent. In summary, the

Environmental Protection Authority found the project to be environmentally

acceptable subject to the recommendations of Bulletin 289.

I

2.

This Notice of Intent will clearly demonstrate that the minor modifications

to the approved proposal will not result in any higher ground level

concentrations of fluoride or unacceptable levels of noise or other adverse

impact on the surrounding environment. In short, it will be demonstrated

that the modifications will have a minimal and acceptable impact on the

environment.

U

3.

I

2 • DESCRIPTION OF MODIFIED PROPOSAL

Following a detailed analysis of the foundation capacity of the proposed

site of the brick plant and kiln structures (proposed locality "C" shown on

Plan Nos 3 and 4). It has been found that the location is geotechnically

unsuitable. These structures are therefore proposed to be relocated

approximately 130 metres north of the original site. As a result of this

relocation it is proposed to also relocate the clay stockpile area to that

original position (locality ttCVf) as shown on Plan No 4.

Under these circumstances it is considered that the additional land area

required along the Helena River flood plain (ie., the 10 metre wide by 210

metre long strip - see Plan No 4) is no longer necessary. As this land

intrudes upon the Helena River flood plain it has been suggested by the

Executive Director of Prestige Brick that this land could be ceded back, to

the Crown free of cost in order to assist in the creation of the Helena

River linear parkiand as promoted in the System 6 report (Department of

Conservation and Environment, 1983).

4.

-- t

r1 - c--c- --- -.----( - -

AllL

---_----_- .L- ".— -- -—----r----i aST S---,- --- ----

______________ - - —__L r±

-- -r\

..c

- — I 3EEOO 'E 'L • _±- C—EAS-

-Tm

-j —

Trr'TT

71

- —x - SCE OG I LJ-T rti -

ME _

TO t4 ff

AJ\i74G5LE71

DLAND ABATTOIR

IV

LL-

AN

41

EWSVAN

71

SO \-•/ - fyK/2 'AA\ -

¼ 7 / - WE4O1'( - <

-'. -

FAN

LESMURM

00

/77

OCTOBER 1987

IJOTICE OF If'JTEI\JT

AMENDMENT TO PRESTIGE BRICK WORKS.

N91 LOCALITY PLAN

PROPOSAL TO RE-DEVELOP THE MIDLAND ABATTOIR PLAN FOR A HIGH TECHNOLOGY BRICK WORKS. B SD C 0 11 S U LI A F1 IS CONSULTING ENGINEEIS, TOWN PLANNEIS £ PPOJICT MANAGEBS.

C; SUITE 6. 2 CANNING HIGHWAY SOUTH PlaiN. PHONE NO 4741366

57.

92.7 Ln SDcL 4y

A2299 In

1832 4.63/

VI

4' l87 25.25

Pt16 109.79 69.53

46.07 4

S - 329 2960

R29090 10802 7954

p4

-. m 25.9332ha to

Pt A39636 -. 10804

40.61

151 1.9 69.990

Pt16 24.82

N

Pt A 39636 -

WE 10805

r- )

S SCAU

4000

OCTOBER 1987 14.74

I

N

t\IOTICE OF It\JTEr'JT TITLE AMENDMENT TO PRESTIGE BRICK WORKS.

PROPOSAL TO RE-DEVELOP THE MIDLAND ABATTOIR PARTICULARS

FOR A HIGH TECHNOLOGY BRICK WORKS.

PLAN .jg;;t%,BSD CONSULTANTS N 92 CONSULTING ENGINEERS, TOWN PLANNERS & PROJECT MANAGERS.

SUITE 6. 2 CANNING HIGHWAY SOUTH PERTH. PHONE N. 4741366

I 317692C L

— \\ RESSEE;JLJ:: '—(Clay Trucks) so::

CLAYTON

10 __

\\

- __ - - - —

0O

FUTURE ii

LAND REQUIREMENtS

gig

FO

— -

SEg O\\ \

/ \\ — -_______f

••

CLAY ST COPC PILE A

LEGEND

93 _

BOUNDARY 01

r

BOUNDARY BE1 WELN LAND REQUIR \TS - G PHASE I AND PHASE

\ -

STRUCURES FO BE RETAI EDND PHASE/

B B

EXTENSIVCLY REDEVELOPED RENOVATED OR L REQUI EMENTS - . / - /7• j '

A. ADMINISTRATION ASS WOS5SOP ' -. - - i \ — -- -- — • I U. CLAY PREPARATION - i. - -. - --- - approx 19'1I)\ - ,,_-7 C. BRICK PLANT AND EIi - '. \:. - / - // I S

0. SPLIT TILE PLAN - I -, f •--..-:- -:--:. RESIDENCES

STORAGE AMD ASCIL AS ?ACIIIES /

EFFLUENT FACILITIES TO REMAIN IN PRESENT STA WHILST SALES YARD IN OPERATIO. DLRl,PHASEI

- LAND TRAFER )

) SUGGESTED BOUNDARY ADJUSTYENT -D \ PILSLEY INVSTMEh - 1/ / XEH4f

..LAND TO BE INCLUDED IN SITE \ \J PTY-L5TD vt S /

TOSE/EWT/ATEO/ __•

..

LAND-EXCISED FRO / TH

OER 0WN PASr AL.

/ / \ , - 1 AREAS OF LAND TO BE NEGOTIATED WITH WESTRAILI L1J SITE AND TRANSFERRED

__\ !

I DIRECTION OF MAIN INTERNAL TRAFFIC CIRCULATION SPINE - — --- --•,j \ \\\ —

5-

__

( \ RAIL SPUR LINES TO BE RETAINED

, \. - \

\n,••_

132 KV SUB—i RANSMISSION LINE TO BE

RELOCATED TO WES T OF EXIST I G AN D NO I (H All sos and areas SJP4 I to survey. / / \

(2) LaW I r?flfer$ sUJeCt to! OhO PROPOSED EXTENSIONS

— / I

LAND REQUIREMENTS & DEVELOPMENT LAYOUT AS APPROVED N

SCALE 2000

FOLLOWING-- PUBLIC SHEET OF ConsuIng Engineers, Town Plonners

STRATEGY MIDLAND ABATTOIR SITE ENVIROMENTAL REPORT E &Proj<Mona9erI.

for PRESTIGE BRICK SEPTEMBER 1987 . s TNG H!GHWAY

P 858!-MK 1 SOUTH PEYTH 6151

• • - I. • 38 3 2 20 21 2

ISOCI 11726CLAYTON

100

J A 00

33

SALES YARDS \ —

4 .

/?q ( . •.:•...

LS 2

I / \•' \ (°

/ • / J • \

LEGEND

BOUNDARY OF SITE \ \\\\

BOUNDARY OF LEASE AREA FOR SALES YARDS •

H 9 . . \ \\\ B

REDEVELOPED RENOVATED ORE)ANDEDFO

SWAN WCON LS A. ADMINISTRATION AND WORKSHOP

AREAE. \7'\ \\•_ d \ 5'

P. CARETAKERS RESIDENCE i/ >-\\\ .. • - . . • -- \ I -o'-\ \\\\\\\\

/ 'NGRESS & EGRESS

STRUCTURES AND EFFLUENT DISPOSAL FACIUTIE / • -

/ .-[ TO REMAIN IN PRESENT STATE WHILST SALES YARD IN OPERATION DURING PHASE I / 'N 1• - . . - - •,

____ / -. f ,,- • . . •

0

SUGGESTED BOUNDARY ADJUSTMENT AND LAND 1O

/ / Z

RLAE

CL

A ) rTar WITH F 7~11 INCLUDED IN SITE

I (W2( %! X1, OWNER _-~DE PASTORAL N F

I -• • • • A ITI0AO METRES- - • . '•• APPR

132 KV STRANSMISSION UNE TO BE • •, •• • • • / \\\ RELOCATED TO WEST OF EXISTING AND • \ /\. NOTE. (1) All dnisicns and areas subjec-f to survey. o / • e4. \ N - PROPOSED STRUCTURES

:• (2) Lind transfers subject to final negotiation1\ eN ,, •

LAND REQUIREMENTS & DEVELOPMENT AMENDED LAYOUT- BSD CONSUI.TANTS

:::::

-20LE 1 00

OF 2

STRATEGY MIDLAND ABATTOIR SITE . PLANT AND KILN BUILDING. W E DRAWING NUMBER

for PRESTIGE BRICK S ] SUITE HIGHWAY - - PLAN N° 4 OCTOBER 1987 SOUTH P€RTH 6151 -

3. THE EXISTING ENVIRONMENT

3.1 Landuse Patterns and Zonings

in order to assist in the evaluation of the proposed modification it is

necessary to once again describe the existing environment (see Plan No 5).

The major landuse adjoining the site is the Midland railway workshops

immediately abutting its northern boundary. To the east of the site

separated by a railway spur line are located the Army Stores buildings and

warehouses which front Military Road. Abutting the site to the south the

Helena River Valley, formed by the river flood plain, dominates the area

and provides a heavy natural vegetated buffer aid screen from the former

rural stockholding paddocks further south.

Further from the site to the north—west is the commercial area known as the

Midland Sub—Regional Centre. Between the railway and Great Eastern Highway

a mixture of old residential properties and showroom industrial premises

exist. East of the site between Military Road and Great Eastern Highway a

substantial industrial area is beginning to form through the gradual

replacement of old residential housing stock. This replacement is being

further encouraged by the zoning of the land under the Council's District

Planning Scheme for industrial purposes.

The nearest significant residential area is the Hazelmere townsite which is

physically isolated from the site and located in excess of 1 km to the

west. In physical and visual terms the Hazelmere locality, including the

former stockholding paddocks are separated from the Abattoir site. The

nearby vegetated buffer created by the Helena River flood plain ensures

that the abattoir site cannot be seen from most locations in the Hazelmere

area and that the site, or its use is not identified as part of that

locality. For these reasons the site is closely, identified with the

industrial areas to the north of the Helena River which surround it such as

the Belivue industrial Area and the Westrail land.

The surrounding landuses and former use of the site is reflected in the

industrial zoning classification given to the land under the Metropolitan

Region Scheme and the Council's District Town Planning Scheme No 9. It is

I

5.

unlikely that this site would ever attract any other zoning other than

industry.

3.2 The Helena River and Flood Plain

The area of the Helena River flood plain immediately abutting the site is

relatively densely vegetated and helps to form a significant screen from

the Hazelmere locality. This flood plain area has been incorporated within

the System 6 Report. The banks of the river have retained only a portion of

the natural vegetation, often only in single rows of trees with solitary

trees and bare stretches intermittent along its length with the landwards

section of the flood plain being better wooded than the river bank itself.

The most common tree in the area is flooded gum with the frequent inclusion

of swamp paper bark along the more level reaches of the flood plain.

Introduced trees occur near Guildford, the most predominant of which is the

Ash. Good regeneration of flooded gum has occurred on many of the flood

plain flats with ground flora in the remaining areas having suffered

denudation by intensive grazing. Included in the ground cover of the flats

are introduced grasses such as Paspalum, Distichum and Stenotraphum,

Secundatem. There are also clumps of Triglochin Procera in the water.

The part of the Helena Valley flood plain adjoining the abattoir site is

not easily accessible to people and is little used. Particularly since it

holds very little water, even during winter months, due mainly to the

damming which has occurred upstream many years previously.

3.3 Climatic Characteristics

The climate is Mediterranean with mild wet winters and hot dry summers.

The long term mean annual rainfall at Guildford is 879mm, mostly occurring

between May and October. Evaporation exceeds rainfall for the months

October to May. Average daily sunshine hours are 7.8 and average number of

rain days (0.2mm) are 121.

The summer wind pattern is dominated by the sea-land breeze system with

proximity to the nearby escarpment resulting in strong east to south-

easterly winds in the morning and moderate to strong south-westerly during

the afternoon. Winter weather patterns are dominated by the progression of

synoptic systems to the east, bringing rain bearing depressions and north-

west to south-west winds. Wind directions are generally less regular than

in summer.

U

3,4 Air Quality

With respect to the principle species, gaseous Hydrogen Fluoride no air

quality data exists in the immediate vicinity. Although no base data for

ambient fluorides exists, it is believed that current levels in the

vicinity of the abattoir are likely to be low (less than .05 pg/rn3).

Other currently operating brickworks in the Swan Valley are approximately 4

km to the north—west of the proposal, so given the prevailing wind

directions, dispersion of emissions from those brickworks is not expected

to result in a cumulative effect in the immediate area of the proposal.

3.5 Noise Characteristics

The existing environment has been shown from measurement to at times exceed

regulatory signed noise levels due to the impact of air and rail

transportation and the nearby Roe Highway as discussed in the original

Public Environmental Report. The operation of the brickworks will comply

with the requirements of the Noise Abatement Act (1972-81). The analysis

of the likely noise impact is discussed in greater detail in the next

section of the Notice of Intent.

3.6 Visual Characteristics

The present state of the site is unsightly from within due to the present

poor condition of disused abattoir buildings and structures. However, the

existing structures are screened from the Hazelmere area by the dense

stands of trees along the Helena River and from Military Road by the

salesyards and Army Depot buildings.

7.

I

4. IMPACT OF TEE AMENDED PROPOSAL COMPARED 10 TEE INITIAL PROPOSAL

4.1 Dispersion of Fluorides

The dispersion model used in this Notice of Intent was the same as that

used in the original Public Environmental Report (May 1987). This was a

Sector Average Gaussian Plume. This model uses a procedure to evaluate

atmospheric stability from solar radiation during the day and cloud cover

at night. Wind speed data collected on a Dines Anemometer was corrected

after calibration against a Woelfe wind speed recorder by the Bureau of

Meterology.

As a result of the brick making process, Hydrogen Fluoride is produced and

emitted. The Hydrogen Fluoride can be removed from the atmosphere by a

range of natural and chemical processes. This summary adopts "a worst

case" stance, examining processes that do not consider removal for the sake

of conservativeness.

Using a kiln stack height of 35 metres the modelling indicated a maximum 3

monthly mean concentration of 0.3 yg/m 3 . The areas exposed to

concentration greater than 0.1 pg/rn3 were binodal in shape as in the

original Public Environmental Report (see Plan No 6). These affects are

intermittent by nature and as such, are shown as the maximum 3 monthly

level modelled during the 5 year modelling period, rather than inferring

that the constant level was maintained over that period.

With reference to the relocation of the 35 metre stack for the proposed

brickworks, it is expected that there will be no increase in the

concentration of fluorides emitted however, there will be a marginal change

in the location of ground level fluoride concentration isopleths from the

location shown in the original Public Environmental Report approved on

September 1, 1987.

The landuse of the areas affected by the highest ground level fluoride

concentration produced, (ie. 0.3 pg/rn3 ) is of generally a rural character

in a situation which has not changed from that identified in the original

Public Environmental Report and is on land which was formerly used as a

stock holding paddock area. The overall number of residential dwellings

! — — 9 Ln

EL

_

(1011

lIiv

4.

it

SIIAVY

(ilia

-

rnoINvs ('I1 /

ifp OIIIJSNOOVIII PNIAV

,7 : los .

. ( I

L_L_ Ill I' I1II " U

Lt /i(

LIII] IL\74

_ jJ c11 4 \

\

(IS j[j II V1flIW I

(

-

(0000 AYM3011 w

> M z \S11vl hullS A31SUINVII 11111 133y,

' uouu fl •.. Alv

I

/FL E

[Ji o

OVO ll

%jW , '. . isti 11300 • )4fr

U 0 0 43 0

U/ . OW±

EA 17

I ,

/

I /

to be affected by the concentrations of 0.2 pg/rn3 or less remains virtually

unchanged (see Plan No 6). No known commercial horticultural or

viticultural activities which are likely to be adversely affected by these

levels of concentrations are carried out in any area encompassed by the

isopleths.

Documented effects of fluoride on human and grazing animal health show that

there are negligible effects likely from the concentration modelled. In

areas where concentrations were in excess of 0.1 ,pg/m 3 there may be some

minor affects of foliar stress visible. Deleterious affects will be

limited to plant species such as gladioli, grape, vine, peach fruit and

jarrah trees in some home gardens within the 0.1 pg/rn3 concentrations

area.

As in the initial proposal, the ground level fluoride concentrations around

the brickworks will have a negligible affect on humans being less than the

highest levels of fluoride that may be encountered daily in the fluoridated

metropolitan water supply.'

The main affect of the fluoride emission is expected to be on plants as was

the case in the original proposal. Sensitive species sustain damage under

concentrations of 0.1 pg/rn 3 while native species will Sustain minor visible

damage at concentrations of 0.5 pg/rn 3. It must be noted however, that

these higher levels are not likely.

The biophysical impacts of fluorides remains unchanged from the original

proposal and limited to minor effects on some plants in home gardens in the

immediate vicinity. Given present landuses within the area, it is not

expected that the modified proposal will generate any additional adverse

effects.

It is unlikely that plant deaths would occur even in the areas of highest

concentration to the west of the proposed brickworks however, some minor

visible plant damage may occur. This is consistent with the predictions of

the initial stack location.

II

Given the prevailing climatic conditions it is' unlikely that the proposed

relocation of the brick plant and kiln will result in unsafe cumulative

effects of emissions given the relatively nearby location of other

brickworks in the Swan Valley.

It can be concluded, that the relocation of the 35 metre high proposed

emission stack to a position approximately 130 metres north of the original

proposal will have negligible effects on humans, grazing animals and no

effect on commercial horticulture or viticulture in the region. There may

be minor plant damage to delicate of. sensitive plants in the area

encompassed by the 0.3 pg/rn3 concentration isopleth. However, it should be

noted that this area is at present largely cleared and undeveloped. In

areas below this concentration effects are considered to be negligible.

4.2 Noise Impact

4.2.1 Relocation of Brick Plant and Kiln

The proposal to locate the Brick Plant and Kiln further to the north will

not have an adverse affect on the environmental noise.

Such a move will benefit the nearest proposed residential area by

increasing the distance.

To the north the presence of railway marshalling yards, industry and

commerce are such as to give a higher assigned level which more than

compensates for the reduction in distance.

As stated in the first report the specification of plant, equipment and

building construction must all ensure that adequate attenuation of noise is

achieved. This is possible within current technology for the type of plant

envisaged.

4.2.2 Relocation of Clay Stockpiles

Prestige Brick propose to operate the stockpile between the hours of 0700

to 1900 Monday to Friday (inclusive). This 'has been confirmed in writing

(see Appendix 2). The appended graph demonstrates that for the stated

working times of 0700 to 1900 Monday 'to Friday (inclusive) the assigned

noise levels can be achieved at the nearest proposed residential area

(Location 2 - See Map No. 7 and Appendix 2). This is dependent upon

maintaining a barrier (clay bund) with an effective height of RL 21.5

metres with the machine working on a maximum RL 14.0 metres; the crest of

the stockpile being 500 metres from the residential boundary and the

U

10.

machine working within 55 metres of the crest. Prestige Brick propose to

operate the stockpile in this manner.

At location 1 (See Map No. 7) being the nearest existing residential

boundary approximately 1400 m away, the assigned noise levels for the

stated times would not be achieved when using a basic CAT 988 wheel loader

as proposed by Prestige Brick. However current technology would be able to

achieve noise control of this machine such that the assigned levels would

be met. Furthermore, the noise evaluation undertaken by Alan Herring

Acoustics does not take into consideration that the clay bund will extend

in a north—south direction as well as east—west therefore acting as a

further barrier to noise. The appended graph shows the discrepancy between

the machine sound power levels as calculated from measurements made at 7

metres and the allowable sound power levels as calculated to meet the

assigned sound pressure levels at the residential boundary.

Delivery of clay to the stockpiles is to be by registered road transport

and hence must comply with the noise requirements for road vehicles. Such

vehicles should not cause any greater impact on the noise environment than

vehicles currently using the freeway and existing road systems.

4.3 Drainage and Clay Stockpile Management

4.3.1 Drainage

The Public Environmental Report (May 1987) stated that "the existing

drainage system is more than adequate to cater for the proposed brickworks

as no new buildings are proposed in real terms and no greater areas of

hardstand are likely to be provided. The existing waste water treatment

plant will receive drainage from most of the abattoir and saleyard area.

Whilst the new proposal provides for the brick plant and kiln to be located

in a building approximately 130 metres north of the original proposal, the

size of the actual building is approximately the same. New hardstand areas

will be required to be constructed to service the new building location

however, existing hardstand in the area of the proposed clay stockpile will

be no longer required.

The amended proposal which provides only for the relocation of the building

and stockpile areas therefore, does not generate any additional runoff and

Pu

11.

therefore, it can be concluded that the existing drainage system is

adequate.

It is however proposed that the stormwater currently being discharged

directly off-site through the Helena River flood plain be controlled by

installing standard oil and silt trapped manholes in the stormwater lines

adjacent to the site boundary to the specification and satisfaction of the

Water Authority of Western Australia and the Shire of Swan. Such

installations are of a standard accepted design that will ensure the

retained soils and silts from the hardstand areas are not discharged into

the flood plain as it has in previous years.

The clay stockpile area will be constructed so that stormwater will be

collected in the north-western corner of the stockpile area and discharged

into the existing waste water settlement and treatment lagoons.

4.3.2 Clay Stockpile Management

The clay stockpile area will be constructed with a permanent clay bund on

the southern and western extremities of the stockpile area. The permanent

bund will be constructed so as to allow for the clay trucks to traffic the

top of the bund and tip their material into the stockpile area located

between the existing buildings marked Btt on the Development Strategy Plan

and the bund. The front end loader will work between the bund and the clay

dump area located on the southern wall of the clay preparation buildings

(building "B"). All stormwater collected in this area will be discharged

into the existing waste settlement and treatment lagoons. Only a minor

amount of stormwater which falls on the outside face of the bund

constructed along the southern boundary of the site will discharge down the

boundary embankment onto the flood plain. The clay bund will have a

hardened or "crust" surface permanently exposed and untrafficable along the

boundary, and as such, stormwater runoff being minimal in volume, will have

no detrimental effect on the flood plain.

The proponent acknowledges the previous recommendation of the Environmental

Protection Authority that "in the event of the requirement to fill part of

the flood plain, the proponent should landscape the filled area in a manner

which recreates the indigenous floodplain vegetation of that area." In

this regard, the proponent proposes to landscape the embankment and land

'U

12.

adjacent to the clay bund for a distance of approximately 15 metres from

the site boundary.

There will be a need for dust management of the clay stockpile area,

particularly when clay is being received. It is proposed that during this

operation water will be used to manage any dust problem that may be

created. It is anticipated that the operation of the front end loader in

the clay stockpile area will not cause any dust problem due to the site

being surrounded by the clay bund and buildings thereby, giving substantial

protection from the wind. However, adequate water sources will be provided

so as to allow for the easy management of any dust problem during workings

in the stockpile area.

The proponent however, recognises that he will be required to take

appropriate action to stop any dust nuisance occurring should he be

directed to do so by the Shire of Swan and/or the nominee of the Minister

for Transport.

4.4 Other Impacts and Environmental Management

The other environmental impacts associated with this proposed relocation of

the brick plant will not change significantly. In fact, it should result

in an improvement to the conditions relating to traffic and transport, the

Helena River and its flood plain and visual characteristics as summarised

below.

The proposed relocation will not generate any additional traffic to that

calculated in the original Public Environmental Report. The potential for

conflict between the operations of the sales yards and the brick plant will

be reduced significantly by the fact that only one ingress and egress point

is now proposed for the brickworks at the southeast of the site as shown on

Plan No. 4.

The Helena River and its flood plain will be affected to a lesser degree by

the deletion of the additional 10 metres of land required as shown on Plan

No.4.

The future residential area will not be adversely affected by the proposed

modifications as the operation of the stockpile area will not generate any

adverse noise impact. Given also the previous considerations detailed in

I

13.

the original Public Environmental Report - particularly those related to

the present screening of the site from the future residential area by the

vegetation of the Helena River flood plain together with the physical

isolation of the site by that same flood plain and the fact that no direct

connection between the two areas is available - the impact on the future

residential area will be negligible as in the original proposal.

The relocation of the proposed plant and kiln building to a more central

position within the site and behind significant abattoir structures will

ensure that the 35 metre stack will be screened toa greater degree from

public view than was the case with the original proposal. While there is a

potential for the clay stockpile area to be more visible from the proposed

residential area in Hazelmere, in planning terms the stockpile would be

considered to be less intrusive to any future residents than the kiln

stack which it replaces in that location.

I

14.

U

5.0 CONCLUSION

The proposed modifications to Prestige Brick's approval to redevelop the

Midland Abattoir site for a high technology brickworks does not result in

significantly different findings from the original Public Environmental

Report (May 1987) in that it will result in a minimal and acceptable impact

on the environment.

The two most important environmental considerations associated with the

modified proposal involve the emission and ground level concentrations of

fluoride resulting from the process of production and the likely changes to

the impact of noise. In this regard it has been clearly demonstrated in

this Notice of Intent that the fluoride emission and resulting ground level

concentrations is likely to have a negligible and acceptable impact on the

environment. The changed conditions are also likely to result in noise

having a negligible and acceptable impact on the environment. Other

aspects of the project such as affect on the Helena River flood plain,

traffic, heat, dust and visual features will be of minimal impact as in the

original proposal, particularly in the context of the industrial area

within which the site is located. In fact, it could be argued that the

proposed relocation of the brick and kiln plant building and clay stockpile

area together with the deletion of the further 10 metres of land

requirement along the Helena River flood plain represents a marginal

improvement in relation to the environmental impacts associated with the

project. Therefore as was found with the original proposal, the overall

redevelopment of the Midland Abattoir site for a high technology brickworks

can be concluded as having an overall minimal and acceptable impact on the

environment.

15.

'.0

1 RECC4MENDATIUNS OF ENVIRONMENTAL PROTECTION AUTHORITY - BULLETIN 289, JULY 1987

SUNNARY

Pilsley investments Pty Ltd trading as Prestige Brick has prepared a Public Environmental Report (PER) for a proposed brickworks at the old Midland abattoir site in Midland. The PER was released for a 10 week public review period concluding on 1 July 1987. The Environmental Protection Authority received 26 submissions.

The Environmental Protection Authority assessment and public submissions raised concerns in the following general areas:

the impact of air emissions on the surrounding area;

noise effects on the surrounding neighbours;

the potential for dust nuisance from traffic and the plant;

the interactions with planning related matters; and

the impact on the Helena River floodplain.

While there are potential environmental impacts associated with each of the above, the Environmental Protection Authority considers that the main issue is the potential for dan-iage to vegetation resulting from fluoride emissions from the plant. In its recommendations the Environmental Protection Authority has sought to address this issue in a comprehensive manner.

Following assessment of the PER, the submissions and the additional information supplied by the proponent the Environmental Protection Authority consi'- ers that:

subject to the proponent's commitments given in the PER and in the additional information supplied to the Environmental Protection Authority an the Recommendations made in this Assessment Report the proposal is environmentally acceptable;

based on the information in the PER there exists a potential for minor injury to vegetation from fluoride fallout from the brickworks. The Environmental Protection Authority considers that this is a realistic assessment. The Environmental Protection Authority emphasises that the fluoride levels which may cause injury to vegetation are considerably lower than those levels which will cause human health affects;

there is insufficient information in the PER on the means by which the noise emissions from the brickworks will be controlled., However, if appropriate control measures are undertaken, noise emissions can be reduced to an acceptable level;

there are aspects of the transport of raw materials and brickworks operation which may result in a dust nuisance. The control of this is the responsibility of the proponent; and

the project may require some minor filling of the Helena River flood plain in the vicinity of the brickworks. It is unlikely that this will have any significant impact on the floodplain or its hydrological characteristics.

Accordingly, the Environmental Protection Authority has made the following conclus ions and recommendations: - - - -

1) The Environmental Protection Authority concludes that the proposal as described in the Public Environmental Report (PER) is environmentally acceptable and recommends that it could proceed subject to:

17.

the proponent's commitments given in the PER and in the additional information supplied to the Environmental Protection Authority; and

the Authority's Conclusions and Recommendations in this Assessment T Report.

Based on the information available to the Environmental Protection Authority recommends that:

the fluoride mass emission rate from the whole plant should never exceed 1.0 gram/second;

these emissions should be released to the environment through a stack with a minimum height of 35 in;

the proponent should monitor the emission rate and supply the results to the Environmental Protection Authority as part of a monitoring and verification programme approved by the Environmental Protection Authority; and

if, in accordance with Recommendation (3) environmental damage occurs as a result of the brickworks operation, this maximum allowable mass emission rate will be reduced to a level such that the objective of the continuing maintenance of current beneficial uses of the locality is

The Environmental Protection Authority recommends that the proponent funds an independent study, to be approved by the Environmental Protection Authority to measure the Ground Level Concentrations (GLC's) of fluoride on areas around the plant, and the associated effects on the environment. For appropriate verification of this sti'dy, monitoring will have to commence well before the plant becomes operaLional. In the event that the Environmental Protection Authority is not satisfied with the assessment of the state of the environment as shown in the results of the study, the Environmental Protection Authority will require the proponent to modify its operations to reduce air emissions to an acceptable level.

The Environmental Protection Authority recommends that the proponent should configure the various parts of the plant so that a scrubber can be retrofitted to Stage 1 should the Environmental Protection Authority consider it necessary.

The Environmental Protection Authority recommends that if the project proceeds to Stage 2 the proponent should maintain the fluoride emissions from the total plant at the mass emission rate set in Recommendation (2).

The Environmental Protection Authority recommends that the noise emissions from the plant will need to be at a level acceptable to the Authority. This will be controlled by appropriate licencing conditions set under the Environmental Protection Act.

U

The Environemntal Protection Authority recommends that should there be a nuisance from dust associated with the brickworks outside the site boundary occurs the Swan Shire Council and the nominee of the Minister for Transport should inform the proponent to take appropriate action to stop the nuisance occurring.

The Environmental Protection Authority recommends that in the event of the reuiqrement to fill part of the floodplain the proponent should landscape the filled area in a nianner which recreates the indigenous floodplain vegetation of that area.

19.

Ii

LL

Jç

Im

ALLAN HERRING ACOUSTICS 3/14 STONE STREET, SOUTH PERTH, WESTERN AUSTRALIA, 6151. TELEPHONE: (09) 367 6200

ALLAN HERRING M,I.E, AUST., MAAS.

20 OcLober 1987

BSD Consultants Suite 6 2 Canning Highway SOUTH PERTH WA 6151

Attention: Mr. Frank Bryant

Dear Eir

Prestige Brick Proposal

Herewith our supplementary report covering amendments to the proposed layout as per:

Drawings received 18J0..87 shcwina relocation of Brick. Plant, Kiln and Clay Stockpile;

Drawing received as marked up 10.10.87 showing stockpile detal is;

Letter dated 14.10.87 cx. Prestige Dric}: stating operating times to which verbal advice added that Stockpile reclamation would be confined to Monday - Friday (inclusive) each week;

Djscussjon on 13.10,87 and 15.10,87 between Messrs Luke Saraciri, Frank Bryant and Bob Chinriery.

The question of the levelling of the tops of the stockpiles to enable dump trucRs to reverse up to the face remains in abeyance. Otherwise, provided attention is given to adequately speciiying noise compliance criteria as noted in Allan Herring Acoustics letter of 17.10.86, the proposed modifications to layout can be achieved whilst satisfying environmental noise requirerients.

''ours faithu11y, For: ALLAN HERRING ACOUSTICS

R.R. Chinnery Chartered Engi'r, Austr1i.,

End.

October 14, 1987

Allan Herring Acoustics 14 Stone Street South Perth 6151

Attention: Mr Bob Chinnery

Dear Sir

Re: PRESTIGE BRICK PROPOSAL - NOISE EYAUJAUON

Frthc r to my recent di;cussion with my Project Co3ultfltg, BLD Consultants Pty Ltd, I wish to confirm my advice that the work on the stockpile area will not commence prior to 7.00 am and will never extend beyond 7.00 pm. Normal working hours will be 7.00 am to 5.30 pm. Work in the stockpile area includes the receival of clay by truck and the transport of this clay from the stockpile to the dump areas via front end loader.

I have also advised the Project Consultants of the proposed stockpile arrangements where, due to the dumping operations of the trucks, a permanent stockpile face be erected to the south and west of the site. The top of the stockpile face will be at approximately RL 21-22. The working elevation of the front end loader will be at approximately RL 12 to a maximum of RL 14.

I trust that this information, together with that supplied by the Project Consultants will be sufficient to enable you to finalise your evaluation on the noise impact of the above proposal. Should you however, have any further queries please do not hesitate to contact me.

Yours faithfully

P 0 Ellett Executive Director

'cv Sod..\idIand. \Vstern AusIraia Teephoe O9 274 5333. F.x 09j 274 1585

''22 S in 605

i

PRESTIGE BRIC1<P1QpOSALs

SUPPLEMENT TO THE REPORT OP OCTOBER 1986

by

ALLAN HERRING ACOUSTICS

20 October 1987

23.

I

T SCALE —

/ J I 25000

\\+--k Noise Monitoring Locations

r\JOTICE OF r\JTENJT

PROPOSAL TO RE—DEVELOP THE MIDLAND A3TTOIR PLAN lfo B S D C 0 NI S U I T 41 N I S FOR A HIGH TECHNOLOGY BRICK wos. N9 7

AMENDMENT TO PRTSTIGE BRICK WORKS.

CONSULTING ENGINEERS. TOWN PLANNERS £ PRO.)ICJ MANAGERS.

NOISE MONITORING NID SUITE 6. 2 CANNING HIGHWAY SOUTH PflTH. PHONE W. 4741366

LOCATIONS

ALLAN HERRING ACOUSTICS Job No, 73J /.. NOE I.SflOA//To,//

87 LO477O// Date /7-fO- /. Sheet No.

41,

_ 4r9B8 Ph/L

I

Lrl

:

H:

63 125 250 500 1000 2000 40.00 8000 ocr,wt CNT2& F&PiAEWCY

24.

II

ALLAN HERRING ACOUSTICS

7AJ3LEZ: NO/ HON TO/AJG Job No. Date /-/087 Sheet No

IPWL

WIAlb

NN 4 go P'L

1:

80

:Nso

: - cl

- -

Nio

63 125 250 500 1000 2000 4000 8000 25.

0ctavc Band Centre Frecuencv E-{ (/s