Final 20B Conference Report ULAB - Amazon S3 · 2020-04-09 · WORKS APPROVAL APPLICATION 20B...

A P R I L 2 0 2 0

Applicant: Chunxing Corporation Pty Ltd

Prepared for Environment Protection Authority

Works Approval Application 20B Conference Report – Chunxing Used Lead Acid Battery Recycling Facility

Level 1 East, 1100 – 1102 Toorak Road, Camberwell, Victoria 3124

(03) 9882 2670 – rmcg.com.au

W O R K S A P P R O V A L A P P L I C A T I O N 2 0 B C O N F E R E N C E R E P O R T – C H U N X I N G U S E D L E A D A C I D B A T T E R Y R E C Y C L I N G F A C I L I T Y

Table of Contents

Declaration 1

Executive summary and recommendations 2

1 Introduction and background 6 1.1 SUMMARY OF APPLICATION 6 1.2 PURPOSE OF THE 20B CONFERENCE 6 1.3 PURPOSE OF THIS REPORT 6 1.4 CONFERENCE FORMAT 7 1.5 ATTENDEES 8

2 Conference process and content 9 2.1 INDEPENDENT CHAIR’S INTRODUCTION 9 2.2 PRESENTATIONS 9 2.3 GROUP DISCUSSIONS 10 2.4 CONSOLIDATED LIST OF QUESTIONS 27 2.5 NEXT STEPS 34

3 Chair’s observations and recommendations 35 3.1 OBSERVATIONS 35 3.2 RECOMMENDATIONS 36

Appendix 1: PowerPoint presentation provided by Chunxing 47

Appendix 2: PowerPoint presentation provided by EPA 48

Appendix 3: Conference agenda 49

Appendix 4: Conference attendees 50

Appendix 5: Table based collateral 54

Appendix 6: Summary of key themes 61

Appendix 7: Conference evaluation 64

W O R K S A P P R O V A L A P P L I C A T I O N 2 0 B C O N F E R E N C E R E P O R T – C H U N X I N G U S E D L E A D A C I D B A T T E R Y R E C Y C L I N G F A C I L I T Y 1

Declaration I am the Chairperson appointed under Section 20B of the Environment Protection Act 1970 to preside over a conference relating to Works Approval Application by Chunxing Corporation Pty Ltd for the proposal to develop a Used Lead Acid Battery Recycling Plant.

I hereby submit my report to the Environment Protection Authority as required under the provisions of the Act.

RM Consulting Group Pty Ltd (trading as RMCG)

6 March 2020

Kristen Stirling S E N I O R C O N S U L T A N T

Limitations of use

This report has been prepared for EPA consideration as part of its role as determining authority of the Works Approval Application. The author has included observations and recommendations that represent impartial, non-expert view, based on the comments made at the conference and submission received during the submission process.

Every effort has been made to ensure the report accurately reflects the discussions, comments and contributions, made at the 20B conference on 25 February 2020. No responsibility or liability can be taken for errors or omissions, or in respect of any use of or reliance upon this report by any third party.

Glossary of acronyms

GLOSSARY OF ACRONYMS

ULAB Used Lead Acid Battery

EPA Environment Protection Authority

WA Works Approval

WAA Works Approval Application

LV Latrobe Valley

REACH Registration, Evaluation, Authorisation and Restriction of Chemicals


Executive summary and recommendations Chunxing Corporation Pty Ltd submitted a Works Approval Application (WAA) to the Environment Protection Authority (EPA) for a Used Lead Acid Battery (ULAB) recycling facility in Hazelwood North. EPA formally accepted the Application on 6 December 2019.

Following a review of the 136 submissions received, EPA determined a Section 20B Conference would be useful to further explore community views and concerns about the proposal.

The conference provided an opportunity for:

§ Chunxing to provide an overview of its ULAB recycling facility WAA

§ EPA to provide an update on the WAA and assessment process

§ Participants to hear about issues raised in submissions, ask questions of Chunxing and EPA and express their views about the proposal.

This report documents the perspectives and questions raised by conference participants. As Chair and author of this report I have included participant contributions in good faith without endorsement or judgment as to their accuracy of veracity.

The following recommendations are made in response to participant concerns as outlined at the conference and have their basis in participant comments made during the conference or in submissions. Additional detail is contained in Section 3 of this report in relation to Chair’s observations and how EPA might deliver the recommendations contained in Tables ES-1 to ES-4 below.

Table ES-1: The following general recommendations relate to actions prior to WAA determination

RECOMMENDATIONS

EPA to continue raising community awareness about where a WAA sits in the overall Approvals and Licensing process and the the criteria assessed at this stage of the the process. EPA could also consider adding a link, when applicable, about EPA’s position statement about when a health risk assessment is required https://ref.epa.vic.gov.au/business-and-industry/guidelines/licensing-and-works-approvals/when-are-human-health-risk-assessments-needed.

EPA to support consolidated questions and responses including: ▪ Facilitating the provision of responses to the list of consolidated questions at Section 2.4 of this S20B Conference

report. ▪ Encouraging the applicant to cross check its Section 22 response with the list of consolidated questions. ▪ Reviewing the responses provided by Chunxing to ensure they accurately and adequately address the outstanding

questions arising from the Conference (as reflected in this report), and seeking further information as required from Chunxing using statutory powers under Section 22 as appropriate.

▪ Consulting with other internal subject matter experts to provide EPA specific responses (as required).

▪ Publishing the consolidated responses on the Engage Victoria website.

Table ES-2: The following topic specific recommendations relate to actions prior to WAA determination

RECOMMENDATIONS

Topic 1 – Potential for human health impacts: ▪ EPA to engage a suitably qualified expert to peer review air dispersion modelling. ▪ EPA to consider whether the WAA is considered a significant WA under Section 19B(3)(a)(i) of the Environment

Protection Act requiring referral to DHHS for advice.


RECOMMENDATIONS

▪ EPA to consider referral of the WAA to its internal Environmental Health Unit for advice.

▪ EPA to consider requiring the proponent to undertake a human health risk assessment.

Topic 2 – Potential for environmental impacts from emissions and other waste by-products: ▪ EPA to confirm with DELWP the outcome of the applicant’s self-referral to DELWP regarding the need for an

Environment Effect Statement (EES) and provide details in its Works Approval Assessment Report. ▪ EPA to seek any additional information from the applicant (Chunxing) using its statutory powers to satisfy itself that the

potential for environmental impacts have been appropriately assessed ▪ Once the applicant’s responses to the Section 22 notices to supply further information has been accepted, EPA to

make the responses available on the Engage Victoria website and notify conference attendees.

Topic 3 – Suitability of proposed location ▪ EPA to determine the adequacies of the available buffers ▪ EPA to share the 20B report with the Latrobe City Council.

Topic 4 – Best practice modelling, technology and future operation (performance monitoring): ▪ EPA to consider commissioning an independent assessment to determine whether the proposed technology for

recycling ULAB in the Chunxing WAA is best practice.

▪ EPA to access information available online on Chunxing’s facility in China to assess the proposed ULAB recycling technology and performance of facility.


Table ES-3: The following topic specific recommendations relate to future actions, if a WA is granted

RECOMMENDATIONS

Topic 1 – Potential for human health impacts § EPA to consider:

- A WA condition requiring a (further or updated) human health risk assessment based on final detailed design of the facility.

- WA/Licence conditions to ensure appropriate monitoring, evaluation and reporting regimes are implemented including a consideration of health monitoring.

Topic 2 – Potential for environmental impacts from emissions and other waste by-products: EPA to consider:

▪ A WA condition requiring the applicant to submit a baseline conditions report for soil, surface and groundwater

▪ A WA condition / licence condition requiring an updated Environmental Management Plan / Environmental Management System to include a monitoring program during construction and future operation in relation to managing:

- Air emissions - Solid and liquid waste - Wastewater - Noise - Odour.

▪ A WA condition that the WA does not take effect until any permit which is required under the Planning and Environment Act 1987 has been served on the Authority by the applicant.

▪ EPA to actively promote to the community, it’s role in compliance including information about how to raise concerns about non-compliance with works approval (and future licence) conditions.

Topic 4 – Best practice modelling, technology and future operation (performance monitoring): EPA to consider requiring WA conditions for: § The installation of a Continuous Emissions Monitoring System and Continuous Operating Monitoring system § The provision of any required reports related to safe operation (such as a HAZOP study) § An updated air quality impact assessment based on final detailed design of the facility § The applicant to seek commissioning approval before the licence application, to allow start-up and testing of initial

operations and to confirm compliance with the works approval EPA to consider requiring a Licence condition for: § Proactive community consultation and the development of an engagement plan for the facility § Provision of regular information to the community on its activities and performance. In addition to appropriate licence conditions, EPA should actively promote to the community, the EPA’s role in compliance including information about how to raise concerns about non-compliance with works approval or licence conditions. EPA to raise the applicant’s awareness about its “social licence to operate” by directing it to information about EPA’s Licensed Operator Risk Assessment (LORA) for determining compliance visit frequency - which includes a category in relation to community engagement https://ref.epa.vic.gov.au/our-work/licences-and-approvals/lora EPA could consider the benefits of requiring the applicant to establish: § Community Issue and Complaints response as a condition in the WA/Licence

▪ Community Consultation Committee/Environmental Review Committee/Community Reference group or similar.


Table ES-4: The following general recommendation relates to future action regardless of whether an Approval is granted

RECOMMENDATIONS REGARDLESS OF WHETHER A WORKS APPROVAL IS GRANTED

▪ EPA to consider its role in providing improved external communications and access to information by making the: - 20B report publicly available - complete WAAAR available for this decision.


1 Introduction and background

1 . 1 S U M M A R Y O F A P P L I C A T I O N

Information about the WAA is available via the Engage Victoria website https://engage.vic.gov.au/epa-works-approvals/ulab and in the, ‘What does this Application propose’ section, the following summary is provided:

“Chunxing proposes to build and operate a ULAB recycling facility using patented secondary lead smelting technology. The proposal estimates 98% of the lead, plastic and electrolyte (sulfuric acid) in ULABs will be recycled.

The proposed project will operate 24 hours, 7 days per week, with allowance for 30 - 40 days of maintenance per year.

The proposal is scheduled as A02 (Other Waste Treatment) and I02 (Metal Melting).”

Public consultation on the WAA occurred for an extended period from the 11 December 2019 through to 7 February 2020 (normally public consultation is for 21 days) during which 136 submissions were received. Responses by Chunxing to the submissions have not yet been provided on the Engage Victoria website.

1 . 2 P U R P O S E O F T H E 2 0 B C O N F E R E N C E

Section 20B (1) of the Environment Protection Act states:

“The Authority may if it is of the opinion that a conference of persons concerned in any matter under consideration by the Authority may assist in a just resolution of the matter, invite all or any of the interested parties to a conference.”

Following a review of public submissions EPA decided to hold a Section 20B Conference to ensure it understands the views of the community regarding the WAA.

The conference was independently chaired by Kristen Stirling. The Chair made the following statements about the purpose of the conference as being an opportunity:

§ For the EPA to listen to, and better understand, the views and concerns of the community and stakeholders

§ To help explain the WAA, the assessment process and current status § To seek where possible resolution on the Application and thoughts on any possible conditions if WA is

issued.

1 . 3 P U R P O S E O F T H I S R E P O R T

This report, prepared by the Conference Chair, documents the key issues and possible solutions as raised during the Conference (and in written submissions).

The Chair has no role in making recommendations about whether the WAA should be approved or refused/rejected.

The EPA’s brief to the Chair highlighted that the conference report should:


§ Provide an independent perspective of the Conference § Highlight views, concerns and issues raised during the Conference and any relevant responses

provided by Chunxing § Identify any issues that were resolved § Make recommendations about aspects that the Chair deems as requiring scrutiny by EPA as it decides

on the WAA.

This report and any recommendations contained within it will be considered by the EPA. This may result in a further formal request to Chunxing for further information.

Separately, the EPA’s technical assessment team will complete its assessment of the Application, taking into consideration submissions, referral responses, and the 20B report. This will assess the potential impact of the works against the requirements of:

§ The Environment Protection Act

§ The state environment protection policies

§ Other policies and guidelines.

The assessment team will prepare a separate WAA Assessment Report which will be made available on the Engage Victoria website once a decision has been made.

1 . 4 C O N F E R E N C E F O R M A T

The Conference format was designed to aid the EPA’s consideration of the Chunxing ULAB recycling facility WAA and provide an opportunity for:

§ Chunxing to provide an overview of its ULAB recycling facility WAA

§ The EPA to present a summary update on the WAA and assessment processes

§ The EPA to present a summary of the issues raised in submissions

§ The community to ask questions and raise any additional matters relevant to EPA’s assessment of the WAA

§ All attendees to share and express any views, concerns and issues about Chunxing’s ULAB recycling facility WAA in a respectful, balanced and non-confrontational environment.

To meet these various aims a format was designed in consultation with both EPA and Chunxing. The agreed format resulted in allocation of time for:

§ Chunxing and EPA to make short PowerPoint presentations to set the context: - Chunxing overview of WAA and response to key themes raised in submissions - The EPA overview of WAA and assessment process and summary of submission themes

§ Discussion rounds: table-based discussions of the main submission themes of: - Potential for human health impacts - Potential for environmental impacts from emissions and other waste by-products - Suitability of proposed location - Best practice modelling, technology and future operation (performance monitoring)

§ Summary of key points raised during discussion rounds from each table.

Further context for each of these aspects is detailed in the body of the report below. A copy of the Conference Agenda is provided at Appendix 1.


1 . 5 A T T E N D E E S

The Conference was promoted via the EPA’s website and invitation sent directly to those who had made a written submission and/or had registered their interest at an earlier information session.

The Conference was well attended with 117 interested community stakeholders, 2 Chunxing representatives and 10 EPA staff. The list of registrations for the Conference is provided in Appendix 4.


2 Conference process and content The 20B Conference was formally opened by the Independent Chair, Kristen Stirling.

2 . 1 I N D E P E N D E N T C H A I R ’ S I N T R O D U C T I O N

The Chair provided an outline of her role as process manager for the 20B Conference. The Chair made the following statements about the purpose of the conference as being an opportunity:

§ For the EPA to listen to, and better understand, the views and concerns of the community and stakeholders

§ To help explain the WAA, the assessment process and current status

§ To seek where possible resolution on the Application and thoughts on any possible conditions if a WA is issued.

Emphasis was placed on the opportunity to explore opportunities, issues, concerns and perspectives about the Chunxing ULAB recycling facility WAA proposal.

The Chair explained that most conversations would be based on points from the written submissions with a focus on the frequent themes coming from a review of the submissions which were:

§ Potential for human health impacts

§ Potential for environmental impacts from emissions and other waste by-products

§ Suitability of proposed location

§ Best practice modelling, technology and future operation (performance monitoring).

Participants were advised that the process would also include opportunities to discuss other topics, participants would not be limited to the four identified as most frequently raised.

The Chair explained the 20B Conference format by walking through the Conference Agenda. The Chair also thanked Chunxing and EPA representatives who had made themselves available for a drop in style community information session in the hour prior to the conference commencing.

2 . 2 P R E S E N T A T I O N S

2 . 2 . 1 B Y C H U N X I N G

Geoff Latimer (Managing Director of Ascend Waste and Environment) provided an overview of the ULAB recycling facility project and their responses to some of the submissions to date. A copy of the PowerPoint slides presented are provided in Appendix 1.

2 . 2 . 2 B Y E N V I R O N M E N T P R O T E C T I O N A U T H O R I T Y

Stephen Adamthwaite (Manager Development Assessments at the EPA) provided context for the EPA’s role as the state’s independent environmental regulator with the objective of protecting human health and the environment from the harmful effects of pollution and waste. He outlined the WAA and assessment process. The PowerPoint slides presented by Stephen Adamthwaite are provided in Appendix 2.

W O R K S A P P R O V A L A P P L I C A T I O N 2 0 B C O N F E R E N C E R E P O R T – C H U N X I N G U S E D L E A D A C I D B A T T E R Y R E C Y C L I N G F A C I L I T Y 1 0

2 . 3 G R O U P D I S C U S S I O N S

The purpose of the group discussion component of the 20B Conference was to enable participants to:

§ Clarify any issues or concerns

§ Provide additional perspectives

§ Share suggestions for solutions to their issues.

The Chair clarified roles and responsibilities of Chunxing and the EPA representatives during the discussion rounds. Participants were advised that:

§ The EPA table hosts’ role was to support the discussion as a facilitator not as a subject matter expert

§ The Chunxing representatives’ roles during discussion rounds was to be an ‘observer’ so that they could listen to the issues raised without providing input to the discussion

§ Chunxing had indicated it is willing to provide answers to specific questions during the evening and will also provide formal clarification/responses to matters raised in the 20B Conference report after it has been provided

§ Roving Chunxing and EPA subject matter experts were available to clarify any questions that arose and that table hosts would call on those resources as needed.

The facilitator for the discussion rounds (Belinda Lowing) explained how the group discussions would proceed. For each topic theme, six position statements were presented relating to the participants position of support/non-support for each theme. For example, in relation to potential for human health impacts the position statements were:

§ Very confident based on the information available so far that health impacts associated with air emissions have been appropriately considered because

§ Quite confident based on the information available so far that health impacts associated with air emissions have been appropriately considered because

§ Neutral, this is not a concern for me either way. I am more concerned about

§ Somewhat but I’d like to know more. The kind of information that would improve my confidence about the appropriate consideration of health impacts associated with air emissions is

§ Not at all confident that the health impacts associated with air emissions have been appropriately considered. Questions that remain unanswered for me regarding potential health impacts associated with air emissions are

§ More interested in providing my views about a different topic such as

Eleven tables were set up for group discussions, six were allocated to specific statement positions and five were nominated as ‘over-flow’ to allow room for high numbers of participants aligning to a certain position.

Group discussions took place over four rounds of approximately twenty minutes each. Participants were invited to self-select to a table that best represented their position on each topic theme. During the discussion rounds it became evident that the majority of participants felt ‘not at all confident’ and therefore most of the discussion during each round was conducted at this position.

Where possible tables were facilitated by an EPA staff member as ‘table host’ whose role was to capture main discussion points on a table based template as shown in Figure 2-1 below. Tables that did not have an EPA staff member as ‘table host’ were requested to ‘self-lead’ with a table participant nominated as scribe.


Figure 2-1: Quadrant for capturing key discussion points

In a pre-briefing, the EPA table hosts were provided with a short summary of the key theme topics and a brief explanation of the key concerns provided for each theme. This theme summary is provided in Appendix 6.

Participants were also provided with individual forms to supplement their input into table-based discussions if they elected to. These forms allowed participants to identify their position on each theme topic and to also provide further information on each topic:

§ What is your main interest in, or concern about, this topic and why?

§ What action can be taken to mitigate any concerns you have?

§ What outstanding questions do you have about this topic?

The main discussion points from the group discussions and individual comments received on individual forms are presented by topic below.


2 . 3 . 1 T O P I C 1 : P O T E N T I A L F O R H U M A N H E A L T H I M P A C T S

This section contains the content of the group discussion as captured by table hosts (Table 2-1 below) and any feedback from individual forms (Table 2-2 below) in separate data tables.

The number of participants is shown for each position to reflect the variation on views within each round and across the rounds. The total number of participants for each round varies as some participants opted not to join a table based discussion for each round, preferring to complete individual notes. Where a similar comment was made by different tables the comment has been recorded once and then the number of times it was made reported in brackets at the end of the comment.

Table 2-1: Main discussion points as captured by the EPA table hosts for Topic 1

POSIT ION DISCUSSION SUB-TOPIC REASON FOR POSIT ION ACTION REQUIRED OTHER QUESTIONS

Very confident (2 participants)

▪ The facility may negatively impact human health.

▪ Proponent would not submit false data to EPA

▪ Guarantees have been made to train and protect workers

▪ Lead pollution evidence has been ignored by opponents.

▪ Has the current level of lead at the school been tested?

Quite confident (0 participants)

Neutral (0 participants)

Not very confident (20 participants)

▪ Water pollution ▪ Testing of tank water ▪ Environmental factors aiding

in increased emissions ▪ Culmination of emissions from

all industries in the area.

▪ Proximity to the facility ▪ Animals grazing on nearby

land ▪ Distance to school/children’s

play area.

▪ Monitoring of tank water for residents

▪ Reports and responses from other authorities

▪ Soil testing ▪ Research into current

emissions and potential future emissions

▪ What happens if emissions exceed those predicted? Will there be compensation?

▪ If lead levels exceed recommended health levels in in tank water, will the operation still go ahead?



▪ Emissions modelling including changes due to climatic factors.

Not at all confident (53 participants)

▪ Buffer zones (3) ▪ Safe lead-blood levels (3) ▪ Air emissions (4) ▪ Drinking water

contamination/water pollution (2)

▪ Impact of lead on community health (5)

▪ Example of how the EPA has dealt with entities who have provided false information in the past

▪ Increased traffic ▪ Movement of waste.

▪ Close distance to sensitive areas (e.g. school) (4)

▪ Other sites around the country have appropriate buffer zones

▪ Lack of confidence in proponent

▪ EPA does not specify an actual buffer zone

▪ Lead blood levels (2) ▪ Confusion around the

consistency of EPA’s policies, standards and regulations

▪ Great diversity of concerns held not just for personal safety

▪ Health department indicates no safe level of lead

▪ Economic development (3) ▪ Concern for community and

food production.

▪ Real time monitoring and transparent data (3)

▪ Update on guidelines ▪ Update air emission

standards ▪ Relocate to a non-residential

area ▪ Greater research into buffer

zones (3) ▪ Greater research into other

emission reduction technology ▪ Not building facility ▪ Strict WHS for staff on site

(blood tests).

▪ Risk of fire to surrounding grassland

▪ Does emissions modelling capture climate change?

▪ How can we trust the data around emissions?

▪ If energy costs increase, will production model change and make matters worse?

▪ What clean up would be required if there’s a catastrophic failure?

In addition to the group discussion the following individual feedback was provided as shown in Table 2-2 below.

Table 2-2: Points from participant forms for Topic 1

POSIT ION NUMBER OF RESPONSES WHAT IS YOUR MAIN INTEREST IN , OR CONCERN ABOUT, THIS TOPIC AND WHY?

Very confident 1 ▪ No response.

Somewhat confident 0

Neutral 0



Not very confident 0

Not at all confident 28 ▪ Is current level of lead provided by EPA, current or should it be revised? Is it a World Standard? ▪ Based on ‘modelled data’ from an unknown source with no clear proof of ‘best practice’ process. It’s

clear that most modern countries are doing everything possible to reduce lead and associated other chemicals in our environment. This is an ‘adder’ not ‘subtractor’ to current environmental concerns in the Valley. Site assessment of current land? What will be uncovered/released from ground at construction phase? More importantly has a site assessment been done, what is the risk management plan?

▪ All emissions are derived from unknown, un-proven data from a Chinese origin therefore actual emissions cannot be verified. This is an industry of extremely high risk factors on many levels. Even in a perfect world this design of smelting’s adds to toxic emission levels. We can’t justify emitting pollutants just because a nearby industry does – otherwise we will never have lower emissions

▪ How does this proposed plant match with Latrobe Shires Vision statements? It does not. Wrong industry, wrong site!

▪ An EES should be considered essential to ensure all community concerns are addressed. I will be extremely disappointed and distasteful of this entire process if it is not considered. Please provide guidelines to the community on why or why not an EES would be considered. I have concern regarding lead in blood. Everyone has some level of lead in their blood now, introducing another source may tip many people over the acceptable levels

▪ Review the EPA limits for lead emissions, ground (soil/water limits) and fugitive emission to USA, Canada and UK where secondary lead smelters are based (i.e. State, County or other local limits) to best scientific knowledge. Higher risk controls overseas, i.e. lead has been reclassified as a substances of very high concern in REACH in 2018 (Registration, Evaluation, Authorisation and Restriction) of chemicals regulation. This revision is only on adverse human health carcinogenic toxic to reproduction

▪ How can you judge that the emissions estimations are true without checking out the Chinese facility. Don’t blame the coronavirus for not checking out the Chinse facility. As this proposal has been ongoing for over twelve months. The virus has been ongoing for less than three months. What legacy are we going to leave our children and grandchildren in years to come?

▪ Eleven times below national background, how was this come by? Discussion indicates EPA would not be required to assess as levels would be below level

▪ How is the EPA going to verify the Chinese data? How is a 500m buffer adequate for a lead smelter? Are the EPA going to update their old standards? EPA Victoria are not equipped to review a lead smelter WAA. What specialist will the EPA employ, Professor Mark Taylor etc? An EES needs to be done, including looking at current LV health and the impacts a lead smelter will have. We have heard all the tricks that plants do to cut corners, show favourable emission data when its being tested. The EPA



can’t be there all the time. I don’t trust that they will do the right thing 24/7. Best practice around the world plus Australia needs to be looked at by the EPA (or better consultants). Dr Lakshmann and Geoff Latimer haven’t instilled faith. No mention of remediating the site and no mention of cleaning up the site and buffer when the company is finished. What is the EPA’s standard for lead emissions and fugitive dust? The proponents 300 times under needs to be locked in. I believe lead in the air can’t be reported in real time. The proponent is giving the impression it can. What toxins can be detected real time. Would the school kids, teachers, surrounding community be tested for lead in their blood before the plant is commissioned as a base line and then periodically after that (the workers and their families)? EPA standards need to be reviewed, they are outdated for e.g. allowable emissions for lead

▪ Beef and dairy farms within a few kms of the proposed site – how can you guarantee live stock will not become contaminated! With the flow on impact to peoples dinner plates etc. This includes community vegetable gardens, children’s play equipment, swimming pools, clothes drying on the line – all poses a risk of ingestion. Risk/impact on children’s development, vulnerable community members such as unborn babies, infants, children, aged and our local aboriginal community

▪ Figures given are based on Chinese statistics of which we are very sceptical. WHO has stated zero level of lead is the only safe figure. If LV has been Health Innovation Zone, how can this possibly even be considered? The school will be impacted. All children and staff will be affected. European Chemicals Agency upgraded lead and cadmium from the initial listing in hazardous material register REACH (listed 2012) to substances of very serious concern. If lead enters the body, once in the body it cannot be expelled

▪ There seems to be no change in provided information ▪ What are the consequences of a catastrophic failure of the plant? The works application discuss failures

which are containable. I am referring to those that aren’t. There are case studies where furnaces like those used at this facility have exploded in an uncontrollable manner, i.e. Gepps cross foundry explosion in July 2018. Mitigation based on a bath operation (i.e. can be shut down within 15 minutes) is not acceptable. A failure of such magnitude means you lose control of the plant and emissions of lead directly into the environment are high, continuous and uncontrollable

▪ Lack of buffer zone to agricultural land and other businesses. Health issues in the LV already concerning levels and proposed plant will contribute to further decline. Exposure to toxic emissions is the major concern as I have a young family which I don’t want health to suffer as a result of where they live. Relocated site to a more suitable location with greater buffer zones

▪ Independent audit of data – this should be conducted as the validity of the data remains questionable. Question over the monitoring of air levels – and what repercussions are there for the company i.e. fines, jail. Is there potential for this plant to expand and what community views come into play and what is heard. Can the company guarantee everyone’s health in this area and are they willing to be responsible and take ownership of health issues (accountability) – what will happen to our lead levels and how will



this be monitored. Questions over transparency of information and data given – EPA needed further details regarding ‘in case of emergencies’ – in a meeting the proponent disregarded this question of ‘emergency’ and said there will be none – however EPA requires this

▪ Validity of data from Chinese plant. Unknown future expansion – what additional health impacts this might have. Ongoing monitoring will be carried out by the proponent – conflict of interest, could the monitoring be doctored? Limited available information about the Chinese plant available (other than what the proponents provided). Lack of accountability of who is responsible if something goes wrong, both financially and through the judicial system.

2 . 3 . 2 T O P I C 2 : P O T E N T I A L F O R E N V I R O N M E N T A L I M P A C T S F R O M E M I S S I O N S A N D O T H E R W A S T E B Y - P R O D U C T S

This section contains the content of the group discussion as captured by table hosts (Table 2-3 below) and any feedback from individual forms (Table 2-4 below) in separate data tables.

Table 2-3: Main discussion points as captured by the EPA table host for Topic 2


Very confident (1 participant)

▪ Very confident that the environmental impacts have been considered with the information provided.

▪ Confident that lead emissions will not create environmental impacts

▪ Residential tank water, will not be impacted by facility because water/stormwater will be captured on site and used on site, only other water leaving the site will be sewage

▪ Wetlands were constructed to capture pollutants from site.

▪ How will rain water be held on site?

▪ Is there potential to investigate other travel options to avoid the use of diesel?

▪ Can renewable energy be used instead of gas?







▪ Buffer zones (4) ▪ Onsite waste and by product

management practices (9) ▪ Waterway contamination

management (4) ▪ Impacts on sensitive areas

(residents/primary school/wetlands) (3)

▪ Cumulative impacts on agriculture and native animals and nearby industries (7)

▪ Food chain concerns (2) ▪ Emissions management (9) ▪ Contamination of product

(zinc-sulfate) (with lead) ▪ Health: asthmatic, repository

issues from pollution ▪ Waste transport/product

transport.

▪ Potential impacts on human health (6)

▪ Proximity to wetlands/farmland/flood zone and other waterways (3)

▪ Uncertainty around the site coping with adverse environmental conditions (4)

▪ Uncertainty around environmental impacts of lead (2)

▪ Uncertainty around waste management practices (6)

▪ Impact on the local food chain

▪ Land zoning ▪ What been told in meetings

is different to what’s in WAA ▪ Doesn’t fit with future

direction of the Valley (2) ▪ Impact on the value of

agriculture (3) ▪ Distrust in

owners/companies (6) ▪ There is no modelling ▪ Impact on liveability and

property values.

▪ More information – independent modelling and examples of how emission impact environment (9)

▪ More water monitoring (2) ▪ More publicly available data ▪ No discharge or offsite runoff

and more storage capacity (2)

▪ Breakdown of each individual emission produced and what level it is produced at

▪ Come up with realistic assessments – not modelling which is not necessarily indicative

▪ Risk management process for worst case scenario contamination (2)

▪ Increased EPA standards ▪ Evidence of procession in

place to protect local wetlands and rivers (i.e. stop product entering them)

▪ CO2 in WAA need to be addressed according to Climate Change Act 2017

▪ Need an EES (4)

▪ Monitoring before/during/after – what happens when things go bad?

▪ Human health: odour issues – will this cause problem. Need to find ways to further minimise this or eliminate (2)

▪ What funding is being offered to these kinds of corporations to build in LV?

▪ Why are job prospects/job availability in LV valued more than impacts to environment and human health from pollution?

▪ Need an environmental effects study

▪ Area is starting to turn around, can EPA standards be reviewed? Comparable to Western Australia and New South Wales

▪ How is EPA verifying the data? Needs to be a peer review process

▪ What is put around the site to stop run off and how long will it last before being



▪ Need to have 5km buffer zone

▪ Relocate position of lead recycling plant

▪ Reduce the distance of travel, from source both directions

replaced – what happens if it fails?

▪ Can we hear from residents around the existing facility in New South Wales?

▪ How does the application meet the liveability strategy?



POSIT ION WHAT IS YOUR MAIN INTEREST IN , OR CONCERN ABOUT, THIS TOPIC AND WHY?


Somewhat confident (1 participant)




▪ Lead has different levels of bioavailability in water/ground water. Excluding stock emissions – fugitive emissions, water/storm water excess may leave the site. The risk of any escape is it is persistent, bio-accumulative and toxic. Have we modelled these potential discharges and where these will mostly end up. Persistence (lead) means it will not degrade in the environment – ‘forever’ materials are a global concern when toxic and bio-accumulative

▪ What and where are the heavy metal and waste going to be disposed? Is burning the waste the safest way of disposal? ▪ We know lead long term effects are not truly known and will not be known for years. They say it’s safe but is it? E.g. foam firefighting, asbestos

was bees knees but now not. Site too close to community. Long-term effect on cattle, unknown. Cattle around Richmond airbase NSW now recognised toxic to animals. The site seems to be in the wrong area, why truck these batteries through Melbourne (more risk of accidents)

▪ Has site been EES assessed? ▪ An ‘EES’ should be conducted here, a toxic emitter built on already very toxic site has to have an EES done, this is the most basic of requests.

Just to ‘expand’ production the Wagga Wagga plant was required to do one before a licence was issued. Zero faith in the plant being the



correct design, smelting is on the way out! Zero faith that it will be maintained to correct levels, as cost (greed) always gives way maintenance – so poisoned landscapes and people. The original 33 acre site would in the days gone by warranted a 500m buffer ‘for some industries’. Now present day the 33 acres has been subdivided with each small block retaining the 500m buffer! The proponent says that 80% of emissions will fall on the 500m buffer and 20% beyond that. The public transfer station is already encompassed by the 500m buffer! In addition 20% flows predominantly downwind to the school and Hazelwood North Community. Wagga Wagga plant had a buffer set by the NSW EPA at 5km, why are we presented with 500m? Answer! The Victorian EPA does not have a buffer distance! The 500m buffer is de-rived from the old 1 in 2 zoning

▪ The state of the site – environmental audit wasn’t signed off on (EPA report 2008) shouldn’t be built on – or at least another report done as part of an EES. Don’t trust the company to undertake maintenance cleaning, worker health, accurate and honest data collecting that would help to keep pollutants from the environment. Environment – The emissions and fugitive dust and what components make up this i.e. lead arsenic, dioxins and furans, antimony, etc. How will people drink their tank water when its contaminated? Eat their vegetables? Is the proponent going to put money aside to clean up the site when they are finished? Off the subject: why is the lead going back overseas and not staying in Australia? We don’t have faith in the proponent, that they will maintain plant and keep things clean so the environment is kept safe. If surrounding land becomes contaminated – how does this get remediated if it’s a few hundred hectares of adjacent farmland? Does he proponent pay for this? Are they insured for this? – Is anyone thinking of the effects on native species which will be picking up lead, and the other toxins from the water, land, food – and what this does to their fertility, life span, etc. An EES will find out if there is an endangered or vulnerable species in the nearby creek, etc

▪ Properties in the area will be impacted as prevailing winds blow predominately W/SW. These winds blow this way most of the year and we believe out paddocks, livestock and tank water will all be affected. Proponent did not take this into account. We are very concerned with noise pollution, as it will be running 24/7, plus odours emitted from smelter

▪ Again, there has been no change in information provided ▪ Control of waste/ by products onsite lack of controlling and potential to be emitted into environment. How site runoff will be continues onsite and

the lack of site capacity to treat and dispose of water in high rainfall events. Lack of buffer zone to waterways and food zone ▪ Buffer zones – lead will travel due to wind – travel to pasture, waterways, water tanks, clothing, it is 16kg of lead travelling in the community. A

lot are farming areas – food chain. Accountability of company of exceeding their promises ▪ Unsure how the pollutants affect livestock. Our own research suggests it is very negative in regard to bee’s which affects part of our farming

plan. Accumulative build-up of heavy metals over time on pasture.

2 . 3 . 3 T O P I C 3 : S U I T A B I L I T Y O F P R O P O S E D L O C A T I O N

This section contains the content of the group discussion as captured by EPA table hosts (Table 2-5 below) and any feedback from individual forms (Table 2-6 below) in separate data tables.




Very confident (3 participants)

▪ Community members have raised concern about the LV as an appropriate location.

▪ There is currently no oversupply of capacity in processing used lead acid batteries.

▪ This plant has the capacity to process other materials (changing the scope of the current submission).

▪ Scope of plant regarding exports of other recycling products (lead, plastic, slurry)

▪ Will the approval have conditions regarding operational maintenance, operated with redundancy in place. Who is inspecting maintenance regimes?




▪ Proximity to schools and other businesses, residences and farmland.

▪ It is too close to schools, residences, business and farmland

▪ Land is already contaminated at this site

▪ Concerns about how far emissions will travel (2)

▪ Concern regarding property values.

▪ Find another location – study of neighbouring/local property values before and after construction of similar ULAB plants in Australia.

▪ Has the applicant studied and taken in to account local weather patterns, especially wind?

▪ How can you prove any lead emitted will land on the facility property?

▪ Why not build in the centre of Australia?

▪ Should the buffer zone be widened/increased – If so, is this an appropriate location?

▪ If employees of ULAB have to be tested every three months, what about the people who live/work/visit places in close proximity to



the facility, will they have to be tested too?

▪ Technology and standards (3).

Not at all confident (60-70 participants)

▪ Proximity to sensitive receptors (4)

▪ Concerns over land contamination issues (4)

▪ Transport and traffic concerns (3)

▪ Pollution, emissions and contamination (3)

▪ Concerns about the size of the buffer zone (2)

▪ Concerns about decreasing property values (2)

▪ Issues with the zoning (2) ▪ Resident and worker health

and safety (4) ▪ Latrobe Valley residents

want to change image of the area and project a healthy image (4)

▪ EPA regulations outdated (2) ▪ Over supply – already

established industry in NSW that can adequately manage current and further amounts of lead.

▪ Proximity to sensitive receptors (2)

▪ Contaminated Land (5) ▪ Transport and traffic

concerns (6) ▪ Buffer Zone ▪ Concern about property

value (2) ▪ Resident and Worker Health

and Safety (2) ▪ Concern about the projected

image and reputation of the LV (4)

▪ Track record of any industry having a malfunction relying on EPA giving notice is not good enough – in the meantime people/businesses have been affected

▪ Environmental and auditing (3)

▪ Lead acid dying technology that still needs to be recycled but most likely oversupply

▪ Will set a precedent for other Cat. Two industries.

▪ Land should be decontaminated completely before they start – the land contamination will only increase

▪ Use different location (7) ▪ Not needed / Don’t build it

(2) ▪ Increase the buffer distance

(2) ▪ Zoning is a legacy issue and

should be changed (2) ▪ Requirement to

fund/contribute to local community (give something back) (mixed views on this)

▪ Transparency and further investigation (2)

▪ Redo the audit on the site ▪ Requires State of the art

technology with trustworthy managers (2)

▪ How are they going to build the plant safely when the soil gets disturbed and the ground is already contaminated? How will they control this?

▪ Should we build a hazardous industry on an identified fault line?

▪ Where is the waste going and how will it get there?

▪ Where is the consideration to impacts on roads in/out freeway?

▪ Why this particular site and not elsewhere?

▪ Is there a buffer zone required for this type of industry?

▪ What happens if property values decrease?

▪ Will the community see the benefits of the employment?

▪ Does this open LV up to further recycling?

▪ Has demand been considered in application?

▪ Why isn’t lead recycling in China?

▪ Why is the EPA even considering the proposal?



▪ Shouldn’t lead automatically be considered as not appropriate?

▪ Why does Government keep approving projects when current projects can’t be properly managed?

▪ Should it be approved by exception? If we need it then yes, but if we don’t, why subject the community to it?

▪ If council own land who does planning permit if it is a conflict of interest?

2 . 3 . 4 T O P I C 4 : B E S T P R A C T I C E M O D E L L I N G , T E C H N O L O G Y A N D F U T U R E O P E R A T I O N ( P E R F O R M A N C E M O N I T O R I N G )

This section contains the content of the group discussion as captured by EPA table hosts Table 2-6 below and any feedback from individual forms Table 2-7 below in separate data tables.





▪ Concerns with how emissions modelling has been done

▪ How trustworthy is the data from China.

▪ Using Chinese plant as a reference makes sense

▪ Bushfire impact is irrelevant to air quality considerations re proposal

▪ Water resource is not an issue.

▪ Independent forensic audit of plant and processes on a regular basis.

▪ Reliability refurbishment of parts? Modelling needs to be done

▪ Technology of proponent – can they produce what they say they can regarding emissions. Best practice for industry?

▪ Bushfire impact, can fire move pollutants from site to surrounding area.



Not very confident (4 participant)

▪ Might be a newer technology but its not proven in Australia

▪ Why is this technology only used in China.

▪ No confidence in reference data from China given known nature of Chinese government.

▪ Reference plant in country other than China to base analysis off.

▪ With recent bushfires, smoke caused solar panels/sensors to stop working. Will bushfire smoke cause monitoring sensors to stop working?

▪ Will the continuous monitoring be conducted by a body independent of government and the facility owner

▪ Why can’t batteries be exported to China?

▪ In it’s final state, will the lead be liquid or solid – where will it go, how will it be



transported? Is it going to be a 24 hour operation?

▪ Have there been studies into impacts of traffic in local area from transport to/from the facility? Will trucks/cars emissions from this also be counted in cumulative pollution impacts?


▪ Reliability of data (4) ▪ Proximity to sensitive

receptors ▪ Distrust in proponent (2) ▪ Land contamination issues

(2) ▪ Transport and traffic

concerns (1) ▪ Future of the use of lead (1) ▪ Pollution, emissions and

contamination (1) ▪ Concerns about the size of

the buffer zone (1) ▪ Concerns about decreasing

property values (1) ▪ Issues with the zoning ▪ Resident and worker health

and safety (2) ▪ The recyclability of lead (2) ▪ Volume of water use and

wastewater management? ▪ Better practices: more

current models ▪ Plant capacity – output.

▪ Concern about the projected image and reputation of the Latrobe Valley (2)

▪ General health concerns (4) ▪ Proximity to sensitive

receptors (2) ▪ Poor community

conultantion (4) ▪ It is a very intrusive site ▪ Devaluation of house and

land ▪ Area already sensitive-why

add to it? ▪ Feel that it is already a ‘done

deal’ and process is just a formality

▪ Not able to verify, how do you know the method is right? How do you know the steps reflect the part?

▪ There are other alternative ways to recycle lead

▪ Safety issues in transporting lead

▪ Additional burden on current resources, e.g. gas.

▪ Independent monitoring/reporting and needs to be included as a condition (7)

▪ Real time data – accurate information

▪ Modelling systems needs to be reviewed again

▪ Proposal could be considered if it was ‘zero emissions’

▪ Blood testing of school students prior to any activity

▪ Community consultant group (independent) should be setup

▪ EES needed ▪ EPA needs to look world-

wide at technologies ▪ Community concerns should

be the deciding vote ▪ Licence must adhere to

WAA limits ▪ Locals in the management

team: process manager,

▪ Why are they using old technology?

▪ How long is site being used for this?

▪ How will they rehabilitate the land/area?

▪ Where does accountability of proponent come into it?

▪ What is the level of financial assurance required?

▪ How will emissions be assessed and monitored?

▪ Where will the waste by-products go? What action will occur if emissions go above claims?

▪ Why wasn’t there been better community engagement?

▪ Where are the monitors going to be placed?

▪ Are waterways going to be monitored?

▪ Should EPA reclassify lead? ▪ Is shut down for

maintenance adequate?



environment manager and operations manager

▪ Alternate location – more suitable that has no impact on community, people, livestock (3)

▪ Bench mark against other facilities.





▪ No response.

Somewhat confident (1 participant)

▪ Really want to know whether the specifications of the Chinese plant that is the model for the WAA are consistent with what actually occurs. Not confident in the accuracy or comprehensiveness of Chinese reporting.




▪ Real time monitoring. Air quality alerts seemed delayed when bushfire smoke around. Primary school needs to have a monitor on site. Monitor around the 2km buffer zone at wet lands, Eel hole, water hole, Kenot Lake. Not sure about technologies sorry. Can we use our knowledge rather than overseas?

▪ Best practice? Based on one plant in China? – Hazelwood is not same construction adding/changing design? Based on ‘Wagga’ plant – that is self-explanatory of ‘what does not work’ over time. Why other countries not adopting?

▪ EC successfully funded and lead a project on solvent lead technology in 2017-2019 that could be scaled up and used across 37 countries in Europe. EC states it has 60 EOI’s for the technology and 12 licences pending. This is close to zero emission low/little waste, very low GHG. It fits EC future strategies for batteries recycling

▪ Where is the data for the best practice coming from? The Chinese company?



▪ Very concerned regarding the frequency and accuracy transparency of monitoring. How can they measure the lead output. EPA can’t even measure that. What evidence is there? The water runoff is going into the wetlands. Kernot hall lake is stocked with trout before each school holidays and we are concerned about the possibility of contamination to fish

▪ What is the integrity and reliability of the applicant data presented? (From the Chinese plants)? Is this data investigated and checked by Australian representatives?

▪ No peer-review of assumptions, modelling or provided data. As it stands there appears to be no capacity to test the veracity of the data ▪ Is it best practice technology? What assumptions have been made in the pollutants monitoring and are they realistic? Concerns that wind

conditions are not representive of site conditions as weather data away from proposed site. Shouldn’t be importing waste from overseas to process locally

▪ Third party organisation needs to visit Chinese plant and formulate their own data to ensure the data is reliable (concerns of monitoring as papermill pollutes the valley too) Wagga plant has capacity and there is no need for this plant. What happens if there is an expansion – more health risks and more environmental impacts as there will be higher emissions and lead. Monitoring systems on private property at the expense of the company – so we can access out data, our land and in our area – for our health

▪ Very limited data provided/accessible other than what proponent provided. Vague mention of future expansion which would leave the door open for worse emissions/pollutions. Due to Chinese internet sensory – it is very hard to research their current plant.


2 . 4 C O N S O L I D A T E D L I S T O F Q U E S T I O N S

Conference participants were encouraged to write down any questions they had on cards provided on each table. These questions were collated at the end of night and have been recorded in Table 2-8.

These questions have been provided to EPA and Chunxing who will provide responses in the WAA report and decision summary.

The questions have been attributed to topics where possible.

Table 2-8: Consolidated list of outstanding questions

CATEGORY QUESTION/COMMENT

Human Health Impacts

▪ Chunxing make no mention of the residual lead dust which will invariably fall on the asphalt roads, buildings, employee’s shoes etc. There is no safe level of lead (ref: WHO). There is no mention of sweeping, there is a lack of adequate buffer zone

▪ How can we trust Chunxing claims of low levels and promised the effects to human health?

▪ What is the air quality standard for lead set SO LONG AGO (1998)? ▪ We need to reset these standards to better protect human health. We need lower levels

for Chunxing to abide by!!

▪ What PPE will be supplied to minimise risk of contamination of workers?

▪ Are all employees to have a blood test before they start work to establish current lead levels in the blood stream?

▪ Are regular blood tests to be administered?

▪ If any worker shows a positive reading, what level of compensation is to be granted and for how long it will last?

▪ What health organisation is being engaged by EPA for the health risks? - Objections from health workers/hospital workers have identified the current Valley

health & Patients they see – this needs to be considered.

▪ Has/will the EPA assess other similar industrial enterprises in Aust e.g. Wagga Wagga NSW (ULAB) - and RIS as part of the WAA?

▪ Will the EPA call for input from the Latrobe Valley Health Assembly, considering that this is proposed for the Latrobe Health Innovation zone?

▪ How will exposure to workers, transferral of toxins to their families from their clothes, skin etc, be minimised? – Washing of clothes with exposure to lead and other toxins.

▪ Lead employee monitoring – will the results of employee (overall) be available? How? ▪ If “no” – why not?

▪ Human health impacts from emissions ▪ Suitability of proposed location.

▪ How will human health and the risk to, and existing health of Latrobe Valley be addressed and studied thoroughly by lead health experts?

▪ The health here is vulnerable and specific, often the worst in the state, for various cancers and illnesses.

▪ What gives the EPA the right to have the final say on the future lives of Hazelwood North people’s lives.

▪ The wider community needs to be made aware i.e. Morewell Township.



▪ The lead smelter plant will have an effect on them as well. No safe level of lead exposure.

▪ Has the Hazelwood north primary school been taken into consideration, as this is less than 2kms (as crows flys)

▪ 140 students attend the school and is growing all the time ▪ Putting young children in danger for next generations to come.

Environmental Impacts

▪ How current are the EPA standards? ▪ I believe they have not been updated since 1998. This is unacceptable.

▪ Big on comparing large vs small emissions level for various categories ▪ More interested in how they arrive at the small emissions level ▪ Where is the real data/verifiable used to feed the projection models?

▪ What guarantee does the La Trobe Valley have that the ULAB plant will adhere to the EPA guidelines?

▪ To EPA ▪ The design limit 6, the EPA for lead emissions – when was this formulated? ▪ Is this our best (2020) scientific understanding of safe design limits?

▪ What safety precautions are being used to stop lead pollution to the environment, soil, water and air?

▪ EPA standards are way behind US standards.

▪ Where will the electrolyte water waste go?

▪ Why after Australia had banned lead for paint, petrol etc, would EPA risk a recycled lead acid battery plant?

▪ Even if the contamination falls on the site (don’t believe), it is there FOREVER.

▪ Why is the EPA standard set @ 3,00 (ng/m) (so high) and this new facility will be nearly at Zero?

▪ Is the EPA approval that last hurdle for application to be successful?

▪ Will EPA be reaching out to the best research authorities in AUS + around the world about lead? Including WHO.

▪ Will the Chunxing plant be a licenced premise, regulated by EPA?

▪ What is the EPA’s licenced limit of emissions for the facility during start up and running off the plant?

▪ Will the plant be self-regulated for emissions?

▪ How does this all fit in the Latrobe Health Innovation Zone?

▪ What is EPA’s responsibility to the Health Innovation zone, considering they hold a position on the zone?

▪ The WAA from the company states an annual mass emission of lead of 16kg. How does this square with their stated level of for below background lead level in the environment?

▪ Current site – what environmental hazards are there on the site and what will need to be done prior to construction?

▪ Possibility of lead getting into tank water via roof rain washing in?

▪ Ongoing monitoring to reassure us of the emissions that lead has not contaminated our water supply?

▪ How is the EPA going to measure lead coming from stack or just rely on Chunxing figures?



▪ The question regarding failure emissions in the China plant was not answered.

▪ Can we have an environmental effects study (EES)?

▪ How can a “prediction” be made on emissions if the lead smelter hasn’t been built yet?

▪ Emissions based on scaling China plant, two times below natural background, how was this come by?

▪ Given talk indicates EPA not required to assess.

▪ Why has there not been an Environmental effects statement.

▪ How come, why isn’t there an Environmental study done?

▪ EPA past records have failed many communities, how can we be assured this won’t happen here?

▪ Can the EPA insist that an EES is carried out prior to this WAA being approved?

▪ Why is there not an EES being considered? I believe this is a must.

▪ Chunxing are here purely to exploit “out dated” zoning, they will not protect us or the environment over profits.

▪ East of Melbourne is the best farming land in Victoria we have. We are always losing that land to developers.

Suitability of proposed location

▪ No consideration given for public access to the waste transfer station, which is located within 500mtr of the stack.

▪ Why is there a very little in the way of a buffer zone?

▪ If current facilities (NSW Wagga) can handle Australia’s capacity to recycle batteries (Lead batteries), why should we risk approving another smelter at all?

▪ Buffer zone seems too close for me, has the spread of high winds, been taken into account?

▪ Why use the Latrobe Valley for this Third World Enterprise? ▪ Aren’t we polluted enough now?

▪ Why is the factory required, if there is currently capacity to process the waste within industry?

▪ If the “pollution” is “estimated” to be so low!? Why is this facility restricted to an already contaminated site?

▪ Pondage had to be drained because of possible earthquake. How safe would this plant be for that?

▪ If everything is contained why do they need a “wetland” pond?

▪ The site for the proposed plant is totally inappropriate.

▪ What is the EPA’s opinion on the Latrobe city’s transfer station, being under the 500m buffer?

▪ How have the EPA tested the veracity of the modelling of planned and fugitive emissions?

▪ Location is too risky: - School - Farms - Workers.

Best practice modelling,

▪ Emissions modelling – no evidence of science in the modelling you should provide models of how the plant is expected to operate in Australia, not using the reference plant.



technology and future operation (performance monitoring)

▪ To Chunxing ▪ Have you completed a bottom up design model for emissions based on the Australian

design plant (not China reference plant)?

▪ Where will the leftovers go from the batteries that are not recyclable? ▪ Could you explain the patented secondary lead smelting technology?

▪ Chunxing WAA was so light on and did not contain real modelling on emissions. ▪ Why should we trust a simplistic 16 times smaller, when we haven’t seen or heard real

data for this proposed plant?

▪ Is a third-party company or regulator used to control and calibrate the emissions monitoring equipment?

▪ Will licencing be requiring standards of operation of the plant, so that backup equipment is always available when the plant operates?

▪ What design standard will it follow?

▪ Natural gas and oxygen are explosive together but controlled by maintaining steady combustion. This combustion can become unstable causing abnormal operation with potential failure of emission control equipment and emissions far greater than what is quoted.

▪ What analytical method will be used to constantly monitor lead?

▪ Licence: Source of batteries world-wide ▪ Under their proposed licence, can they source batteries from other countries?

▪ What assumptions have been made in the pollution modelling and are they realistic?

▪ How is the data “modelled’?

▪ Has an independent (not on the payroll of Chunxing) assessed the validity of the data?

▪ Ongoing monitoring plus reporting of emissions: - Continuous? - Will there be a community consultative committee? - What are the EPA levels?

▪ Ongoing monitoring and reporting of emissions from the ULAB.

▪ What are the maximum emission levels proposed and ongoing monitoring requirements from the EPA?

▪ Who is responsible for monitoring factory outputs – EPA? Chunxing? And where is monitoring station to be established?

▪ Nearest EPA monitoring station – where is it in comparison to plant?

▪ If abnormal emissions are detected, what would be the reporting requirements for the public etc?

▪ Is monitoring up to date 24/7 or a repeat of a test done a week prior?

▪ How many monitoring stations do EPA propose to set up? Where?

▪ If such monitoring stations are set up, what are the levels to be set?

▪ If these levels are breached, what the consequences?

▪ EPA level for lead, is it Australia wide or state based?

▪ The Victorian EPA need to use the same guidelines as the NSW EPA.



▪ Lead impacts: - Many pathways - Many receptors.

▪ Limiting source of batteries to Australia.

▪ How is the EPA going to ensure that data that Chunxing are providing is correct? ▪ If this is not the EPA role, who verifies this? Can an expert independent consultant check

this?

▪ Where has the emission data come from? Is this based on the current plant in China? The one proposed to be built here, is it an exact copy of that one?

▪ Fire S.O.P Emergency evacuation plan. What is your fire (emergency) plan?

▪ Does data get independently audited site assessment – before construction?

▪ What are the “emissions” included in the graph? ▪ Does the graph total emissions get averaged out? ▪ Is the monitoring of plant regular or only when people get concerned?

▪ 1/16 of what production load in China plant?!

▪ Are we now being told that there are safe levels for lead? ▪ We thought lead levels were cumulative and there was no safe levels?

▪ Is the data used in the “modelling” being verified by an independent party? ▪ Chunxing only have one “paid” company working in their interests.

Other ▪ What economic benefit would the plant give to the community and what are the negative impacts of said plant?

▪ Why are they comparing data to hydrome, as they are not smelting due to high gas prices?

▪ Response to the first section 20B request for information when will that become publicly available?

▪ What benefit will there be if after a decade we find out there is a problem with allowing this (ULAB) plant?

▪ Is it going to be more problem than benefit?

▪ I want recycling! But why are the good bits, going overseas and we get more toxic waste?

▪ Having some direct interactions with Chinese businesses, I believe they DO NOT make acceptable working partners.

▪ If EPA approves this lead plant, can the community sue EPA if the emissions quoted in the works approval go above predicated levels?

▪ Chunxing stated early in the process that if they didn’t have community support, they wouldn’t go ahead with the proposal

▪ “The room has spoken”

▪ Has there been a third-party independent organisation to revise data figures and generate their own to ensure there has been zero alterations and is true? (as data is from the existing China plant and divided by 16).

▪ Who will be made accountable for any plant malfunctions/breakdowns, which inadvertently emits dangerous emissions?

▪ Will there be financial/judicial repercussions?



▪ If the plant was to go ahead – will there be 100% ownership on this company, including large fines and jail time?

▪ Monitoring of data, if the plant was to go ahead, should be independently monitored 24/7 and the company should have to give figures more than once a year – and this should be publicly available 24/7.

▪ What site remedial requirements, if any will be required of the applicant?

▪ Can we get a copy of tonight’s presentations?

▪ Are the monies put aside for clean up after the plant shuts down?

▪ As there is the coronavirus problem, can we delay a decision till we can send someone to China to check out their facilities?

▪ Are other concerns going to be addressed tonight?

▪ Cumulative impact on rainwater tanks. The washing off roofs of lead. Daily accumulation of lead then washed into our drinking water.

▪ In time rainwater tanks will have harmful levels of lead.

▪ There are absolutely no benefit to our community in having a lead smelter, only negatives. Can EPA please respond?

▪ Is it true the Latrobe Valley paper mill and power station just pay regular fines to EPA, when emissions are over the limit?

▪ Is this what we can expect from lead smelter if approved?

▪ What odour will be emitted 24hrs a day?

▪ If the process outlined at the 20B conference is “flawed” – will it be conducted again, with more facilitators?

▪ EPA – Who has responded and what are their responses? How come the public don’t know? What technical information was being sought?

▪ Without seeing the Chinese battery facility, how can you believe their estimations of the emissions?

▪ How close is the Chinese facility to the general population?

▪ Independent agent to travel to China but coronavirus has put a stop on this – does this stop a decision being made on the approval, until this has been performed?

▪ Who funds the fact-finding mission to China?

▪ What is the time plan for the visit to China to check?

▪ After the 20B conference, when was the visit to China planned?

▪ Had time to visit China prior to coronavirus outbreak.

▪ Has anyone from EPA and government been to the Chinese battery facility? If not, why not?

▪ How was notification for this meeting made: - Newspaper? - Radio?

▪ Not all submissions were responded to or acknowledged.

▪ Why is the Laverton plant not currently operating?

▪ Is the China plant emission reports available on the internet?



▪ Unlimited time: - Assessing application - Clock stops – requesting further information

▪ How long do they have to provide this?

▪ In the past, can you provide an example of how you have dealt with organisations that have provided information that turned out to be untrue?

▪ Not at all confident that the safe levels for the organisations set by the EPA, are appropriate considering possible health impacts.

▪ How did the EPA come to the set levels they did? When were these levels set? ▪ Has research into acceptable levels been carried out by anyone since these levels were

set?

▪ Explain to me how the EPA justifies a 500m buffer, when Wagga Wagga has 5kms. The worker said Wagga’s carpark is 500m away!

▪ How is the EPA going to prove the Chinese data.

▪ Does the clock stop again, until an EPA representative can get to China?

▪ Will the corporation’s previous behaviour be taken into consideration? I refer to its operation at Stockton NSW, where the environmental consequences are still being dealt with?

▪ Trust in data – independent information needed.

Approvals process ▪ We have just heard on the grapevine that the planning minister has rejected the need for a EES. It only took <2 weeks to decide

▪ What criteria did he/she apply? ▪ Where is the transparency to the public?

▪ Who owns the land?

▪ If Latrobe city owns the land, are they able to issue the permit to build?

▪ In view of the high toxicity of lead, why is there no requirement for an EES/EIS document?

▪ Does the changes to the EP Act scheduled for June 2020, generate any haste to wrap up the WAA in the applicant’s favour?

▪ If this plant is approved, what would be the situation with further companies applying for similar plants producing potential pollutants?

▪ Once one application is approved, would it not open the door for further applications? ▪ The cumulative effects would be devastating.

▪ Who will pay the next $20million to rehabilitate the site of the proposal is approved?

▪ Can Chunxing keep re-applying over and over if continuously knocked back? Years?

▪ Does anyone from EPA live in Hazelwood North, who ticks box on lead smelter to go ahead?

▪ Will the application approval be put off until the China visit?

▪ Why has the planning minister NOT requested Chunxing to write an ESS?

▪ Why has the planning minister NOT been transparent with this seriously worrying development – of an ESS not being needed?

▪ Why is LV being used as a potential dumping ground again?



▪ The EPA require the applicant to sign a fit and proper person form. The applicant is the company, there are two directors and there is one form. Will you require the second director to provide form?

▪ Who are the EPA seeking specialist (expert) advise from in relation to lead impacts on environment/health/safety? And suitable locations – if any!

2 . 5 N E X T S T E P S

EPA will use the 20B Conference report, submissions and referral responses and work through its detailed assessment. EPA may require further information from the applicant at any time during the process and will make that request and response publicly available.


3 Chair’s observations and recommendations

3 . 1 O B S E R V A T I O N S

Although the 20B process was designed to further explore matters raised in submissions, it was deliberately not limited to matters raised in submissions. The reason for this was to allow for those participants who perhaps had not been previously involved to share their perspectives for the first time. To facilitate identification of new concerns participants were provided with multiple opportunities to raise and discuss additional issues of concern. However after reviewing participant inputs to the 20B Conference and comparing these to the matters raised in written submissions, it is evident that the 20B Conference has not resulted in any significantly new matters being raised for Chunxing’s or EPA’s consideration.

The 20B Conference generated numerous questions across a variety of topics. Some of these questions highlight a lack of awareness of the contents and assessment process of the WAA. Other questions demonstrate detailed awareness of the Chunxing WAA proposal and raised specific concerns regarding the lack of independently verified data used to estimate air emissions and the need to complete an Environment Effects Statement (EES).

From review of submissions and the discussion during the 20B Conference it is evident that there is minimal support for the ULAB recycling facility proposed for Hazelwood North. A small (less than three) number of conference participants identified that they were confident that the potential health and environmental impacts had been appropriately considered by the applicant. This sentiment was reflected in statements such as:

▪ Residential tank water will not be impacted by facility because water/stormwater will be captured on site and used on site, only other water leaving the site will be sewage

▪ That wetlands were constructed to capture pollutants from site ▪ Proponent would not submit false data to EPA ▪ Guarantees have been made to train and protect workers.

These opinions were in the minority and the views and discussion captured during the Conference highlighted the significant concern held by the community that the proposed ULAB recycling facility is not suited to the Hazelwood North site and has the potential to negatively impact human health and the surrounding environment.

Concerns frequently raised in the 20B Conference and written submissions include:

▪ A lack of trust in the safety of technology developed and used in China and whether this meets ‘World’s Best Practice’

▪ Modelling, monitoring and reporting of environmental performance and potential health impacts ▪ That the proposed location is unsuitable due to poor zoning, the already impacted health of residents

within the LV and the proximity of a primary school ▪ The need for another ULAB recycling facility given the existing operation in New South Wales ▪ Whether other technologies to recycle the lead may be more appropriate than the process proposed.

Solutions proposed during the 20B Conference and written submissions will often not be the responsibility of a single entity, they will require more integrated planning and environmental and waste management approaches between industry, government and the community to ensure:

▪ Alignment between regional strategies/plans and economic development


▪ Development of industry within appropriately zoned locations ▪ Appropriate management of waste and traffic.

It is evident from the 20B Conference and written submissions that for some participants this WAA is being assessed in a context where trust of the applicant and of EPA is at a low base. Woven through the technical and operational comments are concerns about performance, accountability and credibility of both Chunxing and EPA. In particular concern was expressed over:

▪ Variability in standards and regulations between Environment Protection Authorities in Victoria, New South Wales and Western Australia

▪ The ability of the Victorian EPA standards to align with and meet ‘World’s Best Practice’ ▪ The long-term ownership and stewardship of the ULAB recycling facility, given Chunxing is a Chinese

company ▪ Whether the standards and technologies used in China meet with expectations regarding management

of human health and the environment in Australia.

3 . 2 R E C O M M E N D A T I O N S

I have developed the following recommendations in the tables below to address some of the observations above. These recommendations are predominantly based on participant questions from the 20B Conference, again noting that many of these questions have already been raised in the written submissions. Adoption of the general and specific recommendations below may assist in alleviating community concerns and improving community engagement about the proposal.

Recommendations are made in Tables 3-1 to 3-4 below for the following categories:

▪ Actions prior to WAA determination ▪ Future actions, if a WA is approved ▪ Future actions regardless of whether an Approval is approved.

I note that in preparing this report I had access to the applicant’s written responses to the Section 22 notices to supply further information to EPA. The Chair encourages the EPA to review and make available these responses as soon as is practicable.

In addition I note the timing of the section 20B Conference and the absence of detail about the applicant’s responses to requests for further information has resulted in the reiteration of community concerns and questions and some community frustration at the lack of new information being provided.


3 . 2 . 1 G E N E R A L R E C O M M E N D A T I O N S

Table 3-1: The following general recommendations relate to actions prior to WAA determination

GENERAL RECOMMENDATION (PRIOR TO WORKS APPROVAL

(WA)DETERMINATION)

CHAIR’S OBSERVATIONS SUPPORTING THE RECOMMENDATION

EPA to continue raising community awareness about where a WAA sits in the overall Approvals and Licensing process and the the criteria assessed at this stage of the the process.

§ EPA could also consider adding a link, when applicable, about EPA’s position statement about when a health risk assessment is required https://ref.epa.vic.gov.au/business-and-industry/guidelines/licensing-and-works-approvals/when-are-human-health-risk-assessments-needed.

▪ Some participants appeared to lack a good understanding of EPA’s role in relation to Approvals and Licensing of Scheduled Premises.

▪ Several issues were raised in submissions and in conference discussion that are not within the scope of EPA’s assessment and decision-making role for WAA. These included: - Property values - Planning issues and location of the site - Adequacy of external stormwater infrastructure - External transport.

▪ The Chair notes that information about these aspects is referenced on the Engage Victoria webpage for Chunxing Corporation Pty Ltd (ULAB) https://engage.vic.gov.au/epa-works-approvals/ulab including links to: - ULAB Powers table poster to help clarify areas of agency responsibility - EPA Publication 1523.2 EPA works approvals.

▪ The Chair also notes the provision of the EPA publication 1657 EPA’s works approval assessment process via the overview section on the current WAA webpage page https://engage.vic.gov.au/epa-works-approvals.

EPA to support consolidated questions and responses including: ▪ Facilitating the provision of responses to the list of consolidated questions at

Section 2.4 of this S20B Conference report. ▪ Encouraging the applicant to cross check its Section 22 response with the list of

consolidated questions. ▪ Reviewing the responses provided by Chunxing to ensure they accurately and

adequately address the outstanding questions arising from the Conference (as reflected in this report), and seeking further information as required from Chunxing using statutory powers under Section 22 as appropriate.

▪ Consulting with other internal subject matter experts to provide EPA specific responses (as required).

▪ Section 2.4 of this S20B Conference report consolidates all the questions related to the ULAB recycling facility proposal – some of which are for EPA to answer and some for Chunxing to answer.

▪ Note: in preparing this report the Chair has had access to the applicant’s S22 response by Chunxing and recognises, without commenting on the adequacy of that response, that some of the outstanding questions will have been responded to in the applicant’s Section 22 response.


GENERAL RECOMMENDATION (PRIOR TO WORKS APPROVAL

(WA)DETERMINATION)


▪ Publishing the consolidated responses on the Engage Victoria website.


3 . 2 . 2 T O P I C S P E C I F I C R E C O M M E N D A T I O N S

These recommendations relate to matters raised under main topics considered during the 20B Conference. Reviewing Chunxing’s preliminary response to submissions indicates that many of the questions raised in the 20B Conference process were also raised in written submissions and responses have now been provided by Chunxing.

It is not the Chair’s role to comment on the adequacy or accuracy of any of those responses referred to above, that is a matter for EPA.

The recommendations to EPA below contain a mix of awareness raising suggestions and suggestions for independent verification of data and design specification.

Table 3-2: The following topic specific recommendations relate to actions prior to WAA determination

TOPIC SPECIF IC RECOMMENDATIONS (PRIOR

TO WORKS APPROVAL DETERMINATION)


Topic 1 – Potential for human health impacts:

▪ EPA to engage a suitably qualified expert to peer review air dispersion modelling.

▪ EPA to consider whether the WAA is considered a significant WA under Section 19B(3)(a)(i) of the Environment Protection Act requiring referral to DHHS for advice.

▪ EPA to consider referral of the WAA to its internal Environmental Health Unit for advice.

▪ EPA to consider requiring the proponent to undertake a human health risk assessment.

▪ Within the written submissions community members expressed views that the proposal directly contradicts the LV being declared a Health Innovation Zone, as recommended by the Hazelwood Mine Fire Inquiry. Frequent reference has also been made to World Health Organisation (WHO) advice about ‘no safe level of lead exposure’, and the need for both community and worker health monitoring.

▪ The adequacy of current emissions standards and the impact of high winds on emissions dispersal have been raised. Numerous concerns have also been raised regarding potential impacts on human health, both immediate and long term, due to: - A range of potentially toxic emissions from the proposed recycling facility plant affecting air quality

(including but not limited to lead, SO2, CO2, dioxins) - Exposure to lead (and other potentially harmful substances) via breathing polluted or contaminated

air, ingested as contaminated drinking water or contaminated food - Additional PM2.5 and PM10 pollution through diesel emissions (associated with transporting lead

acid batteries to the site for recycling). ▪ Examples provided include the physical and psychological health and wellbeing of:

- Vulnerable groups (pregnant women, unborn children, elderly, those with pre-existing conditions) - Students of the Hazelwood North Primary School (located 1.6km away) - Workers at the facility - Residents in the area.





▪ Many S20B Conference participants reiterated these comments. There was extensive concern about the overall health impacts this kind of facility could have on both employee and community health (See Table 2-1 and 2-2).

▪ In relation to ‘worker health’ the Chair notes the WAA has been referred to WorkSafe for comment and any response will be recorded in EPA’s Works Approval Application Assessment Report (WAAAR)

▪ There were numerous conference discussion points about the approach to, and adequacy of, the applicant’s data modelling. Several participants questioned the trustworthiness of the data source.

▪ There were some comments questioning the quality of the application and suggesting there were gaps in the information provided to EPA.

▪ For some, there also seemed to be confusion about what a CEMS (continuous emissions modelling system) monitors and whether there could be accurate real time data about lead emissions.

▪ There were also some comments highlighting a lack of confidence in EPA’s expertise to assess this particular kind of application.

▪ The Chair notes that so far EPA has been silent on whether the proposal is considered a significant works approval as defined in the Environment Protection Act 1970.

Topic 2 – Potential for environmental impacts from

emissions and other waste by-products:

▪ EPA to confirm with DELWP the outcome of the applicant’s self-referral to DELWP regarding the need for an Environment Effect Statement (EES) and provide details in its Works Approval Assessment Report.

▪ EPA to seek any additional information from the applicant (Chunxing) using its statutory powers to satisfy itself that the potential for environmental impacts have been appropriately assessed

▪ Once the applicant’s responses to the Section 22 notices to supply further information has been accepted, EPA to make the responses available on the Engage Victoria website and notify conference attendees.

▪ Within the written submissions community members have expressed concern about the cumulative impact of emissions to surrounding land (predominantly agricultural) and waterways (including wetlands), as well as surface water and ground water.

▪ There have been calls for a full environmental audit of the site given its levels of existing contamination. Concerns have also been raised about waste management practices including storage, handling and disposal of chemicals and waste products to avoid stockpiling.

▪ Examples provided included concerns about: - Impacts on livestock, food chain, tank water, plants and pastures - Appropriate management of by-product/slag volumes from the recycling process such as:

– Potential for contaminated materials associated with the packaging and transport of lead acid batteries

– Potential for pine bark contamination. ▪ Stormwater and wastewater management (including potential sewer and draining discharges) ▪ Conference participants raised concerns about the cumulative impact of emissions to surrounding land

and waterways as well as surface water and groundwater ▪ See Tables 2-3 and 2-4





▪ There were several comments expressing lack of trust in the applicant’s environmental performance – both past and future. A number of these concerns seemed to be based on the lack of similar facilities owned or operated in Australia by Chunxing in Australia to refer to.

▪ The Chair notes that several references were made at the Conference and in submission to the need for an Environmental Effects Statement (EES).

▪ The Chair notes the applicant has stated in its second response to S22 that it has “written to DELWP with a self-assessment of the need for an EES for the project, using the referral criteria outlined on page 7 of the relevant Ministerial guidelines. It is clear from this assessment that no trigger for EES exists. DELWP has responded by phone to indicate that they are happy with the assessment”.

▪ The Chair also notes that EPA has made two formal requests for additional information from the applicant regarding: - Building design and equipment - A full process description of input and output materials - Material receival areas - On-site wastewater treatment plant - Air emissions point sources and management - Fugitive emissions control and management - Internal lead concentrations - Design capacities, maintenance program and data to confirm performance standards (Baghouse &

Scrubbers) - Stormwater and site run-ff management - Chemicals, dangerous goods and waste storage handling - Emergency management procedures - Responses to issues raised in the public submissions.

Topic 3 – Suitability of proposed location

▪ EPA to determine the adequacies of the available buffers - EPA to share the 20B report with the Latrobe City

Council.

▪ Within the written submissions community members raised concerns about the Latrobe Valley as an appropriate location for this type of facility.

▪ There are concerns that the facility, if approved, will result in additional impacts on an already impacted community.

▪ Examples provided included concerns about: - The appropriateness of buffers and the proximity to schools (sensitive receptors) and employees of

other businesses (e.g. Council Transfer Station) - Impact on property values if this type of industry is permitted





- Contribution to existing contamination loads / Air Shed pollution e.g. ‘already high levels of SO2 in the Valley’

- Potential to undermine Australia’s ULAB recycling sector with oversupply of capacity ▪ Several conference participants commented that approval of this kind of operation is incompatible with the

area being declared a Health Innovation Zone and reiterated questions about the Latrobe Valley as an appropriate location for this type of facility given the impact of previous industry on the health of residents. In particular there were concerns about the cumulative impact of emissions and the impact of local weather on emissions dispersal

▪ Proximity to sensitive receptors and appropriate buffer zones were also raised as concerns along with concerns raised above in Topic 1 and 2.

▪ See Tables 2-5 and 2-6 ▪ The Chair notes the applicant has submitted a Planning Permit application and that the proposed location

is zoned Industrial 2 Zone ▪ The Chair notes the Latrobe City Council’s role in assessing planning permits and notes the WAA has

been referred to Council for approval.

Topic 4 – Best practice modelling, technology and future

operation (performance monitoring):

▪ EPA to consider commissioning an independent assessment to determine whether the proposed technology for recycling ULAB in the Chunxing WAA is best practice.

▪ EPA to access information available online on Chunxing’s facility in China to assess the proposed ULAB recycling technology and performance of facility.

▪ Within the written submissions community members expressed concern regarding how the emissions modelling has been done, including the trustworthiness of reference data from China.

▪ Concerns were also raised about energy use and greenhouse gas reduction as well as overall safe plant operations

▪ Examples provided included concerns about: - Modelling data not including projected emissions from other proposed plant nearby (APM) or bushfire

smoke impacts from the current fire season. - Availability of newer technology:

– The proposed facility is ‘a very old process’ and ‘outdated technology’ – There are new technologies that are less dangerous; much ‘safer’ technologies that are based

on electrolysis or solvents. ▪ Reference to an ‘EcoMENA article states that “in fact lead-acid battery recycling is regarded as one of the

worst pollution industries worldwide”. ▪ Frequency of proposed emissions monitoring during future operation and the potential to access real time

emissions data. ▪ Environmental performance in relation to water resource use. ▪ 20B Conference participants reiterated concerns that:





- The modelling used to assess emissions is not accurate and needed to include other sources of emissions

- The technology proposed is outdated and not safe - There is no evidence to support the proponent’s history of environmental performance and

governance. ▪ Some participants called for EPA to visit the plant in China and benchmark against similar

industries/facilities in other countries as well as those already in use in Australia. ▪ The University of Britain citric acid facility was one example suggested. ▪ See Table 2-7 and Table 2-8.


Table 3-2: The following topic specific recommendations relate to future actions, if a WA is granted

RECOMMENDATIONS IF WORKS APPROVAL GRANTED CHAIR’S OBSERVATIONS SUPPORTING THE

RECOMMENDATION

Topic 1 – Potential for human health impacts

§ EPA to consider:

- A WA condition requiring a (further or updated) human health risk assessment based on final detailed design of the facility.

▪ WA/Licence conditions to ensure appropriate monitoring, evaluation and reporting regimes are implemented including a consideration of health monitoring.

▪ Conference participants raised numerous concerns about the cumulative impact of emissions from all industries in the area and the specific impact of lead on community health

▪ Concerns were also raised about monitoring and reporting, including: - Access to real time data - What happens if emissions levels exceed what is predicted - Impacts of climate change.

▪ Refer to Table 2-1 and Table 2-2 ▪ Several participants also questioned the adequacy of EPA standards and “buffer

zones” or separation distances. There was considerable confusion about buffer zones and separation differences and this subject was discussed across several different discussion topics

Topic 2 – Potential for environmental impacts from emissions and other waste

by-products:

EPA to consider:

▪ A WA condition requiring the applicant to submit a baseline conditions report for soil, surface and groundwater

▪ A WA condition / licence condition requiring an updated Environmental Management Plan / Environmental Management System to include a monitoring program during construction and future operation in relation to managing:

- Air emissions - Solid and liquid waste - Wastewater - Noise - Odour.

▪ A WA condition that the WA does not take effect until any permit which is required under the Planning and Environment Act 1987 has been served on the Authority by the applicant.

▪ Conference participants raised numerous concerns about the cumulative impact of emissions on the environment

▪ Concerns were also raised about the existing site contamination levels with some references to an environmental audit report from 2008

▪ Refer to Table 2-3 and Table 2-4 ▪ The Chair notes the applicant has referred to its responsibility to implement the

existing Environmental Management Plan for the site in its S22 response to EPA.


RECOMMENDATIONS IF WORKS APPROVAL GRANTED CHAIR’S OBSERVATIONS SUPPORTING THE

RECOMMENDATION

§ EPA to actively promote to the community, it’s role in compliance including information about how to raise concerns about non-compliance with works approval (and future licence) conditions.

Topic 4 – Best practice modelling, technology and future operation

(performance monitoring):

EPA to consider requiring WA conditions for: § The installation of a Continuous Emissions Monitoring System and Continuous

Operating Monitoring system § The provision of any required reports related to safe operation (such as a HAZOP

study) § An updated air quality impact assessment based on final detailed design of the

facility § The applicant to seek commissioning approval before the licence application, to

allow start-up and testing of initial operations and to confirm compliance with the works approval

EPA to consider requiring a Licence condition for: § Proactive community consultation and the development of an engagement plan

for the facility § Provision of regular information to the community on its activities and

performance. In addition to appropriate licence conditions, EPA should actively promote to the community, the EPA’s role in compliance including information about how to raise concerns about non-compliance with works approval or licence conditions. EPA to raise the applicant’s awareness about its “social licence to operate” by directing it to information about EPA’s Licensed Operator Risk Assessment (LORA) for determining compliance visit frequency - which includes a category in relation to community engagement https://ref.epa.vic.gov.au/our-work/licences-and-approvals/lora EPA could consider the benefits of requiring the applicant to establish: § Community Issue and Complaints response as a condition in the WA/Licence

- Community Consultation Committee/Environmental Review Committee/Community Reference group or similar.

▪ Conference participants raised numerous concerns as reflected in the previous table for Topic 4

▪ The Chair notes that at page 168 of the WAA the applicant has made a commitment to real time access to CEMS monitoring data online. This commitment could be reinforced through a specific licence condition

▪ While performance monitoring will be regulated by EPA through specific licence requirements some conference participants suggested that monitoring and reporting should done independently.


Table 3-3: The following general recommendation relates to future action regardless of whether a WA is granted

RECOMMENDATIONS REGARDLESS OF WHETHER

A WORKS APPROVAL IS GRANTED


▪ EPA to consider its role in providing improved external communications and access to information by making the:

- 20B report publicly available

- complete WAAAR available for this decision.

▪ Comments provided by participants during the conference highlight: - A lack of trust that Chunxing will operate with regard to community impacts and good

environmental stewardship over the life of the facility - Concern over EPA’s technical expertise to assess the WA and ability to ensure compliance

with works approval conditions, licence conditions and general environmental protection regulations.


Appendix 1: PowerPoint presentation provided by Chunxing

Chunxing battery recycling facility – 20B Conference

Geoff Latimer, Managing Director Ascend Waste and Environment www.ascend2042.com

Dr Lakshman Jayaweera, CEO/ Director Chunxing Corporation www. chunxing.com.au

Tracy VanderZalm, Communications Consultant Wordwise Communications

http://www.ascend2042.com/

http://www.jschunxing.com/

Outline of presentation

1. Key themes from submissions2. Major issue - emissions impact on human health3. Other issues

Key themes identified from submissions# Key theme No. responses

(approx.) raising issue1 Emissions could impact human health and particular concerns about those living closest to

the facility, including the Hazelwood North Primary School ~ 80

2 Cumulative impacts of emissions to surrounding soil, waterways, agricultural land (and livestock) ~ 25

3 The distance from the facility to the nearest residences/ school is too small (buffer zone) ~ 254 Sulfur dioxide levels will be too high (reference to a previous LV Express article based on a

Greenpeace Report, showing high levels of SO2 in the Valley) ~ 15

5 Dividing the China plant emissions by 16 to use as modelling input for the Hazelwood North proposed plant is “not good science”. ~ 10

6 Lack of trust in Chinese data (or Chinese businesses) ~ 107 Emissions from the facility could contaminate the pine bark next door ~ 108 The plant could have a negative impact on property values ~ 109 The timing or number of engagements held has been inadequate ~ 510 There is newer technology available, such as that promoted by AquaMetals, than what

Chunxing is proposing ~ 5

Data type (for lead, Pb) Ground level conc.1 (ng/m3)

How many times below EPA standard?

EPA design criteria 3,000 1

Hydromet Laverton EPA licence limit 1,421 2.1

Aust Govt background Pb level 100 30

EPA (Regulation 10) exemption level 28 106 Chunxing Haz Nth (worst case anywhere) 9 333

Chunxing Haz Nth (worst case closest receptor) 2 1,500

1 Or ground level concentration as calculated from stack emission data, run through the model established to predict Hazelwood North emissions dispersion behaviour.

-

500

1,000

1,500

2,000

2,500

3,000

3,500

EPA design criteria Hydromet Laverton EPAlicence l imit

Aust Govt background Pblevel

EPA exemption level Chunxing Haz Nth (worstcase anywhere)

Chunxing Haz Nth (worstcase closest receptor)

Ground level conc. (ng/m3)

-

500

1,000

1,500

2,000

2,500

3,000

3,500

EPA design criteria Hydromet Laverton EPA licence limit Aust Govt background Pb level EPA exemption level Chunxing Haz Nth (worst case anywhere) Chunxing Haz Nth (worst case closestreceptor)

Ground level conc. (ng/m3)

Major issue - emissions impact on human healthKey takeaways:

Emissions from this plant are predicted to be, based on the worst modelled case:

• over 300 times below the EPA standard

• over 150 times lower than Hydromet Laverton’s actual EPA licence limit, which was very recently amended (February 2018)

• eleven times below “natural background” levels expected in Australia

• one-third of the General Exemption level (from the need for Works Approval), which is itself set at what would be equivalent to less than a third of natural background.

• Concentrations of lead predicted by the model at the nearest sensitive receptor are just 2% of natural background levels, or 50 times lower.

• This level, which is a worst case anyway, is negligible and indistinguishable from what Latrobe Valley residents, and indeed people across Australia, are breathing now, every day.

Other issues• The distance from the facility to the nearest residences/ school is too small

(buffer zone)

• Suspicion about the China plant emissions data

• There is newer technology available, such as that promoted by AquaMetals,

than what Chunxing is proposing


Appendix 2: PowerPoint presentation provided by EPA

Chunxing Corporation Pty Ltd Used Lead Acid Battery (ULAB) recycling facility Works Approval Application s20B Public ConferenceEnvironment Protection Authority

Introductions - EPA

Stephen AdamthwaiteManager Development Assessments EPA Victoria

• Quentin Cooke, Team Leader, Approvals• Fiona Pond, Engagement, Development Assessments Unit• Lauren Byrnes, Community Engagement Group• Suzanne Hall, Community Engagement Group• Rebecca Angover, Community Engagement Group• John Rees, Community Engagement Group• Peter O’Brien, Community Engagement Group• Stacey Clark, Senior Stakeholder Engagement Advisor,

Gippsland• Jess Bandiera, Regional Manager, Gippsland

Works Approval Assessment process

• EPA’s Statutory Role & Powers• What other approvals are required?

- Planning Permit

Overview of the Works Approval Assessment process

• EPA determined to accept applicationApplication received

• Newspapers (state and local) and online advertising• Referrals to relevant agenciesReferrals and advertising

• 20B conference where this may assist in just resolution of the matterReview of submissions

• Consider submissions and 20B conference• Input from EPA technical expertsFinalise technical assessment

• Approval granted / refusedDecision

• VCAT – Applicant or affected third parties may apply to appeal decisionAppeal provisions

Referrals to external agenciesEPA has referred the application to:• Latrobe City Council• Gippsland Water• Agriculture Victoria• West Gippsland Catchment Management Authority• Country Fire Authority • Sustainability Victoria• WorkSafe Victoria• Department of Education and Training

Review of submissions received by EPA

136

Total number of submissions from

the community

Some of the issues raised:• Public health risks• Lead emission exposure risks• Location of the proposed facility• Risk assessment and management• Air quality modelling• Best practice technology• Noise impacts• Surface/groundwater impacts• Waste disposal• Future performance monitoring

Formal Requests under s22 of the Act Two notices have been served on:31st January:– for further technical information

19th February:– for further information in response to public

submissions received

Requests for further information

Works Approval next steps

1• Once received and accepted, further information requested will be made publicly available and

open for comment.• The s20B Community Conference Report and recommendations will be considered.

2

• Completion of technical assessment:• Compliance against legislation• Analysis of key issues to determine likelihood of pollution and hazard occurring

3• Once decision made to approve or refuse: Notification to submitters

ContactsWebsite:www.epa.vic.gov.auwww.engagevictoria.com.au

Email Us:[email protected]

Call Us: 1300 372 842 (1300 EPA VIC)

http://www.epa.vic.gov.au/

http://www.engagevictoria.com.au/


Appendix 3: Conference agenda Table A3-1: Conference agenda

TIME ACTIVITY WHO

6.00pm 20B Conference commences:

▪ Welcome and Introductions

▪ Acknowledgement of Traditional Owners.

RMCG

6.05pm Purpose of 20B Conference and overview of proceedings. RMCG

6.15pm Overview of Works Approval Application:

▪ Background to the proposal and summary of process

▪ Outline of the proposal.

Chunxing

6.35pm Overview of Works Approval process and summary of submission themes.

EPA (Environment Protection Authority)

6.55pm Overview of discussion rounds. RMCG

7.05 – 7.25pm

7.25 – 7.45pm

7.45 – 8.05pm

8.05 – 8.25pm

8.25 – 8.40pm

Discussion rounds:

▪ Potential for human health impacts

▪ Potential for environmental impacts from emissions and other waste by-products

▪ Suitability of proposed location

▪ Best practice modelling, technology and future operation (performance monitoring)

▪ Other.

All

8.40pm Joint Q and A panel (Optional). RMCG

8.55pm Wrap and close. RMCG


Appendix 4: Conference attendees

FIRST NAME LAST NAME ORGANISATION ( IF APPLICABLE)

A&M Lamont

Abby Peatey

Amy Peatey

Andy Tegart

Angus Fraser

Anna Harmer

Annabelle Gumpold

Antoinette Holm

Arthur And Carol Smith

Audrey Naismith

Bob Temple Retired Industrial Chemist

Braydon Smith

Brendan Chessum

Bronwyn Woodward

Cameron Corrigan Victorian Farmers Federation

Carl Shanahan

Charles Williams And wife Margaret

Cheryl Briggs

Chris Streeter

Chris Jia Invest Victoria

Christine Shanahan

Connie Ban Eyk

Daniel Buis

David Price

Debbie Gregory

Debbie Bellingham Grant & Sophie

Dick Patray

Don And Marion Ireland

Ed Vermeulen

Eloise Cluning



Emily Findlay

Felicetta Kile

Gaye Jones

Grant Bellingham

Harold Jones

Hayley And Scott Koolen And Mynard

Helen Morrison Voices of the Valley

Henry Lieshout

Hughes Sue

Ian Norwood I & L Norwood

Ian & Glenda Combridge

Janet Kootstra

Janette Gibson

Jenny Smethurst

Jenny And Brendan Chessum

Jo Peatey

Jody Riordan Latrobe City Council

John Arkinstall

John Virag

John Spencer

John Catford Latrobe Health Assembly

Jon Knight

Julie Porter

Karen Egan Latrobe City Council

Kaylene Lieshout

Kellie O'callaghan Latrobe City

Kerri And Grant Duncan

Kylie And Colin Taylor

Leanne Norwood Hazelwood North Action Group Member

Leteishah Groen

Liam Faltum

Liam Chessum



Lindy Gumpold

Lyn Poon

Malcolm Gibson

Mark Peatey

Mark And Annie Beyer

Mark And Annie Bath Mp State Member of Parliament – Member For Eastern Victoria Region

Peter Mueller

Peter Bourke

Peter Ingwerson I & L Norwood

Peter And Angela Leviston

Philip Reichert

Phillip Nadvesnik

Phillip Taylor

Ray Jackman

Rosalie Thomas Extinction Rebellion

Sally Fraser

Sam Shanahan

Sean-Paul Smith Latrobe City Council

Sharntaye Jarvis

Sharon Starkey

Shaun Ward

Sheila James

Steven Dockley

Terrence & Doris Key

Tracy Bertoli

Wally Anders

Wayne O'brien Invest Victoria

Wendy Farmer Voices of the Valley

Zhining Yang Invest Victoria

Rebecca Hardy

Eric And Annette Deppeler

Roz Greves



Helen Morrison

Marianne Robinson

Sharon Stakey

Trevor Birkbeck

George Buhagiar

John O'connor

Phillip Edwards

Joanne & Wayne Leviston

Lorraine Bull

Sandra Stevenson


Appendix 5: Table based collateral EPA 20B CONFERENCE – Participant notes – discussion rounds

CHUNXING ULAB WAA

Name (optional):

Email (optional):

Best contact (optional):

Please select one statement for each of the four discussion themes that best represents your view and add your comments in the box provided.

1 . D I S C U S S I O N T H E M E : P O T E N T I A L F O R H U M A N H E A L T H I M P A C T S

Community members have expressed concerns the proposal directly contradicts the Latrobe Valley being declared a Health Innovation Zone, as recommended by the Hazelwood Mine Fire Inquiry. Frequent reference has also been made to World Health Organisation (WHO) advice about ‘no safe level of lead exposure’, and the need for both community and worker health monitoring.

The adequacy of current emissions standards and the impact of high winds on emissions dispersal have been raised. Numerous concerns have also been raised regarding potential impacts on human health, both immediate and long term, due to:

§ A range of potentially toxic emissions from the proposed recycling facility plant affecting air quality (including but not limited to lead, SO2, CO2, dioxins)

§ Exposure to lead (and other potentially harmful substances) via breathing polluted or contaminated air, ingested as contaminated drinking water or contaminated food

§ Additional PM2.5 and PM10 pollution through diesel emissions (associated with transporting lead acid batteries to the site for recycling).

Examples provided include the physical and psychological health and wellbeing of:

§ Vulnerable groups (pregnant women, unborn children, elderly, those with pre-existing conditions) § Students of the Hazelwood North Primary School (located 1.6km away) § Workers at the facility § Residents in the area.

Discussion: consideration of potential health impacts

I am:

£ Very confident based on the information available so far that health impacts have been appropriately considered because:

£ Quite confident based on the information available so far that health impacts have been appropriately

considered because:

£ Neutral: this is not a concern for me either way. I am more concerned about:


£ Somewhat confident but I need to know more. The kind of information that would improve my confidence

about the appropriate consideration of health impacts is:

£ Not at all confident that the health impacts have been appropriately considered. Questions that remain

unanswered for me regarding potential health impacts are:

£ More interested in providing my views about a different topic such as:

2 . D I S C U S S I O N T H E M E : P O T E N T I A L F O R E N V I R O N M E N T A L I M P A C T S F R O M E M I S S I O N S A N D O T H E R W A S T E B Y - P R O D U C T S

Community members have expressed concern about the cumulative impact of emissions to surrounding land (predominantly agricultural) and waterways (including wetlands), as well as surface water and ground water.

There have been calls for a full environmental audit of the site given its levels of existing contamination. Concerns have also been raised about waste management practices including storage, handling and disposal of chemicals and waste products to avoid stockpiling.


Examples provided included concerns about:

§ Impacts on livestock, food chain, tank water, plants and pastures § Appropriate management of by-product/slag volumes from the recycling process

- Potential for contaminated materials associated with the packaging and transport of lead acid batteries

- Potential for pine bark contamination § Stormwater and wastewater management (including potential sewer and draining discharges).

Discussion: consideration of potential environmental impacts

I am:

£ Very confident based on the information available so far that environmental impacts have been

appropriately considered because:

£ Quite confident based on the information available so far that environmental impacts have been




about the appropriate consideration of environmental impacts is: £ Not at all confident that the environmental impacts have been appropriately considered. Questions that

remain unanswered for me regarding potential environmental impacts are:



3 . D I S C U S S I O N T H E M E S : S U I T A B I L I T Y O F P R O P O S E D L O C A T I O N

Community members have raised concerns about the Latrobe Valley as an appropriate location for this type of facility. There are concerns that the facility, if approved, will result in additional impacts on an already impacted community.


§ The appropriateness of buffers and the proximity to schools (sensitive receptors) and employees of other businesses (e.g. Council Transfer Station)

§ Impact on property values if this type of industry is permitted § Contribution to existing contamination loads / Air Shed pollution e.g. ‘already high levels of SO2 in the

Valley’ § Potential to undermine Australia’s ULAB recycling sector with oversupply of capacity.

Discussion: suitability of proposed location

I am:

£ Very confident based on the information available so far that the suitability of the location has been


£ Quite confident based on the information available so far that the suitability of the location has been



£ Somewhat confident but I need to know more. The kind of information that would improve my confidence about the appropriate consideration of the suitability of the location is:

£ Not at all confident that the suitability of the location has been considered. Questions that remain

unanswered for me regarding location suitability are:



4 . D I S C U S S I O N T H E M E : B E S T P R A C T I C E M O D E L L I N G , T E C H N O L O G Y A N D F U T U R E O P E R A T I O N ( P E R F O R M A N C E M O N I T O R I N G )

Community members expressed concern regarding how the emissions modelling has been done, including the trustworthiness of reference data from China. Concerns were also raised about energy use and greenhouse gas reduction as well as overall safe plant operations.


§ Modelling data not including projected emissions from other proposed plant nearby (APM) or bushfire smoke impacts from the current fire season

§ Availability of newer technology:

- The proposed facility is ‘a very old process’ and ‘outdated technology’

- There are new technologies that are less dangerous; much ‘safer’ technologies that are based on electrolysis or solvents

- Reference to an ‘EcoMENA article states that “in fact lead-acid battery recycling is regarded as one of the worst pollution industries worldwide”

§ Frequency of proposed emissions monitoring during future operation and the potential to access real time emissions data

§ Environmental performance in relation to water resource use.

Discussion: best practice modelling, technology and future operation (performance monitoring)

I am:

£ Very confident based on the information available so far that best practice standards have been appropriately considered because:

£ Quite confident based on the information available so far that best practice standards have been




about the appropriate consideration of best practice standards is:

£ Not at all confident that best practice standards have been considered. Questions that remain unanswered

for me regarding best practice standards are: £ More interested in providing my views about a different topic such as:


Is there anything else you would like us to consider as part of this 20B Conference?

Thank you – please complete our short evaluation questionnaire over the page.


Optional Conference Evaluation:

Thank you for your participation in the 20B Conference. We would appreciate your feedback about your experience. Please rate the following statements about your experience:

Q.1 My understanding of the Works Approval Application has increased as a result of tonight’s conference:

£ Strongly agree

£ Agree

£ Neutral

£ Disagree

£ Strongly disagree

Comments:

Q. 2 I felt comfortable participating in the conference process:

£ Strongly agree

£ Agree

£ Neutral

£ Disagree £ Strongly disagree

Comments:

Q. 3 My contribution was listened to:

£ Strongly agree

£ Agree £ Neutral

£ Disagree

£ Strongly disagree

Comments:


Appendix 6: Summary of key themes

K E Y C O M M U N I T Y C O N C E R N S F O R C H U N X I N G U L A B W A A

A list of key community concerns has been developed based community input at information sessions and through the formal submissions process. Many submitters have expressed the view that they do not believe that this industry fits in with current and future community values, relating to public safety, environmental and social benefit.

In summary the list of concerns includes but is not limited to:

§ Adequacy of proposed technology & ability for safe operation if approved, including both onsite and offsite risk management

§ Adequacy of assessment for noise/odour under future operational conditions § Adequacy of, and appropriateness of, community engagement activities § Approach to emissions modelling and adequacy of reference data § Chemical and waste management – storage, handling and disposal § Company’s reputation, social licence to operate and ability to comply with EPA licence conditions § Consideration of existing levels of land contamination at proposed site (per 2008 Site assessment) § Cumulative impacts on human and animal health and the environment (including land and water) from

lead emissions / lead exposure § EPA’s ability (expertise) to adequately assess the WAA and need for appropriate referral to other

agencies (including but not limited to: Latrobe Health Assembly, Emergency Services, Department of Agriculture, Mine Rehabilitation Commissioner)

§ Fire risk management – on site and off § Market over capacity for ULABs § Suitability of location and adequacy of buffer zones.

To guide table-based discussions at the 20B Conference the following themes have been selected based on frequency:

§ Discussion theme: potential for human health impacts § Discussion theme: potential for environmental impacts from emissions and other waste by-products § Discussion theme: suitability of proposed location § Discussion theme: best practice modelling, technology and future operation (performance monitoring).

1 . D I S C U S S I O N T H E M E : P O T E N T I A L F O R H U M A N H E A L T H I M P A C T S

Community members have expressed concerns the proposal directly contradicts the Latrobe Valley being declared a Health Innovation Zone as recommended by the Hazelwood Mine Fire Inquiry. Frequent reference has also been made to World Health Organisation (WHO) advice about ‘no safe level of lead exposure’ and the need for both community and worker health monitoring.

The adequacy of current emissions standards and the impact of high winds on emissions dispersal have been raised. Numerous concerns have also been raised regarding potential impacts on human health, both immediate and long term, due to:


§ A range of potentially toxic emissions from the proposed recycling facility plant affecting air quality (including but not limited to lead, CO2, dioxins)

§ Exposure to lead (and other potentially harmful substances) via breathing polluted or contaminated air, ingested as contaminated drinking water or contaminated food

§ Additional PM2.5 and PM10 pollution through diesel emissions (associated with transporting lead acid batteries to the site for recycling).

Examples provided include the physical and psychological health and wellbeing of:

§ Vulnerable groups (pregnant women, unborn children, elderly, those with pre-existing conditions) § Students of the Hazelwood North Primary School (located 1.6km away) § Workers at the facility § Residents in the area.

2 . D I S C U S S I O N T H E M E : P O T E N T I A L F O R E N V I R O N M E N T A L I M P A C T S F R O M E M I S S I O N S A N D O T H E R W A S T E B Y - P R O D U C T S

Community members have expressed concern about the cumulative impact of emissions to surrounding land (predominantly agricultural) and waterways (including wetlands) as well as surface water and ground water.

There have been calls for a full environmental audit of the site given its levels of existing contamination. Concerns have also been raised about waste management practices including storage, handling and disposal of chemicals and waste products to avoid stockpiling.


§ Impacts on livestock, food chain, tank water, plants and pastures § Appropriate management of by-product/slag volumes from the recycling process

- Potential for contaminated materials associated with the packaging and transport of lead acid batteries

- Potential for pine bark contamination § Stormwater and wastewater management (including potential sewer and draining discharges).

3 . D I S C U S S I O N T H E M E S : S U I T A B I L I T Y O F P R O P O S E D L O C A T I O N

Community members have raised concerns about the Latrobe Valley as an appropriate location for this type of facility. There are concerns that the facility, if approved, will result in additional impacts on an already impacted community.


§ The appropriateness of buffers and the proximity to schools (sensitive receptors) and employees of other businesses (e.g. Council Transfer Station)

§ Impact on property values if this type of industry is permitted § Contribution to existing contamination loads/Air Shed pollution e.g. ‘already high levels of SO2 in the

Valley’ § Potential to undermine Australia’s ULAB recycling sector with oversupply of capacity.


4 . D I S C U S S I O N T H E M E : B E S T P R A C T I C E M O D E L L I N G , T E C H N O L O G Y A N D F U T U R E O P E R A T I O N ( P E R F O R M A N C E M O N I T O R I N G )

Community members expressed concern regarding how the emissions modelling has been done, including the trustworthiness of reference data from China. Concerns were also raised about energy use and greenhouse gas reduction as well as overall safe plant operations.


§ Modelling data not including project emissions from other proposed plant nearby (APM) or bushfire smoke impacts from the current fire season

§ Availability of newer technology:

- The proposed facility is ‘a very old process’ and ‘outdated technology’

- There are new technologies that are less dangerous; much ‘safer’ technologies that are based on electrolysis or solvents

- Reference to an ‘EcoMENA article states that “in fact lead-acid battery recycling is regarded as one of the worst pollution industries worldwide”

§ Frequency of proposed emissions monitoring during future operation and the potential to access real time emissions data

§ Environmental performance in relation to water resource use.


Appendix 7: Conference evaluation

E P A 2 0 B C O N F E R E N C E – E V A L U A T I O N S U M M A R Y

STRONGLY AGREE

AGREE NEUTRAL D ISAGREE STRONGLY D ISAGREE

My understanding of the Chunxing WAA has increased as a result of tonight's conference

✓ ✓✓✓✓ ✓✓ ✓✓✓✓✓✓✓✓✓✓

✓✓✓✓✓ ✓✓✓ ✓ ✓✓✓

I felt comfortable participating in the conference process

✓✓✓✓✓✓✓✓ ✓✓✓✓✓✓✓✓✓✓

✓✓✓✓✓✓✓ ✓✓ ✓

My contribution was listened to

✓✓✓✓✓✓✓✓✓

✓✓✓✓✓✓✓✓✓✓✓✓✓✓

✓✓✓✓✓✓ ✓

Total 24 44 21 3 5

C O M M E N T S

MY UNDERSTANDING OF THE CHUNXING WAA HAS INCREASED AS A RESULT OF TONIGHT 'S CONFERENCE

Already had a good understanding of the WAA having attended meeting EPA, etc.

No new information.

Disappointing that info EPA asks for has no time limit so community waiting.

Process only, not content/answers from proponent.

What about the world health organisation safe level of lead in the environment?.

Felt the presentations were repeats and not very professional. Felt we weren’t spoken to as equals but as 'uneducated' country people.

The whole discussion was very brief and seemed rushed.

Nothing new. Proponents did not answer questions. Dodged proper answers.

More questions.


I FELT COMFORTABLE PARTIC IPATING IN THE CONFERENCE PROCESS

Very good round table views often not realised but relevant of our ideas.

Time limitation was necessary, but it does impact on getting particular information across.

However the facility was poor - run out of water, inadequate food, etc. EPA lack of facilitators for all the tables.

Inclusive and good running by EPA/consultants.

The facilitation process was useful but this also needs to be seen to be listened to.

Perhaps planning, facilities and managing the topics (not sure people comfortable with putting people to declare positions?) Un-estimated numbers?

The process didn’t well work well for the amount of people here.

Process chaotic. Already provided this information in submission - repetitive process.

Crazy way of conducting a meeting: utter chaos.

A little confused by the method but must credit EPA staff with coping with the crowd – 3 times more than anticipated.

Very busy and not much room on table, therefore writing my concerns and questions here.

MY CONTRIBUTION WAS L ISTENED TO

Well prepared presentation, ran to time lines.

A table filled with like-minded people made that process very easy.

Very noisy lots of background noise.

Pleased that the EPA held the conference.

The conference process was a positive experience for our group. The input was enthusiastic and broad and well facilitated by Jessica Bandeira.

I only if the written paperwork is actually read and absorbed and not discarded: as us sceptics think will happen. Enjoy the bonfire.

Not happy with proposal.

Questions should be heard and responded to in our presence, they should have the answers straight up if they are telling the truth.

It was listened too - but hope that everyone's voice and views will be considered - hope the outcome will see this plant not go ahead.

Not really the answers were very vague and had little to no substance or technical information.

Very difficult to be heard as room was extremely noisy.


This report has been prepared by:

RM Consulting Group Pty Ltd trading as RMCG

Level 1 East, 1100 – 1102 Toorak Road, Camberwell, Victoria 3124

(03) 9882 2670 — rmcg.com.au — ABN 73 613 135 247

Offices in Bendigo, Melbourne, Torquay and Warragul (Victoria) and

Penguin and Hobart (Tasmania)

▪

Key Project Contact

Dr Kristen Stirling

0488 908 416 — [email protected]

Document review and authorisation

Job Number: #0736

Doc Version

Final/Draft Date Author Project Director review

BST QA review

Release approved by

Issued to

1.0 Draft 06/03/2020 K. Stirling B. Lowing - -

2.0 Final draft 11/03/2020 K. Stirling

B. Lowing

C.Flanagan-SMith

J. Belz C.Flanagan-SMith

Environment Protection Authority

3.0 Final 1/04/2020 K. Stirling

B. Lowing

K. Stirling Environment Protection Authority

Final 20B Conference Report ULAB - Amazon S3 · 2020-04-09 · WORKS APPROVAL APPLICATION 20B...

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