Dear Councillor,
It has come to the attention of the Association that the Bitumen Emulsion plant proposed for Marion Rd Maddington is on the Council Agenda on Tuesday (24th March 2009). We would like to reiterate our concerns over this proposal.
At a meeting that the Association hosted on the 9th March, there was significant concern over this proposal and the effect that it can have in combination with the impacts that the residents that live close to the industrial area already are subject to. There was a significant number of instances that were conveyed that evening, and by other communications with the Association, which are summarised below:
- Odours – Odours from poultry farms, waste handling / composting, chemical odours from fibreglass operations.
It should be pointed out at this point that both odours and dust are not trivial or nuisance issues, they have the capacity to affect human health. Dust is more correctly described as particulate matter and is limited by the National Environmental Protection (Ambient Air Quality) Measures Act to a maximum concentration of 50µg/m3 (24hr average) for PM10 (Particulates that are smaller than 10 microns). Odours are a triggering of a sense of smell due to the presence of a chemical. Unless the chemical that is present that triggers that sense of smell is established to be safe at the levels that are being exposed to, it must be considered to be unsafe, until proven otherwise. For example, the European Union has set a do not exceed target level of 1ng/m3 for benzo(a)pyrene in ambient air by 2012. Benzo(a)pyrene is used in the EU Directive as a marker for carcinogenic risk, and incidentally is likely to be a constituent of bitumen.
NB: a microgram (µg) is one millionth of a gram, a nanogram (ng) is one billionth of a gram
There was also significant concern over the risks to Bickley Brook, in combination to the impacts that currently affect the environmental health of the Brook.
Concerns over the level of consultation were raised. There was a significant number of residents that live in close proximity to the proposed plant (ie within the 300 metre radius that was used) that did not get any information delivered until they were advised by the Association’s letterdrop or the articles in the Sunday Times or local papers. There was also concern that the letters from both the City of Gosnells or the proponent were not informative enough, or did not provide people with “languages other than English” adequate access to information. There was also no advertisement placed in the local papers that would inform residents. This approach from the proponent could only be described as an attempt to sneak under the radar. One would only have to wonder what they attempted to avoid by not highlighting the supposed benefits of this plant to the wider community.
The proximity of the proposed bitumen plant is also of concern to the community. The EPA Guidance Note on Separation Distances between Industrial and Sensitive Land Uses gives guidance for the location of Asphalt Plants to be 1000 metres from sensitive land uses. There is considerable argument from the proponent that the this facility is not a “asphalt plant”, which in many ways is quite irrelevant. The proposal will handle hot bitumen (at least 160°C), which has the capacity to generate odours / chemical emissions during its handling and storage. These chemical emissions, as described by Dr Peter Dingle on A Current Affair recently, will contain “dozens of carcinogens”. Perhaps this is one of the reasons the EPA suggests that a 1000 metre buffer zone is appropriate. We have already seen that an “Asphalt Plant” can affect residents that are more than 300 metres away from the facility, and recent information that was discovered indicates that a bitumen emulsion plant can also cause odour emission concerns. In March 2004, the South Australian EPA identified a bitumen emulsion plant as a source of odour, partially as a result of calls from the public, and suspended its operations. The Association has also been informed by members of the public, that the currently run facility in Beckenham emits bitumen odours that are noticeable to nearby residents. There goes the argument that a bitumen emulsion plant is no different than an asphalt plant. There is also the potential production of polymer modified bitumen at the proposed facility, about a quarter of the throughput (3000 tpa). The proponent stated that the polymer modified bitumen’s are processed “hot”, which will have the capacity to generate chemical emissions during their handling, production and storage. There are also a documented explosion (South Australia, 1995) that occurred as a result of re-heating polymer modified bitumen in a mobile tanker. The report into the incident noted that “if this incident had occurred in a populated area, the potential for fatal or serious injury and property damage was a strong possibility”.
The proponent has recently spruiked the environmental benefits of the use of bitumen emulsion. These facts are acknowledged, but are also irrelevant. The environmental benefits of the use of bitumen emulsions at the point of use is offset by the environmental costs and risks at the production facility. The environmental costs are therefore transferred to the residents and the environment that surrounds the proposed facility.
The proponent has also gone to great lengths to demonstrate its commitment to preserving the environment. This must have been a recent revelation, as it did not assist the Bickley Brook in 2005 when it was contaminated as a result of a hydrocarbon spill from the existing facilities on that site, or the acknowledged odours that already emanate from their existing washdown facility. If their commitment to the environment was genuine, these events would not have happened.
The Association requests that you vote against this proposal. There are too many concerns over potential impacts of a bitumen emulsion plant that is located within 100 metres of residential homes.
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