Capital Recycling Solutions Pty Ltd (a joint venture between Benedict Industries Pty Ltd and Access Trading Company Pty Ltd (trading as Access Recycling) has proposed the development of a waste incineration facility at the former Shell fuel storage facility at 16 Ipswich St in Fyshwick.  CRS prefers to refer to it as the Fyshwick Advanced Recycling, Resource Recovery & Renewable Energy Centre.

Waste that is currently buried at Mugga Lane tip would be diverted to Fyshwick where up to 25% would be recycled, and the remainder burned with the heat used to generate electricity.  NSW material would also be processed.  The facility would also burn sewage sludge.  This it is claimed would reduce greenhouse gas emissions and the amount of waste buried.

The facility would be only 560m from at the Canberra South Motor Park in north Symondston, and 820m from houses in Narrabundah.   A significant number of dwellings in Narrabundah, Causeway and Kingston Foreshores would be within 2 km

A draft Environmental Impact Statement (EIS) must now be prepared for submission to Environment, Planning and Sustainable Development Directorate (EPSDD).  When this has been lodged EPSDD will seek public comments.

The ISCCC is organising a meeting at 7pm on Tuesday 23 August at the Harmonie German Club to provide the community with an opportunity to find out more about the proposal and ask questions.  The Harmonie German Club is at 49 Jerrabomberra Avenue in Narrabundah.

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Watch Capital Recycling Solutions video on the facility

What we know

About 270,000 tonnes of waste that currently goes to the Mugga Lane tip every year would be diverted to the Fyshwick facility, where perhaps 70,000 tonnes of recyclable material would be recovered and the remaining 200,000 tonnes burned.  It is proposed that a further 150,000 tonnes of waste per year be imported from NSW.  The plant would also incinerate sewerage sludge produced by sewerage treatment works operated by Icon Water and Queanbeyan-Palerang Regional Council.

Heat from the plant would be used to generate about 20MW of electricity, about 6% of ACT electricity consumption.  The proponent claims that the facility would reduce landfill volumes (at the Mugga Lane tip in the ACT and at other sites for any NSW waste) by 90% and by incinerating the waste that cannot be recycled significantly reduce greenhouse gas emissions compared with burying this material in landfill where it would slowly decompose.

The facility will have two 32 m high smoke stacks.  The nearest residences are at the Canberra South Motor Park in north Symondston 560m from the facility.  Residences in Mantina St Narrabundah are 820m from the facility.  A significant number of dwellings in Narrabundah, Causeway and Kingston Foreshores would be within 2 km.

The proponent must now prepare a draft Environmental Impact Statement (EIS) for submission to Environment, Planning and Sustainable Development Directorate (EPSDD).  When this has been lodged EPSDD will seek public comments.

The ISCCC, together with some of its constituent residents’ groups, is organising an information meeting at 7pm on 23 August at the Harmonie German Club to provide the community with an opportunity to hear the proponent outline the proposal, and to question the proponent.

As well as reducing the amount of waste that is buried at landfills, reducing methane emissions, and recovering some of the energy in the waste through using the heat of combustion to generate electricity, the proponent claims the following associated benefits for the facility:

  • Rejuvenating the ACT rail infrastructure and reducing traffic congestion on ACT roads;
  • Providing cross border solutions for waste management benefiting the wider Capital Region and surrounding regional areas;
  • Promoting the ACT as a new innovative waste management hub with advanced energy generation, emission, odour control and other environmental technologies;
  • Providing renewable baseload generation that provides grid support and reduces associated transmission and distribution losses;
  • Reducing future associated transmission network augmentation capital expenditure with avoidance of associated cost increases for the electricity network; and
  • Providing a positive impact on the ACT economy by diversifying the economic base and creating 60 fulltime jobs, and other part time jobs, through the development of a new, innovative and growing industry.

A brochure produced by CRS is here (CRS_BROCHURE Final.pdf)

The CRS Scoping Application is at http://www.canberratimes.com.au/cqstatic/gxfp8u/CapitalRecyclingSolutions.pdf

A similar facility has been proposed for western Sydney but has not yet received EPA approval.  See http://www.blacktown.nsw.gov.au/News_and_Events/News/2017/March/Opinion_Against_Energy_from_Waste

Comments

Incinerating the garbage that is currently buried as land fill (at the Mugga Lane tip in the ACT and at other sites for any NSW waste), would undoubtedly dramatically reduce the tonnage and even more the volume of material that is to be buried.  Whether incineration of this material (to produce CO2 and H2O) would produce less overall greenhouse gas warming compared with burying the material, where it will slowly decompose releasing methane (which is converted to CO2 within about 10 years) over a long period, is a matter for expert advice.

The suggestion that the potential delivery of waste by rail to the facility would reduce road traffic seems to be unlikely.  ACT waste material will continue to be delivered by truck with the destination changed from Mugga Lane tip to Fyshwick, so any increase in rail traffic will only eventuate if suppliers of NSW waste choose to deliver it this way.  To the extent that NSW sourced waste material is delivered by truck road traffic will increase.

What we would like to know

What are the minimum and maximum estimates of truck movements to service the facility, including monthly deliveries and removal of ash and recyclables, assuming no material is delivered or removed by rail?

Does the ACT Environmental Protection Agency have the necessary statutory independence, authority, powers, knowledges and resources to adequately monitor the facilities for odour, smoke, dust, noise, particulates, greenhouse gases, other gases (eg H2S, SO2, NOx), arsenic, chromium, mercury, and other heavy metals, toxic and acid residues in the ash, and compliance with all other agreed performance criteria?  Can it provide adequate and reliable baseline data so that we can know how the waste facility has added to these pollutants?

Will the EPA have the power to shut down the facility if it thinks that any one of the agreed emission standards for the facility is breached?

What monitoring will be in place to monitor longer term impacts on the population (something along the lines of the Government’s longitudinal study of residents in Mr Fluffy houses might be desirable)?

For those who would like to do their own reading on the subject we attach a glossary, as not all articles explain what these acronyms mean.

C&I waste       Commercial and Industrial waste
C & D waste   Construction and Demolition waste
Light residues from C & D waste       Presumably the lower density fraction of C&D waste – wood, cardboard and other packaging materials, plaster board
MFR    Material Recovery Facility
MSW   Municipal Solid Waste (trash, garbage, rubbish)
RDF    Refuse Derived Fuel

Below is a list of questions which we believe should be answered before the proposal can proceed.

  1. What is the smallest estimate of truck movements needed to service the facility, including both deliveries of waste and sewage sludge, and removal of ash and recyclables?
  2. What is the largest estimate of such truck movements, assuming no supplier chooses to deliver or remove material by rail?
  3. Does the ACT have legislation that covers airborne pollution, and, if not, will it be a precondition that the ACT adopts legislation similar to that of NSW?
  4. Will there be a fully independent body charged with monitoring the facilities for odour, smoke, dust, noise, particulates, greenhouse gases, other gases (eg H2S, SO2), arsenic, chromium, dioxin, furans, heavy metal residue in the ash, acid residues in the ash, and compliance with all other agreed performance criteria?
  5. Who will meet the costs of monitoring and ensuring compliance – the proponent, or the ACT taxpayer?
  6. Can you give a rough estimate of the compliance budget and some insight as to how this was derived – eg no of employees, number of monitoring stations, frequency of sampling, costs of analysis, and the timeframes between sampling and response.
  7. How often will compliance tests be carried out on emissions, and will results be published in real time? Or will compliance be based on averages over time so that excessive levels are masked by inclusion of lower levels during times of lower incineration?
  8. Will an independent inspector have the power to shut down the facility if it is considered that any one of these standards has been breached?
  9. If this independent monitor is to be the ACT Environment Protection Authority, would this body have adequate independence, given that it is part of the Chief Minister, Treasury and Economic Development portfolio?
  10. Given that the proposal would introduce a range of new challenges well beyond anything that the existing EPA has to deal with, would the EPA have adequate staff, resources, skills and knowledge to design an appropriate monitoring program, let alone administer such a program?
  11. Given these challenges, should the Government consider outsourcing the monitoring program, either to the EPA of a larger state with the appropriate resources and skills, such as NSW or Victoria, or a commercial third party, eg CSIRO, a University or consortium of universities, or some company or consortium of companies that specialises in supplying such services (to mining companies, for instance)?
  12. What monitoring will be in place to monitor longer term impacts on the population (something along the lines of the Governments longitudinal study of residents in Mr Fluffy houses might be desirable)?
  13. This is believed to be the first incinerator to burn human sewage sludge in Australia. How can the proponent guarantee that the facility will not emit obnoxious odours detectable by surrounding lessees and possibly as far as the Fyshwick markets and Kingston Railway station?
  14. What is the maximum amount of paper, cardboard and other flammable materials that are to be stored at the facility before incineration?
  15. What happens if there is a fire at the facility? What is the worst case in terms of toxic emissions?
  16. What would the extra costs of the proposal be if the facility were constructed at
    1. Williamsdale ACT?
    2. Tarago NSW?
  17. What is the price per kWh that CRS expects to receive from it sale of electricity to ActewAGL? If this is more than the feed in tariff offered to private citizens, is CRS not being subsidised by the ACT Government?
  18. What does CRS expect to be paid to receive
    1. NSW waste and
    2. NSW sewage sludge?
  19. What does CRS expect to be paid to receive
    1. ACT waste and
    2. CT sewage sludge?
  20. Would the establishment of this facility threaten the establishment of a similar facility in NSW?
  21. What would be the annual saving to the ACT Government of any estimated reduction in landfill?
  22. What are the current ambient levels of odour, smoke, dust, noise, particulates, greenhouse gases, other gases (eg H2S, SO2), arsenic, chromium, dioxin, and furans at Hume, Fyshwick, Manuka, and Civic, and how are these levels expected to change at each of the localities specified following the establishment of the proposed Waste Incinerator in Fyshwick?
  23. ow does the projected level of various pollutants following the establishment of the proposed Fyshwick Waste Incinerator compare with the current level of pollutants attributable to wood burning for domestic heating?
  24. Would any new limits on various pollutants introduced as a result of the proposed Fyshwick Waste Incinerator apply to pollutants already present due to current activities such as wood burning for heating?
  25. How would projected truck movements to and from the proposed Fyshwick Waste Incinerator compare with existing truck traffic to the Mugga Lane tip and any other waste disposal site in Canberra (please specify the location of any such).
  26. Would the establishment of the proposed Fyshwick Waste Incinerator increase or decrease truck traffic through inner south Canberra, and by how much?
  27. Are there any recent baseline studies of the composition of Canberra’s Municipal Solid Waste (MSW), Commercial and Industrial waste (C&I waste) and light residues from Construction and Demolition waste (C & D waste) (cardboard and other packaging, timber and plasterboard offcuts).
  28. How is the introduction of container deposit legislation expected to influence the composition of MSW and C&I waste?
  29. Can you name similar waste incineration facilities overseas with much the same nameplate capacity located within an urban area?
  30. How do the feedstock profiles of these facilities compare with those of Canberra’s mix of MSW, C&I and C&D waste?
  31. How do you propose to totally exclude plasterboard (mainly composed of Calcium Sulphate and incinerates to Suphur Dioxide) from the incinerator and how will this impact on the viability of the proposal?
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