Wynnum QLD 4178March 12, 2004Co-ordinator General
Attention: Project Manager
Lytton Refinery Modifications
Major Projects Facilitation Division
Department of State Development
PO Box 168
Brisbane Qld 4002
CALTEX CLEAN FUELS PROJECT ENVIRONMENTAL IMPACT STATEMENT
As residents of Wynnum North living within 1500 metres of the Caltex Oil Refinery, we have the following concerns about the Caltex Clean Fuels Project – Environmental Impact Statement.
1. An article in the Wynnum Herald, dated 25 February 2004, quotes the Caltex manager, Andrew Brewer, as saying “The EIS stated there were no environmental issues that would prevent the project from proceeding”. The whole article gave the impression that the EIS raised no issues that needed community consideration. No wonder only a handful of people attended the “so called” consultation meeting. The consultation meeting was also held before anyone had a chance to look at the EIS. It is difficult to raise relevant issues without first examining, in detail, the predicted outcomes of the project.
2. The EIS document is presented in such a way that makes it intimidating to the general public. The sheer size is daunting, especially in book form. The maps, which should simplify and enhance the presentation of data, are confusing and extremely difficult to read. Why have two different base maps been used? Why is one map so old that it doesn’t even show the existence of the Port of Brisbane? This attitude of “near enough is good enough” does not adequately meet the requirements for government and big business to inform the public about issues which impact on their health. It certainly is not acceptable to local residents.
3. We are not convinced that Caltex can only achieve the goal of providing cleaner fuels by increasing emissions of sulphur dioxide and nitrous oxides into the local community. Why hasn’t the option of employing available methods to reduce these emissions been evaluated in this EIS? How can the general public comment on a document in which available alternatives have not even been disclosed, let alone discussed?
4. The tone of the Air Quality Report gives the impression it was written by a public relations consultant, not an environmental consultant. The presentation is heavily weighted in favour of the project. Where is the balance? Where is the information about the health effects of nitrous oxides and sulphur dioxide? The inclusion of some of the information readily available on the Queensland EPA website would have provided a much more balanced overview of potential health problems for people who are unaware of their dangers.
5. The Executive Summary is misleading in the context of the rest of the report. It is totally biased towards the advantages of the project, providing great detail about the positive effects of cleaner fuel and glossing over “potential health, biophysical, economic and socio-cultural impacts” (ES1.9.17-14). The statement: “The project has not met significant opposition from the local community” (ES1.10-14) fails to recognise that because of the misleading newspaper article discussed previously, and publicity about cleaner fuels providing a safer environment for all Queenslanders, most residents are still in ignorance of the potential health effects from increased emissions. I personally attended both of the Caltex community consultation meetings, and it wasn’t until I spent two days reading the Air Quality Report that it became clear what the possible repercussions of this project really are.
6. While it is repeatedly highlighted in the Air Quality Report that the emission estimates are conservative and therefore results of air modelling scenarios are also expected to be conservative; the effects of a number of different factors, such as meteorological influences, atmospheric stability, an increase in pollutants from other industries, industrial accidents etc. could combine to meet or even exceed those conservative estimates. While air modelling is obviously a good indicator, it is not a guarantee that local residents will not suffer adverse health effects on a regular basis. Can Caltex guarantee that local residents will not endure additional irritation or symptoms as a result of the Clean Fuels project? If not, then should local residents be asked to meet this cost in terms of health and lifestyle?
7. As residents whose dwelling is located within an area predicted to exceed state and national guidelines for sulphur dioxide emissions, we are not convinced that our quality of life will not be negatively affected. What is Caltex’s plan to mitigate probable health impacts in areas that are likely to exceed regulatory guidelines, especially for those whose health is already frail, such as the elderly people living at Nazareth House? We suggest a pamphlet outlining the effects of sulphur dioxide and how to detect its presence in the air, should be distributed to all residents, at the very least those within areas expected to exceed guideline recommendations. We have experienced smells and irritants that we were unable to identify, which caused concern mainly because we did not know their source, or their potential effect. An ability to recognise sulphur dioxide by smell or symptoms, and some background information about it, may alleviate the concerns of a number of residents. Visible pollution such as that shown in the attached photograph highlights the constant visual and physical assault to which nearby residents are exposed.
8. We were shocked to learn that the stack measurement method of gauging sulphur dioxide emissions was so grossly underestimated. Why haven’t sulphur dioxide emission data been subjected to scrutiny against the mass balance method before now? At what point in the EIS process was it decided to use basic mass balance to estimate SO2 emissions? Is basic mass balance recognised by government authorities as the preferred method of measurement? Before reading this report we were using information provided by the National Pollutant Inventory and verbally by Caltex at their second consultative meeting, to estimate the increased amount of SO2 that would be emitted post Clean Fuels project. The NPI reported Caltex emitted 980,000 kg per year for the 2002-2003 reporting year. Caltex indicated an increase in current SO2 emissions of 18%. I can only describe our reaction as horror, when we discovered the final “conservatively” predicted amount of 3,360 tonnes per year, a huge 242% increase on the NPI figure.
9. Why was such outdated data used to model wind direction and velocity? We could find no explanation for why the period June 1997 – July 1998 was used for the wind rose plot (Figure 7.1.6). Is there no more recent data available? Was this period chosen arbitrarily or was there a specific reason for it?
10. The EIS document contains a number of discrepancies that when combined, add to its aura of inaccuracy. The following examples illustrate our point about discrepancies within this document. “The proposed development at Caltex will result in less than 4% increase in NOx emissions and approximately 18% increase in SO2 emissions from the Caltex refinery” (D1-6.5.2-45). “Emissions of sulphur dioxide from the Caltex site are predicted to increase by approximately 20 percent due to the development” (188.8.131.52-25). Using the “conservative” figures based on mass balance, the final estimated amount of 3,360 tonnes per year means there is a potential increase of 22% per year (D3-1). Well what is it…18%, 20% or 22%? Perhaps it depends to whom you are speaking at the time. Table 7.1.4-14 states current SO2 emissions based on mass balance are 2760 tonnes per year. Figure 1 of appendix D3 states current SO2 emissions based on mass balance are 2750 tonnes per year. All of these minor differences, of which I have listed only a few of those noted, add up to major incredulity. Two percent may seem like a small figure, but to residents this “small figure” represents an additional 55 tonnes of sulphur dioxide being spewed into the air around us every year (that is of course if you use the 2750 figure, if you use the 2760 figure it means an additional 55.2 tonnes per year.). Was this document specifically designed to confuse and create scepticism in readers, or are we again subject to the “near enough is good enough” mentality?
11. Unfortunately, due to time constraints we were unable to assess in detail the other reports contained in the EIS document. However, the number of anomalies and inconsistencies that we have found in this report alone, leads us to believe that there are probably just as many problems in other areas. A very disturbing thought! How can residents trust a document that presents outdated information, has a number of discrepancies, is vague about important issues, and leaves so many questions unanswered?
12. Energex is proposing to construct 110kV overhead power lines between residential properties and the Caltex refinery. There is evidence that high voltage power lines charge pollutant particles, increasing chances they will be deposited in the lungs. When added to information on the Qld EPA website that sulphur dioxide can attach to particles, thereby increasing health risks, this becomes an intolerable possibility. Many residents are extremely concerned, and urgently request that authorities assessing this EIS consider the potential dangers to residents from the combined increase in sulphur dioxide and the proposed high voltage overhead power lines. While most people can accept a “slight” increase in emissions which are able to be monitored by the EPA, for the benefit of the state; an increase in emissions plus the additional threat of charged particles of pollution is too much to ask, and should not be expected of residents who already suffer constant increases in neighbouring industries and their associated problems.13. We have spoken to a large number of people in the local area who are extremely concerned about the Clean Fuels project, who do not have the time to absorb and make a reasonable comment on the information contained within this document. They are relying on those responsible for assessing this EIS to protect their health, the health of their children, their lifestyles and their investment in the state of Queensland.