The Rivermouth Action Group Inc Submission
Unfortunately considerable text formating is lost from the Submission as a web page.
15 March, 2004
Attention: Project Manager
Caltex Lytton Refinery Clean Fuel Project
Major Projects Facility Division
Department of State Development
P.O. Box 168
Brisbane, Albert Street Qld 4002
RE: Caltex Clean Fuels project E.I.S.
We appreciate the opportunity to be able to make our submission on Caltex’s Clean Fuel Project at this time.
We must stress at the beginning of our submission that the base maps used in tables contained in the EIS depiction air pollution are anything up to 40 years old.
Figure 7.1.7 etc are old map most probably in excess of 30 years old. The maps do not depict the Port of Brisbane, Whyte Island is still an Island, Crab Creek is still Crab Creek (not filled in, mangroves not dead as yet), Fisherman Islands are still islands, No port road, no port rail line, no bridge to port . No Gateway Bridge, No Gateway Road. No new Brisbane Airport and with the old Brisbane Airport Runway still showing.
Many thousand of new houses have been built in the Wynnum North/Wynnum/Wynnum West area since these maps contained within the E.I.S. were originally produced. How can a reader who is not conversant with the area hope to know just how old the mapping is when they make their decisions. Maybe a person making a decision would believe that there are no or only a few homes in a particular area when in fact houses are almost touching each other street after street.
Our group believes that The Department of State Development and the Brisbane City Council should reject this application and demand that it be resubmitted making sure that all of the maps contained within Caltex’s E.I.S. are up to date and relevant to 2002/3 at least.
We request that all further Terms of Reference issued/ approved by Department of State Development and the Environment Department contain a clause which requires all mapping to be latest available at the time of E.I.S. production.
We also have concerns that the air quality investigation/modelling was carried out using flawed contour mapping. The area of concern is the quarry area (175 PRITCHARD ST LYTTON Lot: 2 Plan: RP176265 which was quarried for use in the Port Drive about 1980) northern edge of the North Point Estate Wynnum. See our Attachment 1.&Attachment 6 Attachment taken from Pritchard Street to the south.
Attachment 7 shows the amount of housing development just south of Caltex.
Also the contours on 117 Sandy Camp Road Wynnum West Lot 1 RP 105333. See our Attachment 4 The side of the hill which existed was bulldozed many years ago yet still appears on BCC mapping as their contour base as at 1980.
Reference that incorrect land contours were used is contained in Chapter 7 Section 22.214.171.124 Para 1. Brisbane City Council BIMAP used.
This concern is highlighted by figure 7.1.10 where the pocket of SO2 appears to be partly on a ridge north and south of Sibley Road and not in the valley. Yes we believe that Sulphur Dioxide is a problem in the community but there is no direct contour linkage of the excessive level to a refinery. How does the Sulphur Dioxide arrive at the mentioned area shown south of the Caltex refinery (with a reading of 570 enclosed within an ellipse of 400 ug/m3) site by being blown in the breeze or as a fall out from whose chimney stack? See our Attachment 2 and Attachment 3
Figure 7.1.11 shows a pollution contour to the south of Caltex. If the map is examined the reader may be forgiven for believing that there are no houses within the red 100 ug/m3 contour around the Caltex site. An inspection of a current street directory will prove otherwise. Just not good enough Caltex!
See our Attachment 5.
We notice in:
Chapter 1 section 1.4.2 page 1-4 para 1 that, “Caltex is committed to conducting its activities in a way that protects the environment and the health and safety of its employees, customers and the community.”
Our comment is that oil refineries appear to do little to reduce the impact of their industry on residents or the environment unless legislation is enacted.
We do concede however that as time has passed newer equipment has become available which allow better control of emissions.
Chapter 1 section 1 page 1-6 para 10 that, “Reduce our environmental impact: Continually improve processes and products to conserve company and natural resources, increase energy efficiency, prevent pollution and minimise waste.”
1 Why was legislation necessary to reduce the sulphur content in Caltex diesel fuels?
2 Why was legislation necessary to reduce benzene in petrol?
3 Why was legislation necessary to reduce vapour pressure in petrol a few years ago.
4 Why was legislation necessary to remove lead from petrol.
5 Why does the EPA have set limits of emissions if Caltex Policy is adhered to by Caltex.
Chapter 2 section 2.1 Page 2-1 Para 2 Sentence 5, “As benzene is recognised as an air toxic, ....”
Comment: This fact is well documented but no reduction until legislation is enforced.
Chapter 2 section 2.2.1 page 2-5 para 2
The text deals with the removal of sulphur from the diesel but not its collection and removal from the effluent stream. An increase of SO2 is to be released into the atmosphere by Caltex.
Chapter 3 section 3.6 page 3-8
Lists Environmental Relevant Activities under taken at Caltex Refinery at Lytton.
The question needs to be asked has Caltex been prosecuted for any breaches of their licences condition or are the emission allowed just increased to allow for the emission released?
I have been at meetings when residents have raised this issue about noise levels and have said that the Caltex were in breach of their licence conditions on noise levels at their home. Caltex reply was that they had undertaken expensive modification to reduce the noise and further noise investigation were continuing.
Caltex state that their plant whenever possible runs at a steady rate and therefore the noise emitted is somewhat always constant. What is not constant is the wind direction and strength and cloud cover which can cause temperature inversion which can increases the noise levels at nearby homes.
I have attended several training sessions on the use of our Group’s Noise Level Meter with B & K and remember plainly being told that the noise reading from source must be checked down wind for exceedences.
Then when the wind direction blows from Caltex to nearby residents the noise level should not be exceeding the allowable limits.
Chapter 4 section 126.96.36.199 Para 1 Removal of hydrogen sulphide and its addition to fuel gas to be burnt as furnace fuel, thus emitting sulphur dioxide into the atmosphere.
Part of our submission is that Caltex is to convert all their boilers to use natural gas, thus removing the sulphur emission from the boilers chimneys stacks.
After all this is a Clean Fuels Project and Caltex should be using clean boiler fuels in their refinery.
The fuel oil and fuel gas should no longer be used especially when they will contain increased sulphur to be burnt in boilers and then vented to atmosphere without any sulphur reduction.
Caltex appears not to have a sulphur recovery plant.
We cannot remember having read anywhere in the EIS where Sulphur will be removed or recovered but only burnt.
Without such equipment sulphur emission will continue to increase as with this modification, We have all heard of Acid Rain. We must demand that Caltex install a sulphur extraction plant with out delay. Whether it is financially viable or not is not of concern. What is of real concern is the health of Brisbane residents and the surrounding environment.
Sulphur Dioxide molecules have been shown to attach them selves to fine particles in the atmosphere and are therefore a major health hazard which can be reduced by Caltex complying with their own stated policy. Source EPA QLD web site.
Chapter 7 Section 7.1.1 page 7-1 para 3
Caltex state, “The proposed Clean Fuels Project (CFP) will result in less particulates, sulphur dioxide and benzene (a VOC) being emitted from vehicles,”
If particulate emission are increased with higher sulphur content in fuels then the increased burning of fuel oil and fuel gas in boilers related with the increased need for steam at Caltex refinery will also result in an increase of particulates and SO2.
To offset the reduction of SO2 and Benzene in south east Queensland airshed the resident of Wynnum are being told that they will as a result suffer more polluted air to breathe in their homes.
This is just not good enough. When B.P. were proposing their co-generation plant they also started out with the same scenario. Less pollution in the wider community and more pollution emitted locally at the refinery.
Our group made a submission to BCC and a copy to B.P. which was based on information gained from the E.I.S. on Gibson Island Power proposed Co-generation Power Plant on Gibson Island and subsequent F.O.I on Brisbane City Council Files. We were subsequently informed by a staff employee of the B.P. refinery that our submission (which we gave them a copy of) resulted in a rethink and lowering of the B.P. refineries emissions with final design.
Chapter 7 Section 7.1.1 page 7-1 dot point 4
“Use of Particulate filters and other pollution controls devices on vehicles which require low levels of sulphur to work efficiently.”
Nowhere does Caltex suggest that they are taking any such modifications to their plant or equipment to reduce their emissions. They are not even reducing the sulphur in their fuel oil and most probably will increase as a result of removing the sulphur from the diesel fuel. The sulphur must end up somewhere but should not be burnt.
Caltex instead will be increasing their emissions especially of sulphur dioxide, NOx and particulate matter..
Chapter 7 Section 7.1.1 page 7-1 last para
“The air dispersion modelling predicts that there will be a slight increased impact from SO2 emissions from the refinery.”
So what if the “dispersion models show a ‘slight’ increase”. The fact that 18% increase of SO2 is forecast and SO2 is the basis for acid rain and attaches to fine particles which are a well documented health hazards. The Caltex proposal is just not good enough in 2004 especially when it does not comply with their own stated policy.
Chapter 7 Section 188.8.131.52 page 7-5 para 4
This paragraph deals with shipping fuels and the displacement of vapours whilst filling empty cargo tanks. In California best practise is to have vapour recovery system even when fill the car fuel tank. Why is Caltex not using best practise when filling shipping cargo tanks?
Chapter 7 Section 184.108.40.206 page 7-8 para 1
This section mentions the use of tall stacks to disperse pollutants. This just meant that they travel further sometimes into residential areas. But they still pollute the local airshed. I have heard it said. “Ths solution to pollution is dilution” But you now read the solution to pollution is dispersion from tall stacks. The trouble is that either way the pollution has been released and if will effect the airshed and local residents and the environment
The need for Caltex Refinery upgrade is to reduce pollution in the South East Queensland Airshed. Do not allow this to happen by polluting the resident at Wynnum any more than at present.
Chapter 7 Section 220.127.116.11 page 7-8 para 3
Since 1996 fugitive emissions have been reduced by 85%. Just how much above Caltex Environmental Licence conditions were the emissions then? Why did Caltex wait until 1996 to start their stated reduction?
When did Caltex’s policy of “Reduce our Environmental Impact” come into existence?
Chapter 7 Section 18.104.22.168 page 7-10 para last
“The remainder (sulphur) accumulates in the fuel gas system”
This Caltex petroleum product needs a sulphur extraction. No figure is given for the sulphur content of this product (fuel gas). Caltex bunker oil supplied to the shipping industry is not allowed to exceed 4% sulphur (MARPOL limit) There was some discussion that the sulphur level of bunker fuel used by large ship was to be reduced. If the reader/s of our submission were to look at the National Pollution Inventory data for the Fisherman Islands Port for sulphur release from shipping they will be even more concerned about the oil refineries emissions of SO2 as a regional issue. We feel that the accumulative effect of Sulphur Dioxide is not being addressed very well in this area of Brisbane.
When the sulphur content in diesel is required to be reduced even further will Wynnum resident then be exposed to an even greater emission of sulphur Dioxide etc in their own homes?
Chapter 7 Section 22.214.171.124 page 7-11 para last
“No test data is available to estimate emissions of benzene from point sources”.
Chapter 7 Section 126.96.36.199 page 7-17 para 1
“Based on this information, ship loading emissions are the dominant fugitive source, accounting for about 72 percent of fugitive benzene emissions.”
That is (page 7-16 para 2) 99 loading each of 15 hours duration of ship loading produce 72% of Benzene fugitive emissions 1,237 kg. This issue has not been addressed . Why we ask? Cannot the vapours be trapped and reused?
Chapter 7 Section 188.8.131.52 page 7-17 first dot point
A 22 % increase in SO2 emissions due to higher sulphur in fuel gas.
Chapter 7 Section 184.108.40.206 page 7-17 second dot point
“A 30% increase in SO2 (on top of the 22%) and NOx emissions from auxiliary boilers (31F1 and 31F2)”
Caltex have been forced to reduce sulphur in their fuel but now want to just burn it locally to dispose of it. Just not good enough Caltex.
Chapter 7 Section 220.127.116.11 page 7-17 last para
Small increase in particulate emissions from auxiliary boilers but likely to be less than 5% resulting in an increase of 0.5 % in overall refinery PM10 emissions.
If 0.5% increase of PM10 is not worth worrying about then Caltex can give our Group 0.5% of their after tax profit.
Chapter 7 Section 18.104.22.168 page 7-24 para 3
“It is important to note that the proposed Clean fuels Project will not result in an increase emissions of PM10.”
Which statement is correct? No increase or 0.5% increase?
Chapter 7 Section 22.214.171.124 page 7-23 para 2
“As is evident from Figure 7.1.5, the Eagle Farm monitoring station is the only EPA managed station within close proximity to the refinery, located just a few kilometres to the west of the Caltex site.”
Just a few kilometres west is actually 5.8 km W.S.W. (247°) of Caltex Refinery.
Chapter 7 Section 126.96.36.199 page 7-25
Isn’t that just wonderful!! A Clean Fuel Project that delivers more local air pollution in what has been documented as the worst possible area of Brisbane to emit such pollutants. We refer to the Peer Review carried out for the Brisbane City Council on the E.I.S. for the proposed Gibson Island Cogeneration Plant by Dr Quintrille ??(spelling) and Dr Bofinger of the Q.U.T several years ago.
We believe that a quick phone call to Dr David Wainwright of the Queensland EPA air pollution section (Ph 07 3896 9239 or Mobile 0418 725 540) will better inform any reader that proposed increases of air pollution are of a real detriment to both the local community and the regional air shed regardless of any assertion made in Caltex’s EIS
Because Eagle Farm Air Monitoring station is quoted for air Pollution in the region other factors need to be taken into account.
Many of the pollutants may have fallen out before they have reached the Eagle Farm monitoring station. Others air pollutants would have dispersed because the wind in that direction is of a higher speed and just 5% of the wind actually blow in the direction of Eagle Farm Monitoring Station from Caltex refinery.
Eagle Farm Monitoring station is some 5.8 Km away from Caltex at 247 deg West South West on flat land about 3.6 AHD
Residents at the North Point Estate are just 1.3 km away from Caltex at between 137 and 175 degrees (south east to almost due south). The refinery is about 4 metres AHD and homes at North Point are on elevated land from 17 metres to 35 metres AHD.
There has been no real testing of air pollution at the 17 metres AHD level of houses at North Point only at a higher of level of over 40 metres AHD. This leaves a massive, untested, fall out zone between the Caltex refinery and to where the Air Monitoring equipment which was situated at Nazareth House. Caltex’s EIS state that the fall out zone where any Hydrogen Fluoride would be of a any concern would be within their boundary. So it is obvious that only some of the emission from Caltex are expected to have reached the air monitoring station and would have fallen out either on Caltex land or on land including residential properties before reaching the then air monitoring station.
If this is the case how much of Caltex Refinery would ever reach the Eagle Farm Air monitor due to dispersion (more higher winds in this direction), level of monitoring air receptor and depositation of pollutants in the 5.8 km.? There needs to be a more realistic monitoring of air quality at residential levels at North Point, Wynnum.
How does the increased emissions comply with SEQRAQS?
Chapter 7 Section 188.8.131.52 page 7-25 para 2
“This together with an increase in emissions of oxides of nitrogen of just 4%, PM10 and carbon monoxide are unchanged and benzene emissions will decrease, means that the net impact upon marine life and vegetation is unlikely to be significantly altered by Clean Fuels project.”
PM10 is up 0.5%.
SO2 is up 18 to 22% at refinery.
Clean Fuel Project need to start at the Refinery with using clean fuels at the refinery not emitting more air pollutants.
Chapter 7 Section 184.108.40.206 page 7-27
The Caltex Clean Fuel Project does not meet the SEQRAQS 1999 priorities.
Increased level of 4% NOx emissions
Increased level of 0.5% PM10 emissions
Increased level of 18% SO2 emissions
Continuing release of Benzene whilst loading shipping tankers.
Past admission that Caltex VOC emissions were in excess of 8,000 kg per day.
Chapter 7 Section 7.1.5 ?? page 7-29 para 1
WHY IS THE NPI DATA BASE FOR THE YEAR 2000 USED IN A DECEMBER 2003 REPORT?
Chapter 7 Section 220.127.116.11 page 7-30 Table 7.1.11
No distances of “Sensitive Receptors” were supplied to advise readers.
Receptors selective selected.
No mention of “Nazareth House” being a Nursing home just1.5 km south (167deg) but only as a monitoring station. The nursing home has 130 beds and about 130 staff
The mention of St Laurence College as a Sensitive Receptor whereas it no longer exists.
No mention of the old aged care facility of Pleasantville (Blue Care) with 158 beds with about 300 staff and is less than 3 km south (195deg ) on Sibley Road Wynnum
No mention of Wynnum North State School 2 km south (153 deg) with 570 students and 40 staff.
No mention of Wynnum North High School 2.5 km south (170 deg) with 680 students and 100 staff.
No mention of the two nursing homes at Wynnum Road Wynnum North adjoining the high school nor the Moreton Bay Nursing Home at New Lindum Road which has facilities for 250 beds or the large Housing Commission complex housing complex of 53 units and the Palm Springs retirement village has over 70 units at Carmichael Court Wynnum West nor of the Wynnum West State School of 502 students and 50 staff.
Chapter 7 Section 18.104.22.168 page 7-32
“The guide line level (SO2)was exceeded, however, in the region centred over the BP refinery, and also in a very small region located approximately 3 km south of the Caltex refinery,”
A very small region which would contain in excess of 500 homes at this time, a large aged care facility called the Moreton Bay Nursing Home, the Wynnum West State Primary School, and further developing housing estates including a housing estate under development application by Clem Jones, Brisbane former Lord Mayor. You can count them if you like as we have done.
Is it to be a Caltex Clean Fuels Project resulting in toxic polluted residential suburbs with the aged care facilities in the firing line?
Chapter 7 table 7.1.11
We comment that the pollution area is actually over existing North Point housing and not over vacant land as depicted in the figure map 7.1.11 shows.
Chapter 7 table 7.1.19 page 7-38
We suggest to the State Development that they check with EPA air monitoring Chief of Staff, Dr David Wainwright to find out if Benzene (as a separate pollutant) was actually measured at the Nazareth House monitoring Station. We were informed at the time that the monitoring station was not calibrated for Benzene but VOCs may have been measured. We also refer to Appendix D1 page 39 last paragraph. Benzene not monitored at Wynnum. Yet on page 77 of Appendix D says that Benzene monitoring was done at Nazareth House during May 2000 to May 2002.
This is very confusing as to what was and was not monitored at Nazareth House.
Ground levels of Benzene are mentioned. The EPA air monitoring station that was in place at Nazareth House was not at ground level. And furthermore was on top of the highest ground in the area as well. The light beam was projected from a upper floor window across a natural depression if my memory is correct to a trailer in the open paddock near Wynnum North Road. Not exactly the ground level of the surround houses or any industries.
Question not answered in EIS was just how Caltex’s Benzene share was decided upon as part of the Benzene readings reportedly taken at the Nazareth House station. How was the wind direction and speed taken into account when this calculation made?
We wonder why only Sulphur Dioxide is the only pollutant which enters the residential area? Do all other air pollutants fall out of the sky before they reach the residential homes or are they just so diluted before that reach them as to not count? Some pollutants shown in the modelling appear to be deposited everywhere else but residential areas. Why is this?
Chapter 7 table 7.1.8 page 7-43
“Locally, around the refinery, air modelling indicates that the Clean Fuels Project has no major effects on the surrounding airshed.”
How can that be true when the Sulphur Dioxide emissions are to increase by 18% and particulates up by.0.5% and an increase NOx emissions which has been described in previous air quality reports as the worst place in Brisbane to increase air emissions.
It has been said that ‘Moreton Bay is dying the death of a thousand cuts’, then we suggest that ‘the local residents are to die from a thousand small increases of air pollution’. Not much has been said about the accumulative effect of the surrounding industries which we are concerned about and believe should be taken into account.
Chapter 7 Section 22.214.171.124 page 7-93
We have concern that water discharges from the Caltex refinery has been exceeding some of their limits. Knowing the EPA one may think that the limit would have been set at level that would not be exceeded but this is apparently not correct and Caltex have been unable to comply with their waste water discharge licence conditions for mercury. All that is said is that they are reviewing technology. Isn’t that just wonderful. No mention of when new equipment will be obtained or installed or made operational.
Chapter 7 Section 7.10.1 page 7-112 para 4
“The Clean Fuels Project will assist to maintain the positive interaction between Caltex and the adjacent community and not cause any untoward negative Socio Economic effect in those areas.”
We don’t believe anything could be further from the truth.
Our reason for this statement is as follows:
Energex has recently announced their intention to install a dual 110kv power line from the new Lytton substation to Fisherman Islands on 30 metre concrete posts.
The community’s attention has been focussed on the effects of major power lines and their health effects in polluted areas. Research has revealed small particles in the air become electrically charged particles when they come in contact in the field surrounding high tension power lines and stay trapped until a breeze of sufficient strength releases them from the electric field. The EPA QLD own web site admits that Sulphur Dioxide will attached itself to fine airborne particles.
Having been told at a public meeting that Sulphur Dioxide will be an increased emission from Caltex as a result of the Clean Fuels Project the local resident have formed a committee to represent their interests. Contact has been made with real estate agents and valuers and the residents were told that they were set to loose thousands of dollars value of their property values should the above ground power line be installed.
Then on top of that to be aware of health risks of the fine particles charged or not they are concerned as we are that the Clean Fuels Project does nothing for the residents of Wynnum North except further pollute them.
We believe that Caltex will find themselves up against this new community group which will demand Best Practise from Caltex Refinery in all aspects.
From what we have seen so far the residents of North Point are house proud and many have professional jobs, both work in many cases in well paid jobs and those who have retired there have substantial capital invested in their homes.
We believe that they, the North Point residents, are now ready to stand up and fight as a community to achieve better outcomes and Best Practise by industry and Government departments and corporations alike for their community and themselves.
We have all seen the way in which fuel supply companies manipulate petrol and diesel fuel prices on an hour to hour basis seven days a week. Caltex cannot even suggest that the necessary upgrades required to their refinery are beyond their financial resources. They supply 55% of Queensland fuel product not to forget supply into northern New South Wales. Even exporting fuel to New Zealand.
The amount of discount presently offered to Woolworth shoppers and what Shell is offering through Coles food stores must amount to a tidy sum each week. Now we read in the weekend paper that a 10 cents a litre discount if purchases are over $50.00 in a North Queensland town.
I believe that we don’t mind paying for Clean Green Fuel especially when it is produced in a Clean Green Refinery. (A bit hard to imagine a clean green refinery) Maybe a World’s best Practise Refinery maybe more appropriate to use.
Chapter 7 Section 7.10.4 page 7-126 table 7.10.7
How can it be suggested that with a eighteen percent increase in Sulphur Dioxide that odours will not increase?
We question their compliance with noise levels in compliance especially during north-west wind blowing.
Chapter 7 Section 126.96.36.199 page 144 Air Emissions and Quality
Our comment on this section with what about Acid Rain?
Page 145 para 4 second sentence. Yes there is a lack of trees in this area due to it being a major residential area.
Chapter 8 page 8-8
We hope that the use of noise sensitive place in this table refers to the residents at North Point and just not those Noise sensitive receptors in previous sections.
Chapter 8 page 8-13 last item in table
Is this joint modelling in place at this time? If so, where are the results of that modelling? Why were they not included in this EIS? Does B.P. Refinery concur with the Sulphur Dioxide modelling in this EIS? Does B.P. concur with how much Caltex admits to their own emissions and do B.P agree with stated B.P. contribution to the emission mentioned in this EIS
Chapter 8 page 8-14
Contains a table reporting maximum Sulphur Dioxide release amount as 6,389 tonnes per year yet Chapter 7 Section 188.8.131.52 refers to a bubble licence of 7,389 tonnes per year.
Which is correct is it 6,389 or 7,389 tonnes per year or has the EPA already granted a new licence to an extra 1,000 tonnes of Sulphur Dioxide per year before the Queensland Government or Brisbane City Council grants their approvals?
Chapter 9 Section 9.1 page 9-1
“Principles of Ecologically Sustainable Development”
Basically Caltex intends to supply petrol and diesel to an ever increasing market in Queensland. South East Queensland is where most of that market will be as the Gold Coast joins the Sunshine Coast through Brisbane and west to Toowoomba.
As for capital city in Australia, Brisbane has the highest potential for high Ozone levels in Australia. This is due to topography surrounding Brisbane in South East Queensland. Much has been written about this known factor. The residents of Sydney refer to their city as the Basin in an effort to raise the issue of air pollution which traps air pollution between the Blue Mountains in the west the Pacific Ocean to the east and produces Ozone which is responsible for many premature deaths each year of the elderly and those with reduced lung capacity for one reason or another or just allergic to Ozone.
We cannot believe that a Company would submit an EIS suggesting that even more Oxides of Nitrogen and Sulphur Dioxide in Brisbane’s airshed was acceptable when their product which is being ever increasingly used produces even more air pollution in South East Queensland’s airshed.
We have not heard of any oil refineries going broke. What we do see is petrol prices being manipulated on an hourly basis. If the local oil refinery needs more money I am certain petrol will rise to accommodate and not fall back again until they are good and ready.
Terms of Reference page 17 of 28
“Examine the affects of adverse conditions (e.g. inversions), mixing heights and sea breeze conditions on air impacts.”
Section 184.108.40.206 nowhere within the EIS do I remember seeing any reference to “inversions” and if that is correct Caltex has not complied with their terms of reference.
State Development need to address the absence of information requested in the Terms of Reference relating to the first paragraph headed 220.127.116.11 Air Quality.
We would suggest that “inversions” (meteorological events) are not addressed within the EIS. A word search of both section 7.1 and 7.2 and appendices D & E for both the words “inversion” and “low cloud” proved negative.
We suggest that is difficult to examine the affects of inversion events without even using the word “inversions”.
We should have seen inversion mentioned in the noise section and how much increased noise residents may experience in such an event.
We should have seen modelling of the different gases in inversion events and how resident may be effected during such events. But none were contained within the EIS.
Mixing heights also appears to be absent from the EIS.
“Provide records of any complaints made in the area regarding air quality.”
Does this only mean how many in each year or when and what the complaint was?
Appendix D page 41 para 2 second last sentence. Does this sentence infer that the sulphur removed from the diesel and not burnt in vehicles will now be burnt in Caltex’s boilers for local emissions at Lytton? Because the removal of sulphur from the diesel will make no difference to airshed.
Appendix D page 47 last para.
We have concerns about the Air Report author/s and would suggest that they contact Dr David Wainwright of the Qld EPA and discuss Photochemical Smog and its formation and movement in the South East Queensland Airshed with him.
We also have concern with the air modelling results. Contours show resemblance to wind patterns in wind rose included. Patterns do not take into account topography of the area. Patterns of air pollution for B.P. differ to Caltex and Incitec. E.g. Appendix D page 69 figure 12. Isn’t it wonderful how the 200 contour misses North Point Estate at Wynnum North but appears in Wynnum West with no connection on a ridge and into a valley of the head water of what would be Lindum Creek. Incitec fertilisers plume is only elongated and only south of the plant. If this SO2 emission is from B.P. then is the plume at Wynnum West from Caltex and if so where is the higher level contour at Caltex?
The particulates emitted from Caltex were never described as to their actual origin or composition. How much was emitted from stacks that could be fitted with electrostatic precipitators or other devices to reduce/stop their emission? How much was wind blown dust etc from the site?
The emissions of fluorides into the atmosphere and the storage of spent neutralised fluoride compounds and their impact on the environment.
We conclude our submission suggesting that the Terms of Reference were not complied with. Flaws exist in the air pollution modelling. Mapping is out dated as is the topography on land adjoining the Caltex refinery. The question about the levels of Benzene emitted from Caltex, Sulphur Dioxide etc.
We request that further studies be carried out be an independent specialist with at least a Peer Review of this EIS by known and acknowledged experts in the Brisbane’s Airshed. Monitoring be carried to calibrate modelling at actual ground level of houses.
We believe that Caltex Clean Fuel Project should start with a cleanup within their own refinery fuel gas and oil systems and compliance with their stated policy.
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