March 22, 2004
Attention: Project Manager
– Lytton Refinery Modifications
Major Projects facilitation Division
Department of State Development
P.O. Box 168
BRISBANE, ALBERT STREET Q. 4002
RE: SUBMISSION - CALTEX CLEAN FUELS PROJECT – E.I.S. STATEMENT
We hereby make the following submissions in relation to the above Caltex project at Lytton.
1. It appears that there will be an increase in emissions from the modifications to the plant. These include small particles, Sulphur Dioxide Carbon Monoxide and Nitrous Oxide Current emissions are substantial. The aim should be to reduce emissions not increase them.
2. In the air quality impact study there are a number of assumptions and “guesstimates”. For instance: “Note that no clear correlation could be identified between monitored stack emissions rates and operational heat duties at the time of testing……….due to ……incorrect records of heat duties during each test; and or, ……..other factors associated with refinery operations…….”
3. Emission increase of the stated 18% will mean extra thousands of tonnes annually over our neighbourhood. It is noted that Wynnum has about 4 times the amount of airborne pollution than neighbouring Manly all due to Caltex emissions. 18% more is intolerable.
4. Increases in Sulphur Dioxide emissions are health dangerous as they adhere to solid particles and so are more likely to come into contact with humans and animals rather than disperse into the atmosphere.
5. Increased sulphur emissions in our neighbourhood is not to be balanced against lower levels in the wider community. We are Caltex’ neighbours and are not to be sacrificed for others good. Stated point sources of sulphur dioxide show increases of 22% and yet another of 30% on top of the 22% to give an overall increase of 18%. A similar scenario is for benzene levels. Caltex plans to reduce levels for the wider community by giving it to us. IT IS JUST NOT ACCEPTABLE.
6. NO INCREASE IN ANY OF THESE EMISSIONS SHOULD BE ALLOWED. CALTEX MUST FIND WAYS TO REDUCE EMISSIONS OVER A REASONABLE TIMEFRAME AND MUST NOT BE ALLOWED TO INCREASE ANY. STRICT ENVIRONMENTAL CONTROL MUST BE ESTABLISHED.
7. Energex is proposing to build a 110kV dual main line to the Port of Brisbane on high poles varying from 20m to 30m high. We have heard of scientific studies that look at air borne particles carried on the wind that are charged by the corona around high voltage lines and the resultant particles when breathed in tend to stick by electrostatic attraction to the persons lungs and this is linked to an increase in lung and other cancers. Sulphur dioxide molecules attaching to the particles greatly exacerbate the risk. We believe that the risk of this happening is an intolerant risk to Caltex and so as well as reducing emissions Caltex should also vigorously persuade Energex to underground this power line that would be between the Caltex plant and our residences (and schools etc.).
8. As well as particles and gasses of emission we also experience odours, noise and vibrations from the operations from time to time. These also need reduction or, better, elimination.
9. Also we dispute that we fall into areas classified as R4. There is a buffer between the industrial areas and the residential ones that make our areas no more than R3 with a night time noise level of 40dB(A) – far less than the 55 sought by Caltex.
10. We dispute the claim that “Sound emissions from the refinery are generally constant in level” At least from our residences there seems to be substantial variance and we think that this is indicated in Figure 2 of the Noise Impact Assessment. Some of the graphs are very difficult to read. These need to be explained more fully. The individual scatters do not seem to correlate with the lines on the graphs.
11. The assumption that a 90% time weighted noise level that disallows any noise that doesn’t endure for at least 9 minutes out of a recorded 10 is a subterfuge that should be disallowed.
12. There should be no allowance for a 5dB(A) allowable value significant deterioration. In fact there needs to be constant evaluation and audit to monitor noise emissions below allowable values. The values should be 0/- and not +/-.
13. The Figure 5 shows noise contours predicted for calm conditions. In fact we need to see contours for various velocities of a northerly wind as this is the problem time as far as residents who will be affected.
14. The recording carried out at 8 Auriga Court would be attenuated by the surrounding and intervening houses. In the past when recordings were being made they were often from our driveway in Constellation Way – a more appropriate site.
15. The conclusions made are totally hypothetical and need to be struck out.
16. There is nothing about vibration effects on residents in the report. Rattling windows and doors is a regular event when the refinery is thumping away. Over recent years there has been improvement of which we are glad. Constant improvement is welcome. Worsening is not.
17. Off-site risk lists Hydrogen Fluoride leakage as the major risk, with L.P.G. leaks and fire as a lesser danger. No mention is made of explosion or terrorist threats. This was mentioned at a recent Caltex meeting but brushed aside. From the Prime Minister down this is a topical issue and must be dealt with and in detail.
18. The other risk mentioned in 7 above is the health risk of tumours and cancer caused by the ionisation of the Caltex emissions as the wind carries them across the proposed 110kV high tension Energex line to the Port of Brisbane. The lines are to be 20 – 30 m high and so will be above the tree tops and fully exposed to the Caltex emissions. This is a new threat that must be eliminated before it becomes a reality. Undergrounding is the only safe option. The risk here is Rating A – catastrophic - multiple fatalities – with a future high frequency A scale so very much in the Extreme red of the Assessment matrix. As Caltex is aware of the problem the risk cannot be all sheeted home to Energex. The Wynnum neighbourhood is relying on Caltex and those authorities having jurisdiction over Caltex to influence Energex to underground the proposed 110kV line and thereby make it safe for this community.
19. The level of consultation may have complied with the act but not the intent. All neighbouring residents should have been individually canvassed and made aware of the Caltex proposal. So many of Northpoint residents were unaware of the proposal or their rights that it seems now to be almost too late. The time for submissions need to be extended to allow for fuller community consultation.