Enfield Asphalt Plant - Statement of Environmental Effects - April 2021
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Boral Enfield Asphalt Operations
Boral Resources (NSW) Pty Ltd
01-Apr-2021
Enfield Asphalt Plant -
Statement of Environmental
Effects
April 2021
01-Apr-2021
Prepared for – Boral Resources (NSW) Pty Ltd – ABN: 51 000 756 507
AECOM Boral Enfield Asphalt Operations
Enfield Asphalt Plant - Statement of Environmental Effects
Enfield Asphalt Plant - Statement of Environmental Effects
April 2021
Client: Boral Resources (NSW) Pty Ltd
ABN: 51 000 756 507
Prepared by
AECOM Australia Pty Ltd
Level 21, 420 George Street, Sydney NSW 2000, PO Box Q410, QVB Post Office NSW 1230, Australia
T +61 2 8934 0000 F +61 2 8934 0001 www.aecom.com
ABN 20 093 846 925
01-Apr-2021
Job No.: 60649606
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retrieval system or transmitted, other than with the written consent of Boral Limited or its subsidiaries.
© AECOM Australia Pty Ltd (AECOM). All rights reserved.
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01-Apr-2021
Prepared for – Boral Resources (NSW) Pty Ltd – ABN: 51 000 756 507
AECOM Boral Enfield Asphalt Operations
Enfield Asphalt Plant - Statement of Environmental Effects
Quality Information
Document Enfield Asphalt Plant - Statement of Environmental Effects
Ref 60649606
Date 01-Apr-2021
Prepared by Mia Willows
Reviewed by Jamie McMahon
Revision History
Authorised
Rev Revision Date Details
Name/Position Signature
1 22-Feb-2021 Draft for client review Jamie McMahon
Associate Director -
Environment
2 04-Mar-2021 Draft for client review Jamie McMahon
Associate Director -
Environment
3 01-Apr-2021 Final Jamie McMahon
Associate Director -
Environment
01-Apr-2021
Prepared for – Boral Resources (NSW) Pty Ltd – ABN: 51 000 756 507
AECOM Boral Enfield Asphalt Operations
Enfield Asphalt Plant - Statement of Environmental Effects
Table of Contents
Executive summary i
1.0 Introduction 1
1.1 Background 1
1.2 The Proponent 1
1.3 Project justification 2
2.0 Characteristics of the Premises 2
2.1 Site and surrounds 2
2.2 Premises Existing Infrastructure 2
2.3 Hours of operation and employment 3
2.4 Traffic, access and parking 3
2.5 Stormwater management 4
2.6 Environmental management 4
3.0 Proposed activities 8
3.1 Product definitions 8
3.1.1 Recycled glass sand 8
3.1.2 Steel furnace slag 9
3.1.3 Recycled asphalt pavement 9
3.2 Importation and storage 9
3.2.1 Glass sand 9
3.2.2 Slag 9
3.2.3 Reclaimed asphalt pavement 9
3.3 Processing of recycled materials 10
3.4 Truck movements 10
3.5 New bitumen storage tank 10
3.6 Hours of operation and staff numbers 11
4.0 Legislative framework 12
4.1 Approval history 12
4.2 Development characterisation 12
4.2.1 Designated development 13
4.2.2 Integrated development 15
4.3 Planning approval pathway 16
4.3.1 Modification approval pathway 16
4.3.2 Environmental impact 16
4.3.3 Substantially the same development 16
4.4 Environmental Planning Instruments 17
4.4.1 State Environmental Planning Policy No. 33 – Hazardous and
Offensive Development 17
4.4.2 State Environmental Planning Policy (Infrastructure) 2007 17
4.4.3 State Environmental Planning Policy No 55—Remediation of Land 17
4.4.4 State Environmental Planning Policy No. 64 – Advertising and signage 17
4.4.5 State Environmental Planning Policy – Vegetation in Non-Rural Areas 17
4.4.6 Strathfield Local Environmental Plan 2012 18
4.5 Development controls 18
4.5.1 Strathfield 2030 Community Strategic Plan - 2018 19
4.6 Other relevant environmental legislation and policies 19
4.6.1 Protection of the Environment Operations Act 1997 19
4.6.2 Protection of the Environment Operations (Waste) Regulation 2014 20
4.6.3 Waste Avoidance and Resource Recovery Act 2001 20
4.6.4 NSW Waste Avoidance and Resource Recovery Strategy 2014-21 21
4.7 Commonwealth legislation 21
4.8 Stakeholder engagement 22
4.8.1 Purpose of engagement 22
5.0 Environmental assessment 24
5.1 Air quality 24
5.1.1 Background 24
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AECOM Boral Enfield Asphalt Operations
Enfield Asphalt Plant - Statement of Environmental Effects
5.1.2 Findings 24
5.1.3 Conclusions 26
5.2 Surface water 27
5.2.1 Surface water field quality parameters 27
5.2.2 Surface water analytical results 27
5.2.3 Existing activities 28
5.2.4 Proposed activities 28
5.3 Noise and vibration 28
5.3.1 Background 28
5.3.2 Impact assessment 31
5.3.3 Mitigation measures 34
5.4 Fire and risk management 34
Storage 34
5.5 Other environmental aspects 34
6.0 Conclusion 37
7.0 References 38
Appendix A
Air quality impact assessment A
Appendix B
Noise and vibration impact assessment B
Appendix C
Surface water characterisation C
Appendix D
Proposed bitumen tank drawings D
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Enfield Asphalt Plant - Statement of Environmental Effects
Executive summary
Bitupave Ltd, a Boral entity company, operates an asphalt batching plant at Greenacre in the
Strathfield local government area (the Premises). The asphalt manufacturing process at the Premises
currently uses a mixture of graded, high-quality materials including aggregate fines, sand, lime and
bitumen.
This Statement of Environmental Effects (SEE) supports a request to modify the Premises’ existing
development consent to receive, store and process increased volumes of reclaimed and recycled
materials for the use in asphalt manufacture. This consent is sought to support greater proportions of
recycled content in asphalt, which is largely driven by sustainability targets embedded in supply
contracts with local government and Transport for NSW for road construction projects.
The Project provides an opportunity to use recycled and reclaimed materials, which would otherwise
be sent to landfill, and meets social expectations to reuse materials that have been collected through
domestic and commercial recycling programs.
Development consents granted under Part 4 of the EP&A Act may be modified under Section 4.55 of
the Act. Whist the Project to import recycled materials is minor in nature, this modification has been
assessed pursuant to Section 4.55(2) owing to the need to further consider environmental aspects
such as odour and risk. As such this SEE has assessed the environmental effects of the proposed
works associated with this Project.
The Project is small in scale and would have minimal environmental impact when operated in
accordance with the specified manufacturing standards. All recycled and reclaimed materials have an
approved resource recovery order/exemption (RRO/E) issued by the NSW EPA and will be
incorporated into the existing EPL 21429 for the Premises. Additional infrastructure would be limited
to one bitumen tank to be incorporated into an existing tank farm, and additional parking is not
required as there would be no change to staffing numbers nor trucks parked on site.
The Project is in the public interest as it provides an opportunity to recycle materials which would
otherwise be sent to landfill. It is consistent the NSW WARR Strategy 2014-21 and the Federal
Government National Waste Action Plan, as well as the objectives of the Strathfield LEP 2012, the
Strathfield DCP and NSW waste handling and reduction legislation. In addition, there is a demand for
the asphalt product from with State and local government which stipulate minimum proportions of
recycled material to meet sustainability policies and objectives.
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Enfield Asphalt Plant - Statement of Environmental Effects
1.0 Introduction
Bitupave Ltd, a Boral entity company, operates an asphalt batching plant at Greenacre in the
Strathfield local government area (the Premises). The Site is co-located with two other Boral
operations – a concrete batching plant and a rail terminal for the delivery of quarry materials at 1-5
Norfolk Road, Greenacre (the Site).
This Statement of Environmental Effects (SEE) supports a request to modify the Premises’ existing
development consent to receive, store and process recycled materials for the use in asphalt
manufacture. Consent for the use of these materials in asphalt manufacture is sought to support
increasing customer demand for greater recycled content in asphalt.
1.1 Background
The demand by consumers for economical, efficient, and environmentally friendly products for use in
road bases has been growing. New and innovative materials are continually being researched and
developed for use in the production of asphalt (Al-Khateeb, 2019). This includes materials such as
recycled glass, slag and reclaimed asphalt pavement.
Many local government agencies and Transport for NSW (Transport for NSW, Paving the Way, 2019)
now stipulate minimum quantities of recycled material in their asphalt. Some of these specifications
require the addition of recycled glass, slag and other recycled content in order to meet certain
operational criteria for the road surface and sustainability standards. Asphalt producers are therefore
increasingly required to include such materials into the asphalt mix.
The Premises currently has development consent and an associated Environment Protection Licence
21429 (EPL 21429) allowing for the operation of an asphalt batching plant and the receival,
processing, and storage of reclaimed asphalt pavement (RAP).Neither the consent or the EPL allow
for the receipt, storage or use of recycled materials such as recycled glass sand and slag in the
asphalt manufacturing processing at this location.
Boral is seeking an amendment to EPL 21429 to permit the receipt, storage and use of recycled glass
sand and slag materials in the asphalt mix produced at the Site. However, the NSW Environment
Protection Authority (EPA) requires that inclusion of these additives in the asphalt mix must be
specified in a development consent prior to the updating of an EPL. This application therefore seeks
approval for the inclusion of these materials in the asphalt mix in order to facilitate a subsequent
amendment to the EPL.
Premises Description
Boral’s asphalt operations at the Premises have been in place since the early 1970s. Over this period
the usage of the facility has changed slightly, though has remained focused on the manufacture of
asphalt, primarily for use in roads and other construction activities.
The Site (and Premises) is located at 1-5 Norfolk Street, Greenacre and is legally described at Lot 41
in deposited plan (DP) 854916 (refer Figure 1-1). The entire lot covers an area of approximately
21,392 m2. Boral Resources (NSW) Pty Ltd is the landowner. Boral Asphalt (trading as Bitupave Ltd)
occupies the southern part of the Site.
The Premises is in a well-established industrial precinct adjacent to the Enfield Intermodal Rail
Terminal. The Premises is on relatively flat terrain, with an elevation ranging between 25 m and 31 m.
A range of commercial, industrial and infrastructure uses are located in the surrounding area.
Co-located at the Site are an aggregate storage facility, a concrete batching plant and a rail terminal.
Raw material for the asphalt and concrete batching plants predominantly arrives at the Site via rail and
is distributed by road.
1.2 The Proponent
The proponent is Bitupave Ltd, a Boral entity company. The landowner is Boral Resources (NSW) Pty
Ltd, which is part of Boral Limited, an Australian owned international building and construction
materials group, headquartered in North Sydney, Australia. Boral’s competitive position is underpinned
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Enfield Asphalt Plant - Statement of Environmental Effects
by being a market leader in cement and construction materials in Australasia, the Boral USG Joint
Venture plasterboard business in Australia and Asia, and cladding and roof tiles in the USA.
Boral Australia employs over 5,000 people in its quarry, concrete, asphalt, concrete placing and
cement operations. The business is a major supplier of products to the dwelling, commercial
construction, and roads and engineering markets.
1.3 Project justification
The use of recycled and reclaimed material in asphalt is increasingly being driven by sustainability
targets embedded in supply contracts with local government and Transport for NSW road construction
projects. The Project provides an opportunity to use recycled and reclaimed materials, which would
otherwise be sent to landfill, and meets social expectations to reuse materials that have been collected
through domestic and commercial recycling programs. Use of materials that previously would be
disposed of as waste material is a vital aspect of improving the sustainability capability of government
and private industry.
The majority of Australia’s municipal waste is collected in dedicated trucks that compress material
collected at kerbside, delivering it to Materials Recovery Facilities (MRFs). Despite high rates of
access to kerbside collection and recycling nationally, many collection and recycling services have
limited capacity to process many types of recyclable materials (DOEE, 2018). Creating demand for
recycled products through supply chain specifications (e.g. Strathfield Council and Transport for NSW)
creates an incentive for MRFs to invest in improved technical capabilities to sort recycled waste and
provide better quality recycled products such as the RAP, glass sand and slag materials proposed to
be used under this project.
01-Apr-2021
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AECOM Boral Enfield Asphalt Operations 1
Enfield Asphalt Plant - Statement of Environmental Effects
Figure 1-1 Regional context
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Enfield Asphalt Plant - Statement of Environmental Effects
2.0 Characteristics of the Premises
This section of the SEE describes the Premises in terms of built infrastructure and natural
characteristics.
2.1 Site and surrounds
Boral’s Enfield plant (the Site) consists of an asphalt batching plant, aggregate storage and a concrete
batching plant and a rail terminal. The Site includes facilities to store, process, transport and
manufacture concrete and asphalt, as well as amenities such as offices, truck and car parking and
storage sheds. The Site is located adjacent to the Enfield Rail Terminal to the east and Roberts Road
to the west. The activities undertaken across the Site comprise an industrial facility that is consistent
with the character of the surrounding area.
An industrial business park located to the south of the plant, beyond Norfolk Road, hosts numerous
commercial and industrial properties. Immediately to the west of the southern extent of the Site is a
Hungry Jacks restaurant and a Shell Petrol Station. The nearest residential properties are located
approximately 30 m to the west of the Premises fronting the western side of Roberts Road. Roberts
Road is a six lane State road that is under the care and control of Transport for NSW. Norfolk Road is
a local road that is owned and managed by Strathfield Council. The locality is illustrated in Figure 2-1.
The total area of the Site is 21,392 m2, with the asphalt batching plant (the Premises) occupying
around 9,200 m2 at the southern extent. The northern extent of the Site includes aggregate storage
facilities, the concrete plant, site offices, maintenance sheds and truck and car parking. To the east is
an existing rail dump hopper which facilitates the delivery of materials by rail.
The existing layout of the Premises is provided in Figure 2-2. The asphalt batching plant consists of
aggregate storage bunkers, asphalt storage bins, feed bins and an office control room and laboratory.
Conveyors, hoppers, water treatment equipment and dryer stacks are also present on the Premises to
assist with the asphalt production process, some of which are shared with concrete batching plant
operations.
The office and amenities are located in the central portion of the Premises, with around 30 approved
car spaces and 25 truck spaces provided. An additional 20 parking spaces are provided at the eastern
extent of the Premises, adjacent to the boundary with the rail terminal. These parking facilities are for
Boral employees only, with around 30 public car spaces available for visitors on Norfolk Road.
The Premises has two main points of access, both along the southern boundary. The entry is located
in the in the southeast corner, with the exit in the southwest corner (refer Figure 2-2). A sealed road
connects the ingress and egress points on Norfolk Road, providing a circulatory one-way route for
vehicles. A designated truck turning circle is provided towards the south east corner of the Premises.
A weighbridge is located to the west of the asphalt manufacturing plant, adjacent to the asphalt
batching plant circuit road. The access points along Norfolk Road serve both the asphalt and concrete
batching plants.
2.2 Premises Existing Infrastructure
The asphalt manufacturing process at the Premises currently uses a mixture of graded, high-quality
materials including aggregate fines and sand, lime and bitumen. The raw material format, storage,
delivery method and maximum limit of raw materials currently used at the Site are outlined in Table
2-1.
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Enfield Asphalt Plant - Statement of Environmental Effects
Table 2-1 Raw materials currently used at the Enfield asphalt batching plant
Maximum
Raw material Delivery quantity received
Raw material Storage
format method on site (tonnes
per annum)
Aggregates, sand Aggregates, sand
Storage silos Rail 256,500
and dust and dust
Lime Powdered lime Lime silo Truck 4,500
High temperature
(160 degrees Bitumen
Bitumen Truck 22,500
Celsius) black storage tanks
viscous liquid
Truck -
delivered as
returned
Aggregates, 2
Covered profilings in
RAP sizes: 14 mm
asphalt mix
back out to
customers
The majority of virgin raw materials are delivered to site primarily via rail, with a small quantity
delivered by truck on an ad hoc basis. Virgin raw materials are moved from the rail loader to storage
silos by conveyor.
All RAP is delivered by truck directly from roadworks sites. RAP, and other raw materials are sorted in
storage bays at the southern extent of the Premises. A front-end loader (FEL) is used to place these
materials into the appropriate hopper (or cold feed bin) located in the middle of the Premises. The
virgin aggregate is then conveyed from the storage silos via a short conveying system into the gas-
fired rotary dryer.
The aggregate is introduced into the higher end of an inclined gas-fired rotary dryer where materials
can reach temperatures of up to 220-270 degrees Celsius. As the hot aggregate leaves the dryer, it
drops into a bucket elevator before being transferred to a set of vibrating screens that drop the
aggregates into individual hot bins according to size.
In order to control aggregate size distribution in the final batch mix, the operator opens various hot
bins until the desired mix is obtained. As the aggregate is weighed, liquid bitumen and filler are added
to separate weigh-hoppers before being dropped into the paddle mixer. Once the dry materials are
evenly mixed, the bitumen is added and stirred through until all of the stone, dust and filler is evenly
coated with a thin film of hot, sticky bitumen, resulting in the final product, which is loaded directly into
trucks or stored in surge bins.
2.3 Hours of operation and employment
The asphalt batching plant operates 24 hours a day, seven days a week. No change to these hours is
sought.
The asphalt plant employs a maximum of 25 full-time employees, with up to 12 staff on site at any one
time. The Premises operates under a shift rotation model, with four shifts per day for production and
two shifts per day for the laboratory operation. No additional staff would be employed as part of the
Project.
2.4 Traffic, access and parking
Vehicle and pedestrian ingress and egress to the Site is separated for safety. Access for vehicles is
via an entry point on the western side of the Norfolk Road frontage. All vehicles enter the Site at this
point and proceed around the Premises in a clockwise direction before exiting via the driveway on the
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Enfield Asphalt Plant - Statement of Environmental Effects
eastern side of the Norfolk Road frontage (refer Figure 2-2). This entry is shared with concrete
batching plant traffic, which circulates through the northern extent of the Site.
Truck movement numbers vary depending on demand. Designated truck turning circles are provided
within the asphalt batching plant along with 25 approved truck parking spaces at the northern extent of
the Site.
Thirty car parking spaces are provided in close proximity to the office building in the northern extent of
the Site. An additional 20 car parking spaces are provided at the eastern extent of the Site, adjacent to
the circuit road. Around 30 public parking spaces are provided for visitors on Norfolk Road, between
the ingress and egress points. No on-site visitor parking is provided.
An internal Traffic Management Plan is implemented across the Site which details the traffic
movements for both the asphalt and concrete operations to ensure the safe movement of all vehicles.
2.5 Stormwater management
Surface water runoff is currently managed on the site via a network of surface and underground
drains. The majority of the Premises’ surface water drains connect to the stormwater detention pit at
the northeast corner of the site and to the drain adjacent to the trade waste separator system. Water
collected at the stormwater detention pit is re-used on-site for dust suppression, primarily at the
aggregate storage bunkers and to wash vehicles on the Premises.
Water collected in the bunded bitumen storage area, in the central portion of the Premises, is re-
directed to the trade waste separator system, treated and submitted for laboratory analysis every two
months. The locations of surface water catchments and sample points are presented in Figure 2-3.
2.6 Environmental management
The environmental management procedures for the Premises are designed to ensure compliance with
conditions of the original consent (as modified), environmental licensing, and all other relevant
government legislation and requirements.
Boral regularly undertakes internal environmental audits to monitor environmental performance
against obligations including development consent conditions and EPL conditions. Recommended
actions from these audits are implemented to ensure ongoing compliance.
Boral also implements an Environmental Permit Planner (EPP) system, which is a document that
details conditions of development consent, environmental licenses and standard environmental best
practice. The EPP is required to be completed monthly by the Premises representative, whilst an
annual (at a minimum) verification of the EPP actions is conducted by a Boral representative external
to site, to ensure the document is being maintained and managed appropriately. Any actions from the
verification are raised and actioned through Boral’s internal incident management system
(SEQuence), which also manages any audit recommendations or improvement actions.
The Enfield asphalt operations currently operate under EPL 21429. This allows for the operation of an
asphalt batching plant and the receipt, processing, and storage of up to 72,000 tpa of RAP. The
conditions of the licence require the Premises to adequately manage air and noise emissions along
with stormwater runoff in accordance with relevant legislation.
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Figure 2-1 The Site
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Enfield Asphalt Plant - Statement of Environmental Effects
Figure 2-2 Asphalt batching plant layout
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Enfield Asphalt Plant - Statement of Environmental Effects
Figure 2-3 Surface water sampling locations
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Enfield Asphalt Plant - Statement of Environmental Effects
3.0 Proposed activities
Boral is seeking approval to receive, process, store and use recycled and reclaimed products at the
Enfield asphalt batching plant for the purposes of use in asphalt manufacture. The specific products
are recycled glass sand and steel furnace slag. In addition to this, Boral is also seeking to increase the
amount of reclaimed asphalt pavement (RAP) received at the Site for use in the asphalt mix. It is
intended to increase the maximum capacity of RAP received on site from 72,000 tonnes per annum
(tpa) to 112,500 tpa.
The use of recycled glass sand and slag is subject to an in-force Resource Recovery Order and
Exemption issued by the NSW EPA that allows some wastes to be beneficially and safely re-used for
specific purposes.
All recycled materials (glass, slag and/or RAP) would be added to the asphalt manufacturing process
on an ‘as needs’ basis, depending on customers’ specifications for the final product and the nature of
the end use. The additives may be used together in a mix or individually.
Each material is described in more detail below.
3.1 Product definitions
The EPA can grant resource recovery orders (orders) and resource recovery exemptions (exemptions)
to allow some wastes to be beneficially and safely re-used, independent of the usual NSW laws that
control applying waste to land, using waste as a fuel, storing waste or using waste in connection with a
process of thermal treatment. Orders include conditions which generators and processors of waste
must meet to supply the waste material. Exemptions contain the conditions which consumers must
meet to use waste for the purposes described above.
Orders and exemptions are only appropriate if the re-use:
• is genuine, rather than a means of waste disposal
• is beneficial or fit-for-purpose, and
• will not cause harm to human health or the environment.
All activities associated with use of the steel furnace slag and recycled glass additives will be
undertaken in accordance with the following orders and exemptions:
• The recovered glass sand order and exemption 2014 (glass)
• The Boral engineered glass sand order and exemption 2020 (glass)
• The steel furnace slag order 2019 (slag).
3.1.1 Recycled glass sand
Glass sand is a manufactured material and the end product resulting from the processing of glass
waste. The glass sand product sourced from recycled glass material is used extensively as a
substitute for virgin (naturally occurring sand) for both road construction, pipe bedding and asphalt
production.
In NSW the management of the glass waste stream represents a significant challenge to state and
local governments. The recovery process traditionally applied to glass waste produces mixed coloured
‘fines’ that are unsuitable for reuse for the manufacture of new glass containers, therefore, a majority
of this waste stream is diverted to landfill due to alternative uses not being readily available.
However, recent improvements to the waste glass recovery processes are now emerging in NSW.
New crushing and size reduction processes allow for the manufacture ofAECOM Boral Enfield Asphalt Operations 9
Enfield Asphalt Plant - Statement of Environmental Effects
When glass sand is blended with excavated VENM sandstone and/or VENM sand it creates a high-
quality sand product that has potential application in concrete, asphalt and pipe bedding. The glass
sand additive can also increase luminescence and reflectivity of the asphalt surface.
The recycled glass sand to be used at the Premises would be mixed with VENM sand.
3.1.2 Steel furnace slag
Slag is the by-product of the steel making process. The slag is removed from the furnace vessel after
refinement of the molten iron and is crushed into a cubic shape. The slag material is provided as
various sized aggregates according to the final end use and is used as a replacement for non-
renewable aggregate sources in the asphalt mix. The steel furnace slag by-product is a non-reactive,
tough and durable material and has excellent pavement skid resistance compared to the commonly
used basalt aggregate, making it ideal for application in the asphalt mix.
Typical slag uses include asphalt aggregate, sealing aggregate, rail ballast and engineering
construction fills. The product is inert and non-flammable.
3.1.3 Recycled asphalt pavement
RAP is produced by the recovery of worn out or damaged asphalt surfaces, mainly from roads. On
roads asphalt is usually recovered using a milling machine that removes the upper surface of the road,
grinding it into fine (5-15 mm) particles. This material is fed directly into a truck which transports the
material to the asphalt batching plant.
As the sources of RAP may vary depending on the original use, road types presence of previous patch
sealing or previous resealing, it is typically necessary to screen the RAP prior to processing into new
asphalt. Boral currently undertakes this within the Premises.
When properly processed, RAP containing high quality and well-graded materials is able to produce a
new product that is similar to – if not better than – asphalt mixed from virgin materials.
3.2 Importation and storage
As outlined above, the proposed activities under this application would be limited to transporting
recycled glass sand, slag and RAP onto the Premises, screening and storage of these products and
use of these products in the asphalt manufacturing process. The importation, screening and storage
process is described below.
3.2.1 Glass sand
Glass sand would be pre-mixed with VENM sand on-site at a set ratio. The plant could potentially use
up to 220,000 tpa of this VENM/glass sand, thus a maximum importation of 22,500 tpa of glass sand is
proposed as part of this application.
3.2.2 Slag
It is proposed to import 31,500 tpa of steel furnace slag to the Premises for use in asphalt
manufacture. The slag would be delivered via a 32 tonne truck and would be stored in a covered
storage bay until needed.
3.2.3 Reclaimed asphalt pavement
RAP is currently transported to the Site by truck, usually from active roadwork sites around Sydney. As
outlined above, the RAP is screened on-site for use in the asphalt manufacturing process. Any
materials rejected by the screening process (such as oversized particles) are transported by truck to
Boral’s licensed Seven Hills facility for further processing. The vast majority this material may be
returned to Site for inclusion in the asphalt manufacturing process. The remainder of this material is
forwarded to a licenced waste facility for disposal.
Both the ‘fresh’ RAP and screened RAP are stored within covered storage bays.
The Enfield Premises currently has capacity to accept up to 72,000 tpa of RAP per year. This
application seeks to increase the Site’s capacity to 112,500 tpa.
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Enfield Asphalt Plant - Statement of Environmental Effects
3.3 Processing of recycled materials
The glass sand, slag and RAP would be added to the existing asphalt mix in the quantities required to
meet the relevant asphalt mixing process specifications (as typically determined by the customer).
This would occur via the addition of the materials through an aggregate feeder, which would be heated
in the same manner as the other aggregates in the asphalt mixing drum and would be controlled by
the plant operators and the batch system.
There would be no change to the existing peak daily, or average daily production of asphalt at the
Enfield site as a result of incorporating these new materials into the mix.
Production at the Premises can range from 2 tonne up to 2,000 tonne per day depending on customer
demand. Almost all product that leaves the Premises is finished asphalt product. Any related waste
material is sent to Boral’s licensed Seven Hills facility where it is reprocessed and returned to Enfield,
or forwarded on to a licenced waste facility.
3.4 Truck movements
Glass sand will be included in the asphalt mix as a replacement of virgin sand. As the virgin sand
typically arrives by rail and the glass sand would arrive by truck this will result in a minor increase in
truck movements. This is expected to be in the range of an average of 2.2 additional truck movements
per day.
Slag will be transported to the Enfield site by truck. Given the slag will replace virgin basalt in the
asphalt mix, which is currently transported to the Premises by rail, this will represent a minor increase
in some vehicle movements, in the order of three additional truck movements per day.
RAP will be transported to the Premises by truck directly from roadwork sites, as is currently the case.
3.5 New bitumen storage tank
A new bitumen storage tank (T5) is proposed to be installed within the Premises. The tank would be
located within the bunded area containing the existing four bitumen storage tanks, adjacent to the
storage bunkers. The tank would have a capacity of 60,000 litres and would be 11.2 metres high and
2.86 metres in diameter, compared to the existing tanks which are 7.32 metres tall and 3.6 metres in
diameter. The new tank would be a light matte grey colour to match the other tanks and existing
infrastructure within the Premises, as well as the Site more broadly. See Appendix D for drawings of
the proposed tanks in the context of the existing tanks and Premises.
The tank would be delivered to site prefabricated and would be positioned into place using a crane.
Installation of the tank would not require any excavation or works to the existing concrete slab within
the bunded area.
The tank would require only minor on-site works (pipework and electrical connections) to connect it to
the existing asphalt manufacturing equipment. The existing tanks and asphalt manufacturing
equipment would remain operational during the installation of the new tank. Although the additional
tank would increase the overall volume of bitumen on site, the main driver is to improve operational
flexibility by increasing the number of bitumen types held at the plant. The number of incoming
bitumen tankers would remain the same as the total quantum of bitumen held on site would not
increase. That is, there would be less frequent deliveries associated with the other bitumen mixes.
The advantages of including the new bitumen tank are as follows:
• To facilitate increased RAP usage in asphalt manufacturing
• To facilitate new product development and expand the use of specialty binders
• To provide operational efficiencies as the tank will be electrically heated and include stirrers
and independent temperature control.
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Enfield Asphalt Plant - Statement of Environmental Effects
3.6 Hours of operation and staff numbers
No changes are proposed to the standard operating hours which are currently 24 hours a day, seven
days a week. No changes to staff numbers are required to administer or handle the materials specified
in the proposed operations.
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Enfield Asphalt Plant - Statement of Environmental Effects
4.0 Legislative framework
The following section identifies the applicable Commonwealth and State environment and planning
legislation, local planning instruments, and discusses the relevant planning approval process
applicable to the Project.
4.1 Approval history
Details of relevant development consents issued for the Premises are provided in Table 4-1. The
current development consent incorporates the following three Boral businesses on the Premises:
1. Asphalt Batching Plant (ABP)
2. Concrete Batching Plant (CBP)
3. Rail terminal for receiving quarry products used by the ABP and CBP
Table 4-1 Site approvals history
Business to which
Date Consent number the approval Description of consent granted
applies
28 September Certificate of ABP, CPB and the Bulk rail receiving distribution centre,
1972 consent rail terminal asphalt, pre-mix concrete and
stabilised rock plants, weighbridge,
office and laboratory
21 May 1998 DA 98/22 CBP Rebuilding of wash out pits, relocation
of the slump stand and modifications to
drainage in the Premises
6 February DA 0001/4 CBP Carry out alterations and additions to
2001 an existing concrete batching plant
comprising an additional plant, new
conveyor, three storage silos,
construction of a wind wall, alterations
to pavements and the stormwater
system, and associated on-site parking
5 December DA 0304/142 ABP Alterations and additions to the
2003 existing asphalt batching plant
incorporating environmental
safeguards – emissions flue and truck
loading area
22 December DA 0506/051 ABP Alterations and additions to the Asphalt
2005 Batching Plant
30 August DA 0102/434 CBP Modification to increase in hours of
2006 operation of concrete batching plant
9 February DA 2006/0088 ABP Extension of an existing natural gas
2007 line and installation of compressed
natural gas refuelling
4.2 Development characterisation
The existing asphalt batching plant’s purpose is to produce hot-mix asphalt, which is an industrial
activity. This proposal is to maintain the production of hot mix asphalt, and to replace a small quantity
of the raw feed material (e.g. aggregate and virgin sand) with recycled additives to meet customer
specifications and improve environmental outcomes.
In NSW, recycled additives are considered to be a waste product under the Protection of the
Environment Operations Act 1997 (NSW) (POEO Act), even when they have been repurposed and
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Enfield Asphalt Plant - Statement of Environmental Effects
assessed as having a low environmental impact and granted a Resource Recovery Order/Exemption
(RRO/E) by the NSW Environment Protection Authority (EPA).
The maximum quantity of recycled or reclaimed materials proposed to be imported , stored and used
on Site is 166,500 tpa (refer Table 4-2).the proposed use of recycled products and management of
waste material is considered ancillary to the primary development purpose of asphalt production.
Table 4-2 Proposed quantities of recycled materials
Material Maximum quantity (tonnes per annum)
Glass sand 22,500
Slag 31,500
RAP 112,500
Total 166,500
The recycled additives will only be brought into site on an as-needs basis. The storage requirements
for the individual components, given their relative quantities, are small and there is anticipated to be a
high turn-over of these products.
4.2.1 Designated development
Section 4.10 of the EP&A Act identifies designated development as a type of development that is
declared to be designated development by an environmental planning instrument, or under Schedule 3
of the Environmental Planning and Assessment Regulation 2000 (the Regulation).
The inclusion of recycled and reclaimed materials into the manufacturing process does not change the
nature of the dominant activity on site, which is bitumen pre‐mix and hot‐mix industries (in which
crushed or ground rock is mixed with bituminous materials).
Part 2 of Schedule 3 of the EP&A Regulation stipulates that alterations or additions to development
that do not significantly increase the environmental impacts of the total development (that being
development combined with the proposed alterations or additions) compared with the existing or
approved development is not designated development.
A consent authority, in forming its opinion of whether the proposed development is designated
development, must take into considerations those factors set out in clause 36. Consideration of the
proposed modification against Clause 36 factors is provided at Table 4-3.
Table 4-3 Consideration of Clause 36 against the proposed modification
Clause reference Consideration against the proposed modification
a. the impact of the existing development having regard to factors including:
i. previous Boral undertakes internal environmental audits to ensure compliance
environmental against environmental and consent obligations. Recommended
management actions from these audits are implemented to ensure ongoing
performance, including compliance. Lessons learned from these audits are communicated to
compliance with the other, similar sites to ensure continual improvement within the
conditions of any asphalt business.
consents, licences,
Boral holds an environment protection licence (EPL 21429) for the
leases or authorisation
facility. The EPL is administered by the EPA and licenses the
by a public authority
recovery of general waste and non-thermal treatment of general
and compliance with
waste. No specific processing or recovery limits are applied. The
any relevant codes of
authorised amount of waste permitted to be on site at any one time is
practice.
3,000 tonnes. The maximum amount of RAP permitted to be received
at the premises is currently 72,000 tonnes in any 12 month period,
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Enfield Asphalt Plant - Statement of Environmental Effects
Clause reference Consideration against the proposed modification
which is proposed to be increased to 112,500 tonnes in any 12 month
period.
The facility manages complaints via an internal incident management
system (SEQuence) that assigns actions and tracks incidents until
close out. Complaints are investigated within 24 hours of being
received.
There have been no previous infringement notices for the Enfield site.
ii. rehabilitation or The importation and use of recycled additives does not require
restoration of any rehabilitation or restoration of disturbed land. All products would be
disturbed land stored and handled on existing hardstand areas that have adequate
controls in place.
iii. the number and nature As per Table 4-1, there have been several modifications to the
of all past changes original 1972 certificate of consent including alterations and additions
and their cumulative to the operation of the concrete and asphalt plants.
effects.
(f) the likely impact of the proposed alterations or additions having regard to factors
including:
i. the scale, character or The proposed modification would involve storing and using a small
nature of the proposal quantity of recycled additives (glass sand and slag) to partially
in relation to the replace those materials currently approved to be received at the
development. facility. The nature of the modification is minor and there would be no
change to production limits, hours of operation nor staffing numbers.
ii. The existing The facility is located on land zoned as IN1 – General Industrial. The
vegetation, air, noise Site is generally occupied by the industrial activities, including plant,
and water quality, machinery, storage areas, driveways and other hard stand. There is a
scenic character and small amount of common urban native and exotic vegetation in the
special features centre of the site and around the fringes. There are no areas of
substantial vegetation around the Site.
Air quality and noise in the locality are typical of a highly urbanised
environment, both being at elevated levels. Water quality within the
Site is moderate, with some VOC and heavy metals present. These
are however managed via the existing trade waste and stormwater
management system. Water quality in surrounding waterways is
expected to be poor-moderate.
iii. The degree to which While it is not anticipated that the proposed development would result
the potential in any discernible impact on the receiving environment, potential
environmental impacts environmental impacts (air quality, noise, surface water) are
can be predicated with quantifiable. Trial testing has been undertaken on inclusion of the
adequate certainty. materials into the asphalt manufacturing process to ensure any
impacts associated with their use are as low as reasonably
practicable (ALARP). Additionally, safety data sheets (SDSs) are
available for each recycled additive, informing their storage, use and
clean up requirements. Each material also has a corresponding EPA
RRO/E that details the material chemical characterisation and testing
requirements to ensure any risk of contamination as a consequence
of the materials application to land is low.
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Enfield Asphalt Plant - Statement of Environmental Effects
Clause reference Consideration against the proposed modification
iv. The capacity of the The subject area is of sufficient capacity to house the recycled and
receiving environment reclaimed materials in the existing storage bay infrastructure. The
to accommodate additives will not reach the surrounding land, air or aquatic receiving
changes in environments due to existing environmental controls in place at the
environmental impacts Premises.
The surrounding locality is a mix of low density residential, business
development and infrastructure (rail corridor). Ongoing gentrification
has resulted in more residences in the broader locality such as
Greenacre and newer residents can potentially be less tolerant of
noise, odour and dust, creating land use conflict. However, mitigation
measures such as storage and production limits and monitoring of
the on-site meteorological station are implemented to minimise any
impacts on the receiving environment.
(g) any proposals:
i. To mitigate the The inclusion of the recycled and reclaimed materials into the asphalt
environmental impact batching process would be managed in accordance with existing
and manage any operational procedures specifically related to controlling the
residual risk maximum production heating temperature. No additional controls are
required to manage environmental impacts, or any residual risk
associated with the storage and use of the materials.
ii. To facilitate Boral regularly undertakes internal environmental audits to monitor
compliance with environmental performance against obligations including
relevant standards, development consent conditions and EPL conditions. Recommended
codes of practice or actions from these audits are implemented to ensure ongoing
guidelines compliance. Boral also implements an Environmental Permit Planner
(EPP) system, which is a document that details conditions of
development consent, environmental licenses and standard
environmental best practice. The EPP is required to be completed
monthly by the Premises representative, whilst an annual (at a
minimum) verification of the EPP actions is conducted by a Boral
representative external to site, to ensure the document is being
maintained and managed appropriately. Any actions from the
verification are raised and actioned through Boral’s internal incident
management system (SEQuence), which also manages any audit
recommendations or improvement actions.
As per condition R1 of the facility’s EPL 21429, Boral must supply to
the EPA an Annual Return to document the facility’s performance
against compliance criteria.
4.2.2 Integrated development
This proposal seeks a modification to the existing consent under s4.55(2) of the EP&A Act.
Modifications are not integrated development, regardless of whether a variation is required to an
approval listed in section 4.46(1) of the EP&A Act.
In essence, a modification under section 4.55 of the Act is not “development” – it is a modification of a
development consent (ie the instrument of consent). The Act makes a clear distinction between
development applications and modification applications.
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Enfield Asphalt Plant - Statement of Environmental Effects
4.3 Planning approval pathway
The following sections of the Environmental Planning and Assessment Act 1979 (EP&A Act) are of
relevance:
4.3.1 Modification approval pathway
Development consents granted under Part 4 of the EP&A Act may be modified under Section 4.55 of
the Act. Whist the Project to import recycled materials is minor in nature, this modification has been
assessed pursuant to Section 4.55(2) owing to the need to further consider environmental aspects
such as odour and risk. The particulars of the relevant section are reproduced below.
2. Other Modifications
A consent authority may, on application being made by the applicant or any other person entitled
to act on a consent granted by the consent authority and subject to and in accordance with the
regulations, modify the consent if—
(a) it is satisfied that the development to which the consent as modified relates is substantially the
same development as the development for which consent was originally granted and before that
consent as originally granted was modified (if at all), and
(b) it has consulted with the relevant Minister, public authority or approval body (within the
meaning of Division 4.8) in respect of a condition imposed as a requirement of a concurrence to
the consent or in accordance with the general terms of an approval proposed to be granted by the
approval body and that Minister, authority or body has not, within 21 days after being consulted,
objected to the modification of that consent, and it has notified the application in accordance
with—
i. the regulations, if the regulations so require, or
ii. a development control plan, if the consent authority is a council that has made a
development control plan that requires the notification or advertising of applications for
modification of a development consent, and
(d) it has considered any submissions made concerning the proposed modification within the
period prescribed by the regulations or provided by the development control plan, as the case may
be.
Subsections (1) and (1A) do not apply to such a modification.
4.3.2 Environmental impact
Environmental impacts associated with the proposed are negligible to minor and are discussed in
Section 5.0.
4.3.3 Substantially the same development
A development consent may be modified under Section 4.55(2) provided it is “substantially the same
development” as the development for which the consent was originally granted.
The proposed modification is considered to be substantially the same development for which the
consent was originally granted on the basis that the ‘essence’ of the development; namely the
batching of asphalt would not change as a result of the proposed modification.
It is further noted that:
• there would be no change to production processes, and a negligible change to traffic volumes,
which means that any quantitative and qualitative assessment of social and environmental
impacts is likely to be minimal
• the importation and use of recycled and reclaimed materials is a replacement for virgin materials
• the Project intends to create environmental benefits by providing a mechanism to reuse materials
that would otherwise be sent to landfill
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Enfield Asphalt Plant - Statement of Environmental Effects
• there would be no changes to the physical features of the development, which are deemed
important, material or essential to the development (such as the plant or the structures at the
facility)
• the proposed activity has a net environmental benefit owing to the reduction of reliance on virgin,
non-renewable, natural products such as sand, and rock aggregates resulting from the use of
these alternative materials
• the Project meets NSW State and Transport for NSW sustainability objectives for asphalt through
the transformation of recycled products into a new product.
The proposed modification is therefore within the scope of Section 4.55(2) as the proposed
development is of minimal environmental impact, is able to be appropriately managed with readily
implementable mitigation measures, and is substantially the same development as the development
from which consent was originally granted.
Consideration of the proposed modification against Clause 36 factors is provided at Table 4-3.
As such, a development application under Part 4 of the EP&A Act is required to be submitted to
Council accompanied by a SEE.
4.4 Environmental Planning Instruments
The following State Environmental Planning Policies (SEPPs) are deemed relevant to the proposed
demolition activities.
4.4.1 State Environmental Planning Policy No. 33 – Hazardous and Offensive Development
SEPP No. 33 requires the consent authority to consider whether an industrial proposal is a potentially
hazardous industry or a potentially offensive industry.
The importation, storage and use of the recycled additive materials would not constitute a hazardous
development. No hazardous materials or dangerous goods would be introduced as a result of the
proposed modification (refer Section 5.4 Fire and Risk Management).
4.4.2 State Environmental Planning Policy (Infrastructure) 2007
Clause 104 of the Infrastructure SEPP relates to traffic-generating development. This clause applies to
specified development that includes an enlargement or extension of existing premises, being an
alteration or addition of the relevant size or capacity. This proposal does not involve enlargement nor
extension of the existing premises, and no additional infrastructure will be built. As a result, this
proposal does not constitute traffic-generating development.
4.4.3 State Environmental Planning Policy No 55—Remediation of Land
The object of SEPP 55 is to provide for a state-wide planning approach to the remediation of
contaminated land.
The use of the subject site will not change as a result of the Project and for the use it is considered
that the land is suitable in its current form. The materials proposed to be stored and used on site are
inert and would not comprise any risk of contamination.
4.4.4 State Environmental Planning Policy No. 64 – Advertising and signage
No signage is required that could be visible from outside the Site. The Project does not incorporate
any advertising or signage that requires development consent subject to Strathfield Council policy
requirements.
4.4.5 State Environmental Planning Policy – Vegetation in Non-Rural Areas
The aims of this SEPP are to protect the biodiversity values of trees and other vegetation in non-rural
areas of the State, and to preserve the amenity of non-rural areas of the State through the
preservation of trees and other vegetation.
The Project would not result in the removal of any vegetation within or surrounding the Site.
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Enfield Asphalt Plant - Statement of Environmental Effects
4.4.6 Strathfield Local Environmental Plan 2012
The Project is located within the Strathfield LGA, which is subject to the Strathfield Local
Environmental Plan 2012 (Strathfield LEP 2012). The Strathfield LEP aims to make local planning
provisions for land in Strathfield in accordance with the relevant standard environmental planning
instrument under section 3.20 of the EP&A Act.
The Project is located within an area zoned as IN1 ‘General Industrial’ under the Strathfield LEP 2012.
The objectives of this zone include:
• To provide a wide range of industrial and warehouse land uses.
• To encourage employment opportunities.
• To minimise any adverse effect of industry on other land uses.
• To support and protect industrial land for industrial uses.
• To minimise fragmentation of valuable industrial land, and provide large sites for integrated and
large floorplate activities.
The plant can be categorised as ‘general industries’ which can be undertaken as development with
consent in the IN1 ‘General Industrial’ zone.
The Premises has been used continuously for the purpose of an asphalt and concrete plant for over
40 years and has been previously assessed as having existing use rights under the Strathfield LEP
2012.
4.5 Development controls
Table 4-4 Relevant Strathfield DCP considerations
Development control Compliance Comments
Part D Industrial Yes The Project is consistent with the existing industrial
Development activity on the Premises. The Project would have a
negligible effect on noise, traffic, dust, hazardous
materials management and visual amenity (refer
Section 5.0).
Part H Waste Yes The Project is consistent with the aims and objectives
Minimisation and set out in this development control as it supports the
Management reuse and recycling of building and construction
materials and encourages the minimisation of
environmental impacts of waste.
A small amount of waste would be generated from the
RAP screening process. This waste would be
considered negligible when assessed against the
potential amount of RAP that would otherwise be
disposed to landfill if not reclaimed and reused in the
asphalt production process.
Part I Provision of Off Yes No additional parking is required and the change in
Street Parking Facilities traffic volumes delivering material to the Premises will
be minor.
Part J Erection and Yes No advertising or signage is proposed. Any specific
Display of Advertising signs required for safety purposes would not be visible
Signs and Structures from the outside of the Premises.
Part K Development on Yes No earthworks are required, nor any impact on the
Contaminated Land handstand area which covers the Premises. The
materials would be stored in covered hardstand bays.
Any remnant materials left on the hardstand can be
captured and managed in the stormwater management
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