Sannikka, M. Objection to Wellington Gas Fired Power Station, NSW

 24 September 2014

 M /s Karen Jones
Director Infrastructure Projects,
NSW Department of Planning & Enviroment
GPO Box 39
SYDNEY NSW 2001

Dear M/s Jones,

Further to my letter to you dated 2 September 2014 I wish to make it clear that I object to the Power Station at this site. I do not object to the Power Station provided it complies with NSW Industrial Noise Policy L90 measured background requirements, ie 25dB(A) 

It has been brought to my attention by Mr Michael Tolhurst , General Manager , Wellington Council when I made a courtesy visit to him on 23 September 2014, that ambient measured noise level results of 25dB(A) were not disclosed to him prior to the submissions by Wellington Council re MOD 2 being made. 

In its Submission to the Department of Planning dated 20 March 2014 Mr Michael Tolhurst, General Manager, Wellington Council states;- 

“I have read the summary of the report by Parsons Brinkerhoff Australia Pty Ltd provided in the Memo by Aaron McKenzie on 20 December 2013 and have reviewed the additional information regarding noise. I note the proposed use of two 4000F gas turbines is within the Project Approval modification made on 7 September 2010. I understand this approval observed the modification around gas fired capacity allowed the station to operate as an intermediate as well as peaking plant with a modified annual capacity factor of 40%.”

 Apropos the PB Memo dated 20 December 2013 ;- 

(a) Item No.2 specifies five penalties available (tonality, impulsiveness , intermittency , irregularity and dominant low frequency) because they cause greater annoyance. PB have used none or only one in all of their assessments. 

(b) Item No.3 of PB Memo – For example, in Attachment B of MOD 1 Submissions Attachment B (page 39) PB have been willing to use low frequency penalty for fin fan noise of 73dB(A) when it is meaningless but it is not added to generator noise of 96dB(A) where it is essential and the penalty is justified.

 (c) Items No.3 & No.4 of the PB Memo – In Table 1 adverse conditions includes 5dB(A) penalty. In Table 2 without the 5dB(A) penalty, when added it doesn’t match Table 1 where it is already included. eg Nanima in Table 2 of 34.5dB(A) plus 5dB(A) does not equal 37.5dB(A) as stated in Table 1. This is just one example of how they have fiddled figures. 

(d) Item No.5 of the PB Memo – C weighting assessments are normally used for loud noises like hearing protection ear muff evaluations not quiet noises like annoyance. 

In the Wellington Power Station Assessment – MOD 1 dated 5 March 2010 the total sound power level is not disclosed instead they list various components that contribute to the total. In Attachment B 1/1 Octave Band Source Noise Levels (page 39) the Exhaust Stack Tip Noise Levels are quoted at 101 dB(A) At page 42 the Power Station Revised Propagation modelling noisiest components at Nanima House are split into smaller contributions when added up do not match the original high value eg 101dB(A) exhaust stack where it is split into two areas of 95.3dB(A) (95.3 + 95.3 = 98.3). 

In the Noise Barrier Investigation dated September 2008 that was incorporated into the original project approval submissions, Table 3.1 – Predicted noise levels with barrier adjacent to Nanima House it is stated at 43dB(A). How can this be known without knowing the total sound power level of the source ?

 The width of the proposed noise barrier is stated at only 10m whereas it is said in the Scope of works section ; –

 It should be noted that in reality, careful consideration to barrier placement would be required and it is expected that the length of the barrier would need to be at a minimum twice the length of the building fa9ade.

 Effects relating to flanking barrier top edge/side edge reflection and transmission coefficients have not been accounted for in the original assessment. These effects would be considered in the detailed design phase.

 In other words , if they do not know the total sound power level of the source and they do not know where the barrier should be placed and the width and the material, how can it be known if it would be compliant. ? If it is 43dB(A) in front of the barrier and the barrier drops the noise by only 8dB(A) how can it meet the measured background noise of 25dB(A) and not to exceed it by EPA requirement of 5dB(A).

Yours sincerely
M. Sannikka

Cc Hon Pru Goward – Minister for Planning
Hon Andrew Gee MP – Member for Orange
Dr Nonn Broner – Acoustician
Mr Michael Tolhurst , General Manager, Wellington Council
M/s Sarah Laurie, CEO Waubra Foundation

Parsons Brinckerhoff Australia Pty Ltd
Level 27, Ernst & Young Centre
680 George Street
Sydney NSW 2000
Australia

 3 June 2007 

Nat Barton
Wellington NSW 2820

Dear Nat, 

Wellington Power Station – ambient noise level monitoring results

As you will be aware, ERM Power has engaged Parsons Brinck erhoff (PB) to undertake the environmental assessment, including community and stakeholder consultation , for the proposed Wellington Power Station project. On behalf of ERM Power we would like to thank you for allowing PB to place a noise logger on your property. The purpose of the 10 day monitoring program was to determine the existing noise environment within the area (the ambient noise level), as a first step in determining the noise impact of the proposed project.

The ambient noise levels at your prope1iy were measured and are provided below

Attended monitoring: 8 12 am LA90 = 35 dB(A)
Unattended monitoring: 7 00 am – 6:00 pm LA90 = 30 dB(A)
6 00 pm – 10 00 pm LA90 = 26 dB(A)
 10:00 pm – 7:00 am LA90 = 25 dB(A)

 LA90 refers to the noise level present for 90% of the time (the background level).

 These background levels will be used to determine the appropriate noise limits permissible for the project in accordance with the Environment Protection Authority (now the Department of Environment and Climate Change) Industrial Noise Policy.

 PB and ERM Power appreciate your cooperation during the initial phases of this project. Please also find enclosed a copy of the latest newsletter . This newsletter provides details of the project, the planning and approval process , the current status of the project and contact details if you wish to provide comments on tl1e project or request further information. ERM Power wants to ensure that community comment is considered during the environmental assessment. Your ongoing involvement and feedback during the project is important. 

Once again, thank you for your cooperation .