Decision Report DRAFT...Decision Report DRAFT L9074/2017/1 Date of Issue: 31/01/2018 Amendment Date:...

Licence: L9173/2018/1

Decision report template (short-form) v0.7 (Nov 2019) i

Application to amend licence

Part V Division 3 of the Environmental Protection Act 1986

Licence number L9173/2018/1

Licence holder Cleanaway Pty Ltd

ACN 000 164 938

DWER file number DER2016/002508

Premises Perth Southern Waste Transfer Station - Welshpool

16-30 Sheffield Road

WELSHPOOL WA 6106

Part of Lot 6 on Diagram 91787

Certificate of Title Volume 2087 Folio 321 as described in Attachment 1

Date of report 1 May 2020

Decision Report

DRAFT

L9074/2017/1 Date of Issue: 31/01/2018

Amendment Date: 17/12/2019

File Number: DER2017/001017-1

DRAFT

Licence

Licence number L9074/2017/1

Licence holder Department of Planning, Lands and Heritage

ABN 68 565 723 484

Registered business address Level 2, 140 William Street PERTH WA 6000

DWER file number DER2017/001017-1

Duration 01/02/2018 to 31/01/2022

Date of issue 31/01/2018

Date of amendment 17/12/2019

Premises details

Northampton Lead Tailings Project

Via Drage Street

NORTHAMPTON WA 6535

Lot 1146 on Deposited Plan 231889

Certificate of Title LR3164/799

As defined in Schedule 1

Prescribed premises category description (Schedule 1, Environmental Protection Regulations 1987)

Production / design capacity

Category 62: Solid waste depot: premises on which waste is stored, or stored, pending final disposal or re-use.

500 tonnes or more per year

Assessed activities directly related to the above category

Temporary stockpiling of tailings and tailings impacted soil Approved for 34,500 tonnes

This licence is granted to the licence holder, subject to the attached conditions, on 17 December 2019, by:

Stephen Checker

MANAGER WASTE INDUSTRIES

REGULATORY SERVICES

Officer delegated under section 20 of the Environmental Protection Act 1986 (WA)

Licence

Stephen Checker

Digitally signed by Stephen Checker Date: 2019.12.17 16:50:58 +08'00'

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Decision report template (short-form) v0.7 (Nov 2019)

Table of Contents

1. Definitions ........................................................................................................... 2

2. Licence and amendment history ....................................................................... 3

3. Purpose and scope of assessment ................................................................... 4

4. Application details .............................................................................................. 4

5. Overview of existing Premises .......................................................................... 4

6. Description of proposed activities .................................................................... 4

Legislative context and other approvals ................................................ 1

7. Emission sources, receptors and pathways .................................................... 1

Emissions ................................................................................................. 1

Environmental Siting ............................................................................... 2

Pathways ................................................................................................... 4

Applicant controls .................................................................................... 5

8. Risk assessment ................................................................................................. 9

Risk assessment – construction........................................................... 11

8.2 Risk assessment – operation ................................................................ 12

9. Consultation ...................................................................................................... 16

10. Conversion record ............................................................................................ 17

11. Conclusion ........................................................................................................ 19

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1. Definitions

Key terms relevant to this decision report and their associated definitions are listed in Table 1.

Table 1: Definitions

Term Definition

Applicant Cleanaway Pty Ltd

Category / categories

Categories of prescribed premises as set out in Schedule 1 of the EP Regulations.

Decision Report refers to this document.

Delegated Officer An officer delegated under section 20 of the EP Act.

Department The department established under section 35 of the Public Sector Management Act 1994 and designated as responsible for the administration of Part V Division 3 of the EP Act.

DWER Department of Water and Environmental Regulation

As of 1 July 2017, the Department of Environment Regulation (DER), the Office of the Environmental Protection Authority (OEPA) and the Department of Water (DoW) amalgamated to form the Department of Water and Environmental Regulation (DWER). DWER was established under section 35 of the Public Sector Management Act 1994 and is responsible for the administration of the Environmental Protection Act 1986 along with other legislation.

Emission has the same meaning given to that term under the EP Act.

EP Act Environmental Protection Act 1986 (WA)

EP Regulations Environmental Protection Regulations 1987 (WA)

Existing Licence The Licence issued under Part V, Division 3 of the EP Act and in force prior to the commencement of, and during this Review

Licence Holder Cleanaway Pty Ltd

Noise Regulations Environmental Protection (Noise) Regulations 1997 (WA)

Prescribed premises

This has the same meaning given to that term under the EP Act.

Premises refers to the premises to which this Decision Report applies, as specified at the front of this Decision Report

Revised Licence the amended Licence issued under Part V, Division 3 of the EP Act following the finalisation of this Review.

Risk Event As described in Guidance Statement: Risk Assessment

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2. Licence and amendment history

Table 2 provides the works approval and licence history for the Premises.

Table 2: Instrument history

Instrument Issued Nature and extent of works approval, licence or amendment

W6021/2016/1 30/05/2018 Works Approval to construct the premises

L9173/2018/1 11/12/2018 Licence to operate the facility

L9173/2018/1 01/05/2020 Licence Amendment to permit installation of a new sorting line, acceptance of Class III waste, exclusion of part of the lot from the premises

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3. Purpose and scope of assessment

Cleanaway Pty Ltd (The Licence Holder) submitted an application to the Department of Water and Environmental Regulation (DWER) on the 17 December 2019 to amend the licence L9173/2018/1 for a Category 62 Solid Waste Depot on Lot 6 on Diagram 91787 in Welshpool.

The Licence Holder is requesting to;

1. Excise a portion of the existing prescribed premises being leased to a third party.

2. Changing the control measures for birds to allow for bird spikes or bird netting to be used.

3. Construct and operate an inert waste sorting line in the adjacent shed.

4. Amending waste acceptance to permit Class III waste and municipal waste.

The Licence Holder has advised there will be no changes to the Category 62 throughput or the current operations.

4. Application details

Table 4 lists the documents submitted during the assessment process.

Table 4: Documents and information submitted during the assessment process

Document/information description Date received

Licence application documentation 17/12/2019

5. Overview of existing Premises

Table 5: Classification of premises and assessed design capacity

Category Description Assessed production or design capacity or throughput

Category 62 Solid Waste Depot: Premises on which waste is stored, or sorted, pending final disposal and re-use.

150,000 tonnes per annual period.

6. Description of proposed activities

Excise a portion of the premises being leased by a third party

A shed in the west of the Premises is being leased to a third party. As the Licence Holder is not in occupational control of this area it has been removed from the Premises.

The change of Premises boundary is considered administrative and does not alter emissions and discharges from the Premises and is not risk assessed in this decision report. Due to the urgency of this request, the change of Premises Boundary has been granted as a separate amendment.

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Construct and operate an inert waste sorting line and balers in the adjacent shed

The proposed new infrastructure and equipment are outlined in Table 6 below and the site layout is shown in Figure 1.

Table 6: Proposed new infrastructure and equipment

Ref Infrastructure or Equipment Site Layout Plan reference (Figure 1)

1 Sorting line including:

Input conveyor,

Input rubber strip,

Trammel roller,

Sorting conveyor,

Operator stand,

Output conveyor, and

Output rubber strip.

Proposed sort line area

2 Two Balers Balers (and Balers –Figure 3)

3 Bird spikes or Bird Netting N/A

4 Storage bins Bin (typical) [Figure 2]

5 On-site Portable Water Monitor Located near personnel door(s) to main transfer warehouse

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Figure 1: Site Plan Layout

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Figure 2: Recycling Equipment Overall Layout Diagram

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Figure 3: Recyclables area equipment general layout

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This proposed change may potentially alter the odour, noise, dust, leachate, smoke, windblown waste, and/or vermin or pathogen emissions at the premises, and this is risk assessed in this decision report.

Amending waste acceptance

The Premises currently accepts putrescible waste (limited to general waste from commercial and industrial premises, and skip bins for residential waste disposal), and Inert Wastes Type 1 and 2.

The Licence Holder has requested the acceptance of residential putrescible waste from green bins, as well as Class III waste in line with the waste that can be accepted at their Banksia Road premises which is where the waste is transported to.

As part of the application the Licence Holder has requested that the wording “limited to” is changed to “includes”. DWER considers that the wording “limited to” is required to provide certainty as to the types of waste that are authorised to be accepted.

The Licence Holder will still not accept clinical waste, quarantine waste, radioactive material, asbestos, biomedical waste, controlled waste, hazardous waste or biosolids.

This proposed change may potentially alter the odour and leachate emissions at the premises, due to the potential for an increase in leachable contaminants from Class III waste. These emissions are risk assessed in this decision report.

Legislative context and other approvals

Contaminated Sites

The Premises was classified under the CS Act on the 7 December 2016 as ‘Contaminated – restricted use’ and is restricted to the current commercial/industrial use.

A Detailed Site Investigation was carried out in August 2016 which determined that asbestos-impacted soil and ACM is buried beneath the bituminized surface in the northern and south eastern portions of the site at a depth of between 0.2 and 0.6 m below ground level. The investigation determined that the majority of asbestos is located in the northern portion of the premises, with two areas of low volumes of asbestos to the southern boundary.

This amendment application does not propose any disturbance of the asphalt.

Planning approvals

The City of Canning issued planning approval on the 15 August 2017. The approval is valid for an initial period of 6 years, with extension subject to satisfactory performance.

Lease agreement

The Licence Holder has provided evidence of a lease agreement between the landowner Kain & Shelton Pty Ltd and Cleanaway Operations Pty Ltd. Cleanaway Operations Pty Ltd is a wholly owned subsidiary of Cleanaway Pty Ltd. The lease if valid for a 15 year period to 2033.

7. Emission sources, receptors and pathways

Emissions

The potential for emissions to impact on sensitive receptors has been assessed in accordance with the Department’s Risk Framework. The key emissions from the proposed amendments which have been considered in this report are odour, noise, dust, leachate, smoke, contaminated firefighting water runoff, windblown waste, and/or vermin or pathogen

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emissions from the construction and operation of an inert waste sorting line and baler systems and odour and leachate emissions from the addition of waste types.

The Applicant has proposed measures to assist in controlling these emissions, where necessary. The control measures are outlined in Section 7.4 below and have been considered when undertaking the risk assessment detailed in Section 8.

Environmental Siting

Potential receptors and environmental aspects

Risk is assessed as a combination of emission sources, the proximity and sensitivity of receptors to those emission sources and any pathways that can allow the emission to reach and potentially harm the receptor. Figure 2, Figure 3 and the table below provides a summary of human and environmental receptors in proximity to the premises which have a potential to be impacted from site activities, and the risk assessment in Section 8 considers these receptors in the context of emissions and potential pathways.

Table 7: Distance to receptors

Human receptors Distance from activity or prescribed premises

Sheffield Lunch Bar Adjacent to the north-west boundary

East Cannington Residential Development 1,350m south of the Premises

Wattle Grove Residential Development 1,450m south-east of the Premises

Wattle Grove Primary School 1,630m south-east of the Premises

Queens Park Residential Development 1,680m south-west of the Premises

Environmental receptors Distance from activity / prescribed premises

Conservation Category Wetlands ~450m north-east

~650m south-east

~1,200m south-east

~1,200m east

~1,200m north

Declared Rare Flora The Premises is located within a designated habitat area approximately 5km by 5km known to contain two Declared Rare Flora populations (Conospermum undulatum and Macarthuria keigheryi)

State Planning Policy 2.8 Bushland Policy for the Perth Metropolitan Region – Bush Forever Site 424

(Includes Threatened Ecological Communities)

~1,000m south


~1,200m north

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~1,325m south-east


(Includes Threatened Ecological Communities)

~1,480m east

Figure 2: Distance to human receptors

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Figure 3: Distance to environmental receptors

Geology, hydrogeology and hydrology

The site is located on the Swan Coastal Plain within the Bassendean Dune System. The sub-surface conditions at the site comprise of Bassendean Sands, these soils are characterised by fine to medium grained quartz. The site is located within a Class 2 Acid Sulfate Soils risk area however, the entire site is sealed by concrete and asphalt hardstand with no clear subsurface works proposed by the licence holder.

There are no watercourses or wetlands within 200m of the premises and the estimated distance to groundwater is approximately 6mbgl flowing in a south-westerly direction (based on historical maximum groundwater contours on DWER’s GIS system). There are three aquifers underlying the site; the Superficial Swan, the Leederville and the Yarragadee North. The groundwater in the area has a salinity of approximately 250-500mg/L and is considered to be a potable water sauce, however it is not within a Public Drinking Water Sauce Area.

Pathways

The following wind roses (Figure 4) provide the annual wind direction and strength (km/h) for 9am and 3pm between the years 1944 and 2010 at the Perth Airport. The region is characterised by predominately west to north-westerly morning winds to strong west to south-westerly afternoon winds. The prevailing winds are predominately towards the railway easement to the north-east of the Premises.

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Figure 4: Wind direction at Perth Airport

The Licence Holder has received four odour complaints in relation to the existing operations of the Premises since operations commenced, all from staff working at neighbouring business Jason Windows, situated directly south of the Premises. Each complaint received by the Licence Holder occurred during the winter months and related to early morning operations in colder weather. The Licence Holder states that at this time of day during the colder months of the year, winds are light and as a result, dispersion of odours is reduced, increasing the chances of odour complaints. Investigations by the Licence Holder concluded that the cause of the complaints was generally attributed to higher than normal accumulations of waste on the tipping floor overnight To rectify this issue, the Licence Holder has reviewed its procedures to ensure the tipping floor is cleaned at the end of the day shift and the volume of waste remaining on the floor in the early morning is minimised.

The Licence Holder appointed EAQ Consulting to conduct odour modelling for the Premises expansion including the addition of the sort line. The odour modelling concluded that the proposed sort line will not alter the existing odour profile of the Premises due to the inert nature of recyclable material being sorted, the infrastructure proposed including the rubber curtains, and that the operation of the conveyor/ sort line is likely to only occur when the fast closing doors are in the closed position. The EAQ study was conducted before the Licence holder included balers to the amendment proposal, however, since the balers will only be compacting clean cardboard it is not expected to alter the odour profile of the Premises. The study confirmed that the risk of fugitive odours is negligible; however should any odour release occur, it will be confined to the recyclables area of the warehouse. Should these fugitive odours escape into ambient air, EAQ considers the likelihood of offsite impacts to be negligible.

These pathways have been considered in the risk assessment table in Section 8.

Applicant controls

The Applicant has proposed the following management controls as part of the application:

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Table 7: Summary of emissions and applicant controls

Source

Emission (as identified above)

Proposed controls

Construction Controls

Vehicle movements

Modification of building Noise

Modern well maintained equipment will be used.

Construction will only occur between 7:00am and 5:00pm on weekdays and 7:00am and 2:30pm on Saturdays.

Modification of building Dust The modification will occur within the enclosed building.

Operational controls

Vehicle movements

Machinery operation

Movement of waste

Noise

Doors remain closed and only open via a sensor to let waste collection vehicles enter and exit.

Doors are rapid closing and will open for less than 30 seconds and close within 10 seconds of vehicle passing through.

Generator supplied with sound attenuation cabin.

Maximum of 2 doors open at any time between 1:00am and 7:00pm and only 1 door will be open at any time between 7:00pm and 7:00am.

Additional acoustic enclosures and barriers around the compactors.

All equipment and vehicles will be well maintained.

Vehicle movements

Movement of waste within the Premises

Dust

Waste collection vehicles are covered.

All internal roads are sealed, hardstands and roads are maintained to avoid build-up of dust.

Waste is not dropped from a height greater than 2m within the tipping floor.

Mix moist waste with dry waste where possible.

Ensuring waste transfer trailers are closed before leaving the Premises.

Waste handling occurs within the enclosed building or enclosed machinery.

Dust misting system.

Waste acceptance and waste handling

Asbestos

Hardstand is regularly inspected and maintained.

Waste loads are visually inspected prior to acceptance at the Premise.

Waste unloaded onto the tipping floor is visually inspected by staff.

In the event that a small volume of asbestos or ACM is identified it will be immediately wetted and quarantined and removed from the Premises as soon as possible.

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In the event that large quantities of asbestos or ACM are identified the waste will be isolated, wetted and covered with plastic. The material will be tested and if it is confirmed to be asbestos material an appropriately licenced contractor will be engaged to remove the asbestos.

Odour

Waste vehicles must be enclosed and sealed.

Any potentially odorous loads tipping onto the floor are prioritised for immediate loading into the transfer trailers.

Waste will be removed from the tipping floor within 24hours of arrival at the premises.

Disturbance of the waste pile is limited to placing onto the conveyor.

Maximum of two doors open during the day and one door open at night.

Waste transfer trailers will be sealed immediately after being filled.

No tipping or handling of the waste occurs outside of the enclosed building.

Rapid closing doors.

Odour extraction system.

If there is a breakdown of machinery or waste is unable to be taken to Banksia Rd waste management facility, waste is diverted to another facility to prevent stockpiling waste for more than 24hrs.

If a power outage occurs there is a generator to provide power to the extractor and compactor to enable continuation of normal operations.

The WTS is well sealed and maintained under negative pressure by a fan extracting 76,817m3/hr of air from within the WTC through the ventilation duct on the northern wall of the facility. This fan is operational any time waste is being handled within the premises.

A full clean-up of tipping area occurs at the end of each operational day.

Rubber curtains at the input and output conveyor.

Leachate

All tipping and waste handling occurs within enclosed building.

Any rainfall that does enter the building (i.e. through doors) or liquids from the waste source on the tipping floor will be retained with the building and be swept towards the drain or have dry waste places on top to prevent pooling of liquid.

All doors to the building are fitted with drive-over bunding to capture waters within the building.

Hardstand outside the building directs rain water away from the building and prevents the infiltration to soils.

The building floor is sealed with an impermeable material and is graded to drain to a 10,000L self bunded leachate storage tank outside of the building, which is regularly

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emptied and removed offsite.

Filters on stormwater drains to catch large pieces of litter and debris.

A 240L spill kit is located near the trailer loading area.

Only solid Class 3 waste will be handled in the WTS.

Fire (smoke)

Waste stockpiles within the building will not exceed 4m high. Waste is transferred out within 24hrs of arrival.

The tipping floor is cleared out at the end of the working day.

Non-conforming waste (including flammable waste) will be removed from the stockpile and stored in skip bins within a dedicated dangerous goods storage area.

Regular cleaning of the building occurs to prevent accumulation of waste around mechanical equipment and power sources.

Infra-red fire detection system is in place to detect hotspots in stockpiles in WTS. The system is connected to a 24hour alarm system. Smoke or heat detection system will be installed across the premises.

Lighting fixtures which cannot drop hot filaments if broken have been installed.

Security measures (alarms, CCTV cameras and fencing) to prevent unauthorised access.

A Fire Risk Assessment was undertaken at the premises and assessed by DFES, the review made recommendations for the following to be incorporated at the premises:

The provision of a vehicle with tray mounted pump and fire hose to increase water application rate; and/or

Provision of on-site portable water monitor(s) for use with on-site fire hydrants allowing fixed spray onto pile.

Pile separation distances to be in accordance with Attachment 1 or 2 of this Decision Report.

Risk of fire is much lower in recyclables side of the building as the waste is hand sorted and all materials stored are essentially dry and inert. Recyclables area is equipped with standard firefighting equipment including thermal imaging system, fire hydrant system with booster connection at the front of the site, fire extinguishers accessible by picking staff, spill kits and excavators available to assist removal of flaming objects.

Fire (Firefighting water)

Installation of further physical barriers, pending Drainage Assessment Report.

In the event of a fire, water will be pumped from the leachate container and removed from the Premises within 24hours.


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The building floor is sealed with an impermeable material and is graded to drain to a 10,000L self bunded leachate storage tank outside of the building, which is regularly emptied and removed offsite

Vermin (pathogen)

Waste is removed within 24hours.


A maximum of 2 doors during the day and 1 door at night are open at any given time. Rapid closing doors.

Regular inspections for vermin infestation.

All tipping within the building.

Roof vents have mesh enclosures.

Installation of bird spikes or netting on rafters throughout

Baits and pesticides are applied where required.

Waste acceptance and waste handling

Movement of waste into transport trailers

Windblown waste


A maximum of 2 doors during the day and 1 door at night are open at any given time. Rapid closing doors.

The licence holder inspects for litter outside of the building after every 10 deliveries and inspects the perimeter of the premises once a week.

All tipping within the building.

Perimeter fencing around the Premises and around the compactor and transfer trailer area.

Waste acceptance Bird impacts

Regular litter inspections.

Immediate clean-up of any spilled waste outside of the building.

A full clean-up of waste from the tipping floor occurs at the end of each operational day.

Daily inspection for potential roosting sites or the presence of birds.

Fully enclosed building with roof vents enclosed in mesh.

Horizontal aspects of the sort line building treated with anti-perch bird spikes or bird netting in WTS area to prevent bird perching.


8. Risk assessment

The identification of the sources, pathways and receptors to determine Risk Events are set out in Tables 10 and 11 below, consistent with the Guidance Statement: Risk Assessments. Risk ratings have been assessed for each key emission source and take into account potential

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source-pathway-receptor linkages. The mitigation measures / controls proposed by the Applicant have been considered in determining the risk rating. Emissions during construction and operation have been assessed separately to allow clear delineation of activity phases.

The conditions in the issued Licence, as outlined in Table 10 and 11, have been determined in accordance with the Guidance Statement: Setting Conditions.

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Risk assessment – construction

Table 10: Identification of emissions, pathway and receptors during construction

Risk Event

Consequence rating1

Likelihood rating1

Risk1 Reasoning Regulatory controls (refer to conditions of the granted instrument) Source/Activities

Potential emissions

Potential receptors, pathway and impact

Applicant controls

Installation of sorting line equipment and balers.

Dust

Air/windborne pathway causing impacts to health and amenity of industrial premises located immediately adjacent including a Lunch Bar and closest residential premises located 1.35km south and within 2km south-west and south-east of the premises.

The installation of equipment will occur within the enclosed building during standard operational times.

Two holes are to be created in the wall between the two sheds, approximately 1.5m x 1m, for the conveyor to pass through. This will occur within the fully enclosed sheds with all other dust preventative controls mentioned in Section 7.4.

Slight Possible Low

Based on the sensitivity of the most affected receptor (neighbouring industrial premises) and the applicant’s controls, the Delegated Officer has determined the risks of noise and dust from the installation of the sorting line and balers to be low.

N/A

Noise

Note 1: Consequence ratings, likelihood ratings and risk descriptions are detailed in the Department’s Guidance Statement: Risk Assessments (February 2017)

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8.2 Risk assessment – operation

Table 21: Identification of emissions, pathway and receptors

Risk Event

Consequence rating1 Likelihood rating1

Risk1 Reasoning Regulatory controls (refer to conditions of the granted instrument) Source/Activities* Potential emissions


Applicant controls

Acceptance of Class III waste

leachate

Seepage through soil to Groundwater (~6mbgl) causing contamination to groundwater supply for nearby users.

No tipping or handling of waste occurs outside of the enclosed building. All waste handled in enclosed vehicles and processed inside the enclosed building.

The tipping floor is bunded, all doors are fitted with drive-over bunding to capture waters within the building.


The building floor is impermeable directs flow to a 10,000L self bunded leachate storage tank which is regularly emptied and removed offsite.

Only solid, spadeable Class III waste will be accepted onto the Premises.

Minor Unlikely Medium

Based on the beneficial use of groundwater, the potential for an increase in moisture content within the new waste stream, combined with the applicant’s controls, the Delegated Officer has determined the risk of leachate emissions on groundwater and overland flow to adjoining premises as medium, therefore acceptable with legislative controls.

Condition 2:

Impervious construction of WTS;

Installation of sump to WTS;

leachates from the tipping floor directed to a storage container;

doors are to incorporate drive over bunding;

spill kits required

non-conforming waste area designed to contain spills;

hardstand to direct rainfall away from the WTS; .

Overland flow to adjoining premises causing contamination of soil.

Overland flow to conservation category wetlands (~450m north-east) impacting on the biological diversity and ecosystem function of the wetlands.

N/A N/A N/A

Wetlands are located up gradient based on regional groundwater flow, and overland flow is not considered likely to travel this distance through highly developed industrial and urban setting.

Contaminated stormwater

Overland flow to adjoining premises causing contamination of soil.

Minor Unlikely Medium

Based on the potential for an increase in moisture content within the new waste stream, combined with the applicant’s controls, the Delegated Officer has determined the risk of contaminated stormwater affecting adjoining premises as medium, therefore acceptable with legislative controls

Operation of the Sorting Line Noise





Maximum of 2 doors open at any time in the day and only 1 door at night.



Moderate Possible Medium

Based on the sensitivity of the most affected receptor (neighbouring industrial premises), the noise modelling results, and the applicants controls, the Delegated Officer has determined the risk of noise impacts during operation on receptors during operation is medium.

Conditions 17-20 require noise validation to ensure both the baler and the sorting line are not exceeding the Noise Regulations.

Conditions 19-22 require validation of predicted modelling and corrective action if required

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Risk Event




Applicant controls

Odour

Air/windborne pathway causing impacts to amenity at industrial premises located immediately adjacent including a Lunch Bar and closest residential premises located 1.35km south and within 2km south-west and south-east of the premises.

Disturbance of the waste pile is limited to placing onto the conveyor.

Maximum of two doors open during the day and one door open at night.

Tipping and handling waste occurs within the enclosed building.


Odour extraction system in waste acceptance area.


Rubber curtains at the input and output conveyer points seal the waste acceptance area from the recyclable area.

Slight Unlikely Low

The portion of the waste stream being diverted through the sort line is highly recyclable, therefore more inert and less odorous than the main body of waste. Therefore, The sort line is not expected to contribute to odour emissions.

Condition 3 limits waste acceptance to acceptable types

Condition 4 excludes processing of odorous putrescible wastes and requires such wastes to be removed off site within 24 hours

Condition 8 requires sealing of waste transfer trailers immediately

Conditions 9 and 10 require the operation of rapid closing doors at the facility

Vermin or pathogen

Direct Contact affecting health and amenity for industrial premises located immediately adjacent including a Lunch Bar and closest residential premises located 1.35km south and within 2km south-west and south-east of the premises.

Waste is removed within 24hours.


A maximum of 2 doors open at once during the day and 1 door at night. Rapid closing doors.

Regular inspections for vermin infestation.

All tipping and handling within the building.

Roof vents have mesh enclosures.

Horizontal aspects of the sort line building treated with anti-perch bird spikes or bird netting in WTS area to prevent bird perching.

Baits and pesticides are applied where required.

Slight Unlikely Low

Based on the sensitivity of nearby industrial receptors and the applicant’s controls, the Delegated Officer has determined the overall risk of vermin impacts on sensitive receptors during operation aslow.

Condition 1: Table 1: Design and installation requirements. Include installation of on-site portable water monitor.

Operation of balers Noise





Maximum of 2 doors open at any time in the day and only 1 door at night.




Based on the sensitivity of the most affected receptor (neighbouring industrial premises), the noise modelling results, and the applicants controls, the Delegated Officer has determined the risk of noise impacts during operation on receptors during operation is medium.

Conditions 17-20 require noise validation to ensure both the baler and the sorting line are not exceeding the Noise Regulations.

Conditions 19-22 require validation of predicted modelling and corrective action if required

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Risk Event




Applicant controls

Odour

Rapid closing doors and rubber curtains of sort line seal the recyclable area from the waste acceptance area.

Only clean cardboard accepted for baling process.

N/A N/A N/A The clean cardboard to be baled is non-odorous

General operations in the Recyclables Area

Fire - smoke


Non-conforming waste (including flammable waste) is removed from the stockpile and stored in skip bins within a dedicated dangerous goods storage area.

Regular cleaning of the building occurs to prevent accumulation of waste around mechanical equipment and power sources.

The waste acceptance area has Infra-red fire detection system is in place to detect hotspots in stockpiles. The system is connected to a 24hour alarm system.

Lighting fixtures which cannot drop hot filaments if broken have been installed.

Security measures (alarms, CCTV cameras and fencing) to prevent unauthorised access.

Recyclables area is equipped with standard firefighting equipment including thermal imaging system, fire hydrant system with booster connection at the front of the site, fire extinguishers accessible by picking staff, spill kits and excavators available to assist removal of flaming objects.

Provision of on-site portable water monitor located near personnel door(s) to main transfer warehouse.


Based upon the sensitivity of neighbouring industrial premises, the applicant’s controls, and the Fire Risk Assessment Report and Review, the Delegated Officer has determined the overall risk of fire – smoke during operations to be medium.

Conditions have been included in the licence to ensure fire management infrastructure is installed as per DFES advice.

Condition 1: Table 1: Design and installation requirements. Include installation of on-site portable water monitor.

Condition 2: Table 2: Infrastructure and Equipment requirements. Include On-site Portable Water Monitor.

Condition 2: Table 2: Infrastructure and Equipment requirements. Include Infra-red fire detection system in the recyclable area.

Fire- firefighting water

Seepage through soil to Groundwater (~6mbgl) causing contamination to groundwater supply for nearby users.

Installation of further physical barriers, pending Drainage Assessment Report.

In the event of a fire, water will be pumped from the leachate container and removed from the Premises within 24hours.


Hardstand outside the building directs rain water away from the building and

Based upon the sensitivity of neighbouring industrial premises, the applicant’s controls, and the Fire Risk Assessment Report and Review, the Delegated Officer has determined the overall risk of fire –firefighting water during operations to be medium.

Conditions have been included in the licence to

Condition 28: Licence Holder must submit a Drainage Assessment Report detailing a review of stormwater flow onsite and any potential amendments to stormwater infrastructure to improve the capture of stormwater and firefighting water onsite.

Overland flow to adjoining premises causing contamination of soil and health impacts to neighbouring industrial premises including a Lunch Bar.

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Licence: L9173/2018/1


Risk Event




Applicant controls

Overland flow to conservation category wetlands (~450m north-east) impacting on the biological diversity and ecosystem function of the wetlands.

prevents the infiltration to soils.

The building floor is sealed with an impermeable material and is graded to drain to a 10,000L self bunded leachate storage tank outside of the building, which is regularly emptied and removed offsite

ensure fire management infrastructure is installed and reviewed as per DFES advice.

Windblown waste

Air/windborne pathway causing impacts to amenity of Industrial premises located immediately adjacent including a Lunch Bar.


A maximum of 2 doors during the day and 1 door at night. Rapid closing doors.

The licence holder inspects for litter outside of the building after every 10 deliveries and inspects the perimeter of the premises once a week.

All tipping and handling occurs within the building.

Perimeter fencing around the Premises and around the compactor and transfer trailer area.

Slight Unlikely Low

Based upon the sensitivity of neighbouring industrial properties and the applicant’s controls, the Delegated Officer has determined the overall risk of windblown waste during operations as low.

N/A

Note 1: Consequence ratings, likelihood ratings and risk descriptions are detailed in the Department’s Guidance Statement: Risk Assessments (February 2017)

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9. Consultation

Table 32: Summary of consultation

Method Comments received DWER response

Department of Fire and Emergency Services (DFES) and the Applicant had a meeting on 26/02/2020. Letter from DFES addressed to DWER received 06/04/2020

Submission of Fire Risk Assessment Review.

DFES Built Environment Branch comments:

o The Applicant must ensure compliance with National Construction Code Volume One (BCA 2016).

o Ensure the requirements of BCA table E1.5 (sprinklers) for fuel load are not exceeded.

o Confirm BCA Clause E1.10 are not exceeded.

DFES HAZMAT Branch comments:

recommends the adaptation of the NSW Fire and Rescue – Fire safety in waste facilities. Pending the publishing of DFES guidelines for MRFs.

Recommends the following to be incorporated at the premises:

The provision of a vehicle with tray mounted pump and fire hose to increase water application rate; and/or

Provision of on-site portable water monitor(s) for use with on-site fire hydrants allowing fixed spray onto pile.

HAZMAT Branch has also recommended the Applicant develop a plan for potential fire water runoff containment on site. This is to be submitted to DFES upon completion.

DWER has considered DFES advice and incorporated the advice into the decision making process and included fire management infrastructure into the licence.

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Licence: L9173/2018/1


Applicant referred draft documents (17/04/2020)

Comments received from Applicant 29/04/2020.

Clarification on dates for proposed installation of equipment

Request to use bird netting as an alternative to bird spikes

Clarification regarding the nature and location of fire detection systems

Clarification on wastes to be accepted and processed (including broad Class III wastes; small amounts of greenwaste may be present on sort line)

Accepted. Documents updated.

Correspondence demonstrating endorsement by DFES for alternative stockpile separation arrangements than Vic/NSW guideline recommendations previously endorsed.

Accepted. Condition 15 updated to include alternative requirements

10. Conversion record

The following table serves as a record of all amended conditions and updates to the licence template.

Existing Licence Condition

Summary Amended licence condition

Summary

1 Emissions N/A This condition has been removed as it replicates the general provisions of the EP Act.

2 and Table 3 Infrastructure and equipment 1 and Table 2 Amendments to include new infrastructure

3 and Table 4 Waste acceptance 2 and Table 3 Amendment to include new waste types.

4 Removal of non-conforming waste

No changes

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5 Removal of asbestos or ACM No changes

6 Enclosed, sealed or covered vehicles

No changes

7 Waste processing No changes

8 and Table 5 Sealing transfer trailers immediately after filling

7 and Table 4 No changes

9 Keep all doors closed

10 Opening rate of rapid-closing doors

11 Control measures to prevent infestations

12 No generation of visible dust

13 Maintain security measures

14 “Quarantine” area for burnt/burning waste

15 Waste pile – fire mitigation related conditions

16 Removal of water from sump within 24 hours

17 Use of sound attenuation measures for generator

18 Malfunction of machinery

19 Noise validation

These conditions have since been complied with and have been amended to reflect the new infrastructure once it is in place.

20 Noise validation

21 Noise validation

22 Noise validation

23 Records- Waste accepted 17

24 Records – Waste removed 18

25 Maintenance of books 19 and 20 Updated wording

26 Complaints management 21

27 Annual Audit compliance report

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28 Annual environmental report

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29 Comply with department request

N/A

30 Submit Drainage Assessment Report

N/A

11. Conclusion

Based on the assessment in this decision report, the Delegated Officer has determined that amendment will be granted, subject to conditions commensurate with the determined controls and necessary for administration and reporting requirements.

Steve Checker MANAGER WASTE INDUSTRIES INDUSTRY REGULATION An officer delegated by the CEO under section 20 of the EP Act

Stephen Checker

Digitally signed by Stephen Checker Date: 2020.05.01 17:22:08 +08'00'

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Appendix 1: Key documents

Document title Availability

Licence Amendment application form and supporting

documentation (December 2019) DWER records (A1852611)

DER, July 2015. Guidance Statement: Regulatory

principles. Department of Environment Regulation, Perth.

accessed at www.dwer.wa.gov.au

DER, October 2015. Guidance Statement: Setting conditions. Department of Environment Regulation, Perth.

DER, August 2016. Guidance Statement: Licence duration.

Department of Environment Regulation, Perth.

DER, February 2017 Guidance Statement: Risk

Assessments. Department of Environment Regulation,

Perth.

DER, February 2017. Guidance Statement: Decision Making. Department of Environment Regulation, Perth.

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Attachment 1: Option A – Pile Separation Distances

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Attachment 2: Option B – Pile Separation Distances

Decision Report DRAFT...Decision Report DRAFT L9074/2017/1 Date of Issue: 31/01/2018 Amendment Date:...

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