Key document template - Report...EPP Environmental Protection (Peel Inlet-Harvey Estuary) Policy...

Licence: L8410/2009/2

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Decision Report

Review of Existing Premises

Division 3, Part V Environmental Protection Act 1986

Licence Number: L8410/2009/2

Applicant: WA Composts Pty Ltd

ACN: 078 383 856

File Number: DER2015/001436

Premises: C-Wise

230 Gull Road

Nambeelup WA 6207

Part Lot 89 on Plan 741

Certificate of Title Volume 1112 Folio 243

Bound by the coordinates –

Easting Northing

1 391261.67 6404603.30

2 391092.13 6404601.08

3 391063.88 6404491.83

4 390960.81 6404490.78

5 390939.60 6404403.92

6 390830.19 6404424.69

7 390803.69 6404416.42

8 390784.98 6404355.39

9 390726.58 6404335.45

10 390649.40 6404376.52

11 390638.29 6404374.77

12 390451.15 6404390.52

Decision Report

Licence: L8410/2009/2

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13 390342.89 6404434.61

14 390357.30 6404521.70

15 390621.65 6404524.51

16 390610.24 6404874.71

17 390600.94 6405170.59

18 390559.39 6405244.99

19 390645.75 6405414.43

20 391249.93 6405416.36

21 391256.34 6404881.82

22 391259.68 6404603.48

Date of report: Thursday, 16 August 2018

Status of Report Final

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Table of Contents

Definitions of terms and acronyms ......................................................................... vii

1. Purpose and scope of assessment ................................................................... 1

2. Background ......................................................................................................... 1

3. Overview of Premises......................................................................................... 2

3.1 Infrastructure .......................................................................................................... 2

3.2 Operational aspects ............................................................................................... 4

3.2.1 Waste/feedstock acceptance ........................................................................... 4

3.2.2 Solid feedstock handling/processing prior to mixing ........................................ 6

3.2.3 Mixing of liquid and solid feedstocks ............................................................... 6

3.2.4 Composting process ........................................................................................ 7

3.2.5 Final product ................................................................................................... 8

3.2.6 Liquid waste treatment and storage in ponds .................................................. 8

3.3 Water balance ...................................................................................................... 10

3.4 Proposed re-direction of pre-wetting area runoff ................................................... 10

3.5 Proposed construction of additional pond ............................................................. 11

4. Legislative context............................................................................................ 11

4.1 Contaminated sites ............................................................................................... 11

4.2 Lease agreement ................................................................................................. 12

4.3 Planning approvals ............................................................................................... 12

4.4 Department of Health ........................................................................................... 12

4.5 Groundwater Licence ........................................................................................... 12

4.6 Department of Primary Industries and Regional Development .............................. 12

4.7 Environmental Protection (Peel Inlet-Harvey Estuary) Policy 1992 ....................... 13

4.8 Part V of the EP Act ............................................................................................. 13

4.8.1 Guidance Statements .................................................................................... 13

4.8.2 Works approvals and licence amendments ................................................... 14

4.8.3 Compliance inspections................................................................................. 15

4.8.4 Site visit 27 May 2016 ................................................................................... 16

4.8.5 Site visit 13 October 2016 ............................................................................. 16

4.8.6 Site visit 5 July 2017 ...................................................................................... 16

4.8.7 Annual Reports ............................................................................................. 16

4.8.8 Compliance history check .............................................................................. 17

5. Modelling and monitoring data ........................................................................ 18

5.1.1 Groundwater monitoring ................................................................................ 18

5.1.2 Odour ............................................................................................................ 20

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6. Consultation ...................................................................................................... 21

6.1 Siting context ........................................................................................................ 21

6.2 Residential and sensitive premises ....................................................................... 23

6.3 Specified ecosystems ........................................................................................... 24

6.4 Groundwater and water sources ........................................................................... 25

6.5 Soil type ............................................................................................................... 29

6.6 Meteorology ......................................................................................................... 29

6.6.1 Wind direction and strength ........................................................................... 29

6.6.2 Rainfall and temperature ............................................................................... 29

7. Risk assessment ............................................................................................... 31

7.1 Confirmation of potential impacts ......................................................................... 31

7.2 Consequence and likelihood of risk events ........................................................... 40

7.3 Acceptability and treatment of Risk Event ............................................................. 41

7.4 Risk of liquid waste and leachate impacts ............................................................ 41

7.4.1 General hazard characterisation and impact ................................................. 41

7.4.2 Sources ......................................................................................................... 42

7.4.3 Criteria for assessment.................................................................................. 43

7.4.4 Licence Holder controls ................................................................................. 44

7.4.5 Key findings ................................................................................................... 46

7.4.6 Consequence ................................................................................................ 46

7.4.7 Likelihood of consequence ............................................................................ 47

7.4.8 Overall rating ................................................................................................. 47

7.5 Risk of odour Impacts ........................................................................................... 48


7.5.2 Sources ......................................................................................................... 48



7.5.5 Key findings ................................................................................................... 52

7.5.6 Consequence ................................................................................................ 52


7.5.8 Overall rating ................................................................................................. 53

7.6 Risk of pathogen impacts (compost product) ........................................................ 54


7.6.2 Sources ......................................................................................................... 54



7.6.5 Consequence ................................................................................................ 54

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7.6.7 Overall rating ................................................................................................. 55

7.7 Risk of contaminant impacts (compost product) ................................................... 55




7.7.4 Key findings ................................................................................................... 56

7.7.5 Consequence ................................................................................................ 56


7.7.7 Overall rating ................................................................................................. 56

7.8 Summary of risk assessment and acceptability .................................................... 57

8. Determined regulatory controls ...................................................................... 59

8.1 Summary of controls ............................................................................................ 59

8.2 Production limit ..................................................................................................... 60

8.3 Waste acceptance controls................................................................................... 60

8.3.1 Waste types .................................................................................................. 60

8.4 Infrastructure and equipment ................................................................................ 61

8.4.1 Liquid waste and leachate impact controls .................................................... 61

8.4.2 Odour control ................................................................................................ 62

8.4.3 Other infrastructure and equipment ............................................................... 62

8.5 Operational controls ............................................................................................. 63

8.5.1 Liquid waste and leachate impact controls .................................................... 63

8.5.2 Odour impact controls ................................................................................... 64

8.6 Groundwater monitoring and reporting ................................................................. 65

8.6.1 Groundwater monitoring requirements .......................................................... 65

8.6.2 Groundwater monitoring reporting ................................................................. 66

8.7 Pond monitoring and actions ................................................................................ 67

8.7.1 Pond monitoring requirements....................................................................... 67

8.7.2 Pond monitoring reporting ............................................................................. 68

8.8 Specified actions .................................................................................................. 68

8.8.1 Pond liner integrity testing and seepage rate testing ..................................... 68

8.8.2 Depth to groundwater investigation ............................................................... 69

8.8.3 Pond and groundwater PFAS testing............................................................. 69

8.8.4 Liquid waste feedstock characterisation and product specification ................ 69

9. Premises production or design capacity – Category 61: Liquid waste facility ......................................................................................................................... 71

10. Appropriateness of Licence conditions .......................................................... 71

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11. Licence duration ............................................................................................... 72

12. Licence Holder consultation ............................................................................ 72

13. Conclusion ........................................................................................................ 72

Appendix 1: Key documents

Appendix 2: Summary of Licence Holder’s comments on draft risk assessment and conditions

Appendix 3: Liquid waste review

Appendix 4: Water balance

Appendix 5: Groundwater monitoring

Appendix 6: Odour Impact Analysis

Appendix 7: Technical Expert Report – Mandurah Odour Investigation

Appendix 8: Technical Expert Report – Review of ‘Investigation of Odour Emissions from Nambeelup Precinct Operations’ and Nambeelup farm precinct water quality laboratory report

Attachment 1: Revised Licence L8410/2009/2

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Definitions of terms and acronyms

Term Definition

AACR Annual Audit Compliance Report

Action Criteria Trigger values defined in the Licence that require the Licence Holder to take action

AER Annual Environment Report

AS 4454-2012 Australian Standard AS 4454:2012: Composts, soil conditioners and mulches

AS/NZS 5667.1 Australian Standard AS/NZS 5667.1 Water Quality – Sampling – Guidance of the Design of sampling programs, sampling techniques and the preservation and handling of samples

AS/NZS 5667.11 Australian Standard AS/NZS 5667.11 Water Quality – Sampling – Guidance on sampling of waste waters

ASTM Refers to international standards (originally American Society for Testing and Materials). In this document refers to standards for electrical liner testing ASTM D6747, D7007, D7003, D7002 and D7703)

Category/Categories (Cat.)

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

CM Farms Derby Industries Pty Ltd trading as CM Farms

CS Act Contaminated Sites Act 2003 (WA)

DER Department of Environment Regulation

Decision Report this document

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

DoW Department of Water, Western Australia

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.

EP Act Environmental Protection Act 1986 (WA)

EP Regulations Environmental Protection Regulations 1987 (WA)

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EPP Environmental Protection (Peel Inlet-Harvey Estuary) Policy 1992

Existing Licence The Licence L8410/2009/2 issued under Part V, Division 3 of the EP Act, in force at the time of this review.

Hardstand The hardstand surfaces described in Table 3 and depicted in Figure 2 of this Decision Report.

HDPE High Density Polyethylene

Hydraulic Conductivity

Describes the ease with which a fluid (usually water) can move through the pore spaces or fractures. It depends upon the intrinsic permeability of the material and the density and viscosity of the fluid. Hydraulic conductivity is expressed as metres per second (m/s).

ICMS DWER’s Incident and Complaints Management System

Licence Holder WA Composts Pty Ltd

mV In the measurement of Oxidation Reduction Potential, mV means millivolts.

Nambeelup Farm Nambeelup Farm is a term used to refer to the three licensed Premises, CM Farms (Licence 6932/1988/11), WA Composts Pty Ltd trading as C-Wise (Licence L8410/2009/2) and Mushroom Exchange Pty Ltd (Licence L7210/1997/10).

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

Occupier Is defined in the EP Act to mean a person who is in occupation or control of a premises, or part of a premises, whether or not that person is the owner of the premises or part of the premises.

Pathogens Any microorganisms such as viruses, bacteria, protozoa, and fungi that cause disease in humans and other species.

Premises C-Wise as specified on page i of this Decision Report

Prescribed Premises

Premises prescribed under Schedule 1 to the EP Regulations

Review A risk based licence review conducted in line with DWER published Guidance Statements

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

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1. Purpose and scope of assessment

On 3 October 2016, the Licence Holder was notified that the CEO of the former Department of Environment Regulation (DER) determined that a risk-based Review of Licence L8410/2009/2 for the composting facility at the Premises was required. Following the Department’s investigations of odour complaints in the Mandurah area, the Department identified that the premises situated at Nambeelup Farm were likely to be the cause of odour experienced in the Mandurah area.

This Review is documented through this Decision Report.

This Review has been undertaken in accordance with DWER’s published regulatory risk-based framework, including Guidance Statement: Decision Making and Guidance Statement: Risk Assessment.

2. Background

Table 1 details the Prescribed Premises Categories that are held by the Licence Holder under the Existing Licence for the Premises. The Premises is a composting facility operated under Licence L8410/2009/2 by the Licence Holder.

Table 1: Prescribed Premises Categories

Classification of Premises

Description Premises production or design capacity

Category 67A

Compost manufacturing and soil blending: premises on which organic material (excluding silage) or waste is stored pending processing, mixing, drying or composting to produce commercial quantities or compost or blended soils.

90 000 tonnes per annual period

Category 61 Liquid waste facility: premises on which liquid waste produced on other premises (other than sewerage waste) is stored, reprocessed, treated or irrigated.

60 000 tonnes per annual period

The Premises are one of three premises which make up Nambeelup Farm. Table 2 details the current operations within Nambeelup Farm.

Table 2: Nambeelup Farm premises

Operator Prescribed Premises Category

Design Capacity

WA Composts Pty Ltd (C-Wise)

67A: Compost manufacturing and soil blending

90,000 tonnes per year

61: Liquid waste facility 60,000 tonnes per year

Derby Industries Pty Ltd (CM Farms)

2: Intensive Piggery 22,000 animals

MushroomExchange Pty Ltd 67A: Compost manufacturing and soil blending

37,000 tonnes per annual period

DWER is also reviewing the licences held by CM Farms and Mushroom Exchange.

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3. Overview of Premises

3.1 Infrastructure

The Premises facility infrastructure, as it relates to Category 67A and 61 activities, is detailed in Table 3 with reference to the site plans shown in Figure 1 and Figure 2.

Table 3: Premises category 67A and 61 infrastructure

Infrastructure

Prescribed Activity Infrastructure Category 67A and Category 61

1 Compacted limestone Hardstand:

300mm of compacted limestone

1.2% fall to the north

2 Asphalt Hardstands:

300mm of compacted limestone/gravel overlaid with 40 – 50mm of asphalt


Concrete Hardstands:

200mm of 40 megapascal (MPa) concrete


3 Compost turner

4 Mobile aerated floor (MAF) system

5 Front end loaders

6 Sprinklers

7 2 x screens (for solid feedstock or compost product)

8 Grinder

9 Pond aeration system - fixed speed air blower connected to nests of aeration stones submerged ~400mm below water surface

10 Screens for runoff from North Eastern Hardstand and sediment trap for runoff from the South Eastern and Western Hardstands

11 Leachate collection drainage channels:

Directing runoff from the North Eastern Hardstand (non-certified composting area) through a temporary drainage channel to Pond 21 or 22.

Directing runoff from the Western Hardstand (organic certified area) and South Eastern Hardstand to Pond 21 or 31.

Constructed as follows:

o Base: 100mm thick steel reinforced concrete

o Sealant between walls (s) and concrete base: concrete

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Infrastructure

o Sealant between limestone blocks: Sikaflex

o Sealant covering internal base and walls: Spraypave tar based sealant

12 7 x HDPE lined ponds (combined capacity of 68,795m3).

Pond volumes (excluding the volume of a 300mm freeboard) and liner perimeter dimensions:

Pond 21 – volume 2,338m3 – 45m x 46m x 2.3m







Monitoring infrastructure

Groundwater monitoring bores - MB1, MB2, MB3A, MB4A, MB5A

(MB3, MB4 and MB5 previously re-located and now referred to as MB3A, MB4A and MB5A)

Figure 1: Site Plan 1 indicating approximate location of drainage from Hardstand areas to ponds

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Figure 2: Site Plan 2 indicating Hardstand materials

3.2 Operational aspects

The Licence Holder currently produces approximately 60,000 to 70,000 tonnes of compost product per year which is sold in bulk to compost suppliers.

The Premises office hours are between 7am and 5pm; however wastes may be received at any time (24 hours per day, 7 days per week).

3.2.1 Waste/feedstock acceptance

Solid waste/feedstock

The following wastes/feedstocks are accepted by the Licence Holder for use in the composting process:

Piggery bedding

Animal manures (pig, chicken, cow, horse, and potentially others)

Animal mortalities (pig, chicken, kangaroo, and rabbit)

Dewatered screenings from CM Farms piggery wastewater treatment plant (dry solids containing manure and pig hair)

‘Off spec’ dairy products (considered a solid when in spadeable form), and other food waste

Greenwaste (municipally source-separated and ground)

Untreated timber (sawdust and various other wood fractions)

Natural fibrous organics (straw, grain husks, and other crop waste)

Mushroom compost (generally spent compost)

The Licence Holder accepts the piggery bedding, pig manure, and pig mortalities from the

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adjacent CM Farms piggery. The pig mortalities are semi-composted within a static composting tunnel within CM Farms prior to acceptance at the Premises.

The Existing Licence does not include any conditions limiting the types of solid wastes which may be accepted.

Between 1 July 2015 and 30 June 2016, the Licence Holder accepted approximately 53,700 tonnes of solid waste/feedstock at the Premises. The Licence Holder advised that this volume is “significantly less than that required to produce the maximum licence capacity of 90 000 tonnes of compost/blended soil” (Bell 2016 [email]).

Liquid waste

The Existing Licence limits the types of third party liquid wastes (set out as Controlled Wastes) which may be accepted by the Licence Holder. The third party liquid wastes which may be accepted are listed in Appendix 3.

The main Controlled Waste types which were accepted by the Licence Holder during the previous three calendar years (2014 to 2016) were:

Waste from grease traps (K110)

Animal effluent and residues (K100)

Waste oil and water mixtures (J120)

Food and beverage processing waste (K200)

Non-toxic salts (D300)

Basic solutions (C100)

Industrial waste water contaminated with a controlled waste (L150)

Between 1 January 2016 to 31 December 2016, the Licence Holder accepted approximately 52,000 tonnes of controlled liquid wastes. The Existing Licence limits the volume of liquid waste which can be accepted under Category 61 to 60,000 tonnes per annum.

The Licence Holder also accepts sludge and treated wastewater from the ponds of adjacent CM Farms piggery. The volume of these wastes that is accepted has not previously been monitored, however the Licence Holder has estimated the current annual volume at approximately 4,000m3 of sludge and 8,000m3 to 10,000 m3 of treated wastewater.

The volumes of wastewater and sludge sourced from CM Farms has previously not been considered to fall within the Category 61 design capacity due to the historical association between the premises. This is due to the fact that the Existing Licence defines ‘third party liquid wastes’ as liquid wastes produced on premises other than Lot 90 and Lot 109 on Plan 741. This review has identified that CM Farms is a separate premises with a separate boundary and therefore the use of piggery wastewater and sludge must be considered to be from other premises, and will be treated as such in this review.

The Departments review of the controlled wastes accepted at the Premises is included in Appendix 3.

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Key findings

The Delegated Officer has reviewed the information regarding the acceptance of liquid waste and has found:

1. Piggery wastewater and sludge sourced from CM Farms is to be considered in calculating the throughput for Category 61 activities.

2. For the majority of the liquid waste types currently accepted at the Premises, DWER has insufficient information for the characterisation of these waste types, such as the contaminants which they may contain and the concentrations of these contaminants.

3. DWER has insufficient information to determine whether potential contaminants within the majority of the liquid waste streams are treated through the composting process, or remain untreated within the compost product.

3.2.2 Solid feedstock handling/processing prior to mixing

Timber and greenwaste may undergo screening or grinding within the Premises to achieve the desired fraction sizes.

3.2.3 Mixing of liquid and solid feedstocks

The Hardstand areas within the Premises are divided into certified organic composting (Western Hardstand) and non-certified composting (North Eastern and South Eastern Hardstands).

Certified organic composting

The inputs to the certified organic composting may include grain husks and other crop waste, straw, sawdust, wood chippings, piggery manure and bedding, dewatered piggery screenings, mushroom compost, chicken manure, and piggery pond wastewater and sludges. The piggery wastewater is sourced from CM Farms ponds 5 and 6, which are the final two ponds in the treatment train.

The certified composting does not incorporate the controlled wastes accepted at the Premises.

In the certified composting area, wastewater and sludge from piggery ponds are initially mixed with solid feedstocks via the following methods:

Initial wetting of solid feedstocks with piggery pond wastewater via sprinklers.

The direct deposition of sludge into a bund made of solid feedstocks. This material is turned onto itself and then incorporated into composting windrows immediately.

Non-certified composting

The inputs to the non-certified composting may include greenwaste, animal mortalities, chicken manure, food waste, sludge from the C-Wise ponds and the range of liquid wastes accepted at the Premises.

In the non-certified composting area, liquid wastes and sludge from the C-Wise ponds are initially mixed with solid feedstocks via the following methods:

Initial wetting of solid feedstocks with wastewater from Ponds 31 and 32.

Direct deposition of liquid wastes (upon delivery to the site) and sludge (upon

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extraction from ponds) into a bund made of solid feedstocks, referred to as the organics receival bund. This is a U-shaped porous bund of compacted greenwaste, with a bed of greenwaste on the bottom. The organics receival bund receives most liquid wastes accepted at the Premises during a day. By the end of each day all of the wetted greenwaste is removed for placement on a mobile aerated floor (MAF) system. The bund is intended to capture solids and absorb some liquid. Excess liquid passes through the bund and flows into Pond 21 and Pond 22 via a leachate drain. The dry bund material remains in place for a week before it is dismantled, mixed with liquid wastes and placed on a MAF system.

For liquid wastes which are determined by the Licence Holder to be incompatible for immediate or entire inclusion into the composting process, these are deposited into a separate bund made of solid feedstocks. This material is turned onto itself and incorporated gradually into composting windrows.

Wet well waste (Controlled Waste Code K130) is deposited into a separate porous bund, allowing liquid to pass through but retaining solid rubbish from the wet well waste to be collected and disposed of to landfill.

Animal mortalities are blended with the mixed material from the organics receival bund each day, prior to the material being stacked on MAF.

3.2.4 Composting process

Whether certified or non-certified, the process of composting is similar with batches initially mixed (according to a recipe for the intended end-product) and tested for carbon, nitrogen, pH, electrical conductivity, and moisture.

In the non-certified composting area, immediately after the initial mixing, the windrows are placed on a MAF system to maintain oxygen levels within the composting material.

In the certified composting area, the carbon source solid feedstocks are pre-wetted for approximately two weeks with piggery wastewater. The nitrogen source solid feedstocks are then added and the material is placed in windrows (not on MAF system) for approximately two weeks. During this period the windrows are turned every two to three days. The material is then moved onto a MAF system.

In either the certified and non-certified areas, once windrows are on a MAF, they undergo several ‘stages’ with each stage involving two weeks (stationery). Between each ‘stage’ the MAF is relocated and the material is moved into the new location (effectively the material is “turned” in this way). The MAF operates on a timer which controls the periods of aeration.

In the certified composting area, piggery pond wastewater is added to composting windrows through sprays on compost turning equipment or by the use of sprinklers.

In the non-certified composting area, wastewater from Pond 32 (and occasionally Ponds 21, 22 or 31) is added to composting windrows through sprays on compost turning equipment or by the use of sprinklers.

In all cases, leachate and liquid wastes are only incorporated up until the end of the first stage of composting on MAF; with only clean water being applied as needed thereafter so that the composting material is not re-contaminated.

The required moisture content throughout the composting process varies across the different compost products produced. The minimum moisture content which is generally aimed for at the start of the composting process and generally maintained during the process has been provided by the Licence Holder and considered by DWER.

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3.2.5 Final product

The Licence Holder has an Allowed Input Organic Certification through Australian Certified Organic for some compost products.

There are various final product lines within the certified and non-certified products. Different products require different screening sizes and varying addition of soil materials such as clays and sands.

After the required MAF stages, material is screened to achieve the required fraction sizes for the product, and then stored. Final product for dispatch is sometimes stored in windrows and turned.

End uses of the products include agricultural land improver, land rehabilitation, home lawns and gardens, dressing of parks and playing fields or other above ground use in urban settings, crops, pasture, horticulture and turf.

3.2.6 Liquid waste treatment and storage in ponds

Multiple ponds within the Premises treat and/or store liquid wastes and collected runoff from Hardstands within the Premises. The direction of flow between the ponds is shown in Figure 3.

Ponds 21, 22, 31 and 32 do not receive any direct discharges of liquid wastes from waste carriers, but Ponds 21 and 22 do receive the liquid waste runoff from the North Eastern hardstand within the Premises. Pond 22 receives the majority of liquid waste runoff, which is from the organics receival bund located immediately south of the pond.

The Licence Holder has estimated that approximately 86% (~51,600 tonnes) of the total volume of liquid wastes which may be accepted per annum (excluding piggery wastewater from CM Farms) is received directly into the organics receival bund, though only 38% of the total volume (~22,800 tonnes) is captured by these solid feedstocks, resulting in approximately 48% of the total volume (~28,800 tonnes) draining into ponds 21 and 22.

The contents of Ponds 21 and 22 are treated by dosing with chemical oxygenation medium, on a weekly and daily basis respectively. Aerators are also operated within these two ponds.

Oily wastewater, currently comprising approximately 14% of the total volume of controlled liquid waste accepted (~8,400 tonnes), is discharged directly into Ponds 23 and 24. This waste is not subject to any treatment within the ponds.

Pond 25 contains historic lime waste which has been utilised in small amounts over a period of years, and is not subject to any treatment within the pond.

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Figure 3: Flow direction between liquid waste treatment/storage ponds

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3.3 Water balance

Water balance calculations have been conducted for the Premises to assess the current storage requirements and storage capacity of the ponds. Details of this review are included in Appendix 4.

Key findings

The Delegated Officer has reviewed the water balance estimations for the Premises and has found:

1. It is estimated that the ponds at the Premises do not have sufficient volume to accommodate the storage requirements of the current operating scenario, in which the runoff from all hardstands within the C-Wise Premises is directed to the C-Wise pond; however years of low rainfall would allow for additional capacity.

3.4 Proposed re-direction of pre-wetting area runoff

Prior to 2016, the runoff from the entire Western Hardstand was directed into the pond within the CM Farms premises which is immediately north of the Western Hardstand (Pond 1 at that time). DWER required that this discharge ceased, which is further discussed within section 0 below. The runoff from the Western Hardstand has since been directed into Ponds 21 and 31 within the Premises.

The Licence Holder has proposed to re-direct the runoff from a portion of the Western Hardstand (the C-Wise pre-wetting area) to Pond 2 within the CM Farms premises, as shown in Figure 4. The Memorandum of Understanding prepared by the Licence Holder and CM Farms for this arrangement specifies that CM Farms shall install the drainage system from the pre-wetting area to CM Farms Pond 2 (C-Wise & CM Farms 2017).

This proposal would slightly reduce the inputs to Ponds 21 and 31 as the runoff from the application of piggery water and bore water within the pre-wetting area and the rainfall which falls within that section of the hardstand would instead be directed into CM Farms Pond 2.

The Licence Holder has proposed that they also maintain the option to direct this runoff to Pond 21 within the Premises.

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Figure 4: Proposed re-direction of pre-wetting area runoff

3.5 Proposed construction of additional pond

In March 2017 the Licence Holder submitted an amendment application to DWER, for the construction of an additional pond within the Premises (Pond 33).

The Licence Holder has proposed the additional pond for the purpose of alleviating the current storage capacity shortage within the Premises. The storage requirements for the Premises increased in 2016 following DWER’s requirement to cease the discharge of runoff from the Western Hardstand into Pond 1 within the CM Farms premises, as discussed within section 0 below.

The proposed pond would have a storage capacity of 40,000m3, would be located immediately east of existing Pond 32 and would receive water flow from Pond 32. The pond would significantly increase the storage capacity within the Premises, as the combined storage capacity of the existing seven ponds is approximately 69,000m3.

4. Legislative context

4.1 Contaminated sites

Lots 89 and 109 on Plan 741 were classified as contaminated – restricted use under the Contaminated Sites Act 2003 on 19 March 2010. The classification was based on the identification of elevated levels of nutrients in groundwater beneath the site. At the time of classification, available monitoring data suggested that the contaminant plume was stable and

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was unlikely to migrate beyond the property boundary due to natural attenuation processes. Ongoing periodic groundwater monitoring was noted to be required in accordance with relevant licence conditions under the Environmental Protection Act 1986.

DWER undertook a review of the site’s classification under the CS Act during early 2018, this review included the assessment of groundwater data resulting from routine licence monitoring, and the results of detailed site investigations undertaken during 2016 and 2017. Upon completion of the review, DWER concluded that the classification remains appropriate. However, several uncertainties and data gaps were identified that require further action to be taken to address the contamination status of the site. The classification remains contaminated – restricted use, however the ‘nature and extent’, ‘reasons for classification’ and ‘restrictions on use’ were updated on 1 June 2018 to reflect the additional technical information that has become available since the site was originally classified in 2010. Formal notices of the update to the site classification were issued to all relevant parties, including the licensees, on 11 June 2018.

4.2 Lease agreement

The Licence Holder has an agreement in place to sublease from Derby Industries Pty Ltd who lease the Premises from George Weston Foods Limited. The agreement expires on 5 November 2018, with an option to extend for 4 years to 5 November 2022.

4.3 Planning approvals

The Premises received planning approval on 2 April 1997 from the Shire of Murray under the Shire of Murray Town Planning Scheme No. 4 for the development of a composting facility.

The Premises holds a current Certificate of Registration of Premises for an Offensive Trade from the Shire of Murray for a composting facility. The registration is renewed annually.

4.4 Department of Health

The Licence Holder has submitted to the Department of Health an Application for Approval of Composting Materials, required under Part IV, section 98 of the Health Act 1911. The application is currently being assessed by the Department of Health.

4.5 Groundwater Licence

The Licence Holder holds Licence number GWL166732(2) to take water, issued by DWER under the Rights in Water Irrigation Act 1914. This licence entitles an annual abstraction of up to 350 000kL for compost production and soil blending purposes and irrigation of up to 10ha of pasture. The Licence is valid until 13 July 2022. The production bore is located close to monitoring bores 3A and 4.

4.6 Department of Primary Industries and Regional Development

The Premises is located within the area to which the Biosecurity and Agriculture Management (Stable Fly) Management Plan 2016 applies. This plan prohibits the storage and transport of commercially derived poultry manure which has not been treated by composting to AS 4454, or by means of a measure approved under the Biosecurity and Agriculture Management Act 2007, without the prior approval of the Department of Primary Industries and Regional Development (DPIRD).

The Licence Holder has advised that an application for ‘Prior Approval of the Director General under the Biosecurity and Agriculture Management (Stable Fly) Management Plan’ is currently being considered by DPIRD.

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4.7 Environmental Protection (Peel Inlet-Harvey Estuary) Policy 1992

Section 60(1) of the EP Act states that ‘The CEO shall in considering an amendment of a licence or an application for a works approval or a licence for the transfer thereof ensure that the works approval or licence or amendment or transfer thereof is consistent with any approved policy’. The Premises is located with the boundary of the Environmental Protection (Peel Inlet-Harvey Estuary) Policy 1992 (EPP) and therefore the Delegated Officer must consider the requirements of this policy.

The EPP sets environmental quality objectives for the Estuary to help rehabilitate and protect it from degradation. The EPP states the use and values of the Estuary as:

For studying the natural environment;

Habitat for a diverse range of fauna and flora;

Commercial and amateur fishery;

Recreation, tourism and landscape amenity; and

A focus for residential development.

The basis for protection of the Estuary as stated in the EPP is:

Nutrient enrichment of the Estuary has been caused by the clearing of native vegetation in the policy area and by land uses that result in nutrients, especially phosphorus, leaching into waterways in the policy area and then flowing into the Estuary.

Nutrient enrichment in the Estuary has stimulated the excessive growth of algae, causing the degradation of the Estuary and creating a serious public nuisance.

The objectives of the EPP include a median load of phosphorus flowing into the estuary of less than 75 tonnes, with the median load of phosphorus from the Serpentine River being less than 21 tonnes.

The EPP states that its objectives are to be achieved and maintained through:

Implementation of planning policy including Metropolitan Regional Scheme;

Appropriate land management by landholders and management authorities in the Policy area;

Advice from government services to land holders in the area;

Local and State Government authorities ensuring that decisions and actions are compatible with the objectives and maintenance of Policy’s objectives.

4.8 Part V of the EP Act

This section covers Works Approvals and Licences issued under Part V of the EP Act and compliance with the conditions of those instruments.

4.8.1 Guidance Statements

The overarching legislative framework of this assessment is the EP Act and EP Regulations.

DWER Guidance Statements which inform this assessment are:

Guidance Statement: Regulatory Principles (July 2015)

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Guidance Statement: Risk Assessments (February 2017)

Guidance Statement: Decision Making (February 2017)

Guidance Statement: Setting Conditions (October 2015)

Guidance Statement: Land Use Planning (February 2017)

Guidance Statement: Licence Duration (August 2016)

4.8.2 Works approvals and licence amendments

Table 4 provides a list of licences granted for the Premises since 2013. DWER has no record of any works approval being issued to WA Composts Pty Ltd. Each licence amendment is further detailed in the table below.

Table 4: Instrument log

Instrument Issued Description

May 2013 – amendment

L8410/2009/1 Increase the design capacity on the Licence as follows:

Category 61 – increased from 40,000 to 60,000 tonnes per annum.

Category 67A – increased from 48,000 tonnes to 125,000 tonnes per annum.

The amendment was requested by the Licence Holder based on projected production following the introduction of the MAF system within the process.

April 2015 – renewal

L8410/2009/2 Reduction in the design capacity on the Licence as follows:

Category 67A – reduced from 125,000 tonnes to 90,000 tonnes per annum.

The amendment was requested by the Licence Holder to reduce the annual licence fees, based on the production at that time being approximately 50 000 tonnes and not expected to reach 90 000 tonnes for several years. The amendment included some administrative updates.

October 2015 – amendment

L8410/2009/2 Licence expiry date extended from 28 October 2015 to 28 January 2016 and administrative updates made. Generic odour conditions were removed to avoid duplication with section 49 of the EP Act.

January 2016 – amendment

L8410/2009/2 Licence expiry date extended from 28 January 2016 to 31 March 2016.

March 2016 – amendment

L8410/2009/2 Licence expiry date extended from 31 March 2016 to 28 October 2017.

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4.8.3 Compliance inspections

The following compliance inspections were conducted by the then DER between March 2016 and December 2016.

Compliance inspection 10 March 2016

The Department conducted a compliance inspection of the Premises on 10 March 2016. The Licence Holder provided information to address the issues raised within the compliance inspection report as listed in Table 5.

Table 5: Outcomes of compliance inspection on 10 March 2016

Issue raised Outcome

Liquid waste acceptance practices and lack of testing/treatment prior to application to greenwaste.

Deposited liquid wastes can remain within the organics receival bund (bund of greenwaste) for a week, potentially becoming anaerobic prior to deconstruction of the bund.

The Licence Holder stated that there is testing of liquid wastes to determine acceptability on the basis of aspects such as biodegradation and odour production.

June 2016 - Implementation of a new liquid waste receival process in which liquid waste is held within the organics receival bund (greenwaste bund) for 1 day rather than 7. The bund is deconstructed daily.

Material from the organics receival bund deconstruction is now accumulated over two weeks (to make a batch) on a Stage 0 MAF system rather than in a static pile prior to being moved onto MAF for Stage 1 (as was previously being done).

Progressive reduction in mortalities stockpile, and a new process of mortalities incorporated with mixed material on day of receival. Static composting (stockpile static for 6-7 weeks after covering) of mortalities is no longer occurring.

Acceptance and re-use of wastewater from third parties without sufficient information on water quality.

The Licence Holder provided the parameters tested and frequency of testing of CM Farms ponds 1 and 5.

Lack of sampling and analysis from ponds in relation to known odorous parameters.

The Licence Holder provided the parameters tested and frequency of testing of C-Wise ponds.

Pond water quality monitoring results were provided to the Department as requested.

The Licence Holder stated that odour is produced as a result of the accumulation of sludge on the bottom of ponds 21 and 22, and that chemical oxidants and enzymes were being used to degrade the sludge. Three different physical/enzymatic treatments were being trialled.

Runoff from the certified composting area is directed into a pond within CM Farms (Pond 1 at that time) which is no longer operational.

The Department requested that the discharge to the CM Farms pond is ceased in accordance with the Environmental Protection (Unauthorised Discharge) Regulations 2004.

A new drain from the certified composting area (Western Hardstand area) has been constructed as a temporary solution to direct runoff from that area (which previously flowed into the CM Farms pond) to Pond 21 and Pond 31.

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Compliance inspection 9 December 2016

The Department conducted a compliance inspection of the Premises on 9 December 2016. The record of the inspection confirms that, following the previous inspection in March 2016, a new process of liquid waste receival within the organics receival bund has been implemented, and the new drain diverting runoff from the organics composting area to Pond 21 and Pond 31 is operational.

4.8.4 Site visit 27 May 2016

A DWER Officer attended the Premises on 27 May 2016, in response to odour complaints received that day. The organics receival bund, the mortalities stockpile, and Ponds 21 and 22 were identified as potential sources of the odours which had been observed off-site that day.

The officer observed that the whole surface area of Pond 22 (except some dead zones, e.g. pond corners) was covered with small bubbles which were emerging from the water and could not be attributed to the aeration system. These bubbles were thought to be biogas being released due to biological and chemical reactions occurring within the sludge; however, the composition of the gas being released was not known.

4.8.5 Site visit 13 October 2016

To inform this Review, DWER Officers attended the Premises on 13 October 2016. The following observations were noted:

The upgrades to the Hardstands are completed, with some limestone Hardstand areas replaced with bitumen and concrete Hardstand.

The new drain directing leachate from the certified organic composting area to Pond 21 and Pond 31 was in the final stages of construction.

No observations were noted regarding odour experienced at the Premises at the time of the inspection.

4.8.6 Site visit 5 July 2017

DWER Officers attended the Premises on 5 July 2017. During this visit small bubbles, thought to be biogas, were again observed rising to the surface of Ponds 21 and 22. Distinct odours were observed from both ponds.

4.8.7 Annual Reports

The Existing Licence requires the annual submission of the following reports:

Annual Monitoring Report (AMR) - providing the quantity of compost produced, the volume of third party liquid waste (per Controlled Waste Category) received and the results of groundwater monitoring within the annual period.

Annual Audit Compliance Report (AACR) – stating the extent to which the Licence Holder complied with the conditions of the licence during the annual period.

January 2016 – December 2016

It was reported in the AMR that monitoring bore MB4 was destroyed by heavy machinery during 2016 and was replaced by monitoring bore MB4A in January 2017. The second sampling event for 2016 for bore MB4 was not conducted. A sampling event for bore MB4A was conducted in January 2017 instead.

This non-compliance was reported within the AACR. No other non-compliances were reported for the annual period.

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It was reported in the AMR that “a number of upgrades and improvements were made to processing areas, including converting some compacted limestone areas to bitumen and upgrading drains/bunding of Hardstands”

The AACR reported the following non-compliances during the annual period:

Storage of some product (finished products or by-products such as potting mix base and oversize screen material) off a compacted limestone/Hardstand surface. The non-compliance was identified through an internal compliance audit initiated by the Licence Holder in February 2015.

Odour release from an anaerobic reaction within Pond 25. Reported as “detected from 8/5/15, decreasing due to treatment until the 13/5/15 when it appeared to have been controlled. Odour returned 21/5/15 and decreased due to further remediation until the 26/5/15 when it was controlled”. The Department issued environmental field reports on 8 May 2015 and 21 May 2015 in relation to these odour events.

Freeboards in Ponds 24 and 25 reducing to less than 300mm for a period of time, caused by rainfall and isolation of ponds involved in odour events during May 2015. No overflow occurred.

Overflow onto bare earth of a potential maximum of 10,000 litres of leachate/runoff collected within a sump prior to flow into Pond 21, on 1 June 2015. The overflow was reported as being “water that was discharged from the end of [C-Wise’s] dam treatment train subsequent to passing through a biofilter (not raw controlled waste)”, and was caused by the blockage of a drain. It was identified by the Licence Holder that this overflow could potentially cause minor groundwater contamination.

Potential odour release from anaerobic reaction within Pond 22 on 13 October 2015.

Groundwater samples from bores MB2-MB5 not analysed for some of the required parameters due to a chain of custody analysis request form being completed incorrectly.


The AACR reported the following non-compliances during the annual period:

Storage of some product (sawdust, timber feedstock and finished products or by-products such as woody mulches, potting mix base, and oversize screen material) off a compacted limestone/Hardstand surface. The non-compliance was identified through an internal compliance audit initiated by the Licence Holder in February 2015.

Pooling of leachate/runoff on compacted limestone and off compacted limestone due to changes in levels for adequate drainage from general wear.

Groundwater sample from MB5 not collected in January 2014 due to the bore being too shallow to reach the summer groundwater depth.

4.8.8 Compliance history check

The incidents and non-compliances recorded within the Department’s Incident and Complaints Management System (ICMS) for the Premises since 2013 are listed within Table 6. All of the items have been closed out.

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In addition to the incidents recorded within ICMS, in undertaking this Review it was identified that the Department’s Controlled Waste Tracking System indicates the following controlled wastes were accepted during 2012 and 2015, which were not approved for acceptance under the Licence:

2012 - Waste mineral oils unfit for their intended purpose (J100) (12500 litres)

2012 - Clinical and related wastes (R100) (7390 litres)

2015 - Arsenic and arsenic compounds (D130) (9000 litres)

The Licence Holder has advised that these records are due to administrative errors in the entering of tracking information in the Controlled Waste Tracking System, and that these categories of waste were not accepted at the Premises.

Table 6: Incidents/non-compliances recorded within ICMS

No. Date Incident/non-compliance

38211 13/10/15 Odour release from an anaerobic reaction within Pond 22 (as reported in 2015 AACR). Section 72 Waste Discharge Notification form completed by Licence Holder.

37020 01/06/15 Discharge of leachate/runoff to land within the Premises due to a blockage in the drain leading to Pond 21 (as reported in 2015 AACR). Section 72 Waste Discharge Notification form completed by Licence Holder.

36881 21/05/15 Odour release from an anaerobic reaction within Pond 25 (as reported in 2015 AACR). The then DER issued Environmental Field Report numbers 4601 and 2352. Section 72 Waste Discharge Notification forms were completed by Licence Holder for both events.

36750 and 36749

08/05/15

37122 2014 Non-compliances reported within 2014 AACR are logged in ICMS. Non-compliances relate to storage of some products, pooling of leachate and a bore sample not collected.

5. Modelling and monitoring data

5.1.1 Groundwater monitoring

DWER undertook a review into the groundwater monitoring data provided by the three premises at Nambeelup Farms over the 2010 to 2017 period. Details of this review are included in Appendix 5.

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Key findings

The Delegated Officer has reviewed the groundwater monitoring programs and has found that:

1. A shared approach and consistent methodology for all premises will facilitate better understanding of contamination events and the effectiveness of controls.

2. Synchronising monitoring bore sampling across all three sites is necessary to allow more comprehensive and meaningful data interpretation.

3. Mercury, zinc and arsenic should be included in the monitoring suite of analytes to ensure that the potential risk to human health and the environment from this type of contamination can be assessed.

4. The selected suite of analytes with the addition of selected metals is considered appropriate for the characterisation and detection of groundwater contamination caused by nutrient rich leachates derived from organic materials. It is not sufficient for leachates from C-Wise operations due to the types of liquid wastes currently received.

5. Testing for PFAS should be included in the next groundwater monitoring event. The Delegated Officer has reviewed the spatial configuration of the existing monitoring bore network and has found:

6. The existing monitoring network, when used as an integrated network across premises’ boundaries, is considered sufficient to identify whether containment infrastructure such as ponds and hardstands are effectively controlling leachate emissions.

7. The monitoring network is not able to identify contamination sources at a small spatial scale such as a single pond. Additional investigations in the form of seepage rate measurements are required for this purpose.

8. The monitoring network includes bores located up and down hydraulic gradient at varying distances from the potential operational contamination sources allowing the determination of a suitable background level against which bores influenced by site sources can be compared.

9. The current network does not allow detailed tracking of contamination and plume delineation, and is insufficient to inform on the risk of impacts on sensitive receptors.

The Delegated Officer has reviewed groundwater monitoring data illustrated in Appendix 5 and concluded that:

10. Groundwater monitoring results infer that groundwater flow in the area of interest is in a south-westerly direction.

11. The levels of nutrients in multiple bores indicate that containment infrastructure integrity may be compromised at all three premises resulting in potential seepage to groundwater.

12. A groundwater contamination plume is likely to extend from the operational area in a south-westerly direction towards sensitive environmental receptors located downgradient from the premises.

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The Delegated Officer has reviewed groundwater monitoring data from C-Wise bores illustrated in Appendix 5 and concluded that:

13. The submitted data has significant gaps requiring improvements in data quality and consistency in future submissions.

14. High ammonia levels have been detected in bore CW05A indicating the likely presence of a nearby contamination source.

15. Given the observed fluctuations and levels of contaminants recorded in some bores, the current biannual sampling regime is not considered sufficient to adequately document environmental performance and determine contamination sources.

16. High nutrient levels in multiple bores indicate that there is likely to be a contaminant source or sources nearby, which need to be identified. It is therefore necessary to confirm through testing that containment infrastructure on site is effective.

5.1.2 Odour

Due to a marked increase in complaints received by the Department in the Mandurah area (Appendix 6, Fig. 1), the Department undertook the Mandurah Odour Investigation to ascertain which odour sources were the major contributors to odour impacts in the Mandurah area and, if possible, to determine the odour impact extent of those sources. Details of the complaints and the investigation are included in Appendix 6, with the final odour investigation included in Appendix 7.

Key findings

The Delegated Officer has reviewed the odour complaint information and odour investigation and has found:

1. There is a potential pathway for odours to travel over 8km from the Premises.

2. Odour emissions observed in the Mandurah area are mainly attributable to the Nambeelup Farm premises.

A Technical Expert Report was prepared by the Department’s Air Quality Services function in November 2016, which includes a review of the documentation shown in Table 7, which was provided to the Department in relation to the Nambeelup Farm.

The report is included in Appendix 8.

Table 7: Odour investigation reports

Document Author Date of document

Hardcopy report:

Draft Investigation of Odour Emissions from Nambeelup Precinct Operations.

David Pitt, Environmental Alliances Pty Ltd (ENVALL)

July 2016

Waste water quality Laboratory Report (ARL job number 16-03831 Revision 01) contained as an attachment in a hardcopy request for advice from DER Acting Executive Director Compliance and Enforcement.

Analytical Reference Laboratory (ARL)

20 June 2016

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Key findings

The Delegated Officer has reviewed the information regarding the Premises in the Department’s Technical Expert Report and has found:

1. The area receiving liquid waste and mortalities for processing within the Premises was amongst the largest estimated odour sources across all of the operations within Nambeelup Farms.

2. There is a significant risk of odour emissions from Pond 21 and Pond 22 at the Premises, represented by the combined low levels of Dissolved Oxygen (DO) and Oxidation Reduction Potential (ORP) within the pond water. The low ORP values represented a risk of production of sulfides (H2S) and fatty acids; two chemical families of odorous compounds.

3. The re-use of pond water in large quantities over a wide surface area results in an odour source with a large surface area, thus increasing odour emissions.

6. Consultation

DWER met with the Shire of Murray and the City of Mandurah during the Review. No formal comments were received from these stakeholders.

The Review was advertised on the DWER website for a period of 25 calendar days from 24 October 2017. No comments were received from the public. Location and siting

6.1 Siting context

Nambeelup Farm is in the locality of Nambeelup in the Shire of Murray and is approximately 60km south of Perth, and approximately 10km northeast of Mandurah town centre. The premises location is shown in Figure 5.

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Figure 5: Regional location of Nambeelup Farm

The relative location of the three Nambeelup Farm premises is shown in Figure 6. The immediate surrounding land is predominantly undeveloped land and rural properties, with a number of commercial kennels located to the south. Murray field airport, a small private airport run by the Royal Aero Club of Western Australia, is located directly south of the premises.

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Figure 6: Delineation of Nambeelup Farm premises (CM-Farms premises is Lot 89 and 109)

6.2 Residential and sensitive premises

The approximate distances to residential receptors from the operational area of the Premises are shown in Table 8 and on Figure 7. Distances were measured using the Intramaps Mapping System on the Shire of Murray’s website.

Table 8: Receptors and distance from activity boundary

Sensitive Land Uses Distance from Prescribed Activity

Murrayfield Airport Approximately 500m south of the Premises boundary

Rural residential premises 1 Approximately 1,100 m south-west of the Premises

Rural residential premises 2 Approximately 1,990 m south-east of the Premises

Nearest residential development (Stake Hill) Approximately 3,160 m north-west of the Premises

Southern portion of Stake Hill residential area Approximately 3,300 m north-west of the Premises

Barrangup residential area Approximately 3, 750 m south-west of the Premises

Mandurah townsite Approximately 10,000 m south-west of the Premises

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Figure 7: Distance to residential receptors from the Premises

6.3 Specified ecosystems

The distances to specified ecosystems are shown in Table 9 and on Figure 8 and Figure 9.

Table 9: Specified ecosystems

Specified ecosystems Distance from the Premises

Nature reserve Crown land vested in the Conservation Commission of Western Australian for the conservation of flora and fauna is located approximately 700 m to the south west of the Premises

Threatened Ecological Communities and Priority Ecological Communities

A threatened ecological community is located approximately 5km to the south west of the Premises

Rare flora The Premises is located within an area approximately 20km by 9km known to contain declared rare flora.

Other relevant ecosystem values Distance from the Premises

Environmental Protection Peel Inlet – Harvey Estuary Policy 1992

The Premises is within the Policy area

Rights in Water and Irrigation Act 1914

Surface Water (Serpentine River System)

Groundwater (Murray)

Within the Premises boundary

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6.4 Groundwater and water sources

The distances to groundwater and water sources are shown in Table 10 and Figure 8 to Figure 12.

Table 10: Groundwater and water sources

Groundwater and water sources

Distance from Premises Environmental Value

Groundwater Groundwater is generally less than 2m from the ground surface across the Premises area (see Figure 10).

Data provided by Marillier, 2012 indicate that the regional direction of groundwater flow may be in a west to north-westerly direction towards the Serpentine River (see Figure 11).

There may be local variations in flow direction near Nambeelup Farm due to the presence of water table management drains, seepage from ponds, and local groundwater abstraction. This is evident in small scale groundwater monitoring and contours at the Nambeelup Farm area documented by Geo and Hydro (2010)1 that indicate groundwater flow in a south-westerly direction.

There are several abstraction bores within the vicinity and down hydraulic gradient from the Premises which are used for livestock watering and irrigation (see Figure 12)

RAMSAR wetland Peel-Yalgorup System (Peel Estuary-Harvey Inlet) located over 11km west-southwest of the Premises.

Wetland of international significance.

Geomorphic Wetlands There are five conservation category wetlands within 1km of the Premises operational areas:

One approximately 1km south-west of the Premises;

Two approximately 800m and 600m south-east of the Premises; and

Two approximately 400m and 800m north of the Premises.

Conservation category

Wetlands (see Figure 9Error! eference source not found.).

1 Geo and Hydro Environmental Management Pty Ltd 2010: Watertable contours across Custom Compost Lot 230 Nambellup Rd Nambellup, Figure 5. Submitted by Custom Compost

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Groundwater and water sources

Distance from Premises Environmental Value

Waterbodies The Nambeelup Brook is located approximately 2km east of the Premises.

The Serpentine River is located approximately 2.5km west of the Premises.

Goegrup Lake is approximately 5km south west of the Premises and is fed by both the Serpentine River and Nambeelup Brook.

All three waterbodies are Conservation category wetlands (western end of Nambeelup Brook only) and ultimately drain to the Peel Harvey Estuary.

Figure 8: Specified ecosystem and water resource locations within regional area

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Figure 9: Specified ecosystem and water resource locations within local area

Figure 10: Depth to groundwater (Marillier, B 2012)

Nambeelup Farm operational area

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Figure 11: Annual Average maximum groundwater level (Marillier, 2012)

Figure 12: Water extraction bores

Nambeelup Farm Operations Area

Nambeelup Farm operational area

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6.5 Soil type

The Premises is underlain by sandy sediments that comprise the Bassendean Sand and Gnangara Sand units of the superficial formation which has a combined thickness of approximately 10m in the area. These sediments are in turn underlain by the sandy sediments that comprise the Rockingham Sand unit. The superficial formations and the Rockingham Sand unit together form an extensive unconfined aquifer that that has a combined saturated thickness of 40m to 50m in the area (Hall et al., 2010; Marillier, 2012).

6.6 Meteorology

6.6.1 Wind direction and strength

The following wind roses (Figure 13) provide the annual wind direction and strength (km/h) for 9am and 3pm between the years 1988 and 2001 in Mandurah (BoM 2016). The region has a dominant wind direction consisting of easterly winds during the morning and south-westerly winds in the afternoon.

Figure 13: Wind roses for Mandurah at 9am and 3pm (BoM 1988-2001)

6.6.2 Rainfall and temperature

The Nambeelup locality experiences mild wet winters and hot dry summers. Figure 14 shows the mean rainfall and maximum temperatures for Mandurah for the period 2001-2016. Mandurah receives a mean annual rainfall of approximately 670mm.

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Figure 14: Mean temperature and rainfall at Mandurah (BoM 2001-2016)

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7. Risk assessment

7.1 Confirmation of potential impacts

Identification of key potential emissions, pathways, receptors and confirmation of potential impacts are set out in Table 11 below. Table 11 also identifies which potential emissions will be progressed to a full risk assessment. Some potential emissions/impacts may not receive a full risk assessment where a potential receptor or pathway cannot be identified.

Table 11: Identification of key emissions

Potential

Emissions Potential

Receptors Potential Pathway

Potential Impacts Continued to detailed risk assessment?

Reasoning

Solid feedstock acceptance, handling and storage

Unloading/movement of solid feedstocks

Storage of feedstock (greenwaste storage on bare ground)

Screening or grinding of some solid feedstocks (e.g. timber)

Leachate and liquid wastes:

Run-off from Hardstand

Seepage through Hardstands

Peel-Yalgorup RAMSAR Wetland/Peel Inlet and Harvey Estuary EPP area Overland flow

Seepage through soil

Transport through groundwater

Increased phosphorus load on Peel Inlet and Harvey Estuary catchment leading to contamination of surface waters

Contamination of surface waters at the point of groundwater expression

Impact the biological diversity of wetland flora and fauna including thrombolite and water bird species

Yes See section 7.4

Groundwater (abstraction bores)

Contamination of groundwater supply for nearby users

Yes See section 7.4

Geomorphic Wetlands – Conservation category wetlands


Yes See section 7.4

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Potential

Emissions Potential



Reasoning

Nambeelup Brook

Contribute to eutrophication and algal blooms which can impact ecosystem function

No

Nambeelup Brook is located approximately 2.5km up gradient from the Premises. Seepage is not considered likely to travel to this receptor.

Serpentine River Yes See section 7.4

On site premises and adjoining land

Contamination of soil Yes See section 7.4

Nature reserve Impact on biological diversity of flora and fauna within conservation area

Yes See section 7.4


Impact on the biological diversity of sensitive ecological communities

Yes See section 7.4

Odour

Residential receptors – nearest residence approx. 1.1km south-west

Patrons of air field located 500m south

Air (windborne)

Impacts to amenity and wellbeing

Yes See section 7.5

Dust including bioaerosols

Amenity impacts from visible dust plumes and deposition on property

Nuisance impacts

Public health effects from inhaled particulates/bioaerosols

No

Sufficient separation distance.

Nearest residential receptors are 1.1km from the Premises.

There is no history of dust complaints from the Premises.

General provisions of the EP Act apply.

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Potential

Emissions Potential



Reasoning

Compost fire (particulates and noxious gases)

Public health effects from inhaled particulates

No




Mixing of solid feedstock and liquid waste

Mixing of liquid wastes, sludge and solid feedstocks on hardstands

Excess liquids drain to ponds




Peel-Yalgorup RAMSAR Wetland/Peel Inlet and Harvey Estuary EPP area

Overland flow



Increased phosphorus load on Peel Inlet and Harvey Estuary catchment leading to contamination of surface waters.


Impact the biological diversity of wetland flora and fauna including thrombolite and water bird species.

Yes See section 7.4



Yes See section 7.4



Contribute to eutrophication and algal blooms which can impact ecosystem function.

Yes See section 7.4

Nambeelup Brook No



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Potential

Emissions Potential



Reasoning




Yes See section 7.4



Yes See section 7.4

Odour

Residential receptors – nearest residence approx. 1.1km south west


Air (windborne) Impacts to amenity and wellbeing

Yes See section 7.5

Composting process

Composting windrows on Hardstands

Windrow turning

Application of liquid waste to windrows via sprinklers





Overland flow



Increased phosphorus load on Peel Inlet and Harvey Estuary catchment leading to contamination of surface waters.


Impact the biological diversity of wetland flora and fauna including thrombolite and water bird species.

Yes See section 7.4



Yes See section 7.4



Yes See section 7.4

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Potential

Emissions Potential



Reasoning

Nambeelup Brook


No




Yes See section 7.4





Yes See section 7.4

Odour



Air (windborne)


Yes See section 7.5



Nuisance impacts


No





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Potential

Emissions Potential



Reasoning



No




Final compost product

Product screening

Product storage

Leachate:




Overland flow






Yes See section 7.4



Yes See section 7.4




Yes See section 7.4

Nambeelup Brook No



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Potential

Emissions Potential



Reasoning




Yes See section 7.4



Yes See section 7.4

Odour

Residential receptors – nearest residence approx. 1.1km south-west


Air (windborne)


Yes See section 7.5



Nuisance impacts


No





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Potential

Emissions Potential



Reasoning



No




Compost removed from the Premises

Pathogens End users

Human contact with compost that may contain pathogens

Public health effects from inhaled or ingested pathogens

Yes See section 7.6

Contaminants within product

Premises where product is applied to land

Directly applied to land


Liquid waste and leachate storage and treatment

Liquid waste (and leachate) treatment and/or storage in ponds


Overtopping of ponds

Seepage through pond lining

Liner rupture


Overland flow






Yes See section 7.4



Yes See section 7.4



Yes See section 7.4

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Potential

Emissions Potential



Reasoning

Nambeelup Brook


No

Nambeelup Brook is located approximately 2.5km up gradient from the premises. Seepage is not considered likely to travel to this receptor.





Yes See section 7.4



Yes See section 7.4

Odour



Air (windborne) Impacts to amenity and wellbeing

Yes See section 7.5

Operation of vehicles and other machinery

Operation of vehicles, grinder, compost turner, front end loaders, screens

Noise



Air Amenity impacts causing nuisance

No



Noise Regulations apply

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7.2 Consequence and likelihood of risk events

A risk rating will be determined for risk events in accordance with the risk rating matrix set out in Table 12 below.

Table 12: Risk rating matrix

Likelihood Consequence

Slight Minor Moderate Major Severe

Almost Certain Medium High High Extreme Extreme

Likely Medium Medium High High Extreme

Possible Low Medium Medium High Extreme

Unlikely Low Medium Medium Medium High

Rare Low Low Medium Medium High

DWER will undertake an assessment of the consequence and likelihood of the Risk Event in accordance with Table 13 below.

Table 13: Risk criteria table

Likelihood Consequence

The following criteria has been used to determine the likelihood of the risk / opportunity occurring.

The following criteria has been used to determine the consequences of a risk occurring:

Environment Public Health* and Amenity (such as air and water quality, noise, and odour)

Almost Certain

The risk event is expected to occur in most circumstances

Severe on-site impacts: catastrophic

off-site impacts local scale: high level or above

off-site impacts wider scale: mid level or above

Mid to long term or permanent impact to an area of high conservation value or special significance^

Specific Consequence Criteria (for environment) are significantly exceeded

Loss of life

Adverse health effects: high level or ongoing medical treatment

Specific Consequence Criteria (for public health) are significantly exceeded

Local scale impacts: permanent loss of amenity

Likely The risk event will probably occur in most circumstances

Major on-site impacts: high level

off-site impacts local scale: mid level

off-site impacts wider scale: low level

Short term impact to an area of high conservation value or special significance^

Specific Consequence Criteria (for environment) are exceeded

Adverse health effects: mid level or frequent medical treatment

Specific Consequence Criteria (for public health) are exceeded

Local scale impacts: high level impact to amenity

Possible The risk event could occur at some time

Moderate on-site impacts: mid level

off-site impacts local scale: low level

off-site impacts wider scale: minimal

Specific Consequence Criteria (for environment) are at risk of not being met

Adverse health effects: low level or occasional medical treatment

Specific Consequence Criteria (for public health) are at risk of not being met

Local scale impacts: mid level impact to amenity

Unlikely The risk event will probably not occur in most circumstances

Minor on-site impacts: low level

off-site impacts local scale: minimal

off-site impacts wider scale: not detectable

Specific Consequence Criteria (for environment) likely to be met

Specific Consequence Criteria (for public health) are likely to be met

Local scale impacts: low level impact to amenity

Rare The risk event may only occur in exceptional circumstances

Slight on-site impact: minimal

Specific Consequence Criteria (for environment) met

Local scale: minimal to amenity

Specific Consequence Criteria (for public health) met

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^ Determination of areas of high conservation value or special significance should be informed by the Guidance Statement: Environmental Siting.

* In applying public health criteria, DWER may have regard to the Department of Health’s, Health Risk Assessment (Scoping) Guidelines

“on-site” means within the prescribed Premises boundary.

7.3 Acceptability and treatment of Risk Event

DWER will determine the acceptability and treatment of Risk Events in accordance with the Risk treatment Table 14 below.

Table 14: Risk Treatment

Rating of Risk Event

Acceptability Treatment

Extreme Unacceptable. Risk event will not be tolerated. DWER may refuse application.

High Acceptable subject to multiple regulatory controls.

Risk event will be tolerated and may be subject to multiple regulatory controls. This may include both outcome-based and management conditions.

Medium Acceptable, generally subject to regulatory controls.

Risk event is tolerable and is likely to be subject to some regulatory controls. A preference for outcome-based conditions where practical and appropriate will be applied.

Low Acceptable, generally not controlled.

Risk event is acceptable and will generally not be subject to regulatory controls.

7.4 Risk of liquid waste and leachate impacts

7.4.1 General hazard characterisation and impact

There are no point source emissions of wastewater to surface water or groundwater associated with the operation of the Premises. However, emissions of controlled waste and leachate high in nutrients and other contaminants may occur.

Emissions of liquid wastes and leachates (including contaminated storm water) from the Premises may contain nutrients, heavy metals, chemicals (e.g. pesticides), and hydrocarbons, or other contaminants from industrial liquid waste feedstocks. Limited information has been provided by the Licence Holder in regards to the content of the controlled wastes that are accepted at the Premises.

Emissions of leachate or liquid wastes directly to soils onsite may result in seepage or overland flow to groundwater or adjoining land. The soil at the Premises is fine to coarse sand which is considered likely to allow leachate seepage to move through the soil profile. The depth to groundwater is approximately two meters which increases the likelihood of leachate seepage reaching groundwater. This may result in the contamination of the soils and groundwater within and adjacent to the Nambeelup Farm premises, which may impact nearby users. DWER’s GIS mapping system indicates that groundwater in the area may have a Total Dissolved Solids concentration of 500 to 3000 mg/L, and is considered to be fresh to brackish. Therefore the groundwater is considered a receptor of beneficial use as it may be considered potable, suitable for irrigation or livestock. This is consistent with the presence of groundwater extraction bores in the area as identified in section 6.4.

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Rising groundwater, the result of mounding, has the potential to intercept the root zone of native vegetation. This may lead to an oversaturation of soils and/or accumulation of salts that can impact the growth of native vegetation.

If the flow of contaminated groundwater reached the nature reserve located approximately 700m south west of the Premises, this could result in impacts to the health and diversity of flora and fauna within the reserve.

The pathway for emissions to surface water may be via overland flow or within groundwater flow. Contaminated groundwater may be expressed within the Geomorphic Wetlands and the Serpentine River, which are both down gradient of the Premises. Emissions may contribute to the nutrient load within the Peel Inlet and Harvey Estuary, which is fed by the Serpentine River. Threatened ecological communities are also located within the vicinity of the conservation category wetlands and are likely to be impacted by any contamination of the groundwater and surface water in the area.

The expression of contaminated groundwater in surface water bodies may result in eutrophication and the excessive growth of algae. Algae growth may impact the survival of existing organisms through light and oxygen restriction and cause the degradation of the surface water value and beneficial use. Contamination in the groundwater and/or the wetlands may impact the biological diversity of threatened ecological communities.

7.4.2 Sources

Emissions of leachate and liquid wastes may occur from the following sources summarised in Table 15.

Table 15: Potential sources of liquid waste and leachate seepage and runoff

Source Potential event

Feedstock storage Seepage through Hardstand, or seepage directly to bare earth

Runoff from Hardstand or bare earth Mixing of solid feedstock and liquid wastes

Active composting and compost product storage

Ponds containing liquid wastes and collected leachate Seepage through liner (damage/high permeability/insufficient distance of pond base to groundwater)

Overtopping of ponds

The various potential sources of leachate and liquid waste emissions have been separately discussed and assessed (below).

Solid feedstock storage

The following solid feedstocks are accepted at the Premises:

Green waste (municipally source-separated and ground)

Untreated timber (sawdust and various other wood fractions)

Natural fibrous organics (straw, grain husks, other crop waste)

Mushroom compost (generally spent compost)

Dewatered screenings from piggery wastewater treatment plant (dry solids containing manure and pig hair)

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Piggery bedding

Animal manures (pig, chicken, cow, horse, and potentially others)

Animal mortalities (pig, chicken, kangaroo, and rabbit)

‘Off spec’ dairy products (considered a solid when in spadeable form) and other food waste

The solid feedstocks which pose the greatest risk for leachate generation, based on the nature of the wastes, are piggery bedding, pig and chicken manures, animal mortalities and food waste.

Composting of Certified compost

The mixing for the certified composting stream involves the mixing of piggery manure, piggery bedding, chicken manure and piggery pond wastewater and sludge.

To maintain the necessary moisture content, piggery pond water is added to the windrows via sprinklers in the early composting stages. In the later composting stages clean water is added to the windrows.

Composting of non-certified compost

The mixing for the non-certified composting stream involves the mixing of chicken manure, animal mortalities, food waste and a variety of liquid wastes accepted at the Premises. The controlled waste types received at the Premises are specified by their controlled waste number and limited information has been provided to DWER on the characteristics of the waste types.

To maintain the necessary moisture content, wastewater from Pond 32 (or occasionally other ponds) is added to the windrows via sprinklers in the early composting stages. In the later composting stages, clean water is added to the windrows.

Liquid waste and run-off storage in ponds

The ponds within the Premises collect leachate runoff from the limestone, asphalt, and concrete Hardstand areas. This run-off may contain a large variety of controlled waste types used within the non-certified composting, and some hydrocarbon materials are discharged directly to the ponds. Seepage or overflow from the ponds may therefore contain nutrients, heavy metals, hydrocarbons, pesticides, and a variety of other contaminants.

7.4.3 Criteria for assessment

The following guidelines are considered appropriate assessment criteria to assess the potential impact on the beneficial use of groundwater.

Australian and New Zealand Guidelines for Fresh and Marine Water Quality ANZECC & ARMCANZ (2000) for livestock drinking water quality.

The following guidelines are considered appropriate assessment criteria to assess the potential impact on groundwater dependent and freshwater ecosystems and surface water quality.

Australian and New Zealand Guidelines for Fresh and Marine Water Quality ANZECC & ARMCANZ (2000) for slightly–moderately disturbed ecosystems (95% protection level trigger values).

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7.4.4 Licence Holder controls

The liquid waste and leachate controls undertaken by the Licence Holder are identified in Table 16.

Table 16: Licence Holder controls for liquid waste and leachate seepage and runoff

Source Control(s) Operation details Reference to Issued Licence Premises Layout Map and Hardstand Materials Map (Attachment 1)


Compacted limestone Hardstand:

300mm of compacted limestone.

Graded with a 1.2% fall to prevent pooling.

Solid feedstocks stored on compacted limestone

with the exception of:

off spec dairy products and other food waste which are not stored prior to being directly mixed on asphalt/concrete

mortalities which are stored on asphalt/concrete

greenwaste which is stored on bare ground

Limestone

Asphalt Hardstands:

300mm of compacted limestone/gravel overlaid by 40 or 50mm of asphalt.


Mortalities stored on asphalt Hardstand.

Asphalt

Temporary bunding and drainage channels direct leachate and liquid waste runoff from limestone area to Pond 21 or Pond 31.

- N/A

Certified composting process and product storage

Asphalt Hardstands:

300mm of compacted limestone/gravel overlaid by 40 or 50mm of asphalt.


Concrete Hardstands:

200mm of 40 megapascal

Following processes undertaken on concrete or asphalt Hardstands:

Mixing of all liquid wastes and solid feedstocks

Active composting

Storage of final compost

Asphalt

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Source Control(s) Operation details Reference to Issued Licence Premises Layout Map and Hardstand Materials Map (Attachment 1)

Non-Certified composting process and product storage

(MPa) concrete.


Bunding and drainage channels:

Direct leachate and liquid waste runoff from asphalt and concrete Hardstands to Ponds 21, 22 or 31.

Note: the Licence Holder has proposed a change to the existing drainage by re-directing runoff from a small portion of the Western Hardstand (the pre-wetting area) to pond 2 within the CM Farms premises.

product


All ponds have 1.5mm HDPE geomembrane lining

- Ponds 21, 22, 23, 24, 25, 31 and 32

Minimum freeboards of 300mm are maintained in all ponds.

System is monitored via daily checks, weekly measurements and a water balance spreadsheet (calculating inputs and outputs) so that any capacity issues are known ahead of time. If pond levels need to be adjusted, this can be done by pumping between any two ponds.

Proposed construction of additional 1.5mm HDPE lined pond to increase storage capacity

Proposed to receive flow from Pond 32.

N/A

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7.4.5 Key findings

The Delegated Officer has reviewed the information regarding the groundwater impacts from the Premises and has found:

1. The storage and handling of compost and leachates has the potential to impact groundwater and surface water quality if not appropriately contained.

2. The soil type at the Premises is readily permeable and groundwater is likely to be located within two meters below ground level.

3. There are several potential receptors present. Groundwater is considered a pathway and receptor.

4. Groundwater monitoring at the Premises to date indicates a significant elevation of nitrogen and phosphorus above background levels.

5. Groundwater monitoring regime could be further improved to more accurately determine any impacts.

6. There are other sources of leachate on Nambeelup Farm at Mushroom Exchange and CM Farms.

7.4.6 Consequence

The guidelines for livestock drinking water quality indicate that concentrations of total dissolved solids between 2000-3000mg/L may result in a reluctance of poultry to drink, and levels above 3000mg/L may result in a decline in animal condition (poultry is the most sensitive of the livestock considered) (ANZECC & ARMCANZ 2000). The recent monitoring results (2016-2017 averaged data) showed that a number of bores exceeded 2000mg/L (CW01, CW02, CW05(A), CM08S and CM11S). The highest results were from bores CM11S and CW05(A), which are located on the western perimeter of the operational areas, and were above 3000mg/L.

The guidelines for slightly to moderately disturbed ecosystems provides a 95% protection trigger level value of 0.9mg/L for ammonia (ANZECC & ARMCANZ 2000). The recent monitoring results (2016-2017 averaged data) show that the majority of the bores within the Nambeelup Farm Premises exceed that trigger level to some degree. However, a number of bores (CM11S, CW05(A), CW02 and ME01) show levels of ammonia in excess of 30 times the trigger level. The results for bores CM11 and CW05(A) were 127 and 144 times higher than the trigger level respectively.

Bore CM10S is inferred to be downgradient of the operational areas and is the closest bore to the conservation category wetlands and the nature reserve. The results for this bore show an ammonia level of 6mg/L, however it is located approximately 400m from these receptors.

Solid feedstock storage and certified composting and product storage

Based on the key receptors (potential beneficial use of groundwater within and adjacent to the Nambeelup Farm premises, the nearby nature reserve and wetland, and the EPP area with its nutrient load management requirements), the Delegated Officer has determined that liquid waste and leachate from individual sources could cause low-level off-site impacts to the groundwater quality and the nearby nature reserve and wetland, nutrient inputs into the EPP area with a risk that specific consequence criteria are not being met. Therefore, the Delegated Officer considers the consequence of liquid waste and leachate emissions from these sources to be Moderate.

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Non-certified composting and product storage and liquid waste and run-off storage

Based on the limited information provided on the types of liquid wastes accepted on the Premises and the key receptors (potential beneficial use of groundwater within and adjacent to the Nambeelup Farm premises, the nearby nature reserve and wetland, and the EPP area with its nutrient load management requirements), the Delegated Officer has determined that liquid waste and leachate from individual sources could cause mid-level off-site impacts to the groundwater quality and the nearby nature reserve and wetland, and nutrient inputs into the EPP area with a risk that specific consequence criteria are not being met. Therefore, the Delegated Officer considers the consequence of liquid waste and leachate emissions from these sources to be Major.

7.4.7 Likelihood of consequence

Solid Feedstock Storage

Based upon the Licence Holder’s controls (particularly the storage of piggery bedding, animal manures, dewatered screenings and mushroom compost on compacted limestone) and the readily available pathway, the Delegated Officer has determined that moderate impacts could occur at some time. Therefore, the Delegated Officer considers the likelihood to be Possible.

Certified composting and product storage

Based upon the Licence Holders controls and the readily available pathway, the Delegated Officer has determined that moderate impacts could occur at some time. Therefore, the Delegated Officer considers the likelihood to be Possible.

Non-certified composting and product storage

Based upon the Licence Holders controls, the limited information on the controlled waste types used in the process and the large volumes of controlled waste used in the process, and the readily available pathway, the Delegated Officer has determined that major impacts could occur at some time. Therefore, the Delegated Officer considers the likelihood to be Possible.

Liquid waste and run-off storage

Based upon the Licence Holders controls, limited information on the controlled waste types used in the process, the large volumes of controlled waste used in the process, and the readily available pathway, the Delegated Officer has determined that major impacts could occur at some time. Therefore, the Delegated Officer considers the likelihood to be Possible.

7.4.8 Overall rating


The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of liquid waste and leachate impacts from solid feedstock storage is Medium.


The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of liquid waste and leachate impacts from certified composting and product storage is Medium.


The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of liquid waste and leachate impacts from non-certified composting and product storage is High.

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The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of liquid waste and leachate impacts from liquid waste and run-off storage is High.

Collective sources

Considering the multiple potential sources of leachate within the Premises and within the other Nambeelup Farm Premises, the Delegated Officer has determined that the multiple sources contribute to an increased overall consequence from the emissions, as they may result in a greater cumulative volume of leachate emitted and therefore increase the severity of the impact on receptors. The Delegated Officer has determined that leachate emissions from the Nambeelup Farm premises collectively could cause mid-level off-site impacts and could therefore have a Major consequence.

The Delegated Officer considers that the likelihood of a major impact resulting from the Nambeelup Farm premises collectively is Possible.

The Delegated Officer has determined that the overall rating for the collective sources is High.

7.5 Risk of odour Impacts


Individual responses to odour emissions may vary depending on age, health status, sensitivity, and odour exposure patterns. Perceived odour intensity may increase or decrease on exposure. Community response to an odour can include annoyance, potentially leading to stress, and loss of amenity. Exposure to repeated odour events can create a nuisance effect.

The sources of odour within the Premises are discussed in the sections below.

The location of the Premises adjacent to the Mushroom Exchange and CM Farms premises results in cumulative odour impacts from the Nambeelup premises. The cumulative effect is considered to increase the consequence and likelihood of odour emissions from the Premises.

Exposure times and frequency of odour emissions depend on day to day activities and weather conditions.

The Mandurah Odour Investigation identified that odour from the premises within the Nambeelup farm area could be recognised up to 8.5km from the premises, within the suburbs around Mandurah.

7.5.2 Sources


The Licence Holder stores a number of solid feedstock types at the Premises prior to use in the composting process. The most odorous of these feedstocks are animal mortalities (pig, chicken, cow, horse) and food wastes.


The composting process for the certified compost involves the handling and mixing of solid feedstocks (such as pig and chicken manure and piggery bedding) and piggery pond wastewater and sludge, which has the potential to release odours.

Non-certified composting process and product storage

The composting process for the non-certified compost involves the handling and mixing of solid feedstocks (such as animal mortalities and food waste), sludge from the ponds within the Premises and a range of controlled waste types. Controlled wastes added to feedstocks for

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composting can potentially disrupt the chemical processes within the compost windrows. Limited information has been provided on the characteristics of the controlled wastes accepted at the Premises and therefore the odour potential of these waste sources cannot be quantified.


Odour may be emitted from the liquid waste and run-off stored within the ponds at the Premises as these liquids are likely to be high in nutrients and organic matter. The controlled wastes, which are either directly discharged into Ponds 23 and 24 or are captured within run-off from the Hardstands, have potential to alter the chemical and biological processes within the ponds therefore causing odour emissions. Limited information has been provided on the characteristics of the controlled wastes accepted at the Premises.


There are no set threshold or concentration criteria for odour assessment. The general provisions of the EP Act make it an offence to cause or allow unreasonable emissions which includes emissions of odour that unreasonably interfere with the health, welfare, convenience, comfort or amenity of any person.


The odour controls undertaken by the Licence Holder are identified in Table 17.

In addition to the below controls, the Licence Holder maintains an onsite weather station and an incident register which records details of complaints received.

Table 17: Licence Holder controls for odour emissions

Source Control(s) Operation details

All solid feedstocks

Minimise storage times. Prevent long term static stockpiles.

Stock rotation (older stock used first, with the exception that wet loads of chicken manure or mushroom compost used prior to dry loads).

Pre-treatment of pig mortalities on CM Farms premises prior to acceptance

Treatment via immediate covering in a static composting tunnel. Left unturned for 6 months before use as solid composting feedstock on C-Wise Premises.

Mortalities (other than pig mortalities) covered and incorporated daily.

Mortalities covered with greenwaste (or similar material) immediately upon arrival at the Premises.

Mortalities are blended with material from the organics receival bund to form windrows on MAF within 24 hours of receival at the Premises.


Turning - windrows in first two weeks of certified composting (following feedstock wetting) are turned for aeration.

Turned every 2 to 3 days.

Wind speed and direction monitoring prior to turning

MAF - compost windrows positioned over MAF system for aeration.

Windrows on MAF are deconstructed and moved every 2 weeks for the purpose of mixing and aeration.

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MAF operates on a timer which controls periods

of aeration.

Large droplet sprinklers to deliver liquid waste to composting windrows

Source liquid waste from piggery ponds 5 or 6.

Compost windrow monitoring

Composting monitored to meet critical control points (mostly unspecified by the Licence Holder), including the requirement to meet a typical carbon to nitrogen ratio at the start of the composting process (ratio was provided and considered by DWER).

The temperature of each windrow is checked daily.

Oxygen levels are monitored approximately weekly in compost on MAF.

The moisture of the material is checked prior to windrow turning or shifting on MAF, and more moisture is added prior to movement if needed.

Moisture levels are maintained and were provided to and considered by DWER.

Non-Certified composting process and product storage

Direct incorporation of most incoming liquid waste feedstock with greenwaste in organics receival bund.

Captures solids - reducing solids entering Pond 21.

Most liquid wastes received are blended with greenwaste material as they are received throughout the day, with all of the deliveries being incorporated to form new composting windrows by the end of the day.

(The exceptions to this are wastes that are mixed with greenwaste in a separate bund due to incompatibility for direct mixing in the organics receival bund, and oily waste waters which are discharged directly to Ponds 23 and 24)

MAF - compost windrows positioned over MAF system for aeration.

Windrows on MAF are deconstructed and moved every two weeks for the purpose of mixing and aeration.

MAF operates on a timer which controls periods

of aeration.

Large droplet sprinklers to deliver liquid waste to composting windrows

Source liquid waste from Pond 32 (but occasionally from Ponds 21, 22 or 31).

Compost windrow monitoring

Composting monitored to meet critical control points (mostly unspecified by the Licence Holder), including the requirement to meet a typical carbon to nitrogen ratio at the start of the composting process (ratio was provided and

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considered by DWER).


Oxygen levels are monitored approximately weekly in compost on MAF.

The moisture of the material is checked prior to windrow turning or shifting on MAF, and more moisture is added prior to movement if needed.

Moisture level which is generally maintained was provided and considered by DWER.


Pond aeration system Available to operate in up to two ponds at one time.

Screens for runoff from North Eastern Hardstand

To prevent solid material entering the ponds within the Premises.

Sediment trap for runoff from the South Eastern and Western Hardstand (excluding the pre-wetting area on the Western Hardstand when this runoff is directed to CM Farms pond 2)

Chemical treatment of Ponds 22 and 21

Ponds 21 dosed weekly and Pond 22 dosed daily with chemical oxygenation.

Pond water quality monitoring and responsive actions

Following water quality parameters in Ponds 21, 22, 23 and 24 measured at least twice per week:

Temperature

Dissolved Oxygen (DO)

pH

Oxidation Reduction Potential (ORP)

Following water quality parameters in all ponds measured monthly:

parameters as listed above

Electrical Conductivity

Total Dissolved Salts

Chemical Oxygen Demand (COD)

Sodium

If results indicate an ORP of below -380, a shock treatment is implemented (using a combination of Sodium Percarbonate, Oceanic Bio Granular Shock and Oceanic Bio tablet).

If results indicate that DO in any pond is below 0.2ppm (considered anoxic), the pond water will be aerated (either mechanically through

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pumping/recirculation/aeration or chemically (through addition of Sodium Percarbonate).

If the pH is outside the critical range (7-8.5 for Ponds 21, 22, 31 and 32, 6-8 for Ponds 23 and 24, and 7-12 for Pond 25) corrective action is taken using either an acid or an alkali.

Isolation of oily wastewater

Oily wastewater received and stored in isolated ponds (Ponds 23 and 24) to manage hydrocarbons or other potential residues.

7.5.5 Key findings

The Delegated Officer has reviewed the information regarding the odour impacts from the Premises and has found:

1. The three Nambeelup Farm premises are likely to have a cumulative odour impact.

2. Odour emissions from the Nambeelup Farm area have had a demonstrated impact on receptor amenity.

3. The appropriate management of leachates and leachate ponds is imperative for managing odour emissions from the Premises.

7.5.6 Consequence

All sources

Based upon the sensitivity of residential receptors, the large residential population located within the distance which odour from the Premises has previously travelled (as determined in the Mandurah Odour Investigation), the Delegated Officer has determined that odour emissions from individual sources may cause mid-level impacts to amenity. Therefore, the Delegated Officer considers the consequence of odour emissions from the Premises to be Moderate.


Solid Feedstock storage

Based upon the Licence Holder’s control measures, DWER investigations, site visits and technical advice, and the highly odourous nature of some feedstocks the Delegated Officer has determined that the likelihood of moderate odour impacts from the storage of feedstocks could occur at some time. Therefore, the Delegated Officer considers the likelihood to be Possible.

Certified compost process and product storage

Based upon the Licence Holder’s control measures, DWER investigations, site visits and technical advice, the Delegated Officer has determined that the likelihood of moderate odour impacts from the certified compost process and product storage could occur at some time. Therefore, the Delegated Officer considers the likelihood of odour impacts from the certified compost process and product storage to be Possible.

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Non-certified compost process and product storage

Based upon the Licence Holder’s control measures, DWER investigations, site visits and technical advice, and the limited information provided on the characteristics of all controlled waste types used within the process, the Delegated Officer has determined that moderate impacts are likely to occur in most circumstances. Therefore, the Delegated Officer considers the likelihood of odour impacts from the non-certified compost process and product storage to be Likely.

Liquid waste storage

Based upon the Licence Holder’s control measures, DWER investigations, site visits and technical advice, the Delegated Officer has determined that the likelihood of moderate odour impacts will probably occur in most circumstances. Therefore, the Delegated Officer considers the likelihood to be Likely.



The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of odour impacts from solid feedstock storage is Medium.


The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of odour impacts from certified composting and product storage is Medium.


The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of odour impacts from non-certified composting and product storage is High.


The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of odour impacts from liquid waste and run-off storage is High.

Collective sources

Considering the multiple potential sources of odour within the Premises and within the other Nambeelup Farm Premises, the Delegated Officer has determined that the multiple sources contribute to an increased overall consequence from the emissions, as they may result in greater cumulative odour emissions and therefore increase the severity of the impact on amenity. The Delegated Officer has determined that odour emissions from the Nambeelup Farm premises collectively could cause high level impacts to amenity and could therefore have a Major consequence.

The Delegated Officer considers that the likelihood of a major impact resulting from the Nambeelup Farm premises collectively is Likely.

The Delegated Officer has determined that the overall rating for the collective sources is High.

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7.6 Risk of pathogen impacts (compost product)


The final compost produced has the potential to contain pathogens that may affect the health of the product users when inhaled or ingested.

7.6.2 Sources

Pathogen levels in compost product are the result of insufficient pasteurisation or the re-contamination of the compost after pasteurisation.


Australian Standard AS 4454 contains pathogen limits for compost products. The Western Australian guidelines for biosolids management (DEC 2012) provides additional pathogen limits for the unrestricted use of biosolids, which are considered comparable for compost products.

The Licence Holder has advised that the compost products meet the pathogen recommendations set out in AS 4454.


The pathogen controls undertaken by the Licence Holder are identified in Table 18.

Table 18: Licence Holder controls for pathogens within the compost product



Turning/mixing of windrows during composting to ensure sufficient pasteurisation

Windrows not on MAF turned every 2 to 3 days.

Windrows on MAF are deconstructed and moved every 2 weeks.

Temperature monitoring during composting


Adhere to the pasteurisation requirements of AS 4454.

Testing for pathogen content of final product

An analysis against all parameters in the Australian standard AS 4454 is undertaken at least quarterly for each process line.

7.6.5 Consequence

Based upon the potential health effects associated with exposure to pathogens, the Delegated Officer has determined that pathogens within the compost product could cause high level adverse health effects. Therefore, the Delegated Officer considers the consequence to be Severe.


Based upon the Licence Holder controls, the Delegated Officer has determined that pathogens being present within the compost product and causing high level health effects for product users may only occur in exceptional circumstances. Therefore, the Delegated Officer considers the likelihood to be Rare.

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The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 12) and determined that the overall rating for the risk of pathogens impacting the health of product users is High.

7.7 Risk of contaminant impacts (compost product)


Composting materials have the potential to contain contaminants which may contaminate the premises of product users.

High contaminant levels in compost could be a result of the incorporation of inappropriate waste types, the inappropriate ratio of feedstocks or insufficient processing of waste.

The risk of contaminant impacts from compost products has been separately considered below for the products produced within the certified composting stream, and the products produced within the non-certified composting stream.

The municipally sourced greenwaste and the non-typical liquid waste feedstocks, which are used within the non-certified composting stream, are associated with a higher level of uncertainty regarding product quality due to the range of potential contaminants within these feedstocks.


Australian Standard AS 4454 contains contaminant limits for compost products.

The Licence Holder has advised that the compost products meet most of the chemical and physical recommendations set out in AS 4454 (with exception of some spikes in metals).


The contaminant controls undertaken by the Licence Holder are identified in Table 19.

It is noted that DWER does not have information regarding the results of previous compost quality testing undertaken by the Licence Holder.

Table 19: Licence Holder controls for contaminants within the compost product



Inspection of new liquid controlled waste streams prior to acceptance

Inspection and sampling undertaken however limited information on the details of these processes has been provided.

Testing of recurring liquid controlled waste deliveries

Quality testing of final product

An analysis against all parameters in the Australian standard AS 4454 is undertaken at least quarterly for each process line.

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7.7.4 Key findings

The Delegated Officer has reviewed the information regarding the contaminant impacts from the use of compost product produced on the Premises and has found:

1. The uncertainty regarding the potential contaminants within many of the liquid waste feedstocks and their level of treatment within the composting process presents a risk of unknown contaminants being present within the product.

7.7.5 Consequence

Certified compost products

Based upon the inputs to the certified composting process, and the likely scale of use of the product, the Delegated Officer has determined that contaminants within the compost product could cause minimal off site impacts at a local scale. Therefore, the Delegated Officer considers the consequence to be Minor.

Non-certified compost products

Based upon the inputs to the certified composting process (which potentially include contaminants of greater consequence), and the degree to which some contaminants remain within the product, and the likely scale of use of the compost product, the Delegated Officer has determined that contaminants within the compost product could cause low level off-site impacts at a local scale. Therefore, the Delegated Officer considers the consequence to be Moderate.



Based upon the relatively higher level of consistency in the inputs to the certified composting process, the Delegated Officer has determined that contaminants from these products causing minimal off site impacts at a local scale will probably not occur in most circumstance. Therefore, the Delegated Officer considers the likelihood to be Unlikely.


Based upon the relatively lower level of consistency in the inputs to the non-certified composting process, the Delegated Officer has determined that contaminants from these products causing low level off site impacts at a local scale may occur at some time. Therefore, the Delegated Officer considers the likelihood to be Possible.



The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 13) and determined that the overall rating for the risk of contaminants within the certified compost products causing minimal off site impacts is Medium.


The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 13) and determined that the overall rating for the risk of contaminants within the non-certified compost products causing low level off site impacts is Medium.

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7.8 Summary of risk assessment and acceptability

A summary of the risk assessment and the acceptability of the risks with treatments are set out in Table 20 below. Controls are described further in Section 8.

Table 20: Risk assessment summary

Emission Pathway and Receptor

Licence Holder controls Impact Risk Rating

Acceptability with treatment (conditions on instrument)

Type Source

1A

Risk of liquid waste and leachate impacts


Seepage through soil to groundwater on-site.

Overland flow and migration through groundwater to adjoining lands, nature reserve, EPP area, geomorphic wetlands, Serpentine River.

Storage on compacted limestone

Mortalities stored on Hardstand

Contamination of groundwater supply for nearby users.

Impact to flora and fauna at nearby nature reserve

Contamination of surface waters and impacts to ecosystem function.

Moderate

Possible

Medium

Acceptable, generally subject to regulatory controls

1B Certified composting and product storage

All processing occurs on Hardstand which drains to leachate system

Licence Holder has proposed drainage from Western Hardstand to CM Farms pond.

Moderate

Possible

Medium


1C Non-certified composting and product storage

Major

Possible

High

Acceptable subject to multiple regulatory controls

1D Liquid Waste storage

HDPE lined, minimum freeboard of 300 mm

Major

Possible

High


2A

Risk of odour Impacts


Pathway:

Air (windborne)

Receptor:

Stock rotation

Immediate covering of mortalities


Moderate

Possible

Medium


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Emission Pathway and Receptor

Licence Holder controls Impact Risk Rating

Acceptability with treatment (conditions on instrument)

Type Source

2B Certified composting and product storage

Receptors at air field and residences Windrow turning or

forced aeration of windrows

Moderate

Possible

Medium


2C Non-certified composting and product storage

Direct mixing of liquid wastes upon receival

Forced aeration of windrows

Major

Likely

High


2D Liquid Waste storage

Pond aeration

Chemical treatment

Major

Likely

High


3A Risk of pathogen impacts from use of compost product off-site

All compost product

Human contact with compost product

Pasteurisation and quarterly testing of product

Public health effects from inhaled or ingested pathogens

Severe

Rare

High


4A

Risk of contaminant impacts from use of compost product off-site

Certified compost product

Premises where product is applied to land Some testing of incoming

feedstocks

Quarterly testing of product

Contamination of soil

Minor

Unlikely

Medium


4B Non-certified compost product

Premises where product is applied to land

Minor

Unlikely

Medium


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8. Determined regulatory controls

8.1 Summary of controls

A summary of the risks with corresponding controls are set out in Table 21. The risks are set out in the assessment in Section 7 and the controls are detailed in this Section 8. Controls will form the basis of conditions in the Licence set out in Attachment 1.

Table 21: Summary of regulatory controls to be applied

Controls

8.2

Pro

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cti

on

Lim

it

8.3

Was

te a

cc

ep

tan

ce

co

ntr

ols

8.4

In

fras

tru

ctu

re a

nd

eq

uip

me

nt

8.5

Op

era

tio

na

l c

on

tro

ls

8.6

Gro

un

dw

ate

r

mo

nit

ori

ng

8.7

Po

nd

wa

ter

qu

ali

ty

mo

nit

ori

ng

an

d a

cti

on

s

8.8

Sp

ec

ifie

d a

cti

on

s

Ris

k Ite

ms

(see r

isk a

naly

sis

in

se

cti

on

7)

1A. Leachates from solid feedstock storage

• • • • •

1B.Leachate from certified composting and product storage

• • • • •

1C. Leachate from non-certified composting and product storage

• • • • •

1D. Leachate from liquid waste and run-off storage in ponds

• • • • • • •

2A. Odour from solid feedstock storage • • •

2B. Odour from certified composting and product storage

• •

2C. Odour from non-certified composting and product storage

• • •

2D. Odour from liquid waste and run-off storage in ponds

• • • • •

3A. Pathogens from compost product •

4A. Contaminants from certified compost •

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8.2 Production limit

The Licence Holder will be limited to producing a maximum of 90,000 tonnes of compost product per Annual Period.

While this Review has primarily been based on the current operations of the Premises, in which the compost production is approximately 60,000 to 70,000 tonnes per annual period, the Category 67A premises production or design capacity within the Existing Licence has been specified as the compost production limit within the Revised Licence.

Grounds: The Delegated Officer considers that an increase in the quantity of compost being produced to 90,000 tonnes per annum should not require any further regulatory controls provided that the operation of the composting process is not changed. It is considered necessary to include a production limit to restrict more significant increases in production without undergoing assessment.

8.3 Waste acceptance controls

8.3.1 Waste types

The Licence Holder will be limited to accepting the solid and liquid wastes which are currently being accepted at the Premises under the Existing Licence, with the exception that the liquid controlled waste type N140 fire debris or fire wash waters may not be accepted.

The annual volume of liquid wastes excluding wastewater and sludge from CM Farms has been limited to Category 61 premises production or design capacity within the Existing Licence.

The annual volume of wastewater and sludge from CM Farms has been limited to the maximum volume that would be required to meet the compost production capacity, as estimated by the Licence Holder.

This restriction does not preclude the acceptance of non-waste feedstocks.

Grounds: The waste types which may be accepted at the Premises are limited to those which have been assessed.

The Delegated Officer has determined that the controlled liquid waste N140 fire debris or fire wash waters may no longer be accepted at the Premises due to its potential to contain polyfluoroalkyl substances (PFAS) from firefighting foams, and the risk that these substances may seep from storage ponds and contaminate compost product. Some of these substances can resist degradation by acids, bases, oxidants, microbes and metabolic processes. PFAS are considered to cause significant impacts to the environment and public health due to their properties and have the potential to bioaccumulate and biomagnify (DER 2017).

Further information regarding the annual volume of wastewater and sludge from CM Farms is included within section 9.

product use off-site

Contaminants from non-certified compost product use off-site

•

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8.4 Infrastructure and equipment

8.4.1 Liquid waste and leachate impact controls

The following infrastructure and equipment must be maintained and operated onsite for liquid waste and leachate management:

hardstands (limestone, asphalt and concrete);

bunding and drainage channels;

ponds; and

groundwater monitoring bores.

A requirement that the asphalt and concrete Hardstands, bunding and drainage channels meet a hydraulic conductivity of less than 1.0 x 10-9 m/s will be included.

The Hardstands will be required to be capable of accommodating the weight and movement of vehicles and equipment used on the Hardstands, without compromising the integrity of the Hardstands or altering the drainage.

The hardstands and drainage channels must have a drainage gradient to ensure the free drainage of all runoff from the Hardstands into the drainage channels.

The Licence Holder will be allowed to direct the runoff from the pre-wetting area on the Western Hardstand to be directed to Pond 2 within the CM Farms premises (as proposed by the Licence Holder). As requested by the Licence Holder, the condition has been drafted to still give the Licence Holder the option to direct the runoff from the pre-wetting area into Pond 21 within the Premises.

Note: These controls generally replicate the Licence Holder’s controls and were considered by the Delegated Officer in determining liquid waste and leachate emission impact risk.

The Licence Holder’s proposal to construct an additional pond (Pond 33) has not been accepted.

Grounds: The maintenance of the existing infrastructure is necessary for the mitigation of liquid waste and leachate impacts to groundwater. The specification of a Hydraulic Conductivity of less than 1.0 x 10-9 m/s for the asphalt and concrete Hardstands, bunding and drainage channels will ensure that seepage of leachate and consequently groundwater contamination from these locations is adequately controlled. Note that a requirement for the Licence Holder to undertake testing to determine the rate of seepage through the pond liners is included as a specified action within Section 8.8.1.

Appropriate grading of the Hardstands and drainage channels prevents pooling, thus reducing the risk of seepage and controlling odour.

The Licence Holder’s proposal to have the option to direct all runoff from the pre-wetting area of the Western Hardstand to Pond 2 within the CM Farms premises is considered acceptable as the CM Farms ponds are lined and maintained with a 300mm freeboard. The CM Farms pond is estimated to have sufficient storage capacity to accommodate this discharge and an agreement for this arrangement which was signed by licence holders has been provided to DWER.

The construction of Pond 33 is not currently considered acceptable, due to the uncertainty regarding the separation distance between the base of the existing ponds and the groundwater level throughout the year, and the potential that the existing ponds may be a source of groundwater contamination. The Licence Holder must manage the inputs to the existing ponds to maintain a freeboard as specified within Section 8.5.1, noting that years with a lower rainfall than that used within the water balance calculations in Appendix 4 would allow

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more capacity for the storage of liquid waste inputs.

8.4.2 Odour control

The following infrastructure and equipment must be maintained and operated onsite for odour management:

MAF system for the aeration of composting windrows;

aeration system for Pond 21 and Pond 22 that achieves aeration of the entire pond surface and operated continuously; and

sediment traps and/or screens for runoff from all hardstands.

The existing screens and traps are to be maintained to capture solid materials preventing it from entering Ponds 21 and 22. A new screen and sediment trap is required to be installed for the runoff from the pre-wetting area, to capture solid materials preventing it from entering pond 2 within CM Farms.

Written notification must be provided to the CEO confirming the installation of the solids capture infrastructure for the discharge to CM Farms Pond 2 prior to this discharge occurring.

Note: These controls generally replicate the Licence Holder’s controls and were considered by the Delegated Officer in determining odour emission impact risk.

Grounds: A key finding of the assessment is that Pond 21 and Pond 22 are a major potential source of odour at the Premises.

The Delegated Officer considers that aeration of Pond 21 and 22 is necessary to maintain pond water quality, and therefore reduce the odour risk associated with the pond water. It has been determined through consultation with the Licence Holder due to the complexities surrounding the generation of odour, the use of water quality parameters to control and manage odour has limitations. As an alternative, the pond aeration will be required to achieve aeration across the entire pond surface, to maintain an aerobic layer at the pond surface. Continuous oxygenation of the ponds through aeration, acts to ensure aerobic conditions are maintained within the pond surface and can decompose odourous compounds (generated within deeper water or sludges) before they emit to the atmosphere. This requirement applies only to Ponds 21 and 22 because these are the first two ponds in the train of ponds.

The Delegated Officer considers that it is necessary that all runoff from the hardstands is directed to ponds via infrastructure for solids capture, to prevent solid material entering the ponds (including Pond 2 within CM Farms). This is expected to assist in maintaining an aerobic state in the ponds resulting in reduced odour emissions from this source.

A maximum screen opening size of 50mm by 50mm will be specified within the Licence, which allows for a screen with an opening size which has been proposed by the Licensee. The specification of the maximum screen opening size provides enforceable wording for the performance and compliance of this solids capture infrastructure.

A sediment trap is required to be installed in addition to a screen to capture solids from the runoff being directed to CM Farms Pond 2. The sediment trap is in addition to the Licence Holders proposed screen for this runoff, however this is considered necessary as Pond 2 is not the primary treatment pond within the CM Farms wastewater treatment system. Solids are removed from the CM Farms wastewater prior to wastewater flow to Pond 2.

8.4.3 Other infrastructure and equipment

The Licence Holder will be required to install equipment to monitor the volume of piggery wastewater and sludge accepted from CM Farms.

The volumes of all waste and non-waste feedstocks accepted at the Premises are required to

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be monitored under the record-keeping section of the Revised Licence, and reported to DWER annually.

The Licence Holder will be required to install equipment to monitor the volume of runoff from the pre-wetting area on Western Hardstand which is discharged into Pond 2 within the CM Farms premises via the drain to be installed by CM Farms.

Note: The volume of wastewater and sludge accepted from CM Farms has not previously been monitored.

8.5 Operational controls

8.5.1 Liquid waste and leachate impact controls

The following operational controls must be undertaken for the management of liquid waste and leachate:

Storage of the following solid feedstocks on limestone, concrete or asphalt Hardstand from May to September (the wettest period of the year):

o Untreated timber (sawdust and various other wood fractions) o Natural fibrous organics (straw, grain husks, and other crop waste)

Storage of the following solid feedstocks on concrete or asphalt Hardstand throughout the year:

o Dewatered screenings from CM Farms piggery wastewater treatment plant (dry solids containing manure and pig hair)

o Mushroom compost (generally spent compost) o Animal manure o Piggery bedding o Animal mortalities (pig, chicken, kangaroo, and rabbit) o ‘Off spec’ dairy products (considered a solid when in spadeable

form), and other food waste

The mixing of feedstocks and composting to be done on a concrete or asphalt Hardstand.

The only liquid waste applied to solid feedstocks within the pre-wetting area of the Western Hardstand is piggery wastewater or sludge sourced from CM Farms.

Maintenance of a minimum of 300mm freeboard within the ponds at all times.

Note: These controls generally replicate the Licence Holder’s controls and were considered by the Delegated Officer in determining liquid waste and leachate emission impact risk. The requirement to store dewatered screenings, mushroom compost, animal manure and piggery bedding on concrete or asphalt Hardstands is in addition to the existing Licence Holder controls. The allowance for the storage of untreated timber and natural fibrous organics to be stored on bare earth during October to April is in response to Licence Holder comments during consultation.

Grounds: The Delegated Officer has determined that based on the outcomes of the risk assessment detailed in this report, additional regulatory controls through licence conditions are required to mitigate the high liquid waste and leachate impact risk.

As discussed in Section 0, all Hardstands are required to meet certain specifications for the mitigation of liquid waste and leachate impacts to groundwater. The Delegated Officer considers that the requirement to store dewatered screenings, mushroom compost, animal manure and piggery bedding in addition to animal mortalities and food waste on an asphalt or

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concrete Hardstand rather than a limestone Hardstand is required to reduce the likelihood of seepage to groundwater from these feedstocks.

The Delegated Officer has determined that untreated timber and natural fibrous organics pose little risk in regards to leachate generation during the drier period of the year, and has therefore decided that these wastes will not be required to be stored on a hardstand during that period (October to April).

Piggery wastewater and sludge shall be the only liquid wastes applied within the pre-wetting area as the runoff from this area will be directed back into Pond 2 within the CM Farms premises. This requirement ensures that other liquid wastes do not run-off into the CM Farms Pond 2.

The Delegated Officer considers that existing freeboard of 300mm within the ponds is sufficient to mitigate potential overflow.

8.5.2 Odour impact controls

The following operational controls must be undertaken for the management of odour:

Cover mortalities immediately upon acceptance at the Premises to achieve odour reduction, and incorporated into a windrow on the day of acceptance at the Premises.

Each load of liquid waste is directly mixed with solid feedstocks on the day of acceptance of the load at the Premises, except where loads of liquid waste are discharged directly into Ponds 22, 23, 24 or 25 upon receipt at the Premises.

Sludge sourced from any pond within the Premises is mixed with solid feedstocks, or the sludge is removed from the Premises, on the day the sludge is removed from the pond.

All mixed solid and liquid feedstocks (excluding initial wetting of feedstocks with liquid from ponds within the Premises or wastewater from CM Farms) are used to create a new composting windrow on the day of mixing.

Liquid sourced from CM Farms or from ponds within the Premises for application to feedstocks or windrows must be sourced from Ponds 31 or 32 or CM Farms Ponds 5 or 6.

Use of large droplet sprinklers where sprinklers are used for the application of piggery wastewater from CM Farms or liquid from Ponds 31 or 32 to solid feedstocks or compost windrows.

Feedstocks that have been or are being wetted with liquid from Ponds within the Premises and piggery wastewater, and all compost windrows, are to be turned a minimum of every three days or placed on an aeration system to promote an aerobic state within the feedstocks.

Note: These controls generally replicate the Licence Holder’s controls and were considered by the Delegated Officer in determining odour emission impact risk. The requirements to turn the feedstocks being wetted with liquid from ponds within the Premises or piggery water is in addition to the existing Licence Holder controls.

Grounds: The Delegated Officer has determined that based on the outcomes of the risk assessment detailed in this report, additional regulatory controls through licence conditions are required to mitigate the high odour impact risk.

The requirements to mix liquid feedstocks and sludge with solid feedstocks on the day of acceptance of the liquid feedstock or removal of sludge from the pond, and the formation of a new composting windrow on the day of mixing, are required to prevent the liquid wastes or

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mixed feedstocks from sitting static for a longer period and potentially becoming anaerobic. This is considered to be effective in minimising odour emissions. Feedstocks being wetted with liquid from ponds within the Premises or wastewater from CM Farms are excluded from the requirement to form a compost windrow on the day of mixing, in accordance with the current process undertaken on the Premises. However those feedstocks being wetted will be required to be turned or placed on an aeration system to promote an aerobic state within the feedstock, as discussed below.

The Delegated Officer has determined that the re-use of pond water from CM Farms or ponds within the Premises should be restricted to the final ponds within the two pond systems, as these ponds will have the highest quality water, with the least odour potential when applied to feedstocks or windrows.

The Delegated Officer has determined that the use of large droplet sprinklers, as opposed to sprinklers with a finer spray, will reduce the dispersion of odour during the application of CM Farms wastewater or liquid from Ponds 31 and 32.

The Delegated Officer considers that appropriate maintenance of the composting process is necessary to adequately control the risk from odour from the Premises. The requirement to maintain the wetted feedstocks and compost windrows to promote an aerobic state by turning the wetted feedstocks and windrows at least every three days or placement on an aeration system is considered to be effective in minimising odour emissions from these sources.

8.6 Groundwater monitoring and reporting

8.6.1 Groundwater monitoring requirements

The Licence Holder is required to carry out ongoing quarterly groundwater monitoring at all bores on the Premises for the following parameters:

Standing water level

pH

Total dissolved solids (TDS)

Mercury

Zinc

Arsenic

Nitrate-nitrogen

Nitrite-nitrogen

Ammonium-nitrogen

Total nitrogen

Total phosphorus

Groundwater assessment levels of 13.4 mg/l for total nitrogen or 2.6 mg/l for total phosphorus will be specified.

The Licence Holder will be required to undertake all groundwater monitoring following the methods specified in AS 5667.1 and AS 5667.11 and have the results tested by a NATA accredited laboratory for the analytes specified.

Note: The ongoing monitoring is based on the existing monitoring requirements but has been expanded to include mercury, zinc and arsenic as new analytes. Monitoring frequency has been increased to quarterly intervals. .

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CM Farms will be required to install an additional groundwater monitoring bore on the southern boundary of the CM Farms premises to provide further data closer to the sensitive receptors south of the Premises. The monitoring data from all three Nambeelup Farm premises will in future be interpreted collectively; therefore this requirement on the CM Farms Licence is also relevant to addressing the leachate risk from this Premises. Further investigation or regulatory control may be required in future depending on the groundwater quality results obtained from the additional bore.

Grounds: Due to high levels of groundwater contamination documented from the groundwater bores at the Premises (Appendix 5), quarterly monitoring is required to allow for a more thorough interpretation of monitoring results. DWER will be able to use the monitoring results to assess whether appropriate progress has been made or whether additional controls need to be implemented. The parameters required to be sampled on an ongoing basis have been expanded to include mercury, zinc and arsenic and are consistent with monitoring carried out at the other Nambeelup Farm premises and relevant to the materials received, used, and stored at the three premises.

Mercury, zinc and arsenic have been included in the quarterly monitoring suite of analytes to ensure that the potential risk to human health and the environment from this type of contamination can be assessed on an ongoing basis.

The selected suite of analytes with the addition of selected metals is considered appropriate for the characterisation and detection of groundwater contamination caused by nutrient rich leachates derived from organic materials.

The requirement to have the samples taken using a specified method and analysed in a specified laboratory is considered appropriate in ensuring the quality of the data submitted.

8.6.2 Groundwater monitoring reporting

The Licence Holder will be required to provide a quarterly report of groundwater monitoring results (excluding the last quarter of the year which will be captured within the annual report), which includes a summary of the results above the background levels (as determined in Appendix 5) for the previous quarter and the raw monitoring data in Excel format.

The Licence Holder will also be required to report all groundwater monitoring results on an annual basis. This report will be required to contain raw data in Excel format, a comparison of data against groundwater background levels (as determined in Appendix 5) and ANZECC stock water guidelines, and details of sampling quality assurance and quality control.

Grounds: The Delegated Officer considers that this reporting is appropriate to monitor groundwater impacts at the Premises, and the specification of the reporting requirements is sufficient to enable DWER to analyse the data. The data will be used to determine the adequacy of infrastructure controls and assess for groundwater impacts resulting from infrastructure defects, failure, or malfunction (e.g. pond seepage as a result of liner failure). DWER may review the appropriateness and adequacy of the Licence controls based on the review of the monitoring data.

The quarterly reporting frequency provides a mechanism for DWER to be informed of issues and respond to an exceedance of background levels within a shorter timeframe than if the exceedance was only reported annually.

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8.7 Pond monitoring and actions

8.7.1 Pond monitoring requirements

The Licence Holder is required to undertake ongoing monitoring of pond water at the Premises for the following parameters:

Oxidation Reduction Potential (ORP)

Dissolved oxygen (DO)

pH

Temperature

Biochemical oxygen demand (BOD5)

Volume of sludge

The Licence Holder will be required to desludge a pond when sludge is at more than 30% capacity. Capacity is calculated as pond water volume, not including freeboard.

The Licence Holder will be required to undertake a once-off monitoring event for the following parameters:

Total nitrogen

Total phosphorus

Note: Following the issue of the Revised Licence, a program of inspections for the Nambeelup Farms premises will be undertaken to assess compliance with the Revised Licence and the effectiveness of the licence conditions. The management of the ponds will be a particular focus, including observations to determine the frequency of occurrence of bubbles (suspected biogas) being released from any ponds. Further investigation will be required if this is observed to be ongoing.

Grounds: Pond water quality sampling was requested by the Department in June 2016 for all ponds at Nambeelup Farm for the purpose of evaluating the potential for the production of odorous compounds. Pond water quality analysis results are further discussed in Appendix 8 highlighting the need to improve the water quality for odour reduction.

Ongoing monitoring is therefore considered necessary to assess whether the ponds are working effectively and to evaluate the potential for the production of odorous compounds. A monitoring regime of all operational ponds at the Premises has been specified in the Licence, with the parameters based on those analysed in June 2016 at all the Nambeelup Farm premises.

A once-off nutrient monitoring event is required to provide information that can be used with pond integrity testing results to determine the quantities of contaminants being emitted from the Premises.

Desludging of the ponds will ensure that the operational capacity of the ponds is maintained. The buildup of sludge in the aerobic ponds can also promote anaerobic conditions that increase the risk of odourous compounds being generated.

The Delegated Officer has determined that once-off monitoring for total nitrogen and total phosphorus is required to provide the concentrations necessary for an estimation of the emission rate of nitrogen and phosphorus through the pond liners (the requirement for the Licence Holder to provide this estimation is addressed within Section 8.8.1).

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8.7.2 Pond monitoring reporting

The Licence Holder will be required to provide within an annual report the raw pond monitoring data, time series graphical plots and details of the sampling quality assurance and quality control.

Details of any sludge removal from the ponds will be required within the annual report.

Grounds: The Delegated Officer considers that the water quality monitoring is required to ensure that ponds are adequately managed so that odour generation is minimised. DWER may use the reported monitoring results to assess whether ponds have been appropriately managed or whether additional controls are required. DWER may also request pond monitoring data outside the annual reporting timeframe as part of compliance inspections or complaint investigations.

8.8 Specified actions

8.8.1 Pond liner integrity testing and seepage rate testing

The Licence Holder will be required to carry out liner integrity or seepage rate testing on all ponds within the Premises. This testing should be carried out by 15 August 2019.

The results of the liner integrity or seepage rate testing shall be reported to the Department within one month of the completion of the testing for each pond. An estimation of the total volume of seepage (from that pond per year) and total mass of nitrogen and phosphorus emitted via seepage (from that pond per year) will also be required to be reported at this time. The designed hydraulic conductivity of the liner (in an undamaged or repaired state), hydraulic head pressure, seepage rate testing result (where available) and pond monitoring results for total nitrogen and total phosphorus shall inform these estimations.

If the results of either testing method indicate that the pond liner is damaged, an upgrade plan must also be provided at this time.

An estimation of the separation distance between the base of the ponds and the groundwater level at the time of the seepage test shall also be provided. If the groundwater level is above the base of the pond at the time of the test, this is likely to influence the results.

Grounds: Nambeelup Farm is classified as contaminated under the CS Act. Groundwater monitoring carried out across Nambeelup Farm suggests that sources of contamination are present. The monitoring is not able to confirm the exact location of sources within the Nambeelup Farm premises; however the leachate ponds are potential sources.

Given the potential for the ponds to be sources of contamination, a requirement for the Licence Holder to test liner integrity or seepage rate has been included in the Licence. The option to undertake a seepage rate test has been provided because it’s unlikely to be feasible for the Licence Holder to undertake liner integrity testing on all ponds within a 12 month period, given the size of the ponds within the Premises.

The Delegated Officer considers that an overnight or four to seven day water balance test (Ham and Baum 2009 and Parker et al. 2009) for seepage rate and ASTM methods (D6747, D7007, D7703, D7002 or D7703) for liner integrity testing are appropriate testing methods.

The Delegated Officer has determined that it’s necessary to estimate the seepage rate and the rate of nitrogen and phosphorus emissions from the ponds to allow further consideration of the potential risk to receptors and to verify that the mass of phosphorus emissions are not inconsistent with the environmental quality objectives of the Peel Inlet-Harvey Estuary EPP. DWER will consider the estimations submitted. If the seepage rates from the ponds are considered to be too high, additional regulatory controls may be needed.

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8.8.2 Depth to groundwater investigation

The Licence Holder is required to conduct an investigation into the depth to groundwater from the base of the ponds to the maximum groundwater level.

Grounds: The risk to groundwater increases with reduced separation distance. If the separation distance is not sufficient, seepage from ponds may be a significant source of groundwater contamination.

The groundwater report will be used to determine the appropriateness of the pond systems and verify the specified control measures are in place. DWER may review the appropriateness and adequacy of the Licence controls based on the details of the report. Additional controls may be required to mitigate the risk from any ponds that do not have a sufficient separation distance.

8.8.3 Pond and groundwater PFAS testing

The Licence Holder will be required to do once-off groundwater and pond testing for Perfluorooctane sulfonate (PFOS), Perfluorohexane sulfonate (PFHxS) and Perfluorooctanoic acid (PFOA). The Licence Holder will be required to report the figures and compare against the Interim screening level for non-potable and recreational uses.

The sampling for PFAS analysis must be undertaken by a Certified Practitioner (a person holding a ‘Site Contamination’ specialist certification under the Certified Environmental Practitioners Scheme).

Grounds: The Licence Holder has previously accepted fire wash waters and other un-characterised controlled wastes which may possibly contain polyfluoroalkyl substances (PFAS). PFAS are considered to cause significant impacts to the environment and public health due to their properties and have the potential to bioaccumulate and biomagnify. The Delegated Officer considers that due to the high risk of impacts to groundwater the Premises should be tested to determine if PFAS are present in the pond and/or groundwater.

DWER will use the results of the testing to determine the suitability of current control measures in place. The monitoring parameters and Interim screening levels have been derived from DWER Guideline: Interim Guideline on the Assessment and Management of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) (DER 2017).

The Delegated Officer has determined that the sampling shall be undertaken by a Certified Practitioner due to the complexities associated with PFAS sampling, and in particular the potential for ‘false positives’.

8.8.4 Liquid waste feedstock characterisation and product specification

The Licence Holder will be required to characterise the liquid waste streams that are accepted and added to the composting process within six months following the issue of the Revised Licence, with the exception of the putrescible and organic controlled waste types K100, K110, K130, K200 and K210 and the piggery wastewater and sludge received from CM Farms.

A liquid waste stream refers to a liquid waste type from a particular source or multiple sources where those liquid wastes are produced by the same processes, have the same characteristics and the same contamination risk profile.

The characterisation shall include the source of the waste stream, the process which produced it, the contaminants which the waste contains and the concentration ranges for those contaminants (determined through laboratory analysis).

A minimum analytical suite for will be specified for each Liquid Waste Stream based on the applicable controlled waste category.

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The Licence Holder will be required to identify the extent to which each stream contributes to the biological process of making compost.

For any liquid waste streams which contain contaminants that do not contribute to the biological process of making compost, the Licence Holder must identify the contaminants that are treated within the composting process and their treatment pathway, and the contaminants that are not treated.

The Licence Holder will be required to document the quality control procedures currently applied or proposed to be applied to assess whether incoming liquid waste streams conform to their characterisation, the treatment effectiveness of the biological composting process, and compost product quality in relation to contaminant content.

The report including the above information will need to be provided to DWER by 15 March 2019.

The Licence Holder will also be required by 15 March 2019 to provide a report which includes:

the details all of the compost products produced at the Premises and their proposed end uses;

the Licence Holders proposed product specifications for each of the compost products;

a comparison of the Licence Holders proposed product specifications with product standards which DWER has sourced from AS 4454 and the Western Australian Guidelines for Biosolids Management (DEC 2012); and

where the product specifications deviate from the product standards, how the product specification ensures that the product is suitable for its intended end use.

For any additional waste streams accepted after the 6 month period following the issue of the Revised Licence, the Licence Holder must:

undertake the characterisation of the waste stream;

identification of how the liquid waste stream contributes to the biological composting process of making compost;

identify how the contaminants within the waste stream are or are not treated by the composting process; and

assess the impact on the compost quality in relation to the product specification which was submitted to the DWER as part of the above requirement.

This information will be required to be recorded; however will not need to be reported to DWER at this stage.

Grounds: The Delegated Officer has determined that the putrescible and organic waste types K100, K110, K130, K200 and K210 (shaded in grey within Table 1 of Appendix 3), and piggery wastewater and sludge received from CM Farms, contribute to the biological process of making compost and are unlikely to contain contaminants that cannot be treated through the composting process. Further information regarding the characterisation of these waste types is therefore not required.

The information provided by the Licence Holder to date is not sufficient to appropriately characterise the other liquid waste types in regards to their sources, the contaminants which they may contain, and the level of treatment of these contaminants. The Delegated Officer considers that the information requested is necessary to enable DWER to determine the suitability of these liquid wastes streams for incorporation into the composting process.

The minimum analytical suite varies for each controlled waste category, some requiring a wider scope for analysis due to their potential to contain a wider variety of contaminants (for example L150 Industrial Wastewater Contaminated with a Controlled Waste).

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The degree of treatment within the composting process of contaminants within the liquid waste inputs is relevant to the risk to human health and the environment posed by the use of the Compost Products. The proposed sampling, testing, quality control procedures and product specification which are intended to mitigate this risk is also necessary information for the consideration of the appropriate regulatory controls.

A period of six months for the characterisation of liquid wastes received is considered a reasonable period within which the Licence Holder would typically receive loads from the majority of their liquid waste sources.

DWER will determine the addition of any further regulatory controls following the consideration of the reported information.

9. Premises production or design capacity – Category 61: Liquid waste facility

A Premises Production or Design Capacity of 93,300 tonnes for Category 61 has been included within the general description of the Premises in Schedule 2 of the Revised Licence.

Grounds: The Existing Licence authorises a throughput of 60,000 tonnes per annual period for category 61 activities. The acceptance of wastewater and sludge from the piggery was previously not captured within the category 61 throughput or monitored.

The Licence Holder has estimated that approximately 38,090 tonnes of piggery wastewater (including up to 30% runoff during application to feedstocks) and 4000 tonnes of sludge sourced from CM Farms is required annually to meet the Category 67A compost product capacity of 90,000 tonnes per annum (C-Wise 2017).

The Delegated Officer has determined that the estimated annual volume of piggery wastewater and sludge which may be accepted to meet the compost production capacity should be captured within the Category 61 premises production/design capacity. The revised production or design capacity for Category 61A of 102,090 tonnes per annum is therefore the sum of the Category 61 production or design capacity of the Existing Licence (60,000 tonnes), plus the Licence Holders estimated annual piggery wastewater and sludge requirements to meet the compost production capacity.

10. Appropriateness of Licence conditions

The conditions in the Issued Licence in Attachment 1 have been determined in accordance with DWER’s Guidance Statement on Setting Conditions.

Condition Ref Grounds

Emissions This condition is valid, risk-based and consistent with the EP Act.

Compost production limit This condition is valid and risk-based (see Section 8).

Waste acceptance controls

These conditions are valid, risk-based and contain appropriate controls (see Section 8).

Infrastructure and equipment controls

Operational Controls

Groundwater Monitoring

Pond Monitoring and actions

Specified Actions

Record-keeping These conditions are valid and are necessary administration requirements to ensure compliance.

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Ongoing reporting These conditions are valid and are necessary reporting requirements to ensure compliance and assessment of environmental performance.

DWER notes that it may review the appropriateness and adequacy of controls at any time, and that following a review, DWER may initiate amendments to the Licence.

11. Licence duration

Giving consideration to the current lease period for the Premises, the Issued Licence has an expiry date (28 October 2019) which is a one year extension on the expiry date of the existing Licence. The Licence period will therefore extend beyond the current lease period, however this is considered to be a low risk as the lease is expected to be extended beyond that expiry date. Should the lease not be extended and on-going management of the site is considered necessary the Department will consider issuing a Closure Notice on the Premises. The Issued Licence duration may be extended in future should the lease for the Premises also be extended.

12. Licence Holder consultation

The Licence Holder was provided with the draft decision report and draft Licence on 29 March 2017 for an initial consultation period. The Licence Holder was provided with the revised draft decision report and draft Licence on 13 February 2018 for a second consultation period.

The Licence Holder provided comments which are summarised along with DWER’s response in Appendix 2.

13. Conclusion

This assessment of the risks of activities on the Premises has been undertaken with due consideration of a number of factors, including the documents and policies specified in this decision report (summarised in Appendix 1). This assessment was also informed by a site inspection by DWER officers on 13 October 2016.

Based on this assessment, it has been determined that the Revised Licence will be granted subject to conditions commensurate with the determined controls and necessary for administration and reporting requirements.

Ruth Dowd Senior Manager Waste Industries Delegated Officer under section 20 of the Environmental Protection Act 1986

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Appendix 1: Key documents

In-text references

Document Title In-text ref Availability

1 ANZECC & ARMCANZ, 2000. Australian and New Zealand Guidelines for Fresh and Marine Water Quality.

ANZECC & ARMCANZ 2000

www.agriculture.gov.au/Site

CollectionDocuments/water/

nwqms-guidelines-4-vol1.pdf

2 Australian Pork Limited, 2010. National Environmental Guidelines for Piggeries, Second Edition (Revised)

Australian Pork Limited 2010

www.australianpork.com.au

3 Bell, J. (C-Wise) (1 December 2016). Info request [Email] Bell 2016 [email] DWER records (A1336379)

4 Bureau of Meteorology - Climate data online. Accessed 5 October 2016

BOM 2016 bom.gov.au

5 C-Wise (28 August 2017). Licence renewal application form and supporting information.

C-Wise 2017 DWER records (A1512776)

6 C-Wise & CM Farms, December 2017. Memorandum of Understanding between C-Wise and Derby Industries Pty Ltd for Dam Water and Run-off Management.

C-Wise & CM Farms 2017

DWER records (A1584975)

7 Department of Environment and Conservation, December 2012. Western Australian guidelines for biosolids management.

DEC 2012 www.der.wa.gov.au/compon

ent/k2/item/4131-biosolids-

management

8 Department of Environment Regulation, Western Australia, 2014. Assessment and management of contaminated sites, Contaminated sites guidelines.

DER 2014 www.der.wa.gov.au/your-

environment/contaminated-

sites/61-contaminated-sites-

guidelines

9 Department of Environment Regulation, Western Australia, 2017. Interim guideline on the assessment and management of perfluoroalkyl and polyfluoroalkyl substances (PFAS). Contaminated sites guidelines.

DER 2017 www.der.wa.gov.au/images/

documents/your-

environment/contaminated-

sites/guidelines/Guideline_o

n_Assessment_and_Manage

ment_of_PFAS_v2.1.pdf

10 Department of Water, 2009. Ponds for stabilising organic matter. Water Quality Protection Note, WQPN 39

DoW 2009 water.wa.gov.au

11 Department of Environmental Quality, State of Idaho, 2014. Statistical Guidance for Determining Background Ground Water Quality and Degradation.

DoEQ, 2014 www.deq.idaho.gov/media/1

226/guidance-statistical-

degradation.pdf

12 Hall, J., Kretschmer, P., Quinton, B. and Marillier, B., 2010. Murray Hydrological Studies: Surface water, groundwater and environmental water. Conceptual model report. Department of Water, Water Science Technical

Series, Report WST 16

Hall et al., 2010 water.wa.gov.au

http://www.agriculture.gov.au/SiteCollectionDocuments/water/nwqms-guidelines-4-vol1.pdf



http://www.der.wa.gov.au/your-environment/contaminated-sites/61-contaminated-sites-guidelines




http://www.der.wa.gov.au/images/documents/your-environment/contaminated-sites/guidelines/Guideline_on_Assessment_and_Management_of_PFAS_v2.1.pdf






http://www.deq.idaho.gov/media/1226/guidance-statistical-degradation.pdf



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13 Ham, J.M. and Baum, K.A., 2009. Measuring seepage from waste lagoons and earthen basins with an overnight water balance test. Transactions of the American Society of Agricultural and Biological Engineers, 52(3), 835-844

Ham and Baum, 2009

DWER records

14 Marillier, B. (2012). Nambeelup groundwater modelling report. Department of Water, Water Science Technical Report No WST 47.

Marillier, B 2012 water.wa.gov.au and DWER

records (A1169872)

15 Parker, D.B.; Eisenhauer, D.E.; Schulte, D.D.; and Nienaber, J.A., 1999. Seepage Characteristics and Hydraulic Properties of a Feedlot Runoff Storage Pond. Biological Systems Engineering: Papers and Publications, 179.

Parker et al. 2009 DWER records (A1700931)

16 United States Environmental Protection Agency (US EPA), 2011. Principles of design and operations of wastewater treatment pond systems for plant operators, engineers, and managers. (457 pages) Accessed 3 March 2017.

US EPA 2011 https://www.epa.gov/sites/pr

oduction/files/2014-

09/documents/lagoon-pond-

treatment-2011.pdf

17 WA Composts Pty Ltd, September 2017. C-Wise response to DWER request for information regarding use of CM Farms’ dam water on C-Wise hardstand and return of leachate to CM Farms’ dam 2.

WA Composts Pty Ltd 2017a


18 WA Composts Pty Ltd – C-Wise – spreadsheet for water balance for DER. Provided on site visit 5/7/17.

WA Composts Pty Ltd 2017b


19 YSI International, 2008. ORP Management in Wastewater as an Indicator of Process Efficiency, Application Note.

YSI Environmental 2008

https://www.ysi.com/File%20

Library/Documents/Applicati

on%20Notes/A567-ORP-

Management-in-Wastewater-

as-an-Indicator-of-Process-

Efficiency.pdf

20 Zang, R.H., Dugba, P.N. and Bundy, D.S. 1997 Laboratory study of surface aeration of anaerobic lagoons for odor control of swine manure. Transactions of the American Society of Agricultural and Agricultural Engineers 40(1): 185-190

Zhang, Dugba and Bundy 1997

-

Other documents

Document Title Availability

21 Bell, J. (C-Wise) (November 2016). Response to Information Request in letter 11th November 2016 [Email]


22 Bell, J. (C-Wise) (23 November 2015). Information [Email] DWER records (A1017039)

23 Bell, J. (C-Wise) (23 June 2015). Information to clarify for licence conversion to REFIRE [Email]


24 Bell, J. (C-Wise) (24 December 2015). C-Wise DER Licence [Email] DWER records (A1025893)

25 C-Wise (31 May 2017). Letter Re: Response to Notice Under Section 59(B) Of the Environmental Protection Act 1986 Regarding Licence Review and Amendment to Licence L8410/2009/3.


https://www.epa.gov/sites/production/files/2014-09/documents/lagoon-pond-treatment-2011.pdf




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26 C-Wise (2 March 2017). Application form for amendment and supporting documentation.

Attached within the following emails:

Casey, T. (C-Wise) (2 March 2017). C-Wise – Licence amendment application – Dam 33 [Email]

Casey, T. (C-Wise) (16 March 2017). C-Wise – Licence amendment application – Dam 33 [Email]

Casey, T. (C-Wise) (13 April 2017). APPLICANT NOTIFICATION – L8410/2009/2 – APPLICATION TO AMEND LICENCE. [Email]

DWER records (A1387035,

A1395281, A1421181)

27 Casey, T. (C-Wise) (1 March 2018). RE: C-Wise dam leak detection tests [Email]


28 Bell, J. (C-Wise) (4 April 2018). RE: C-Wise WA Composts Licence L8410/2009/2 - Feedback to Review and Proposed Amendments [Email]


29 C-Wise (29 March 2018). Letter RE: C-Wise Response to Review and Proposed Amendments to Licence L8410/2009/2.

Attached within the following email:

Maiden, A. (C-Wise) (29 March 2018). C-Wise WA Composts Licence L8410/2009/2 - Feedback to Review and Proposed Amendments [Email]


30 Bell, J. (C-Wise) (24 April 2018). RE: Clarification on hardstand drainage [Email]


31 C-Wise (11 May 2018) Letter RE: Notice under Section 59(B) of the Environmental Protection Act 1986 regarding Licence Review and Amendment of LicenceL8410/2009/2 - Request for Further Information.

Attached within the following email:

Bell, J. (C-Wise) (11 May 2018). Response to further clarification required letter - L8410 WA Composts Pty Ltd [Email]


32 Bell, J. (C-Wise) (6 June 2018). Update [Email]. DWER records (A1689846)

33 Bell, J. (C-Wise) (8 May 2018) RE: PFAS sampling and CM Farms wastewater volume [Email]


34 Custom Composts, 2009. Report to DEC, Kwinana.

Attached to email: Custom Composts (January 2009). New DEC License and review of operations. [Email]


35 DER (8 April 2008). Letter RE: PROPOSED LINED STORAGE PONDS – WANDALUP FARMS, NAMBEELUP


36 DER (6 May 2016). Letter to Craig Salt, WA Composts Pty Ltd DWER records (A1134310)

37 DER (December 2016). File Note: Inspection 9 December 2016 DWER records (A1357452)

38 DER (11 July 2017). CEO1831/17: Nambeelup odour and groundwater data request


39 DER (6 July 2017) File Note: Site Visit – C-Wise DWER records (A1468369)

40 DER (10 June 2016) File Note: Nambeelup Site Visit (CM Farms piggery, C-Wise, Costa mushroom compost) following odour complaints, 27 May 2016.


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41 DER Guidance Statement on Regulatory principles

www.dwer.wa.gov.au

42 DER Guidance Statement on Setting conditions

43 DER Guidance Statement on Licence duration

44 DER: Guidance Statement: Decision Making

45 DER Guidance Statement: Risk Assessment

46 Geo & Hydro Environmental Management Pty Ltd. (2010). Borehole Log Borehole Name: CC05.

Attached to email:

Bell, J. (November 2010). Groundwater Monitoring Bore Construction. [Email]


47 Geo & Hydro Environmental Management Pty Ltd. (2010). Borehole Log Borehole Names: CC01, CC02, CC03, CC04.

Attached to email: Bell, J. (2011). Monitoring Bore Updates. [Email]


48 Geo & Hydro Environmental Management Pty Ltd. (2012). A H1 Hydrogeology

Report for WA Composts PL trading as C-Wise.


49 International Organisation for Standardization (ISO) 2014. International

Standard ISO 17289 Water quality – Determination of dissolved oxygen –

Optical sensor method

www.iso.org/standard/59515.

html

http://www.dwer.wa.gov.au/

http://www.iso.org/standard/59515.html

http://www.iso.org/standard/59515.html

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Appendix 2: Summary of Licence Holder’s comments on draft risk assessment and conditions

Table 1: Licence Holder’s comments in response to the draft Decision Report and Licence provided to the Licence Holder on 29 March 2017 and 13 February 2018.

Aspect Summary of Licence Holder comment DWER response

General Comments received on 1 June 2017:

The proposed licence amendment may:

- cause C-Wise to potentially suffer loss of jobs or material financial loss;

- impact C-Wise’s support of CM Farms and Mushroom Exchange; and

- impact business that currently rely on C-Wise to accept liquid waste.

DWER has given further consideration to many aspects of the draft amendment. Of particular significance, the draft has been amended to continue to allow the acceptance of all of the liquid wastes which are allowed under the Existing Licence (with the exception of N140 fire debris and fire wash water), however the Licence Holder will be required to provide further information regarding liquid waste characterisation and behaviour within the composting process, and the proposed product specifications for the compost produced with a comparison to AS 4454. This additional information will allow DWER to undertake further assessment of the risks associated with the compost product use.

General Comments received on 1 June 2017:

The prescriptive nature of the proposed licence amendments could be seen as being adversarial and our concern is that these amendments have been based on a less than complete understanding of our business operations. As a result, the DER assessment of the C-Wise business risks is considered to be higher than the real position of those risks.

DWER has undertaken the assessment of the operations based on the information on file, site visits and further information which has been provided by the Licence Holder. Where possible DWER has defined outcomes; however, where there is difficulty in implementing an outcome based condition, more prescriptive conditions have been applied. DWER will request additional information through several conditions

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We firmly believe that the most appropriate way of protecting the environment is through an outcomes-based approach to the licence conditions which prescribes the desired goals associated with environmental protection and then allows C-Wise to implement appropriate methods and controls to achieve the desired outcomes.

We are firmly of the view that a mutually acceptable outcome can be reached that not only aligns with the DER’s expectations in terms of environmental management and protection but does not compromise our operations unnecessarily or impose what we believe amounts to a restraint of trade.

We are deeply concerned with DER’s approach in relation to this matter particularly where we believe that there has not been full transparency from the DER, in particular with regards odour issues. We are also of the view that the highly prescriptive approach has been driven by an unnecessary overreaction to the BioOrganics matter.

where this is considered necessary due to a current level of uncertainty (such as the liner integrity or seepage rate tests to be undertaken for the ponds). The restriction on the liquid waste types within the previous draft has now been amended to require further information on the characterisation of liquid wastes and their level of treatment etc. within the composting process. This information will undergo further assessment when received by DWER. DWER’s aim is to fully document the decision making process and the information informing decisions within the Decision Report.

Draft decision report – section 4.8.2: Odour and Appendix 5 and 6

Comments received on 1 June 2017:

C-Wise has not been notified of odour complaints as they have been recorded by DER, nor have we been invited to address any of the community complaints at appropriate community events.

In the Mandurah Odour Investigation conducted by the DER on 19 May 2016, the DER linked odour to the Nambeelup site. Please note that C-Wise was made aware of this investigation at a later date, being 15 July 2016 and was not informed by the

Noted. DWER has now implemented a process of notifying the Nambeelup Farm Licence Holders of relevant complaints on a regular basis. It is correct that the DER did not receive any complaints relating to the Nambeelup Premises on the 19th of May 2016. The following response was provided to the Licence Holder on 11 July 2017 via letter in regards to the methodology within the Mandurah Odour Investigation:

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DER that their odour investigation report was going to be released on their web-site.

In the explanation of how this odour investigation came about, the report states that “The investigation was carried out independent of any complaints …”. As set out in the investigation report, the DER field officers encountered odours at 21 different positions, at distances ranging between 8.2kms and 1.0kms from Nambeelup. However, it is our understanding that on that same day there were no odour complaints made to the DER by the community.

It is also of concern to C-Wise that neither this study, nor any other DER study described in the report has employed the conventional measurement of odour, i.e. Odour Units. Rather they have depended on qualitative assessment of the type and strength of odour.

In the report, it is acknowledged that there are a number of other potential natural odour sources (lakes and rivers) in the Mandurah area. This is relevant to the specific complaint validation made by DER Air Quality officers on 27 May 2016. It is noted that of the two complainants, one lives 6kms from Nambeelup on the edge of Goegrup Lake and the other has Black Lake, a notorious odour producer, in a direct line between themselves and Nambeelup Farm. No indication of wind speed or odour type is provided to support the conclusions that the

With regard to the odour assessment methodology, the Department field odour surveys follow a method derived from the German standard VDI 3940 Part 2 (2006). Using this method, field measurements are reported as “odour recognised” or “not recognised” and the “odour character” (should the odour be recognised). Odour units refer to the measurement of odour concentration, which is not an odour dimension measured when performing odour field surveys. Also, the strength (or intensity) of an odour is reported following a scale that is presented in the German standard VDI 3940 Part 3 (2010). The measurement of odour intensity was not within the scope of the Mandurah Odour Investigation.

It is agreed that the figure illustrating the complaint validation undertaken by Air Quality Officers on 27 May 2017 should include an indication of wind speed and direction during the period of observation. This information was provided to all Nambeelup Farm premises Licence Holders on 11 July 2017. Figure 8 within Appendix 5: Odour Impact Analysis has been updated to include the wind direction and speed.

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Nambeelup site was responsible for both complaints.

Draft decision report – section 4.8.1: Groundwater monitoring


Regarding the analysis conducted by the DER on the bore hole groundwater data, C-Wise would like to understand how the DER has reached their conclusion that C-Wise has contaminated the groundwater. It is our opinion that DER has provided no evidence to support this conclusion.

There is no reference to the groundwater conditions prior to C-Wise occupying the site and no evidence has been provided of how the nutrient load could have come about from the composting activities. The DER has compared the nutrient concentrations in the various bores around site to an arbitrary baseline value and concluded that “High nutrient levels in multiple bores indicate that there is substantial seepage from C-Wise infrastructure requiring improvement.”

We believe it would be beneficial for us to discuss in detail how the DER reached this conclusion given that:

• From our analysis of the groundwater data there is no indication that the nutrient and TDS concentrations have increased with time, and indeed for phosphorus, it has decreased since 2010.

• C-Wise has not seen the data that supports such a conclusion.

In the Decision Report, DWER has outlined possible contamination scenarios, specifically relating to the infiltration pathways of nutrient rich leachates to groundwater. It is agreed that some of the phrasing used within the previous draft Decision Report implied certainty that the C-Wise operations had and were continuing to cause contamination of groundwater, when there is insufficient groundwater monitoring data of reliable quality to provide that level of certainty. The phrasing used throughout the Decision Report in regards to the interpretation of the results of groundwater monitoring has been revised to acknowledge the lack of certainty by discussing that the groundwater monitoring results indicate that there has potentially been or likely to have been a source of contamination from the existing Premises. DWER has also initiated a review of the site’s classification under the CS Act to consider the groundwater data collected since the date of classification. The Delegated Officers view is that the groundwater monitoring results and the hydrogeological setting of the Premises justify the requirement that the Licence Holder undertake liner integrity and seepage rate testing for the ponds within the Premises.

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• DER has been informed previously that prior to C-Wise occupying the site, and for a period until recently, other businesses on the Nambeelup site had a licence to operate an overflow drain that allowed treated effluent to be discharged into the environment.

• C-Wise has never during its tenure discharged either treated or untreated process water into the environment.

• The C-Wise operation is conducted on hardstand which consists of either 300mm of compacted limestone or 300mm of compacted limestone overlain with either 40-50 mm of hot mix, or 200 mm of 40 MPa concrete.

• The integrity of the containment infrastructure (dams and hardstand) has not been compromised and there is no evidence available to indicate such.

• The design of the entire facility was undertaken in consultation with, and was granted approval from the DER over the period of the 20 years’ operation.

• In February 2012, an Environmental Assessment Report for the Nambeelup Industrial Area District Structure Plan was commissioned by the Department of Planning. They included in that report the Department of Environment and Conservation report from March 2010 that concluded though the site had some historical contamination “… natural processes are restricting the migration of contamination and are likely to be decreasing the overall concentration of ammonia on the Site. At the time of Classification, the potential contaminants of concern appear to be contained on the Site such

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that human and environmental receptor exposure is restricted. “.

Given these facts, we are concerned that the resultant risk mitigation strategies proposed by the DER in the proposed licence amendments for C-Wise make assumptions about the impact of C-Wise activities on the state of the groundwater at Nambeelup and are contrary to earlier DER advice.

Draft decision report – Section 3.2.6 Liquid waste treatment and storage in ponds: 3.2.7 Key findings - 1


The Licence Holder does not agree that piggery water and sludge accepted from CM Farms should be considered as part of the volume accepted under Category 61 on the Licence, for the following reasons:

i. there is no remuneration between C-Wise and CM Farms for its use;

ii. if this was introduced, it would apply a severe financial penalty to the business; and

iii. the current tracking forms apply to road deliveries by vehicle, not to volumes transferred by a pump.

The piggery wastewater and sludge is a liquid waste which is accepted which is produced on another premises, and therefore meets the description of the Category 61 Liquid Waste Facility. The pumping of the wastewater and sludge from CM Farms doesn’t require tracking through Controlled Waste Tracking Forms, as it isn’t transported on roads. In regards to the annual licence fee, the increase in the Category 61 capacity will not increase the annual fee as the Category 67A capacity attracts a higher fee than Category 61. The Licence holder is only charged for the category which attracts the highest annual fee. No change has been made to the inclusion of the piggery wastewater and sludge within the Category 61 production or design capacity.

Draft decision report – Section 3.2.6


The Licence Holder clarifies that the quantity of

These figures have now been included these figures in the description of the activities and the water balance assessment within this Decision Report.

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Liquid waste treatment and storage in ponds: 3.2.7 Key findings - 2

wastewater and sludge accepted from CM Farms is not measured but can be estimated to an accuracy of about 20% based on known pumping rates, pump operational times and because the quantities of water used to make a specific volume of compost are known from years of operational experience.

Typically, about 8,000 – 10,000 m3/annum of piggery wastewater is used in C-Wise‘s composting process. An amount of 4000 m3/annum of sludge is typically used.



The Licence Holder notes that the key finding no.3 is partly incorrect. The intent of dams 21 and 22 is to hold liquid organics that seep through the receival process during high acceptance periods. Dams 23, 24, and 25 are used for storage of specific types of liquid wastes (ammonium nitrate, oily waters, and calcium carbonate) that are introduced into the process as required. The primary intent of Dams 31 and 32 is to accommodate winter rainfall events, and an additional benefit are that they act as polishing ponds, to allow biodegradable material to be degraded.

DWER has given further consideration to the approach within the previous draft Decision Report. The discussion regarding the historical intent of the ponds has been removed from the Decision Report as this is no longer considered relevant, due to the revision of the regulatory controls proposed to be applied to the liquid waste acceptance.



The Licence Holder confirms that the ponds were not designed for intensive treatment of liquid organic wastes, but by virtue of their design (shallow with large surface area to provide surface aeration) contribute to aerobic breakdown of biodegradable material and also have a pathogen reduction role due to having a large surface area exposed to UV

As above.

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light.

Draft decision report – Section 4.8.1: Groundwater monitoring - Key findings


In regards to the groundwater monitoring for arsenic which DWER has proposed, the Licence Holder seeks to understand, if arsenic was detected in groundwater samples, how DWER would determine that the arsenic is not a consequence of the recent (and authorised) historical practices of irrigation of effluent on the site.

The presence and levels of arsenic in the groundwater will inform on risks to potential receptors associated with this type of contamination. DWER recognises that it may not be possible to determine with confidence the extent to which the presence of arsenic would be due to past activities within the Premises.

Draft decision report – Section 4.8.1 Groundwater monitoring (and Appendix 4 section 3) - Key findings - 2


The Licence Holder does not agree with the requirement for electrical testing of liner integrity on the basis that it cannot be conducted safely, noting that Section 1.7 of ASTM-D7007 2009 states “These procedures are potentially VERY DANGEROUS, and can result in personal injury or death.”

The Licence Holder considers that the standing water seepage rate method would be difficult due to the inability to distinguish small leakage rates by observing change in water levels.

See the comments and response provided below in regards to condition 24.



The Licence Holder considers that the method of using an up gradient bore to develop a reference level against which impact bores can be compared is a flawed methodology, as it allows comparison in space, but fails to take into account the change in bore values with time.

The chosen methodology is consistent with methodologies outlined in the NEPM for contaminated sites investigations and will allow existing concentrations at the site to be compared to the background concentrations for which data is available. DWER acknowledges that there are some limitations with this method of interpreting results and has removed the groundwater action criteria and the need to increase monitoring frequency when the

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monitoring results exceeded those criteria. Instead the Licence Holder will need to compare their results against calculated background levels when reporting the groundwater monitoring results.



Licence Holder considers that the detection of plume mobilisation can only be done by looking at variations in concentrations with time and with a detailed understanding of the movement of groundwater.

DWER agrees that more detailed groundwater investigations would be required to fully delineate a contamination plume. The key finding has been revised to state that the current monitoring bore network would be insufficient for this purpose.

Draft decision report – Section 4.8.1 Groundwater monitoring (and Appendix 4 section 4) - key findings - 1


The Licence Holder disagrees that concentrations from groundwater monitoring results can be used to confirm groundwater flow direction.

The key finding has been revised to state that the groundwater monitoring results infer groundwater flow direction.



The Licence Holder considers that it’s unclear how DER came to the conclusion that high nutrient levels in multiple bores indicate that containment infrastructure integrity is compromised resulting in seepage from all three premises, as the levels may be a consequence of the recent (and authorised) historical practices of irrigation of effluent on the site.

The Licence Holder asks how DER would determine that the levels are not due to this irrigation.

DWER considers that shallow bores that are located close to the operational infrastructure are likely to reflect contamination from more recent activities at those locations. DWER’s understanding is that authorised discharges have not occurred within the Nambeelup Farm premises within the last 10 years. As discussed in response to other feedback above, the phrasing used throughout the Decision Report in regards to the interpretation of the results of groundwater monitoring has been revised to acknowledge the lack of certainty by discussing that the groundwater monitoring results indicate that there has potentially been or likely to have been a source of contamination from the existing Premises.

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The key finding has been revised to state that containment infrastructure integrity may be compromised. Liner integrity or seepage rate testing will be required to provide further information regarding the likelihood of the ponds as a current source of contamination.



The Licence Holder disagrees with DER’s conclusion that a plume extends from the operational areas in a south-westerly direction which confirms an open pathway to impact sensitive environmental receptors downgradient from the premises.

The Licence Holder notes that they would have expected DER to test groundwater outside the Nambeelup premises to confirm this assertion and this was not done.

DWER has revised the wording of this key finding to state that the extension of a plume in a south-westerly direction is likely and indicates an open pathway. Groundwater monitoring results from the existing bore network through the mandated monitoring regime have been used within this Review. DWER has also initiated a review of the site’s classification under the CS Act to consider the groundwater data collected since the date of classification. Further investigation could be required within this process.



The Licence Holder notes that all monitoring data has been provided to DER as required, however an opportunity to improve the data quality is welcome if this results in improved outcomes for all parties.

DWER notes the Licence Holder’s comment.

Draft decision report – Section 4.8.1 Groundwater monitoring (and


The Licence Holder suggests that the conclusion in regards to high ammonia levels detected in C-Wise

DWER has revised the wording of this key finding to state that high ammonia levels have been detected in bore CW05A indicating the likely presence of a nearby contamination source.

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Appendix 4 section 5) - key findings - 2

bore 5A (CW05A) should be that C-Wise infrastructure is not responsible for these levels, as C-Wise bore 2 (CW02) is closer to C-Wise infrastructure and has lower levels of ammonia, and CW05A is closer to CM Farms infrastructure.



The Licence Holder queries DER’s finding that there is substantial seepage from C-Wise infrastructure, as an analysis of the change in nutrient concentration with time indicates that there is no net accumulation of nutrients. It is unclear to the Licence Holder how this finding has been concluded given the recent (and authorised) historical practices of irrigation of effluent on the site.

The Licence Holder suggests that this key finding is a contradiction of the second key finding of section 4.8.1 which states that the monitoring network is not able to identify contamination sources at a small spatial scale such as a single pond.

As stated in response to other feedback above, DWER considers that shallow bores that are located close to the operational infrastructure are likely to reflect contamination from more recent activities at those locations. DWER’s understanding is that authorised discharges have not occurred within the Nambeelup Farm premises within the last 10 years. DWER has revised the wording of this key finding to state that high nutrient levels in multiple bores indicate that there is likely to be a contaminant source or sources nearby, which need to be identified. It is therefore necessary to confirm through testing that containment infrastructure on site is effective.

Draft decision report – Section 4.8.2 Odour – key findings - 1


Licence Holder agrees that odours can travel significant distances however considers that the application of a more robust scientific scrutiny in the form of a specific odour plume dispersion model and odour unit emission data would assist in identifying the potential of the Nambeelup Farm premises to produce detectable odours at those distances.


Draft decision report – Section 4.8.2

Comments received on 1 June 2017: In regards to the approach to odour identification, the use of odour units is used in some jurisdictions in the

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Odour – key findings - 2

The Licence Holder considers that DER’s conclusion that odour emissions observed in the Mandurah area are mainly attributable to the Nambeelup Farm Premises is highly contentious, as DER did not employ conventional scientific approaches to odour identification (i.e. Odour Units combined with an odour dispersion model).

context of specifying predictive odour modelling criteria for impact assessment of new proposed facilities. For existing facilities empirical evidence of impacts involving human noses is generally preferred as the uncertainties in odour modelling predictions can be very large. Such empirical lines of evidence of odour impact include field studies, complaints data and community survey data. A standard referenced for odour field studies is the German standard VDI 3940 Part 2, (2006) “Measurement of odour impact by field inspection – Measurement of the impact frequency of recognizable odours - Plume measurement”.



The Licence Holder finds it difficult to understand DER’s conclusion that the composting operations are one of the largest sources of odour emissions from the Nambeelup Farm Premises, given that the C-Wise composting operations are aerobic.

This key finding has been removed as it was too general. DWER agrees that the composting windrows are not typically one of the major odour sources from the Premises, however the earlier stages of the liquid waste receival and feedstock mixing is likely to be more odorous.



The Licence Holder notes that the Premium and Wandalup composting areas (which employ clean feedstocks such as jarrah, oats, straw, spent mushroom compost, and previously piggery water for pre-wetting) has never previously been identified as odorous.

The Licence Holder notes that the liquid waste receivals process and mortalities storage have been

Noted. The terminology of ‘Premium and Wandalup’ composting areas was sourced from the report by ENVALL July 2016 Draft Investigation of Odour Emissions from Nambeelup Precinct Operations. This key finding has been revised to remove reference to the Premium and Wandalup composting areas as its unclear what process the ENVALL report was referring to in regards to these terms. The key finding now states that the area receiving liquid waste and mortalities for processing within the Premises was amongst the largest estimated odour

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re-designed with the objective of removing opportunity for odour production.

sources across all of the operations within Nambeelup Farms. DWER acknowledges the changes which the Licence Holder has implemented in the liquid waste receival and mortalities storage. This change in noted within Section 0 of the Decision Report.



The Licence Holder agrees that from a desk-top analysis, the conclusion that the DO and ORP within Ponds 21 and 22 indicate a significant odour risk (with potential production of sulphides and fatty acids) is valid. However the Licence Holder notes that in practice this does not occur on any regular or irregular frequency; possibly due to very low concentrations of sulphur or pre-cursers to fatty acids in the dam water, or conditions that are not conducive to growth of anaerobic bacteria that can mediate these reactions.

Noted, however the requirement to maintain the ORP level within the ponds above an action criteria has been removed from the Licence.



The Licence Holder does not consider the C-Wise pond water to have an odour.

DWER notes the Licence Holder’s comment. Based on the available information used within this Review, this key finding has not changed.

Draft decision report – Appendix 3 Liquid waste review – liquid waste volumes - key findings –1


The Licence Holder clarifies that DER’s estimation of the quantity of controlled liquid waste that can be utilised in the composting process is incorrect, and refers to information provided to DER on 13 April 2017 which states that at the current production rate (approximately 60,000 tonnes of compost per year)

DWER has reconsidered the restriction on the liquid waste types within the previous drafts and the drafts has now been amended to require further information on the characterisation of liquid wastes and their level of treatment etc. within the composting process.

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approximately 45,000 m3 of C-Wise pond water can be utilised in the composting process.

Further information received on 5 July 2017:

Further information was provided by the Licence Holder which indicates the estimated quantity of liquids needed throughout the composting process.

The information which the Licence Holders comment relates to has been removed from the decision report as it’s no longer relevant in the justification of the regulatory controls proposed. The new information provided has been used to update the description of the operations where applicable.



As above, the Licence Holder clarifies that DER’s estimation of the quantity of controlled liquid waste that can be utilised in the composting process is incorrect.

As above.



The Licence Holder clarifies that DER’s estimation of the quantity of piggery wastewater that is accepted at the Premises is incorrect. A figure of 8,000 to 10,000 tonnes is provided.

This information has been used to update the description of the operations where applicable.

Draft decision report – Risk of liquid waste and leachate impacts - Section 7.4.5 Key findings - 1


The Licence Holder considers that compost and leachate is appropriately contained in regards to the risk of impact on groundwater and surface water.




The Licence Holder doesn’t understand the key finding or its intent.

The consideration of groundwater as the most impacted receptor has been revised. The key finding has also been revised.

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The Licence Holder disagrees with DER’s use of the word ‘increase’, in stating that the groundwater monitoring results indicate a significant increase of nitrogen and phosphorous about background levels. The Licence Holder raises that the word increase assumes a change with time; however DER’s comparison of average values between different bores is not a comparison with time. The Licence Holder queries how DER would determine that the presence of nitrogen and phosphorus is not a consequence of the recent (and authorised) historical practices of irrigation of effluent on the site.

The wording of this key finding has been revised for clarification to state that groundwater monitoring at the premises to date indicates a significant elevation of nitrogen and phosphorus above background levels. DWER recognises that it may be difficult to determine with confidence the extent to which the presence of nitrogen and phosphorus would be due to past activities within the Premises. However, as stated in response to other feedback above, DWER considers that shallow bores that are located close to the operational infrastructure are likely to reflect contamination from more recent activities at those locations. DWER’s understanding is that authorised discharges have not occurred within the Nambeelup Farm premises within the last 10 years.



The Licence Holder re-iterates that there were previous authorised historical practices of irrigation on site that has been a source of groundwater contamination at the site.

As above.

Draft decision report – Risk of odour impacts – Section 7.5.5 Key findings – 1


The Licence Holder queries whether it is scientifically correct to state that the surrounding prescribed premises will have a cumulative odour impact, as this would only be so if the same compounds were emitted.

The Delegated Officer considers that a cumulative impact is possible where similar odours are emitted.

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Draft decision report – Risk of odour impacts – section 7.5.5 Key findings – 2


The Licence Holder queries what ‘demonstrated’ means in regards to DER’s finding that odour emissions have had a demonstrated impact on receptor amenity.

The demonstrated impact refers to odour complaints that have been verified by DWER officers.

Draft decision report – Risk of odour impacts – 7.5.5 Key findings - 3


The Licence Holder agrees with DER’s finding and notes that there is ample evidence to indicate that leachate and leachate ponds within the Premises are appropriately managed in regards to potential odour emissions.

DWER notes the Licence Holder’s comment; however the Delegated Officer considers that previous observations at the Premises and water quality results indicate that further management actions are justified.

Draft decision report – Appendix 3 Liquid waste review – water balance calculations- key findings –1


The Licence Holder considers that there are errors in DER’s finding that there is insufficient storage capacity in the ponds to accommodate excess liquid waste that isn’t required to support the composting process. The Licence Holder clarifies that there is no excess liquid waste because the composting process can accommodate all of the liquid waste volume (in the initial mixing with liquid waste and the application of liquid waste/pond water within the first stage of composting). The excess water that cannot be accommodated is the excess rainfall runoff that must be accommodated as a consequence of the DER directive that all of the runoff from the western hardstand must be accommodated in the C-Wise ponds; prior to this the ponds were able to accommodate all rainfall runoff.

Regardless of which individual inputs are considered to be in excess of the storage capacity, the total inputs to the ponds exceed the available storage capacity. DWER has reconsidered the restriction on the liquid waste volumes within the previous draft and the draft has now been amended to allow the acceptance of 60,000 tonnes of liquid waste (plus piggery wastewater and sludge), as per the Existing Licence. The information which the Licence Holders comment relates to has been removed from the decision report as it’s no longer relevant in the justification of the regulatory controls proposed. .

Draft decision report – Appendix 3 Liquid

Comments received on 1 June 2017: DWER notes that for most liquid wastes accepted, the few parameters typically monitored were

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waste review – controlled waste acceptance - key findings –1

The Licence Holder considers the meaning of DER’s finding that a number of waste types are unable to be characterised is unclear and provides the following information:

All liquid wastes accepted by C-Wise are categorized as required by the conditions of the Prescribed Premises Category Licence 61 under which C-Wise operates and which is administered by the DER. The characterization of the wastes is very specific in this system and allocation of wastes is made firstly by the originator and then checked by experienced chemists and chemical engineers at C-Wise.

If the statement refers to the ability to check the constituents of the waste, chemical species can be characterized by any number of analytical methods and if this is required, then this can be done. It is true that some of the waste categories include hydrocarbons, and the biological degradation of the hydrocarbon chains into useful carbon compounds such as humic and fulvic acids is a mechanism that can be optimised by a properly operated and controlled compost process. C-Wise has been successfully incorporating liquids containing short- and long-chain hydrocarbons into their processes for many years and has a very good

provided on 28 August 2017, but that the information provided also states that the parameters are “dependent on the generator, transporter and waste stream”. DWER has reconsidered the restriction on the liquid waste types within the previous draft and the draft has now been amended to require further information on the characterisation of liquid wastes and their level of treatment etc. within the composting process. This information will undergo further assessment when received by DWER. The Licence Holder may already have the level of detailed information required; however DWER does not currently have this information and considers that this information is necessary in assessing the addition of many liquid waste types within composting. The term ‘contaminant’ in regards to the content of liquid wastes is used in a general sense to refer to substances within the wastes which may cause that waste type to be potentially harmful to human health or the environment. The use of the term ‘chemical’ has been replaced with the use of the term contaminant.

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understanding of the loading rates that allow complete degradation of such compounds.

The Licence Holder considers the meaning of the word ‘chemicals’ in DER’s finding is unclear and provides the following information:

Many liquids received at the site contain “chemicals”, and many of these are highly desirable for composting, such as ammonium nitrate and sulphate containing species. These compounds are incorporated into the compost through biological mediation and the sulphate compounds in particular are of significant benefit in WA’s low sulphate soils.

The Licence Holder considers the meaning of the word ‘contaminants’ in DER’s finding is unclear, and that it’s unclear how the finding is relevant to the DER decision to amend the licence conditions. The Licence Holder notes that C-Wise has always adhered strictly to the categories of their licence and it is this categorization that should be used as measure to control liquid waste movement and treatment, not reference to species such as “hydrocarbons” or “chemicals”, or “contaminants” which are not specified in their type or effect.

Further information provided on 28 August 2017:

Typical monitoring schedule provided for each controlled waste category and solid feedstocks accepted at the Premises.

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Draft decision report – Appendix 3 Liquid waste review – controlled waste acceptance - key findings –2


The Licence Holder is happy to undertake testing for PFAS on the understanding that if this chemical is not detected in any significant quantity, then testing for it will not be included as a standard requirement, as it is expensive.

DWER will assess the need for ongoing monitoring based on the result of the once off sampling event.

Draft decision report – Appendix 4 Groundwater Monitoring – monitoring analytes – key findings -1


The Licence Holder is happy to undertake testing for species such as arsenic on the understanding that if this chemical is not detected in any significant quantity, then testing for it will not be included as a standard requirement, as it is an additional financial burden. The Licence Holder notes it would be useful to understand why arsenic in particular has been targeted as all of the heavy metals are a potential risk to human health.

The groundwater monitoring suite has been further considered. Mercury and zinc have been added to the ongoing groundwater monitoring suite on the basis that these metals are appropriate for the characterisation and detection of groundwater contamination caused by nutrient rich leachates.

Draft decision report – Appendix 4 Groundwater Monitoring – monitoring analytes – key findings -2


The Licence Holder would agree to inclusion of arsenic only after discussion of the response to key finding 1 above.

The Licence Holder refutes DER’s statement within Appendix 4 that “nutrients are the main contaminants entering the groundwater from storage ponds and processing areas”, noting that such statements, without evidence, highlight that a lack of appropriate scientific scrutiny has been applied.

As above. It is agreed that this statement incorrectly suggests certainly regarding seepage from ponds and processing areas. This sentence has been amended to state that “nutrients are the main contaminants likely to enter the groundwater…”, indicating the potential for seepage from the ponds and processing areas.

Premises boundary GPS coordinates

Information received 29 March 2018:

Premises boundary coordinates provided.

The Licence has been updated to include these coordinates.

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Draft licence – Emissions: Condition 1 in first and second draft


C-Wise agrees with the intent of attempting to specify permissible liquid and gaseous emissions, but does not agree with the conditions as specified. Therefore, until agreement is reached on those conditions, C-Wise cannot agree with the description of the emissions as stated. Whilst C-Wise agrees with the general intent of specifying the type of emissions that are permitted, we are of the view that the condition is not appropriate for a Licence, is confusing and poorly-framed and also incorporates reference to compliance with other legislation which we suggest is inappropriate. C-Wise suggests that further discussions be held in relation to this condition and its intent. We are of the view that, as currently framed, it is likely to be ultra-vires.

DWER notes the Licence Holder’s comment. The only change made to this condition has been the removal of the reference to material change.

Draft licence – Notification of Material Change: Conditions 2, 3 and 4 in first draft


C-Wise does not agree with this Condition because the definition of Material Change provided in the licence is too restrictive, too onerous and ill-defined. For example, the requirement to notify the CEO of a change in ownership of equipment used on site has no bearing on potential for odour or groundwater contamination and may have legal and/or technical implications that are not currently apparent to C-Wise.

These conditions relating to material change have been removed from the draft licence.

Draft licence – Information: Condition 5 in first draft


C-Wise would accept that any sample analysis should be undertaken by a properly accredited


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laboratory. However, the comments associated with Conditions 29, 32, 38, and 41 should be noted.

Draft licence – Information: Conditions 6 and 7 in first draft


Not acceptable to C-Wise because it refers to Condition 12 which includes requirements which are unacceptable to C-Wise.

DER interprets this comment as an objection to the types of feedstocks included within condition 12, rather than an objection to the records and reporting required by condition 6. See the response to condition 12 below.



Not acceptable to C-Wise because it refers to conditions that are unacceptable to C-Wise (see reference to Conditions 19 to 28).

Condition 8 doesn’t make reference to conditions 19 to 25 or 28. DER interprets this comment as an objection to the C:N ratio monitoring and action criteria within conditions 26 and 27, rather than an objection to the maintenance of records required by condition 8. See the response to conditions 26 and 27 below.



C-Wise currently maintains a register of complaints received from the DER. This condition is confusing as written because it does not specify details such as whether it refers only to notice of complaints received from the DER, or whether it refers to complaints directly received from the public. With regard to the former, we understand that the DER has very recently initiated a formal register of complaints of odour and that it distributes these to businesses in the area for notification only. C-Wise has recently been notified of complaints in the area and on querying these was informed that the intent was not to allocate blame for the odour and that no action was required by the receiving party. The condition as described is contrary to this advice. In reference to sub-conditions (a) to (d), it is unusual

The condition wording has been amended to make it clear that the Licensee must only record the complaints which are received directly to the Licensee, which does not include the complaints summary information which is sent to the Licensee from DWER. The Licensee should consider whether the Premises has contributed to the complaints that were received by DWER, however the condition wording does not state that the Licensee is expected to prove that the odour did not come from the Premises.

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that the DER requires personal details from the complainant, but not a record of the area in which the complainant recorded the odour.



C-Wise will do all it can to provide as complete a response as possible in an appropriate time, to a reasonable request.

DWER notes the Licence Holder’s comment. No change has been made to the condition.

Draft licence – Feedstock controls: Condition 12 in first draft


C-Wise cannot accept this condition because it is such a severe limitation of trade that C-Wise could not exist as a viable entity if this was applied. C-Wise urgently requests clarity from the DER on the outcomes it desires for the business, as it is our considered position that application of this condition to the Licence will not provide the outcomes that are implied and stated in the draft Decision Report. A major concern is the elimination of the low strength and high strength non-biological waste categories, given that these are not associated with organic odour production to which the DER refers in the draft Decision Report. It should also be noted that reduction of liquid waste volumes would require C-Wise to draw increased quantities of water from the aquifer to meet its demands.

C-Wise would be happy to review the categories of waste currently being accepted and identify those that are least well aligned to treatment by composting and that can be accommodated more

DWER has reconsidered the restriction on the liquid waste types and volumes within the previous draft and the revised draft has been amended to instead require further information on the characterisation of liquid wastes and their level of treatment etc. within the composting process. This information will undergo further assessment when received by DWER. This condition has been amended to include the list of liquid wastes which may be accepted under the Existing Licence, with the exception of N140 fire debris and wash water. The condition which restricted the types of feedstocks which could be accepted at the Premises has been amended to restrict only the types of waste which can be accepted. This wording therefore does not preclude the acceptance of non-waste feedstocks, such as fertilisers and micronutrients for example. The total volume of wastewater and sludge accepted from CM Farms cannot be calculated each year based on the proposed equation, as the rainfall

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easily by other waste treatment facilities that DER has identified.

Further information provided 28 August 2017:

Propose that restrictions on feedstock acceptance allow for the following feedstocks:

- “Solid organic material that is degradable by composting” and

- “Organic and inorganic ingredients complementary to or beneficial to compost, mulch or soil conditioner end-user requirements”.

Further comments received on 29 March 2018:

The 33,000 tonnes of piggery wastewater and sludge which is permitted to be accepted from CM Farms (as per the second draft for comment) doesn’t take account of the inefficiencies in the wetting process and the fact that much of the water drawn from CM Farms will be returned as runoff rather than used by C-Wise (integrated into the composting process). The total annual volume should be calculated using the following equation, as opposed to just using the volume of CM Farms water and sludge C-Wise receive.

Volume of wastewater used by C-Wise = Volume of CM Farms water or sludge received – Volume of C-Wise runoff to CM Farms.

captured within the hardstand area which runs back into the CM Farms ponds will interfere will determining the actual volume of wastewater which was returned to CM Farms. As the figures of 29,300 tonnes of piggery wastewater and 4,000 tonnes piggery sludge which were specified within the second draft for comment were based on the Licence Holders estimation of the composting needs (which the Licence Holder has since advised did not account for runoff from the wetting process), the volume of piggery wastewater has been increased by 30% as requested. The following changes have been made to the text regarding the Category 61 production capacity:

The Licence Holder has estimated that approximately 38,090 29,300 tonnes of piggery wastewater (including up to 30% runoff during application to feedstocks) and 4000 tonnes of sludge sourced from CM Farms is required annually to meet the Category 67A compost product capacity of 90,000 tonnes per annum (C-Wise 2017).

The Delegated Officer has determined that the estimated annual volume of piggery wastewater and sludge which may be accepted to meet the compost production capacity should be captured within the Category 61 premises production/design capacity. The revised production or design capacity for Category 61A of 102,090 93,300 tonnes per annum is therefore the sum of the Category 61 production or

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Further comments received on 8 May 2018:

An increase of 30% to the volume of piggery water incoming (as permitted within the second draft for comment) should account for any runoff back to the CM Farms dams (and therefore the calculation will not be required).

Further comments received on 4 April 2018:

C-Wise receive sand as well as various other nutrients or inputs (e.g. bentonite, fertilisers, micronutrients) for specific customer blends. These are certainly not ‘solid wastes’ but they are not listed under ‘feedstocks’ at all in table 2 either, do they need to be? Can they be left out or have a catch-all of ‘various compost product additives’ or some such thing as it will be impossible to list all of the various inputs that customers might ask for in their specific blends.

design capacity of the Existing Licence (60,000 tonnes), plus the Licence Holders estimated annual piggery wastewater and sludge requirements to meet the compost production capacity.

Draft licence – Specified infrastructure and equipment controls: Condition 13 in first draft


C-Wise cannot accept this set of conditions for numerous reasons. The overarching problem is that these conditions are highly prescriptive and not “outcomes-based”, the latter being a stated objective of the DER. C-Wise would look forward to the opportunity to propose an approach to the DER that would achieve each of its objectives in relation to protection of the environment, non-reduction of public amenity and development of sustainable businesses positively engaged with the public whilst

A degree of prescription has been considered necessary where an enforceable outcome based condition could not be achieved.

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also ensuring that the C-Wise operations are not fettered financially or via a restraint of trade.


Regarding the physical characteristics of the hardstands, those constructed by Custom Composts at Nambeelup were designed to meet best practice and exceeded the standards required for composting hardstands at that time. Since their installation, C-Wise has been diligent in maintaining their integrity. The DER has acknowledged that the C-Wise construction method has set a new standard and C-Wise can understand their desire to apply this standard to the entire industry. However, it is not possible to judge whether the design would meet the new hydraulic conductivity requirement of 1*10-9 m/s as it was not a specification at the time of construction. C-Wise would be interested to understand how appropriate this value is and to understand the outcome DER requires that has caused it to institute this measure.


Propose that a specific hydraulic conductivity for the hardstands and drainage channels is not specified within the Licence, and they are instead required to be “maintained with the load capability and hydraulic conductivity required at the time of construction”.

DWER understands that the hydraulic conductivity of the hardstands can be tested by undertaking laboratory testing of sample of the hardstand removed by coring. The Licence Holder’s proposed wording regarding the hardstand hydraulic conductivity would not be enforceable as the specific hydraulic conductivity required at the time of construction isn’t known. The proposed wording is not accepted.


DWER considers that the alternative wording proposed of maintaining the ponds in their “as-built condition” would also require the ponds to be maintained at the current capacity. A freeboard of

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Regarding Items 5 to 11 of Table 3, C-Wise would prefer that the volume is not specified, but that the terminology “be maintained in their as-built condition” be used. The current specification method will cause significant problems should C-Wise and the DER wish to discuss how an increase in freeboard would be accommodated.

300mm will be required to be maintained for all ponds. The Licence Holder would need to request an amendment of the licence if a reduced freeboard was proposed in future. Additional text has been added to this table to specify that the pond capacities listed exclude the 300mm freeboard.


Regarding Item 12 of Table 3, C-Wise would be willing to discuss how installation of additional monitoring and/or testing could be employed as a means of converting the proposed prescriptive measures to be outcomes-based.

The intent of the Licence Holders comment is unclear, as this item is the listing of the existing groundwater bores within the Premises.

Comments received on 1 June 2017: Regarding Item 13 of Table 3, C-Wise operates its dams under a Dam Management Plan, a copy of which has been provided to DER. This plan is under constant review and improvement and C-Wise considers this a much better tool to use to minimize potential for odour than the proposed prescriptive controls associated with oxygen measurement.


Propose to replace DWER’s proposed requirement that the dam aeration system must be “fit for the purpose of maintaining a Dissolved Oxygen level of >1mg/L within Pond 21 and 22” with the requirement that it must be “fit to maintaining Redox Potential values within Pond 21 and 22 that will not produce

DWER has not referred to management plans within the Licence conditions because the review and update to the plans can later cause uncertainty as to the content which was considered by DWER at the time of the assessment. Instead key controls are incorporated into Licence conditions, as has been the case with maintaining the aeration of Ponds 21 and 22. The Licence Holder’s proposed wording would not be enforceable as the Redox Potential values that will not produce odour are not specified. Following further consideration, the Dissolved Oxygen action criterion for pond monitoring has been removed from the conditions.

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odour when managed within C-Wise Dam Management Plan.

The requirement that the aerator must be fit for the purpose of maintaining a Dissolved Oxygen level of greater than 1mg/L has been removed from the Licence and replaced with the requirement that the aerators must be able to achieve the aeration across the entire surface of Ponds 21 and 22.


Item 14 of Table 3 is a good example of where an apparently innocuous prescriptive measure is open to interpretation. Use of technical terms in controls provide opportunity for legal interpretation. For example, the use of the term “solid material” is not defined. Does it refer to all “non-dissolvable” material, or just the “settleable” material (one measure of water quality is through the use of Total Suspended Solids for example)? Technical terms such as this would logically require a definition, i.e. is “non-dissolved” material greater than 0.45μm etc., or for “settleable material”, is the test a standard test or would a special test be required? If standard tests are required these would need to be specified, and so it carries on, with each measure requiring more and more detail. C-Wise does not wish to enter into such protracted and convoluted arrangements and it is for this reason that co-operative discussions between the DER and C-Wise are required and welcomed.

Comments received on 29 March 2018:

The wire mesh aperture of the screens (screening runoff from North-Eastern Hardstand, South-Eastern

It is agreed that the wording within the previous draft of ‘solid material’ is subjective. DWER has considered that to achieve more clarity it may be necessary to specify the key aspects of the infrastructure for the capture of solids, such as the screen size. This information was therefore requested from the Licence Holder. DWER has expanded on the justification for the specification of a maximum screen opening size within Section 8. A maximum screen opening size of 50mm by 50mm has been specified within the Specified Infrastructure and Equipment Controls section of the Licence. It is noted that a sediment trap is not proposed in addition to the screen for the runoff from the pre-wetting area to CM Farms Pond 2. To reduce the sediment load input to Pond 2, a sediment trap will also be required to be installed, though particular specifications for this infrastructure has not been included.

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Hardstand and Western Hardstand) is 50mm by 50mm and a wire thickness of 3mm.


Regarding Item 15 of Table 3, C-Wise would agree that flow measurement is required for piggery wastewater, should this wastewater be used in the future. It should be noted that currently piggery wastewater is not used by C-Wise due to the inability to accommodate the runoff in the C-Wise dams – this water previously gravitated to the CM Farms’ dams until C-Wise was directed by the DER to build the drain to divert the water.

DWER notes the Licence Holder’s comment. No change has been made to the condition.


The final point regarding application of prescriptive measures is that this reduces our capacity to be innovative to achieve desired outcomes, the consequence being that proposed changes will require protracted engagement and correspondence with the DER. In effect, the risk is transferred from the operator to the regulator agency with all of the complications this presents.

It is agreed that outcome based regulatory controls are preferable where they may be effective.


Propose that a specific fall percentage for hardstands is not required, and that’s it’s sufficient to require the hardstands to be “graded with a fall to prevent pooling”.

Accepted. The fall percentage has been removed from the draft conditions.

Draft licence – Specified infrastructure and equipment controls:

Comments received 29 March 2018:

Request that 6 months is allowed for installation and operation of the screen/trap infrastructure and flowmeter (to monitor the volume of runoff

A timeframe of 4 months for installation is considered sufficient. Not change has been made to the condition.

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Condition 5 in second draft provided

discharged to CM Farms from the pre-wetting area) due to the potentially significant electrical and civil works that may be needed.

Draft licence – Specified infrastructure and equipment controls: Condition 14 in first draft Condition 6 in second draft


C-Wise would accept their obligation to inform the DER of changes to their capability to monitor parameters such as flow of piggery wastewater.

Comment received 29 March 2018:

Request that 4 months is allowed for the installation and operation of the flowmeter (to monitor the volume of piggery wastewater accepted) given that an appropriate flowmeter must be sourced, and electrical and civil infrastructure must be installed.

DWER accepts that a period of 2 months may be too short. The timeframe for installation has been amended to 4 months.

Draft licence – Specified Infrastructure and equipment controls: Condition 15 in first draft


C-Wise does not accept this condition for the reason that it does not accept aspects of Condition 13.

See response to condition 13 above.

Draft licence – Operational controls: Condition 16 in first draft


C-Wise notes that the DER has excluded greenwaste from the materials specified in Table 4 and therefore accepts this condition.

Further comments received 29 March 2018:

This condition has been proposed to largely be consistent with the C-Wise current licence conditions. In accordance with these conditions,

The Revised Licence does not include a definition for greenwaste. Text has been added to the description of greenwaste within the Waste Acceptance table in the Licence to indicate that greenwaste is shredded trees and plants as per the Licence Holders comments. The Delegated Officer has considered the Licence Holder’s proposal to store untreated timber and natural fibrous organics on bare earth, and agrees

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greenwaste (shredded trees or plants) is the only material able to be stored off a hardstand surface.

‘Greenwaste’ is defined as ‘waste that originates from flora and which does not contain or has not been treated or coated with preserving agents, biocides, fire retardants, paint, adhesives or binders’. Therefore, untreated timber (sawdust and various other wood fractions) and natural fibrous organics (straw, grain husks, and other crop waste), as listed in the new draft licence, would also be classified as ‘greenwaste’ under the current licence.

Untreated timber and natural fibrous organics are carbon risk and able to be stockpiled on bare earth in many agricultural or forestry related settings. These materials would have a similar or lower risk profile for producing leachate than that of greenwaste. Therefore, untreated timber and natural fibrous organics should also be able to be stored off a hardstand surface.

It is also proposed that low risk items 5, 6 and 7 (mushroom compost, animal manures and piggery bedding) are permitted to be stored on compacted limestone, asphalt or concrete. These materials are dry and there is no pre-wetting in this area and therefore no leachate production.

that during the dry months of the year the untreated timber and natural fibrous organics pose little leachate risk. The condition has been amended to allow the storage of these materials on bare earth during October to April. No change has been made to the storage requirements for mushroom compost, animal manures and piggery bedding as these wastes are considered to present a higher leachate risk.

Draft licence Operational controls condition 17 in first draft


C-Wise would agree that mixing of feedstocks and composting should only be carried out on concrete or asphalt.

DWER notes the Licence Holder’s comment. No change it made to the condition.

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Draft licence – Operational controls: Condition 18 in first draft


C-Wise cannot agree to this condition as it unfairly reduces the available dam volume. Historically C-Wise has had no overtopping events and as a consequence wishes to discuss the intent of this condition.

The required freeboard for all ponds within the draft Revised Licence has been changed to 300mm as this is consistent with the current operation of the ponds and is considered by the Delegated Officer to be sufficient.

General comments Draft licence – Operational Controls: Conditions 19 to 28 in first draft


C-Wise does not agree with Conditions 19 to 28. Many of the requirements are illogical or cannot be implemented practically because they are based on poor understanding of composting in general and the C-Wise process specifically. C-Wise cannot accept a framework of control that is excessively prescriptive, particularly when it is predicated on a lack of understanding of the C-Wise operations.

Our view is that a prescriptive ‘command and control’ style approach to licensing inherently requires a detailed appreciation and understanding of every aspect of the operations, measures and controls that are associated with a prescribed activity. This is simply not feasible. What is more appropriate is to provide an outcomes-based approach that requires environmental objectives to be achieved within the framework of a licence that allows proponents to progress with their operations in an appropriate and environmentally-sensitive manner.

An example of poor definition of the requirements is illustrated in the response to condition 19.


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Draft licence – Operational controls: Condition 19 in first draft Condition 12 in second draft

Comments received on 1 June 2017: C-Wise cannot accept this condition as there are three problems in the description; (i) the term “shredded greenwaste” is not an appropriate description of the material used to cover the mortalities – a better term would be “biocover”, (ii) the term “windrow” implies an unaerated stockpile which is contrary to intent of the C-Wise aerated system, and (iii) “on the day of acceptance” is not possible, because the mortalities are received late in the day and there is not opportunity to include them in the process within that day – a more accurate description would be “within 24 hours”. This discussion highlights the problems identified in the latter section of condition 13 above, i.e. the more prescriptive the requirement, the greater the detail that is required in definitions around the requirement.


Propose that the cover for mortalities should be referred to as ‘appropriate material’ rather than shredded greenwaste.


Propose the term ‘composting pile’ to be used instead of ‘windrow’ as a windrow generally refers to a long coned row that can is aerated using a compost turner. Composting pile by comparison can refer to any types of composting or aeration method including a pile aerated by loader flips, windrow aerated by compost turner or an aerated static pile

This condition has been amended to specify that mortalities shall be covered to achieve odour reduction, and shall be incorporated into a windrow within 24 hours of acceptance at the Premises. The term windrow is used to refer to a line of heaped composting material, whether positioned over the mobile aerated flooring or not. The draft Revised Licence also requires that all composting windrows are turned or positioned over a MAF system, therefore it isn’t implied that the term windrow applies only to an unaerated stockpile. No change has been made to the use of the term ‘windrow’.

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(which is currently aerated using C-Wise’ aerated technology).

Draft licence – Operational controls – Condition 19 in first draft Condition 13 in second draft

Comments received on 29 March 2018:

Propose that the requirement that liquid wastes be mixed with solid feedstocks on the day of receival of the liquid waste, is changed to allow appropriate liquid feedstocks to be offloaded directly to, and stored in, dedicated HDPE lined holding ponds. C-Wise mixes liquid and solid feedstocks in a carefully constructed process designed to:

- Wet the solid feedstocks, and

- Trap or filter a significant proportion of the entrained solids.

However not all liquid wastes contain settleable or filterable solids that require treatment through a ‘biofilter’. In addition, from an odour perspective it is critical that some liquid waste types are maintained separately.

An example is liquid ammonium nitrate and alkaline solutions, to prevent evolution of ammonia gas. If the wording in the draft licence was to remain in the final version of the licence, there would be a significantly enhanced risk of odour due to potential mixing of incompatible liquid wastes at the receival point and in downstream dams. In addition, such a compulsory requirement would add significant costs to the business through unnecessary processing with no beneficial impact on odour. Proposed alternative wording for this condition is given below:

“The Licence Holder must mix each load of liquid feedstock with solid feedstocks on the day of

DWER acknowledges that liquid wastes may be discharged directly into ponds 22, 23, 24 and 25 rather than mixed with solid feedstocks on acceptance. As the other ponds (21, 31 and 32) are in a train sequence, these ponds should not receive direct discharges of liquid waste. The condition has been amended to allow liquid wastes to be discharged directly into ponds 22 to 25.

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acceptance of the load of liquid waste feedstock at the Premises, except where liquids are assessed as appropriate to be offloaded directly to a storage area or vessel (e.g. liquid feedstocks with a low odour potential, low level of solids and/or that contain predominantly inorganic composts)”.

Draft licence – Operational controls: Conditions 22 to 25 in first draft Conditions 15 to 18 in second draft


C-Wise’ understanding is that the intent of these conditions is to manage odour, however they are operationally very prescriptive and, as written, not reflective of the odour risks of some of the processes involved or feasible for a commercial composting operation.

Currently carbon sources, including greenwaste, untreated timber and natural fibrous organics, are pre-wet with water from either CM Farms ponds 5 or 6, or C-Wise dams 31 or 32. This is a static pile wetting process in which the carbon materials are flooded with water to start to soften the material and increase its bound moisture prior to adding nitrogen rich materials and starting the composting process. This is done is a static unaerated pile, usually for a week or two. Given the nature of the materials and water used – being materials and waters of the lowest odour risk, this process should be exempt from Condition 18 (promoting an aerobic state).

Condition 18 should only be applicable once nitrogen sources have been added to the pre-wet carbon and the composting process has begun properly. This is when biological decomposition is ‘catalysed’, when oxygen requirements peak, and

DWER was previously unaware that initial wetting of feedstocks was undertaken with wastewater from Ponds 31 and 32. Section 3.2 (Operational Aspects) has been updated with this information. Condition 15 has been amended to exclude (from the requirement to create a new composting windrow on the day of mixing liquid and solid feedstocks) initial wetting with liquid from Ponds 31 and 32 in addition to CM Farms wastewater. Condition 18 has also been amended to capture the activity of pre-wetting with wastewater from Ponds 31 and 32. The Delegated Officer considers that the requirement to maintain an aerobic state by turning should apply to feedstocks undergoing initial wetting with wastewater from Ponds 31, 32 and CM Farms ponds 5 and 6, as these wastewaters may act as a nitrogen source. Additional wording has been added to condition 18 to refer to MAF or another aeration system.

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when odour could be generated if aerobic conditions are not maintained.

Condition 18 should also apply when waters from ponds other than those listed earlier in this section, and other solid feedstock materials, are used, because they contain an increased nitrogen load and can initiate the composting process. In conjunction with this, waters from other ponds should be treated like liquid waste and mixed with solids on the day of acceptance.

The reference to MAF should be removed from conditions 18 as this is a specific piece of aeration equipment, and in the future, alternative aeration technology may be used.

Condition 15: The Licence Holder must ensure that all mixed solid and liquid feedstocks are used to create a new composting pile on the day of mixing.

Condition 16: Condition 15 does not apply to carbon materials (i.e. greenwaste, untreated timber waste and natural fibrous organics) which are being wetted with waters from CM Farms ponds 5 or 6, bore water, or water from C-Wise dams not receiving runoff of liquid organic waste.

Condition 17: The Licence Holder must use large droplet sprinklers where sprinklers are used for the application of waters (excluding bore water) to solid feedstocks or composting piles.

Condition 18: The Licence Holder shall promote an aerobic state within all composting piles.

Draft licence – Operational controls:

Comments received on 1 June 2017: DWER has re-considered the requirement to undertake C:N ratio process monitoring. This

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Condition 26 in first draft

C-Wise does not understand the DER’s reason for specifying the carbon to nitrogen ratio. The objective of composting is to reduce the carbon ratio while converting inorganic nitrogen to organically bound nitrogen as the compost becomes more mature with time. Therefore, in the latter stages of composting the carbon value is reduced in relation to the nitrogen value. Therefore, this condition is contrary to the principles of composting. If the reason for this condition is potential for odour, has the DER noted that the C-Wise process is aerobic, with minimal potential for malodours and could the DER indicate the source of this information that a carbon to nitrogen ratio of more than 25:1 be maintained throughout the composting process? It should be noted that the C-Wise process has an operational procedure that includes many Critical Control Points to which its operations strictly adhere. One of these CCPs is the requirement to meet a carbon to nitrogen ratio of at least [redacted] at the start of the composting process.

The approach proposed here appears to suggest a lack of understanding of the general principles of composting and more specifically of the C-Wise process. As we have noted previously, a prescriptive approach inherently requires such understanding.


Propose that this condition is removed, as it’s not feasible for the process with the highest odour risk in the business, and that ensuring aeration of actively composting piles is a much better way of managing odour.

requirement has been removed from the Licence, on the basis that the Licensee has been and will continue to monitor their composting process and that the records of this monitoring may be requested by DWER if required.

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This condition is proposed for DWER to be able to review records and correlate with odour reports and for the most part reflect C-Wise standard practice.

Currently C:N ratio is monitored at the ‘start’ and ‘finish’ of every batch of compost that is produced. The ‘start’ sample is taken once all ingredients have been adequately blended to produce a relatively homogenous mix, and therefore enable a representative sample to be taken. Because of this, the process with the highest odour risk is not analysed until 3 weeks into production due to the inclusion of chicken mortalities and the impossibility of obtaining a representative sample.

In the first draft of this licence a parameter was set around the C:N ratio, being a minimum of 25:1, as a means of controlling odour production. A higher C:N ratio however, is not necessarily a good indicator of low odour potential. The C:N ratio decreases throughout the composting process in correlation with odour potential and materials with a higher C:N ratio may become odorous if not provided with sufficient aeration.

Anaerobic processes are also much more likely to produce pervasive volatile compounds that will be noticed off-site than those potentially produced by lower C:N ratio material (which may emit ammonia – a gas that is easily dispersed and does not usually carry over long distances). Hence the reason that C-Wise requests that this condition is removed.

Draft licence – Groundwater

Comments received on 1 June 2017: The existing monitoring network, which consists of shallow bores that are arranged in close proximity to leachate ponds and Hardstands is designed to

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monitoring an actions: Conditions 29 to 31 in first draft

C-Wise refuses to acknowledge the DER assumption that it is responsible for the nutrient load in the groundwater and also refuses to accept that the controls the DER are proposing will have a significant effect on the situation. The DER does not appear to wish to concede the possibility that groundwater nutrient loads are a consequence of previous or recent historical irrigation of the area, a consequence of the activities of other operators, or influenced by natural concentrations. It is only when this is acknowledged that a development plan can be formulated to address the problem and improve the groundwater quality. C-Wise wishes to be part of this improvement plan and make use of their unique understanding of the site which is a consequence of their very early successful interventions to limit groundwater and nutrient flow to the Peel Harvey catchment.

detect recent contamination from current operational activity and infrastructure. It is considered that historical contamination is likely to have migrated downgradient from its original source which is likely to be away from the current operational site in a westerly or south westerly direction and is also likely to have seeped to greater depths in the superficial aquifer than is screened with the shallow bores. DWER acknowledges that there are potential sources of contamination within the other Nambeelup Farm premises. The key finding within the previous draft of the Revised Licence which stated that nutrient levels indicated seepage from C-Wise infrastructure has been amended to state that nutrient levels in multiple bores indicate that there is likely to be a contaminant source or sources nearby, which need to be identified. It is therefore necessary to confirm through testing that containment infrastructure on site is effective.

Draft licence – Pond monitoring and actions: Condition 32 in first draft


C-Wise wishes to discuss with DER the pond monitoring described in Table 7 to understand what outcome the DER is trying to achieve by the proposed use of the specified monitoring and its frequency. These parameters cannot be considered in isolation. For example, what combination of DO, pH, temperature and BOD would the DER consider appropriate for the dams? If the temperature were to

decrease by 5⁰C at a different time of the year, what

The Delegated Officer has considered the use of Oxidation Reduction Potential instead of Dissolved Oxygen as an indicator of potential odour generation from the ponds. As an alternative to the Dissolved Oxygen action criterion of 1mg/L, an Oxidation Reduction Potential action criterion of -25mV was considered as a level which may prevent the generation of hydrogen sulfide. However, following further consideration the Delegated Officer has determined that due to the

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values of DO, pH, and BOD would then be appropriate?

The DER appears to have little consideration for the operational variability of the composting process as a result of its proposed approach to regulation of this aspect of the operations as opposed to an outcomes-based focus which C-Wise would be happy to discuss.


Propose Reduction Oxidation Potential (Redox) be use in place of DO as a means of identifying conditions that could result in odour production. Measurement of DO at low concentrations of oxygen is a poor measure of the potential for odour production. By comparison, Redox has the ability to be far more discriminatory at low oxygen concentrations in its measurement of potential reductive conditions that can lead to odour, i.e. conditions leading to evolution of hydrogen sulphide and mercaptans.

The following three aspects should be considered. Firstly, maintenance of a DO concertation of 1mg/L in all of the C-Wise dams would not be economical. Assuming an oxygen utilisation rate in the dams of just 10% that in a wastewater treatment plant, this would amount to an input of 250 kgO/kWh, the power consumption would be 167kW. Assuming power costs of 25c/kWh, this amounts to an annual power bill of $365,000. There would be an

complexity of the potential reactions within the pond, neither parameter is entirely appropriate as a single indicator of the risk of odour emissions from the ponds. Therefore, this action criterion may not be an effective control. As an alternative, the aeration equipment in Pond 21 and Pond 22 will be required to achieve the aeration of the entire surface of the pond, so that an aerobic layer is maintained at the surface. The aeration will be required continuously. The aeration of the ponds is intended to ensure aerobic conditions are maintained within the surface of the ponds and can decompose odourous compounds (generated within deeper water or sludges) before they emit to the atmosphere. The requirement that the aerator must be fit for the purpose of maintaining a Dissolved Oxygen level of greater than 1mg/L has been removed from the Licence. The Dissolved Oxygen action criterion has been removed from the pond monitoring condition.

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infrastructure requirement of a number of air compressors powered by diesel generators and sub-surface aeration pipework and diffusion systems in each dam. These systems would be controlled by significant instrumentation and process control systems. This is provisionally estimated to cost in the region of a couple of million dollars, a totally impractical proposal.

Secondly, maintenance of a DO concentration of more than 1mg/L is not sufficient protection from some types of odour. As an example, if a dam had a high ammonium concentration, a DO of more than 1mg/L would not protect it from producing odour if the pH increased above a value that allowed the ammonium to volatilise as ammonia.

Thirdly, C-Wise has a weekly measurement procedure in which a number of parameters are monitored, including DO, temperature, Total Dissolved Solids, and Redox potential. A significant history (many years) of data has been built up with these measurements and a protocol based on Redox measurement has been developed as an early warning signal of odour. Actions, such as chemical oxygen dosing and operational procedures are specified based on the Redox value. This has provide to be a very good method of predicting potential odour evetns that would eventuate some days in the future, is no action was taken.

Draft licence – Pond monitoring and


C-Wise cannot see how such a requirement for notification can work practically.

This condition has been amended to remove the requirement for notification within five working days. Monitoring results which trigger and action will only

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actions: Condition 33 in first draft

need to be reported within the quarterly reports and the annual report.



C-Wise wishes to discuss the proposed test and understand the background to the DER decision to specify measurement of the sludge volume and the decision to specify a volume of 30% as the cut-off value. The C-Wise experience is that the dam sludge is not malodorous and is willing to demonstrate this to the DER. C-Wise would contend that irrespective of whether the sludge volume was 20 or 30%, it would still have a similar surface area for both cases. Does the DER then have evidence that it is the depth of sludge that causes odour?

DWER’s view is that the build-up of sludge within the ponds can pose the risk of encouraging anaerobic conditions to develop. These grounds for the inclusion of this requirement are included within the draft decision report. No change has been made to the condition.



Not acceptable to C-Wise because it refers to Condition 34 which specifies conditions of the licence that are unacceptable to C-Wise.

DWER interprets this comment as an objection to the monitoring requirements within condition 32, rather than an objection to the reporting required by condition 35. See the response to condition 32 above.

Draft licence – Specified actions: Condition 36 in first draft Condition 24 in second draft


C-Wise would agree with this approach if the electrical testing could be conducted safely. The procedure ASTM-D7007 2009 uses electrical current. The standard itself warns of its highly dangerous nature, as described in Section 1.7 of the procedure, “These procedures are potentially VERY DANGEROUS, and can result in personal injury or death.” The standing water seepage rate method would not work due to the inability to distinguish small leakage rates by observing change in water levels.

Response provided following comments provided on 28 August 2017: The draft Revised Licence conditions have been revised to only require seepage testing via the overnight water balance test at this stage. DWER will consider whether any further actions are required following the consideration of the seepage rate testing results. Response provided following comments received 29 March 2018:

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Further comments provided on 28 August 2017:

Accepted the proposed requirement to undertake seepage rate testing for all ponds.


Propose changes to the testing regime that can be used for calculation of seepage rate. Currently C-Wise is undertaking a step-wise process of emptying, cleaning and testing liner integrity (and repairing if required) the dams in a sequence that will not significantly compromise operation of the process. As at 29 March 2018, Dam 22 had been emptied of water, de-sludged, cleaned inspected, tested electrically for voids, repaired, re-tested electrically and re-commissioned. Damn 21 is currently being de-sludged and will also follow the same process. The plan is to have Dam 21 re-commissioned by the end of April 2018.

The sequence of dam cleaning will continue until the 2018 winter season commences. The program will resume when the weather permits.

Electrical testing was undertaken on Dam 22 to comply with ASTM D6747-2015 “Standard Guide for Selection of Techniques for Electrical Detection of Potential Leak Paths in Geomembranes” and ASTM D7703-2016 “Standard Practice for Leak Location on Exposed Geomembranes using the Water Lance System”.

It is C-Wise’ objective to electrically test all dams using this method. This will allow the DWER to

DWER has considered the Licensee’s preference to have the option to undertake either form of testing. The condition has been amended to allow this. ASTM D6747 and ASTM D7703 and a four to seven day water balance test are also considered acceptable methods and have been included within the condition. A 12 month period will be specified for the completion of the testing.

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calculate the dam seepage rate by using the hydraulic conductivity of the HDPE liner material in a condition as specified by the liner manufacturer.

For dams that are not electrically tested prior to the seasonal change, a hydrostatic leak test will be conducted before the expiry of a 12 month period from the issue of the licence. C-Wise proposed that for the hydrostatic leak test, either the overnight standing water test, or the 4-7 day standing water test be permitted. Our experience is that contractors do not have the equipment to undertake the overnight standing water test but are set-up to carry out the 4-7 day test.

Specifically, it is proposed that:

- Where conditions allow, an electrical leak detection test will be used to satisfy the pond seepage rate resting requirement, and where conditions do not allow, a hydrostatic leak test will be used. This will be either a procedure following the Ham and Baum (2009), or the equivalent ASTM/Australian Standard method.

- The completion date be extended to 12 months because the test work for the entire set of C-Wise dams cannot be completed within 2 months, even allowing for the fact that testing has already been completed for one dam and is progressing on another.

Draft licence – Specified actions:

Comments received on 1 June 2017: DWER interprets this comment as an objection to the testing requirements within condition 36, rather than an objection to the reporting required by

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Not acceptable to C-Wise because it refers to Condition 36 which specifies conditions of the licence that are unacceptable to C-Wise.

condition 37. See the response to condition 36 above.

Draft licence – Specified actions: Conditions 38 to 42 in first draft


As a general comment covering Conditions 38 to 42; taking note of the Key finding on page 72, that “… a shared approach … for all premises …”, and “Synchronising monitoring bore sampling across all three sites is necessary …”, it would seem logical that the tests being requested are conducted in conjunction with the other businesses on site. This would provide background data at the date of testing. However, given the history of the site and the length of operation of some businesses on site, and given that it is a registered contaminated site, if adverse results are found, such testing proves no liability to any party.

No change has been made to the draft Revised Licence conditions which will allow each licence holder 3 months to undertake the monitoring. However, it is agreed that it would be beneficial for the licence holders to arrange for the sampling across all bores to be undertaken at the same time.

Draft licence – Specified actions: Condition 38 in first draft


C-Wise wishes to discuss the proposed test and understand the background to the DER decision to measure these parameters.

Further information received 28 August 2017 and 6 June 2018:

Results provided for a groundwater monitoring event conducted during July 2017, October 2017 and January 2018 for all monitoring bores for total petroleum hydrocarbons and a suite of metals.

The requirement for a once-off groundwater analysis for total petroleum hydrocarbons and certain metals has been removed from the Licence as the Licensee has now completed this monitoring.


Comments received on 1 June 2017: DWER interprets this comment as an objection to the monitoring requirements within condition 38,

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May not be acceptable to C-Wise because it refers to Condition 38 which specifies conditions of the licence that may be unacceptable to C-Wise.

rather than an objection to the reporting required by condition 39. See the response to condition 38 above.



C-Wise does not understand how the groundwater level beneath all the dams can be determined and wishes to discuss this with the DER.

This condition has been amended to elaborate that separation distance shall be estimated based on the standing water level monitoring results during the previous 5 annual periods.



C-Wise wishes to discuss the proposed test and understand the background to the DER decision to measure these parameters.

The grounds for requiring the groundwater monitoring for PFAS is included within the draft decision report.



May not be acceptable to C-Wise because it refers to Condition 41 which specifies conditions of the licence that may be unacceptable to C-Wise.

DWER interprets this comment as an objection to the testing requirements within condition 41, rather than an objection to the reporting required by condition 42. See the response to condition 41 above.

Draft licence – Specified actions: Conditions 29 and 31 in second draft Corresponding definition for ‘Liquid Waste Streams’.


Proposed definition of ‘Liquid Waste Stream’ is amended as follows, because different sources may produce nearly identical wastes and separate characterisation assessment is unnecessary:

Liquid Waste Stream refers to liquid wastes of a particular category that are produced by similar processes, have similar characteristics and the same contamination risk profile.

A review of the costs associated with testing of the liquid wasre streams for the parameters listed

The existing definition within the Licence has been as follows to ensure where wastes are produced by the same process and have the same contamination risk profile that multiple characterisations do not need to occur.

Liquid Waste Stream means a liquid waste type from a particular source or multiple sources where those liquid wastes are produced by the same processes, have the same characteristics and the same contamination risk profile.

The definition suggested by the Licence Holder is too vague and not considered enforceable to incorporate within the licence.

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indicates that such a testing regime would be unreasonable for two reasons:

- It does not make sense for some streams which never contain these chemcicals, and

- The costs would be financially debilitating at greater than $500 per test.

Regarding this requirement, C-Wise would like to discuss what specifically is required by DWER. This would appear to be an information gathering exercise about the origin and composition of liquid wastes, potentially an open-ended exercise. It is not a licence measure to ensure compliance with environmental standards. In addition, there is no additional information in the Decision Report that provides guidance on the scope of this information gathering exercise. C-Wise would be willing to work with DWER to develop a knowledge base of information. However, because the scope is not apparent, the anticipated manpower and associated costs cannot be determined. C-Wise requests that this condition be withdrawn and that a project be developed outside of the Licence to assist DWER in its endeavours in the area.

To assist, C-Wise has already engaged a highly experienced waste industry chemical consultant to undertake initial review of the contamination risks associated with each controlled waste category and subsequently the analyses that would be required to manage these risks. The outcome of that review is documented in the table attached (not duplicated here). What we identified is potentially a simpler and

The requirement for and purpose of this condition was discussed with the Licence Holder at a meeting held on 7 March 2018 and is summarised again below: There are a large number of waste streams currently accepted at the premises and added to the composting process. DWER has concerns that a number of these waste streams may contain contaminants which may not benefit the composting process or be effectively treated by the composting process and are in effect being accepted for waste disposal or dilution in the process. Examples include paints, industrial waste treatment plant residues and resins, glues and adhesives. DWER has concerns that accepting such wastes which may contain contaminants could result in composts which may represent a risk to end users and the environment. DWER does not consider that dilution of contaminants in a composting operation is an appropriate method of managing/treating waste and that wastes should not be accepted solely for this purpose. This condition has therefore been imposed to provide an opportunity for the Licence Holder to provide a one-off characterisation of the waste streams they accept and demonstrate how they contribute to the composting process and how any contaminants contained within the wastes are effectively treated by the composting process.

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more appropriate testing regime for each category and what would be a more commercially sustainable level of analysis per category.

DWER has allowed these wastes to continue to be accepted while this characterisation is on-going In addition, DWER needs to fully understand the characterization of waste streams accepted, including potential contaminants they may contain to consider the risks such contaminants may represent to groundwater and to determine whether any further parameters need to be added to the groundwater monitoring program. DWER acknowledges that the characterisation will have a cost associated with it however the need for this information is considered to be necessary to fully assess/validate the risk the activities on site represent to the environment and to assess the risks to compost end users and land. Whilst cost is an issue that DWER will have regard to when setting controls, it is not the key consideration in determining controls required in a licence granted under Part V of the EP Act. The range of parameters that are required to be tested has been informed by work undertaken on another premises. The minimum analytical suite has been amended to customise the analytical suite for each controlled waste type, taking into consideration the Licence Holders commentsregarding cost and the Guideline Assessment and Management of Contaminated Sites (DER 2014).


Comments received 29 March 2018: The requirement to compare the compost product specification to a coliphage standard has been reconsidered and removed from the Licence.

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Condition 30 in second draft

There are two main requirements in this condition, (i) that C-Wise’ composted products’ in-house specifications be compared to parameters from AS4454:2012 and the WA Biosolids Guidelines 2012 (including an additional requirement to meet a coliphage standard), and (ii) amongst other requirements, that C-Wise justifies that it’s product specification is suitable for the product’s intended use.

Regarding the first requirement, C-Wise currently has no data for analysis of coliphages and has found that coliphage analysis is not something that is routinely conducted on composts.

C-Wise has enquired with both of their key laboratories and neither undertake analysis for coliphages, though they are enquiring with their suppliers to see if they can subcontract this work. A cost of this analysis is not yet known and as such it is not known if it is feasible for C-Wise to conduct this analysis on their composted products. The lack of availability of this test would indicate that it is not a widely acknowledged risk for composted products and that salmonella and E.coli or faecal coliforms are sufficient human pathogen indicators for pasteurisation.

From our initial research on the use of this parameter it would appear that there is considerable national and international scepticism as to its merits

The purpose of this condition was discussed with the Licence Holder during a meeting on 7 March 2018 and is summarised below: Through this condition DWER is trying to understand the specification of composts produced by the Licence Holder and how they compare to parameters for materials with unrestricted/related uses (as in the Australian Standard AS4454 and the WA Bioslids Guidelines). The reason for this is two-fold:

1. DWER need to ensure that the product specifications are sufficiently considering contaminants that may be present in the waste used to produce the compost and whether they have been effectively treated by the composting process. This is important to ensure product specifications have been appropriately set so that end products are suitable for their intended end use and do not --through the presence of contaminants - represent an unacceptable risk to end users or the environment; and

2. To determine whether product specifications are sufficiently robust to determine that wastes which have been treated to the required standard (and tested to verify this) have been transformed into marketable products. Where compost represents a

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as a measure of the presence or not of human pathogens. C-Wise is awaiting expert input and will provide this to DWER as it becomes available.

Regarding the second requirement, C-Wise would like to discuss what specifically is required by DWER. This would appear to be an information gathering exercise about the intended use of compost products by end-users, potentially an open-ended exercise. It is not a licence measure to ensure compliance with environmental standards. In addition, there is no additional information in the Decision Report that provides guidance on the scope of this information gathering exercise. C-Wise would be willing to work with DWER to develop a knowledge base of information. However, because the scope is not apparent, the anticipated manpower and associated costs cannot be determined. C-Wise requests that this condition be withdrawn and that a project be developed to assist DWER in its endeavours in this area.

product rather than a waste, the licensing provisions in Part V of the EP Act will no longer apply.

DWER does not consider that the comparison of product specifications (which the Licensee has advised are available) against the criteria specified in the licence and the provision of a justification for any deviations based on end use of the product, is a significant undertaking or open ended requirement. The condition is considered by DWER to be clear and necessary and has therefore been retained in the licence.

Draft licence – Schedule 1 Maps Hardstand Materials Map


A portion of the area in yellow marked as limestone hardstand has been converted to asphalt since this map was produced. A current map is provided.

In future, DWER should be contacted prior to works occurring in case a Works Approval is required. The Hardstand Materials Map has been updated to reflect the information provided by the Licence Holder.

Draft licence – Schedule 3 Reporting


Report on controlled waste characterisation and report on suitability of composted products for proposed end use are missing from this table.

These reports have been added to the summary table.

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Summary of reporting requirements

Draft licence – Schedule 3 Reporting Annual reporting requirements


Reporting of groundwater monitoring annual includes the requirement to compare data to ‘the ANZECC guidelines stock water values’. However, the ANZECC ‘Livestock drinking water quality’ parameters are variable. Please clarify exactly what parameters for which analyte we need to compare our monitoring bore data to.

The requirement to compare groundwater quality monitoring data against the ANZECC guidelines for livestock drinking water quality has been updated to state that the Licensee should use the recommended water quality trigger levels where available, otherwise use the lowest values which may be hazardous or cause an impact for any livestock.

Proposed construction of dam 33

Further information received on 28 August 2017:

Water balance information is provided to explain the need for additional dam storage capacity since the re-direction of the Western Hardstand runoff into the C-Wise ponds, with reference to the amendment application submitted in March 2017 for the construction of a new dam.

The proposed construction of dam 33 has been addressed within this Decision Report.

Category 67A and Category 61 production or design capacities


Propose to retain the premises production or design capacities for category 67A and 61 which are specified on the Existing Licence (90,000 tonnes per annual period and 60,000 tonnes per annual period respectively).

Accepted. The category 67A and category 61 product and design capacities of the have been amended for consistency with the Existing Licence.

Additional groundwater monitoring results provided


A summary of the results of groundwater monitoring undertaken during July 2017 for the following parameters are provided:

Hydrocarbons

DWER’s proposed once-off monitoring suite of metals has been removed from the Licence as the Licence Holder has now undertaken the monitoring and provided the corresponding laboratory reports.

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Arsenic

Cadmium

Chromium

Copper

Mercury

Nickel

Lead

Zinc

Selenium

Further information provided 29 March 2018:

The laboratory reports for the results of the groundwater analysis for the above parameters during July 2017, October 2017 and January 2018 were provided.

Further information provided on 6 June 2018:

The laboratory reports for the results of groundwater analysis during April 2018 for the following parameters are provided:

Iron

Manganese

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Appendix 3: Liquid waste review

As part of the licence review, DWER has undertaken a review of the liquid waste types accepted and used within the Premises.

The Existing Licence limits the types of third party liquid wastes (set out as Controlled Wastes) which may be accepted by the Licence Holder to the Controlled Waste Types listed in Table 1.

DWER has determined that the putrescible and organic waste types shaded in grey within Table 1, and the piggery wastewater and sludge received from CM Farms, contribute to the biological process of making compost, and are unlikely to contain contaminants that cannot be treated through the composting process.

DWER considers that the information provided by the Licence Holder is not sufficient to appropriately characterise the remaining waste types in regards to the contaminants which they may contain and the concentration of these contaminants.

Contaminants within the waste streams may remain untreated within the composting process (i.e. not broken down or converted) and may therefore pose an elevated risk to human health and the environment through compost product use. The risk assessments undertaken within this Review are presented within Section 7.

Table 1: Controlled wastes which may be accepted under the Existing Licence.

Category Group Name

Waste Code

Description

Putrescible and Organic Wastes

K100 Animal effluent and residues

K190 Wool scouring wastes

K140 Tannery wastes not containing chromium

K210 Septage wastes

K110 Waste from grease traps

K200 Food and beverage processing wastes

K130 Sewage waste from the reticulated sewage system

Soils and Sludge

N150 Fly ash excluding fly ash generated from Australian coal fired power stations

N205 Industrial waste treatment plant residues

Paints, Resins, Inks and Organic

Sludge

F110 Aqueous based waste from the production, formulation and use of resins, latex, plasticisers, glues and adhesives

F130 Solvent based water from the production, formulation and use of resins, latex, plasticisers, glues and adhesives

F100 Aqueous based waste from the production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish

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Oils

J130 Oil interceptor waste

J120 Waste oil and water mixtures or emulsions and hydrocarbon and water mixtures or emulsions

J180 Oil sludge

Organic Solvents

G110 Non halogenated organic solvents

G160 Waste from production, use and formulation of organic solvents not otherwise specified

Organic Chemicals M130 Non halogenated organic chemicals

M250 Surfactants and detergents

Acids B100 Acidic solutions

Alkalis C100 Basic solutions

Inorganic Chemicals

D300 Non Toxic Salts

D360 Phosphorous

T120 Waste from production or formulation of photographic chemicals or processing materials

D330 Inorganic sulphides

Industrial Wash Water

L150 Industrial waste water contaminated with a controlled waste

L100 Car and truck wash waters

N/A Stormwater

N/A Pond water

N140 Fire debris and wash water

Key findings

The Delegated Officer has reviewed the information regarding the liquid waste review and has found:

1. For the majority of the liquid waste types currently accepted at the Premises, DWER has insufficient information for the characterisation of these waste types, such as the contaminants which they may contain and the concentrations of these contaminants.

2. DWER has insufficient information to determine whether potential contaminants within the majority of the liquid waste streams are treated through the composting process, or remain untreated within the compost product.

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Appendix 4: Water balance

Water balance calculations have been undertaken by DWER to determine the storage capacity required to contain the estimated inputs to the ponds in the current operating scenario.

The current operating scenario is for the current level of production (60,000 tonnes of compost) and liquid waste acceptance (52,000 tonnes of controlled liquid waste and approximately 4,000m3 of sludge and 8,000 to 10,000 m3 of treated wastewater from CM Farms), with all of the runoff from the Western, North Eastern and South Eastern Hardstands being directed to the ponds within the C-Wise Premises.

Water balance calculations

Table 1 displays the calculations undertaken by DWER for the current operating scenario. Derived from these calculations yearly inputs and outputs from ponds have been estimated and presented in Figure 1.

Figure 1: Yearly inputs and outputs from C-Wise ponds based on water balance calculations in Table 1

Figure 2 shows that the cumulative storage requirements in this operating scenario may continue to increase each year due to the imbalance between the pond inputs and outputs.

30266

47584

4000

28891

53144

37216

0

20000

40000

60000

80000

100000

120000

Vo

lum

e (

m3

or

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ne

s)

Yearly inputs and outputs from ponds

Pond water use in composting

Evaporation from ponds

Liquid waste (runoff from organics bund +direct discharge to ponds 23 and 24)

Runoff from application of piggery waterand bore water in composting

Runoff from rainfall on eastern andwestern hardstands

Rainfall directly into ponds

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Figure 2: Pond storage required based on water balance calculations in Table 1

Key findings

The Delegated Officer has reviewed the information regarding the water balance calculations and has found:

1. It is estimated that the ponds at the Premises do not have sufficient volume to accommodate the storage requirements of the current operating scenario, in which the runoff from all hardstands within the C-Wise Premises is directed to the C-Wise pond; however years of low rainfall would allow for additional capacity.

0.0

10000.0

20000.0

30000.0

40000.0

50000.0

60000.0

70000.0

80000.0

Vo

lum

e (

m3

)Ponds storage (2 year period)

Storage required(cumulative)

Current storage capacity

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Table 1: Water balance calculations for a one year period

Parameter Symbol Formula Units Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Total for year

Days in month D days 31 28 31 30 31 30 31 31 30 31 30 31

Precipitation (Hopelands BOM figures)1 P mm/month 15.1 9.6 18.6 46.7 91.0 123.8 133.5 122.7 79.3 35.4 28.3 12.8 716.7 mm

Evaporation (Medina DAFWA figures)2 E mm/month 254.8 209.0 189.1 116.6 80.8 57.8 57.8 81.6 113.7 165.0 210.8 246.3 1783.2 mm

Pan factor F 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75 0.75

Inputs

Rainfall directly into ponds P P+((P*(Pca-Pwa))/Pwa) mm/month 16.1 10.2 19.8 49.7 96.7 131.5 141.8 130.3 84.2 37.6 30.0 13.6 30266.2 m3

Runoff from application of piggery water and bore water in composting W (Q*D)/Pwa mm/month 9 8 9 8 9 8 9 9 8 9 8 9 4000.0 m3

Runoff from rainfall on Eastern and Western Hardstands RO (P*(He+Hw))/Pwa mm/month 25 16 31 78 152 207 223 205 132 59 47 21 47583.9 m3

Liquid waste (runoff from organics bund + direct discharge to ponds 23 and 24) Lw ((A+B)*D)/Pwa mm/month 62 56 62 60 62 60 62 62 60 62 60 62 28891.0 m3

Total input

TI (P+W+RO+Lw) mm/month 112 90 121 196 319 406 435 406 285 167 145 105 110741.1 m3

- (TI*Pwa)/1000 m3/month 4437 3567 4815 7779 12679 16146 17291 16116 11312 6641 5773 4187

Outputs

Evaporation from ponds Ev E*F mm/month 191 157 142 87 61 43 43 61 85 124 158 185 53144.1 m3

Pond water use in composting Re (R*D)/Pwa mm/month 80 72 80 77 80 77 80 80 77 80 77 80 37216.0 m3

Total output

TO Ev+Re mm/month 271 229 221 164 140 120 123 141 162 203 235 264 90360.1 m3

- (TO*Pwa)/1000 m3/month 10754.2 9082.9 8797.7 6534.8 5567.5 4781.6 4882.8 5591.5 6448.4 8077.1 9341.1 10500.4

Net input NI TI-TO mm/month -159 -139 -100 31 179 286 312 265 122 -36 -90 -159

Storage required (cumulative)

S S of previous month + NI of current month mm/month 0 0 0 31 210 496 809 1,073 1,196 1,160 1,070 911

- (S*Pwa)/1000 m3 0.0 0.0 0.0 1243.7 8355.3 19719.9 32127.7 42652.1 47516.1 46079.7 42511.6 36197.7

1 Data sourced from http://www.bom.gov.au/jsp/ncc/cdio/weatherData

2 Data sourced from https://www.agric.wa.gov.au/weather-stations

Table 3: Additional parameters used within water balance calculations

Parameter Symbol Formula Units Runoff from application of piggery water and bore water (estimated by DWER as 10% of approximate volume applied) Q (4000/365)*1000 L/Day 10958.9

Liquid waste runoff from organics bund to ponds 21 and 223 A (20465/365)*1000 L/Day 56068.5

Liquid waste discharged directly to ponds 23 and 243 B (8426/365)*1000 L/Day 23084.9

Water drawn from ponds 23, 24 and 32 for compost3 R (37216/365)*1000 L/Day 101961.6

Western Hardstand area3 Hw - m2 27400.0

North Eastern and South Eastern Hardstand area3 He - m2 38990.0

Total pond water surface area for evaporation3 Pwa - m2 39737.0

Total pond area for rainfall catchment3 Pca - m2 42228

3 Sourced from information provided by Licence Holder (WA Composts Pty Ltd 2017b)

http://www.bom.gov.au/jsp/ncc/cdio/weatherData

https://www.agric.wa.gov.au/weather-stations

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Appendix 5: Groundwater monitoring

1. Monitoring programs

Groundwater monitoring has been undertaken at each of the three premises (C-Wise, CM Farms and Mushroom Exchange) according to their licence conditions. Available data spans the timeframe from 2010 to 2017. Sampling intervals have been variable with CM Farms and C-Wise monitoring biannually and Mushroom Exchange in quarterly intervals. Interpreting groundwater data in the context of the entire site encompassing all three bore networks is made more difficult by unsynchronised sampling events.

Key findings

The Delegated Officer has reviewed the groundwater monitoring programs and has found that:

1. A shared approach and consistent methodology for all premises will facilitate better understanding of contamination events and the effectiveness of controls.

2. Synchronising monitoring bore sampling across all three sites is necessary to allow more comprehensive and meaningful data interpretation.

2. Monitoring analytes

The monitored analytes are largely consistent for all three operations reflecting that nutrients are the main contaminants likely to enter groundwater from storage ponds and processing areas. Monitoring analytes include:

Total nitrogen (C-Wise, CM Farms) / total inorganic nitrogen (Mushroom Exchange)

Ammonia nitrogen

Nitrate nitrogen

Nitrite nitrogen

Total phosphorus

pH

Total dissolved solids

Nutrient rich seepage changes the chemical environment within the soil leading to the mobilisation of metals and metalloids from the soil into the groundwater. Measuring this secondary contamination needs to be considered as part of the standard monitoring analyte suite, particularly with regards to potentially toxic elements such as mercury, zinc and arsenic that can have impacts on human health.

While CM Farms and Mushroom Exchange potential discharges conform with the selected suit of analytes except for metals, C-Wise is receiving a range of controlled liquid wastes such as waste oil and industrial wash water that can contain a variety of other contaminants not captured by the current monitoring regime. There is a risk that controlled liquid wastes such as industrial wash

waters have introduced Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) which are known

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to be persistent, bioaccumulative and toxic. It is therefore required that testing for these substances is included in the next groundwater monitoring event to determine whether PFAS is present in the groundwater.

Key findings

The Delegated Officer has determined that:

1. Mercury, zinc and arsenic should be included in the monitoring suite of analytes to ensure that the potential risk to human health and the environment from this type of contamination can be assessed.

2. The selected suite of analytes with the addition of selected metals is considered appropriate for the characterisation and detection of groundwater contamination caused by nutrient rich leachates derived from organic materials.

3. The current monitoring regime is not sufficient to detect contamination from the range of controlled liquid wastes currently received by C-Wise.

4. Testing for PFAS should be included in the next groundwater monitoring.

3. Monitoring bore network spatial configuration

The locations of groundwater bores in relation to operational infrastructure such as ponds and Hardstands are shown in Figure 1. It is expected that contamination levels detected in groundwater bores are highest where the bore is closest to the source of the contamination and that attenuation occurs with greater distance from the source.

Small scale groundwater contours at the Nambeelup Farm area have been documented by Geo and Hydro (2010)2.

The contours indicate that the dominant groundwater flow in this area is in a westerly to south-westerly direction. Bores located down hydraulic gradient from contamination sources are therefore expected to show higher levels of contaminants than those located up hydraulic gradient.

C-Wise

C-Wise bores (CW01-04A) ‘frame’ the operational pond area by being located near corners of a rectangle drawn around the ponds. An additional bore (CW05A) is placed at the north-western corner of the Hardstand area of the composting operation. Bores are located close to potential sources of contamination so that monitoring can seek to detect any seepage and therefore provide information on the likely effectiveness of pond lining and leachate management systems.

Based on the proximity to the C-Wise storage ponds and the dominant groundwater flow, bores CW01 and CW05A would be expected to show higher levels of contaminants if leakage from the ponds occurred. Although located up hydraulic gradient, the close proximity of bore CW02 to C-Wise and CM Farm ponds makes it possible that impacts from either ponds’ leakages will be detected in this bore. Bore CW05A also has the potential to be impacted by potential seepage from multiple sources including the storage ponds of C-Wise, CM Farms and leachate seepage

2 Geo and Hydro Environmental Management Pty Ltd 2010: Watertable contours across Custom Compost Lot 230 Nambellup Rd Nambellup, Figure 5. Submitted by Custom Compost

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from the C-Wise Hardstand area.

Bore CW01 located between the C-Wise and CM Farm ponds should detect seepage from both pond clusters. Bores CW03A and CW04A are located up hydraulic gradient and thus would be less impacted by seepage plumes.CW03A is further away from the ponds than CW04A and is therefore expected to have the lowest contaminant levels.

The C-Wise bore network, consisting of five bores, should be capable of detecting any contamination originating from the main operational areas of ponds and Hardstand. However, some of the bores may be influenced by contamination from other premises which makes the clear attribution of sources more difficult. In addition, there are no C-Wise bores south of the ponds and Hardstand despite the likelihood that a contamination plume would travel downgradient in a south-westerly direction.

Mushroom Exchange

Mushroom Exchange maintains five monitoring bores located close to their operational infrastructure. Bores ME02 and ME03 are north of the ponds, bores ME04 and ME05/S east of the hardstand, and bore ME01/S west of the ponds. Due to their proximity to the infrastructure the bores should be capable of detecting any contamination caused by seepage from the ponds and hardstand. Bores ME01/S and ME02 may also be influenced by potential contamination plumes from C-Wise ponds located north of the bores. There is no Mushroom Exchange bore south-west of the infrastructure which is the likely direction in which a contamination plume originating from the Mushroom Exchange ponds or hardstand would travel.

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Figure 1: Groundwater monitoring bore network for CM Farms, C-Wise and Mushroom Exchange.

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CM Farms

CM Farms maintains a network of ten monitoring bores of which three are located close to infrastructure and the remaining seven at varying distances west, north-west and south-west from the ponds and Hardstand.

Bore CM11S is situated west of Pond 5 where it is likely to capture groundwater contamination originating from the adjacent pond cluster. There are no further CM bores near this pond cluster but C-Wise bores CW01and CW02 east of the pond cluster, as well as CW05A southwest of the ponds, should also detect any contamination originating from the ponds.

In February 2016, three new monitoring bores were installed at the new Pond 0. Two shallow bores CMWS01 on the western side and CMWS02 on the eastern side of the pond. A deep bore (CMDW03) has also been installed on the western side of the pond. The bores should be able to detect any contamination originating from Pond 0 but will potentially also be influenced by any contamination plumes from sources located at the C-Wise and Mushroom Exchange premises. Monitoring data from the new bores at Pond 0 are not included in this analysis due to only limited data points being available at the time of assessment.

Bores CM09S and CM10S are located approximately 500m west and 800m south-west of CM Farms ponds respectively. Being hydraulically downgradient from CM Farms, C-Wise and Mushroom Exchange sources, they should be able to detect any contamination plumes from all upgradient operations. The ability to identify distinct sources, however, becomes more difficult the further the bores are away from source locations.

The remaining six bores are located at distances from 700m to 1500m from operational sources. Bores at these distances will reflect background conditions if they are located up-gradient and to varying degrees will capture contamination from operational sources depending on their distance and direction from the source.

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Key findings

The Delegated Officer has reviewed the spatial configuration of the existing monitoring bore network and has found:

1. The existing monitoring network, when used as an integrated network across premises’ boundaries, is considered sufficient to identify whether containment infrastructure such as ponds and Hardstands are effectively controlling leachate emissions.

2. The monitoring network is not able to identify contamination sources at a small spatial scale such as a single pond. Additional investigations in the form of pond liner integrity testing and seepage rate measurements are required for this purpose.

3. The monitoring network includes bores located up and down hydraulic gradient at varying distances from potential operational contamination sources allowing the determination of a suitable background level against which impact bores influenced by site sources can be compared.

4. The current monitoring network does not allow detailed tracking of contamination and plume delineation, and is insufficient to inform on the risk of impacts on sensitive receptors.

4. Monitoring data analysis: Contaminant concentrations, sources and groundwater flow

The available monitoring data has been analysed by:

Comparing contaminant levels found near operational infrastructure with background levels.

Reviewing contaminant concentrations in the context of groundwater flow and the location of contaminant sources and receptors.

Reviewing and interpreting data trends identifying correlations and fluctuations.

To visualise groundwater monitoring data maps have been created showing levels of contaminants in bores across the monitoring network for total phosphorus (TP), total nitrogen/total inorganic nitrogen (TN/T(I)N), and total dissolved solids (TDS). Where total inorganic nitrogen was monitored only, T(I)N was used as an estimator of TN. Data was summarised by calculating concentration averages for each analyte from each bore. For Figure 2 concentration averages were obtained from data between 2010 and 2017 and for Figure 3 concentrations were averaged over 2016 and 2017 only. The shorter timeframe provides a picture of the current situation while the longer timeframe considers contamination history.

A background groundwater quality level for selected analyte concentrations was derived using data from bore CM06S. The bore is located up hydraulic gradient, to the north-west of the three Nambeelup premises. It is therefore not likely to be influenced by contamination sources from the premises. An Upper Tolerance Limit (UTL) is calculated for each background contaminant concentration according to a defined statistical approach (DoEQ, 2014). The set confidence level is 95%. Contaminant concentrations from other bores can then be compared against the calculated UTLs to understand whether monitoring results from the other bores differ from background levels. The UTLs are shown in Table 1 as Background levels.

To aid data visualisation and interpretation data are displayed in a spatial context in Figure 2

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and Figure 3. Data was simplified by distributing values over five categories based on a background level multiplier as outlined in Table 1.

Table 1: Groundwater contamination categories Analytes Units Guideline Background levels

(UTL CM06S) <2x <3x <4x <5x >5x

TN mg/L 2# 8.11 16.22 24.3 32.4 40.6 >40.6

TP mg/L 0.2# 2.17 4.34 6.51 8.68 10.9 >10.9

TDS mg/L 764 1528 2292 3056 3820 >3820

# Department of Environment Regulation Contaminated sites guidelines (DER2014)

A summary of monitoring results between 2010 and 2017 is provided in Figure 2 showing that the highest contaminant levels occurred in operational areas near the ponds and attenuate with distance to the source. Nutrient levels in some bores exceeded the selected reference background level by more than five times indicating the presence of contaminant sources. Given the proximity to ponds and hardstands, this containment infrastructure may be compromised resulting in significant seepage. The fact that bores at different premises next to different pond clusters are affected also points to multiple contamination sources.

The results infer the groundwater flow direction as south-westerly. Consistently, there are higher concentrations down hydraulic than up hydraulic gradient.

The contamination levels detected in bores CM09S and CM10S indicate that a groundwater contamination plume may extend from the operational area in a south-westerly direction towards sensitive environmental receptors located downgradient from the premises. To delineate the full extent of such a contamination plume would require more detailed groundwater investigations.

A comparison of Figure 2 and Figure 3 shows a similar pattern between averaged results over the long term (2010-2017) or over the short term (2016-2017), specifically that contamination concentrations are higher down hydraulic gradient than up hydraulic gradient. Decreases in contaminant concentrations are observed in some bores in most recent times particularly up hydraulic gradient from Mushroom Exchange pond clusters and C-Wise pond clusters (Figure 3 ). Down hydraulic gradient improvements in concentrations are more difficult to identify as a consistent observation across all contaminants. There are both lower and higher concentrations for some contaminants in bores down hydraulic gradient from ponds and hardstands when comparing historic averages with recent averages.

Key findings

The Delegated Officer has reviewed groundwater monitoring data illustrated in Figure 2 and Figure 3 and concluded that:

1. Groundwater monitoring results infer that groundwater flow in the area of interest is likely in a south-westerly direction.

2. The levels of nutrients in multiple bores indicate that containment infrastructure integrity may be compromised at all three premises resulting in seepage to groundwater.

3. A groundwater contamination plume is likely to extend from the operational area in a south-westerly direction towards sensitive environmental receptors located downgradient from the premises.

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Figure 2: Groundwater monitoring results. Values for each analyte represents an average for data from 2010 to 2017. Selected analytes: Total Nitrogen (TN) or alternatively Total Inorganic Nitrogen (TIN), Total Phosphorus (TP) and Total Dissolved Solids (TDS).

* Background levels were calculated using a statistical analysis from the data from CM06S for further details see Section 4

CM07S

TN 5.7

TP 1.7

TDS 736

CM06S

TN 2.4

TP 0.9

TDS 515

CM03S

TN 2.1

TP 0.1

TDS 1241

CM08S

TN 9.2

TP 6.7

TDS 2432

CM04S

TN 2.8

TP 0.6

TDS 757

CM09S

TN 15.1

TP 1.5

TDS 1098

CM10S

TN 26.8

TP 8.8

TDS 898

CW05 CW05A

TN 64 114

TP 2.9 3.8

TDS 870 2875

CM11S

TN 244

TP 24.7

TDS 3279

CW01

TN 148.2

TP 10.5

TDS 1718

CW02

TN 28.9

TP 2.6

TDS 1591

CW03 CW03A

TN 7.7 2.8

TP 1.4 0.8

TDS 269 573

CW04 CW04A

TN 14.2 0.8 (TIN)

TP 2.1 0.5

TDS 400 320

ME02

T(I)N 31

TP 3

TDS 792

ME03

T(I)N 17

TP 3

TDS 936

ME01 ME01S

T(I)N 48 29.2

TP 12 9.5

TDS 1606 788

ME04

T(I)N 13

TP 5

TDS 1089

ME05 ME05S

T(I)N 19 4.2

TP 4 4

TDS 1144 190.8

Analytes Background levels*

<2x <3x <4x <5x >5x

TN 8.11 16.22 24.3 32.4 40.6 >40.6

TP 2.17 4.34 6.51 8.68 10.9 >10.9

TDS 764 1528 2292 3056 3820 >3820

• = Groundwater Bore All units are mg/L

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Figure 3: Groundwater monitoring results Values for each analyte represents an average for data from data for 2016 - 2017 in mg/L. Selected analytes: Total Nitrogen (TN) or alternatively Total Inorganic Nitrogen (TIN), Total Phosphorus (TP) and Total Dissolved Solids (TDS).

Data averaged from sampling events: CM: May and October 2016, CW: CW01 June and October 2016 CW02, CW03A and CW05A June and October 2016 CW04A January 2017, ME: July, October 2016 and January, April 2017.

* Background levels were calculated using a statistical analysis from the data from CM06S for further details see Section 4 .

CM07S

TN 10

TP 1.2

TDS 795

CM03S

TN 4.0

TP BLR

TDS 1150

CM06S

TN 5.5

TP 0.4

TDS 370

CM08S

TN 19.5

TP 13

TDS 2815

CM04S

TN 6.0

TP 0.6

TDS 865

CM09S

TN 21.5

TP 0.5

TDS 1075

CM10S

TN 74

TP 9

TDS 645

CM11S

TN 225

TP 30

TDS 3855

CW05(A)

TN 140

TP 4

TDS 3050

CW01

TN 25.6

TP 6.6

TDS 2050

CW02

TN 31

TP 1.3

TDS 2200

CW03(A) BG

TN 1.8

TP 0.8

TDS 445

CW04

TN 0.8

TP 0.5

TDS 337

ME02

TIN 31.2

TP 2.0

TDS 381.7

ME01

TIN 29.2

TP 9.5

TDS 787

ME03

TIN 16.8

TP 2.9

TDS 476

ME04

TIN 9

TP 3.6

TDS 483

ME05

TIN 4.2

TP 4

TDS 191

Analytes Background levels

<2x <3x <4x <5x >5x

TN 8.11 16.22 24.3 32.4 40.6 >40.6

TP 2.17 4.34 6.51 8.68 10.9 >10.9

TDS 764 1528 2292 3056 3820 >3820

• = Groundwater Bore All units are mg/L

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5. Detailed analysis of contaminant concentrations

For a more detailed analysis data trends as graphed in Figure 4 are reviewed and discussed in the following paragraphs. The data is based on the information received from the licence holders submitted in Annual Environmental Reports (AERs). The bores have been renamed to accommodate the display of all bores on a single map. While the numbering has been retained, a two letter pre-fix has been added to denote ownership according to licence holder (CW = C-Wise, CM = CM Farms, ME= Mushroom Exchange). There are three C-Wise bores CW03A, CW04A and CW05A that have replaced bores CW03, CW04 and CW05 during the time from 2010 to 2017. The replacement bores are located in approximately the same locations as the bores that were replaced.

To facilitate data visualisation and comparison the data are presented as line graphs in Figure 4 . The data, however, is discontinuous consisting of separate distinct data points.

C-Wise

Monitoring data from C-Wise is graphed in Figure 4 .

Total inorganic nitrogen (T(I)N) is an important analyte that can indicate the presence of nutrient rich leachate. When comparing the concentrations of T(I)N across the C-Wise bore network, it is evident that bore CW03A and previously bore CW03 as well as CW04A and CW04 are consistently showing lower levels of T(I)N. Bore results from CW03 and CW03A are consistent with background levels. This is also true for CW04A and CW04, except for data before January 2014These levels are up hydraulic gradient from potential contamination sources such as ponds and Hardstands. Results from bore CW01 located west of the C-Wise ponds shows concentrations significantly elevated (more than 5 times) above background levels. Equally, bore CW02 is impacted by above background concentrations, except for sampling dates between July 2013 and January 2014. Notably from February 2015 to most recent sampling in October 2016 there is an increasing trend in concentration Data availability for bores CW05/5Ais limited but particularly the data points from February 2015 to June 2016 show significantly elevated concentrations (more than 5 times) above background levels. The results indicate that there is likely to be active sources near bores CW01, CW02 and CW05A contributing to T(I)N levels elevated above background.

The concentrations of T(I)N are closely related to the concentrations of nitrate, nitrite and ammonia.

When comparing nitrate and nitrite levels with T(I)N concentrations, the nitrate results for bores CW01 and CW04/4A account for much of T(I)N while T(I)N in bores CW02 and CW05A is dominated by ammonia. The ammonia levels for recent data points are high with 120mg/L ammonia recorded in the latest sample from June 2016.

Together with T(I)N, TP describes the nutrient component of wastewaters and leachates. Elevated TP levels can have detrimental impacts on native plants and promote algal blooms in water bodies. The Peel Inlet Harvey Estuary Environmental Protection Policy (EPP 1992, s. 6, 7) specifically addresses the need to reduce nutrient inputs including phosphorus from its policy area which includes the Nambeelup premises.

TP levels in bore CW01 have been significantly (between 4 and 5 times) above background levels (Figure 4 e) and a recent result from bore CW05A from June 2016 also indicates an elevated level. However, data return for bore CW05A has large gaps and is therefore hard to interpret with regards to any trends. The concentrations in the remaining bores CW02, CW03/3A CW04/4A appear to have remained consistent with background levels at least since July 2013. The results indicate that there are potentially active contaminant sources near bores CW01 and CW05A contributing to TP levels elevated above background

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The pH levels separate mainly bore CW04 and CW03 (pH between 4 and 5) against bores CW01, and CW05A (pH between 6 and 7) (Figure 4 g). This separation is consistent with findings derived from the other analytes including TDS that infer greater impact of nutrient leachates on bore CW01 and CW05A.

Elevated levels of TDS were recorded in bores CW01, CW02 and CW05A (Figure 4 f).

Key findings

The Delegated Officer has reviewed groundwater monitoring data from C-Wise bores illustrated in Figure 4 and concluded that:

1. The submitted data has significant gaps requiring improvements in data quality and consistency in future submissions.

2. High ammonia levels have been detected in bore CW05A indicating the likely presence of a nearby contamination source.

3. Given the observed fluctuations and levels of contaminants recorded in some bores, the current biannual sampling regime is not considered sufficient to adequately document environmental performance and determine contamination sources.

4. High nutrient levels in multiple bores indicate that there is likely to be a contaminant source or sources nearby, which need to be identified. It is therefore necessary to confirm through testing that containment infrastructure on site is effective.

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a) Total Inorganic Nitrogen in relation to BG b) Ammonia concentrations

c) Nitrate concentrations d) Nitrite concentrations

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e) Total Phosphorus in relation to BG and trigger level f) Total Dissolved Solids concentrations

g) PH

Figure 4: Groundwater monitoring data submitted by C-Wise, 2010 to 2017.

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CM Farms

Monitoring data from CM Farms has been graphed by analyte in Figure 5. High levels of TN (more than 5 times background levels) have been recorded from bore CM11S (Figure 5a) which is located west of Pond 5. High levels also occurred in bore CM10S in June 2016 but the level dropped significantly in October 2016. It is unclear what could cause such a fluctuation. Recent results also show bore CM09S and CM08S above background levels. These results indicate that there are potential contaminant sources up hydraulic gradient from the bores that may be impacting on TN concentrations. Given the proximity of bore 11S to CM Farms ponds, these could be an active contamination source. They could also affect bore CM10S which is located 800m south-southwest from CM11S and down hydraulic gradient from the ponds. In addition the results from bore CM09S could be impacted by the same contaminant source due to its location approximately 500m southwest of bore CM11S. Ammonia and Nitrate levels are graphed in Figure 5b-c. Nitrite has not been graphed as it remained below detection level for the entire monitoring period. Concentrations of Ammonia and Nitrate show elevated levels and fluctuating patterns in bore CM11S indicating potential impacts from a nearby contamination source.

Bore CM11S also recorded high levels (more than 5 times background levels) of TP and similar to TN the graph shows substantial fluctuations. There is some graph alignment between TN and TP between May and October 2015 indicating they are likely to be caused by the same contamination source. It is likely that this source is one or multiple CM Farm ponds located close to CM11S. The fact that there are large nutrient spikes indicate that there may have been some events such as operational activities that contributed to increased nutrient seepage. It is unclear, however, what these events were.

Data spikes are also observed in bores CM11S, CM09S and CM08S for TDS (Figure 5f) and it is unclear what these are caused by.

It is possible that data spikes reflect some level of seasonality and rainfall pattern but such a pattern is not clearly discernible. The cause is more likely to be data integrity issues relating to sampling methodologies.

Key findings

The Delegated Officer has reviewed groundwater monitoring data from CM Farm bores illustrated in Figure 5 and concluded that:

1. High nutrient levels have been detected in bore CM11S indicating the likely presence of a nearby contamination source.

2. From the location of the impacted bore, it is inferred that one or multiple CM Farm ponds could be the contamination source.

3. Given the observed fluctuations and high levels of contaminants recorded, the current biannual sampling regime is not sufficient to adequately document environmental performance and determine contamination sources.

4. High nutrient levels in bore CM11S and bores CM10S and CM09S indicate that a groundwater contamination plume originating at the operational area may have mobilised and moved in a south-westerly direction towards sensitive receptors.

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a) Total Nitrogen in relation to BG b) Ammonia concentrations

c) Nitrate concentrations d) Total Phosphorus in relation to BG

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e) PH f) Total Dissolved Solids concentrations

Figure 5: Groundwater monitoring data submitted by CM Farms, 2010 to 2016

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Mushroom Exchange

Monitoring data from Mushroom Exchange has been graphed by analyte in Figure 6. In contrast to data from C-Wise and CM Farms, the data from Mushroom Exchange has been collected in quarterly intervals which provides greater detail and data resolution. However, the quarterly sampling intervals are not consistent and there are some data gaps.

Nitrogen based nutrient concentrations are shown in Figure 6a-d. T(I)N levels graphed in Figure 6a show high concentrations and large fluctuations over the historical time series. Such data fluctuations are difficult to interpret in light of describing any trends. Generally T(I)N concentrations in bores ME01 and ME02 are higher and above the background level compared to bores ME03 and ME04. This is consistent with a downgradient location of bores ME01 and ME02 in relation to possible sources from the Mushroom Exchange pond cluster. ME01 and then ME02 appear to be the most impacted bores on the premises. Recent data points from October 2016 and January and April 2017 show a trend of declining concentrations of T(I)N in bores ME01S and ME02.

Concentrations of T(I)N, ammonia, nitrate and nitrite show patterns and fluctuations that are not easily explained. There may be some alignment with T(I)N data however. The data for ammonia in bore ME01 (Figure 6b), for instance, mirrors the data for T(I)N in the same bore (Figure 6a). Data points for nitrate (Figure 6c), however, are more closely aligned with T(I)N concentration in bores ME03, ME04 and ME05 (Figure 6a).

A review of the time series of TP concentrations (Figure 6e) shows generally high concentrations and large fluctuations over the historical time series but recent sampling events indicate a reduction in TP concentrations with levels in bore ME02 reaching background concentrations.

TDS levels in all bores show a declining trend over the long term historically. Most recent data appear to be somewhat stable (Figure 6f).

PH levels a (Figure 6g) show a sudden decline in all bores between April 2016 and July 2016 but have been stable over the most recent period (Figure 6g).

Key findings

The Delegated Officer has reviewed groundwater monitoring data from Mushroom Exchange bores illustrated in Figure 6 and concluded that:

1. The submitted data has some gaps highlighting the importance to ensure that data quality and consistency is maintained in future submissions.

2. High nutrient levels above background have been detected in multiple bores surrounding the Mushroom Exchange infrastructure indicating the likely presence of a nearby contamination source. It is therefore necessary to confirm through testing that containment infrastructure on site is effective.

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a) Total Inorganic Nitrogen in relation to BG b) Ammonia concentrations

c) Nitrate concentrations d) Nitrite concentrations

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e) Total Phosphorus in relation to BG f) Total Dissolved Solids concentrations

g) PH

Figure 6: Groundwater monitoring data submitted by Mushroom Exchange, 2010 to 2017

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Appendix 6: Odour Impact Analysis

1. Complaints

From October 2015 the then DER began to receive an increase in odour complaints which were recorded in the Department’s Incident and Complaints Management system as potentially being related to the Nambeelup premises due to location, odour characterisation, similarity with complaints made at the same time and/or statements made by the complainant. Figure 1 shows the number of odour complaints recorded each month from August 2014 to January 2018 where the Nambeelup Farms were listed as a potential source.

Figure 1: Complaints attributed to Nambeelup Farms

2. Desktop Assessment

Given the significant increase in complaints over the 2016 annual period, a desktop assessment was undertaken to determine whether the odour complaints could be reasonably attributed to the Nambeelup Farm area based on likely wind direction. This initial screening tool is based on wind direction averages from the Bureau of Meteorology.

Figure 2 demonstrates the suburbs where complaints were received from (where a suburb was given) and the dominant wind directions for the Mandurah area. The data indicates that the majority of complaints during 2016 were received from suburbs that are predominately downwind and in closest proximity of the Nambeelup Farm area.

0

10

20

30

40

50

60

70

80

Au

g-1

4

Oct

-14

De

c-1

4

Feb

-15

Ap

r-1

5

Jun

-15

Au

g-1

5

Oct

-15

De

c-1

5

Feb

-16

Ap

r-1

6

Jun

-16

Au

g-1

6

Oct

-16

De

c-1

6

Feb

-17

Ap

r-1

7

Jun

-17

Au

g-1

7

Oct

-17

De

c-1

7

No ofcomplaints

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Figure 2: Number of complaints per suburb in 2016 (where suburb was provided at time of complaint)

On a number of occasions there were multiple complaints made on the same day. The meteorological data was analysed for these events which demonstrated that complaints were made at times when the suburbs were likely to be experiencing wind from the direction of the Nambeelup Farms. Figures 3 and 4 below demonstrate the location of complaints and the recent wind direction for complaints made on the 18 March and 11 April respectively.

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Figure 3: Four complaints made on the 18 March 2016

Figure 4: Ten complaints made on the 11 April 2016

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The complaints data also demonstrates that the outlying suburbs more than 8 kilometres from the premises reported complaints at the time when recent wind directions were likely to place them downwind of the Nambeelup Farms. Figure 5 demonstrates complaints made near Karnup were received on the 18 February where morning winds were SSE and afternoon winds were SE.

Figure 5: Seven complaints made on the 18 February 2016

While the wind directions are averaged data for the area, it demonstrates that on many occasions the complaints were made in locations where the wind directions could reasonably attribute the Nambeelup Farm area as a potential source of odour, and indicate that there is a potential pathway for odours to travel from the premises to the receptor location.

4. Odour Investigation

As complaints began to increase at the end of 2015, the then DER conducted the Mandurah Odour Investigation at the start of 2016, with seven surveys conducted by DER officers during April to June of 2016. The purpose of the survey was to ascertain which odour sources were the major contributors to odour impacts in the Mandurah area and if possible, to determine the odour impact extent of those sources. The investigation was carried out independent of any complaints and was based on weather data provided by the Department of Agriculture with supplementary weather data taken by DER Officers on the ground at the point of assessment. The full investigation report is attached as Appendix 7.

The following figures 6 and 7 are taken from file notes in support of the investigation and demonstrate that odours could be identified at over 8km from the premises, and that the assessment involved taking measurements upwind of the premises.

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Figure 6: Location of odours observed 19 May 2016

Figure 7: Location of odours observed 2 June 2016 (blue dots indicate no odours observed upwind)

The findings of the report demonstrate that while there are a number of potential natural odour sources (lakes and rivers) as well as two other prescribed premises in the Mandurah area, in the majority of cases the odour observed by DER officers was attributable to the Nambeelup Farms. Odours from the Nambeelup Farms were also observed up to 8.5km from the premises which further correlates to a number of complaints made in suburbs over 8km away from the Nambeelup Farms.

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3. Key findings

The Delegated Officer has reviewed the odour complaint information and has found:

1. There is a potential pathway for odours to travel over 8km from the Nambeelup Farm premises.

5. Specific complaint validation

Verification of individual odour complaints on the ground is difficult due to the need to be in close proximity at the time of the complaint. On the 27 May 2016 DER Air Quality officers were in the Nambeelup area to conduct the Mandurah Odour Investigation and two complaints were received by DER at this time. DER officers were therefore able to validate these complaints by recording odours observed in the area just before the complaints were made and up to an hour after the complaints were made. These observations and shown in Figure 8. During the period of observation the one minute average wind directions at the Pinjarra weather station ranged between east north-easterly and south easterly, and the one minute average wind speeds ranged from 0.29m/s and 1.5m/s (data sourced from the Department of Agriculture and Food).

Figure 8: Odour complaints and DER observations – 27 May 2016

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6. Key findings

The Delegated Officer has reviewed the information regarding the odour investigation and has found:

1. Odour emissions observed in the Mandurah area are mainly attributable to the Nambeelup Farm premises.

2. Odour impacts have been confirmed up to 8.5 km from the premises.

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Appendix 7: Technical Expert Report – Mandurah Odour Investigation

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Appendix 8: Technical Expert Report – Review of ‘Investigation of Odour Emissions from Nambeelup Precinct Operations’ and Nambeelup farm precinct water quality laboratory report

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Attachment 1: Revised Licence L8410/2009/2

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