Section 53 V Audit - Landfill Operation

133

Transcript of Section 53 V Audit - Landfill Operation

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Section 53 V Audit - Landfill Operation

Portland Landfill - 210 Cape Nelson Road,

Portland

Service Order No. 8004905

Glenelg Shire Council

May 2016

184-01

Nolan Consulting Pty Ltd

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Table of Contents

Executive Summary ................................................................................... i

1. Introduction ................................................................................... 11

1.1 Requirement for audit of landfill operation .....................................11 1.2 Auditor ....................................................................................................11 1.3 Compliance with audit requirements ..............................................11 1.4 Definitions ...............................................................................................11 1.5 Location of audit findings ...................................................................11

2. Audit scope and method ............................................................. 13

2.1 Scope ......................................................................................................13 2.2 Audit objective .....................................................................................13 2.3 Audit scope ...........................................................................................13 2.4 Audit tasks ..............................................................................................14 2.5 Reference documents ........................................................................15

3. Landfill development and operations ......................................... 16

3.1 Location and area ...............................................................................16 3.2 Ownership ..............................................................................................16 3.3 Land use .................................................................................................16 3.4 Landfill staging and key design features .........................................17 3.5 Landfill life...............................................................................................20 3.6 Facility operator ....................................................................................20 3.7 Human resources ..................................................................................20 3.8 Landfill operations ................................................................................21 3.9 Complaints and regulatory performance .......................................26

4. Implementation of progressive rehabilitation ............................ 28

4.1 Existing capping ....................................................................................28 4.2 Rehabilitation Plan ...............................................................................28 4.3 Scheduling .............................................................................................29 4.4 Finished surface level ...........................................................................29 4.5 Design progress .....................................................................................29 4.6 Stormwater drainage ..........................................................................30 4.7 Landfill gas management ..................................................................31 4.8 Conclusion .............................................................................................32

5. Conceptual site model ................................................................. 33

5.1 Climate ...................................................................................................33 5.2 Topography ...........................................................................................33 5.3 Soils ..........................................................................................................33 5.4 Hydrogeology .......................................................................................33 5.5 Surface water ........................................................................................40 5.6 Cultural heritage sites ..........................................................................40 5.7 Vegetation .............................................................................................40

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5.8 Landfill gas .............................................................................................40 5.9 Sources, pathways and receptors ....................................................41

6. Risk of landfill operations .............................................................. 45

6.1 Beneficial uses .......................................................................................45 6.2 Risk assessment method ......................................................................51 6.3 Updated landfill register ......................................................................54 6.4 Compliance risk register ......................................................................54

7. Assessment of monitoring program implementation ................. 63

7.1 The verified program ...........................................................................63 7.2 Assessment of implementation ..........................................................64 7.3 Annual reporting ...................................................................................71

8. Interpretation of monitoring results .............................................. 72

8.1 Scope ......................................................................................................72 8.2 Leachate levels ....................................................................................72 8.3 Groundwater flow direction ...............................................................72 8.4 Water quality .........................................................................................73 8.5 LFG monitoring ......................................................................................78

9. Progress with previous Auditor's recommendations .................. 82

10. Update and reverification of monitoring program ..................... 85

10.1 Updated program ................................................................................85 10.2 Environmental audit program ............................................................96 10.3 Reverification ........................................................................................96

11. Conclusions ................................................................................... 97

12. Recommendations ......................................................................102

13. Applicability .................................................................................105

14. References....................................................................................106

15. List of abbreviations and units .....................................................109

List of Figures (after Cardno; 2015b)

1. Site Locality Plan

2. Landfill Development Sequence

3. Bore Location Plan

4. Landfill Gas Bore Location Plan

5. Leachate Collection System

6. Regional Geology

7. Geological Cross-Section A-A’

8. Geological Cross-Section B-B’

9. Groundwater Elevation (April 2015)

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10. Groundwater Hydrographs

11. Groundwater Database Search Results

12. Groundwater Salinity (April 2015)

13. Groundwater Ammonia Concentration (April 2015)

Appendices

A EPA Licence 22492

B Photographs (March 2016)

C Nolan Consulting (2014) “Section 53V Audit – Landfill Operation, Portland Landfill –

210 Cape Nelson Road Portland”

D Cardno (2015b) “Hydrogeological Assessment for Leachate Level Management -

Portland Landfill 210 Cape Nelson Road, Portland, Vic.”

E GHD (2015b) “Portland Landfill Annual Environmental Monitoring Results Report

2014/15”

F Portland Landfill Risk Assessment Register (updated May 2016)

G Portland Landfill Compliance Risk Register (updated May 2016)

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Executive Summary

The Glenelg Shire Council operates a landfill located at 210 Cape Nelson Road, 3 km south-

south-west of the Portland town centre. The landfill, known as the Portland Landfill, is licensed

to operate under the Environment Protection Authority licence 22492 (formerly HS776) as

amended on 30th June 2014.

The licence requires that an Environmental Auditor appointed pursuant to the Environment

Protection Act 1970 must conduct environmental audits at the frequency specified in the

verified Monitoring Program. The verified Monitoring Program was updated and re-verified in

November 2014 by John Nolan (Nolan Consulting; 2014) as the appointed Environmental

Auditor.

The re-verified Monitoring Program specified that next audit of landfill operation be undertaken

for the period from 1st July 2014 to 31st December 2015. The scope of the audit is described in

Appendix 6 of the EPA (2011b) Landfill Licensing Guidelines, Publication 1323.2.

Audit objective

The objective of the audit is to identify and, where possible, quantify the risk of any possible

harm or detriment to a segment of the environment caused by the landfill operation.

Background

The audit report has been prepared in accordance with:

Section 53V of the Environment Protection Act 1970 which sets out requirements that must

be met when an Environmental Auditor prepares an environmental audit report in

relation to the risk of any possible harm or detriment to a segment of the environment

caused by any industrial process or activity, waste, substance or noise;

Appendix 6 of the EPA Landfill Licensing Guidelines;

EPA Environmental Auditor Guidelines for the Preparation of Environmental Audit Reports

on Risk to the Environment; and

Condition L1_L2 of the EPA Licence 22492 (as amended on 30th June 2014).

In undertaking the audit, the Auditor has had regard to, among other things, the:

relevant State Environment Protection Policies;

verified Environmental Monitoring Program (Nolan Consulting; 2014);

Portland Landfill monitoring reports for the audit period of 1st July 2014 to 31st December

2015; and

the beneficial uses of the premises and surrounding land.

Audit details and audit site

Details of the audit and audit site are presented in Tables E1 and E2.

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Table E1: Audit report summary

Item Description

EPA file reference no. 67141-5 (CARMS No.)

8004905 (Service Order No.)

Auditor John Nolan

Auditor term of appointment 08/02/2014 to 07/02/2019

Name of person requesting audit David Hol

Relationship to premises/location Project Planning and Facilities Manager

Glenelg Shire Council

Date of request 9th October 2015

Date EPA notified of audit 31st December 2015

Completion date of the audit 26th May 2016

Reason for audit EPA Licence 22492, Condition L1_L2

Description of activity Operation of Portland Landfill

EPA region South West Region

Dominant – Lot on plan Lot 1 on Title Plan 120803

Crown Allotment 3G, Section 13 of Plan 3414

Additional – Lot on plan Crown Allotment 60M, Section D of Plan 5651

Site/premises name Portland Landfill

Building/complex sub-unit No.

Street / Lot – Lower No. 210

Street / Lot – Upper No.

Street Name Cape Nelson

Street type (road, court, etc.) Road

Street Suffix – (North, South, etc.)

Suburb Portland

Postcode 3350

GIS coordinates of centroid

-38.37059167

141.5834472

Latitude (GDA94)

Longitude (GDA94)

Members and categories of support

team utilised

Nil

Outcome of the audit Audit report with recommendations

Further work or requirements Recommendations as set out in Section 12 of this audit report and

in the Executive Summary

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Table E2: Physical Site information

Item Description

Groundwater segment Segment A2

Surrounding land use North: Yarraman Park, public open space, scrubland, open

grassed paddocks.

East: Cemetery, open grassed paddocks beyond cemetery.

South: Open grassed paddocks with two residences.

West: Open grassed paddocks, scrubland and one residence.

Audit findings

Risk of landfill operations to beneficial uses identified by the environmental Auditor

1. The Nolan Consulting (2014) risk assessment, including the risk registers, has been

reviewed. The risk register has been updated as part of the audit. No changes to the risk

profile have been required.

2. The following are considered to be very high risks:

groundwater contamination by leachate:

from active cell (on site);

from active cell (off site);

via unsaturated zone (on site); and

via unsaturated zone (off site).

3. The following are considered to be high risks:

LFG migration via unsaturated zone (on-site);

groundwater contamination by leachate from active waste cell impacting on

down gradient groundwater users; and

asphyxiation resulting in death or serious injury of site workers caused by a LFG

explosion via unsaturated zone migration.

4. The following are considered to be medium risks:

corrosion of on-site transmission towers via leachate through the unsaturated zone;

and

litter from active waste cell on the health of flora & fauna and visual amenity;

windblown and traffic generated litter from active waste cell on amenity of on-site

workers;

windblown dust from site activities and traffic on amenity of on-site workers;

windblown dust from site activities on health of on-site workers and humans at

nearby residences and Yarraman Park;

traffic generated on health of on-site workers;

odour from leachate storage dam on amenity of workers;

toxic gases (H2S) on health of maintenance workers;

noise from machinery, equipment, and traffic on amenity of workers;

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leachate, via runoff and/or groundwater pathways, on surface water beneficial

uses;

contamination of land by overfilling of leachate storage dam;

on-site groundwater caused by increased level in leachate storage dam

increasing infiltration through unsaturated zone;

vermin from active waste cell on amenity of on-site building occupants and

humans at and in the vicinity of the landfill;

damage to flora due to fire at active waste cell;

poor weed management within the site on amenity and local flora; and

erosion from capped landfill on on-site flora and fauna.

5. The beneficial uses adopted for the atmosphere at the premises, groundwater beneath

the premises, any surface water on the premises and the environment surrounding the

premises are appropriate.

6. The environmental aspects adopted in the updated risk register are comprehensive and

appropriate.

Assessment of implementation of the Monitoring Program

7. The previously verified Monitoring Program (Nolan Consulting; 2014) was structured as

specific sub-programs for individual environmental elements.

8. There are two generic categories of monitoring within the verified environmental

programs. These are Category A for regular or incident driven inspections by trained GSC

staff and Category B for groundwater, leachate, and LFG sampling and testing based

programs.

9. The Category A monitoring activity is observation (visual and olfactory) by trained GSC

staff. The verified Monitoring Program requires evidence of the observations to be

reported.

10. Implementation of the Category A monitoring is progressing. Further improvements are

required in staff training, systematic monitoring and reporting.

11. The Environmental Monitoring contract includes most Category B monitoring

requirements presented in the verified Environmental Monitoring program.

12. The Category B groundwater and leachate monitoring sub-program was implemented

in accordance with the verified monitoring program except for:

a level data logger has not been installed in LIS bore IB5;

new groundwater bores PO34A, PO34B, PO35A and PO35B and new leachate

monitoring bores LB01R and LB02RA are yet to be not surveyed;

flow meter on LIS discharge line has failed;

pulse counters (for flow) and data loggers (for level) installed but are yet to be

reported;

chain of custody forms do not to identify sample containers;

trip blank sample not obtained during the VOC sampling; and

completed groundwater bore purging and sampling records do not report on bore

condition.

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13. The LFG monitoring sub-program was implemented in accordance with the verified

monitoring program except for:

monitoring records of pits and other enclosed spaces did not include location

details, evidence of corrosion, and presence of odours;

LFG monitoring in building records do not include location details (e.g. monitor

positions, building conditions, and presence of odours);

monitoring for signs of corrosion at the bore network is not undertaken, and

reporting of corrosion monitoring results needs to be documented ;

LFG surface monitoring is limited to a few (nine) locations on Area A and B and

does not include Area A and B vegetated areas and sections of Area C which has

not been filled within any three month period.

plant health at and within 50 m of the landfill while monitored is not fully reported.

14. LFG monitoring data is not incorporated into the integrated monitoring database.

15. The annual monitoring report requires a declaration that the monitoring program was

completely in accordance with the verified monitoring program and explains any non-

conformances, including names of persons responsible for each component of the

monitoring program.

Interpretation of monitoring results - groundwater

16. The background groundwater is within Segment A2 (less than 1,000 mg/L).

17. The groundwater salinity immediately down-gradient of Areas A and B is close to the

leachate salinity, and the salinity down-gradient of Area C that is elevated above

background but less than the leachate salinity. The salinity plume extends to the north-

east (including to the east of Cape Nelson Road).

18. The background groundwater ammonia concentration is less than 100 µg/L.

19. Elevated ammonia contamination of the groundwater, at concentrations of 5 mg/L and

above, occur immediately down-gradient of Area A and to the east of the landfill site.

There are moderate levels of ammonia contamination immediately down-gradient of

Area C, immediately down-gradient of Area A/B, to the east of Cape Nelson Road, and

north-west of Yarraman Park.

20. The elevated TDS and ammonia concentrations are associated with landfill leachate.

21. Evidence of nitrate concentration above the ANZECC (2000) Ecosystem Freshwater 95th

percentile guideline values are inconsistent and do not reflect the salinity and ammonia

contamination plume.

22. Volatile fatty acids are indicators of leachate contamination. Concentrations of 20 mg/L

or above were only found in April 2015 at PO32A (300 m north-east of the site entrance).

23. The average Mulvey L/N ratios at the leachate monitoring bore L/N ratio is 161. The only

groundwater bores with ratios above 10 that may be indicative of a leachate impact

are at PO18R (along eastern boundary), PO08R (between IB6 and IB7), PO32 (300 m

north-east of the site entrance), PO03 (along western boundary), and PO01 (south-side

of Derril Road).

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24. There is negligible evidence of volatile organic and semi-volatile organic compounds in

the groundwater. There were no exceedances of the ANZECC (2000) Ecosystem

Freshwater 95th percentile trigger value and the Australian Drinking Water Guidelines

health guideline values for these compounds except for benzene at PO07 and LIS bores

IB4 and IB8 which marginally exceed the AWDG health guideline value of 1 µg/L.

25. The leachate plume extends at least 400 m to the north-east of Derril Road and possibly

550 m to Madeira-Packet Road as well as to the east of Cape Nelson Road.

26. This 2016 Audit of Landfill Operation has found that the October 2015 plume extent has

stabilised since June 2014 with reductions in ammonia concentrations within the main

leachate plume,

Interpretation of monitoring results – landfill gas

27. All boundary LFG probes recorded methane at concentrations below the BPEM

boundary action level of 1% v/v at all monitoring events except for LFG23 at one

monitoring event when 1.0% was recorded.

28. Of the perimeter bores LFG monitoring bores LFG02, LFG07, LFG23 and LFG24 have with

CO2 concentrations that are consistently over 1%v/v above background. These are

located along the eastern boundary except for LFG07 which is located in the south-west

corner.

29. Isolated CO2 concentrations of greater than 1%v/v above background have occurred

at monitoring bores LFG03, LFG06, LFG11, LFG12, LFG15, LFG19, and LFG22.

30. All CO2 concentrations are less than 10 % v/v above background except for LFG02 which

is up to 14.2 % v/v above background concentration.

31. The maximum gas screening value (GSV) for CO2 is 0.044 L/hr which based upon CIRIA

(2007) represents a very low risk.

32. The CO2 concentrations at joint LFG probe/EPA (2015a) Landfill BPEM compliant bores

sites for LFG08/8A, LFG10/10A, LFG18/18A and LFG20/20A are consistent between bores

and probes. The key exceptions are for LFG10/10A, and LFG20/20A in the August 2015

monitoring event. In both occasions the probes recorded 0.1% v/v and the bores

recorded 1.0% v/v to 1.1% v/v. As the results are inconclusive ongoing monitoring of the

probes and bores up to the end of 2015/16 year is recommended.

33. While the reported CO2 exceedances of the EPA (2015a) Landfill BPEM action level are

relatively minor, and are unlikely to be landfill sourced, the potential for subsurface

migration of CO2 from the landfill cannot be excluded.

34. Monitoring of the Area A and Area B landfill surface has found methane concentrations

above the 200 ppm action level at several locations. These are generally in areas with

poor vegetation development.

35. While the recapping of the majority of Area A and B should reduce methane

concentration at the surface to below the final cap action level of 100 ppm there is a risk

of lateral migration within the lower lying areas which will not be recapped due to the

presence of native vegetation.

36. The methane concentrations within all building, structures and subsurface services were

well below the EPA (2015a) Landfill BPEM action levels, except for one instantaneous

methane concentrations of 22.0 ppm found outside the stormwater drain at Cape Nelson

Road near the cemetery gate. This is well below the EPA (2015a) Landfill BPEM action

level of 5,000 ppm.

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37. There are no obvious LFG trends based upon the limited set of historical records.

Updated Monitoring Program

38. The Monitoring Program (Nolan Consulting; 2014) has been updated as part of this Audit

of Landfill Operation to reflect the revised CSM, the updated risk assessment, the

verification auditor’s comment’s, the Monitoring Program assessment, and progress with

implementing the 2014 Audit of Landfill Operation recommendations.

39. The updated Monitoring Program includes the following elements:

roles and responsibilities;

Category A monitoring (visual and olfactory);

Category B monitoring (groundwater);

Category B monitoring (LFG);

reporting; and

contractor requirements.

40. In general the updates are of a minor nature. The key changes are the inclusion of one

additional groundwater monitoring bore, two additional leachate monitoring bores,

and the expansion of the methane landfill surface monitoring program.

41. The updated Monitoring Program is verified as meeting the EPA (2011b) Landfill Licensing

Guidelines requirements and being adequate for GSC and the EPA to determine

compliance with the licence.

Implementation of progressive rehabilitation

42. GSC has scheduled the landfill to close following the commissioning of the transfer

station. This is expected to occur in mid-2016.

43. The Rehabilitation Plan has been approved by the EPA. This includes the top of waste

Pre-settlement Contour Plan.

44. The Technical Specification and Construction Quality Assurance Plan for Phase 1

Capping (Stages 1 and 2 cap) have been completed.

45. Phase 1 capping is expected to occur in the 2016/17 financial year. The delay from that

scheduled in the Rehabilitation Plan is due to the need to address native vegetation

management issues as required under the Environment Protection and Biodiversity

Conservation Act 1999 and to consider alternative capping design options.

Audit Recommendations

The recommendations of this environmental audit, incorporating those outstanding from the

2014 Audit of Landfill Operation, are presented in Table E3 below.

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Table E3: Audit of Portland Landfill operation – Recommendations

No Recommendation Risk

rating

Recommended

completion date

Monitoring program

1 Implement updated Monitoring Program including: High Ongoing

a) Install, survey, and monitor additional leachate monitoring

bores.

Centre of Area A (to base of waste); and

Centre of Area B (to base of waste).

High Aug 2016

b) Install, survey and monitor one additional groundwater

monitoring bore in the vegetated area between Area C and

the northern site boundary.

High Aug 2016

c) Install a level data logger in LIS bore IB5. High Aug 2016

d) Install temporary weather station at site to monitor rainfall and

evaporation.

Med Nov 2016

e) Survey new groundwater bores PO34A, PO34B, PO35A and

PO35B, new leachate monitoring bores LB01R and LB02RA, and

the above proposed bores to AHD and location.

Low Dec 2016

f) Maintain the flow meter on the LIS discharge line. High Ongoing

g) Ensure chain of custody forms identify sample containers. Low Ongoing

h) Ensure trip blank sample are obtained during the VOC sampling. Low Ongoing

i) Ensure groundwater bore purging and sampling records report

on bore condition. Low Ongoing

j) Undertake methane monitoring of the capped and

intermediate landfill surface, which was not been filled within the

preceding three month period. at a 25 m grid. This should include

the vegetated area of Area A and Area B.

Med First monitoring

event following

Phase 1 capping

k) Identify the location of new service pits associated with the

transfer station and ancillary facilities. High Upon

commissioning

l) Revise building, structures and service pit LFG monitoring points

to accommodate the new transfer station and ancillary facilities High Upon

commissioning

m) Provide a more comprehensive report of plant health at specific

locations on the cap and within 50 m of the landfill. Low Next audit

2 Provide all weather 4x4 vehicle access to within 5 m of all bores for

all conditions except flooding events.

Low First monitoring

event following

Phase 1

capping.

3 Establish an integrated database to hold and enable efficient

reporting of all monitoring records and data from 1989, preferably

in ESDAT format in accordance with the prepared service

specification.

Low Next audit

Hydrogeology

4 Resolve with the EPA the potential for using the Groundwater

Quality Restricted Use Zone (GQRUZ) under SEPP Groundwaters of

Victoria as a mechanism to manage this risk.

Low Next audit

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No Recommendation Risk

rating

Recommended

completion date

Conceptual model

5 Undertake a comprehensive analysis of MSA and BFA aquifers

groundwater quality analysis that identifies discrete characteristics.

This should include using Stiff and Piper diagrams and Mulvey L/N

ratios.

Mediu

m

Mar 2017

Leachate interception system (LIS)

6 Operate the LIS in accordance with the Cardno (2015b)

“Hydrogeological Assessment for Leachate Level Management -

Portland Landfill 210 Cape Nelson Road, Portland, Vic.”

High Jul 2016

7 Monitor the LIS in accordance with the verified Monitoring Program

(Table 10-2 of this report). This includes reporting of level, flow rate,

and condition at individual LIS bores, leachate level at leachate

storage dam, flow to leachate storage dam and leachate storage

dam water balance.

High Jul 2016

8 Review the LIS monitoring data every six months to determine the

effectiveness of operation whether the leachate bore level, LIS

flow, groundwater level, and groundwater chemistry triggers are

not exceeded as described in Cardno (2015b) “Hydrogeological

Assessment for Leachate Level Management - Portland Landfill 210

Cape Nelson Road, Portland, Vic”..

High Ongoing

9 Implement an Operation & Maintenance manual and program to

provide for system monitoring and optimisation.

Med Sep 2016

Infrastructure

10 Confirm with AusNet Services that they have responsibility for

monitoring structural integrity of the HV transmission line towers

(including corrosion).

Low Next audit

LFG Risk Management

11 Review monitoring results from the LFG monitoring probe/bores

monitoring sites, to determine if any changes to the risk profile are

required.

Med Jul 2016

12 Check that the GSC restriction on residential development within

500 m of the site prevents any future residential development,

particularly of buildings with unvented basements.

Med Nov 2016

13 Review the need for LFG control in Areas A and B, particularly

around the eastern part of the site, within a thin corridor along the

southern fringe and the adjoining Malings Road reserve where the

existing cap will not be remediated.

Med First monitoring

event following

Phase 1

capping.

Planning

14 Investigate and implement a mechanism to control proposed

developments within 500 m from the landfill. This would involve a

trigger to identify planning permit applications for such

developments and a process to identify and mitigate risk such as

through an Environmental Significance Overlay or an

Environmental Audit Overlay.

Low Next audit

15 Complete Aftercare Management Plan in accordance with the

Post Closure Supporting PAN.

Med In accordance

with PAN

requirements.

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No Recommendation Risk

rating

Recommended

completion date

Operational

16 Ensure the stormwater drainage system for the Phase 2 cap is

designed for the whole site and includes adequate stormwater

sedimentation pondage(s) to allow capture and treatment of

stormwater prior to discharge from the site.

Low With Phase 2

cap design

17 Ensure the Phase 2 cap design considers the management of the

shallow fill found to the north-west of the leachate storage dam as

part of the drilling program to install monitoring bore 35A/B.

Med With Phase 2

cap design

18 Remediate the existing perimeter drainage system. Low Next audit

19 Improve operational management procedures as per the Landfill

Compliance Risk Register (Appendix F). These include:

Establish a procedure to report on site infrastructure corrosion

inspection photographs to identify action requirements;

Low

Next audit

Ensure daily inspections are undertaken on all days in which

the landfill is operating;

Low Ongoing

Modify the daily and monthly checklists to identify the locality

where observations are made; and

Low Sep 2016

Maintain a record of visual inspections of loads at the

weighbridge.

Med Sep 2016

20 Ensure at least 300 mm of daily cover is placed on the tipping face

and the intermediate cover within Area C is maintained. This will

require additional cover over parts of Area C where litter is

emerging.

Med Ongoing

21 Fence off Area A. Low Next audit

Auditor activities

22 Review assessment of LIS system performance against triggers and

determine whether the LIS performance meets the design

objective for period from 1st January 2016 to 31st December 2016

High Feb 2017

23 Undertake for period up to 30th June 2017. Mediu

m

31st Oct 2017

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1. Introduction

The Glenelg Shire Council (GSC) operates a landfill located at 210 Cape Nelson Road, 3 km

south-south-west of the Portland town centre (Figure 1). The landfill, known as the Portland

Landfill, is licensed to operate under the Environment Protection Authority (EPA) licence 22492

(formerly HS776) as amended on 30th June 2014. The licence is attached to this audit report as

Appendix A.

1.1 Requirement for audit of landfill operation

Condition L1_L2 of the licence (Appendix A) states that “You must engage an environmental

Auditor appointed pursuant to the Act to conduct the environmental audits at the frequency

specified in the verified Monitoring Program”.

The verified Monitoring Program was updated and re-verified in November 2014 by John Nolan

(Nolan Consulting; 2013) as the appointed Environmental Auditor. The re-verified Monitoring

Program specified that next audit of landfill operation be undertaken for the period from 1st July

2014 to 31st December 2015.

1.2 Auditor

John Nolan, an Environmental Auditor appointed under the Environment Protection Act 1970

(the ‘Auditor’), has been engaged by the GSC to undertake this audit of the landfill operation.

1.3 Compliance with audit requirements

The audit has been conducted in accordance with Section 53V of the Environment Protection

Act 1970.

The audit report has been prepared in accordance with:

Section 53V of the Environment Protection Act 1970 which sets out requirements that must

be met when an Environmental Auditor prepares an environmental audit report in

relation to the risk of any possible harm or detriment to a segment of the environment

caused by any industrial process or activity, waste, substance or noise;

Appendix 6 of EPA (2011b) Landfill Licensing Guidelines, EPA publication 1323.2;

EPA (2015b) “Preparation of Environmental Audit Reports on Risk to the Environment”,

Publication 952.5; and

Condition L1_L2 of EPA Licence 22492.

1.4 Definitions

The term “site” is used within this report. It refers to the area subject to the licence as shown in

the licence’s Schedule 1A – Locality Plan and in Figure 1. It is noted that this area excludes the

area in the north-west previously known as Cell 4.

1.5 Location of audit findings

The locations of the audit findings within the body of this report are listed in Table 1-1.

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Table 1-1: Location of audit findings within the landfill operation audit report

Audit findings Location in audit

report (section)

Implementation of progressive rehabilitation. Section 4

Comment on the risk assessment prepared by landfill operator. Section 6

Risk of landfill operations to beneficial uses identified by the Environmental

Auditor. Section 6.3

Assessment of implementation of the Monitoring Program. Section 7

Interpretation of monitoring results. Section 8

Implementation of recommendations made in previous audit reports. Section 9

Comment on the audit frequency. Section 10.2

Assessment of the adequacy of the Monitoring Program to determine

compliance with licence actions. Section 10.3

Verification of the Monitoring Program. Section 10.3

Recommendations. Section12

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2. Audit scope and method

2.1 Scope

The scope of the audit of landfill operation is consistent with the Appendix 6 of the

EPA (2011b) Landfill Licensing Guidelines.

2.2 Audit objective

The objective of the audit is to identify and, where possible, quantify the risk of any possible

harm or detriment to a segment of the environment caused by operation of the landfill.

2.3 Audit scope

2.3.1 Activity to be audited

The activity to be audited is the operation of the Portland Landfill including the placement of

waste.

2.3.2 Component of the activity to be considered

The audit assesses all aspects of the landfill operation. The audit also considers and makes

comment on the risk assessment and environmental Monitoring Program and progressive

rehabilitation of landfill cells, including capping of any cells.

Commentary is provided on the ability of the Monitoring Program to generate sufficient

information to enable compliance with licence conditions to be determined.

2.3.3 Segment of the environment to be considered

The segments of the environment considered is the premises including the atmosphere at the

premises, groundwater beneath the premises and any surface water on the premises, and the

environment surrounding the premises to which the activity may pose a risk. The geographical

extent includes the landfill premises and surrounding land.

2.3.4 Elements of the environment to be considered

The audit elements are groundwater, surface water, land, odour, atmosphere and

management of landfill gases, including potential off-site migration.

2.3.5 Beneficial uses to be considered

The actual and potential beneficial uses of a segment of the environment need to be identified

before any risk of harm or detriment to them can be assessed. Beneficial use is defined in

Section 4 of the Environment Protection Act 1970. Beneficial use means a use of the

environment, or any element or segment of the environment, which:

is conducive to public benefit, welfare, safety, health or aesthetic enjoyment and which

requires protection from the effects of waste discharges, emissions or deposits or of the

emission of noise; or

is declared in a State Environment Protection Policy to be a beneficial use.

Beneficial uses that are considered are those specified in State Environment Protection Policies

(SEPPs). SEPPs identify indicators to be employed when measuring environmental quality and

environmental quality objectives that are necessary to sustain designated beneficial uses.

The beneficial uses to be considered are identified in Section 6.1 of this report.

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2.3.6 Risk assessment

This audit of landfill operation reviews the method and findings of the:

Nolan Consulting (2014) S53V Audit risk assessment;

Cardno (2015b) “Hydrogeological Assessment for Leachate Level Management”; and

Glenelg Shire Council (2015) “Portland Transfer Station – Landfill Gas Risk Assessment”.

The audit updates the assessment, as appropriate, based upon the review and the evidence

obtained during the audit.

2.3.7 Period of time over which the audit is to be conducted

The audit considers operations at the landfill from 1st July 2014 to 31st December 2015 as well as

relevant past operations.

2.3.8 Audit criteria

The audit criteria are:

1. Compliance with:

Environment Protection Act 1970;

Waste Management Policy (Siting, Design and Management of Landfills) 2004;

relevant State environment protection policies;

EPA licence 22492;

the verified environmental Monitoring Program; and

progressive rehabilitation requirements.

2. The placement of waste has not had an adverse impact on the beneficial uses of the

site and its local surrounds.

2.4 Audit tasks

The audit included the following tasks:

familiarisation with landfill operations including inspection of the landfill operating area;

review of the operations including rehabilitation;

assessment of risk to the beneficial uses;

review and update of the risk assessment;

review, update, and re-verification of the environmental Monitoring Program; and

preparation of this audit report.

The Auditor undertook a site visit on 7th March 2016. During the site visit, the Auditor:

inspected relevant documents held by GSC;

interviewed GSC’s Project Planning and Facilities Manager, Resource Management

Officer, and Waste Program Manager (part);

inspected the landfill, including monitoring infrastructure and surrounds, with GSC’s

Project Planning and Facilities Manager (part), Resource Management Officer, and

Waste Program Manager.

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Selected photographs from the site visit are shown in Appendix B.

2.5 Reference documents

The key reference documents are:

Nolan Consulting (2014) “Section 53V Audit – Landfill Operation, Portland Landfill – 210

Cape Nelson Road Portland”, Service Order No. 8004179 [Appendix C];

Cardno (2015b), “Hydrogeological Assessment for Leachate Level Management -

Portland Landfill 210 Cape Nelson Road, Portland, Vic.” [Appendix D]; and

GHD (2015b) “Portland Landfill Annual Environmental Monitoring Results Report 2014/15”,

August 2015 [Appendix E]; and

Nolan Consulting (2014) includes the verified Monitoring Program.

The other main reference documents considered during the audit are listed in Section 14.

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3. Landfill development and operations

3.1 Location and area

The site address is 210 Cape Nelson Road, Portland. It is located approximately 3 km south-

south-west of the Portland town centre (Figure 1). The site is bounded by Cape Nelson Road to

the east, Malings Road to the south, McNeillys Road to the west, and Derril Road to the north.

Access is via Derril Road.

The site is approximately 33 ha in area including 14 ha which has been subject to landfilling.

3.2 Ownership

The site is understood to be owned by Glenelg Shire Council (GSC) with the exception of one

parcel of crown land.

3.3 Land use

3.3.1 Zoning

The site

Most of the site is zoned Public Use Zone 6. A small area in the north-east corner of the site is

zoned Public Park and Recreational Zone.

Surrounding land

The zoning of the surrounding land as shown in the EPA licence is:

north – PPRZ (Public Park and Recreational Zone);

south – RCZ1 (Rural Conservation Zone 1);

west – FZ (Farming Zone); and

east – PUZ5 (Public Use Zone 5).

3.3.2 Former land use

Lane Piper (2010a) noted that the eastern portion of the site (Area A), was a limestone quarry

in the late 1950’s and early 1960’s. AGC Woodward-Clyde (1992) noted that the limestone

extraction extended “more or less to the watertable”.

3.3.3 Surrounding land use

The surrounding land uses are shown in Table 3-1.

Table 3-1: Surrounding land uses

Location Description

North Grassland, scrubland, Yarraman Park (with go-cart and horse trotting track), and open

grassed paddocks.

East Cemetery. Open grassed paddock beyond cemetery.

South Open grassed paddocks and low density residential - two dwellings (Malings Road).

West Open grassed paddocks and scrubland with one residential dwelling (McNeillys Road).

Medium density residential development occurs north-east of Madeira Packet Road; about

500 m north-east of the site entrance on Derril Road.

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3.4 Landfill staging and key design features

The landfill history was researched and documented by Lane Piper (2010a) “Environmental

audit report (Groundwater - 2010)”. Landfilling commenced in the early 1960’s. The original EPA

licence was issued on 12th March 1976.

The landfill’s key features are summarised in Table 3-2. The sequence of landfill development in

Areas A, B, and C is shown in Figure 2.

Table 3-2: Key Portland landfill features

Feature Description

Landfill type Below ground with above ground mounding of the final landfill surface.

AGC Woodward-Clyde (1992) advised that the land would be pre-

stripped to 44 m AHD or a minimum of 2 m above the watertable. The

depth below ground surface is estimated to be about 6 m in the east

(Area A) to a few metres in the west (Area C).

Start of landfilling In the late 1950’s.

The original licence was issued in 1976.

Current landfill surface

area

Approximately 14 ha (includes Area A, Area B, and Area C).

Completed cells Area A (eastern area): Filling commenced in the late 1950’s – early

1960’s. Lane Piper (2010a) notes that this area was a limestone quarry

prior to filling. The base is just below the watertable. The landfill was not

constructed with a liner, below fill leachate collection system nor a gas

collection system. Rehabilitation occurred in 1983.

Area B (central area): Filling commenced in 1983. Filling is understood

to have been completed in 2013. The landfill has not been constructed

with a liner, below fill leachate collection system nor a gas collection

system. The Works Approval documentation (AGC-WWC; 1992) advised

that the land would be pre-stripped to 44 m AHD or a minimum of 2 m

above the watertable.

Operating cells Area C (western area, and south of Leachate Storage Dam): Filling

commenced in 1992. Filling was still occurring as of 7th March 2016. The

landfill has not been constructed with a liner, below fill leachate

collection system nor a gas collection system.

The feature survey conducted on 8th September 2014 found the lowest

point on the excavated surface that was about to be filled was

43.62 m AHD. The Berry Whyte Surveyors feature survey of 21st

September 2016 had a low point of 43.3 m AHD in the excavated area.

GSC advised that some areas of overfill were identified in the

September 2016 topographical survey of the landfill.

Dedicated asbestos cell

About 100 m to the west of the weighbridge (western part of Area B).

Future cells Nil

Cell 4 has been withdrawn from the current licence.

Waste placement method Deposited in layers between daily cover.

Fill depth Variable; up to 15 m.

Floor and wall treatment Nil.

Capping Area A: Has a cap that varies from 0.25 m and 0.70 m in thickness of

predominantly silty sand or sandy silt (Senversa; 2013). The cap does not

currently meet the EPA (2015a) Landfill BPEM requirements.

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Feature Description

Arrangements for recapping of Area A, excluding segments with

mature vegetation, have been proposed and accepted by the EPA

(Section 4.5).

Areas B&C: GSC has advised that an interim cap has been placed over

these areas and that the thickness is about 300 mm.

Gas collection Nil.

Leachate management Subsurface leachate collection system

There is no subsurface leachate collection system below Areas A, B,

and C.

A leachate collection sump has been installed in the north-east corner

of the operating area in Area C. This is pumped to the Leachate

Storage Dam.

Leachate Interception System (LIS)

A Leachate Interception System (LIS) was installed in 1993. It was

designed by AGC Woodward-Clyde (1991). The LIS currently includes

four operating interception bores (IB4, IB5, IB6R, and IB7) located along

the northern boundary that pump to the leachate storage dam

located to the north-east of Area C. The pumps are operated with

compressed air sourced from the insulated compressor house on the

northern boundary of the site to the west of the entrance gate.

The leachate collection system is shown in Figure 5.

Leachate Storage Dam

The Leachate Storage Dam was designed by AGC Woodward-Clyde

(1992) to be 200 m long, 65 m wide, and about 3.5 m deep (including

0.5 m of freeboard). The design allowed for an engineered liner of clays

with a hydraulic conductivity of 2x10-8 m/s. The design drawing

provided by GSC show the dam with a 300 mm compacted clay liner,

a floor level of 42.0 m AHD, and a crest level of 47.0 m AHD.

GSC advised that the dam always holds water, has never overflowed,

has not been pumped, and has not been desludged.

During January 2015, Berry & Whyte Surveyors Pty Ltd surveyed the

elevation of the walls, floor, and water level in the dam (and installed a

graduated survey pole near the north-west corner of the dam for water

level monitoring). At the time of the survey, the water in the dam was at

approximately 42.55 m AHD. The surveyed depth of the dam from top

of bank to floor is approximately 5.0 m, and the floor elevation of the

dam is approximately 42.0 m AHD. Allowing 0.5 m freeboard, and

assuming 14,000 m2 surface area, the dam storage volume is about

63 ML.

GHD (2015a) assessed the dam liner permeability and thickness.

Laboratory permeability test results (using tap water) reported the

permeability range of 4 x 10-9 m/s to 1 x 10-10 m/s. Cardno (2015b)

suggested the liner permeability may be higher as the salinity of water

in the dam will be higher than tap water.

Leachate pooling adjacent McNeillys Road

In 2012 leachate pooling was observed in a shallow depression on the

western boundary of Area C adjacent to McNeillys Road. Excess

stormwater was collected and pumped to the Leachate Storage Dam.

Although the shallow depression has been filled leachate still is

understood to occasionally collect at this location after heavy rains.

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Feature Description

Under these circumstances the leachate is pumped into the Leachate

Storage Dam.

This area was dry at the time of the 7th March 2016 site inspection.

Former sub-soil cut-off drain

GSC provided information to Lane Piper (2010a) that indicated that a

sub-soil cut-off drain had been constructed to a depth of 1 m below

the fill batter in response to the unlicensed discharge of leachate to

Derril Road in 1991. This cut-off drain was connected to a sump from

where it was recycled back into the landfill. There is no evidence that

suggest that this system still exists.

Stormwater management The GHD (2011) “Report for Further Investigation of Waste Disposal

Options – Stormwater Management Plan found that the site has no

formal drainage channels or stormwater treatment ponds designed to

manage surface water runoff.

Any water that is not evaporated, transpired by vegetation or infiltrated

into the waste mass is conveyed along internal roads following the

existing grade. Surface runoff from contaminated areas potentially

combines with uncontaminated flows through the site. Surface runoff

from the site is not captured in formal sedimentation ponds and there

are no formal means of determining whether site runoff is

contaminated.

The southern boundary of the site has an open channel (up to 2 m

deep) on the northern side of Malings Road that captures runoff from

both external catchments and the existing landfill area that drains

towards Malings Road. The channel drains to the east and west from a

topographic highpoint on the Malings Road stormwater drain midway

between McNeillys Road and Cape Nelson Road. Drainage flows to

the east are piped under Cape Nelson Road.

Drainage flows to the west of this point on Malings Road travel in a

westerly direction, then in a northward direction along the eastern side

of McNeillys Road, and then in an easterly direction along Derril Road. It

is then diverted, near the Derril Road entrance to the landfill, to the

north-east into a depression located south of Madeira Packet Road.

The drain on the eastern side of McNeillys Road is a densely vegetated

open channel (up to 0.5 m deep).

Stormwater from the east of the site entrance flows along Derril Road

and under Cape Nelson Road to the east. This stormwater is then

directed into a stormwater drain running alongside Cape Nelson Road.

The following infrastructure is located within the site:

site office and weighbridge;

toilet near the site office;

shed behind site office;

shipping container;

transfer station and recycling facility; and

transfer station shop.

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The site offices and weighbridge are situated in the centre of the site on the site access road

off Derril Road. The access road is asphalted near the entrance and then gravelled.

The transfer station and recycling facility is located directly west of the site offices. It includes

recycling skips for scrap steel, concrete, and brick rubble. Waste oil and batteries are

accepted and stored. The waste oil is stored in a self bunded tank. The batteries are stored in

a covered area. Tyres, mattresses, whitegoods, and electronic waste are segregated on-site.

There is limited on-site use for crushed concrete as crushed limestone is now used as access

road aggregate.

The new transfer station, which is scheduled to commence operation in July 2016, will include

a transfer station building, a gatehouse (weighbridge and site office), a recycling building, and

small storage sheds for specialised wastes and general equipment. As such the existing site

office, weighbridge, transfer station, and recycling facility will be decommissioned.

Commercial and household separated green waste is also accepted at the site.

Overhead 500 kV transmission lines run through the site in a north-west to south-easterly

direction towards the Alcoa’s Portland Smelter. The maximum allowable landfill level below the

transmission lines is understood to be 44 m AHD.

GHD, on behalf of GSC, sought AusNet Services approval to allow part of the transfer station

to be built within the 30 m easement on either side of the centre line of transmission line towers.

This approval was provided with conditions in August 2014.

3.5 Landfill life

The landfill is scheduled to close on 1st July 2016. This is subject to the transfer station being

commissioned by this date.

3.6 Facility operator

The site is operated by GSC. Site operations include the landfill and will include the new transfer

station and ancillary facilities.

3.7 Human resources

Responsibility for managing the landfill is with GSC’s Project Planning and Facilities Manager.

Other staff that have landfill responsibilities are:

Resources Management Officer;

Waste Program Manager;

Facility Maintenance Co-ordinator (for LIS operations)

Weighbridge Attendants (one full time and casual part time);

Compactor Operator (one full time and casual part time); and

casual staff provide relief, collect litter and undertake other support activities.

The landfill staff report directly to the Resources Management Officer. GSC’s Facilities

Maintenance Officer manages and maintains the leachate interception system.

Hollyrock Hire is contracted to excavate to 44 m AHD, to place cover material at the end of

each day, to operate the compactor on weekends, and to undertake the mulching of green

waste. Kelcar is contracted to transfer on-site skips from the transfer station to the landfill. This

includes asbestos.

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3.8 Landfill operations

A commentary of some key operational aspects based upon the site inspection, discussions

with GSC staff, and a review of key documents is presented below.

3.8.1 Receipt of waste at weighbridge

Wastes accepted

Historical

Prior to 1992, Lane Piper (2010a) found that the following waste products had on occasions

been accepted at the landfill:

waste oil and petroleum product up to 1977;

15 to 20 tonne of off-specification PVC product containing less than 20 ppm residual vinyl

chloride monomer;

offal and fish waste up to 1989; and

phenol contamination of an unknown source (reported by EPA in 1989).

The amended licence, as of 1992, allowed for industrial, commercial, and trade activities into

Areas B and C excluding:

liquid wastes including waste oils;

soluble chemical wastes;

prescribed wastes other than asbestos wastes;

infectious wastes, pharmaceutical wastes and pathological wastes;

triple interceptor and grease trap wastes;

automotive batteries; and

nightsoil wastes; and hazardous wastes.

Current

The landfill is currently licensed to receive:

putrescibles waste;

solid inert waste;

pneumatic automotive tyres shredded into pieces less than 250 millimetres in all

dimensions;

asbestos waste of domestic origin; and

asbestos (all forms).

The Auditor notes that on 21st June 2010 the EPA advised GSC that recreational fish waste and

fish waste from processors (provided that it is dewatered and untreated) are not prescribed

wastes. Dead animals are accepted as putrescible waste.

Most green waste that is received and mulched at the site is landfilled. A lesser component is

occasionally used as cover material. GSC is investigating future organic processing options.

Although synthetic mineral fibre (SMF) from the Portland Aluminium Smelter is classified as an

industrial waste and hence can be accepted at the landfill, GSC does not accept it at present

as it has not developed OH&S protocols to address the fibre content.

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Asbestos waste of a domestic origin and occasional commercial loads, through pre-existing

arrangements, are accepted at the facility. The asbestos is placed in an on-site skip and

disposed of at the dedicated area within the landfill when the skip is near full.

Waste quantities

As of 30th June 2011 the residential population of the Glenelg Shire was 19,843. The Portland

landfill services this population, excluding that serviced by the Casterton landfill and the

Dartmoor and Nelson transfer stations, as well as commercial operators.

Glenelg Shire Council’s EPA levy payment data spreadsheet provides data on the quantities

of waste received at the landfill since 2007-08. The breakdown is presented in Table 3-3.

Table 3-3: Waste quantities received at Portland Landfill (tonne)

Year Municipal Commercial Prescribed Total

2007-08 8,664 2,560 291(1) 11,515

2008-09 8,313 1,357 485(1) 10,155

2009-10 8,942 1,146 244 10,332

2010-11 9,347 795 214 10,335

2011-12 6,723 638 213 7,574

2012-13 21,721(2) 2,028 187 23,936

2013-14 23,433(3) 1623 101 25,157

2014/15 11,846 1,359 76 13,281

2015/16 (to 31st Dec)

Oct-Dec qtr.

7,477.6 616.9 20.2 8114.4

(1) The prescribed waste in 2007-08 was asbestos only. The 2008-09 prescribed waste was asbestos and fish.

(2) Includes 16,429 tonne of soil specifically sourced from projects to be used as cover material. Most of the

soil is obtained from Council stockpiles. A minor component is understood to be obtained from

industrial sources.

(3) Includes 17,300 tonne of soil specifically sourced for cover material.

The post 2013-14 reduction in the quantity on municipal waste is due to a reduction in the use

of cover material.

Private self-haul traffic is restricted to the transfer station.

Operating hours

The landfill is open from 8.00 am to 4.30 pm from Monday to Friday and 8.30 am to 4.30 pm on

Saturdays, Sundays, and public holidays.

Weighbridge

The weighbridge is manned during all operating hours.

3.8.2 Transfer of waste to active landfill cell

The landfill receives municipal waste from GSC collections and commercial waste contractors.

The landfill is closed to self-haul public traffic.

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3.8.3 Tipping of waste at active landfill cell

The tipping face was observed during the audit site inspection of 7th March 2016. The tipping

area was about 20 m in width and the height of fill following compaction was less than 2 m.

The observed wastes at the tipping face were acceptable wastes under the EPA licence.

3.8.4 Compaction of waste and daily cover placement

The wastes at the tipping face are compacted each day.

Daily cover is mainly sourced from waste soil from Council road works and developments. Lesser

quantities are sourced from green waste mulch and in-situ soil. Daily cover is not removed from

the active tipping face at the commencement of each day.

The Compactor Operator visually inspects the cover to determine if the 300 mm requirement is

met. GSC advised that while they have attempted to apply 300 mm of cover material over the

active filling area at the end of each day, a lesser height has been applied on several

occasions due to difficulties in securing off-site supplies. Evidence of lesser quantities applied

are found in the completed Monitoring and Compliance Daily Checklists and the 2140-15 levy

statement. This non-compliance is also stated in the 2014/15 Annual Performance Statement.

The audit inspection of 7th March 2016 found that litter was emerging through the southern and

western segments of Area C (see photographs). Further cover is required to prevent the off-site

migration of litter.

3.8.5 Odour occurrences

GSC advised that no odour complaints were made over the July 2014 to December 2015 audit

period.

No significant odour was identified beyond the property boundary during the 7th March 2016

audit inspection.

3.8.6 Litter management

Litter is managed as follows:

a permanent cyclone fence surrounds the site except for Area A. GSC has advised that

the fences are located within the property boundary;

2.5 m x 2.5 m mobile litter fences are used in selective areas around the active tipping

face;

an internal litter fence along the southern boundary of the Leachate Storage Dam;

daily cover is applied at the tipping face;

litter is collected about three times per week; and

additional litter collections are undertaken when required by GSC staff.

GSC advise that off-site litter occurrences are infrequent as a result of high winds and only

occur on McNeillys Road to the west. Over the July 2014 to December 2015 audit period GSC

advised that no litter complaints were made.

At the time of the 7th March 2016 audit site inspection some litter was observed within isolated

non-active areas of Area C and along the western boundary (inside of the fence-line). GSC

intend to install further temporary litter fencing to the west of the operating area.

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3.8.7 Mobile plant and equipment

The on-site vehicles include a Komatsu compactor, a traxcavator, a front end loader and a

ute. The Komatsu compactor is fitted with a reversing beeper. The ute is used to cart water for

dust suppression.

With the exception of the traxcavator, which is hired from Hollyrock Hire Pty Ltd, the above

vehicles are Council owned. These vehicles are maintained as part of Council’s vehicle

maintenance schedule (either per ‘000 km or a set number of services per year).

A contractor operates the tub grinder for green waste mulching.

Diesel fuel is supplied from an on-site trailer mounted and unbunded tank.

3.8.8 On-site storage of chemicals

Waste oil is stored in a double skinned self bunded tank. Small quantities of herbicides, cleaning

fluids and petrol (less than 5 L) are stored in the garden shed. GSC is not aware of other

chemicals that are stored within the site. These chemicals will be transferred to a new shed

within the new transfer station facility.

3.8.9 Leachate Interception system

Design

As described in Table 3-2 the Leachate Interception System (LIS) was designed by AGC

Woodward-Clyde (1992). It was installed in 1993 and is operated by GSC.

The original design allowed for development in three stages.

Stage 1 is the only stage that has been implemented. This stage was designed to intercept

leachate from the “old tip” in Area A. This involved the installation of bores IB4 to IB7 along the

northern boundary of the site below Area A in 1993. These bores were required to fully

penetrate the Bridgewater Formation Aquifer (the BFA). Bore IB8 was installed in 1997.

The LIS was designed with a capacity of 0.175 ML/day (63 ML/yr). It is noted that this was based

upon the bores being screened over the full sequence of the BFA, up to 20 m, that would result

in a drawdown of 4 m at the bores and about 2 m around the interception bore field. It was

assumed that the pumps would be suction pumps that are limited to a lift of about 6 m.

These interception bores were to be operated when the down-gradient groundwater

monitoring bores showed an average 20% increase in the average background salinity or

salinity above 1,500 mg/L.

Cardno LanePiper (2014c) reviewed the LIS in 2014 and concluded that it was operating below

design capacity and provides limited control on the off-site migration of contaminated

groundwater, and that the LIS could achieve the design criteria through the operation of the

existing four leachate interception bores, supplemented with three additional leachate

interception bores.

LIS upgrade

As a consequence of this finding the LIS was upgraded during 2015. The details are provided

in Cardno (2015b) and GHD (2015c). The current leachate collection system is shown in

Figure 5.

The upgrade involved the replacement of bore IB6 with IB6R. GHD (2015c) then undertook the

following works:

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supervised a contractor to remove the existing pumps from the bores IB4, IB5, IB6R and

IB7and undertake bore development to remove accumulated silt from the bores;

install new leachate interception pumps in bores IB4, IB5, IB6R and IB7;

install automated water level loggers (counters) in bores IB4, IB7 and IB6R;

install an appropriate flow meter for a 50mm (OD) diameter high pressure poly pipe that

transfers leachate from the bores to the leachate pond.

Cardno (2015b) “Hydrogeological Assessment for Leachate Level Management - Portland

Landfill 210 Cape Nelson Road, Portland, Vic.” reports on the current status of the LIS. Details of

these leachate interception bores are presented in Table 3-4. All bores with installed pumps are

screened across the MSA and the upper part of the BFA.

Table 3-4: Leachate interception bore details [after Cardno (2015b)]

Bore Year

drilled

Screened

depth (m bgl)

Comments

IB4 1993 5.9-11.5 Under gatic cover, pump, data logger and pulse counter

installed.

IB5 1993 5.4-12.2 Under gatic cover, pump and pulse counter installed.

IB6R 2015 5.0-11.0 Under gatic cover, pump, data logger and pulse counter

installed.

IB7 1993 4.0-10.0 Under gatic cover, pump, data logger and pulse counter

installed.

IB8 1997 4.57-21.5 Standpipe – no pump fitted.

The data loggers have been installed to record the drawdown in the bores and how the levels

fluctuate over time, and to allow assessment of the performance of the pumps. The pulse

counters have been installed within the headworks of each bore to record the bore flow rates

and how they fluctuate over time, and to allow for the pump performance assessment.

The 125 mm diameter leachate interception bores are installed with PVC casing and screens.

The pulse counters record the number of pumping cycles that each bore completes and thus

provides an indication of the volume of groundwater extracted for each bore. The typical

pump volume per cycle is 0.95 L for the QED short AP4+ pneumatic pumps. [GHD(2015) advise

the pulse counters continue to record pumping cycles even if no groundwater is being

discharged, i.e. the water level falls below the base of the pump].

Cardno Lane Piper (2014c) noted that the water discharge lines connected to the pumps are

likely to require flushing or replacement, due to build-up of silt or slime that may cause partial

blockage and adversely affect system performance. GSC advised that the bores will be

purged regularly and that regular pump maintenance is planned.

Cardno Lane Piper (2015b) described IB5 redevelopment and installation of a new pump, and

monitoring of operation by GSC showed a relatively steady extraction rate, averaging

20 kL/day over six weeks. Cardno (2015b) reports the new pump in IB6R to be operating at

20 kL/day.

The ultimate number of extraction points and the optimum extraction rate will depend on the

actual system performance, and the drawdown achieved at each extraction point. This is

subject to a number of variables, including local variations in aquifer hydraulic properties, and

bore and pump performance.

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The overall performance of the system in terms of the groundwater extraction rate and

drawdown has not yet been assessed, and therefore it is not yet known whether the actual

performance of the LIS meets the design objective. The original AGC Woodward-Clyde (1991

and 1992) design include interception bores IB9 to IB11 downgradient of Area C. Groundwater

monitoring bores PO34B and PO35B were installed downgradient of Area C with suitable

diameter casing to enable the extraction of groundwater impacted by leachate, if required.

3.9 Complaints and regulatory performance

3.9.1 Complaints

There were no complaints recorded over the July 2014 to December 2015 audit period.

3.9.2 Regulatory performance

The EPA issued a Clean Up Notice NO8243/90001966 for the landfill on 3rd March 2010 (EPA:

2010). The notice specified that both groundwater and landfill gas audits were to be

undertaken and that a Clean Up Plan be prepared to address any Clean Up and ongoing

management issues within a time-bound framework.

The Portland Landfill Clean Up Plan was prepared by GSC (2011a) in accordance with these

requirements as well as the recommendations of both the Environmental Audit Reports for

Groundwater (LanePiper; 2010a) and Landfill Gas (LanePiper; 2010b). The CUP includes

timeframes to achieve the audit recommendations.

The EPA revoked the CUN on 19th November 2014.

The EPA issued a post closure supporting Hydrogeological Assessment (HA) Pollution

Abatement Notice (PAN) [Notice ID: 90005080] for the landfill on 10th November 2014. The HA

report must be supplied to the EPA by 31st December 2015. The HA was undertaken by Cardno

(2015b) and verified by John Nolan as the EPA appointed auditor. The HA was submitted to the

EPA on 11th December 2015 together with the letter of verification. As a result the EPA revoked

the PAN on 28th January 2016.

A draft Aftercare Management Plan post closure PAN has been issued.

Annual Performance Statement

The 2014/15 Annual Performance Statement (GSC; 2015) identified that GSC has complied with

all operations related licence conditions except for:

LI_G1 Waste from the premises must not be discharged to the environment except

in accordance with this licence.

See response to Condition LI_L5 and LI_DL1.

LI_L3 By the end of each day's operations waste must be covered with a layer of

soil at least 0.30 metres thick or using another method of cover approved by

EPA.

Due to insufficient available material for daily cover, height of cove on some

occasions limited to 0.2 m. GSC advised staff are putting in measures to

ensure adequate cover material available.

LI_L5 You must prevent emissions of landfill gas from exceeding the investigation

levels specified in Best Practice Environmental Management, Siting, Design,

Operation and Rehabilitation of Landfills (EPA Publication 788).

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Exceedances of EPA(205) BPEM LFG Action levels recorded on 23rd July 2014,

30th October 2014, 5th February 2015,and 30th April 2015 monitoring events. An

analysis of the exceedances is provided in Section 8.5. GSC advised of the

action taken in response to the non-compliances. This included the

installation of a background LFG monitoring bore, committing to a LFG

collection system for Area C and placement of additional cover material in

areas of elevated methane emissions at the surface.

L1_L8 You must ensure that an independent annual survey is conducted for each

landfill cell to (a) determine the quantity of waste deposited and verify the

amount of landfill levy payable, (b) demonstrate the need for any new cells

and (c) confirm that cell heights are less than the approved pre-settlement

contour plan.

The July 2015 survey indicated parts of Stage 3 (Area C) have been overfilled.

GSC committed to reprofiling to ensure the top of waste levels complied with

the PSCP.

L1_L9 You must manage each landfill cell so that it’s final contour (including the

landfill cap) prior to settlement is not higher at any point than the pre-

settlement contour plan shown in Schedule 1.

See response to Condition LI_L5 and LI_DL1.

L1_DL1 You must not contaminate land or groundwater.

Non-compliances were identified from the analytical results associated with

the 23rd July 2014, 30th October 2014, 5th February 2015, and 30th April 2015

monitoring events. These results indicated a leachate plume extending at

least 400 m and possibly 550 m down gradient of the landfill. In response, GSC

subsequently upgraded the LIS.

On 5th November 2015 GSC advised the EPA that they are now compliant with licence

conditions LI_L8 and LI_L9. The survey by Berry and Whyte Surveyors Pty of 28th October 2015

confirmed that the landfill surface had been reprofiled to remove the excess waste so that the

surface was consistent with the top of waste PSCP.

EPA Inspections

The EPA did not undertake any site inspections during the audit period.

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4. Implementation of progressive rehabilitation

This audit of landfill operation is required to determine if progressive rehabilitation is being

suitably implemented. Suitable implementation is deemed to occur if all filled cells are

rehabilitated, planned cell rehabilitation is underway, or the landfill operator can demonstrate

that rehabilitation works are programmed for timely commencement.

Landfill cell rehabilitation works include:

capping and revegetation in accordance with regulatory requirements and the EPA

(2015a) “Best Practice Environmental Management Siting, Design, Operation and

Rehabilitation of Landfills”;

capping in accordance with EPA approved design;

installation and ongoing maintenance and replacement of gas and leachate collection

infrastructure; and

decommissioning of infrastructure no longer required.

These matters are addressed in GHD (2013), “Portland Landfill – Landfill Rehabilitation Plan” of

October 2013. This report was approved by the EPA.

4.1 Existing capping

Area A was capped in 1983. GSC has provided anecdotal advice that the cap is about

600 mm thick.

In early 2013 Senversa (2013) undertook a site investigation to confirm the thickness and

composition of the cap in Area A. Eighteen test pits were excavated in an approximate grid

pattern across the area. The thickness varied between 0.25 and 0.70 m, with the majority of

locations having less than 0.5 m. Soil types were predominantly silty sand or sandy silt, however

the consistency of cover soils varied across the investigation area. In addition to silty sands and

sandy silts a range of soils from clay to gravelly sands were encountered.

The cover soils were dry of optimum moisture content with the moisture increasing slightly in a

number of test pits once waste was encountered. Leachate was not encountered. Slight landfill

gas odours were noted once waste was encountered. In general the cover soils were not

compacted.

An interim cap of about 300 mm (daily cover) is understood to have been placed over Area B

or Area C where the waste is at the pre-settlement top of waste level. Lane Piper (2010b) noted

1.0 m of stiff to hard silt clay above waste at monitoring bore LFG 13 in Area B which suggests

that the capping may be more extensive in some places than 300 mm of daily cover.

4.2 Rehabilitation Plan

The Rehabilitation Plan identified three stages. Alignment of these stages with the landfill areas

is provided in Table 4-1.

Table 4-1: Correlation with rehabilitation stages with filling cells/areas

Landfill Stage Cell/Area

1A A (central and eastern)

1B A (western) + B (north-east)

2 B

3 C

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4.3 Scheduling

The proposed capping schedule is presented in Table 4-2.

Table 4-2: Capping schedule

Capping Phase Landfill Stage Commence Complete

1 1A(1), 1B, and 2 2016-17 (Qtr1) 2016-17 (Qtr4)

2

3 including asbestos disposal area

2017/18 (Qtr2) 2017/18

(Qtr4)

The completion date for Capping Phase 2 (Stage 3) is consistent with the GHD (2013)

Rehabilitation Plan. Rehabilitation of the landfill is nominated as a priority program within GSC’s

adopted Strategic Financial Plan 2014/2015 – 2023/2024, with a budgeted expenditure

allocation of $10.1 million.

4.4 Finished surface level

The EPA approved top of waste pre-settlement contour plan (PSCP) is attached, as

schedule 1C, to Licence 22492 as amended on 30th June 2014.

The PSCP shows separate mounds in Stage 1A, Stage 1B, Stage 2 and Stage 3 with a maximum

level of 53.5 m AHD in Stage 3. The pre-settlement slopes are generally within the EPA (2015a)

Landfill BPEM recommended range of maximum of 1:5 (20%) to 1:20 (5%). Slopes of greater

than 5% are limited to filled areas located at the perimeter of the waste mass where the landfill

batters down to the surrounding natural surface.

4.5 Design progress

4.5.1 Phase 1

This phase of the cap construction involves remediating the existing cap in accordance with

the EPA-approved Rehabilitation Plan (GHD; 2013).

Removal of the existing mature native vegetation is not proposed around the edges of

Stage 1A (the very eastern part of the site), within a thin corridor along the southern fringe of

Stage 2 and the adjoining road reserve (Malings Road) as it was considered that the

environmental damage in removing the vegetation outweighed the environmental benefit in

remediating the cap to cover the full extent of waste. Thus the existing cap in these areas will

not be remediated.

The Technical Specification, Design Drawings and CQA Plan were prepared by GHD (2015e),

GHD (2015f), and GHD (2015g)]. The design included two capping profile options.

The option 1 capping profile is as follows:

topsoil 0.2 m;

low permeability clay 0.5 m (minimum).

subgrade fill as required to meet top of waste PSCP level

The option 2 capping profile is as follows:

topsoil 0.3 m

soil sub-base 0.3 m;

geosynthetic clay liner

subgrade fill as required to meet top of waste PSCP level

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The design was reviewed by Wajahat Bajwa (GHD; 2015h) as the environmental auditor

appointed under the Environment Protection Act 1970 and subsequently accepted for the

capping of Stages 1 and 2 by the EPA on 12th January 2015.

GSC is seeking tenders for both design options.

Phase 2

A Type 2 landfill cap [Table 8.1 of the EPA (2015a) Landfill BPEM is proposed for Phase 2 (Stage

3 including asbestos disposal area).

It is as follows:

topsoil and soil sub-base – 1.0 m;

filter geotextile;

protection geotextile;

LLDPE geomembrane; and

low permeability clay – 0.5 m (minimum).

The optional gas collection layer is not proposed as a passive LFG collection system is to be

installed (See Section 4.7). Similarly, due to the proposed slopes of the final surface profile it is

not presently intended that the optional drainage layer be provided.

4.5.2 Auditor verification

The EPA advised GSC on 12th August 2014 that all construction phases should be verified by an

Auditor as per EPA (2011b) and that the proposed management of the existing vegetation is

acceptable provided that the potential risks from the landfill is minimised/controlled.

4.6 Stormwater drainage

All surface drainage around the landfill will be located within the property boundary.

The Rehabilitation Plan (GHD; 2013) advises that the size and grades of the drains will be

defined during detailed design of the cap. The sizing of the drains will be based on

containment and control of a 1 in 20 year storm event with adequate freeboard and the

containment of a 1 in 100 year event with no freeboard. The drain grades should result in flow

speeds that reduce the risk of cap erosion but allow the water to exit the landfill area fast

enough as to limit percolation of runoff water through the cap.

The final design is likely to include one retardation/sedimentation pond. It is noted that the

superseded GHD (2011) stormwater management plan included a 0.5 ML capacity pond in

the south west corner and a 2.5 ML capacity pond in the north-east corner.

It is also understood that the stormwater flows into the northerly sloping drainage line from the

Derril Road entrance to the landfill, which flows into a depression located south of Madeira

Packet Road, will be diverted along Derril Road to the east.

The stormwater drainage system of the Phase 1 cap is to be comprise of:

drainage constructed along the perimeter of the cap;

cap surface diversion drains; and

and diversion bunds

to the grades and levels indicated in the Drawings.

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The cap surface diversion drains and bunds are designed to direct runoff water from the cap

towards the perimeter diversion drains and then to the discharge locations. The drains will also

assist in preventing runoff water from flowing into adjacent private land.

The perimeter and cap diversion drains are to be constructed in accordance with BPEM

Guidelines for Stormwater Management. The clay cap diversion bunds are to be installed on

the slope of the final cap. These bunds shall be installed as part of the liner, prior to placement

of the topsoil layer.

The stormwater drainage system for the Phase 1 cap does not appear to involve the

construction of sedimentation pond(s) and remediation of the existing perimeter drainage

systems. This will be required as part of the Phase 2 capping.

4.7 Landfill gas management

Based upon 20,000 tonne of waste being deposited and applying LMS (2007) estimated that

the landfill is likely to generate about 760 tonne/yr of methane and up to 16,000 tonne/yr of

carbon dioxide equivalents (t CO2-e). Prior to the decision to close the landfill LMS (2007)

estimated that LFG emissions will peak at about 200 m³/hr.

Section 6.7.1 of the EPA (2015a) “Best Practice Environmental Management Siting, Design,

Operation and Rehabilitation of Landfills” suggests the following as potentially suitable landfill

gas treatment technologies for LFG generation rates of greater than 100 m3/hr and less than

250 m3/hr:

power generation;

high-temperature flaring;

low calorific flaring; and

other oxidation technology and discharge (e.g. passive flares, biofilters, and biocovers).

LMS (2007) considered power generation and flaring as possible alternatives. Passive systems

were recommended against. It was noted that about 300 m3/hr is typically required for a 1 MW

power plant.

4.7.1 Phase 1

LFG collection is not incorporated into the Phase 1 cap design.

4.7.2 Phase 2

The Rehabilitation Plan (GHD; 2013) includes a passive LFG collection system for Phase 2

(Stage 3) to be installed during cap construction.

The proposed LFG management system included:

a horizontal gas collection system installed immediately below the final cap;

riser pipes incorporating valves will be connected to the horizontal collection pipes to

enable the collected gas to be brought to the surface for treatment; and

a gas flare of sufficient capacity to flare all methane collected through the network.

GHD (2013) recommended that should the LFG generation rates, post collection system

installation and/or the perimeter LFG monitoring bore network emissions exceed the gas action

levels specified in Table 6.4 of EPA (2015a) “Best Practice Environmental Management Siting,

Design, Operation and Rehabilitation of Landfills”, consideration would be given to upgrading

the passive system to an active system by provision of a blower / booster (vacuum pump) or

to complement the horizontal system with vertical bores installed into the waste mass.

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4.8 Conclusion

GSC has scheduled the landfill to close following the commissioning of the transfer station. This

is expected to occur in mid-2016.

The Technical Specification and Construction Quality Assurance Plan for Phase 1 Capping

(Stages 1 and 2 cap) have been completed and accepted by the EPA.

Phase 1 capping is expected to commence in the 1st quarter of 2016-17. The delay from that

scheduled in the Rehabilitation Plan is due to the need to address native vegetation

management issues as required under Environment Protection and Biodiversity Conservation

Act 1999 and to consider alternative capping design options.

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5. Conceptual site model

The Conceptual Site Model (CSM) has been developed by Lane Piper (2010a&b), Cardno

LanePiper (2011a&b), Cardno LanePiper (2014b&c), and Cardno (2015b). It is consolidated

below and is informed by the description of the landfill and its operations as discussed in

Section 3.

The CSM describes the physical conditions as well as the pathways and receptors for key

hazards associated with each environmental element.

5.1 Climate

Meteorological data has been obtained from the Portland Meteorological Station (No. 90700).

Portland has a temperate climate with warm summers. The mean annual precipitation from

1857 to 2012 was 838 mm with the wettest month being in July (108 mm) and the driest month

being in February (33 mm).

The mean monthly evaporation ranges from 33 mm in July to 132 mm in December. Rainfall

typically exceeds pan evaporation from May to September.

5.2 Topography

Regionally the land falls away to sea level at Fawthrop Lagoon which is located 1.7 km to the

north-north-east.

The topography of the site has been modified by past quarrying and landfilling activity. The site

has a top of mound level of about 50 m AHD immediately to the east of the site office. From

here the land slopes to the north, north-east, south and south-east-south.

5.3 Soils

The soils are formed from the siliceous sands of the Malanganee Sands Formation that covered

most of the site prior to quarrying.

5.4 Hydrogeology

The hydrogeological information presented below is sourced from the various site specific

references (Section 14) and in particular:

Geological Survey of Victoria SV (1978) “Portland 1:63,000 Geological Map Sheet”;

Cardno LanePiper (2014b) “Hydrogeological Assessment - Portland Landfill at 210 Cape

Nelson Road, Portland”;

Cardno (2015b), “Hydrogeological Assessment for Leachate Level Management -

Portland Landfill 210 Cape Nelson Road, Portland, Vic.”; and

logs of on-site constructed groundwater and leachate monitoring bores.

5.4.1 Groundwater and leachate monitoring bore details

Twenty four groundwater monitoring bores were drilled on the site and immediate surrounds

between 1989 and 1997. These were termed monitoring bores PO01to PO24. These bores were

drilled to depths ranging from 3.5 m to 29 m. In 2012 six of these bore were replaced with new

bores as the original bores were dry, lost or damaged. These bores have the same number as

the original bores except for the suffix of “R”. An additional 15 bores, including five nested sites,

were installed between 2013 and 2015 under the supervision of Cardno.

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The locations of all monitoring bores are shown in Figure 3 and the details are summarised in

Table 5-1. Bore logs are shown in Cardno LanePiper (2014b) and Cardno (2015a).

Table 5-1: Groundwater monitoring bore details [Cardno LanePiper (2014b) & Cardno (2015a)]

Bore Year Aquifer(1) Aquifer, Location Screen

(m bgl)

Comments

PO1 1989 MSA/BFA South side of Derril Road. 7.0-19.0 Good condition.

PO2 1989 MSA/BFA North side of Malings Road. 6.0-18.0 Good condition.

PO3 1989 MSA/BFA East side of McNeillys Road, in clearing. 4.0-16.0 Lost.

PO4 1990 MSA South side of McNeillys Road, along

road.

2.0-10.0 Covered by a felled

tree from January to

April 2015.

PO05R 2012 MSA/BFA/

NVA

Road Reserve along south side Derril

Road. West side of road.

4.68-7.68 Replacement of dry

bore.

PO06 1990 MSA/BFA/

NVA

South side of Derril Road. 1.5-11.75 Good condition.

PO07 1990 MSA/BFA South side of Derril Road. 2.0-12.0 Good condition.

PO08R 2012 MSA South side of Derril Road. 1.0-4.0 Replacement of dry

bore.

PO09 1992 MSA North of Malings Road, near intersection

with Cape Nelson Road.

6.5-9.5 Good condition.

PO10 1992 MSA North of Malings Road. 1.5-3.5 Under water in three

of four 2013/14

monitoring events.

PO11R 2012 MSA East side of Derril Road. 2.3-5.3 Replacement of dry

bore/destroyed

bore.

PO12 1992 MSA West side of Madeira Packet Road. 1.5-3.5 Good condition.

PO13 1992 MSA South west corner of Yarraman Park.

Inside Yarraman Park, within tracks.

1.0-7.0 Good condition.

PO14 1992 MSA Inside Yarraman Park, East side of park. 2.0-8.0 Good condition.

PO15R 2012 MSA North West corner of Yarraman Park.

Inside Yarraman Park, along the tracks.

2.5-7.0 Replacement of dry

bore.

PO17 1997 MSA/BFA East of Cape Nelson Road. 3.3-28.5 Good condition.

PO18R 2012 MSA East of Cape Nelson Road. 3.0-6.0 Replacement of dry

bore.

PO19R 2012 MSA/BFA Road Reserve along south end of Derril

Rd. East side of road.

3.0-6.0 Replacement of dry

bore.

PO20 1997 MSA/BFA North of Derril Road and IB6R. 3.65-25.5 Good condition.

PO21 1997 MSA/BFA Cnr. Derril Road & Cape Nelson Road. 2.4-28.6 Good condition.

PO22 2010 MSA South-east of Yarraman Park. 0.8-3.8 Good condition.

PO23 2010 MSA Along Cape Nelson Road. 0.9-3.9 Good condition.

PO24 2010 MSA Along Cape Nelson Road. 0.9-3.9 Good condition.

PO25 2013 NVA Derril Rd near entrance. 15.0-18.0 Good condition.

PO26A 2013 MSA South-west corner of site. 2.5-5.5 Good condition.

PO26B 2013 BFA Adjacent PO26A. 10.5-13.5 Good condition.

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Bore Year Aquifer(1) Aquifer, Location Screen

(m bgl)

Comments

PO28 2013 MSA Derril Rd - Cape Nelson Rd cnr. 2.0-5.0 Good condition.

PO29 2013 BFA Nolan123. 11.5-14.5 Good condition.

PO30 2013 BFA Madeira Packet Rd - Cape Nelson Rd

cnr.

12.0-15.0 Good condition.

PO31A 2013 MSA North, on Madeira Packet Rd. 3.0-6.0 Good condition.

PO31B 2013 BFA Adjacent PO31A. 12.0-15.0 Good condition.

PO32 2013 BFA South of PO31A. 5.5-8.5 Good condition.

PO33A 2013 MSA North-east of Derril Rd entrance. 0.5-2.5 Good condition.

PO33B 2013 BFA Adjacent PO33A. 6.0-9.0 Good condition.

PO34A 2015 MSA 30 m north-west of leachate storage

dam.

1.0-4.0 Good condition.

PO34B 2015 BFA Adjacent PO34A. 5.0-11.0 Good condition.

PO35A 2015 MSA North-west of Derril Rd entrance. 1.0-4.0 Good condition.

PO35B 2015 BFA Adjacent PO35A. 5.0-11.0 Good condition.

(1)

MSA - Malanganee Sands Aquifer

BFA - Bridgewater Formation Aquifer

NVA - Newer Volcanic Aquifer

While most of the original bores were screened across the shallow Malanganee Sands

Formation (MSA) and the deeper Bridgewater Formation (BFA) aquifers, the 15 bores installed

from 2015 onwards were screened in single aquifers only.

It was intended that monitoring bores PO34A/B and PO35A/B be installed directly

downgradient of the leachate storage dam to monitor groundwater directly down-gradient of

Area C. It was not possible to install these bore at the targeted locations due to the presence

vegetation that would require approval under the Environment Protection and Biodiversity

Conservation Act 1999 to establish an access track and the presence of fill to the north-east of

the leachate dam (which had not previously been mapped).

Due to these constraints monitoring bores PO34A/B were installed north-west of the leachate

pond and monitoring bores PO35A/B were sited on the southern ‘verge’ of Derril Road. The

rationale was that these bores would monitor potentially impacted groundwater from both the

leachate storage dam and from Area C. Monitoring bores PO34B and PO35B have been

designed so that they can be converted to LIS interception bores if required.

The locations of leachate monitoring bores are shown in Figure 3 and summary details are

presented in Table 5-2.

Table 5-2: Leachate monitoring bore details [Cardno LanePiper (2014b) & Cardno (2015a)]

Bore Year

drilled

Area Location Screened

depth

(m bgl)

Comments

LB01 2012 C Approx. 130m south-west of

Leachate Storage Dam.

4.5-7.5 Operational

LB01A 2015 C Installed in February 2015

Adjacent LB01

1.0-8.9 Operational

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Bore Year

drilled

Area Location Screened

depth

(m bgl)

Comments

LB02R 2013 B Centre of Landfill. Behind rubbish

stockpile, near transmission tower.

Decommissioned in February 2015.

4.5-7.5 Decommissi

oned

LB02RA 2015 B Installed in February 2015. Centre

of Landfill. Behind rubbish

stockpile, near transmission tower.

1.0-5.1 Operational

LB03 2012 A South of Derril Road, south of

PO07.

1.0-4.5 Operational

The leachate monitoring bore logs and construction details are provided in Cardno (2015b).

LB01A was installed in February 2015 as LB01 did not appear have sufficient depth to monitor

leachate levels in the lower part of the waste mass. LB02 was replaced with LB02R in 2013 as

the original bore had been destroyed. LB02R was decommissioned in February 2015, as the

bore was screened below the waste, and was replaced by LB02RA.

With the exception of the monitoring bores drilled in 2015, all groundwater and leachate

monitoring bores were surveyed to the Australian Height Datum in February 2014.

5.4.2 Geology

Portland is situated close to the northern margin of the Otway Basin, a major sedimentary basin

that extends from near Geelong into South Australia.

Within the local area the Otway Basin includes unconsolidated Quaternary and Tertiary

sediments of marine and non-marine origin. The stratigraphic units beneath the site are

described from oldest to youngest in Table 5-3. The outcropping regional geology is shown in

Figure 6.

Table 5-3: General Stratigraphy, Portland Area

Stratigraphic unit Lithology

Malanganee Sands Formation

(Holocene/Upper Quaternary

Age).

Thin sequence of siliceous sand dune and sheets. This covered most

of the site prior to quarrying. The 2012 and 2013 drilling programs has

found that this formation is absent in some locations.

Bridgewater Formation

(Pleistocene/Lower

Quaternary Age).

Calcareous sand and clay with various amounts of carbonite

cementation forming calcareous dunes (calcarenite) and dune

limestone. This formation ranges in depth below the surface of 9 m in

the central area of the site to about 22 m near the eastern

boundary of the site. AGC Woodward-Clyde (1992) refers to a

marine transgression sequence of clay, limestone and sand followed

by a marine regression with deposition of sand, silt, and clay.

Newer Volcanics Basalt

(Quaternary to late Tertiary

Age).

Residual clay representing weathered basalt with less weathered

basalt at depth. The basalt has occurred in several flows with a

combined thickness below the Bridgewater Formation of 25 m to

40 m.

Whalers Bluff Formation

(Tertiary aged).

This formation, which has not been identified at the site, occurs

along the shoreline cliffs east of the Portland township. It consists of

calcareous clays, silts, and sands with volcanic tuffs and shelly beds.

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Stratigraphic unit Lithology

Dilwyn Formation The Dilwyn Formation lies below the site at considerable depth

(greater than 1,000 m). It is separated from the above shallow

Tertiary sediments by an extensive thickness of marls.

All of the bores that have intersected the Newer Volcanics Basalt have identified a sandy clay

to clay sequence of 1.0 to 3.5 m thickness at the BFA/NVA interface.

The Cardno (2015b) south-west to north-east cross sections A-A’ and B-B’ are shown in Figure 7

and Figure 8 respectively. The location of these sections are shown in Figure 3.

The lithological logs of the deeper monitoring bores installed in 2013 suggest that the boundary

between the BFA and MSA is indistinct. There are references to cemented and calcareous

sediments to the north up until at least Madeira Packet Road. The depth from the ground

surface to the base if the BFA is approximately 22 m thick near the north-eastern boundary of

the site (at PO31B)

5.4.3 Aquifers

The main aquifers underlying the site and the local area are:

Malanganee Sands Aquifer (MSA);

Bridgewater Formation Aquifer (BFA); and

Newer Volcanics Aquifer (NVA).

The Dilwyn Formation is not considered to be hydraulically connected to the above shallow

aquifers due to the extensive thickness of intervening low permeability marls.

5.4.4 Groundwater levels

Based upon the water level monitoring data from the nested piezometers the MSA and BFA is

acting as a single aquifer system. While the BFA is always saturated the MSA is unsaturated in

some locations.

The interpolated watertable surface within the MSA/BFA as of April 2015 is shown in Figure 9.

The watertable slopes in a north-easterly direction from 45 m AHD in the south-west of the site

to 32.4 m AHD on the Madeira Packet Road to the north-east of the site. The gradient of the

watertable surface increases near IB4 to IB8.

The interpolated watertable level across the Leachate Storage Dam as of April 2015 ranged

from 42.0 m AHD in the south-west to 40.4 m AHD in the north-east. As the water level within the

dam can range from the floor level of 42 m AHD to the freeboard level of 47 m AHD, the

leachate storage dam is likely to recharge the underlying aquifer for most of the year.

Groundwater hydrographs for groundwater monitoring bores PO01to PO24 over the 1991 to

February 2015 period are shown in Figure 10. These hydrographs confirm that the watertable

elevation has not changed significantly over the past twenty five years.

The water level ranges from close to the surface (at monitoring bore PO13) to over 9 m below

ground level at monitoring bore PO25. PO13 is south of the Go Kart track at Yarraman Park,

and PO09 is screened within the Newer Volcanics aquifer just north of the Derril Road entrance

to the landfill.

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Although the interception bores IB4 to IB7 may have resulted in a minor steepening of the

hydraulic gradient from north to south, the influence is considerably less than the 2 m around

the borefield designed for by AGC Woodward-Clyde (1991 and 1992).

5.4.5 Groundwater movement

Recharge and discharge

Recharge to the MSA is via rainfall infiltration. Groundwater flow from the site is inferred to

ultimately discharge to the coast. There is also likely to be discharge to Fawthrop Lagoon.

Flow

The groundwater flow rate across the site is variable due to lithological heterogeneity in the.

5.4.6 Salinity

The MSA/BFA groundwater salinity (in mg/L TDS) as of April 2015 is presented as a contour plan

in Figure 12. This indicates a background salinity of about 500 mg/L to 1,200 mg/L with elevated

concentrations of up to 9,000 mg/L down-gradient to the north-east of the landfill.

The salinity of the NVA aquifer at PO25 is consistent while previously reported as ranging from

1,100 mg/L to 1,100 mg/L was 2,700 mg/L in April 2015.

Groundwater quality is discussed further in Section 8.4.

5.4.7 Aquifer parameters

Groundwater within the MSA is unconfined. It is unconfined to semi-unconfined in the BSA

becoming more confined with depth.

AGC Woodward-Clyde (1992) estimated the hydraulic conductivity of the MSA/BFA from

recovery tests at monitoring bores PO04 to PO08. The transmissivity ranged from 8m2/day to

23 m2/day with an average hydraulic conductivity of about 1 m/day.

Cardno LanePiper (2014b) undertook slug tests on six bores screened in the MSA only and two

bores were screened in the MSA/BFA on 17th July 2012. The estimated hydraulic conductivity

ranged from 0.11 m/day to 1.76 m/day (with an average of about 0.74 m/day).

Slug tests were also undertaken on monitoring bores PO34B and PO35B, both screened in the

BFA in 2014 (Cardno; 2015a). The estimated mean hydraulic conductivities were 1.87 m/day

(PO34B) and 0.04 m/day (PO34B).

AGC Woodward-Clyde (1992) estimated the storativity to be about 0.3.

5.4.8 Groundwater users

AGC Woodward-Clyde (1992) advised the BFA was the most widely used aquifer adjacent the

site and that Rural Water Corporation (now Southern Rural Water) groundwater bore records

indicate no registered groundwater users (e.g. for irrigation and industrial uses) down the

hydraulic gradient from the site.

Nolan Consulting (2013) undertook a search of the Victorian Water Resource Data Warehouse

for groundwater bores within 3 km of the landfill as part of the 2013 Audit of Landfill Operation.

“Non-groundwater”, “not known”, and “miscellaneous” bores were excluded from the search.

120 bores with known groundwater uses were identified within 3 km and 35 bores with known

groundwater uses were identified within 1 km of the landfill. Uses of these bores, within 1 km

and 3 km of the site are as listed in Table 5-4.

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Table 5-4: Summary of groundwater bores within 3 km of site (as of November 2012)

Use Within 1 km Within 3 km

Urban 0 6

Irrigation 1 2

Dewatering 0 1

Stock and domestic 7 49

Stock 5 12

Domestic 8 21

Observation 0 4

Groundwater investigation 14 25

Total 35 120

Cardno (2015b) undertook a groundwater database search of the Water Measurement

Information System in January 2015. This search confirmed the information provided in Table

5-4 for bores within 1 km of the site with the exception that the number of investigation bores

had increased from 14 to 26. The location of these bores are shown in Figure 11.

None of the stock and domestic, stock, domestic, and irrigation bores identified in the

database search are located within 1 km to the north-east of the site (in the down-gradient

direction). It should be noted that groundwater may also be utilised by unregistered bores not

appearing on the database.

None of the water supply bores (i.e. those registered for domestic, stock or irrigation use)

identified within 1 km of the site are located hydraulically down-gradient (north-east) of the site

where they may be most vulnerable to contamination from the site.

There are no on-site groundwater supply bores.

Cardno LanePiper (2014a) undertook a telephone survey of property owners with properties

within 500 m of the site boundary. The objective of the survey was to identify any unregistered

private groundwater bores within 500 m of the site boundary. Of the 61 properties included in

the survey, 41 participated. The survey was also used to determine if there are any buildings

basements located within 500m of the site boundary.

Table 5-5 presents a summary of the survey findings.

Table 5-5: Summary of telephone survey findings

Item Yes No Don’t know

Properties with groundwater bores 2 38 1

Properties with basements 0 41(1) 0

(1)Although not actually a basement, the responder from 119 Malings Road indicated that the property

is a two storey building with one room cut into a hill.

Groundwater bores were identified as being present at 119 Malings Road, immediately south

of the landfill and at Oakpark Road (about 900 m west of the site). The Malings Road bore is

used for stock watering and domestic purposes and appears to be identified as Bore 88510 on

the Victorian Water Resource Data Warehouse. The Oakpark Road bore was identified as not

being in use.

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5.5 Surface water

All stormwater from the filled landfill areas runs off into an existing surface drainage system

around the property boundary. Refer to Table 3-2 for details.

The major drainage line in the local area is Wattle Hill Creek. It flows in an easterly direction to

Fawthrop Lagoon, which discharges via a canal to the ocean at Portland Harbour. Fawthrop

Lagoon is located approximately 1.7 km to the north of the site. Wattle Hill Creek receives runoff

from the urban catchment.

There are unnamed drainage channels south and east of the site that flow in a south-easterly

direction towards the coast.

5.6 Cultural heritage sites

The EPBC database has not been searched for cultural and spiritual heritage sites.

5.7 Vegetation

In 2011 GSC (2011b) undertook a vegetation survey within the site to identify any vegetation

that was possibly affected by LFG. The survey was undertaken on a 50 m grid.

The survey found that:

although there are some areas or ‘patches’ of affected native vegetation, there was no

vegetation present on the landfill site of any State or National significance, either through

the Catchment and Land Protection Act 1994 or the Flora and Fauna Guarantee Act

1988;

the main native plants affected on-site are acacia longifolia or common name coastal

wattle. There are also some affected coastal tea trees; and

on the north-east fence line there is a large patch of brown and dying gorse. This may or

may not be because of the presence of methane.

GSC (2011b) concluded that there is only a small amount of observable vegetation that is

affected on the site by possible landfill contamination or methane.

GHD has undertaken a native vegetation and fauna survey around the property boundary as

part of the rehabilitation planning process. GSC has advised that the southern brown

bandicoot was identified during the survey.

5.8 Landfill gas

The Portland landfill gas (LFG) monitoring bore network was established by Lane Piper (2010b)

as part of the Landfill Gas Audit. It consisted of 22 monitoring probes installed around the

perimeter of the landfill (i.e. outside of waste mass) and two LFG bores (LFG13 and LFG14)

installed in the landfill cap (i.e. within the waste mass

The depths of these monitoring points range from 1.0 m to 3.1 m. All probes were constructed

with 6 mm Teflon tubing. These soil vapour probes are connected to quick release fittings hence

are not open to the atmosphere. Typically only the very bottom section of each soil vapour

probe is screened. LFG13 and 14 have been constructed as bores with 25 mm PVC screen and

casing.

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An additional four LFG monitoring bores (LFG8A, LFG10A, LFG18A and LFG20A) were installed

by GHD in February 2015 to provide comparative results to the corresponding soil vapour

probes. Bore LFG9A was installed to replace the previously destroyed LFG9, and LFG25 was

installed offsite to provide an indication of background or natural carbon dioxide

concentrations.

The location of all LFG monitoring probes and bores are shown in Figure 4.

5.9 Sources, pathways and receptors

5.9.1 Sources

The contamination sources are the waste streams described in Section 3.8.1. These can

generate leachate and LFG. The composition of both the leachate and LFG is dependent

upon the composition of the waste itself.

5.9.2 Migration pathways

LFG through air

Vertically and horizontal LFG migration from the landfill can occur through advective and

diffusive flow mechanisms through the unsaturated zone.

Advective flow of LFG occurs where a pressure gradient is present such as between two soil

layers, soil and a building above, or a service trench and surrounding soil. Diffusive LFG flow

occurs under a concentration gradient as occurs with chemicals mixing in water. The LFG flow

rate under diffusion is much slower than for advective flow.

The unsaturated zone varies in thickness within the landfill and its surrounds. Away from the

landfill the unsaturated zone is predominately comprised of loose sand and silty sand with lesser

silt and clay dominated soils of the MSA.

Vertical migration is restricted by the variable non-engineered cap on Area A, the interim cap

on Areas B and the daily cover in Area C. As the landfill is unlined, the local geology is the only

constraint to lateral LFG migration.

Groundwater

Landfill leachate that percolates through the unlined floor can mix with the groundwater in the

underlying aquifer. Information on landfill history indicates that waste was deposited at levels

close to, and possibly in places, slightly below the watertable. The rate of leachate generation

in the Portland landfill is likely to be much higher than for a landfill constructed with a Type 2

liner and cap (EPA; 2015b).

LFG can migrate by partitioning with leachate or groundwater. This involves methane, as a

volatile organic chemical, dissolving into the liquid phase. There is potential for the methane to

then partition (evolve) out of the water and into the soil gas above the watertable. This may

not be the most significant mechanism due to the low methane solubility in the groundwater

which is estimated to be about 21.5 mg/L2 (Cardno LanePiper; 2011b).

Surface Water

No natural surface water bodies are present at the site. The nearest natural surface water body

to the site is Fawthrop Lagoon, which is located approximately 1.7 km to the north east and its

tributary Wattle Hill Creek. Both groundwater and surface water are potential migration

pathways to Fawthrop Lagoon.

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Groundwater quality monitoring data indicates that the leachate plume has not migrated as

far as Fawthrop Lagoon.

Underground services and conduits

Underground services, conduits, and pits can transport LFG and leachate. The extent and

location of underground services at the site prior to establishment of the new transfer station

and ancillary facilities are described in Table 5-6.

Table 5-6: Extent and location of services

Service Type Description

Stormwater An underground stormwater drain collects runoff from the weighbridge

area and discharges via the resale centre to the stormwater drainage

system at Derril Road. It is understood that no other underground

stormwater network is present in site.

Telephone A Telstra cable runs southwards to the site office from the property

boundary on Derril Road (near IB4). There also appears to be a Telstra

cable entering the property from the south along Malings Road near

Cape Nelson Road.

Electricity To weighbridge, site office, and compressor house. Information on

subsurface cable location is being sought by GHD as part of the transfer

station design process. Power will be required at the new transfer station.

Compressed air The interception bore pumps are run via a compressed airline from the

bores to the compressor house.

LIS Common connector pipe along Derril Road connecting all IB bores. The

western extent of the LIS system is the compressor house. A header pipe

from around IB8 runs southward then westward to connect into the

eastern side of the Leachate Storage Dam.

Mains water Main pipe line along Cape Nelson Road.

20 mm mains off-take to site office. Route from Cape Nelson Road to site

office is unknown.

Fire water supply A water cart is located towards the southern end of the site. The CFA use

their own hoses and water supply.

Sewerage The site is not sewered.

Septic tank toilet system. Toilet located within site office building. GSC has

been unsuccessful in its search for the septic tank drainage system.

Gas Nil.

GSC has advised that Yarraman Park underground services are likely to be accessed from

McNeillys Road to the north-west.

5.9.3 Receptors

The receptors of potential harm due to the landfill activities that have been considered

relevant include:

people occupying or working at the site and nearby residences, businesses and schools;

flora and fauna on the site and surrounding the site;

the atmosphere as a sink for greenhouse gases;

physical infrastructure on and off-site;

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land;

groundwater and potential users; and

surface waters.

The proximity of residences, townships, schools and commercial facilities to the landfill premises

are presented in Table 5-7.

The approximate locations of nearby residences are shown in Figure 3.

Table 5-7: Summary of Portland Landfill development

Type Proximity to landfill

Residences Residence – Malings Road (200 m south of Area A & 70 m south of site).

Residence – On Malings Road near corner with McNeillys Road (120 m

south of Area C and 60 m south-west of site).

Residence - Cnr. Derril and McNeillys Road (250 m north-west of Cell C.

Residence – north of Derril Road (250 m north of Area C from Derril Road).

Multiple residences –about 500 m NE of landfill (north of Madeira Packet

Road).

Townships Portland CBD - about 3 km north-east of the landfill site.

Schools Nil within 1 km.

Commercial facilities Yarraman Park trotting track and go-cart track – on the boundary of the

site to the north-west.

Table 5-7 shows that there are several residences and commercial/industrial buildings within

the recommended buffer distance of 500 m for “buildings or structures” specified in Table 5.2

of EPA (2015a) Landfill BPEM for Type 2 landfills.

GSC has advised that it does not have any planning related restrictions for development within

500 m of the landfill.

The Cardno LanePiper (2014a) telephone survey of 41 participating property owners within

500 m of the landfill site did not identify any building basements. The property owner at 19

Malings Road indicated that their property is a two storey building with one room cut into a hill.

Information on:

flora and fauna;

physical infrastructure on and off-site;

the land;

groundwater and potential users; and

surface waters.

is provided earlier in the audit report.

There are no groundwater or surface water dependent ecosystems including flood plains,

special conservation, heritage, or protected areas or recreational waters within 1 000 m of the

landfill site.

5.9.4 Glenelg Planning Scheme

The nearest Residential Zone is 468m away from the landfill.

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Planning Clause 19.03-5 in the Glenelg Planning Scheme has the 2004 Waste Management

Policy (Siting, Design and Management of Landfills) as a reference document. It requires a

Type 2 Landfill to have a buffer distance of 500m from all buildings or structures.

Clause 52.10 of the Glenelg Planning Scheme has a recommended setback of 100m for a

transfer Station from Residential Zones (GRZ1).

The only identified Planning Permit issued within the 500 m buffer since 1st July 2015 was issued

for an extension of an existing dwelling extension at 87 Malings Road (approx. 55 m from the

landfill) on the 21st September 2015 (Planning Permit P15117).

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6. Risk of landfill operations

The following risk assessment tasks have been undertaken as part of this audit of landfill

operation:

identification of beneficial uses;

review of the Nolan Consulting (2014) risk assessment based upon:

collation of relevant information

update of conceptual model

review of July 2014 to December 2015 monitoring data (see Section 8);

update of the landfill risk assessment register;

update of the landfill compliance risk register; and

summarise the outcomes.

6.1 Beneficial uses

The following Government of Victoria State Environment Protection Policies (SEPPs) have been

reviewed to identify the relevant land, groundwater, and surface water beneficial uses:

SEPP (Variation to Waters of Victoria) – 2003;

SEPP (Groundwaters of Victoria) – 1997;

SEPP (Air Quality Management) - 2001; and

SEPP (Prevention and Management of Contaminated Land) – 2002.

EPA (2011d) “Noise from Industry in Regional Victoria Recommended Maximum Noise Levels

from Commerce, Industry and Trade Premises in regional Victoria” provides guidance on

applicable noise limits.

The beneficial uses for each of these environmental systems are described below.

6.1.1 Surface waters

Under the Variation to SEPP (Waters of Victoria) the site and surrounds is located within the

“Murray and Western Plains” segment. Within this segment, the aquatic ecosystem is

considered to be ”slightly to moderately modified”.

For this segment the rivers and streams are considered potentially suitable for all beneficial uses

including:

primary contact recreation;

aesthetic enjoyment;

indigenous cultural and spiritual values;

non-indigenous cultural and spiritual values;

agriculture and irrigation;

aquaculture;

industrial and commercial use;

human consumption after appropriate treatment; and

fish, crustacea and molluscs for human consumption.

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The applicable guidelines for primary contact recreation, agriculture and irrigation, industrial

and commercial use, and human consumption after appropriate treatment are presented in

Table 6-1.

6.1.2 Groundwaters

The SEPP (Groundwaters of Victoria) provides that groundwater is characterised into segments

with each segment having particular beneficial uses. Segments are based on groundwater

salinity, generally reported as Total Dissolved Solids (TDS).

The SEPP (Groundwaters of Victoria) may determine these beneficial uses may not apply

where:

there is insufficient yield;

the background level of water quality indicator other than Total Dissolved Solids (TDS)

precludes a beneficial use;

the soil characteristic precludes a beneficial use; and

a groundwater quality restricted use zone (GRUZ) has been declared.

Away from the leachate plume groundwater within the MSA and BFA aquifers falls within

segment A2, as characterised by the site TDS concentrations. Segment A2 applies to

groundwaters with a salinity range of 500 mg/L to 1,000 mg/L. The segment is consistent to that

determined by Lane Piper (2010a), “Environmental Audit Report (Groundwater - 2010) - 210

Cape Nelson Road, Portland”. (There are isolated instances in which the salinity of monitoring

bores slightly below 500 mg/L. An example is PO14 for which the salinity was 480 mg/L in the

April 2015 monitoring event).

Groundwater within the NVA falls within segment B based upon the records of monitoring bore

PO25. The salinity at this bore ranges between 1,000 mg/L and 1,100 mg/L.

Table 3 of the SEPP (Groundwaters of Victoria) specifies the water quality criteria required to

protect these beneficial uses. The protected beneficial uses and applicable water quality

guideline values for this segment are listed in Table 6-1.

Table 6-1: Water quality criteria for groundwater

Beneficial use category Applicable water quality criteria

Potable water supply

(acceptable)

The NH&MRC (2011) “Australian Drinking Water Guidelines”

replace the former 2004 guidelines. Table 10.5 of the guidelines

include both human health and aesthetic guideline values for

physical and chemical characteristics.

Maintenance of aquatic

ecosystems

Government of Victoria (2003) “SEPP (Variation to Waters of

Victoria)” applies and the water quality guidelines are found in

Chapter 2 of ANZECC (2000), “Australian and New Zealand

Guidelines for Fresh and Marine Water Quality”.

Table A4 of the “SEPP (Variation to Waters of Victoria)” sets the

environmental quality objectives for metal, non-metal, ammonia,

and sulphides within the water column of rivers and streams at

95% of species (level of protection) for the Murray and Western

Plains Segment. This means that the water quality objective

should be met 95% of the time. The environmental quality

objectives for non-metals are 95% in urban areas and 99%

outside of urban areas.

The freshwater trigger values at 95% and 99% are obtained from

Table 3.4.1 of ANZECC (2000) “Australian and New Zealand

Guidelines for Fresh and Marine Water Quality”.

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Beneficial use category Applicable water quality criteria

Potable mineral water supply Food Standards Australia New Zealand (2014)”Australia New

Zealand Food Standards Code - Standard 2.6.2 - Non-Alcoholic

Beverages and Brewed Soft Drinks”.

Agriculture, parks and gardens ANZECC (2000) “Australian and New Zealand Guidelines for Fresh

and Marine Water Quality Guideline”. Section 4.2 - Water Quality

for Irrigation and General Water Use.

Stock watering ANZECC (2000) “Australian and New Zealand Guidelines for Fresh

and Marine Water Quality Guideline”, Section 4.3 - Livestock

Drinking Water Quality.

Industrial water use ANZECC (1992) “Australian Water Quality Guidelines for Fresh

and Marine Waters”, Chapter 5.

[Note: ANZECC (2000) “Australian and New Zealand Guidelines

for Fresh and Marine Water Quality” does not provide specific

guidance for industrial water use because industrial water

requirements are so varied (both within and between industries)].

Primary contact recreation NHMRC (2008) “Guidelines for Managing Risks in Recreational

Water”, Section 9 - Chemical Hazards.

Buildings and structures Australian Standard (2009) “AS2159-2009 Piling – Design and

Installation”, Table 6.4.2.

The water quality guideline values for indicator parameters are presented in Table 6-2.

Table 6-2: Groundwater environmental quality standards guideline values (triggers)

Indicator Unit AWDG

(2011)

Health

AWDG

(2011)

Aesthetic

ANZECC

(2000)

EcoSystem

Fresh Water

(95%)

ANZECC

(2000)

Agriculture

Parks and

Gardens

ANZECC

(2000)

Stock

watering

NHMRC

(2008)

Recreation

al Waters

pH - - 6.0-8.5 6.0-8.5 6.0-8.5

total dissolved solids mg/L - 600 2,000 2,500

ammonia mg/L - 0.5 0.9 5.0

nitrate (as N) mg/L 11.3 - 0.16 90.3 113

nitrate (as NO3) mg/L 50 - 0.7 400 500

chloride mg/L 250 2,500

sulphate mg/L 500 250 2,000

sodium mg/L 180 1,800

calcium mg/L 1,000

magnesium mg/L 2,000

Arsenic III mg/L 0.01 NA 0.0240(1)

cadmium mg/L 0.002 NA 0.0002

copper mg/L 2 1 0.0013

Lead mg/L 0.01 NA 0.0044

Zinc mg/L NA 3 0.0150

Nickel mg/l 0.02 NA 0.0110

Selenium mg/L 0.01 NA 0.0110

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The NHMRC (2008) “Guidelines for Managing Risks in Recreational Water” advise that

environmental quality standards for chemicals in recreational waters should assume that

recreational water makes only a relatively minor contribution of drinking water consumption,

and that 10% is of the correct order. Based upon this advice the NH&MRC (2011) “Australian

Drinking Water Guidelines” guideline concentrations, including aesthetic, are multiplied by 10

times for recreational waters.

The Lane Piper (2010a) Groundwater Audit reviewed monitoring data from 2009 to 2010 and

drew conclusions with respect to whether these applicable beneficial uses are precluded due

to contamination and whether the use is likely. These conclusions have been reviewed based

upon the further development of the conceptual model and more recent monitoring data.

The precluded and likely uses are presented in Table 6-3 together with a commentary.

Where beneficial uses could be realised down-gradient of the site, although the use is

precluded in the immediate vicinity of the landfill, an appropriate management regime is

required to avoid impacts on bores currently operating or potentially installed in the future for

an intended use.

6.1.3 Air quality

The SEPP (Air Quality Management) beneficial uses are as follows:

life, health and wellbeing of humans;

life, health and wellbeing of other forms of life, including the protection of ecosystems

and biodiversity;

local amenity and aesthetic enjoyment;

visibility;

the useful life and aesthetic appearance of buildings, structures, property and materials;

and

climate systems that are consistent with human development, the life, health and

wellbeing of humans, and the protection of ecosystems and biodiversity.

6.1.4 Land

Based upon the site’s zoning and the down-gradient zoning, the SEPP (Prevention and

Management of Contaminated Land) the land segments requiring protection are

recreational/open space and sensitive use. The beneficial uses to be protected are:

modified and highly modified ecosystems;

human health;

buildings and structures; and

aesthetics.

6.1.5 Noise

The EPA (2011d) “Noise from Industry in Regional Victoria Recommended Maximum Noise

Levels from Commerce, Industry and Trade Premises in regional Victoria” provide the methods

to set noise levels for industry in regional Victoria. They provide a balance between protecting

community wellbeing and amenity near industrial premises and supporting the social and

economic value of industry in regional Victoria.

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Ma

y 2

01

6

Pa

ge

49

Po

rtla

nd

La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

Tab

le 6

-3:

Su

mm

ary

of g

rou

nd

wa

ter

be

ne

fic

ial u

se a

sse

ssm

en

t

Be

ne

fic

ial u

se

ca

teg

ory

Pro

tec

ted

Be

ne

fic

ial

Use

s o

f th

is

Gro

un

dw

ate

r

Se

gm

en

t

Precluded

Use

C

om

me

nta

ry

Existing

Likely to be

realised

Unlikely to be

realised

Po

tab

le

wa

ter

sup

ply

–a

cc

ep

tab

le

No

This

be

ne

fic

ial u

se is

no

t p

rec

lud

ed

aw

ay f

rom

th

e le

ac

ha

te p

lum

e.

The

ba

ckg

rou

nd

wa

ter

qu

alit

y is

ge

ne

rally

with

in t

he

gu

ide

line

va

lue

s fo

r p

ota

ble

wa

ter

sup

ply

(h

ea

lth

).

This

use

is

un

like

ly t

o b

e r

ea

lise

d a

s it is

ass

um

ed

th

at

a r

etic

ula

ted

su

pp

ly is

ava

ilab

le t

o

ne

arb

y r

esi

de

nts

.

Ma

inte

na

nc

e

of

aq

ua

tic

ec

osy

ste

ms

Ye

s √

This

be

ne

fic

ial u

se is

pre

clu

de

d.

Ma

ny o

f th

e c

on

tam

ina

nts

in t

he

ba

ckg

rou

nd

gro

un

dw

ate

r e

xc

ee

d m

ain

ten

an

ce

of

aq

ua

tic

ec

osy

ste

m g

uid

elin

e v

alu

es.

Ch

rom

ium

, c

op

pe

r, z

inc

an

d n

itra

te h

ave

be

en

rep

ort

ed

at

co

nc

en

tra

tio

ns

ab

ove

th

e g

uid

elin

e v

alu

es

in o

ne

or

mo

re b

ore

s.

This

is

an

exi

stin

g u

se a

s g

rou

nd

wa

ter

na

tura

lly d

isc

ha

rge

s to

re

ce

ivin

g w

ate

rs.

Po

tab

le

min

era

l w

ate

r

sup

ply

Ye

s

This

be

ne

fic

ial u

se is

pre

clu

de

d.

Gro

un

dw

ate

r d

oe

s n

ot

co

nfo

rm t

o t

he

po

tab

le m

ine

ral w

ate

r d

efin

itio

n. In

its

na

tura

l sta

te

it d

oe

s n

ot

co

nta

in s

uff

icie

nt

CO

2 a

nd

oth

er

solu

ble

ma

tte

r to

ca

use

eff

erv

esc

en

ce

or

imp

art

a d

istin

ctive

ta

ste

[SEP

P (

Gro

un

dw

ate

rs o

f V

icto

ria

)].

Ag

ric

ultu

re,

pa

rks

an

d

ga

rde

ns

No

Th

is b

en

efic

ial u

se is

no

t p

rec

lud

ed

.

Mo

st c

on

tam

ina

nt

co

nc

en

tra

tio

ns

are

be

low

th

e g

uid

elin

e c

rite

ria

, w

ith

th

e e

xce

ptio

n o

f

ele

va

ted

sa

linity c

on

ce

ntr

atio

ns

with

in t

he

plu

me

.

This

be

ne

fic

ial u

se c

ou

ld b

e r

ea

lise

d in

th

e v

icin

ity o

f th

e s

ite

.

Sto

ck

wa

terin

g

No

Th

is b

en

efic

ial u

se is

no

t p

rec

lud

ed

.

Mo

st c

on

tam

ina

nt

co

nc

en

tra

tio

ns

are

be

low

th

e g

uid

elin

e c

rite

ria

, w

ith

th

e e

xce

ptio

n o

f

ele

va

ted

sa

linity a

nd

nitra

te c

on

ce

ntr

atio

ns

with

in t

he

plu

me

.

Page 58: Section 53 V Audit - Landfill Operation

Ma

y 2

01

6

Pa

ge

50

Po

rtla

nd

La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

Be

ne

fic

ial u

se

ca

teg

ory

Pro

tec

ted

Be

ne

fic

ial

Use

s o

f th

is

Gro

un

dw

ate

r

Se

gm

en

t

Precluded

Use

C

om

me

nta

ry

Existing

Likely to be

realised

Unlikely to be

realised

This

be

ne

fic

ial u

se c

ou

ld b

e r

ea

lise

d in

th

e v

icin

ity o

f th

e s

ite

, n

ec

ess

ita

tin

g a

n a

pp

rop

ria

te

ma

na

ge

me

nt

reg

ime

to

av

oid

imp

ac

ts o

n n

ea

rby b

ore

s c

urr

en

tly o

pe

ratin

g o

r p

ote

ntia

lly

inst

alle

d in

th

e f

utu

re.

Ind

ust

ria

l

wa

ter

use

Ye

s

This

be

ne

fic

ial u

se is

pre

clu

de

d.

Gro

un

dw

ate

r is

un

like

ly t

o b

e u

sed

fo

r in

du

stria

l a

s th

e r

eq

uire

d s

alin

ity f

or

mo

st u

ses

is a

t o

r

be

low

th

e b

ac

kg

rou

nd

gro

un

dw

ate

r sa

linity p

urp

ose

s (<

10

0 m

g/L

fo

r th

e t

extile

ind

ust

ry).

This

be

ne

fic

ial u

se is

un

like

ly t

o b

e r

ea

lise

d in

th

e v

icin

ity o

f th

e s

ite

.

Prim

ary

co

nta

ct

rec

rea

tio

n

No

This

be

ne

fic

ial u

se is

no

t p

rec

lud

ed

aw

ay f

rom

th

e le

ac

ha

te p

lum

e.

This

be

ne

fic

ial u

se r

ela

tes

to t

he

use

of

gro

un

dw

ate

r to

fill

sw

imm

ing

po

ols

, o

r a

wa

ter

bo

dy

wh

ich

is in

pa

rt f

ed

by g

rou

nd

wa

ter

an

d m

ay b

e u

sed

fo

r sw

imm

ing

. R

esi

de

ntia

l pro

pe

rtie

s

are

with

in 1

00

m f

rom

th

e s

ite

to

th

e s

ou

th a

nd

25

0 m

fro

m t

he

site

to

th

e n

ort

h.

Fa

wth

rop

La

go

on

an

d W

att

le H

ill C

ree

k a

re a

bo

ut

1.7

km

fro

m t

he

no

rth

ern

site

bo

un

da

ry

an

d a

bo

ut

1.3

km

fro

m t

he

plu

me

fro

nt.

Am

mo

nia

(N

) c

on

ce

ntr

atio

ns

exc

ee

d t

his

be

ne

fic

ial u

se g

uid

elin

e c

rite

ria

in s

eve

n o

f th

e b

ore

s te

ste

d.

Tho

se b

ore

s re

po

rtin

g t

he

mo

st e

leva

ted

am

mo

nia

(N

) c

on

ce

ntr

atio

ns

(PO

06

an

d P

O0

7)

are

loc

ate

d c

lose

to

lan

dfill.

The

re

alis

atio

n o

f th

is b

en

efic

ial u

se is

un

like

ly b

ut

po

ssib

le.

Bu

ildin

gs

an

d

stru

ctu

res

No

Th

is b

en

efic

ial u

se is

no

t p

rec

lud

ed

.

The

so

ils a

re c

on

sid

ere

d li

ke

ly t

o b

e m

ild t

o n

on

-ag

gre

ssiv

e w

ith

re

spe

ct

to t

he

ir e

ffe

ct

on

co

nc

rete

pile

s, t

he

pH

is

alw

ays

ab

ove

6.0

, a

nd

th

e c

hlo

rid

e a

nd

su

lph

ate

co

nc

en

tra

tio

ns

are

we

ll b

elo

w 6

,000

mg

/L a

nd

1,0

00

mg

/L r

esp

ec

tive

ly. (S

ee

Ta

ble

9.1

of

Au

stra

lian

Sta

nd

ard

AS2

15

9-2

009

Pili

ng

– D

esi

gn

an

d In

sta

llati

on

).

Page 59: Section 53 V Audit - Landfill Operation

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67141-5_a.docx

The guidelines set out recommended maximum noise levels which can be applied to manage

the impacts of noise from the landfill on the community taking into account the landfill and

surrounding land is zoned PPRZ, RCZ1, FZ and PUZ5.

For a Public Use Zone as the generating zone to a Rural Conservation Zone (RCZ) as the most

sensitive receiving zone, the noise levels under EPA (2011d) are:

day 45 dBA (7.00 am to 6.00 pm (Monday to Friday) and to 1.00 pm on Saturday)

evening 37 dBA (6.00 pm to 10.00 pm (Monday to Friday) and from 1.00 pm on Saturday)

night 32 dBA (all other hours)

Day time limits apply at all operation times except from 1.00 pm to 4.30 pm on Saturday when

the evening limits apply and on Sunday when the night lime limits apply. After 1.00 pm on

Saturdays and on Sundays the transfer station is operated with no municipal loads being

received.

6.2 Risk assessment method

The EPA (2011b) Landfill Licensing Guidelines require an environmental risk assessment to be

prepared that identifies and evaluates the potential risks of landfill operations to the

environment. The risk assessment is required to inform the landfill Monitoring Program. The

approach to risk assessment is described in Section 4 of the EPA (2011a) Licence Assessment

Guidelines. It involves the following steps:

establishing the context of the risk assessment;

identifying risks (environmental aspects); and

risk analysis (including development of a risk register).

6.2.1 Risk assessment matrices

Two risk assessment matrices are applied. One is applied to all risks except LFG and the other

to LFG only.

All risks except for LFG

The EPA (2011a) Licence Assessment Guidelines qualitative risk assessment framework is

applied to all risks except for LFG. The level of risk is a combination of the likelihood of a risk

event occurring and the consequence if it does.

The qualitative measure of likelihood is presented in Table 6-4.

Table 6-4: Qualitative measure of likelihood (all hazards except LFG)

Rating Indicator Description Frequency

5 Almost certain Multiple incidents recorded. Expected to occur almost all the time.

4 Likely Several incidents recorded. Is expected to occur most of the time.

3 Possible Some incidents have been

recorded. Might occur.

2 Unlikely Few incidents recorded. Might occur but not expected to.

1 Rare No recorded or known incidents. Only expected to occur under atypical

conditions.

The qualitative measures of consequence are provided in Table 6-5.

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Table 6-5: Qualitative measure of consequence (all hazards except LFG)

Level Descriptor Description

5 Severe Human deaths, operations cause catastrophic off-site impacts, immense

financial losses.

4 Significant Extensive human injuries, operations cause substantial off-site impacts,

major financial losses.

3 Medium Some health impacts to human, operations cause some external impacts,

large financial loss.

2 Minor First aid treatment, operations cause some minimal off-site impacts, small

financial loss.

1 Negligible Operations cause no injuries, negligible off-site impacts, and negligible

financial loss.

The level of risk is a combination of the likelihood of a risk occurring and the consequence of it

occurring. Using matrices in Table 6-4 and Table 6-5, the level of risk posed is presented in

Table 6-6.

Table 6-6: Qualitative risk assessment matrix (all hazards except LFG)

Likelihood Consequences

Severe (5) Significant (4) Medium (3) Minor (2) Negligible (1)

Almost certain (5) Very High Very High Very High Very High High

Likely (4) Very High Very High Very High High High

Probable (3) Very High High High Medium Medium

Not likely (2) High High Medium Low Low

Rare (1) High Medium Low Low Low

Legend:

Very High - immediate action required.

High risk - management required by senior staff.

Medium - specify required management.

Manage with standard operating procedure.

LFG risks

The UK Environment Agency (2004) “Guidance on the Management of Landfill Gas” LFG risk

assessment method has been adopted in preference to EPA (2011a) Licence Assessment

Guidelines as the UK guidelines recognise that when the likelihood is ‘extremely unlikely’ of ‘very

unlikely’ that the risk may be insignificant or acceptable even if the consequence is

catastrophic.

The LFG severity likelihood matrix is shown in Table 6-7 below.

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Table 6-7: Severity likelihood matrix for LFG hazards (UK Environment Agency; 2004)

Likelihood Severity of consequences

Minor Noticeable Significant Severe Major Catastrophic

Extremely unlikely 1 2 3 4 5 6

Very unlikely 2 4 6 8 10 12

Unlikely 3 6 9 12 15 18

Somewhat

Unlikely 4 8 12 16 20 24

Fairly probable 5 10 15 20 25 30

Probable 6 12 18 24 30 36

Notes on likelihood:

Extremely unlikely: Incident occurs less than once in a million years.

Very unlikely: Incident occurs between once per million and once every 10,000 years.

Unlikely: Incident occurs between once per 10,000 years and once every 100 years.

Somewhat unlikely: Incident occurs between once hundred years and once every 10 years.

Fairly probable: Incident occurs between once 10 years and once per year.

Probable: Incident occurs at least once per year.

Notes on consequence:

Minor: Nuisance on-site only (no off-site effects), no outside complaint.

Noticeable: Noticeable nuisance off-site e.g. discern odours, minor breach of permitted emission

limits, but no environmental harm. One or two complaints from the public.

Significant: Sustained nuisance, e.g. offensive odours, several breach of permitted emissions limits with

possibility of prosecution, and numerous public complaints.

Severe: Severe and sustained nuisance, e.g. strong offensive odours, major breach of permitted

emissions limits with possibility of prosecution, and numerous public complaints.

Major: Evacuation of local populace, temporary disabling and hospitalisation, serious toxic effect on

beneficial or protected species, widespread but not persistent damage to land.

Catastrophic: Major airborne release with serious off-site effects. Site shutdown.

The magnitude of the risks against the scores presented in Table 6-7 and are shown in Table 6 8.

Table 6-8: LFG Magnitude of risk (UK Environment Agency; 2004)

Magnitude of Risk Score

Insignificant 6 or less

Acceptable 8 to 12

Unacceptable 15 or more

6.2.2 Environmental aspects

The risk register considers aspects and hazards associated with the following elements:

water;

groundwater;

air;

land;

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vegetation;

noise; and

aesthetics.

6.2.3 Risk register

For each of the identified aspects/hazards the updated risk register identifies:

environment element;

pathways for risk(factors influencing the likelihood of the risk occurring);

receptors;

location (on-site or off-site);

potential environmental impacts (description of impacts should the risk occur);

existing controls (controls in place to prevent or mitigate the risk);

likelihood of hazard (likelihood of the risk occurring); and

consequence/severity (consequence of the risk occurring including receptor impact).

6.3 Updated landfill register

The Portland Landfill Risk Assessment Register (updated May 2016) is presented in full in

Appendix F and in a comprehensive summary form in Table 6-9 for all non-LFG risks greater than

low and all LFG risk that are greater than insignificant. In updating the register consideration

has been given to the risk assessment undertaken by Cardno (2015b), “Hydrogeological

Assessment for Leachate Level Management - Portland Landfill 210 Cape Nelson Road,

Portland, Vic”.

The risk profile has not changed significantly from that presented in Nolan Consulting (2014).

This reflects only minor refinements to the conceptual site model, and generally consistent

monitoring results.

6.4 Compliance risk register

The Portland Landfill Compliance Risk Assessment Register (updated May 2016) has been

prepared (Appendix G of this audit report) to assess the environmental risks associated with site

operational activities as they relate to licence requirements and the criteria presented

EPA (2015a) Landfill BPEM.

Page 63: Section 53 V Audit - Landfill Operation

Ma

y 2

01

6

Pa

ge

55

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La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

Tab

le 6

-9:

Ris

k A

sse

ssm

en

t su

mm

ary

ta

ble

En

viro

nm

en

tal

Ele

me

nt

En

viro

nm

en

tal

Asp

ec

ts /

Ha

zard

s

(So

urc

e)

Pa

thw

ay

s R

ec

ep

tors

P

ote

ntia

l En

viro

nm

en

tal

Imp

ac

ts

Ex

istin

g

Co

ntr

ol

Lik

e

lih

oo

d

Co

nse

qu

en

ce

Ris

k L

eve

l

&Sc

ore

Su

rfa

ce

wa

ter

Su

rfa

ce

wa

ter

Co

nta

min

atio

n

by le

ac

ha

te /

sed

ime

nt.

Su

rfa

ce

ru

n o

ff.

Su

rfa

ce

wa

ters

. D

etr

ime

nt

to s

urf

ac

e

wa

ters

(i.e

. a

qu

atic

ec

osy

ste

ms)

.

No

ne

2

4

M

ed

ium

Gro

un

dw

ate

r.

De

trim

en

t to

su

rfa

ce

wa

ters

(i.e

. a

qu

atic

ec

osy

ste

ms)

.

LIS

2

4

Me

diu

m

Gro

un

dw

ate

r

Gro

un

dw

ate

r C

on

tam

ina

tio

n

by le

ac

ha

te.

Ac

tive

wa

ste

ce

ll.

Gro

un

dw

ate

r.

Co

nta

min

atio

n (

on

-site

&

off

-site

).

No

ne

. 5

4

V

ery

Hig

h

Gro

un

dw

ate

r u

sers

(extr

ac

tive

).

Co

nta

min

atio

n (

off

-site

).

3

4

Hig

h

Inc

rea

sed

lea

ch

ate

le

ve

l

in r

ete

ntio

n

po

nd

s.

Un

satu

rate

d

zon

e.

Gro

un

dw

ate

r.

Co

nta

min

atio

n (

on

-site

).

No

ne

. 2

4

M

ed

ium

Co

nta

min

atio

n

by le

ac

ha

te.

Un

satu

rate

d

zon

e.

Gro

un

dw

ate

r.

Co

nta

min

atio

n (

on

-site

&

off

-site

).

LIS

5

4

Ve

ry H

igh

LFG

mig

ratio

n.

Un

satu

rate

d

zon

e.

Gro

un

dw

ate

r.

Co

nta

min

atio

n (

on

-site

).

No

ne

. 5

3

V

ery

Hig

h

LFG

Air

LFG

mig

ratio

n.

Un

satu

rate

d

Zo

ne

.

Oc

cu

pa

nts

of

bu

ildin

gs

(on

-site

).

De

ath

or

serio

us

inju

ry d

ue

to e

xp

losi

on

.

2

6

A

cc

ep

tab

le

Wo

rke

rs (

e.g

. Sta

ff,

ma

inte

na

nc

e,

etc

.) (

on

sit

e).

Asp

hyxia

tio

n d

ue

to

dis

pla

ce

me

nt

of

oxyg

en

to b

elo

w 1

9.5

% b

y L

FG

.

No

ne

. 3

6

U

na

cc

ep

tab

le

Page 64: Section 53 V Audit - Landfill Operation

Ma

y 2

01

6

Pa

ge

56

Po

rtla

nd

La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

En

viro

nm

en

tal

Ele

me

nt

En

viro

nm

en

tal

Asp

ec

ts /

Ha

zard

s

(So

urc

e)

Pa

thw

ay

s R

ec

ep

tors

P

ote

ntia

l En

viro

nm

en

tal

Imp

ac

ts

Ex

istin

g

Co

ntr

ol

Lik

e

lih

oo

d

Co

nse

qu

en

ce

Ris

k L

eve

l

&Sc

ore

De

ath

or

serio

us

inju

ry d

ue

to e

xp

losi

on

.

No

ne

. 3

6

U

na

cc

ep

tab

le

H

um

an

s /

Re

sid

en

ts

(off

site

).

Asp

hyxia

tio

n d

ue

to

dis

pla

ce

me

nt

of

oxyg

en

to b

elo

w 1

9.5

% b

y L

FG

.

No

ne

. 2

6

A

cc

ep

tab

le

M

ain

ten

an

ce

/

co

nst

ruc

tio

n

wo

rke

r in

tre

nc

h /

pits

(off

site

).

Asp

hyxia

tio

n d

ue

to

dis

pla

ce

me

nt

of

oxyg

en

to b

elo

w 1

9.5

% b

y L

FG

.

No

ne

. 2

6

A

cc

ep

tab

le

In

fra

stru

ctu

re (

on

-

site

).

Da

ma

ge

to

in

fra

stru

ctu

re

du

e t

o e

xp

losi

on

or

co

rro

sio

n.

No

ne

. 4

3

A

cc

ep

tab

le

Air

LFG

in

un

de

rgro

un

d

serv

ice

s.

Un

satu

rate

d

zon

e (

serv

ice

tre

nc

he

s).

Oc

cu

pa

nts

of

bu

ildin

gs

(on

site

).

Asp

hyxia

tio

n d

ue

to

dis

pla

ce

me

nt

of

oxyg

en

to b

elo

w 1

9.5

% b

y L

FG

.

No

ne

. 2

6

A

cc

ep

tab

le

De

ath

or

serio

us

inju

ry d

ue

to e

xp

losi

on

.

2

6

Ac

ce

pta

ble

Wo

rke

rs (

e.g

. Sta

ff,

ma

inte

na

nc

e,

etc

.) (

on

sit

e).

Asp

hyxia

tio

n d

ue

to

dis

pla

ce

me

nt

of

oxyg

en

to b

elo

w 1

9.5

% b

y L

FG

.

3

6

Un

ac

ce

pta

ble

De

ath

or

serio

us

inju

ry d

ue

to e

xp

losi

on

.

3

6

Un

ac

ce

pta

ble

Hu

ma

ns

/ R

esi

de

nts

(off

site

).

De

ath

or

serio

us

inju

ry d

ue

to e

xp

losi

on

.

2

6

Ac

ce

pta

ble

Ma

inte

na

nc

e /

co

nst

ruc

tio

n

wo

rke

r in

tre

nc

h /

pits

(off

site

).

Asp

hyxia

tio

n d

ue

to

dis

pla

ce

me

nt

of

oxyg

en

to b

elo

w 1

9.5

% b

y L

FG

.

2

6

Ac

ce

pta

ble

Page 65: Section 53 V Audit - Landfill Operation

Ma

y 2

01

6

Pa

ge

57

Po

rtla

nd

La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

En

viro

nm

en

tal

Ele

me

nt

En

viro

nm

en

tal

Asp

ec

ts /

Ha

zard

s

(So

urc

e)

Pa

thw

ay

s R

ec

ep

tors

P

ote

ntia

l En

viro

nm

en

tal

Imp

ac

ts

Ex

istin

g

Co

ntr

ol

Lik

e

lih

oo

d

Co

nse

qu

en

ce

Ris

k L

eve

l

&Sc

ore

Air

Em

issi

on

of

tra

ce

co

mp

on

en

ts –

toxic

ga

ses

(H2S).

Am

bie

nt

air.

Oc

cu

pa

nts

of

bu

ildin

gs

(on

site

).

Ch

ron

ic h

ea

lth

ris

k –

sta

ff,

ma

inte

na

nc

e w

ork

ers

(o

n-

site

).

Co

ntr

ol o

f

wa

ste

stre

am

in

ac

co

rda

nc

e

with

lan

dfill

lice

nc

e.

3

3

Ac

ce

pta

ble

Air

Fu

gitiv

e L

FG

. A

mb

ien

t a

ir.

Infr

ast

ruc

ture

tra

nsm

issi

on

to

we

r

(ab

ove

gro

un

d).

(on

-sit

e).

Co

rro

sio

n o

f in

fra

stru

ctu

re.

No

ne

. 5

2

A

cc

ep

tab

le

Lan

d

Un

satu

rate

d

zon

e

(Ad

ve

ctive

or

diffu

sive

flo

w).

Infr

ast

ruc

ture

tra

nsm

issi

on

to

we

r

(su

b-s

urf

ac

e)

(on

-

site

).

4

2

Gro

un

dw

ate

r P

art

itio

nin

g o

f

LFG

gro

un

dw

ate

r.

Gro

un

dw

ate

r

flo

w t

hro

ug

h

aq

uife

r.

Infr

ast

ruc

ture

bu

ildin

gs,

un

de

rgro

un

d

serv

ice

s, f

en

ce

s

(on

sit

e).

Co

rro

sio

n o

f u

nd

erg

rou

nd

infr

ast

ruc

ture

.

No

ne

. 2

6

A

cc

ep

tab

le

Pa

rtitio

nin

g

fro

m le

ac

ha

te

or

gro

un

dw

ate

r

resu

ltin

g in

va

po

ur

intr

usi

on

.

Oc

cu

pa

nts

of

bu

ildin

gs

(on

site

).

De

ath

or

serio

us

inju

ry d

ue

to e

xp

losi

on

.

No

ne

2

6

A

cc

ep

tab

le

Ve

ge

tatio

n

Fu

gitiv

e L

FG

. U

nsa

tura

ted

zon

e (

i.e.

Ad

ve

ctive

or

diffu

sive

flo

w).

Ve

ge

tatio

n (

on

-

site

.).

Da

ma

ge

to

ve

ge

tatio

n.

No

ne

. 4

3

A

cc

ep

tab

le

Page 66: Section 53 V Audit - Landfill Operation

Ma

y 2

01

6

Pa

ge

58

Po

rtla

nd

La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

En

viro

nm

en

tal

Ele

me

nt

En

viro

nm

en

tal

Asp

ec

ts /

Ha

zard

s

(So

urc

e)

Pa

thw

ay

s R

ec

ep

tors

P

ote

ntia

l En

viro

nm

en

tal

Imp

ac

ts

Ex

istin

g

Co

ntr

ol

Lik

e

lih

oo

d

Co

nse

qu

en

ce

Ris

k L

eve

l

&Sc

ore

Od

ou

r

Od

ou

r P

rese

nc

e o

f

toxic

ga

ses

(H2S).

Am

bie

nt

air –

od

ou

r

imp

ac

tin

g

bre

ath

ing

spa

ce

s.

Wo

rke

rs (

e.g

. Sta

ff,

ma

inte

na

nc

e,

etc

.) (

on

-sit

e).

Ch

ron

ic h

ea

lth

ris

k –

sta

ff,

ma

inte

na

nc

e w

ork

ers

.

No

ne

. 3

2

M

ed

ium

Lan

d

Lan

d

Co

nta

min

atio

n

by le

ac

ha

te

an

d /

or

LFG

co

nd

en

sate

.

Un

satu

rate

d

zon

e.

Infr

ast

ruc

ture

tra

nsm

issi

on

to

we

r

foo

tin

g (

on

-site

).

Co

rro

sio

n o

f in

fra

stru

ctu

re.

No

ne

. 2

4

M

ed

ium

C

on

tam

ina

tio

n

by le

ac

ha

te.

Ove

rfill

ing

of

lea

ch

ate

sto

rag

e d

am

.

Lan

d (

soil)

(o

n-s

ite

).

Co

nta

min

atio

n –

la

nd

. N

on

e.

2

4

Me

diu

m

No

ise

So

un

d

Ma

ch

ine

ry /

Eq

uip

me

nt

/

Tra

ffic

.

Am

bie

nt

air.

Wo

rke

rs,

(e.g

. Sta

ff,

ma

inte

na

nc

e,

etc

.) (

on

-sit

e).

Ae

sth

etic

. P

PE –

sa

fe

wo

rk

pro

ce

du

re.

2

3

Me

diu

m

Litt

er

Ae

sth

etic

s

Ae

sth

etic

s Li

tte

r.

Ac

tive

wa

ste

ce

ll.

Flo

ra &

Fa

un

a

(on

-sit

e).

Ae

sth

etic

s a

nd

vis

ibili

ty;

he

alth

of

fau

na

.

Da

ily c

ove

r.

3

2

Me

diu

m

Ac

tive

wa

ste

ce

ll –

win

db

low

n.

Wo

rke

rs (

e.g

. Sta

ff,

ma

inte

na

nc

e,

etc

.) (

on

-sit

e).

Ae

sth

etic

an

d v

isib

ility

. D

aily

co

ve

r

Re

gu

lar

site

ch

ec

ks.

3

2

Me

diu

m

Page 67: Section 53 V Audit - Landfill Operation

Ma

y 2

01

6

Pa

ge

59

Po

rtla

nd

La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

En

viro

nm

en

tal

Ele

me

nt

En

viro

nm

en

tal

Asp

ec

ts /

Ha

zard

s

(So

urc

e)

Pa

thw

ay

s R

ec

ep

tors

P

ote

ntia

l En

viro

nm

en

tal

Imp

ac

ts

Ex

istin

g

Co

ntr

ol

Lik

e

lih

oo

d

Co

nse

qu

en

ce

Ris

k L

eve

l

&Sc

ore

Ae

sth

etic

s – D

ust

Ae

sth

etic

s D

ust

. A

mb

ien

t a

ir –

win

db

low

n.

Wo

rke

rs (

sta

ff,

ma

int.

) (o

n-s

ite

).

Ae

sth

etic

& v

isib

ility

. N

on

e.

3

2

Me

diu

m

Tra

ffic

/ro

ad

s.

Wo

rke

rs (

e.g

. Sta

ff,

ma

inte

na

nc

e,

etc

.) (

on

-sit

e).

3

2

Me

diu

m

Hu

ma

n

He

alth

Du

st.

Am

bie

nt

air –

win

db

low

n.

Hu

ma

ns

(off

-site

).

Ae

sth

etic

& v

isib

ility

. N

on

e.

3

2

Me

diu

m

Hu

ma

ns

(off

-site

).

3

2

Me

diu

m

Wo

rke

rs (

on

-site

).

3

2

Me

diu

m

Tra

ffic

/ro

ad

s.

Wo

rke

rs (

on

-site

).

3

2

Me

diu

m

Ve

rmin

Ae

sth

etic

s V

erm

in (

rats

,

bird

s, e

tc.)

Ac

tive

wa

ste

ce

lls.

Oc

cu

pa

nts

of

bu

ildin

gs

(on

-site

.)

Ve

cto

rs o

f d

ise

ase

. N

on

e.

3

2

Me

diu

m

Hu

ma

ns

at

an

d in

the

vic

inity o

f th

e

lan

dfill

(off

-site

).

3

2

Me

diu

m

Ve

ge

tatio

n

Ve

ge

tatio

n

Fire

. A

ctive

wa

ste

ce

ll.

Flo

ra &

Fa

un

a (

off

-

site

).

Da

ma

ge

to

flo

ra.

Fire

bre

aks.

2

3

M

ed

ium

W

ee

d

ma

na

ge

me

nt.

Site

an

d

ina

ctive

/

clo

sed

wa

ste

ce

lls.

Flo

ra &

fa

un

a in

vic

inity o

f la

nd

fill

(on

-sit

e).

Ae

sth

etic

an

d v

isib

ility

.

Da

ma

ge

to

loc

al f

lora

.

No

ne

. 3

2

M

ed

ium

Site

reh

ab

ilita

tio

n.

Flo

ra &

Fa

un

a (

off

-

site

).

Su

rfa

ce

wa

ter

run

off

.

Ero

sio

n o

f la

nd

fill

ca

p a

nd

exp

osu

re o

f b

urie

d w

ast

e.

No

ne

. 3

2

M

ed

ium

Page 68: Section 53 V Audit - Landfill Operation

May 2016

Page 60

Portland Landfill - 210 Cape Nelson Road, Portland

Section 53V Audit

Nolan Consulting Pty Ltd

67141-5_a.docx

6.4.1 Information sources

The Auditor has inspected the site, undertaken interviews, and selectively reviewed existing

procedures and checklists. These documents include:

Environmental complaints register;

Checklists:

- Routine Inspection Contaminated Water Checklist (Weekly)

- Monitoring and Compliance Daily Checklist

- Monitoring and Compliance Monthly Checklist;

Safe Work Procedures (SWP) for transfer station operation – ventilation of buildings; and

Infrastructure corrosion inspections for May 2015, October 2015 and January 2016.

6.4.2 Monitoring and compliance checklists

The Routine Inspection Contaminated Water Checklist (Weekly) requires inspections of the

Leachate Interception Bores, compressor shed, flow to the leachate storage dam, leachate

storage dam water level and whether further action required.

The Monitoring and Compliance Monthly Checklist includes the following questions:

is there any

- rubbish outside of the boundary perimeter?

- internal windblown rubbish?

- any free laying water on-site?

- asbestos exposed?

- audible noise leaving the site?

- audible noise detectable at any Sensitive Receptor locations?

- vermin visible on-site?

- odour detectable on-site?

- odour at any Sensitive Receptor Locations?

- dust visible on or off-site?

- dust visible at Sensitive Receptor Locations?

is there

- a stock pile of material for daily cover that is sufficient for two weeks?

- ponding of water visible on-site?

- visible leachate anywhere on-site?

is the

- tipping face under 30m long and clear of obstructions?

- lift restricted to 2 m?

Green Waste Stockpiles satisfactory? (Must be under 2m high and 5m apart).

leachate pond in good condition (no cracks/erosion) and at a low depth?

has 300mm of daily cover been applied?

Page 69: Section 53 V Audit - Landfill Operation

May 2016

Page 61

Portland Landfill - 210 Cape Nelson Road, Portland

Section 53V Audit

Nolan Consulting Pty Ltd

67141-5_a.docx

are the groundwater and LFG bores intact and easy to access?

The Monitoring and Compliance Daily Checklist checks whether the following are satisfactory:

perimeter cleanliness;

internal windblown rubbish;

clearance of litter screens;

transfer area / skip condition ;

tip face area under 30 m long and clear of obstructions;

has 300 mm of cover been applied;

asbestos covered;

free laying water on-site;

audible noise, detectable odour, visible dust, visible vermin; and

green waste, concrete, tyre, recyclable steel and timber stockpiles, and recycle shop in

satisfactory condition.

The Facility Maintenance Co-ordinator undertakes the Routine Inspection Contaminated

Water Checklist (Weekly).

Either the Weighbridge Attendant or the Compactor Operator undertakes the daily inspection

and completes the compliance checklist. The Resources Management Officer undertakes the

monthly inspection.

The Auditor witnessed copies of all completed contaminated water checklist, daily and

monthly landfill monitoring and compliance checklists for March, April, June, September and

December 2015.

6.4.3 Observations on landfill practices and procedures

The following observations on landfill practices and procedures were made during the audit.

Environmental complaints

GSC has a procedure for environmental complaints, maintains an environmental complaints

form, and keeps an up to date environmental complaints register.

Complaints received by Customer Services or the Resources Management Officer are

registered in GSC’s ECM data management system.

GSC advised that no complaints were received over the audit period.

Inspections for corrosion

The GSC Resource Management Officer has initiated a quarterly inspection of the site

infrastructure for evidence of corrosion. Photographs are taken at these inspections. A

procedure is now required to report on the findings.

Inspection checklists

The monthly inspections are undertaken at the required frequency. The daily inspections are

generally undertaken from Monday to Friday. There are however gaps. There were only four

daily inspection reports provided for December 2015. This may be related to senior

management staffing changes.

In April 2015 daily inspections were undertaken on one Friday only, and one Saturday only.

Page 70: Section 53 V Audit - Landfill Operation

May 2016

Page 62

Portland Landfill - 210 Cape Nelson Road, Portland

Section 53V Audit

Nolan Consulting Pty Ltd

67141-5_a.docx

The checklists are prepared by the appropriate officer, are submitted to the GSC Resource

Management Officer, are checked, and then scanned and stored.

The checklists are yet to be modified to fully satisfy the Cat A monitoring requirements, and in

particular to identify the locality where observations are made.

Daily cover

The monitoring and compliance daily checklist includes a requirement to advise on whether

300 mm of daily cover has been placed. The inspection for daily cover now occurs at the end

of the day.

There were several occurrences of less than 300 mm of cover being placed due to a lack of

availability. This was noted in the 2014/15 Annual Performance Statement.

Visual inspections

Visual inspection records are not maintained at the weighbridge.

6.4.4 The register

The Portland Landfill Compliance Risk Assessment Register (updated May 2016) has been

prepared (Appendix G of this audit report). It identifies the type of monitoring required for each

licence condition where applicable, the timing and frequency of the monitoring, and the

QA/QC measures.

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7. Assessment of monitoring program implementation

This section of the audit assesses progress with implementing the verified environment

Monitoring Program. The assessment draws upon site observations of the location and

installation of monitoring infrastructure and of groundwater, leachate and LFG monitoring, a

review of monitoring infrastructure installation and monitoring reports, and discussions with GSC

and GHD as the contractor engaged to undertaken the monitoring.

7.1 The verified program

The verified Monitoring Program is provided in Section 10 of the Nolan Consulting (2014)

“Section 53V Audit – Landfill Operation, Portland Landfill – 210 Cape Nelson Road Portland”.

The Monitoring Program includes sections on:

roles and responsibilities;

Category A visual monitoring;

Category B monitoring of groundwater, leachate and LFG; and

environment audit program.

Definitions of the Category A and Category B monitoring programs are as follows:

Cat A: Regular or incident driven inspections by trained GSC staff, reporting of visual

inspection observations, and the implementation of mitigation measures where non-

compliances observed.

Cat B: Sampling and testing based programs with on-site and laboratory testing. These

programs also require reporting and adherence to QA/QC procedures.

The category of monitoring required for each environmental element is presented in Table 7-1.

Table 7-1: Status of monitoring types for each environmental element

Environmental Element Type A monitoring Type B Monitoring

Required Regular

frequency

Required Addressed in the

environmental

monitoring

contract

Surface water √ Weekly × NA

Groundwater/leachate × NA √ Generally

Air – LFG √

Quarterly

(Plant stress only) √

Yes, except for

landfill surface

Air – Odour √ Daily × NA

Air - Climate × NA × Covered in LFG

Land × NA × NA

Noise √ Weekly × NA

Aesthetics – Litter √ Daily/Weekly × NA

Aesthetics – Dust √ Weekly × NA

Aesthetics – Vermin √ Fortnightly × NA

Vegetation √ Quarterly × NA

Corrosion √ Quarterly × NA

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7.2 Assessment of implementation

The assessment presented below addresses both the Category A and Category B programs

over July 2014 to December 2015audit period.

7.2.1 Cat A monitoring

The required Cat A monitoring activity is observation (visual and olfactory) and must be

undertaken by trained staff. The verified monitoring program requires evidence of the

observations to be reported.

Progress with the implementation of the Cat A monitoring is presented in Table 7-2.

Table 7-2: Progress with implementation of Cat A Monitoring

Aspect Finding Required

frequency

Progress

Training Variable During the audit period staff training has included

asbestos awareness, first aid, and resource

recovery.

Verbal on-site advice is provided by senior

officers.

Formal training of all officers in identification of

environmental issues including ‘calibration’ for

odour monitoring is yet to be undertaken.

Documentation of training needs identification

and records of training undertaken is required.

Observations Surface

water/leachate

Weekly Undertaken as part of the monthly compliance

checklist. Monitoring points not defined.

Air – Odour Daily Within site observations undertaken as part of the

daily compliance checklist. Need to extend this

to the site boundary.

Noise Weekly Off-site observations undertaken as part of the

daily compliance checklist.

Aesthetics – Litter Daily

/Weekly

Daily visual inspections of cover by Compactor

Operator. Daily boundary and on-site inspections

undertaken.

Aesthetics – Vermin Fortnightly Within site observations undertaken as part of the

monthly compliance checklist.

Vegetation Quarterly Plant health monitoring of the cap undertaken

by GHD.

Checklists Compliance checklists addresses most Cat A

monitoring requirements.

Reporting GSC maintains a complaints register.

The daily, weekly, and monthly compliance

checklists are scanned and stored electronically.

The checklists need to identify locations of

observations and follow up actions undertaken

to address any issues.

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7.2.2 Cat B monitoring - records reviewed

The Category B program is undertaken by GHD.

The Cat B monitoring undertaken over the audit period is reported in GHD (2015b) “Portland

Landfill Annual Environmental Monitoring Results Report 2014/15” for the 2914/1`5 monitoring

events and in the laboratory results and data files for the 2015/16 monitoring events.

The monitoring events undertaken during the 18 month audit period are presented in Table 7-3.

Table 7-3: Cat B Monitoring undertaken

Element 2014/15 2015/16

22-25/7 28-31/10 02-06/2 28/4-01/5 4-6/8 28-30/10

Groundwater – General √ √ √ √ √ √

Groundwater -VOC and SVOC x x x √ x x

Leachate √ √ √ √ √ √

LFG - Bores and probes √ √ √ √ √ √

LFG - In-building & services √ √ √ √ √ √

LFG – Landfill surface X √ √ √ √ √

Plant stress/dieback survey √ √ √ √ √ √

The GHD (2015b) “Portland Landfill Annual Environmental Monitoring Results Report 2014/15”.

included the following:

groundwater and leachate purging and sampling records;

MGT Eurofins (primary laboratory) analytical results;

ALS (secondary laboratory) analytical results;

chain of custody forms;

tabulation of water quality results;

field water quality analysis calibration certificates;

water quality data QC reviews; and

LFG bore monitoring records.

7.2.3 Cat B Monitoring – Groundwater and leachate

Progress with the implementation of the groundwater monitoring subprogram as developed is

presented in Table 7-4. The assessment has focussed on the 28th April 2015 to 1st May 2015

monitoring events.

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Table 7-4: Progress with implementing groundwater and leachate monitoring subprogram

(Cat B)

Variables Description Compliance

Installation of

new monitoring

bores

Groundwater

New bores PO34A, PO34B, PO35A and PO35B

installed in September 2015.

Leachate

Bores LB01R and LB02RA installed in February 2015

and LB02R decommissioned.

Compliant

Upgrade of LIS

system

IB6 replaced with IB6R

IB4, IB5, and IB7 redeveloped.

All bores installed with new pumps, pulse counters

and level data loggers except for IB5 which does not

have a data logger.

Cumulative flow meter installed on LIS discharge line

near leachate storage dam.

Gauging board installed in leachate storage dam.

Leachate storage dam floor level and gauging board

datum surveyed.

Generally compliant

Install data logger in IB5.

Works completed by October

2015.

Level survey All bores surveyed to AHD except for new

groundwater bores PO34A, PO34B, PO35A and PO35B

and new leachate monitoring bores LB01R and

LB02RA.

Partially compliant

Survey all new bores.

Bore

maintenance

Bores inspected were locked.

Tree covering monitoring bore PO04 has not been

removed. (PO04 which was also covered by the tree

in the January and April 2015 monitoring events).

Surface casing of monitoring bore PO04 damaged as

of 7th March 2016.

Compliant

Monitoring

occurrence

Frequency

Quarterly monitoring was undertaken. The scheduling

was acceptable although the January 2015

monitoring event was undertaken in early February.

Generally compliant

Groundwater monitoring bores

All required groundwater bores with a sufficient water

volume for sampling was monitored except for PO04

which was covered and PO10, PO32, PO33A, PO33B

which were inundated with surface water on one to

two occasions.

Generally compliant

Leachate monitoring bores

All required leachate monitoring bores with a

sufficient water volume for sampling were monitored

except for leachate monitoring bore IB01 was

thought to be lost. It was found and monitored from

July 2014.

Complaint

Leachate Interception System

Interception bores IB4, IB5, IB6, IB7, and IB8 are

monitored for water quality. Pulse counters (for flow)

and data loggers (for level) installed but not reported

as yet.

Not compliant

Maintain flow meter.

Download data and include in

reporting.

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Variables Description Compliance

Flow meter on discharge line has failed.

Leachate storage dam level monitored as part of the

Routine Inspection Contaminated Water Checklist

(Weekly) weekly.

parameters Quarterly

(Jan,

Apr, Jul,

Oct)

Quarterly sampling and analysis

undertaken.

Compliant

Annually

Annual testing for SVOC and VOC screens

for all groundwater and leachate was

undertaken in April 2015. These have

been included to address past isolated

events where non-permitted wastes were

accepted.

Compliant

Purging and

sampling

procedure

GHD (2015b) stated that purging and sampling of

groundwater bores was undertaken in accordance

with EPA (2000) “Groundwater Sampling Guidelines”.

Compliant

SWL gauging

procedure

Standing Water Level (SWL) Monitoring undertaking at

commencement of each groundwater monitoring

event.

Compliant

Groundwater

sampling

procedure

Groundwater purging and sampling sheets provide

details on the purge method. The only exceptions

were a few bores for which the water level was low or

the bore was inaccessible to the low flow pump.

The field parameters at most bores had stabilised.

Compliant

Field Records Completed groundwater bore purging and sampling

records provided for each bore including bore/site

details, standing water level, and field parameter

value.

Groundwater bore purging and sampling records did

not identify that metals filtered in the field as stated in

the GHD (2015b) annual report.

The sample containers used were not clearly

identified in the CoC forms, particularly for SVOC and

VOC screens.

Partially compliant

Groundwater bore purging

and sampling records to clarify

which samples are filtered in

site.

CoC forms to identify sample

containers

Calibration

certificates

TPS90-FLMW calibration certificates provided in the

annual monitoring report.

Compliant

Field

Parameters

Groundwater physiochemical parameters are

monitored and recorded during purging.

Compliant

Groundwater

Sample

Collection

Sampling commence once physiochemical

parameters have stabilised and are placed in

containers for delivery to the laboratory under Chain

of Custody documentation.

Compliant

QC Samples See Section 3.4 of the GHD (2015b) “Portland Landfill

Annual Environmental Monitoring Results Report

2014/15”.

The trip blank sample was not collected during the

annual (April) event and analysed for VOC screen

analysis.

Generally compliant

Obtain trip blank sample during

the annual event for VOC

screen analysis.

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Variables Description Compliance

Trend analysis

plots

Plots should be from 1989 to present day (after pre

2012 data is incorporated into the database).

Partially compliant

Bore

maintenance

observations

The completed groundwater bore purging and

sampling records do not require reporting on bore

condition.

Not compliant

Include statement on bore

conditions.

Records Refer to GHD (2015b) “Portland Landfill Annual

Environmental Monitoring Results Report 2014/15”.

Generally compliant

Contractor GHD had been engaged to undertake the

monitoring and has been assessed by GSC to meet

this criteria.

Compliant

GHD (2014b) reported on the QA/QC results for each of the 2014 /15 monitoring events. The

QA/QC results are reviewed in Table 7-5.

Table 7-5: Groundwater Data Quality Review

Variables Description

Data Validation reporting. GHD (2015b) provides specific data validation reporting.

Holding times Eurofins advised that the samples were extracted within the holding

times.

Blind duplicate testing (Primary

laboratory).

Two April 2015 internal duplicates were analysed. The RPD

exceedances were confined to:

Duplicates 1 – COD (104% compared to 50% acceptable);

Duplicates 1 - TKN and nitrogen (62% compared to 50%

acceptable); and

Duplicates 2 - TKN and nitrogen (98% compared to 50%

acceptable)

Field split testing (Secondary

laboratory).

The April 2015 field split duplicate RPD exceedances are:

Duplicates 1 – VFA (87% compared to 50% acceptable)

Duplicates 1 – Lead (95% compared to 50% acceptable)

Duplicates 1 – COD (125% compared to 50% acceptable)

Duplicates 2 – VFA (151% compared to 50% acceptable)

Duplicates 2 – COD (59% compared to 50% acceptable)

Duplicates 2 –Ammonia (88% compared to 50% acceptable)

Trip Blanks. Not undertaken.

Laboratory Internal QC. Evidence of the laboratories internal QC testing is present and

complete as provided by GHD. Both Eurofins-MGT (Primary) and ALS

(Secondary) performed internal QC with adequate testing and

satisfactory results for matrix spikes and method blanks.

Limit of Reporting. The Limits of Reporting were generally lower than the respective

assessment criteria for each of the analytes.

NATA endorsement of

Laboratory reports.

Laboratory reports were stamped with the NATA endorsement

stamp and signature.

Decontamination and

Equipment Blanks.

One rinsate blank was collected. No analytes were identified

above the limit of detection.

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Variables Description

Sample Integrity. Field Chain of Custody/Laboratory request forms can be found in

documents provided by GHD.

Validity of Data Set. The data quality review indicates no significant systematic errors in

the data collection process for groundwater and leachate and

therefore the data set used as the basis for assessment is considered

valid and complete.

7.2.4 Cat B Monitoring - LFG

Progress with the implementation of the LFG monitoring subprogram as developed is presented

in Table 7-6. The assessment has focussed on the April 2015 monitoring events.

Table 7-6: Progress with implementing LFG monitoring subprogram (Cat B)

Item Details

Installation of

new monitoring

bores

New bores LFG8A, LFG10A, LFG18A, LFG20A, and

LFG25 installed.

Compliant

Probes and

Bores –

Monitoring sites.

All designated LFG bores/probes are monitored

except for those that are flooded.

The bores have been positioned at approximately

50 m spacing where houses are proximal to filled

areas, and within approx. 250m spacing elsewhere

along the landfill boundary.

The soil vapour probes are connected to a quick

release fitting hence are not open to the atmosphere.

Typically only the very bottom section of each soil

vapour probes is screened.

Compliant

Probes and

Bores -

Monitoring

frequency.

Quarterly LFG monitoring is conducted. Compliant

Weekly monitoring of new LFG monitoring bores for

one month has not been conducted.

Not compliant

Probes and

Bores- sampling

procedures. -

GHD (2015b) advised LFG monitoring was undertaken

in accordance with EPA (2011c) Draft Landfill Gas

Fugitive Emissions Monitoring Guidelines.

GHD has hired all LFG monitoring equipment. Probes

and bore monitoring is undertaken with a GA5000

meter. Evidence of LFG equipment calibration has

been provided.

The Airmet GA5000 calibration sheets has not been

signed.

Compliant

Most LFG monitoring has been undertaken during

falling or low atmospheric pressure on all 2014/15

monitoring events.

Records of CH4, CO2, O2 concentrations during each

bore purge (minimum of six occasions).

Compliant

Monitoring

Procedure –

Surface of

Monitoring commenced in October 2014.

Limited to nine sampling points in Area A and Area B.

Not compliant

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Item Details

intermediate

cap.

Instrument not identified. Assumed to be an Inspectra

laser. No calibration certificate provided.

Area C that has not been

filled over the past three

months should be

monitored and grid over

the remainder of Area A

and B should be on a 25 m

grid.

Pits and other

enclosed spaces

– monitoring

points and

frequency.

Monitoring is undertaken at locations identified in the

verified monitoring program.

Monitoring has been undertaken on a quarterly basis.

Compliant

Pits and other

enclosed spaces

–equipment.

Services and buildings are monitored with an

Inspectra Laser for methane, and a GA5000/GA2000

for CO2, O2, CO and H2S concentrations (when

measured). CH4 in the services and buildings

monitoring field sheets is in ppm. This is confirmed in

Monitoring Record.

Compliant

Pits and other

enclosed spaces

–measurements.

Monitoring records include peak LFG concentrations

and location details.

Compliant

Monitoring

Procedure –

Indoor Air

Quality.

Within each building monitoring undertaken at one

location only.

As required monitoring is undertaken on a quarterly

basis. Monitoring occurs with an Inspectra Laser for

methane and a GA2000 for CO2 and O2. Inspectra

Laser calibration record not provided.

Partially compliant

Monitoring records do not include location details

(e.g. monitor positions, building conditions, presence

of odour). Would be useful to include description of

any evidence of corrosion, and presence of odours in

the notes.

Non-compliant

Monitoring

Procedure -

Plant Stress of

Die Back.

Plant health at and within 50 m of the landfill is now

monitored.

A more substantive record of the monitoring is

required.

Partially compliant

Monitoring

Procedure –

Infrastructure.

Perimeter fencing, buildings and the bore network,

and any other significant infrastructure are

photographed for signs of corrosion. These

photographs have not been interpreted.

The overhead 500 kV transmission line towers are not

included as they are maintained by AusNet Services.

The bore network is not currently monitored for

corrosion.

Generally compliant

Performance

indicator.

Guideline limits where relevant for the site are

followed.

Compliant

Incorporation of

LFG monitoring

data into

database.

While LFG monitoring data is captured in a data

management system, it is yet to be combined into a

single integrated database including groundwater

monitoring.

Not compliant

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7.3 Annual reporting

The annual report is provided in GHD (2015b) “Portland Landfill Annual Environmental

Monitoring Results Report 2014/15”.

The reports requires a declaration that the monitoring program was completely in accordance

with the verified monitoring program and explains any non-conformances, including names of

persons responsible for each component of the monitoring program.

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8. Interpretation of monitoring results

The scope of work for an audit of landfill operation includes an interpretation of monitoring

results.

8.1 Scope

The following has been considered in this interpretation of monitoring results:

Nolan Consulting (2014) “Section 53V Audit – Landfill Operation, Portland Landfill – 210

Cape Nelson Road Portland”;

Cardno LanePiper (2014b), “Hydrogeological Assessment - Portland Landfill, 210 Cape

Nelson Road, Portland, VIC”;

GHD (2015b), “Portland Landfill Annual Environmental Monitoring Results Report 2014/15”;

GHD (2015d), “Portland Landfill Annual Performance Statement 2015 Supporting

Information Report”; and

Cardno (2015b), “Hydrogeological Assessment for Leachate Level Management -

Portland Landfill 210 Cape Nelson Road, Portland, Vic”.

Cardno (2015b) presented:

hydrographs of all groundwater monitoring bores from 1991 to February 2015;

groundwater elevation plan (April 2015); and

salinity contours (April 2015).

8.2 Leachate levels

Information on leachate levels obtained from the three operating leachate monitoring bores

is presented in Table 8-1.

Table 8-1: Leachate bore information [after Cardno (2015b)]

Bore ID

Area

Ground

Surface

Base of

Bore

Waste

Thickn

ess

(m)

Waste

base

Bore

Depth

(mbgl)

Leachate Elevation

(m AHD)

(mAHD) (mAHD) (mAHD) Feb

2015

Apr

2015

Oct

2015

LB01 C 50.86 43.36 >7.5 <43.36 7.5 NA NA 43.946

LB01R C 50.9(1) 41.9(1) 8.9 42(1) 9.0 45.69 43.97 44.154

LB02RA B 49.2(1) 44.0(1) 5.2 44(1) 5.1 Dry Dry Dry

LB03 A 46.67 42.22 >4.5 < 42.22 4.5 43.63 Dry 42.856

(1) Estimated level, based on adjacent surveyed bores.

The waste at leachate bore LBO2RA (Area B) is dry. The leachate in Area C is up to 2.2 m above

the base of the waste at LB01R, and the leachate level in Area A (at LB03) fluctuates from dry

conditions to at least 1.4 m above the base.

The interpolated watertable surface at LBO3 as of April 2015 was about 36.0 m AHD. This

suggests the maximum leachate level of 43.63 m is up to 7 m above the watertable surface.

8.3 Groundwater flow direction

The overall groundwater flow direction is to the north-east.

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Of the nested piezometers separately monitoring the MSA and BFA aquifers, there is no

significant level difference to the south-west of the landfill (at PO26A/B) and there is a

downward gradient of:

0 m to 3.5 m at PO31A/31B at Madeira-Packet Road to the north;

0.17 m at PO34A/B to the north of the north-west corner of the leachate storage dam (as

of the October 2015); and

7.06 m at PO35A/B to the south-east of PO05R (of the October 2015).

The downward gradient is suggestive of local recharge through infiltration.

The mean upward gradient of about 0.3 m at PO33A/B since October 2013, located 140 m

north of IB6/IB7, suggests some impact of the LIS interception bores.

The level within the NVA at PO25 ranges between 7.5 m to 9 m below the level of the

adjacent MSA/BFA bore (PO06). There is a slight increase in the hydraulic gradient towards

the LIS interception bores which indicates a minor beneficial impact.

Over the two years since October 2013 the average change in the watertable surface has

been a marginal fall of 0.1 m. The monitoring bores with a +/- change in level of greater than

0.5 m are PO08R, PO09, PO17, and PO06 which had level falls of 0.6 m to 0.8 m, bore PO18

which had a fall of 1.8 m, and PO02 which had an increase in level of 0.8 m.

The level trends are seasonal and do not appear to reflect any obvious landfill impacts.

8.4 Water quality

8.4.1 Salinity and ammonia

As salinity and ammonia are key groundwater contamination indicators, the analytical results

from March 2010, July 2012, April 2015 and October 2015 are compared in Table 8-2.

Exceedances of water quality guideline values are highlighted. The salinity and ammonia

concentrations of April 2015 are mapped in Figure 12 and 13 respectively.

Table 8-2: Selective salinity and ammonia concentrations at monitoring sites

Site

Beneficial use Salinity as TDS guideline values (mg/L) Ammonia guideline values (mg/L)

Segment A2 1,000 -

Drinking water - Aesthetic 600 0.5

EcoSystem - Fresh Water 2,000 0.9

Stock watering 2,500 -

Salinity as TDS (mg/L) Ammonia (µg/L)

General Location 2/3/10 4/7/12 15/5/14 28/10/15 2/3/10 4/7/12 15/5/14 28/10/15

IB4 Down, local, Cell A NA 2,200 3,200 2,500 NA 25 79 63

IB5 Down, local, Cell A NA 3,000 1,200 2,900 NA 9.6 16 3.1

IB6 Down, local, Cell A NA 2,900 3,000 3,800 NA 9.1 51 1.7

IB7 Down, local, Cell A NA 2,200 2,400 1,800 NA 1.7 27 0.75

IB8 Down, local, Cell A NA NA 2,600 NA NA NA 240 NA

LB01 Cell C NA 5,300 NA 3,400 NA 490 NA 490

LB01R Cell C NA NA NA 3,100 NA NA NA 220

LB02R Cell B NA NA 2100 Decom. NA NA 130 Decom.

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Site

Beneficial use Salinity as TDS guideline values (mg/L) Ammonia guideline values (mg/L)

Segment A2 1,000 -

Drinking water - Aesthetic 600 0.5

EcoSystem - Fresh Water 2,000 0.9

Stock watering 2,500 -

Salinity as TDS (mg/L) Ammonia (µg/L)

General Location 2/3/10 4/7/12 15/5/14 28/10/15 2/3/10 4/7/12 15/5/14 28/10/15

LB02R Cell B Not installed NA Not installed NA

LB03 Cell A NA 9,500 NA 4,000 NA 800 NA 720

PO1 Down, Local, Cell C 1,100 1,300 1,100 1,200 0.54 2 0.74 0.63

PO4 Down, local, Cell C - 1,100 2,000 NA - 1 0.69 NA

PO05R Down, local, Cell C - 1,800 1,800 1,800 - 0.49 0.40 0.28

PO34A Down, Local, Cell C Not installed 1,800 Not installed 0.22

PO34B Down, local, Cell C Not installed 2,000 Not installed 0.47

PO35A Down, Local, Cell C Not installed 2,000 Not installed 0.09

PO35B Down, local, Cell C Not installed 3,100 Not installed 3.5

PO06 Down, local, Cell C 2,000 2,600 1,900 2,700 210 31 73 42

PO07 Down, local, Cell A 4,700 5,700 4,400 4,000 79 160 200 40

PO08R Down, local, Cell A - 6,800 4,800 6,000 - 1.2 79 28

PO13 Down, local, Cell C 1,300 1,200 930 1,300 0.05 0.10 0.36 0.15

PO19R Down, local, Cell A/B - 3,700 5,100 5,300 - 2.10 0.57 0.33

PO20 Down, local, Cell A/B - 3,200 3,300 3,700 - 1.5 5.6 4.5

PO22 Down, local, Cell A/B 2,400 2,100 3,000 3,000 0.05 0.04 0.06 0.05

PO25 Down, local, Cell A/B (NVA) NA NA 1,100 1,400 NA NA 0.27 0.47

PO33A Down, intermediate, Cell A NA NA 13,000 7,800 NA NA 0.92 0.38

PO33B Down, intermediate, Cell A NA NA 2,500 2,800 NA NA 0.13 0.22

PO12 Down, regional, Cell A - 570 1,100 900 - 0.19 0.06 0.05

PO14 Down, regional, north 560 680 480 790 0.043 0.30 0.43 0.06

PO30 Down, regional, north NA NA 1,200 1,400 NA NA 0.40 0.26

PO31A Down, regional, north NA NA 1,600 1,100 NA NA 0.06 0.1

PO31B Down, regional, north 1,200 1,300 0.27 0.33

PO32 Down, regional, north 1,400 3,200 0.31 0.88

PO3 Lat, local, west - 800 620 590 - 0.39 0.37 0.38

PO17 Lat, local, east - 1,900 1,100 1300 - 120 92 100

PO18R Lat, local, east - 2,100 2,300 1,300 - 42 0.12 2.7

PO21 Lat, local, east 1,100 1,100 930 960 0.34 0.42 0.37 0.32

PO28 Lat, local, east NA NA 1,000 1,100 NA NA 0.63 0.55

PO11R Lat, regional, east - 820 750 1,000 - 0.44 0.31 0.18

PO15R Lat, regional, north - 1,200 680 540 - 0.65 0.65 0.85

PO23 Lat, regional, east 480 410 660 830 0.33 <0.01 0.09 0.6

PO24 Lat, regional, east 330 510 420 470 0.15 <0.01 <0.01 <0.01

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Site

Beneficial use Salinity as TDS guideline values (mg/L) Ammonia guideline values (mg/L)

Segment A2 1,000 -

Drinking water - Aesthetic 600 0.5

EcoSystem - Fresh Water 2,000 0.9

Stock watering 2,500 -

Salinity as TDS (mg/L) Ammonia (µg/L)

General Location 2/3/10 4/7/12 15/5/14 28/10/15 2/3/10 4/7/12 15/5/14 28/10/15

PO29 Lat, regional, east NA NA 1,000 1,000 NA NA 0.43 0.38

PO2 Up, local, south 540 790 1,100 1,200 0.25 0.06 0.50 0.29

PO09 Up, local, south NA 490 820 570 0.05 0.07 0.08

PO26A Up, south-west corner NA NA 1,800 1,200 NA NA <0.01 <0.01

PO26B Up, south-west corner NA NA 680 650 NA NA 0.05 <0.01

LDam Down, local, Cell C NA NA NA 2,700 NA NA NA 6.5

This salinity monitoring data for April 2015 (Figure 12) indicates the following:

(a) The leachate salinity ranges from 3,100 mg/L in Cell C (LB01R) to 4,000 mg/L in Cell A

(LB03).

(b) Up-gradient groundwater salinity ranges from 300 mg/L to 980 mg/L (with the exception

of PO26A in the MSA which had a concentration of 1,500 mg/L in the April 2015

monitoring event).

(c) The salinity immediately down-gradient of Areas A/B is close to the leachate salinity, and

down-gradient of Area C is elevated above background but less than the leachate

salinity. The exception is monitoring bore PO35B which is screened across low

permeability sediments which contributes to the higher salinity of 3,100 mg/L.

(d) Elevated salinity concentrations extend at least 400 m to the north-east of Derril Road

(at PO32) and possibly 550 m (to Madeira-Packet Road at PO31A/PO31B and PO30). The

latter cannot be confirmed as the salinity is at the upper extent of the background

concentration range.

(e) The elevated salinity concentration plume extends to Cape Nelson Road to the east.

(f) There is a plume of elevated groundwater salinity at PO19, PO20, and PO22 (down-

gradient of Area A/B).

(g) The salinity in the MSA aquifer at the 2.5 m deep monitoring bore PO33A at the July 2013

monitoring event was 2,200 mg/L. This increased to 13,000 mg/L at the April 2015

monitoring event and has subsequently fallen to 7,800 mg/L in October 2015. The wide

fluctuations may reflect perching and/or evapotranspiration). The salinity of the BFA at

the nested piezometer is relatively stable at 2,300 mg/L to 2,800 mg/L.

(h) To the north-east along Madeira-Packet Road the groundwater salinity is generally similar

to the up-gradient salinity, suggesting down-gradient attenuation.

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This ammonia concentrations (Figure 13) indicate the following:

(a) Leachate ammonia concentration ranging from 270 mg/L in Area C (LB01R) to 800 mg/L

in Area A (LBO3) with an average of about 480 mg/L. [LBOR2A is not considered as it is

screened below the waste].

(b) Up-gradient concentration is less than 0.20 mg/L (with the exception of PO02 which has

a concentration varying from 0.06 mg/L to 0.50 mg/L and 0.29 mg/L in October 2015).

(c) High levels of contamination immediately down-gradient of Area A (PO07, PO08, and

PO20) and to the east of the site at PO17 (above 5 mg/L).

(d) Moderate levels of contamination, greater than 0.5 mg/L and less than 5 mg/L,

immediately down-gradient of Area C (PO01and PO4), immediately down- gradient of

Area A/B (PO06 and PO19R), down-gradient of Cell A (PO33A), east (PO28), and north-

west of Yarraman Park (PO15R).

(e) The ammonia concentration plume extends to at least 40 m the east of Cape Nelson

Road and attenuates to the north-east.

Based upon the above data the leachate plume extends:

at least 400 m to the north-east of Derril Road (at PO32) and possibly 550 m (to Madeira-

Packet Road at PO31A/PO31B);

to the east of Cape Nelson Road (PO17 and PO18); and possibly

to the north-west of Yarraman Park, (although this may be due to site specific sources of

ammonia).

The 2014 Audit of Landfill Operation reported on an increase in the extent of the leachate

plume from that reported in the 2013 Audit of Landfill Operation. This finding was considered to

be based upon additional data from bores installed in 2013 rather than further plume migration.

This 2016 Audit of Landfill Operation has found that the October 2015 plume extent has

stabilised since June 2014 with reductions in ammonia concentrations observed within the main

plume.

8.4.2 Water quality – other inorganics

Table 6 of GHD (2015b) tabulates bores reporting contaminant concentrations above

beneficial use guideline values for all 2014/15 monitoring events.

Elevated nitrate concentrations above the ANZECC (2000) Ecosystem Fresh water 95%ile of

0.16 mg/L are inconsistent and do not reflect the salinity and ammonia contamination plume.

For example ANZECC (2000) Ecosystem Fresh water 95%ile exceedances from the April 2015

monitoring event are found at PO06 (adjacent IB8), PO08R (between IB6 and IB7), PO18R (on

Cape Nelson Road), and PO26A (up-gradient at south-west corner of the site).

Volatile fatty acids are indicators of leachate contamination. Concentrations of above

20 mg/L were only found in April 2015 at PO32A (300 m north-east of the site entrance).

The Mulvey L/N ratio is an indicator of leachate contamination. It is:

(K +NH4+ NO3)/ (Mg + Ca + Na) x 100

The average leachate monitoring bore L/N ratio is 161. The average groundwater monitoring

bore L/N ratio is 4.3. The only ratios above 10 are at PO18R - 10.7 (along eastern boundary),

PO08R - 28.1 (between IB6 and IB7), PO32 - 40.2 (300 m north-east of the site entrance), PO03 -

42.9 (along western boundary), and PO01 – 101 (south-side of Derril Road).

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The exceedances of ANZECC (2000) Ecosystem support 95%ile and the NH&MRC and NRMMC

(2011) AWDG health guideline values for metals are presented in Table 8-3.

Table 8-3: Groundwater bore exceedances of metals beneficial use guideline values

Bore Cd Cu Pb Ni Se Zn

ANZECC (2000) EcoSystem Fresh Water (95%) 0.0002 0.0013 0.0044 0.011 0.011 0.015

NHMRC (2011) Drinking Water - health 0.002 2 0.01 0.02 0.01

Up-gradient bores

PO02 <0.0002 <0.001 <0.001 0.004 <0.001 0.029

PO26B <0.0002 0.001 0.004 0.009 <0.001 0.021

Lateral

PO18R (local, east) 0.0012 0.002 <0.001 0.055 <0.001 3.1

PO21 (local, east) <0.0002 0.009 <0.001 0.006 <0.001 0.01

PO11R (regional, east) <0.0002 <0.001 0.009 0.011 <0.001 0.013

PO15R (regional, north) <0.0002 <0.001 0.001 0.004 0.04 0.011

PO23 (regional, east) <0.0002 0.019 0.003 0.01 <0.001 0.037

Downgradient Area A/B (local)

PO06 <0.0002 0 <0.001 0.01 0.001 0.015

PO08R <0.0002 0.008 <0.001 0.014 0.003 0.029

PO20 <0.0002 <0.001 0.045 0.005 <0.001 0.015

PO22 <0.0002 <0.001 0.014 0.003 <0.001 0.011

Downgradient, intermediate, Cell A

PO33A <0.0002 <0.001 <0.001 0.004 <0.001 0.025

PO33B <0.0002 0.003 <0.001 0.006 0.001 0.008

Downgradient, regional, north

PO14 <0.0002 0.001 <0.001 0.025 <0.001 0.029

PO31A <0.0002 0.002 0.004 0.004 <0.001 0.01

PO31B <0.0002 0.011 0.002 0.001 <0.001 0.03

The metal beneficial use guideline value exceedances are inconclusive in demonstrating a link

with leachate. The most significant exceedance of the guideline values is the zinc

concentration of 3.1 mg/L at monitoring bore PO18R which is immediately east of Area A. Since

April 2013 the zinc concentration at this bore has ranged from 0.41 mg/L to a peak of 3.1 mg/L.

At the October 2015 monitoring event the concentration fell to 1.4 mg/L. At all other monitoring

bores the zinc concentration is within the background range.

8.4.3 Organics

Laboratory analysis was undertaken for BTEXs, monocyclic -aromatic hydrocarbons (MAHs),

organo-chlorine (OC) pesticides, polycyclic-aromatic hydrocarbons (PAHs), phenols, volatile

organic compounds (VOCs), semi-volatile organic compounds (SVOCs), chlorinated

hydrocarbons, explosives, halogenated hydrocarbons, herbicides, nitroaromatics. The only

exceedances of laboratory limits of reporting for the April 2015 monitoring event are presented

in Table 8-4.

ANZECC (2000) Ecosystem support 95%ile and the NH&MRC and NRMMC (2011) AWDG

guideline values are also presented in Table 8-4.

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Table 8-4: Groundwater bore exceedances of organics LORs

Be

nze

ne

1,2

-dic

hlo

rob

en

zen

e

1,4

-dic

hlo

rob

en

zen

e

Ch

loro

be

nze

ne

Bis

(2-e

thylh

exy

l) p

hth

ala

te

Bore µg/L µg/L µg/L µg/L µg/L

LOR 1 1 1 1 5

ANZECC (2000) Ecosystem Freshwater) 95%ile 950 160 60 NA NA

AWDG health guideline value 1 1500 300 300

PO06 <1 <1 <5 - 3 <1 <5

PO07 3 <5 - 3 <5 - 2 44 <5

PO08R <1 <1 <1 <1 5

PO10 <1 <1 <1 <1 10

PO11R <1 <1 <1 <1 6

PO20 1 <1 <1 17 <5

PO26B <1 <1 <1 <1 8

PO31A <1 <1 <1 <1 5

PO31B <1 <1 <1 <1 5

PO33A <1 <1 <1 <1 6

IB4 5 <1 <1 5 7

IB6 <1 <1 <1 <1 8

IB7A <1 <1 <1 <1 10

lB8 2 <1 <5 - 7 58 <5

LB01 <1 <1 <1 <1 10

LB01A <1 <1 <1 <1 14

Leachate storage dam <1 <1 <1 <1 6

The only exceedances of organic toxicant guideline values are for benzene at monitoring bore

PO07 and interception bores IB4 and IB8 which marginally exceed the ADWG guideline value

of 1 µg/L. Potable water has been identified as a beneficial use that is unlikely to be realised

(Table 6-3).

8.5 LFG monitoring

8.5.1 Subsurface monitoring

GHD monitored the LFG bores/probes for peak and stabilised CH4, CO2, O2 concentrations and

peak H2S and CO concentrations on six occasions over the audit period. The LFG bore steady

state CH4, CO2 and flow rate records are presented in Table 8-5.

Page 87: Section 53 V Audit - Landfill Operation

Ma

y 2

01

6

Pa

ge

79

Po

rtla

nd

La

nd

fill

- 2

10 C

ap

e N

els

on

Ro

ad

, P

ort

lan

d

Se

ctio

n 5

3V

Au

dit

No

lan

Co

nsu

ltin

g P

ty L

td

67

14

1-5

_a

.do

cx

Tab

le 8

-5:

LFG

bo

re s

tea

dy

sta

te C

H4,

CO

2 a

nd

flo

w r

ate

re

co

rds

Bo

re ID

C

H4

Ste

ad

y s

tate

%v

CO

2 S

tea

dy s

tate

%v

Flo

w r

ate

(L/

hr)

Bo

re ID

23/0

7/1

430/1

0/1

45-6

/02/2

015

30/0

4/1

54-6

/08/1

529/1

0/1

523/0

7/1

430/1

0/1

45-6

/02/2

015

30/0

4/1

54-6

/08/1

529/1

0/1

523/0

7/1

430/1

0/1

45-6

/02/2

015

30/0

4/1

54-6

/08/1

529/1

0/1

5

LFG

01

0.0

0.0

0.0

0.0

0.0

0.1

0.1

0.1

0.1

0.1

0.1

0.3

0.2

0.0

0.0

LFG

02

0.0

0.0

0.0

0.0

0.0

0.0

11.9

16.0

14.8

11.0

12.9

14.1

-0.1

0.4

0.2

0.3

0.0

0.0

LFG

03

0.0

0.0

0.0

0.0

0.0

1.0

0.9

0.9

10.0

0.8

0.4

0.2

0.3

0.0

0.0

LFG

04

0.0

0.1

-0.3

LFG

05

0.0

0.0

0.0

0.0

0.0

0.0

1.6

0.9

1.3

1.3

1.4

0.9

-0.2

0.3

0.1

0.2

0.0

0.0

LFG

06

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.1

3.9

2.5

0.1

3.1

-0.2

0.1

0.2

0.2

0.0

0.0

LFG

07

0.0

0.0

0.0

0.0

0.0

0.0

3.2

0.1

2.8

1.8

2.7

3.1

-0.2

0.2

0.1

0.3

0.0

0.0

LFG

08

0.0

0.0

2.2

1.7

0.2

0.2

LFG

8A

0.0

0.0

0.0

0.0

1.9

2.2

0.4

4.4

0.1

0.2

0.0

0.0

LFG

09

LFG

9A

00

00

1.2

0.9

1.3

2.5

0.1

0.3

00

LF810

0.0

0.0

0.0

0.7

1.3

0.1

0.0

0.2

0.0

LFG

10A

0.0

0.0

0.0

0.0

1.1

1.3

1.0

1.8

0.1

0.2

0.0

0.0

LFG

11

0.0

0.0

0.0

4.7

2.6

6.2

0.2

0.7

0.0

LFG

12

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.1

3.0

6.4

0.1

5.9

0.1

0.5

0.2

0.2

0.0

0.0

LFG

13

75.5

67.1

37.4

38.0

68.2

59.9

18.4

23.3

26.0

19.0

20.1

19.8

-0.2

0.3

0.1

0.2

0.1

0.0

LFG

14

0.0

0.0

0.0

0.0

0.0

5.6

5.4

9.8

7.3

6.5

0.1

0.3

0.2

0.3

0.0

LFG

15

0.0

0.0

0.0

0.0

0.0

0.1

3.0

3.7

0.1

2.2

0.3

0.3

0.4

0.0

0.0

LFG

16

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.1

1.3

1.7

2.8

2.8

0.0

0.3

0.1

0.2

0.0

0.0

LFG

17

0.0

0.0

0.0

0.0

0.0

0.0

1.4

1.6

1.5

1.2

1.5

1.5

-0.1

0.4

0.1

0.4

0.0

0.0

LFG

18

0.0

0.0

0.0

0.0

0.0

0.0

1.4

1.0

1.4

0.9

1.3

1.1

-0.3

0.3

0.2

0.2

0.0

0.0

LFG

18A

0.1

0.0

0.0

0.0

1.3

1.0

1.4

1.0

0.1

0.1

0.0

0.0

LFG

19

0.0

0.0

0.0

0.0

0.0

2.3

2.3

1.7

2.5

2.7

0.3

0.1

0.3

0.0

0.0

LFG

20

0.0

0.0

0.0

0.0

0.0

0.0

0.1

0.1

0.9

0.8

0.1

0.0

0.0

0.3

0.2

0.3

0.0

0.0

LFG

20A

0.0

0.0

0.0

0.0

0.4

0.9

1.1

0.3

0.1

0.2

0.0

0.0

LFG

21

0.0

0.1

4.3

LFG

22

0.0

0.0

0.0

0.0

0.0

0.1

0.1

0.1

10.4

0.1

0.0

0.2

0.1

0.2

0.0

LFG

23

1.1

0.0

0.0

0.0

0.5

0.0

3.3

2.7

2.1

2.8

3.0

2.2

0.1

0.8

0.1

0.2

0.1

0.0

LFG

24

0.0

0.0

0.0

0.0

0.0

0.0

5.3

2.7

3.1

3.0

4.8

3.1

0.0

0.4

0.1

0.2

0.1

0.0

LFG

25

0.0

0.0

0.0

0.0

0.6

0.8

2.5

0.6

0.0

0.3

0.0

0.0

Flo

w r

ate

(L/

hr)

CO

2 S

tea

dy

sta

te %

vC

H4 S

tea

dy

sta

te %

v

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Findings

The findings for the subsurface LFG monitoring over the audit period are summarised below.

On several occasions LFG probes could not be sampled as the tubing filled with water.

Monitoring bore LFG25 was installed as a background monitoring bore prior to the

February 2015 monitoring event.

Monitoring bore LFG13 is located within the waste mass. The methane concentration

over the monitoring period ranged from 37.4 %v/v to 75.5 % v/v. Monitoring bore LFG14

is also located in the waste mass

All boundary LFG probes recorded methane at concentrations below the EPA (2015a)

Landfill BPEM action level of 1% v/v at all monitoring events except for:

LFG23 at the 23/7/2014 monitoring event (1.0%).

Of the perimeter bores LFG monitoring bores LFG02, LFG07, LFG23 and LFG24 have CO2

concentrations that are consistently greater than 1%v/v above background

concentration. These are located along the eastern boundary except for LFG07 which is

located in the south-west corner.

Isolated CO2 concentrations of greater than 1%v/v above background concentration

have occurred at monitoring bores LFG03, LFG06, LFG11, LFG12, LFG15, LFG19, and

LFG22.

All CO2 concentrations are less than 10 % v/v above background except for LFG02 which

is up to 14.2 % v/v above background.

The maximum gas screening value (GSV) for CO2 is 0.044 L/hr which based upon CIRIA

(2007) represents a very low risk.

Discussion

The Nolan Consulting (2014) audit report recommended that four additional BPEM compliant

LFG monitoring bores be installed adjacent LFG probes LFG07, LFG08, LFG10, and LFG18. The

purpose was to assist in assessing the reliability of the LFG probes in comparison with BPEM

compliant bores.

The need or otherwise for replacement of the LFG probes with EPA (2015a) Landfill BPEM

compliant LFG monitoring bores was to be determined following a review of results from a few

monitoring events.

The CO2 concentrations at LFG08/8A, LFG10/10A, LFG18/18A and LFG20/20A are consistent

between bores and probes. The key exceptions are for LFG10/10A, and LFG20/20A in the

August 2015 monitoring event. In both occasions the probes recorded 0.1% v/v and the bores

recorded 1.0% v/v to 1.1% v/v. As the results are inconclusive ongoing monitoring of the probes

and bores up to the end of 2015/16 year is recommended.

While the reported CO2 exceedances of the EPA (2015a) Landfill BPEM action level are

relatively minor, and it is acknowledged that clayey sediments with organic matter often

record CO2 concentrations with the reported range, the potential for subsurface migration of

CO2 from the landfill cannot be excluded.

8.5.2 Landfill surface

The EPA (2015a) Landfill BPEM require the intermediate cover area of the landfill surface to be

monitored to determine if the 200 ppm methane concentration action level is exceeded.

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Quarterly monitoring commenced in October 2014. Typically this monitoring has been limited

to nine sampling points in Area A and Area B. Area C has not been monitored.

GHD (2015b) noted that methane concentrations at the landfill surface of greater than the

200 ppm action level have consistently been detected in a bare patch near LFG13, and to the

immediate east of the weighbridge. Up to 17,000 ppm (1.7%) methane has been detected in

this area. Other areas of exceedances have also been noted, and these generally correlate

with bare patches of cap, whereas the remainder is vegetated with grasses.

GHD (2015b) advised that some of the capped areas, particularly to the south, were not

monitored due to various access difficulties. While the recapping of the majority of Area A

and B should reduce methane concentration at the surface to below the final cap action level

of 100 ppm there is a risk of lateral migration around the southern area which will not be

recapped due to the presence of native vegetation

8.5.3 Building, structures and subsurface services

On all monitoring events the methane concentrations within all building, structures and

subsurface services were well below the EPA (2015a) Landfill BPEM action levels.

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9. Progress with previous Auditor's recommendations

John Nolan undertook a Section 53V groundwater audit of the Hyland Highway landfill in 2014.

This is referenced as Nolan Consulting (2014) “Section 53V Audit – Landfill Operation, Portland

Landfill – 210 Cape Nelson Road Portland”, Service Order No. 8004179.

The audit report presented twenty four recommendations. Progress on the works associated

with the recommendations is presented in Table 9-1.

Table 9-1: Progress with 2014 Audit of Landfill Operation recommendations

No Recommendation Completion

date

Auditor comment on

implementation progress

Monitoring program

1 Implement updated Monitoring Program including: Ongoing

(a) Install, survey, and monitor additional leachate

monitoring bores.

- near LB02R (to base of waste); and

- adjacent LB01 (to base of waste).

Mar 2015 Completed.

(b) Install, and monitor five additional BPEM

compliant LFG monitoring bores adjacent:

- LFG07, LFG08, LFG10, and LFG18; and

- groundwater monitoring bore PO15R

(background).

Mar 2015 Completed.

(c) Replace all the other soil vapour LFG probes

with new BPEM compliant LFG monitoring bores

(subject to confirmation from monitoring results

at LFG07, LFG08, LFG10, and LFG18 that soil

vapour probes may underestimate subsurface

LFG concentration and flows).

Dec 2015 Not required at this stage.

(d) commence methane monitoring of the interim

cap and the final cap (once installed).

Jan 2015 Partially completed.

Coverage is limited and

does not include Area C

(where filling has not

occurred for a period of

three months or more.

2 Provide all weather 4x4 vehicle access to within 5

m of all bores for all conditions except flooding

events.

Jun 2015 Not completed.

GSC propose to undertake

as part of associated cap

construction activities.

3 Established an integrated database to hold and

enable efficient reporting of all monitoring records

and data from 1989, preferably in ESDAT format in

accordance with the prepared service

specification.

Dec 2014 Not completed.

GHD has data in ESDAT

format from 2011. Earlier

data has been obtained

and now needs to be

entered manually.

Hydrogeology

4 Resolve with the EPA the potential for using the

Groundwater Quality Restricted Use Zone (GQRUZ)

under SEPP Groundwaters of Victoria as a

mechanism to manage this risk.

Mar 2014 Not commenced.

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No Recommendation Completion

date

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implementation progress

Conceptual model

5 Undertake a comprehensive analysis of MSA and

BFA aquifers groundwater quality analysis that

identifies discrete characteristics. This should

include using Stiff and Piper diagrams and Mulvey

L/N ratios.

Jun 2015 Not undertaken.

Cardno (2015b) considered

a single unit for the purpose

of hydrogeological

assessment of leachate

level management.

6 Investigate the hydraulic connection between the

Leachate Storage Dam and the watertable.

Jun 2015 Competed.

Undertaken by Cardno

(2015b).

7 Complete the Hydrogeological Assessment

supporting Post Closure PAN.

Dec 2015 Completed.

Leachate interception system

8 Upgrade the Leachate Interception System in

accordance with Cardno LanePiper (2014c)

recommendations. Specifically:

(a) Redevelop an existing bore, install a new

pump and test over a month to determine if

design pumping rate can be achieved.

Jan 2015 Completed.

(b) If the design pumping rate is achieved at the

redeveloped bore, redevelop the other three

existing bores and replacing the four old

pumps and fittings. If not develop and

implement an alternative leachate control

system that meets the design objectives.

Jun 2015 Completed. The three

existing bores redeveloped

and the old pumps and

fittings replaced.

(c) Install an intermediate sump and transfer pump

at the head of the transfer pipe to maximise

performance (as required).

As

required

Not required.

(d) Install three new bores (IB9 to IB11) to fully

intersect the BFA with new pumps.

Jun 2015 Not commenced.

Addressed in the Cardno

(2015b) Hydrogeological

Assessment

(e) Implement an Operation & Maintenance

manual and program to provide for system

monitoring and optimisation.

Aug 2015 Not commenced.

Infrastructure

9 Investigate the location of on-site electricity supply

pits and Telstra pits and include in LFG monitoring

program. This should consider the proposed

transfer station.

Mar 2015 Completed.

10 Ensure weighbridge office toilet is vented. Sep 2013 Not undertaken.

Vented amenities to be

provided in the new transfer

station facility.

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implementation progress

LFG Risk Management

11 Extend the Safe Work Procedure - Transfer Station

Operation – Ventilation of building to include the

Resale Centre and the toilet.

Dec 2013 Completed.

12 Review monitoring results from the new LFG

monitoring bores, to determine if any changes to

the risk profile are required.

Dec 2015 Completed.

Reviewed as part of this

audit of landfill operation.

13 Check that the GSC restriction on residential

development within 500 m of the site prevents any

future residential development, particularly of

buildings with unvented basements.

Mar 2015 Checked.

No planning trigger limiting

development within 500 m

buffer. Only one permit

issued within 500 m buffer

since 1st July 2015. It was for

a veranda.

Operational

14 Improve operational management procedures as

per the Landfill Compliance Risk Register

(Appendix F).

Ongoing No change since 2014.

15 Fence off Area A. Upon

completio

n of Area

A final

capping

Awaiting final capping.

16 Include daily checking of the waste height at the

tipping face in the monitoring and compliance

daily checklist (to ensure it does not exceed 2 m).

Ongoing Completed.

In Daily checklist.

Next audit

17 Undertake for period up to 31 December 2015. 31 Mar

2016

Completed through this

audit.

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10. Update and reverification of monitoring program

The Monitoring Program has been updated as part of this Audit of Landfill Operation to reflect

the revised CSM, the updated risk assessment, the Verification Auditor’s comment’s, the

assessment of the Monitoring Program over the audit period, and progress with implementing

the 2014 audit recommendations.

The updated monitoring program is presented below for:

roles and responsibilities;

Category A monitoring (visual and olfactory);

Category B monitoring (groundwater and leachate);

Category B monitoring (LFG);

reporting; and

contractor requirements.

In general the changes to the verified Monitoring Program (Nolan Consulting; 2014) are of a

minor nature.

10.1 Updated program

10.1.1 Roles and responsibilities

GSC is responsible for implementing and undertaking the monitoring program. In doing so it

should identify and allocate responsibilities for all monitoring activities to relevant staff and

consultants, and ensure that all responsible officers have adequate training and skills to perform

the tasks.

The Project Planning and Facilities Manager should:

undertake internal audits to ensure the monitoring program is being effectively

implemented; and

review the annual monitoring report and take the necessary actions arising from the

report outcomes.

The Resource Management Officer should facilitate the undertaking of the Category A

monitoring including the completing of the daily, weekly and monthly checklists.

10.1.2 Category A monitoring

Previously separate monitoring sub-programs were prepared for surface water, odour, litter,

vermin, dust, noise. These sub-programs have been brought together into a single Category A

(Cat A) program. This program includes infrastructure (corrosion), dust, and on-site vegetation

health.

The prerequisites for the implementation of the Cat A monitoring are:

the preparation of monitoring checklists at daily, weekly, and quarterly frequencies; and

provision of appropriate staff training.

The updated Cat A monitoring program is presented in Table 10-1.

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Table 10-1: Updated Category A monitoring program

Variables Description

Monitoring locations Location Hazard Regular

frequency

Landfill cap. Surface water/leachate. Weekly

Weeds. Quarterly

Access roads. Surface water/leachate. Weekly

Transfer and recycling station. Surface water/leachate. Weekly

Corrosion. Quarterly

Leachate storage pond &

immediate surrounds &

stormwater detention ponds

(when constructed - for

overflow & seepage).

Surface water/leachate. Weekly

Odour. Daily

Litter. Daily

Vermin. Weekly

Site boundary. Surface water/leachate. Weekly

Noise. Weekly

Odour. Daily

Litter. Daily

Dust. Weekly

Vermin (fence check). Weekly

On & within 50m of landfill. Plant health. Quarterly

Weighbridge & site office. Corrosion. Quarterly

Bore network. Corrosion. Quarterly

Resale Centre. Corrosion. Quarterly

Compressor shed. Corrosion. Quarterly

Noise. Weekly

Active tipping face. Odour. Daily

Litter. Daily

Cover material. Daily

Dust. Weekly

New works area. Noise. Weekly

Dust. Weekly

Surface water/leachate. Weekly

Site Entry. Dust. Weekly

Other triggers for

inspections

Complaint or notification of a discharge by any GSC staff.

New works area.

Construction of a new cell.

Extreme event (such as very high winds & significant storm).

Placement of odorous material (for odour only).

Following any significant change in site operational procedures.

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Variables Description

Reporting to include Name of responsible officer, date & time of day.

Environmental conditions (wind direction and strength and

temperature).

Discharge across the site boundary (e.g. stormwater, sediment, litter)

with likely source, direction and characteristics (e.g. colour, odour, and

turbidity for water).

Emissions across site boundary (odour, dust, and noise).

Freeboard in leachate storage dam less than 0.5m (i.e. BEPM threshold).

Extent of any in-site or off-site water ponding.

Cause of any off-site discharge /emissions or significant on-site

generation.

Actions taken to address issue.

Performance

indicators

Generic

No complaints.

Stormwater

No evidence of leachate pond failure, leakage or over filling (i.e.

freeboard to be maintained at >0.5m).

No evidence of significant ponding (i.e. for extended periods after

rainfall.).

Noise

No excessive noise above levels established as normal.

Triggers for sampling

and analysis

Stormwater

Off-site discharges – when significant off-site discharge of odorous

and/or turbid water occur. Sampling and analysis for pH, TDS,

suspended solids, phosphorous, total nitrogen and TOC as a minimum.

Fawthrop Lagoon - if leachate plume is shown to extend within 500 m of

the lagoon. Sampling and analysis as above on a quarterly frequency.

Stormwater sedimentation ponds once constructed - Sampling and

analysis as above on a quarterly frequency.

Dust

More than four dust complaints in any one financial year would trigger

the installation and monitoring of a minimum of three dust gauges

(adjacent the active tipping face, adjacent active traffic area, and on

boundary downwind). See Lane Piper (2010b) for further detail.

Noise

In the event of a future development of the landfill or urban

encroachment from surrounding areas which may result in a change of

risk level to a “High Risk” site, the noise limits may then need to be

monitored to ensure compliance with acceptable noise levels stated in

EPA (2011d) “Noise from Industry in Rural Victoria”.

Records Evidence of staff training for monitoring across all categories. In

particular odour monitoring along boundary should only be taken by

staff that have been calibrated.

Daily log book of key on-site activities, personal on-site, visitors, OHS

incidents, and any key environmental issues.

Daily, weekly, and monthly check list templates.

Completed checklists.

Evidenced of actions taken.

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Variables Description

Up to date complaints register including, relevant photographs, actions

taken and conclusion of task (i.e. objective achieved) with name of

person responsible.

Associated

procedures

Dust management – to identify dust suppression watering triggers (i.e.

no of dry days, wind direction etc., and watering arrangements.

Responsibility Landfill staff (trained).

The updated Cat A monitoring program includes the requirement to take stormwater samples

once the stormwater sedimentation ponds are constructed. These will be analysed to

determine if any impact from leachate or other known contaminants at the site.

10.1.3 Groundwater and Leachate (Cat B)

The updated Groundwater and Leachate monitoring program (Cat B) is presented in Table

10-2.

Table 10-2: Updated groundwater and leachate monitoring subprogram (Cat B)

Variables Description

Level control IB bores, leachate monitoring bores, and groundwater monitoring bores to top of

casing and ground surface level (mAHD).

As constructed Leachate Storage Dam floor level (mA HD).

Outstanding bores requiring level control are PO34A, PO34B, PO35A and PO35B

and new leachate monitoring bores LB01R and LB02RA

Monitoring

locations and

infrastructure

Groundwater bores

The following groundwater bores shall be monitored for standing water level and

sampled for laboratory analysis:

PO1, PO2, PO3, PO4, PO05R, PO06, PO07, PO08R, PO09, PO10, PO11R, PO12,

PO13, PO14, PO15R, PO17, PO18R, PO19R, PO20, PO21, PO22, PO23, PO24,

PO25, PO26A, PO26B, PO28, PO29, PO30, PO31A, PO31B, PO32, PO33A,

PO33B;PO34, PO34A, PO35, PO35A.

Install new monitoring bore in the wooded area between Area C and the

northern boundary.

Leachate interception bores

The following leachate interception bores (IB bores) shall be monitored for water

quality and cumulative pumped volume.

IB4, IB5, IB6R and IB7.

All leachate interception bores shall be maintained with pulse counters and level

data loggers. The only outstanding item is a level data logger on IB5.

Leachate monitoring bores

The following leachate monitoring bores shall be monitored for standing water

level and water quality.

LB01, LB01A, LB02RA, and LB03.

New bores in centre of Area A and Area B to confirm cell base elevation and

leachate level in the centre of these cells.

Leachate storage dam

A gauge board shall be established and maintained within the leachate storage

dam.

The leachate storage dam shall be monitored for level and quality.

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Variables Description

A Cumulative flow meter shall be installed and maintained on the LIS discharge

line near the leachate storage dam.

Weather station

Install temporary weather station for on-site rainfall to improve the estimate of net

evaporation loss and support the calculation of the leachate storage dam water

balance.

Guideline values Presented in Table 6-2.

Frequency Weekly Dam level.

LIS bore levels (download quarterly).

Cumulative pump pulse counts.

Flow rate from LIS system to leachate storage dam.

Rainfall and pan evaporation.

Quarterly

(Jan, Apr,

Jul, Oct)

All bores (groundwater and leachate monitoring, and leachate

interception bores) to be tested for:

TDS;

pH;

major ions (sodium, calcium, potassium, magnesium, chloride,

sulphate, carbonate, bicarbonate), including charge balance

error calculations;

nitrogen species (ammonia, nitrate, nitrite, total nitrogen, TKN);

Volatile fatty acids;

Metals (antimony, arsenic, Cd, beryllium, total Cr, copper,

cobalt, lead, mercury, molybdenum, nickel, selenium, tin, zinc);

Methane;

BOD and COD; and

TOC.

To the extent possible analysis should be conducted to method

detection limits compatible with criteria for protection of

groundwater beneficial uses.

Annually

(Jan)

Bores PO1, PO4, PO05R, PO06, PO07, PO08R, PO13, PO19R, and

PO25 to be tested for:

SVOC screen (GC/MS USEPA 8270C); and

VOC screen (P&T GC/MS USEPA 8260B.

Procedures Compliance with EPA (2000) “Groundwater Sampling Guidelines” and EPA (2009)

“Sampling and Analysis of Waters, Wastewaters, Soils and Wastes”.

Standing Water Level (SWL) Monitoring

At the commencement of each groundwater monitoring event, groundwater

level shall be gauged using a water level meter in accordance with methods

specified in EPA Pub 669 Section 4.4.

A water level meter shall be used to measure the depth to groundwater relative

to the ground level and surveyed top of PVC casing in each bore.

Groundwater Sampling Method

In each groundwater monitoring event samples shall be collected for laboratory

analysis using a low flow (minimum purge) methodology in accordance with

methods specified in EPA Pub 669 Section 4.5.2.

Field Records

A completed sampling record is required for each bore including bore/site details,

standing water level, stabilised parameter values and sample containers used.

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Variables Description

Field Parameters

Groundwater physiochemical parameters (field parameters - temperature,

electrical conductivity, dissolved oxygen, redox potential, pH) to be monitored

and recorded during groundwater removal (purging), prior to collecting

groundwater samples for laboratory analysis.

Groundwater Sample Collection

Sampling shall commence once the physiochemical parameters have stabilised

within ranges stated in EPA Pub 669, Section 4.5.1. Samples shall be collected

directly into new and appropriately preserved laboratory bottles and packed in

chilled containers for delivery under Chain of Custody documentation.

Samples for metals analysis shall be filtered to 0.45 μm in accordance with EPA

Pub 669, Section 4.8.

QC Samples

In each monitoring event the following QC samples shall be collected in

accordance with methods outlined in EPA Pub 669, Section 4.3.2, and

analysed for the suite of analytes applicable to primary groundwater samples.

2 x blind duplicates (for analysis at the primary lab).

2 x field split (for analysis at a secondary lab).

1 x rinsate blank.

In addition to the requirements stated above, one trip blank sample shall be

collected during the annual (Jan) event and analysed for VOC screen analysis.

Maintenance of monitoring infrastructure

In the event bores (groundwater, leachate and interception) and leachate

storage dam monitoring infrastructure are found to not be clearly labelled or

damaged (e.g. locks broken, corrosion of steel standpipe etc.), this information

shall be recorded on field log sheets and GSC notified immediately following

completion of the monitoring event. Arrangements shall be made to rectify these

deficiencies in bore identity and integrity.

In the event that the sample water from bores is turbid, and/or includes sand,

bores should be redeveloped in accordance with methods outlined in EPA Pub

669 Section 3.3, including (but not limited to) actively agitating the water column

prior to the removal of water until water is visibly clean and of constant quality

(meets the criteria for physiochemical properties for sampling). Observations

made during bore development, such as (but not limited to) volumes and water

quality observations, shall be recorded on a bore development log.

Measure LIS bores on a quarterly basis for silt ingress and clean out if there is a

significant build up and leachate pumping is compromised.

Performance

indicator

Groundwater, leachate and LIS monitoring has proceeded in accordance with

requirements outlined in the monitoring program and any subsequent

recommendations provided in future audits of landfill operation.

The leachate bore level, LIS flow, groundwater level, and groundwater chemistry

triggers are not exceeded as described in the Cardno (2015b) Hydrogeological

Assessment.

The monitoring program may need to be revised (i.e. monitoring frequency

decreased and/or bores removed from program):

in consultation with the appointed Environmental Auditor where increasing

contaminant concentration trends are reported; and

in the event contaminant concentrations fall below criteria for protection of

beneficial uses.

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Variables Description

Bores outside the site boundary maintain water quality levels within the

groundwater segment identified for the area.

10.1.4 Landfill gas (Cat B)

The updated LFG monitoring program (Cat B) is presented in Table 10-3.

Table 10-3: Updated LFG monitoring subprogram (Cat B)

Item Details

Monitoring Procedure

Probes and Bores

The LFG bores/probes to be monitored are:

LFG01, LFG02, LFG03, LFG04, LFG05, LFG06, LFG07, LFG08, LFG09,

LFG10, LFG11, LFG12, LFG15, LFG16, LFG17, LFG18, LFG19, LFG20,

LFG21, LFG22, LFG23 and LFG24 – oil vapour probes with Teflon

tubing (at landfill boundary).

LFG13, LFG14 – 25 mm diameter PVC bores (in landfill cap).

LFG08A, LFG09A, LFG10A, LFG18A, and LFG20A EPA (2015a)

Landfill BPEM compliant bores

LFG25 background EPA (2015a) Landfill BPEM compliant bores.

Replacement of all other soil vapour LFG probes with new BPEM

compliant LFG monitoring bores (subject to confirmation from

monitoring results at LFG08A, LFG10A, LFG18A and LFG20A that soil

vapour probes may underestimate subsurface LFG concentration

and flows (to be determined after last monitoring event in

2015/16).

At all times the bores are to be sealed at the surface from the

atmosphere.

Monitoring Procedure

Probes and Bores

Quarterly (Jan, Apr, Jul, Oct) LFG monitoring.

Weekly monitoring for one month, for new LFG monitoring bores,

following installation.

Monitoring shall (to the extent practicable) be conducted during

falling and/or low atmospheric pressure.

All LFG monitoring equipment shall be operated in accordance with

manufacturer’s instructions and to requirements provided in EPA

(2011c) Landfill Gas Fugitive Emissions Monitoring Guidelines, Publ. No.

1416.

The following LFG monitoring procedure shall be followed at bores /

probes, with

1. Run meter in ambient air and record ambient air readings until

stabilisation.

2. Record bore pressure reading using a manometer (or equivalent).

If reading above 1mmH2O, then also take a pressure reading at

conclusion of monitoring.

3. Record gas flow rate and relative pressure. Ensure the unit has

been “zeroed” prior to taking these readings.

4. Purge LFG probes for a minimum period of one minute and bores

for a minimum period of three minutes. Record CH4, CO2, O2

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Item Details

concentrations (to 0.5% or lower) on a minimum of six occasions

during each bore purge.

5. If concentrations are fluctuating, continue running pump and

recording concentrations at 1 minute intervals until stable.

6. At completion of monitoring at each bore / probe, purge the

meter in open air until ambient readings are achieved.

Monitoring of monitoring trace elements (volatile organics) at

monitoring bores LFG02, LFG07 and LFG23 over two consecutive

monitoring events.

Monitoring Procedure –

Surface of landfill

Monitor on a 25m square grid over cap and intermediate cover (where

filling will not be undertaken for the next three months) and final cover

areas. This should include the vegetated areas of Areas A and B.

Diversions off the grid pattern to target and monitor any cracks,

odours, stressed vegetation, or infrastructure potentially penetrating

the cap (e.g. bores, posts) is allowed.

Conduct monitoring on a quarterly basis.

Monitor with extendable probe with the specifications recommended

in the EPA (2011c).

The operator should stand still for several seconds and record readings

at ground surface.

Locations (GPS co-ordinates) and concentrations of elevated

methane and carbon dioxide should be recorded along with wind

speed and direction.

This procedure should be modified as required to conform to any

changes between the draft and EPA (2011c) guidelines.

Monitoring Procedure -

Pits and other enclosed

spaces

Monitor:

Leachate Interception pits (IB4 to IB7)

Telstra pits (i) at corner of Cape Nelson Road and Derril Road and

(ii) other on Cape Nelson Road;

water main pit adjacent bore LFG02;

stormwater drains at

- Cape Nelson Road (near cemetery gate)

- 275 Cape Nelson Road

- corner of Derril Road and Cape Nelson Road

- corner Malings Road and Cape Nelson Road

- between recycling shop and weighbridge

following structures

- beneath weighbridge

- shipping container

- weighbridge office

- weighbridge toilet

- shed behind weighbridge

- recycling shop;

new pits and enclosed spaces established with new transfer station

and associated infrastructure; and

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Item Details

compressor house, compressor electrical box, and beneath

compressor house slab.

Quarterly (Jan, Apr, Jul, Oct) monitoring.

Monitor for CH4, CO2, and O2 concentrations.

Record CH4, CO2, O2 concentrations within pit or enclosed space

immediately upon opening of manhole cover, lid etc.

1. Monitoring records should include LFG concentrations (peak and

stabilised) and location details, evidence of corrosion, and

presence of odours.

2. The program should be modified as required to conform to any

changes in the final version of the EPA (2011c) guidelines.

Within each building monitor at several representative locations to

provide an even coverage of the space while focussing on areas

where gas ingress is most likely (i.e. floor holes or cracks).

Monitoring Procedure –

Indoor air

Conduct monitoring on a quarterly basis.

Monitoring equipment should be operated in accordance with

manufacturer’s instructions.

At each location monitor for several minutes or until readings have

stabilised.

Monitoring records should include LFG concentrations (peak and

stabilised) to an accuracy of ± 0.5% or less and location details (e.g.

monitor positions, building conditions, presence of odours).

This procedure should be modified as required to conform to any

changes between the draft and final EPA (2011c) guidelines.

Action levels as per

Table 10-5 (from Table 6.4 of the BPEM; 2014b).

Performance Indicator All LFG monitoring data and associated information shall be recorded

on standard field record sheets.

Records and Data

Management

LFG monitoring data shall be incorporated into the database

established for groundwater monitoring.

Table 10-4 provides the required details of the LFG monitoring equipment and Table 10-5

provides details of the LFG performance indicators.

Table 10-4: LFG Monitoring Equipment Details

Item Details

LFG bore monitoring An extractive LFG analysers that meets the Performance specification

as per Table 4.1 of EPA (2011c) and is capable of monitoring flow to 0.1

L/hr.

The analyser shall be calibrated to monitor methane (CH4), carbon

dioxide (CO2), oxygen (O2) and flow. Calibration certificates to be

provided by from rental company.

Landfill surface, service

trenches and pits, and

buildings and structures

monitoring

A low-concentration methane detector that meets the Performance

specification as per Table 4.2 of EPA (2011c). An extendable probe to

be used for the landfill surface survey.

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Item Details

An extractive LFG analyser should be used to monitor CO2 and O2 in

service trenches and pits

The meters shall be calibrated. Calibration certificates to be provided

by the rental company.

Pressure gauge A pressure measure device (i.e. manometer, bi-directional gauge or

equivalent) is required to gauge relative bore pressure prior to and

following sampling of the bore. The pressure gauge should allow for

relatively low pressures (e.g. as low as Pascals rather than mbar or

hectapascals).

Table 10-5: LFG Performance Indicators [from Table 6.4 EPA (2015A) Landfill BPEM]

Location Parameter(s) Action level and unit

Landfill surface final cover

areas.

Methane concentration in air

(50 mm above the landfill

surface).

100 ppm.

Within 50 mm of penetrations

through the final cap.

Methane concentration in air

(50 mm from the point of

discharge).

100 ppm.

Landfill surface intermediate

cover areas (not scheduled to

receive waste during the next

three months).

Methane concentration in air

(50 mm above the landfill

surface).

200 ppm.

Within 50 mm of penetrations

through the intermediate cover.

Methane concentration in air

(50 mm from the point of

discharge).

1,000 ppm.

Biofilters. Methane flux. 1.0 g/m2/hr.

Subsurface geology at the

landfill boundary.

Methane and carbon dioxide

concentrations.

1.0 % v/v methane

or

1.5% v/v CO2 above

background.

Subsurface services on and

adjacent to the landfill site.

Methane concentration. 10,000 ppm.

Buildings/structures on and

adjacent to the landfill site.

Methane concentration in air. 5,000 ppm.

LFG flares. Methane and volatile organic

compounds.

98% destruction efficiency.

LFG flares. Methane and volatile organic

compounds.

98% destruction efficiency.

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10.1.5 Annual Reporting (Cat B)

An annual monitoring report is required each completed financial year. The report should

include the following:

A summary of the scope of the monitoring events and methods using tabulations;

A declaration that the monitoring program was completely in accordance with the

verified monitoring program and explains any non-conformances, including names of

persons responsible for each component of the monitoring program;

Identification of any changes to the monitoring points;

A tabulated checklist of all bores at the site noting compliance with the monitoring

specification for each monitoring event, i.e. stating that the bore was sampled or

otherwise noting the reasons for non-compliance;

New field and laboratory groundwater, leachate, and LFG data should be added to a

database holding and enabling efficient reporting of all monitoring records and data

from 1989, preferably in ESDAT compatible format;

A listing of all equipment used by make and model and evidence of any calibration; and

Plans showing the locations of all monitoring locations (i.e. bores, pits, indoor locations)

and general site features;

For water sampling:

- tabulated field parameters and laboratory analytical data, including graphical

presentation of trends for key parameters (including but not limited to reduced

water levels , pH (field), EC (field), dissolved oxygen (field), ammonia (as N), nitrate

(as N), calcium, chloride, magnesium, manganese (filtered), total iron (filtered),

potassium, sodium, sulphate, TDS, and TOC);

- Groundwater flow contour plan;

- Ammonia and TDS iso-concentration maps;

- NATA-stamped laboratory certificates for all results;

- signed chain of custody and laboratory sample receipt records;

- trend analysis for groundwater reduced level, ammonia, nitrate, and TDS;

- Exceedances of beneficial use criteria;

- Equipment calibration certificates; and

- Originals of the groundwater, surface water and leachate field record sheets.

For LFG monitoring:

- tabulated field parameters and laboratory analytical data, including graphical

presentation of trends for key parameters;

- NATA-stamped laboratory certificates for all results;

- signed chain of custody and laboratory sample receipt records;

- trend analysis for groundwater reduced level, ammonia, nitrate, and TDS;

- Exceedances of EPA(2015b) BPEM action levels;

- Equipment calibration certificates; and

- Originals of LFG field record sheets.

An electronic recording device (CD-ROM or USB memory stick) containing the annual

data set as well as a copy of the entire updated database.

An assessment of performance.

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An annual licence compliance report should be prepared in support of the Annual

Performance report as well as the QA/QC monitoring requirements listed in the landfill

compliance risk register (Appendix F).

The annual report should also assess performance against the leachate bore level, LIS flow,

groundwater level, and groundwater chemistry triggers as described in the Cardno (2015b)

Hydrogeological Assessment.

10.1.6 Monitoring contractor requirements (Cat B)

The monitoring contractor is required to be to be prequalified, suitably qualified and

experienced to undertake the monitoring in accordance with EPA guidelines and industry

standards of practice. The pre-qualification criteria are:

operates under a quality management system certified under ISO/AS9001, covering the

monitoring activities contained in this specification;

procedures for each of the monitoring activities required by the program;

has written Safe Work Procedures for the required work;

has staff experienced and trained in the requisite monitoring tasks;

operates a suitably qualified NATA certified chemical testing laboratory (able to conduct

tests and issue NATA reports for ALL of the requisite testing) OR has a service agreement

with a suitable NATA certified laboratory;

has a service agreement with a second or quality control laboratory;

owns and operates OR has a service agreement with a provider of all requisite field

equipment and instruments;

has a data validation procedure and system;

operates a data management system using compatible with ESDAT software operated

by the client’s consultants and Auditor;

experienced in reporting monitoring results to EPA and or EPA-appointed Environmental

Auditors; and

documented evidence of all of the above must be submitted to GSC for pre-

qualification.

10.2 Environmental audit program

The next audit of landfill operation is scheduled for 31st October 2017 with the audit period

being up to 30th June 2017. Thereafter, and subject to the outcome of the 2017 audit, the

subsequent audits should be undertaken every two years unless superseded by the yet to be

developed environmental monitoring program which will be required under the Closed Landfill

supporting PAN for aftercare.

10.3 Reverification

This updated Monitoring Program is considered to be complete and is therefore verified as

being adequate for GSC and the EPA to determine compliance with the licence.

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11. Conclusions

Risk of landfill operations to beneficial uses identified by the environmental Auditor

1 The Nolan Consulting (2014) risk assessment, including the risk registers, has been

reviewed. The risk register has been updated as part of the audit. No changes to the risk

profile have been required.

2 The following are considered to be very high risks:

groundwater contamination by leachate:

from active cell (on site);

from active cell (off site);

via unsaturated zone (on site); and

via unsaturated zone (off site).

3 The following are considered to be high risks:

LFG migration via unsaturated zone (on-site);

groundwater contamination by leachate from active waste cell impacting on

down gradient groundwater users; and

asphyxiation resulting in death or serious injury of site workers caused by a LFG

explosion via unsaturated zone migration.

4 The following are considered to be medium risks:

corrosion of on-site transmission towers via leachate through the unsaturated zone;

and

litter from active waste cell on the health of flora & fauna and visual amenity;

windblown and traffic generated litter from active waste cell on amenity of on-site

workers;

windblown dust from site activities and traffic on amenity of on-site workers;

windblown dust from site activities on health of on-site workers and humans at

nearby residences and Yarraman Park;

traffic generated on health of on-site workers;

odour from leachate storage dam on amenity of workers;

toxic gases (H2S) on health of maintenance workers;

noise from machinery, equipment, and traffic on amenity of workers;

leachate, via runoff and/or groundwater pathways, on surface water beneficial

uses;

contamination of land by overfilling of leachate storage dam;

on-site groundwater caused by increased level in leachate storage dam

increasing infiltration through unsaturated zone;

vermin from active waste cell on amenity of on-site building occupants and

humans at and in the vicinity of the landfill;

damage to flora due to fire at active waste cell;

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poor weed management within the site on amenity and local flora; and

erosion from capped landfill on on-site flora and fauna.

5 The beneficial uses adopted for the atmosphere at the premises, groundwater beneath

the premises, any surface water on the premises and the environment surrounding the

premises are appropriate.

6 The environmental aspects adopted in the updated risk register are comprehensive and

appropriate.

Assessment of implementation of the Monitoring Program

7 The previously verified Monitoring Program (Nolan Consulting; 2014) was structured as

specific sub-programs for individual environmental elements.

8 There are two generic categories of monitoring within the verified environmental

programs. These are Category A for regular or incident driven inspections by trained GSC

staff and Category B for groundwater, leachate, and LFG sampling and testing based

programs.

9 The Category A monitoring activity is observation (visual and olfactory) by trained GSC

staff. The verified Monitoring Program requires evidence of the observations to be

reported.

10 Implementation of the Category A monitoring is progressing. Further improvements are

required in staff training, systematic monitoring and reporting.

11 The Environmental Monitoring contract includes most Category B monitoring

requirements presented in the verified Environmental Monitoring program.

12 The Category B groundwater and leachate monitoring sub-program was implemented

in accordance with the verified monitoring program except for:

a level data logger has not been installed in LIS bore IB5;

new groundwater bores PO34A, PO34B, PO35A and PO35B and new leachate

monitoring bores LB01R and LB02RA are yet to be not surveyed;

flow meter on LIS discharge line has failed;

pulse counters (for flow) and data loggers (for level) installed but are yet to be

reported;

chain of custody forms do not to identify sample containers;

trip blank sample not obtained during the VOC sampling; and

completed groundwater bore purging and sampling records do not report on bore

condition.

13 The LFG monitoring sub-program was implemented in accordance with the verified

monitoring program except for:

monitoring records of pits and other enclosed spaces did not include location

details, evidence of corrosion, and presence of odours;

LFG monitoring in building records do not include location details (e.g. monitor

positions, building conditions, and presence of odours);

monitoring for signs of corrosion at the bore network is not undertaken, and

reporting of corrosion monitoring results needs to be documented ;

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LFG surface monitoring is limited to a few (nine) locations on Area A and B and

does not include Area A and B vegetated areas and sections of Area C which has

not been filled within any three month period.

plant health at and within 50 m of the landfill while monitored is not fully reported.

14 LFG monitoring data is not incorporated into the integrated monitoring database.

15 The annual monitoring report requires a declaration that the monitoring program was

completely in accordance with the verified monitoring program and explains any non-

conformances, including names of persons responsible for each component of the

monitoring program.

Interpretation of monitoring results - groundwater

16 The background groundwater is within Segment A2 (less than 1,000 mg/L).

17 The groundwater salinity immediately down-gradient of Areas A and B is close to the

leachate salinity, and the salinity down-gradient of Area C that is elevated above

background but less than the leachate salinity. The salinity plume extends to the north-

east (including to the east of Cape Nelson Road).

18 The background groundwater ammonia concentration is less than 100 µg/L.

19 Elevated ammonia contamination of the groundwater, at concentrations of 5 mg/L and

above, occur immediately down-gradient of Area A and to the east of the landfill site.

There are moderate levels of ammonia contamination immediately down-gradient of

Area C, immediately down-gradient of Area A/B, to the east of Cape Nelson Road, and

north-west of Yarraman Park.

20 The elevated TDS and ammonia concentrations are associated with landfill leachate.

21 Evidence of nitrate concentration above the ANZECC (2000) Ecosystem Freshwater 95th

percentile guideline values are inconsistent and do not reflect the salinity and ammonia

contamination plume.

22 Volatile fatty acids are indicators of leachate contamination. Concentrations of 20 mg/L

or above were only found in April 2015 at PO32A (300 m north-east of the site entrance).

23 The average Mulvey L/N ratios at the leachate monitoring bore L/N ratio is 161. The only

groundwater bores with ratios above 10 that may be indicative of a leachate impact

are at PO18R (along eastern boundary), PO08R (between IB6 and IB7), PO32 (300 m

north-east of the site entrance), PO03 (along western boundary), and PO01 (south-side

of Derril Road).

24 There is negligible evidence of volatile organic and semi-volatile organic compounds in

the groundwater. There were no exceedances of the ANZECC (2000) Ecosystem

Freshwater 95th percentile trigger value and the Australian Drinking Water Guidelines

health guideline values for these compounds except for benzene at PO07 and LIS bores

IB4 and IB8 which marginally exceed the AWDG health guideline value of 1 µg/L.

25 The leachate plume extends at least 400 m to the north-east of Derril Road and possibly

550 m to Madeira-Packet Road as well as to the east of Cape Nelson Road.

26 This 2016 Audit of Landfill Operation has found that the October 2015 plume extent has

stabilised since June 2014 with reductions in ammonia concentrations within the main

leachate plume,

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Interpretation of monitoring results – landfill gas

27 All boundary LFG probes recorded methane at concentrations below the BPEM

boundary action level of 1% v/v at all monitoring events except for LFG23 at one

monitoring event when 1.0% was recorded.

28 Of the perimeter bores LFG monitoring bores LFG02, LFG07, LFG23 and LFG24 have with

CO2 concentrations that are consistently over 1%v/v above background. These are

located along the eastern boundary except for LFG07 which is located in the south-west

corner.

29 Isolated CO2 concentrations of greater than 1%v/v above background have occurred

at monitoring bores LFG03, LFG06, LFG11, LFG12, LFG15, LFG19, and LFG22.

30 All CO2 concentrations are less than 10 % v/v above background except for LFG02 which

is up to 14.2 % v/v above background concentration.

31 The maximum gas screening value (GSV) for CO2 is 0.044 L/hr which based upon CIRIA

(2007) represents a very low risk.

32 The CO2 concentrations at joint LFG probe/EPA (2015a) Landfill BPEM compliant bores

sites for LFG08/8A, LFG10/10A, LFG18/18A and LFG20/20A are consistent between bores

and probes. The key exceptions are for LFG10/10A, and LFG20/20A in the August 2015

monitoring event. In both occasions the probes recorded 0.1% v/v and the bores

recorded 1.0% v/v to 1.1% v/v. As the results are inconclusive ongoing monitoring of the

probes and bores up to the end of 2015/16 year is recommended.

33 While the reported CO2 exceedances of the EPA (2015a) Landfill BPEM action level are

relatively minor, and are unlikely to be landfill sourced, the potential for subsurface

migration of CO2 from the landfill cannot be excluded.

34 Monitoring of the Area A and Area B landfill surface has found methane concentrations

above the 200 ppm action level at several locations. These are generally in areas with

poor vegetation development.

35 While the recapping of the majority of Area A and B should reduce methane

concentration at the surface to below the final cap action level of 100 ppm there is a risk

of lateral migration within the lower lying areas which will not be recapped due to the

presence of native vegetation.

36 The methane concentrations within all building, structures and subsurface services were

well below the EPA (2015a) Landfill BPEM action levels, except for one instantaneous

methane concentrations of 22.0 ppm found outside the stormwater drain at Cape Nelson

Road near the cemetery gate. This is well below the EPA (2015a) Landfill BPEM action

level of 5,000 ppm.

37 There are no obvious LFG trends based upon the limited set of historical records.

Updated Monitoring Program

38 The Monitoring Program (Nolan Consulting; 2014) has been updated as part of this Audit

of Landfill Operation to reflect the revised CSM, the updated risk assessment, the

verification auditor’s comment’s, the Monitoring Program assessment, and progress with

implementing the 2014 Audit of Landfill Operation recommendations.

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39 The updated Monitoring Program includes the following elements:

roles and responsibilities;

Category A monitoring (visual and olfactory);

Category B monitoring (groundwater);

Category B monitoring (LFG);

reporting; and

contractor requirements.

40 In general the updates are of a minor nature. The key changes are the inclusion of one

additional groundwater monitoring bore, two additional leachate monitoring bores, and

the expansion of the methane landfill surface monitoring program.

41 The updated Monitoring Program is verified as meeting the EPA (2011b) Landfill Licensing

Guidelines requirements and being adequate for GSC and the EPA to determine

compliance with the licence.

Implementation of progressive rehabilitation

42 GSC has scheduled the landfill to close following the commissioning of the transfer

station. This is expected to occur in mid-2016.

43 The Rehabilitation Plan has been approved by the EPA. This includes the top of waste

Pre-settlement Contour Plan.

44 The Technical Specification and Construction Quality Assurance Plan for Phase 1

Capping (Stages 1 and 2 cap) have been completed.

45 Phase 1 capping is expected to occur in the 2016/17 financial year. The delay from that

scheduled in the Rehabilitation Plan is due to the need to address native vegetation

management issues as required under the Environment Protection and Biodiversity

Conservation Act 1999 and to consider alternative capping design options.

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12. Recommendations

This section of the audit report presents the environmental audit recommendations. The

recommendations are based on risk assessment and are prioritised as defined in Table 12-1.

Table 12-1: Definition of priorities of auditor recommendation

Priority Description

High Requires immediate action to manage high environmental risk or mitigate high

impact

Medium Requires prompt action (within six months) to manage moderate to low impact.

Low Requires action prior to the next Landfill Operation Audit to manage a low

environmental risk, or mitigate a low impact.

The recommended completion dates of several low priority recommendations are in advance

of the next Landfill Operation Audit as it is practical to do and is considered desirable to provide

the information required to monitor changes to the risk profile.

The recommended completion dates of several high priority recommendations are not

immediate as additional monitoring, design or construction is required. For these

recommendations the completion dates are considered that which can be practically

achieved based upon an immediate and prioritised focus.

The recommendations are presented in Table 12-2. These recommendations incorporate the

outstanding recommendations from the Nolan Consulting (2014) “Section 53V Audit – Landfill

Operation, Portland Landfill – 210 Cape Nelson Road Portland”.

Table 12-2: Audit of Portland Landfill operation recommendations

No Recommendation Risk rating Recommended

completion date

Monitoring program

1 Implement updated Monitoring Program including: High Ongoing

a) Install, survey, and monitor additional leachate monitoring

bores.

Centre of Area A (to base of waste); and

Centre of Area B (to base of waste).

High Aug 2016

b) Install, survey and monitor one additional groundwater

monitoring bore in the vegetated area between Area C and

the northern site boundary.

High Aug 2016

c) Install a level data logger in LIS bore IB5. High Aug 2016

d) Install temporary weather station at site to monitor rainfall and

evaporation.

Med Nov 2016

e) Survey new groundwater bores PO34A, PO34B, PO35A and

PO35B, new leachate monitoring bores LB01R and LB02RA, and

the above proposed bores to AHD and location.

Low Dec 2016

f) Maintain the flow meter on the LIS discharge line. High Ongoing

g) Ensure chain of custody forms identify sample containers. Low Ongoing

h) Ensure trip blank sample are obtained during the VOC

sampling.

Low Ongoing

i) Ensure groundwater bore purging and sampling records report

on bore condition.

Low Ongoing

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No Recommendation Risk rating Recommended

completion date

j) Undertake methane monitoring of the capped and

intermediate landfill surface, which was not been filled within

the preceding three month period. at a 25 m grid. This should

include the vegetated area of Area A and Area B.

Med First monitoring

event following

Phase 1

capping

k) Identify the location of new service pits associated with the

transfer station and ancillary facilities.

High Upon

commissioning

l) Revise building, structures and service pit LFG monitoring points

to accommodate the new transfer station and ancillary

facilities

High Upon

commissioning

m) Provide a more comprehensive report of plant health at

specific locations on the cap and within 50 m of the landfill.

Low Next audit

2 Provide all weather 4x4 vehicle access to within 5 m of all bores for

all conditions except flooding events.

Low First monitoring

event following

Phase 1

capping.

3 Establish an integrated database to hold and enable efficient

reporting of all monitoring records and data from 1989, preferably

in ESDAT format in accordance with the prepared service

specification.

Low Next audit

Hydrogeology

4 Resolve with the EPA the potential for using the Groundwater

Quality Restricted Use Zone (GQRUZ) under SEPP Groundwaters of

Victoria as a mechanism to manage this risk.

Low Next audit

Conceptual model

5 Undertake a comprehensive analysis of MSA and BFA aquifers

groundwater quality analysis that identifies discrete characteristics.

This should include using Stiff and Piper diagrams and Mulvey L/N

ratios.

Medium Mar 2017

Leachate interception system (LIS)

6 Operate the LIS in accordance with the Cardno (2015b)

“Hydrogeological Assessment for Leachate Level Management -

Portland Landfill 210 Cape Nelson Road, Portland, Vic.”

High Jul 2016

7 Monitor the LIS in accordance with the verified Monitoring Program

(Table 10-2 of this report). This includes reporting of level, flow rate,

and condition at individual LIS bores, leachate level at leachate

storage dam, flow to leachate storage dam and leachate storage

dam water balance.

High Jul 2016

8 Review the LIS monitoring data every six months to determine the

effectiveness of operation whether the leachate bore level, LIS

flow, groundwater level, and groundwater chemistry triggers are

not exceeded as described in Cardno (2015b) “Hydrogeological

Assessment for Leachate Level Management - Portland Landfill 210

Cape Nelson Road, Portland, Vic”..

High Ongoing

9 Implement an Operation & Maintenance manual and program to

provide for system monitoring and optimisation.

Med Sep 2016

Infrastructure

10 Confirm with AusNet Services that they have responsibility for

monitoring structural integrity of the HV transmission line towers

(including corrosion).

Low Next audit

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No Recommendation Risk rating Recommended

completion date

LFG Risk Management

11 Review monitoring results from the LFG monitoring probe/bores

monitoring sites, to determine if any changes to the risk profile are

required.

Med Jul 2016

12 Check that the GSC restriction on residential development within

500 m of the site prevents any future residential development,

particularly of buildings with unvented basements.

Med Nov 2016

13 Review the need for LFG control in Areas A and B, particularly

around the eastern part of the site, within a thin corridor along the

southern fringe and the adjoining Malings Road reserve where the

existing cap will not be remediated.

Med First monitoring

event following

Phase 1

capping.

Planning

14 Investigate and implement a mechanism to control proposed

developments within 500 m from the landfill. This would involve a

trigger to identify planning permit applications for such

developments and a process to identify and mitigate risk such as

through an Environmental Significance Overlay or an

Environmental Audit Overlay.

Low Next audit

15 Complete Aftercare Management Plan in accordance with the

Post Closure Supporting PAN.

Med In accordance

with PAN

requirements.

Operational

16 Ensure the stormwater drainage system for the Phase 2 cap is

designed for the whole site and includes adequate stormwater

sedimentation pondage(s) to allow capture and treatment of

stormwater prior to discharge from the site.

Low With Phase 2

cap design

17 Ensure the Phase 2 cap design considers the management of the

shallow fill found to the north-west of the leachate storage dam as

part of the drilling program to install monitoring bore 35A/B.

Med With Phase 2

cap design

18 Remediate the existing perimeter drainage system. Low Next audit

19 Improve operational management procedures as per the Landfill

Compliance Risk Register (Appendix F). These include:

Establish a procedure to report on site infrastructure corrosion

inspection photographs to identify action requirements;

Low

Next audit

Ensure daily inspections are undertaken on all days in which

the landfill is operating;

Low Ongoing

Modify the daily and monthly checklists to identify the locality

where observations are made; and

Low Sep 2016

Maintain a record of visual inspections of loads at the

weighbridge.

Med Sep 2016

20 Ensure at least 300 mm of daily cover is placed on the tipping face

and the intermediate cover within Area C is maintained. This will

require additional cover over parts of Area C where litter is

emerging.

Med Ongoing

21 Fence off Area A. Low Next audit

Auditor activities

22 Review assessment of LIS system performance against triggers and

determine whether the LIS performance meets the design

objective for period from 1st January 2016 to 31st December 2016

High Feb 2017

23 Undertake for period up to 30th June 2017. Medium 31st Oct 2017

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13. Applicability

This environmental audit report (“Report”) has been prepared in accordance with Part IXD of

the Environmental Protection Act 1970. The objective of the audit is to identify and, where

possible, quantify the risk of possible harm or detriment to a segment of the environment

caused by the operation of the Portland landfill.

This Report:

1. has been prepared by John Nolan and his team as indicated in the appropriate sections

of this Report (“Nolan Consulting”) for the Glenelg Shire Council (“Council”).

2. may be used and relied on by Council and EPA Victoria.

3. may be provided to other third parties but such third parties’ use of or reliance on the

Report is at their sole risk.

The maximum extent permitted by law, all implied warranties and conditions in relation to the

services provided by Nolan Consulting and the Report are excluded unless they are expressly

stated to apply in this Report.

The services undertaken by the Auditor, his team and Nolan Consulting in connection with

preparing this Report were undertaken in accordance with current professional practice and

by reference to relevant environmental regulatory authority and industry standards in

accordance with Section 53V of the Environment Protection Act 1970.

The opinions, conclusions and any recommendations in this Report are based on assumptions

made by the Auditor, his team and Nolan Consulting when undertaking services and preparing

the Report (“Assumptions”), as specified throughout this Report.

Nolan Consulting and the Auditor expressly disclaim responsibility for any error in, or omission

from, this Report arising from or in connection with any of the Assumptions being incorrect.

Subject to paragraphs in this section of the Report, the opinions, conclusions and any

recommendations in this Report are based on conditions encountered and information

reviewed at the time of preparation of this Report and are relevant until such times as the site

conditions or relevant legislations changes, at which time, Nolan Consulting expressly disclaims

responsibility for any error in, or omission from, this Report arising from or in connection with

those opinions, conclusions and any recommendations.

The Auditor and Nolan Consulting have prepared this Report on the basis of information

provided by Council, which the Auditor and Nolan Consulting have not independently verified

or checked (“Unverified Information”) beyond the agreed scope of work.

Authorised on 26th May 2016 by:

John Nolan

Environmental Auditor

(appointed pursuant to the Environmental Protection Act 1970)

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14. References

Legislation and Regulations

Government of Victoria (1970), “Environment Protection Act, 1970”, Act No. 8056/1970).

Government of Victoria (1988), “Flora and Fauna Guarantee Act, 1988”.

Government of Victoria (1994), “Catchment and Land Protection Act, 1994”.

Government of Victoria (1997), “State Environment Protection Policy (Groundwaters of

Victoria)”.

Government of Victoria (1994), “Catchment and Land Protection Act, 1994”.

Government of Victoria (2001), “State Environment Protection Policy (Air Quality

Management)”.

Government of Victoria (2002), “State Environment Protection Policy (Prevention and

Management of Contaminated Land)”.

Government of Victoria (2003), “Variation to State Environment Protection Policy (Waters of

Victoria)”.

Government of Victoria (2004), “Waste Management Policy (Siting, Design and Management

of Landfills)”.

Guidelines

Australian and New Zealand Environment Conservation Council ANZECC (1992), “Australian

Water Quality Guidelines for Fresh and Marine Waters”.

Australian and New Zealand Environment Conservation Council (2000), “Australian and New

Zealand Guidelines for Fresh and Marine Water Quality”.

Australian Standard (2009), “AS2159-2009: Piling – Design and Installation”.

CIRIA (2007), “Assessing Risk Posed by Hazardous Ground Gases to Buildings”, CIRIA

Publication C665.

Food Standards Australia New Zealand (2014), ”Australia New Zealand Food Standards Code

- Standard 2.6.2 - Non-Alcoholic Beverages and Brewed Soft Drinks”.

National Health and Medical Research Council (2008), “Guidelines for Managing Risks in

Recreational Waters”.

National Health and Medical Research Council and Natural Resources Management

Ministerial Council (2011), “National Water Quality Strategy: Australian Drinking Water

Guidelines 6 2011”.

UK Environment Agency (2004), “Guidance on the Management of Landfill Gas”, September

2004

EPA References

EPA (2000), “Groundwater Sampling Guidelines”, Publication 669.

EPA (2009), “Sampling and Analysis of Waters, Wastewaters, Soils and Wastes”, Publication

IWRG701.

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EPA (2010), “Clean Up Notice pursuant of Section 62A of the Environment Protection Act 1970”,

2 March 2010.

EPA (2011a), “Licensing Assessment Guidelines – Guidelines for Using a Risk Assessment

Approach to Assess Compliance with Licence Conditions”, Publication No. 1321.2, June 2011.

EPA (2011b), “Landfill Licensing Guidelines”, Publication 1323.2, August 2011.

EPA (2011c),”Draft Landfill Gas Fugitive Emissions Monitoring Guidelines”, Publication 1416,

September 2011.

EPA (2011d), “Noise from Industry in Regional Victoria Recommended Maximum Noise Levels

from Commerce, Industry and Trade Premises in regional Victoria”, Publication No. 1411,

October 2011”.

EPA (2014), “Glenelg Shire Council, EPA Licence”, last amended on 30 June 2014.

EPA (2015a) “Best Practice Environmental Management Siting, Design, Operation and

Rehabilitation of Landfills”, Publication 788.3, August 2015.

EPA (2015b), “Preparation of Environmental Audit Reports on Risk to the Environment”,

Publication 952.5, 21st December 2015.

General information

Government of Victoria (current), “Victorian Water Measurement Information System”, web

based product.

Site Specific References

AGC Woodward-Clyde (1991), “Leachate Interception system borefield design”.

AGC Woodward-Clyde (1992), “Proposal for licence amendment and supporting

documentation for Works Approval in the Matter of AAT Appeal No 1992/11803 & 1991/42675”,

for Portland City Council, June 1992.

Cardno (2015a), “Upgrade to Groundwater & Leachate Monitoring Network Portland Landfill,

210 Cape Nelson Road, Portland, Victoria”, 29th October 2015.

Cardno (2015b), “Hydrogeological Assessment for Leachate Level Management - Portland

Landfill 210 Cape Nelson Road, Portland, Vic.”, 11th December 2015.

Cardno LanePiper (2011a), “Landfill Risk Assessment – 210 Cape Nelson Road, Portland

Victoria”, June 2011.

Cardno LanePiper (2011b), “Landfill Monitoring Program – 210 Cape Nelson Road, Portland

Victoria”, December 2011.

Cardno LanePiper (2014a), “Portland Landfill Telephone Survey 210 Cape Nelson Road,

Portland, Victoria”, 5 March 2014

Cardno LanePiper (2014b), “Hydrogeological Assessment - Portland Landfill, 210 Cape Nelson

Road, Portland, VIC”, April 2014.

Cardno LanePiper (2014c), “Leachate Interception System Upgrade Feasibility, Portland

Landfill – 210 Cape Nelson Road, Portland Victoria”, October 2014.

Geological Survey of Victoria (1978), “Portland 1:63,360 Geological Mapsheet”.

Page 116: Section 53 V Audit - Landfill Operation

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Page 108

Portland Landfill - 210 Cape Nelson Road, Portland

Section 53V Audit

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67141-5_a.docx

GHD (2011), “Report for Further Investigation of Waste Disposal Options – Stormwater

Management Plan”, report to Glenelg Shire Council, September 2011.

GHD (2013), “Portland Landfill Rehabilitation Plan”, report to Glenelg Shire Council, October

2013.

GHD (2015a), “Portland Landfill Leachate storage dam Liner Geotechnical Report”, report to

Glenelg Shire Council, 27th May 2015.

GHD (2015b), “Portland Landfill Annual Environmental Monitoring Results Report 2014/15”,

report to Glenelg Shire Council, 20th August 2015.

GHD (2015c), “Landfill Leachate Interception Bores Pump Installation”, report to Glenelg Shire

Council, 8th September 2015.

GHD (2015d), “Portland Landfill Annual Performance Statement 2015 Supporting Information

Report”, report to Glenelg Shire Council, 10th September 2015.

GHD (2015e), “Portland Landfill Rehabilitation - Phase 1 Landfill Cap Technical Specification”,

report to Glenelg Shire Council, November 2015

GHD (2015f), “Portland Landfill Rehabilitation - Phase 1 Landfill Cap Design Drawings”, report to

Glenelg Shire Council, November 2015

GHD (2015g), “Portland Landfill Rehabilitation - Phase 1 Landfill Cap CQA Plan”, report to

Glenelg Shire Council, November 2015.

GHD (2015h), “Portland Landfill Stages 1 and 2 Final Cap Design Auditor Assessment”, report to

Glenelg Shire Council, December 2015.

Glenelg Shire Council (2011a), “Portland Landfill Licence HS776 Clean up Plan“, 3rd March 2011.

Glenelg Shire Council (2011b), “Plant Health Survey Portland Landfill”, May 2011.

Glenelg Shire Council (2014), “EPA Annual Performance Statement 2014-2015”.

Glenelg Shire Council (2015), “Portland Transfer Station – Landfill Gas Risk Assessment”.

Lane Piper (2010a), “Environmental Audit Report (Groundwater - 2010) - 210 Cape Nelson

Road, Portland”, 30 July 2010.

Lane Piper (2010b), “Environmental Audit Report (Landfill Gas) - 210 Cape Nelson Road,

Portland”, 3 December 2010.

LMS Generation Pty Ltd (2007), “Landfill Gas Evaluation of the Portland Landfill”, June 2007.

Nolan Consulting (2014) “Section 53V Audit – Landfill Operation, Portland Landfill – 210 Cape

Nelson Road Portland”, CARMS Ref. No. 67141-4, Service Order No. 8004179, November 2014.

Senversa (2013), “Landfill Cap Investigation Portland Landfill”, April 2013.

Page 117: Section 53 V Audit - Landfill Operation

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Section 53V Audit

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67141-5_a.docx

15. List of abbreviations and units

Chemical Names

BOD Biological Oxygen Demand

BTEX Benzene, Toluene, Ethylbenzene & Xylenes (subset of MAH)

MAH Monocyclic Aromatic Hydrocarbons

OCP Organo Chlorine Pesticides

PAH Polycyclic Aromatic Hydrocarbons

SVOC Semi-Volatile Organic Compounds

TDS Total Dissolved Solids (salinity of water)

TOC Total Organic Carbon

VOC Volatile Organic Compound

Technical Terms

AHD Australian Height Datum

AMG Australian Map Grid

ANZECC Australian and New Zealand Environment and Conservation Council

BFA Bridgewater Formation Aquifer

BGL Below Ground Level

CQAP Construction Quality Assurance Plan

COC Chain of Custody

DO Dissolved Oxygen

EC Electrical Conductivity

EPA Environmental Protection Authority

GCMS Gas Chromatograph - Mass Spectrometer

LFG Landfill Gas

LOR Limit of Reporting

MSA Malanganee Sands Aquifer

NEPM National Environmental Protection Measure

NVA Newer Volcanic Aquifer

N/A Not Applicable

PSCP Pre-settlement Contour Plan

QA Quality Assurance

QC Quality Control

RPD Relative Percentage Difference

Page 118: Section 53 V Audit - Landfill Operation

May 2016

Page 110

Portland Landfill - 210 Cape Nelson Road, Portland

Section 53V Audit

Nolan Consulting Pty Ltd

67141-5_a.docx

Units

Ha Hectares

mAHD metres Australian Height Datum

mg/L Milligram per Litre

mTOC Metres below Top of Casing

ppb Part per Billion

ppm Parts per Million

μg/L Microgram per Litre

μS/cm Micro Siemens per Centimetre (Electrical Conductivity - Water)

Page 119: Section 53 V Audit - Landfill Operation

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Portland Landfill - 210 Cape Nelson Road, Portland

Section 53V Audit

Nolan Consulting Pty Ltd

67141-5_a.docx

Figures (after Cardno; 2015b)

Figure 1: Site Locality Plan

Figure 2: Landfill Development Sequence

Figure 3: Bore Location Plan

Figure 4: Landfill Gas Bore Location Plan

Figure 5: Leachate Collection System

Figure 6: Regional Geology

Figure 7: Geological Cross-Section A-A’

Figure 8: Geological Cross-Section B-B’

Figure 9: Groundwater Elevation (April 2015)

Figure 10: Groundwater Hydrographs

Figure 11: Groundwater Database Search Results

Figure 12: Groundwater Salinity (April 2015)

Figure 13: Groundwater Ammonia Concentration (April 2015)

Page 120: Section 53 V Audit - Landfill Operation
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3

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Page 130: Section 53 V Audit - Landfill Operation

PR

OJE

CT:

RE

F:

10

Fig

ure

.cdr

SC

ALE

: N

A

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AW

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V: 1

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: N

ove

mber

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FIG

: 10

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No: 209195.8

TIT

LE

:

Gro

un

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g-13

Sep

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Oct

-13

No

v-13

Dec

-13

Jan

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Feb

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Mar

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Ap

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May

-14

Jun

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Page 131: Section 53 V Audit - Landfill Operation

PR

OJE

CT:

RE

F: F

igure

11.c

dr

SC

ALE

: N

A

DR

AW

N: G

GS

RE

V: 1

DA

TE

: Ja

nuary

2015

FIG

: 11

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No: 209195.8

TIT

LE

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un

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Page 132: Section 53 V Audit - Landfill Operation

PR

OJE

CT:

RE

F:

12

Fig

ure

.c

dr

SC

ALE

: S

ee s

cale

bar

DR

AW

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V: 1

DA

TE

: O

ctober

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FIG

: 12

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No: 209195.8

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Page 133: Section 53 V Audit - Landfill Operation

PR

OJE

CT:

RE

F:

13

Fig

ure

.c

dr

SC

ALE

: S

ee s

cale

bar

DR

AW

N: D

JL

RE

V: 1

DA

TE

: N

ove

mber

2015

FIG

: 13

JOB

No: 209195.8

TIT

LE

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mo

nia

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200

400

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