IR-T08 Amendment Notice (Major) template · 2020. 4. 7. · AMP Asbestos Management Plan Asbestos...

L6956/1997/11 IR-T08 Amendment Notice (Major) template v2.0 (July 2017) 1

Licence Number L6956/1997/11

Licence Holder Shire of Victoria Plains

File Number: DWERVT1560

Premises Bolgart Refuse Site

Bolgart East Road

BOLGART WA 6568

Legal description –

Lot 1 on Diagram 16424

Certificate of Title Volume 1182 Folio 811

Date of Report 7 April 2020

Status of Report Final

Amendment Report


1. Definitions and interpretation

Definitions

In this Amendment Report, the terms in Table 1 have the meanings defined.

Table 1: Definitions

Term Definition

AACR Annual Audit Compliance Report

Amendment Report refers to this document

AMP Asbestos Management Plan

Asbestos Guidelines

means the document titled Guidelines for managing asbestos at construction and demolition waste recycling facilities, published by the Department of Environment and Conservation, 2012 as amended from time to time

BGL below ground level

Category/ Categories/ Cat.

categories of Prescribed Premises as set out in Schedule 1 of the EP Regulations

CEO means Chief Executive Officer.

CEO for the purposes of notification means:

Director General Department Administering the Environmental Protection Act 1986 Locked Bag 10 JOONDALUP DC WA 6919

or:

[email protected]

CS Act Contaminated Sites Act 2003

Delegated Officer an officer under section 20 of the EP Act

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

DWER Department of Water and Environmental Regulation

EP Act Environmental Protection Act 1986 (WA)

mailto:[email protected]


Term Definition

EP Regulations Environmental Protection Regulations 1987 (WA)

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

Landfill Definitions means the document titled Landfill Waste Classification and Waste Definitions 1996 published by the CEO as amended from time to time

Licence Holder Shire of Victoria Plains

Minister the Minister responsible for the EP Act and associated regulations

NEPM National Environmental Protection Measure

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

Prescribed Premises

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

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

Revised Licence the amended Licence issued under Part V, Division 3 of the EP Act, with changes that correspond to the assessment outlined in this Amendment Report.

Risk Event as described in Guidance Statement: Risk Assessment

SAQP Sampling and Analysis Quality Plan

Special Waste Type 1

has the meaning defined in Landfill Definitions

2. Amendment Description

This amendment has been informed by DWER’s Regulatory Framework which is available at https://www.der.wa.gov.au/our-work/regulatory-framework.

2.1 Purpose and scope of assessment

The purpose of this assessment is to undertake a CEO initiated licence amendment of L6956/1997/11. The licence is for the Bolgart Refuse Site, a prescribed premises Category 64 Class II landfill in Bolgart, Western Australia (the premises).

The scope of the amendment includes:

Removal of an improvement program condition requiring the Licence Holder to submit a groundwater Sampling and Analysis Quality Plan (SAQP). The Licence Holder

https://www.der.wa.gov.au/our-work/regulatory-framework


submitted this document on 17 December 2019 and has satisfied this condition.

Addition of new conditions which require the installation and monitoring of groundwater monitoring bores at the premises and submission of an annual groundwater monitoring report.

Removal of an improvement program condition requiring the Licence Holder to submit an Asbestos Management Plan (AMP). The Licence Holder submitted this document on 18 February 2020.

Addition of new conditions relating to asbestos management at the premises.

This amendment provides DWER with an opportunity to assess the acceptability of the submitted groundwater SAQP and AMP and amend the licence to reflect the requirements of the proposed groundwater investigation and asbestos management measures.

2.1.1 Background

2015 Licence amendment The premises is partially located within the Bolgart Water Reserve, a Priority 2 Public Drinking Water Source Area (P2 PDWSA). The revised Bolgart Water Reserve Drinking water source protection plan (herein referred to as the ‘Water Source Protection Plan’) was released in April 2016 (Department of Water [DOW], 2016a). The Water Source Protection Plan outlined that the Bolgart Water Reserve boundary had been changed to reflect a better understanding of the hydrogeology of the area (DOW, 2016a). The new boundary was based on the surface catchment boundary for both the Western and Bull Road wellfields (DOW, 2016a).

The revised boundary incorporated most of the premises within the Bull Road wellfield. The Water Source Protection Plan identified the Bolgart Refuse Site as a high management priority land use due to the potential for contaminants to leach from the unlined landfill into groundwater. At the time, the then Department of Water (DOW) recommended that the Licence Holder:

implement a groundwater monitoring system to monitor potential contaminant plumes which may be moving towards the production bore; and

investigate the proper closure of the old sections of the landfill and the capture of contaminated water at the site.

Class II landfilling activities are incompatible with P2 PDWSAs based on Water quality protection note no. 25 Land use compatibility tables for public drinking water source areas (DOW, 2016b). Notwithstanding this guidance, the premises is allowed to continue operating because it was an existing approved land use prior to the PDWSA being proclaimed (DOW, 2016b).

The Premises is located approximately 500 m north of bore 6/81, one of the two production bores providing Bolgart’s current water supply. The layout of the premises in relation to the

Bolgart Water Reserve and wellhead protection zone are shown in Figure 1.


Figure 1: Location of the premises within the Bolgart Water Reserve and wellhead protection zone

The licence was previously amended in 2015 to require completion of an improvement program including preparation and submission of a groundwater SAQP. As part of the same amendment assessment, DWER identified that an AMP was required for the premises to manage the risks associated with asbestos acceptance and disposal. The 2015 amendment improvement program therefore also included a requirement for the Licence Holder to prepare and submit an AMP. The Licence Holder did not implement the improvement program.

2019 Licence amendment On 18 September 2019, the Licence Holder applied for an extension of the licence expiry date by two years. While assessing the 2019 licence amendment, the Delegated Officer determined that contamination of the Bolgart Water Reserve by leachate from the unlined landfill was a key issue of concern in assessing the application. As no groundwater monitoring had been undertaken at the premises, very limited information was available to conduct an informed risk assessment for this Risk Event.

The Delegated Officer determined that further groundwater investigations were required to understand the potential human health risk posed by leachate from the Bolgart Refuse Site. These investigations were summarised into the following stages:

preparation of a groundwater SAQP;

implementation of the SAQP including installation and sampling of groundwater monitoring bores; and

preparation of a report assessing the potential for human health risks resulting from landfill leachate at the premises.

The results of the stages above were intended to inform the requirements for ongoing monitoring and/or further intrusive investigations.

The Delegated Officer determined that a two year extension of the licence duration would provide the Licence Holder with sufficient time to complete the staged investigations outlined above.

500 m

200 m

Wellhead protection zone (6/81)

Bolgart Water Reserve

(Bull Road Wellfield)

Premises


During DWER’s preparation of the 2019 draft licence amendment, the Licence Holder informed DWER that they would like Special Waste Type 1 (asbestos) removed as an accepted waste type at the premises. The Licence Holder gave this instruction after deciding to direct future asbestos disposal within the Shire of Victoria Plains to the Calingiri Refuse Site (L6955/1997/11).

DWER issued a licence amendment on 17 October 2019 which included extension of the

licence expiry date from 22 October 2019 to 22 October 2021. The licence amendment also

included:

Updates to the requirements of the groundwater SAQP and an extension of the due date for this document to 28 February 2020.

Updates to the requirements of the AMP and an extension of the due date for this document to 30 March 2020.

2.1.2 Review of groundwater SAQP

On 17 December 2019, the Licence Holder submitted a groundwater SAQP prepared by GHD. DWER reviewed the groundwater SAQP against the requirements in condition 3.1.1 of the licence. A summary of this assessment is provided in Table 2 below. The Delegated Officer determined that the groundwater SAQP submitted by the Licence Holder satisfies this component of the improvement program required by condition 3.1.1 in the licence.

2.1.3 Review of AMP

On 18 February 2020, the Licence Holder submitted an AMP. DWER reviewed the AMP against the requirements in condition 3.1.1 of the licence. A summary of this assessment is provided in Table 3 below.


Table 2: Review summary for groundwater SAQP

Licence requirement SAQP DWER assessment

Prepared in accordance with Section 5 and Appendix B of Schedule B2 of the Assessment of Site Contamination NEPM (NEPM ASC).

The SAQP was prepared in accordance with Section 5 and Appendix B of the NEPM ASC.

The SAQP followed an appropriate data quality objective methodology and outlined suitable requirements for the groundwater bore installation, monitoring and reporting.

A desktop assessment of likely groundwater flow direction and depth to groundwater.

Data recorded at a groundwater bore located approximately 750 m south of the premises indicated a depth to groundwater of 1-3 m below ground level (BGL). Based on the difference in elevation between this location and the premises, GHD inferred the depth to groundwater at the premises to be 3-10 m BGL.

The groundwater flow direction was inferred to be in the direction of topographic fall with some potential influence from the proximity of the Bull Road groundwater production bore located approximately 500 m south of the premises. Based on this information, GHD inferred groundwater flow at the premises to be towards the south east and/or north west (Figure 2).

The desktop assessment of groundwater flow direction and depth is satisfactory given the limited information available in the vicinity of the premises.

Groundwater bore installation and monitoring will provide more reliable information in relation to groundwater depth and flow in the vicinity of the premises.

Proposal for the installation of at least three groundwater monitoring bores which are appropriately located and installed to monitor potential impacts from premises activities and to monitor background groundwater quality.

Placement of monitoring bores shall also take into consideration the aim of identifying potential risks to the wellhead protection zone (production bore 6/81) located to the south of the Premises.

The SAQP proposed the installation of three monitoring bores as follows (Figure 2):

MB01 inferred as up hydraulic gradient of the premises to monitor background/ambient conditions.

MB02 inferred as down hydraulic gradient, to the west of waste disposal areas at the premises.

MB03 inferred as down hydraulic gradient, to the south of waste disposal areas at the premises.

The depth of groundwater monitoring installation will be subject to hydrogeological conditions observed at the premises. Based on the inferred groundwater depth of 3-10 m BGL, GHD expected installation depths to be 10-15 m BGL.

The siting of monitoring bores satisfies the requirements of this condition and is appropriate for detecting potential impacts from premises activities and background groundwater quality.

MB03 is sited between waste disposal areas at the premises and the wellhead protection zone to the south. Monitoring of this bore will allow an assessment of potential risks to the Bolgart drinking water supply from the premises.


Licence requirement SAQP DWER assessment

Proposed parameters to be measured and analysed.

The SAQP proposed the following monitoring suite for groundwater bores at the premises:

heavy metals (As, Cd, Cu, Cr, Pb, Hg, Ni, Zn);

major ions;

pH (field) and total dissolved solids (TDS);

total recoverable hydrocarbons (TRHs);

benzene, toluene, ethylbenzene and xylenes (BTEX);

polycyclic aromatic hydrocarbons (PAHs);

polychlorinated biphenyls (PCBs);

volatile organic compounds (VOCs);

semi-volatile organic compounds (SVOCs);

phenolics;

nutrients (nitrate, nitrite, ammonia, total nitrogen);

pesticides/herbicides – organochlorine pesticides (OCPs) and organophosphorus pesticides (OPPs); and

perfluoroalkyl and polyfluoroalkyl substances (PFAS).

The analytical suite proposed in the SAQP is appropriate to provide an assessment of general groundwater quality at the premises.

The contaminants selected for analysis are representative of contaminants commonly associated with landfilling activities and will allow an assessment of potential risks to groundwater from premises activities.

Proposed sampling frequency. The SAQP proposes to conduct one groundwater monitoring event and then base the need for further monitoring on the findings of the first monitoring event.

The SAQP did not propose timing for groundwater monitoring during the year.

The Delegated Officer considers that a minimum of two six-monthly groundwater monitoring events are required to provide a reliable initial assessment of groundwater conditions at the premises. DWER’s preferred timing of such events is during February to April and August to October.


Figure 2: Map of proposed groundwater monitoring locations (GHD, 2019)


Table 3: Review summary for AMP

Licence requirement AMP DWER assessment

Identification of where asbestos may be present on the site

Map showing coordinates of asbestos burial area ( Figure 3)

The Licence Holder should amend the map to show the extent of the asbestos burial area. The current map only shows a single GPS coordinate and the size of the burial area is not clear. The map should clearly show a shape which covers the entire asbestos burial area based on the Shire’s best knowledge of historical practices at the premises. Maintenance of a plan showing the position of Special Waste Type 1 is required under condition 3.1.6 in the Revised Licence.

Measures implemented to prevent the disturbance of buried asbestos

AMP states: “No one is permitted to excavate or use heavy machinery in the location of the existing material containing asbestos disposal area without the explicit approval from the Chief Executive Officer”

The control proposed by the Licence Holder is suitable. No detail was provided about how ground disturbing activities approved by the Shire CEO will be managed. Should excavation or heavy machinery operations be necessary, the Licence Holder should implement appropriate controls to prevent asbestos fibre generation (e.g. dust suppression).

Standard operational procedures (SOP’s) for the pre-acceptance and acceptance of waste and how any asbestos detected on site will be managed

AMP states: “Waste containing asbestos is no longer permitted at this site as per the amended refuse site licensing conditions” “Waste containing asbestos can be deposited at the Calingiri Refuse Site by prior arrangement” “A sign is placed at the entrance of the Bolgart Refuse Site states: ‘No waste containing asbestos is permitted at the Bolgart Refuse Site’”

The Licence Holder’s AMP did not provide any detail about how asbestos detected on site will be managed. As members of the public are able to directly deposit waste into the landfill cells at the premises, it is possible that unauthorised asbestos disposal may occur. The Licence Holder should have procedures in place to inform staff how to manage any such asbestos detected at the premises.

Identification of each person’s roles and responsibilities under the AMP

CEO is responsible for authorizing heavy machinery or excavation works in the vicinity of the asbestos burial area.

The AMP should also state who is responsible for:

ensuring that no asbestos is received at the premises; and

managing and recording asbestos detected at the premises.

Procedures for detailing No information provided DWER considers that the most likely incidents relating


Licence requirement AMP DWER assessment

incidents or emergencies associated with asbestos

to asbestos which may occur at the premises include:

Detection of asbestos in the current landfill disposal area (i.e. unauthorised disposal by member of the public without supervision by premises staff).

Disturbance of asbestos in the former designated burial area.

Unexpected finds of asbestos in other parts of the premises (e.g. illegal dumping or historical waste disposal).


Figure 3: Map of asbestos burial area


The Delegated Officer determined that the AMP submitted by the Licence Holder does not completely satisfy this component of the improvement program required by condition 3.1.1 in the licence. In addition, the AMP did not meet the requirements outlined in the Guidelines for managing asbestos at construction and demolition waste recycling facilities (DEC, 2012) (Asbestos Guidelines), as required by condition 3.1.1. The Delegated Officer has determined that the deficiencies in the AMP can be remedied by additional conditions in the licence. The Delegated Officer also notes that the Asbestos Guidelines are intended for use at construction and demolition waste recycling facilities which have a higher risk of receiving asbestos and generating fibres through processing activities than the premises which receives small quantities of waste and does not carry out any waste treatment/processing on the premises. Based on these findings, the AMP improvement program condition will be removed from the licence as part of this amendment and additional conditions relating to asbestos will be added to the licence.

3. Other approvals

No other approvals are relevant to the scope of the amendment.

4. Licensing history

Table 4 provides the amendment history for L6956/1997/11.

Table 4: Amendments

Instrument Issued Amendment

L6956/1997/11 17/09/2015 Amended to add improvement conditions requiring an Asbestos Management Plan and groundwater Sampling and Analysis Plan.

L6956/1997/11 29/04/2016 Amended to extend the licence duration by three years.

L6956/1997/11 16/10/2019 Amended to extend the duration by two years including an extension to the completion dates of improvement conditions and remove Special Waste Type 1 as an accepted waste type (this amendment).

L6956/1997/11 07/04/2020

Amended to remove the groundwater SAQP and AMP from the improvement program.

New conditions requiring groundwater bore installation, monitoring and reporting.

New conditions relating to asbestos management.

5. Environmental siting

Table 5 below lists the relevant sensitive land uses in the vicinity of the prescribed premises which may be receptors relevant to the proposed amendment.

Table 5: Sensitive land uses and distance from activity boundary

Residential and sensitive premises Distance from Prescribed Premises

Rural farmland Adjacent to the western, northern, eastern and southern boundaries of the Premises

Golf course 250 m west south-west of the Premises

Bolgart Primary School 880 m west of the Premises


Residential and sensitive premises Distance from Prescribed Premises

Bolgart town residential area 980 m west of the Premises

Table 6 below lists the relevant environmental receptors in the vicinity of the prescribed premises which may be receptors relevant to the proposed amendment.

Table 6: Environmental receptors and distance from activity boundary

Environmental receptors Distance from Prescribed Premises

Public Drinking Water Source Area

The Bolgart Water Reserve is a P2 PDWSA which comprises two wellfields associated with production bores 6/81 and 1/96.

The southern portion of the Premises is located within the Bull Road Wellfield (Figure 1). The Western Wellfield of the Bolgart Water Reserve is located 1.2 km west of the Premises.

The production bores draw from an unconfined aquifer and are screened from 12.45 m to 16.9 m (6/81) and 15.3 m to 18.3 m (1/96) (DOW, 2016a). Raw water from the production bores is pumped to the Bolgart East treatment plant where it is blended and chlorinated (DOW, 2016a). Blending is undertaken in a one to one ratio from the two bores because of the high salinity levels in the 6/81 bore (DOW, 2016a).

Groundwater The depth and flow direction of groundwater in the vicinity of the premises is not known. Topography within the vicinity of the premises slopes down towards the south, west and north-west.

Bolgart is underlain by crystalline basement rocks of the Yilgarn Craton. The basement is overlain by a weathered profile consisting of kaolinite clay, sandy clay and sand, and is covered by laterite on the hills, and locally by residual sand on the slopes (DOW, 2016a). The residual sand is unconsolidated and up to 30 m thick, possibly occupying depressions within the weathered profile (DOW, 2016a).

Groundwater in the Bolgart area is predominantly found in residual sand and underlying fractured and weathered bedrock (DOW, 2016a). The sandy aquifer is considered to be unconfined and is vulnerable to contamination (DOW, 2016a).

Groundwater licences held by the Water Corporation for the two production bores servicing the town water supply are the only groundwater licences identified within 5 km of the Premises.

The DWER Water Information Reporting tool identified 21 groundwater bores within approximately 2 km of the Premises. Groundwater bore owners included private owners, the Water Corporation, Bolgart Primary School (Department of Education) and the Public Works Department (current owner unknown).

Waterways Conservation Areas

The Premises is located within the Avon River Management Area

Surface Water The Bolgart Brook is located approximately 1.25 km west of the Premises. This is a non-perennial watercourse.

Two unnamed perennial lakes are located approximately 3 km south-east of the Premises.

An unnamed minor watercourse is located 3.15 km south-east of the Premises.

Threatened and Priority Ecological Communities

26 occurrences of the Wheatbelt Woodlands (Eucalypt woodlands of the Western Australian Wheatbelt) were identified within 2 km of the Premises. This is a Priority 3 and critically endangered community.

Threatened/Priority Fauna One Priority 4 fauna species (western brush wallaby) and one vulnerable fauna species (bilby) were identified within 2 km of the Premises.

Parks and Wildlife None identified within 5 km of the Premises


Environmental receptors Distance from Prescribed Premises

Managed Lands and Waters

Regional Parks

Green Growth Commitment Areas

Threatened/Priority Flora

Ramsar Sites

Directory of Important Wetlands

Geomorphic Wetlands

Acid Sulfate Soils Based on CSIRO’s Australian Soil Resource Information System Mapping Tool, there is a low probability of acid sulfate soils occurring at the Premises.

6. Risk assessment

Table 7 below describes the Risk Events associated with the amendment consistent with the Guidance Statement: Risk Assessments. This table identifies whether the emissions present a material risk to public health or the environment, requiring regulatory controls.

Risk Events considered in the risk assessment are limited to leachate emissions to groundwater and asbestos fibre release to air. The Delegated Officer considers that these are the only Risk Events relevant to the scope of the licence amendment which is focused on groundwater investigations and asbestos management at the Premises.


Table 7: Risk assessment for proposed amendments during operation

Risk Event

Source/ Activities*

Potential emissions

Potential receptors, pathway and impact

Applicant controls Consequence rating1 Likelihood rating1

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

Storage and disposal of waste in the Class II landfill

Leachate to groundwater

Down-gradient groundwater users including the production bore (6/81) and the Bolgart Water Reserve

Groundwater bore installation, monitoring and reporting

Major Possible High

Leachate generated in the landfill is likely to infiltrate into the subsurface as the landfill is unlined. The Delegated Officer considers the likelihood of leachate impacting the Bolgart Water Reserve is possible; the risk event could occur at some time. As the depth and flow direction of groundwater are not well understood it is not known if groundwater pathways exist to connect the premises and the 6/81 production bore capture zone. Based on the 200 m separation distance between the premises and the wellhead protection zone, the Delegated Officer considers the likelihood of leachate impacting the 6/81 production bore supply is possible. Contaminants generated in leachate from a landfill may present a risk to human health if consumed in drinking water. The Delegated Officer understands that this type of contamination (e.g. nutrients, metals and hydrocarbons) may not be detected or removed under the current analytical and treatment methods implemented by the Water Corporation in their management of the Bolgart town water supply (DOW, 2016a). The Delegated Officer considers the consequence to be major based on the potential for mid-level adverse health effects if the Bolgart town water supply were to become contaminated.

Conditions 2.3.1 and 2.3.2 – groundwater bore installation Conditions 2.3.3, 2.3.4, 2.3.5 and Schedule 2 – groundwater monitoring Condition 4.2.2 – groundwater monitoring report

Down-gradient aquatic ecosystems

Minor Possible Medium

Contaminants generated in leachate from a landfill may present a risk to aquatic ecosystems. It is not known if groundwater pathways connect the premises and surface water features. Based on the separation distance of 1.2 km to the closest surface water feature (Bolgart Brook) the Delegated Officer considers the potential environmental consequence to be minor and the likelihood of this Risk Event to be possible.

Acceptance of non-conforming waste loads Disturbance of buried asbestos

Asbestos fibres

Generation of airborne fibres and dispersion to nearby receptors (golf course, primary school and residential areas)

Removal of Special Waste Type 1 as an accepted waste type AMP

Severe Unlikely High

No longer accepting Special Waste Type 1 will reduce the risk of asbestos fibre generation at the premises. However, a risk of fibre generation remains due to the potential disturbance of buried waste and acceptance of non-conforming waste types. The AMP submitted by the Licence Holder does not adequately address risks at the premises and additional conditions will be added to the licence to address these control gaps.

Condition 1.3.7 – adding “No Asbestos” to the sign at the front entrance Conditions 1.3.11 to 1.3.13 – asbestos acceptance and management Condition 3.1.6 – asbestos register

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


7. Consultation

Table 8: Summary of consultation

Method Comments received DWER response

Applicant referred draft documents (30/01/2020)

Licence Holder replied on 18 February 2020 requesting that the deadline for construction and development of new groundwater bores be extended from 31 July 2020 to 31 October 2020. This change would allow the required works to be included in the Shire of Victoria Plains’ 2020-2021 budget.

The Delegated Officer considers that a three month extension to the groundwater investigation timeframe is acceptable. The following licence amendments were made to the reflect this change:

Timeframe for works in Table 2.3.1 extended to 31 October 2020.

Timing for post-winter 2020 monitoring event changed from August-October to August-November to provide the Licence Holder with a reasonable timeframe to conduct the first monitoring event.

Due date for groundwater monitoring report extended from 30 June to 31 July.

8. Decision

Based on the assessment in this Amendment Report, the Delegated Officer has determined that a licence amendment will be made, subject to conditions commensurate with the determined controls and necessary for administration and reporting requirements.

Groundwater bore installation

The Licence Holder is required to install groundwater bores by 31 October 2020. The Delegated Officer considers that this provides sufficient time for the Licence Holder to undertake these works. The Delegated Officer is satisfied with the bore installation methodology and locations proposed in the groundwater SAQP and has added conditions to the licence which are consistent with the proposed approach.

Groundwater monitoring and reporting

The Delegated Officer is generally satisfied with the monitoring programme and methodology proposed in the groundwater SAQP and has added conditions in the licence which are consistent with the proposed approach.

The groundwater SAQP only proposed one initial monitoring event to be conducted. The Delegated Officer recommends that two six-monthly monitoring events are undertaken before DWER reviews the groundwater monitoring programme.

Conditions have been added to the licence which require two six-monthly monitoring events to be completed during the annual period from 1 July 2020 to 30 June 2021 and annual monitoring events to be undertaken from 1 July 2021 onwards.

The Licence Holder is required to submit a groundwater monitoring report which summarises the results from the first year of groundwater monitoring by 31 July 2021. Based on the findings of this report, DWER will review the suitability of the existing groundwater monitoring


programme, including the monitoring frequency, parameters and locations. Any changes to the groundwater monitoring programme which result from this review will be implemented by licence amendment. It is likely that DWER will require ongoing groundwater monitoring at the premises as a regulatory control on the licence given the potential risks associated with a landfill in a P2 PDWSA. The current licence is due to expire on 22 October 2021. The results of groundwater monitoring at the premises may contribute to DWER’s assessment of any applications from the Licence Holder to extend the licence duration.

Asbestos Management Plan DWER has addressed deficiencies in the AMP by addition of new conditions relating to asbestos management in the licence. DWER recommends that the Licence Holder revises the AMP to address some of the missing information highlighted in Table 3 to inform Shire staff of appropriate procedures for managing asbestos risks at the premises.

Contaminated Sites Act 2003

The Delegated Officer notes that the premises is not currently classified under the Contaminated Sites Act 2003 (CS Act). Under the CS Act, the occupier of a site must report to the CEO known contamination within 21 days of becoming aware of the contamination or suspected contamination as soon as is reasonably practicable.

8.1 Summary of amendments

Table 9 provides a summary of the proposed amendments and will act as record of implemented changes. All proposed changes have been incorporated into the Revised Licence as part of the amendment process.

Table 9: Licence amendments

Condition No. Proposed amendments

1.1.2 Definitions added for new terms relating to groundwater monitoring

1.3.1 Waste specification for Inert Waste Type 1 removed to prevent duplication of new condition 1.3.12 below.

1.3.3 Reference to requirements for acceptance and landfilling of asbestos in the Environmental Protection (Controlled Waste) Regulations 2004 removed.

1.3.7 Additional requirement for sign at entrance to specify “No Asbestos”

1.3.12 New condition specifying that waste which contains or is suspected to contain visible asbestos or ACM must not be accepted onto the premises.

1.3.13 New condition outlining how suspected or detected asbestos should be managed if identified at the premises.

2.3.1 New condition added requiring the installation of new monitoring wells MB01, MB02 and MB03 by 31 October 2020

2.3.2 New condition added requiring the submission of a well construction report within 60 days of well completion


Condition No. Proposed amendments

2.3.3, 2.3.4, 2.3.5 and Schedule 2

New conditions added requiring groundwater monitoring to be undertaken in accordance with requirements outlined in Schedule 2

3.1.1 Improvement program removed

4.1-4.3.1

5.1-5.2.1

Numbering updated to reflect removal of Section 3, all conditions re-numbered

3.1.1 (formerly 4.1.1)

Condition amended to require books to be kept for groundwater monitoring

3.2.2 (formerly 4.2.2)

New condition added requiring groundwater monitoring report to be submitted by 31 July each year

Schedule 1 New map of groundwater monitoring locations added

MANGER WASTE INDUSTRIES REGULATORY SERVICES An officer delegated by the CEO under section 20 of the EP Act


Appendix 1: Key documents

Document title In text ref Availability

1 Licence L6956/1997/11 L6956/1997/11

accessed at www.dwer.wa.gov.au

2 DER, July 2015. Guidance Statement:

Regulatory principles. Department of

Environment Regulation, Perth.

DER 2015a

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

DER 2015b

4 DER, August 2016. Guidance

Statement: Licence duration.

Department of Environment

Regulation, Perth.

DER 2016a

5 DER, November 2016. Guidance

Statement: Environmental Siting.


Regulation, Perth.

DER 2016b

6 DER, February 2017. Guidance

Statement: Risk Assessments.


Regulation, Perth.

DER 2017a

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

DER 2017b

8 DWER, June 2019. Guideline: Decision making. Department of Water and Environmental Regulation, Perth.

DWER 2019

9 DEC, 2012. Guidelines for managing asbestos at construction and demolition waste recycling facilities. Department of Environment and Conservation, Perth.

DEC 2012

10 DOW, 2016a. Bolgart Water Reserve Drinking water source protection plan. Department of Water, Perth.

DOW 2016a

11 DOW, 2016b. Water quality protection note no. 25 Land use compatibility tables for public drinking water source areas. Department of Water, Perth.

DOW 2016b

12 GHD, 2019. Bolgart Landfill Groundwater Sampling and Analysis Plan for Groundwater Monitoring.

GHD 2019 DWER records

(A1852522)

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

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