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2021Woodlawn Bioreactor and Crisps Creek IMF Independent

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2021Woodlawn Bioreactor and Crisps Creek IMF Independent Prepared for Veolia Environmental Services (Australia) Pty Ltd )Prepared by Ramboll Australia Pty Ltd Date May 2021 Project Number 318001112 INDEPENDENT ENVIRONMENTAL AUDIT WOODLAWN BIOREACTOR AND CRISPS CREEK INTERMODAL FACILITY Veolia Environmental Services (Australia) Pty Ltd Woodlawn Bioreactor and Crisps Creek Intermodal Facility May 2021 Page i INDEPENDENT ENVIRONMENTAL AUDIT Revision Final Date 24/05/2021 Made by Emily Rowe & Vanessa White Checked by Victoria Sedwick Approved by Victoria Sedwick Description Independent Environmental Audit of Woodlawn Bioreactor and Crisps Creek Intermodal Facility Ref: 318001112 Version Control Record Revision Date Comments Final Draft 28/04/2021 Issued for review by Veolia for factual accuracy Independent Audit Tables Final Draft 1 30/04/2021 Issued for review by Veolia for factual accuracy Final 24/05/2021 Issued as final This document is issued to Veolia Environmental Services (Australia) Pty Ltd for the purposes of an Independent Environmental Audit of the Woodlawn Bioreactor and Crisps Creek Intermodal Facility. It should not be used for any other purpose. Whilst reasonable attempts have been made to ensure that the contents of this report are accurate and complete at the time of writing, Ramboll Australia Pty Ltd disclaims any responsibility for loss or damage that may be occasioned directly or indirectly through the use of, or reliance on, the contents of this report. © Ramboll Australia Pty Ltd Ramboll Level 3, 100 Pacific Highway PO Box 560 North Sydney NSW 2060 T +61 2 9954 8100 www.ramboll.com 31800 1112 Woodlawn Bioreactor and IMF IEA_Final Report_Final_24May2021.docx Ramboll Veolia Environmental Services (Australia) Pty Ltd Woodlawn Bioreactor and Crisps Creek Intermodal Facility May 2021 Page ii CONTENTS 1. EXECUTIVE SUMMARY 1 2. INTRODUCTION 4 2.1 Background 4 2.2 Audit objective and scope 4 2.3 Exclusions 5 2.4 Audit Team 5 2.5 Audit Period 5 3. AUDIT METHODOLOGY 6 3.1 Selection and Endorsement of Audit Team 6 3.2 Independent Audit Scope Development 6 3.3 Compliance Evaluation 6 3.4 Site Inspection and Interviews 6 3.5 Consultation 7 3.6 Compliance Status Descriptors 10 4. AUDIT FINDINGS 11 4.1 Approval and Document List 11 4.2 Compliance Performance 15 4.3 Summary of Agency Notices, Orders, Penalty Notices or Prosecutions 16 4.4 Previous Audit Recommendations 17 4.5 EMPs, Sub-plans and Post Approval Documents 17 4.6 EMS 18 4.7 Environmental Performance 18 4.8 Complaints 20 4.9 Incidents 20 4.10 Actual Versus Predicted Environmental Impacts 21 4.11 Site Inspection 21 4.12 Site Interviews 21 4.13 Improvement Opportunities 21 4.14 Key Strengths 23 5. RECOMMENDATIONS AND OPPORTUNITIES FOR IMPROVEMENT 24 5.1 Non-compliance Recommendations 24 5.2 Opportunity for Improvement Recommendations 25 6. CONCLUSIONS 28 APPENDICES Appendix A Independent Audit Tables Appendix B Audit Team Appendix C Independent Audit Declaration Form Appendix D Site Inspection Photographs Appendix E DPIE approval of audit team 318001112 Woodlawn Bioreactor and IMF IEA_Final Report_Final_24May2021.docx Ramboll Veolia Environmental Services (Australia) Pty Ltd Woodlawn Bioreactor and Crisps Creek Intermodal Facility May 2021 Page 1 1. EXECUTIVE SUMMARY Veolia Environmental Services (Australia) Pty Ltd (Veolia) engaged Ramboll Australia Pty Ltd (Ramboll) to conduct an Independent Environmental Audit (IEA, or the Audit) of the Woodlawn Bioreactor (Bioreactor) and Crisps Creek Intermodal Facility (IMF). The Bioreactor is located within the Woodlawn Eco-Precinct, located off Collector Road, approximately 10 km southwest of the Village of Tarago. The IMF is located approximately 8 km east of the Bioreactor and 2 km south of Tarago. The Audit is required under Condition 6 of Schedule 7 of the Project Approval (PA) 10_0012 and Condition 19 of Development Consent (DC) 31-02-99. The objective of the Audit was to independently and objectively assess the environmental performance and compliance status of the Bioreactor and IMF sites under PA 10_0012 and DC 31-02-99, as well as the two sites’ Environment Protection Licences (EPLs), EPL 11436 and EPL 11455, respectively. The Audit Period was from the date of the 2018 IEA site visit on 12 March 2018 to the date of this Audit site visit on 17 March 2021. The Auditors consider that overall environmental practices for the site are generally adequate with evidence of improvements in environmental performance including the commissioning and operation of the Leachate Management Plant (LTP), lining of evaporation dams and improvements to the landfill gas extraction system, mechanical evaporation systems and process control systems. The Auditors note that more than 50 additional conditions were triggered during this Audit due to construction of the LTP and works on evaporation dams, that required auditing, compared to the 2018 IEA. There were seventeen (17) non-compliances during the Audit Period of which eleven (11) are considered to be administrative in nature. The non-compliances are summarised as follows. PA 10_0012: • NC1, Schedule 3, Condition 5 – The limit for maximum waste input rates at the Landfill for waste received as residual waste from Veolia’s Mechanical Biological Treatment (MBT) facility was exceeded in the 2019 and 2020 Annual Environmental Management Report (AEMR) reporting periods, as a result of regulatory instruction with regards to Mixed Waste Organic Outputs (MWOO). The NSW Government Department of Planning, Environment and Industry (the Department, or DPIE) approved an increase in the limit for putrescible regional waste received by road from 90,000 tonnes per annum (tpa) to 125,000 tpa, subject to further consultation with Goulburn Mulwaree Council (GMC) to determine if a climbing lane was required for Tarago Road, and if required, the climbing lane was to be constructed to the satisfaction of GMC prior to the increase in acceptance of regional waste. Veolia consulted GMC and GMC requested that the 2013 traffic assessment be updated by 30/11/19. The traffic assessment was updated and a draft report issued in March 2021. Based on data reported in the AEMRs, Veolia accepted more than 90,000 tpa regional waste by road in 2019 and 2020 prior to determining that the climbing lane was not required to the satisfaction of GMC. The Auditors recommend that Veolia confirm the quantities of putrescible regional waste received by the Bioreactor during the 2019 and 2020 reporting periods to determine if the approved limit of 90,000 tpa was exceeded. The Auditors recommend that Veolia investigate the causes for the confirmed limit exceedances and undertake appropriate corrective actions to prevent a recurrence. The Auditors recommend that Veolia confirm that GMC accept ARRB’s advice that the climbing lane is not considered necessary. • NC2, Schedule 3, Condition 9 – The LTP was occupied prior to the issue of an occupation certificate (07/04/2021). No recommendation is provided as the Occupation Certificate for the LTP has been issued. 318001112 Woodlawn Bioreactor and IMF IEA_Final Report_Final_24May2021.docx Ramboll Veolia Environmental Services (Australia) Pty Ltd Woodlawn Bioreactor and Crisps Creek Intermodal Facility May 2021 Page 2 • NC3, Schedule 4, Condition 18D – Veolia transferred ~50 ML stormwater from Evaporation Dam (ED) ED3S to ED2 during the Audit Period. There is no evidence available to the Auditors that the seepage or leakage points identified in ED2 have been repaired to the satisfaction of the Department and the NSW Environment Protection Authority (EPA) prior to the transfer of any stormwater from ED3S to ED2. The Auditors recommend that prior to transferring anymore stormwater from ED3S to ED2, Veolia should establish that the leakage points in ED2 have been identified and repaired to the satisfaction of the Planning Secretary and EPA. • NC4, Schedule 4, Condition 18E – The LTP was commissioned on 04/10/2018, which was four days after the stipulated completion date of 30/09/18. No recommendation is required as the LTP is operational. • NC5, Schedule 4, Condition 18M – There is no evidence that quarterly updates have been submitted to Water NSW or the Department in accordance with this Condition. The Auditors recommend that quarterly reports be provided to the EPA, Water NSW and the Department of the leachate volume in the ED1 Coffer Dam and the remaining leachate storage volume. • NC6, Schedule 5, Condition 20 – This non-compliance continued from the previous IEA through to November 2020 when the Tarago Loop Extension works were completed and the train was no longer required to be split in two. No recommendation is required as the non-compliance has been addressed. • NC7, Schedule 6, Condition 4 – The Transport Code of Conduct was last issued in 2011 and was not updated in consultation Roads and Maritime Services (RMS), GMC, Palerang Council (now the Queanbeyan-Palerang Regional Council (QPRC)) and the Community Liaison Committee to the satisfaction of the Department prior to the receipt of more than 50,000 tpa of regional waste. The Auditors recommend that Veolia’s Transport Code of Conduct be updated in consultation RMS, GMC, Palerang Council and the Community Liaison Committee, and to the satisfaction of the Department. • NC8, Schedule 7, Condition 7 – Four complaints received between 19/04/2018 and 26/05/2018 were not published on the website within seven days of a complaint being made. No recommendation is required as the non-compliance has been addressed. • NC9, Schedule 7, Condition 8 – Waste volume limits were exceeded during the Audit Period, which represent an ‘incident’, as defined in PA 10_0012, Schedule 2, Definitions. The waste volume limit exceedances were not notified and reported to the Department within the required timeframes. The Auditors recommend that Veolia conduct an investigation as to why the Department was not notified of these exceedances (e.g. failure to identify the waste volume limit exceedances as an ‘exceedance’ and/or an ‘incident’, failure to understand this Condition, this requirement not specified in a procedure?) and based on the investigation findings carry out appropriate corrective action(s) to prevent a recurrence.
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