Rehabilitation Plan

Appendix O – Rehabilitation Plan

GHD | Report for Latrobe City Council –Hyland Highway Landfill Extension, 3136742 Latrobe City Council Hyland Highway Landfill – Rehabilitation Plan

Prepared By: Chandana Vidanaarachchi - Latrobe City Council Reviewed By: John Nolan - Nolan Consulting Pty Ltd 1 INTRODUCTION

Hyland Highway Landfill is owned and operated by Latrobe City Council under the licence 25565 as amended on 17 August 2018 and issued by Environmental Protection Authority (EPA) Victoria. The landfill is licenced to accept putrescible waste, solid inert waste, asbestos waste of domestic origin and tyres shredded into pieces <250 mm into Cell 4 and Cell 5.

The landfill is located at 64 Hyland Highway Loy Yang. It consists of 6 cells on a footprint of 8.2 Ha, with approved capacity of 960,000 cu.m. Landfill Cells 1, 2, 3A and 3B have been completely filled, Cell 4 is partially filled and waste is currently being accepted in Cell 5. Cell 6 is the final cell under the existing works approval. It is yet to be constructed.

2 STATUTORY REQUIREMENT

2.1 LICENCE CONDITION

EPA Licence Condition LI_L22 states that

You must implement a rehabilitation plan for the landfill. The plan must:

a) be revised after each cell is full, if necessary;

b) meet the requirements of Section 8 of Best Practice Environmental Management (BPEM), Siting, Design, Operation and Rehabilitation of Landfills (EPA Publication 788.3, released August 2015);

c) set timeframes for placement of final capping of all completed cells, calculated from the date that the cell became full; and

d) set timeframes for the progressive capture and treatment of landfill gas and leachate from each completed cell.

This Rehabilitation Plan addresses the above licence requirement including the Section 8.1.1 of the BPEM Requirement that the plan should include: • the potential afteruses of the site, taking into consideration current and likely future land use in the area surrounding the site

• operational requirements, to ensure that the capping is designed to suit the intended afteruse • surface contours before and after settlement • specifications and materials to be used in the final cap • Preservation/installation of environment performance control or monitoring features.

3 AFTERUSE

The likely afteruse of the site, taking into consideration current and likely future land use in the area surrounding the site is public open space. This would become available when the landfill is closed and the land is revegetated with native species.

The site which includes the landfill footprint is owned by Latrobe City Council and is approximately 100 Ha.

Due to steep slopes and landfill gas infrastructure the landfill footprint will be fenced off as it is unsuitable for public access. This would be reviewed once the obligations under any post closure pollution abatement notice are compiled with.

Beyond the site the adjacent motor cycle club is used for racing events.

4 SURFACE CONTOURS BEFORE AND AFTER SETTLEMENT

The before settlement contour plan across all cells is that provided in Schedule 1C of the licence. It is the top of waste pre-settlement contour plan (PSCP) and is given in Appendix A with cross sections.

As the landfill is considered to be well compacted, the settlement is expected to range from 10% to 20%. An after settlement contour plan will be prepared upon landfill closure which would allow for a projection from the settlement that would have occurred by that time. 5 REHABILITATION COMPLETED

The progressive rehabilitation of the landfill commenced in the 2014/15 financial year with the Stage 1 cap. This involved the capping of the western two thirds of Cells 1 and 2. The 1.2 Ha capped area is shown as Stage 1 capping in the attached plan. The rehabilitation works which was completed by June 2015 included the construction of a BPEM compliant cap and installation of landfill gas management system. The Stage 1 landfill gas management system included 14 landfill gas extraction bores and a gas flare.

The constructed Stage 1 cap consisted of (from bottom up):

Gas collection trench

Sub-grade

GCL

Geomembrane

Cushion Geotextile

Sand Drainage Layer 300 mm thick

Subsoil minimum 700 mm thick

Topsoil

Vegetation

Figure1 : Stage 1 Cap Profile The Stage 2 capping works commenced in the 2016/17 financial year and were completed in July 2017. This involved the completion of the capping of Cells 1 and 2 and 90% of Cell 3. The works involved construction of BPEM compliant cap and the installation of 11 landfill gas extraction bores and connect them to the existing gas flare.

The constructed Stage 2 cap consisted of (from bottom up)

Gas collection trench Sub-grade GCL Geomembrane Geocomposite Subsoil Topsoil Vegetation

Where the cap slope exceeded 5%, Geogrid was placed to improve the sub-soil stability.

6 TIMEFRAMES FOR THE PLACEMENT OF FINAL CAPPING

The tentative timeframe for future landfill capping is shown in below and in Appendix B. The required funding has been allocated for this works in the council’s long term financial plan.

Table 1: Landfill Capping Schedule Capping Landfill Cell Expected time Expected time of Expected Time of stage of filling Rehabilitation Gas Infrastructure completed commenced Installation 3 Cell 3 Jun 2018 Sep 2019 Jul 2019 Remaining 10% 4 Cell 4 Sep 2021 Jul 2021 Jul 2021 5 Cell 5 Sep 2023 Jan 2024 Jan 2024 6 Cell 6 Sep 2024 Jan 2025 Sep 2024 Each stage of capping will consist of a BPEM compliant cap and the installation of additional landfill gas extraction bore connected to a flare with adequate flaring capacity.

Stage 3 capping works are proposed to commence in the 2019/20 financial year. When stage 3 capping is completed the cells 1, 2 and 3 will be entirely capped.

Cell 4 will be ready for capping when waste acceptance in Cell 5 ceases.

The timetable for capping presented in Table 1 assume site operational requirements allow Cell 5 to be completely filled by September 2023. If this is not possible Cell 5 will be capped with Cell 6.

7 MATERIALS TO BE USED IN THE FINL CAP

The landfill cap for Stages 3 to 6 will be designed to meet BPEM requirements and also to satisfy overall stability of landfill.

The Stage 3 cap will consist of (from bottom up)

Gas collection trench

Sub-grade

GCL

Geomembrane

Geocomposite

Subsoil

Topsoil

Vegetation

Where the cap slope exceeds 5%, Geogrid has been placed to improve the subsoil stability.

Figure 2: Cell 3 Cap Profile (Steep Sections)

Figure 3: Cell 3 Cap Profile (General)

It is anticipated that the Stage 4, 5 and 6 cap will have a similar material specification.

8 LANDFILL GAS AND LEACHATE MANAGEMENT

8.1 LANDFILL GAS MANAGEMENT

A plan showing the landfill gas management system is shown in Appendix C.

The gas management system will be expanded with the landfill capping program. The gas wells will be installed simultaneously with the landfill capping of each completed cells. 8.2 LEACHATE MANAGEMENT

All the landfill cells (current and future) have/will have a leachate collection system with network of leachate collection pipes, 300 mm thick drainage aggregate layer, a sump, riser pipe and submersible pump and will comply with the leachate related licence conditions. This setup can handle leachate over a period of time until leachate load become negligible. The collected leachate will always be appropriately treated.

9 MONITORING

Monitoring of Groundwater, Surface water, Landfill Gas and Leachate will be continued as per the verified monitoring program during the operational period and aftercare period.

Any changes to monitoring requirement will be made in consultation with Environmental Auditor and EPA.

10 REVISIONS

This rehabilitation plan will be revised after each cell is full, as if necessary, and after any future extension of the landfill following a works approval.

APPENDIX 1

SURFACE CONTOURS BEFORE SETTLEMENT

LANDFILL FORM – Cross Sections E&F

APPENDIX 2

HYLAND HIGHWAY LANDFILL – CAP CONSTRUCTION STAGES

CELL 1&2

CELL 3 CELL 1&2

ff, §: O' Qj,'! ' IS' , ° ()'0/ '-0 1:', CELL 4 �.' /1

� ...

�� Cap Stage boundaries Cell boundaries Stormwater c:::::::::J Stage 1 capping completed in 2015 Jun Pond c:::::::::J Stage 2 capping completed in Jun 2017 c:::::::::J Stage 3 capping � Cell 4 capping c:::::::::J Cell 5 capping c:::::::::J Cell 6 capping s

APPENDIX 3

HYLAND HIGHWAY LANDFILL

LANDFILL GAS INFRASTRUCTURE

Latrobe City Council Hyland Highway Landfill – Rehabilitation Plan

Prepared By: Chandana Vidanaarachchi - Latrobe City Council Reviewed By: John Nolan - Nolan Consulting Pty Ltd 1 INTRODUCTION

2 STATUTORY REQUIREMENT

2.1 LICENCE CONDITION

EPA Licence Condition LI_L22 states that

You must implement a rehabilitation plan for the landfill. The plan must:

a) be revised after each cell is full, if necessary;

b) meet the requirements of Section 8 of Best Practice Environmental Management (BPEM), Siting, Design, Operation and Rehabilitation of Landfills (EPA Publication 788.3, released August 2015);

c) set timeframes for placement of final capping of all completed cells, calculated from the date that the cell became full; and

d) set timeframes for the progressive capture and treatment of landfill gas and leachate from each completed cell.

3 AFTERUSE

The site which includes the landfill footprint is owned by Latrobe City Council and is approximately 100 Ha.

Beyond the site the adjacent motor cycle club is used for racing events.

4 SURFACE CONTOURS BEFORE AND AFTER SETTLEMENT

The constructed Stage 1 cap consisted of (from bottom up):

Gas collection trench

Sub-grade

GCL

Geomembrane

Cushion Geotextile

Sand Drainage Layer 300 mm thick

Subsoil minimum 700 mm thick

Topsoil

Vegetation

Figure1 : Stage 1 Cap Profile

The Stage 2 capping works commenced in the 2016/17 financial year and were completed in July 2017. This involved the completion of the capping of Cells 1 and 2 and 90% of Cell 3. The works involved construction of BPEM compliant cap and the installation of 11 landfill gas extraction bores and connect them to the existing gas flare.

The constructed Stage 2 cap consisted of (from bottom up)

Gas collection trench

Sub-grade

GCL

Geomembrane

Geocomposite

Subsoil

Topsoil

Vegetation

Where the cap slope exceeded 5%, Geogrid was placed to improve the sub-soil stability.

6 TIMEFRAMES FOR THE PLACEMENT OF FINAL CAPPING

The tentative timeframe for future landfill capping is shown in below and in Appendix B. The required funding has been allocated for this works in the council’s long term financial plan.

Each stage of capping will consist of a BPEM compliant cap and the installation of additional landfill gas extraction bore connected to a flare with adequate flaring capacity.

Stage 3 capping works are proposed to commence in the 2019/20 financial year. When stage 3 capping is completed the cells 1, 2 and 3 will be entirely capped.

Cell 4 will be ready for capping when waste acceptance in Cell 5 ceases.

The timetable for capping presented in Table 1 assume site operational requirements allow Cell 5 to be completely filled by September 2023. If this is not possible Cell 5 will be capped with Cell 6.

7 MATERIALS TO BE USED IN THE FINL CAP

The landfill cap for Stages 3 to 6 will be designed to meet BPEM requirements and also to satisfy overall stability of landfill.

The Stage 3 cap will consist of (from bottom up)

Gas collection trench

Sub-grade

GCL

Geomembrane

Geocomposite

Subsoil

Topsoil

Vegetation

Where the cap slope exceeds 5%, Geogrid has been placed to improve the subsoil stability.

Figure 2: Cell 3 Cap Profile (Steep Sections)

Figure 3: Cell 3 Cap Profile (General)

It is anticipated that the Stage 4, 5 and 6 cap will have a similar material specification.

8 LANDFILL GAS AND LEACHATE MANAGEMENT

8.1 LANDFILL GAS MANAGEMENT

A plan showing the landfill gas management system is shown in Appendix C.

The gas management system will be expanded with the landfill capping program. The gas wells will be installed simultaneously with the landfill capping of each completed cells. 8.2 LEACHATE MANAGEMENT

9 MONITORING

Monitoring of Groundwater, Surface water, Landfill Gas and Leachate will be continued as per the verified monitoring program during the operational period and aftercare period.

Any changes to monitoring requirement will be made in consultation with Environmental Auditor and EPA.

10 REVISIONS

This rehabilitation plan will be revised after each cell is full, as if necessary, and after any future extension of the landfill following a works approval.

APPENDIX 1

SURFACE CONTOURS BEFORE SETTLEMENT

LANDFILL FORM – Cross Sections E&F

APPENDIX 2

HYLAND HIGHWAY LANDFILL – CAP CONSTRUCTION STAGES

CELL 1&2

CELL 3 CELL 1&2

ff, §: O' Qj,'! ' IS' , ° ()'0/ '-0 1:', CELL 4 �.' /1

� ...

APPENDIX 3

HYLAND HIGHWAY LANDFILL

LANDFILL GAS INFRASTRUCTURE

Appendix P – Environmental Monitoring Program

GHD | Report for Latrobe City Council –Hyland Highway Landfill Extension, 3136742 Nolan Consulting Pty Ltd ABN 91 088 244 884 P O Box 1238 Surrey Hills North VIC 3127 Nolan Consulting Tel: 0410 099 314

[email protected]

5 December 2011

Mr. Chandana Vidanaarachchi Coordinator Landfill Services Waste Services Latrobe City PO Box 264 Morwell VIC 3840

Dear Chandana

Re: Auditor verification of risk assessment & verification of environmental monitoring program – Hyland Highway Landfill (EPA Licence LS65990)

The purpose of this letter is to verify the monitoring program for the Highland Highway landfill as prepared by consultants Hyder Consulting Pty Ltd.

Regulatory requirements

The EPA landfill licensing guidelines (EPA publication 1323.1, the “Guidelines”) describe the Victorian regulatory requirements for environmental management of landfill operations. The Guidelines include requirements for environmental monitoring and auditing of landfill operations. For existing landfills without an auditor-verified monitoring program, the following must be undertaken:

a) Prepare a risk assessment (RA) and environmental monitoring program (MP) for the licensed operations. b) In the meantime, maintain the existing monitoring program. c) Engage an environmental auditor to conduct a 53V environmental audit that includes review of the RA and verification of the MP. d) Following completion of the audit described above, implement the monitoring and audit program consistent with the verified MP

For Council’s Highland Highway landfill, Hyder Consulting has been engaged to prepare the RA and MP. I have been engaged to conduct a 53V environmental audit of the landfill that includes review of the RA and verification of the MP.

Review of risk assessment of landfill operations

The Guidelines require an environmental risk assessment for each licensed landfill to be prepared that identifies and evaluates the potential risks of landfill operations to the environment. The RA is used to inform the MP for each licenced landfill. The risk management approach to assess compliance with licence conditions are outlined in the EPA licence assessment guidelines (EPA publication 1321.1).

Nolan Consulting Pty Ltd

The RA requirements are described in Section 4 of the EPA licence assessment guidelines. In summary they require:

. establishing the context of the RA; . identifying risks; and . risk analysis (including development of a risk register).

For Council’s Highland Highway landfill a RA has been prepared by Hyder Consulting. I have undertaken a review of the RA. This has involved review and consideration of the following aspects of the RA:

. identified environmental segments, elements and beneficial uses requiring protection; . identified risk sources associated with each environmental segment and element based on the types of waste currently and historically received at the landfill; . number type and location of the various receptors; . receptor pathways; . prioritisation of receptors and impact assessment; . risk screening undertaken; and . proposed methodology to translate risk assessment results to the environmental monitoring program.

The review of the RA has been conducted concurrently with my review of the MP as described below.

Review and verification of environmental monitoring program

The requirements for environmental monitoring programs of licensed landfills are described in Section 2 of the Guidelines. In summary the monitoring program must, as a minimum, include:

. list of all environmental elements to be included in the program; . monitoring details (parameters to be monitored, sampling point locations, sampling methods, equipment and infrastructure, monitoring frequencies); . place limits on the maximum leachate head above the lowest point of open cell drainage layers and, where specified by EPA, below the groundwater table; . trigger levels for action for each of the monitoring parameters; . quality assurance requirements; . a Section 53V audit program; and . method for verification of capped cells against approved EPA design.

A first draft MP (incorporating the RA) for the Highland Highway landfill was prepared by Hyder Consulting and submitted to me on 24 October 2011. I reviewed the draft MP and RA taking account of information provided to me on the landfill by Council, my observations during a site visit of 4 May 2011, and EPA requirements. I provided a detailed set of comments on the draft RA and MP on 31 October 2011.

Latrobe ltr1 2011-12-05.docx Nolan Consulting Pty Ltd

A second draft MP (incorporating the RA) was prepared and submitted to me on 18 November 2011. My further comments on this draft, as issued to Hyder on the 26 November 2011, were addressed to my satisfaction in the final Highland Highway Landfill Environmental Monitoring Plan submitted to me by Hyder Consulting on 3 December 2011. This report, file name “aa003889 - latrobe landfill ra and mp – highland highway (final v2), is attached to this verification letter.

Verification

I hereby verify that, in my opinion, after having assessed the risk assessment and monitoring program for the Highland Highway landfill (dated 3 December 2011), and having regard to the conditions of EPA Licence LS65990 and other relevant environmental policies, guidelines and documents published by EPA, the program is adequate for Latrobe City (the licence-holder) and EPA to determine compliance with the licence.

Please note that the first environmental audit under the monitoring program will be of landfill operations up to 31 December 2012 and is required to be completed by 31 March 2013. This is different to that originally anticipated and advised to EPA in my audit notification. I will advise the EPA audit team of the amended audit timeline.

Please feel free to contact me directly should you require further advice and/or clarification.

Yours faithfully

John Nolan Environmental Auditor appointed under the Environment Protection Act 1970 cc Mr Garry Kay, Client Relationship Manager, EPA Gippsland Region

Attachment A: Highland Highway Landfill Environmental Monitoring Program (December 2011)

Latrobe ltr1 2011-12-05.docx Nolan Consulting Pty Ltd

Attachment A

Highland Highway Landfill Environmental Monitoring Program 3 December 2011

LATROBE CITY COUNCIL RISK ASSESSMENT AND ENVIRONMENTAL MONITORING PROGRAM 2011 HYLAND HIGHWAY LANDFILL

Hyder Consulting Pty Ltd ABN 76 104 485 289 Level 16, 31 Queen Street Melbourne VIC 3000 Australia Tel: +61 3 8623 4000 Fax: +61 3 8623 4111 www.hyderconsulting.com

LATROBE CITY COUNCIL RISK ASSESSMENT AND ENVIRONMENTAL MONITORING PROGRAM 2011 HYLAND HIGHWAY LANDFILL

Author Mauro De Thomasis

Checker Richard Johnson

Approver Mauro De Thomasis

Report No AA003889-05A (Final V2)

Date 3 December 2011

This report has been prepared for Latrobe City Council in accordance with the terms and conditions of appointment for Hyland Highway Landfill dated 15 April 2011. Hyder Consulting Pty Ltd (ABN 76 104 485 289) cannot accept any responsibility for any use of or reliance on the contents of this report by any third party.

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Hyder Consulting Pty Ltd-ABN 76 104 485 289 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

CONTENTS

1 INTRODUCTION ...... 1 1.1 Scope of work ...... 1 1.2 Reviewed documents ...... 2 1.3 Development of conceptual site model ...... 3 2 LANDFILL DESCRIPTION AND ACTIVITIES ...... 4 2.1 Site description and landfill staging ...... 4 2.2 Landfill design and construction ...... 7 2.3 Landfill rehabilitation ...... 9 2.4 Landfill operations ...... 9 2.5 Complaints and regulatory performance ...... 13 3 REGIONAL PHYSICAL FEATURES ...... 14 3.1 Rainfall ...... 14 3.2 Topography ...... 14 3.3 Geology ...... 14 3.4 Hydrogeology ...... 15 3.5 Surface water ...... 17 3.6 Vegetation ...... 18 3.7 Nearby receptors ...... 18 4 RISK ASSESSMENT...... 22 4.1 Scope and methodology ...... 22 4.2 Risk analysis matrix ...... 23 4.3 Risk register ...... 24 4.4 Groundwater risk assessment by GHD ...... 25 4.5 Initial screening of off-site landfill gas risks ...... 26 4.6 Medium and greater risks ...... 28 5 MONITORING PROGRAM ...... 29 5.1 Monitoring objectives ...... 29 5.2 Review of the former monitoring program ...... 29 5.3 Description of local environment and activities ...... 33 5.4 Monitoring locations ...... 33 5.5 Indicators and triggers ...... 36 5.6 Sampling and inspection frequency ...... 38 5.7 Sampling procedures and quality assurance ...... 39 5.8 Reporting ...... 41 5.9 Future reviews ...... 41

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Hyder Consulting Pty Ltd-ABN 76 104 485 289 Page i aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

5.10 Environmental audit frequency ...... 41 6 REFERENCES ...... 42

Attachments:

A: Site Photographs (11 pages) B: Former EPA Licence (12 pages) C: Current EPA Licence (7 pages) D-1: Landfill Risk Assessment Register (3 pages) D-2: Landfill Compliance Risk Register (6 pages)

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Page ii Hyder Consulting Pty Ltd-ABN 76 104 485 289 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

1 INTRODUCTION

Hyder Consulting was commissioned by the Latrobe City Council (LCC) to prepare the Risk Assessment and the Environmental Monitoring Program for the Hyland Highway Landfill. The premises address is Hyland Highway, Loy Yang.

Both the Risk Assessment and the Environmental Monitoring Program are presented in this report. 1.1 Scope of work

The Hyland Highway landfill is an existing landfill without an Environment Protection Authority (EPA) appointed auditor-verified monitoring program.

The required process for establishing the risk based audit program for this landfill is described in the EPA (2010) Landfill Licensing Guidelines (Publication No. 1323.1). It is as follows:

. Prepare a risk assessment (RA) and environmental monitoring program (MP) for the licensed operations; . In the meantime, maintain the existing monitoring program; . Engage an environmental auditor to conduct a S53V environmental audit that includes review of the RA and verification of the MP; and . Implement the monitoring and audit program consistent with the verified MP. The RA and MP apply to all landfill areas that have been or are currently being filled (i.e. Cells 1 and 2). 1.1.1 Risk assessment

The risk assessment methodology is consistent with the guidance provided in Publication 1323.1 and, in particular, with Section 4 of EPA (2010) Licensing Assessment Guidelines – Guidelines for Using a Risk Assessment Approach to Assess Compliance with Licence Conditions (Publication 1321.1).

In broad terms the methodology involves the following tasks:

. Establish the context of the landfill assessment; . Identify risks; and . Analyse risks. The following environmental elements have been considered in the risk assessment:

. Water; . Air; . Soil; . Rehabilitation; . Health and safety; and . Native flora and fauna. A full description of the methodology is described in Section 4 of this report.

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Hyder Consulting Pty Ltd-ABN 76 104 485 289 Page 1 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

1.1.2 Monitoring program

The scope of the monitoring program development is consistent with the guidance provided in Publication 1323.1 and in Section 5 of Publication No. 1321.1. The scope of work and method for developing the environmental monitoring program is fully described in Section 5 of this report and summarised below:

. Establish monitoring objectives; . Review existing environmental monitoring program; . Describe site activities and the surrounding environment; . Select appropriate indicators; . Set trigger levels; . Identify monitoring locations; . Establish the frequency and timing of sampling; and . Develop quality assurance and control measures. A landfill site visit was conducted by the Hyder team on 19 April 2011 with LCC’s Landfill Services Co-ordinator. Selected landfill site photographs are provided in Attachment A. During the landfill site visit discussions were held with the Landfill Services Co-ordinator to assist in determining the history of the landfill construction and operation. 1.2 Reviewed documents

The full list of documents that have been reviewed is presented in Section 6 of this report. Key documents include:

. Former EPA licence LS65990 (issued 4 June 2009); . New EPA licence LS65990 (amended 30 June 2010); . Report in support of Works Approval Application, GHD 2007a; . Letter report in response to Southern rural Water request for additional information on groundwater modelling, GHD 2007b; . Draft CQAP, GHD 2007c; . Audit Report, Assessment for Works Approval Application, GHD 2007d; . Detail design of leachate pond, GHD 2007e; . Draft Works Approval Application, GHD 2007f; . Alternate Landfill Liner Report, GHD 2007g; . Draft soil survey report for Callignee Landfill, GHD 2007h; . Draft and Final Documentation Supporting Works Approval Application for Proposed Landfill - Callignee South, GHD 2007i & j, respectively. . Flora and fauna assessment of a potential landfill site at Callignee South, Victoria, Biosis 2006; . EPA Works Approval letter, EPA 2008; . Audit Report, Performance of Landfill Liner and Leachate Collection Systems, Hyland Highway Landfill, Callignee, Golders Associates 2010; . Hyland Highway Landfill EPA Licence Compliance Report; Meinhardt 2010;

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Page 2 Hyder Consulting Pty Ltd-ABN 76 104 485 289 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

. Annual Performance Statement 2009/2010 – Latrobe City Council 2010; . Final Works Approval amendment, EPA 2010; and . Hyland Highway Landfill Groundwater Bore Installation (draft report), Meinhardt 2011. The former EPA Licence LS65990 (issued 4 June 2009) and current EPA Licence LS65990 (issued 30 June 2010) are provided as Attachments B and C, respectively. 1.3 Development of conceptual site model

For a risk to exist, there must be a source (or hazard), a pathway and a receptor (or target). The relationship between these elements can be understood through the conceptual site model. The elements, descriptors, and evidence for the conceptual site model are presented in Table 1.1.

Table 1.1: Conceptual Site model elements

Element Descriptor Evidence (including section of report in which described)

Source Composition Extent of waste body (Section 2.1 and 2.4); of Waste and General description of topography (S3.2); its extent Actual waste type and area deposited on landfill site (S2.4.1 and 2.1.4); Age of waste /period of operation of landfill (S2.1 and 2.1.4); Evidence of leachate generation following landfill site inspection (S2.4.3); and History of landfill site development including age of waste/phases (S2.1 and S2.4). Pathway Leachate Landfill site geology (S3.3); Migration Landfill site capping / base / side lining (S2.2 and 2.3); Groundwater flow direction (S3.4.3); and Surface water drainage (surface water pathway) (S2.4.2 and 3.5). Landfill Gas Landfill site geology (S3.3); Migration Landfill site capping / base / side lining (S2.2 and 2.3); and Likely presence of underground services/conduits (S3.7.2). Receptors Leachate Groundwater beneficial use category (S3.4.6); Migration Drinking Water Supplies (other than private wells) within 1,000m (both surface water and groundwater) (S3.7.3 and S3.7.5); Location of houses, schools, industrial development, including land use (zoned lands) within 1,000m (protection of potential private bores) (S2.1.1 and 3.7.1); Protected Areas: Location and designation of any groundwater or surface water dependent ecosystems; flood plains; special conservation, heritage, or protected areas; recreational waters; etc, within 1,000m of the boundary of the landfill site (S3.7.3); and Location and designation of any surface water bodies within 1,000m of boundary of the landfill site (S3.7.5). Landfill Gas Location of houses, schools, industrial developments, temporary Migration accommodation, and land use (zoned lands) within 500m of the landfill site (S2.1.1 and 3.7.1); and Details and locations of underground services (S3.7.2).

Section 2 (Landfill Description and Activities) and Section 3 (Regional Physical Features) of this report provide the basis for the conceptual site model. Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Hyder Consulting Pty Ltd-ABN 76 104 485 289 Page 3 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

2 LANDFILL DESCRIPTION AND ACTIVITIES 2.1 Site description and landfill staging

Schedule 1A “Locality Plan” of the current EPA Licence LS65990 shows the ‘licensed area’ as applying to the area bounded by Callignee South Road (western and southern boundaries), the diagonal boundary between the landfill and mining licence (eastern boundary) and a site access road which runs east-west (northern boundary).

Schedule 1B “Premises Plan” of the current EPA Licence LS65990 shows the scheduled premises (i.e. the landfill area) as an area occupying the north-east portion of the overall ‘licensed area’. As such, in this report the licensed area (i.e. the overall site) is referred to as “the site” and the scheduled premises (i.e. the landfill area), is referred to as “the landfill site” and includes the area in which the primary and secondary stormwater dams are located (as per the EPA Licence Schedule 1B – Premises Plan).

The site is owned and operated by the LCC. Figure 1 provides a site locality plan and shows the licensed area boundary, and the boundary of the landfill site.

The landfill site is located about 2km north-east of Traralgon South. It is accessed via 3km of sealed road from the Hyland Highway at Loy Yang. The weighbridge is located near the entry to the site off Hyland Highway. The landfill site includes provision for ten cells, as shown in Figure 2, of which Cells 1 and 2 are currently being filled as a single combined cell. 2.1.1 Zoning

The scheduled premises is zoned Special Use Zone (SUZ1) under the LCC’s Planning Scheme and is bounded by further SUZ1 to the north and by Farming Zone (FZ) to the west, south and east.

The scheduled premises (and surrounding area to the south and east) is subject to a Wildfire Management Overlay (WMO). This overlay is not considered to present a major issue in relation to the landfill RA and MP as it is does not impose major environmental constraints to landfill operational requirements. 2.1.2 Former land use

The former land use was forestry and timber plantation.

Land use immediately surrounding the landfill site is predominantly forestry. Other land uses near the site include the Loy Yang Open Cut mine overburden dump (approximately 700 m to the north of the landfill site) and the Loy Yang motorsport race track (approximately 600 m to the north-west of the landfill site). 2.1.3 Loy Yang Open Cut Coal Mine

Loy Yang A is a 2000 megawatt thermal power station with an adjacent open-cut coal mine (the “Loy Yang Open Cut Coal Mine”). The coal mine is located more than 3.5 km from the landfill site on the opposite side of the Hyland Highway. The mine is the largest open cut coal mine in Australia, extracting approximately 31 million tonnes of coal per annum (Loy Yang Power, 2010).

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Page 4 Hyder Consulting Pty Ltd-ABN 76 104 485 289 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

The base of the mine is at an elevation of approximately -40m AHD (i.e., approximately 40m below sea level). The mine pit is about 200 m deep, 3 km in length and 2 km wide at its widest.

Figure 1 Aerial photo showing landfill site locality and surrounds.

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Hyder Consulting Pty Ltd-ABN 76 104 485 289 Page 5 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

Figure 2 Aerial photo showing key site features.

Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Page 6 Hyder Consulting Pty Ltd-ABN 76 104 485 289 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

2.1.4 Landfill development

Works Approval for the landfill site was obtained on 4 March 2008.

Waste was first deposited in June 2009 which corresponds with the first issue of the EPA Licence.

The landfill includes provision for ten cells of which Cells 1 and 2 are combined and are currently being filled (refer Figure 2), with future cells to be progressively developed and filled towards the east.

Based on an average cell footprint of 14 000 m2 and an average fill depth of 6.5 m for each cell, the average waste capacity of a cell is estimated to be approximately 90 000 m3.

At the current disposal rate of about 45 000 tonnes per year and assuming an in-situ waste density of 0.8 tonne/m3, it is estimated to take just under two years to fill each cell and approximately 16 years to fill the landfill site.

The relative level of the base of the combined Cell 1/2 (i.e. the top of liner, or lowest point of drainage layer) varies from about 139.4 mAHD at its north-west corner to 114.9 mAHD at its south-east corner. 2.2 Landfill design and construction 2.2.1 Historical and current landfill

Cells 1 and 2 are combined and are the active cells currently being filled.

The waste is placed at the base and then pushed up the face. A compactor is then used to compact the waste and minimise the amount of settlement. Soil excavated from a stockpile of excavated material from future Cell 3 is used as daily cover. No rehabilitation is currently being undertaken.

There is currently no landfill gas extraction or subsurface gas monitoring infrastructure installed at the landfill site and surrounds. 2.2.2 Landfill liner

According to the Audit Report, Assessment for Works Approval Application, GHD 2007d, the base of each cell was proposed to be lined with a double composite liner system comprising a primary liner, a secondary liner and a synthetic geomembrane (HDPE) liner.

The design of the cell lining system at Latrobe Hyland Highway Landfill prepared by GHD (GHD 2007d) included the following key features from bottom to top of liner;

 1,000 mm thick compacted clay layer and textured HDPE geomembrane to form the secondary composite liner;

 Geosynthetic drainage grid (Geonet GTG512 layer);

 Geosynthetic Clay Liner (GCL X1000 layer) to form the primary GCL liner;

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 Layer of A34 bidim®1;

 Leachate collection layer comprised of 300 mm of aggregate;

 Layer of A34 bidim® and a pipe to form the primary leachate drain;

 Connection of the secondary leachate drain to a secondary leachate inspection pit (located outside the cell); and

 Connection of the primary leachate drain to the leachate pond.

The landfill liner has been designed to slope towards the south easttern corner of the combined Cell 1/2 at a 1 in 7 gradient (Golders, 2010).

The lining system described above extends from the base along the external sides of each landfill cell, with the exceptioon of the 300 mm aggregate layer which is not part of the side lining.

Figure 3 Landfill liner configuration (as provided by LCC) The primary leachate collection sysstem comprises a series of interconnnected perforated 150 mm diameter HDPE pipes within the leachate collection layer that conveys leachate via gravity towards a low point in the south-east corner of the combined Cell 1/2.

1 bidim® is a continuous filament nonwoven needle-punched polyester geotextile of higgh porosity.

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Leachate drains by gravity into the leachate pond located to the south of the combined Cell 1/2.

The secondary leachate collection system is comprised of interconnected perforated HDPE pipes within <40 mm drainage aggregate below the Geosynthetic drainage grid (Geonet GTG512 layer). The connecting secondary leachate collection system pipes are located along the east edge of Cell 1/2. These pipes grade to a low point in the south- east corner of the combined Cell 1/2.

An environmental audit report verifying the CQA plan and construction of the liners for Cell 1/2 and the Leachate Pond was prepared by GHD in May 2009 (GHD, 2009). The audit report concluded that the cell and leachate collection pond linings and the leachate collection systems had been constructed in accordance with the EPA approved CQAP Plan and EPA's subsequent approvals and that their operation would not increase the risk of harm to the groundwater environment than that approved by the EPA.

Construction of the next cell (Cell 3) is underway, however, a documented or environmental auditor approved Construction Quality Assurance Plan (CQAP) for this cell was not available as part of this review. As such, any cells currently being prepared do not form part of this RA and MP and will be addressed as part of subsequent reviews of the RA ad MP. 2.3 Landfill rehabilitation

The proposed landfill cap is to be constructed in accordance with EPA (2010c) ‘Best Practice Environmental Management Siting, Design, Operation and Rehabilitation of Landfills’ (‘the Landfill BPEM’). The cap will incorporate a 1, 000 mm compacted clay liner overlain by a geomembrane (LLDPE) barrier and a sandy drainage medium and a topsoil layer. The cap will have a permeability of not greater 1 x 10-9 m/s. It is noted that Works Approval Application GHD (2007a) modelled the infiltration of precipitation through the cap, stormwater runoff, leachate generated, and leachate leakage through the base liner. Infiltration of precipitation through the cap and leachate leakage was shown to satisfy the requirements of the EPA 2001 version of the Best Practice Environmental Management - Siting, Design, Operation and Rehabilitation of Landfills (Publication 788).

Landfill cells will be capped as soon as practicable, not longer than 12 months after cells are filled. Final contours for the landfill are included in the “Final Contour Plan” as shown in Attachment B. 2.4 Landfill operations

The current landfill operations that have been identified as environmental aspects for the risk register, as presented in Attachment D and described in Section 4.3, are as follows:

. Leachate management; . Surface water management; . Landfill gas management; . Landfill rehabilitation; . Waste receival and on-site management (at weighbridge, transfer to active cell, tipping and compaction); . Odour management; . Noise management;

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. Dust management; . Litter management; and . Other activities (vehicle movement and storage of fuels and chemicals). Cells 1 and 2 are subject to the monitoring program presented in this report.

A commentary of some key operational aspects is presented below. 2.4.1 Wastes currently received

According to EPA Licence LS65990 (June 2010), the landfill is licensed to receive putrescible waste, solid inert waste, asbestos of domestic origin, shredded tyres and prescribed industrial waste (contaminated soil – Category C). However, LCC has advised that it surrendered the acceptance of Category C (contaminated soil) as part of the EPA final Works Approval Amendment 2010.

According to Meinhardt (2010), during the reporting period of 2009/2010 financial year, around 23 000 tonnes of Municipal Waste and 24 000 tonnes of Industrial Waste were deposited at the landfill. 2.4.2 Surface water management

The nearest permanent surface water feature to the landfill site is the Traralgon Creek which runs in a northerly direction and, at its closest point, is about 1 100 m from the western boundary of the landfill site. The creek has its headwaters in the Strzelecki Ranges adjacent to the TarraBulga National Park. Traralgon Creek is a tributary of the Latrobe River, which flows eastward, 12 km to the north of the landfill site and discharges to the Gippsland Lakes. Shingle Creek, a minor tributary of Traralgon Creek is located 2 km south of the landfill site. Watercourses surrounding the site are shown in Figures 1 and 5.

The landfill site is located immediately south of an east-west trending ridgeline. As a consequence the surface runoff within the landfill site is mainly limited to that which is generated within the site itself. The existing surface levels ranging from approximately 152 m AHD in the north to 119 m AHD in the south. The location of the landfill site ensures that it is not subject to flooding from adjacent catchments.

The landfill area was previously covered by plantation forest which still surrounds the landfill site. The surface water runoff currently naturally drains to the south and then west into a minor water course which then enters Traralgon Creek to the west.

The active landfill area (combined Cell 1/2) does not have permanent cover (cap) and most rainfall infiltrates into the landfill and collects as leachate. There is also a component that is captured in the two stormwater diversion drains.

On the eastern side of the active landfill area, stormwater runoff drains in a south- westerly direction down a gravel road and enters the primary stormwater dam located south-west of Cell 3, which is currently under construction.

On the western side of the active landfill area, stormwater runoff drains in a southerly direction down a gravel road, then easterly below the combined Cell 1/2 and then enters the primary stormwater dam. During the site visit of 19th April 2011 (which occurred during recent heavy rainfall) there was visible surface erosion along the drainage line. No litter was evident in the erosion scars during the site visit.

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The stormwater within the primary stormwater dam then discharges when close to capacity, via a pipe, into a secondary stormwater dam located at the southern end of the combined Cells 1/2 and to the west of the primary stormwater dam. According to the LCC representative, water captured by the stormwater dams is used as required for on-site dust suppression. A small “wetland” area has been retained as a site feature and is located immediately east of the leachate pond, north-east of the stormwater dams and east of the eastern cut-off drain, within the southern boundary of the landfill site.

During the site visit of 19th April 2011 (which occurred during recent heavy rainfall), both the primary settling stormwater dam and secondary dam were heavily impacted by sediments in suspension.

Overflows from the secondary stormwater dam and the wetland area discharge into the minor watercourse located to the south-west of the landfill site. This ephemeral watercourse eventually flows in a westerly direction towards Traralgon Creek.

No water testing was conducted in this area as part of the 2010 sampling round, conducted by Meinhardt. 2.4.3 Leachate

The primary leachate collection system grades to a low point in the south-east corner of the combined Cell 1/2. From this location it is piped under gravity through a penetration in the side liner of the southern bund wall of the combined Cell 1/2. Leachate from this point is treated by sand filtration to reduce the suspended solids and then by reverse osmosis to reduce the salinity. Through this treatment process; i.e. after sand filtration, the leachate is stored temporarily in 11 storage tanks which are dosed with Alum to reduce suspended solids. The movement of leachate through the treatment process is controlled by a series of valves within pits.

The brine from the RO plant is discharged to the leachate pond. The treated low salinity water is then discharged to the primary stormwater dam (Figure 2). The leachate pond is lined and has a design capacity of approximately 655 kL (with a 300 mm freeboard).

The secondary leachate collection system also grades to a low point in the south-east corner of the combined Cell 1/2. From this location it is piped under gravity through a penetration in the side liner of the southern bund wall of the combined Cell 1/2. Leachate from this point is piped to a secondary leachate inspection pit. This pit is connected to the leachate pond via a pipe to flow under gravity.

As discussed in Section 2.2.2, the leachate pond liner was designed by GHD (2007e) and the leachate pond construction was audited by GHD in 2009 (GHD, 2009). The leachate liner performance was audited by Golder Associates (2010).

According to the LCC representative, the landfill produces around 100,000 litres of leachate per week (5.2 ML/yr). This figure is consistent with data for 2009/2010 shown in the Meinhardt 2010 report.

The LCC representative also mentioned that the secondary leachate collection system was collecting a substantial amount of leachate, as evidenced by the meter readings for the meter installed at the discharge point of the secondary outlet (which indicated that the secondary system collected around 300 m3 of leachate since its installation). The volume of leachate collected (0.15 ML/yr) indicates that there may be some leakage from the primary liner or some faults in the installation of the geosynthetic clay liner (GCL).

The environmental audit conducted by Golders (Golders Associates, 2010) raised the following elements:

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“The Auditor has found that the general performance of Cells 1 and 2 of the landfill is in line with his understanding of the design intent, insofar as some leachate would have been expected to accumulate within the secondary leachate drain and report to the secondary leachate inspection pit. However, the amount of leachate reporting to the secondary leachate inspection pit and the observed inter-connection of the primary leachate drain and the secondary leachate drain at the low point of Cell 1 was greater than would have been expected.

Although there is a high level of connectivity between the primary and secondary leachate drains, the Auditor is of the opinion that the landfill cell is currently operating in a manner that has a higher level of redundancy than a ‘standard’ EPA BPEM designed putrescible waste landfill cell would. Further, there is no evidence to suggest that the secondary composite liner will not perform adequately to protect the groundwater environment.

However, the Auditor has identified that the stability of the waste mass, the capacity of the leachate collection pond and the long term performance of the primary leachate collection drain have the potential to pose an increase to the risk of harm or detriment occurring to the land, groundwater and/or surface water segments of the environment and that further investigation and/or rectification works are required”.

Conclusions and recommendations for the current Cells 1 and 2 from Golder Associates (2010) are listed below.

“The Auditor considers the following measures are needed to reduce the risk of possible harm or detriment occurring from leachate generated in the current (Cells 1 and 2) landfill cells:

. Increase the capacity of the leachate holding and treatment infrastructure. Assess and upgrade, as necessary, the functionality of the secondary leachate inspection pit given that it may not have been designed to continuously store leachate; . If practicable, install a leachate collection sump within or immediately adjacent to Cell 1. The sump should be designed to receive leachate from both the primary and secondary leachate transfer pipes and convey the combined flow, without penetration of the side liner, to the leachate collection pond. A robust lining system should be designed for the base of the sump to minimise risk of leakage from the sump. Detailing of the sump design will need to consider short term leachate management and tie in with adjacent liners. . Close Cells 1 and 2 in a timely manner to minimise the volume of leachate generated. Capping should be consistent with that proposed in the Works Approval Application, involving a composite compacted clay and geomembrane liner overlain by cover soils. The stability of the cap should be considered in the detailed design. . Further investigation and assessment of the long term stability of the proposed final waste surface. From this assessment it is possible that the following measures may be required: . Increase the height of the southern bund using a centreline construction with removal of waste locally at the southern toe of Cell 1; . Modify the height and gradient of the final waste profile; . Install piezometers (in addition to those in place) or leachate wells to monitor the head of leachate within the waste mass; . Preferentially construct the final landfill cap at the southern end of Cell 1 and place additional clean ballast at the downstream toe to increase the factor of safety against waste movement at the toe of the landfill.” Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Page 12 Hyder Consulting Pty Ltd-ABN 76 104 485 289 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

Key recommendations from the Golder Associates (2010) audit with respect to future cells are summarised as follows:

. Increase the capacity of the leachate holding and treatment infrastructure; . The leachate collection system of the cells should comprise a leachate collection sump within the landfill cell as part of the primary leachate collection system with levels of redundancy in case of blockage; and . There should be no penetration of the downstream bund wall side liners by leachate transfer pipes; . The liner system comprise a double composite liner in order to have a performance in line with the expectations of EPA (unless alternative lining can be agreed with EPA, as outlined above); and . Compliance with the new Landfill BPEM guidelines. An assessment of compliance with these recommendations was considered beyond the scope of this review. 2.5 Complaints and regulatory performance 2.5.1 Complaints

During the landfill site visit, the LCC representative indicated that there were two incidents of leachate spill/overflow from the leachate pond (Sep 2009 and Oct 2009) and that an odour complaint was lodged with EPA in November 2009. 2.5.2 Regulatory performance

LCC advised that they have not been issued by the EPA with any pollution abatement notices, clean up notices, or enforcement action, associated with the landfill operation from the EPA over the past 2 years.

The Annual Performance Statement 2009-2010 (LCC, 2010) identified that LCC has complied with all licence conditions with the exception of Conditions WM3 (litter), L4 (contaminated water, as identified above), L5 (landfill gas) and L8 (annual survey).

An odour complaint lodged with EPA in November 2009 was not included as a non- compliance by LCC as the landfill was confirmed not to be the source of the odour

LCC noted non-compliance with respect to litter (Condition WM3) indicating that “infrequently on heavy wind days litter blows outside landfill perimeter”.

Conditions L1 (auditor verified monitoring program) and L2 (appointment of environmental auditor) were reported as “not applicable”.

The Annual Performance Statement 2010-2011 (LCC, 2011) identified that LCC complied with all licence conditions with the exception of Conditions WM3 (litter, as identified above), L1 (Monitoring Program), L5 (landfill gas) and L8 (annual survey).

Non compliances with Condition L5 related to the lack of an auditor verified monitoring program to assess potential landfill gas emissions.

It is noted that non-compliances associated with L1 and L5 will be addressed following verification of the monitoring program presented in this report.

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3 REGIONAL PHYSICAL FEATURES

This section of the report describes the local and regional physical features, including the nearest receptors that form part of the conceptual site model supporting the risk assessment. 3.1 Rainfall

The mean annual precipitation as obtained from the Bureau of Meteorology (Latrobe Valley airport) website is 773 mm with the wettest month being September (77 mm) and the driest month being February (44 mm). 3.2 Topography

An east west trending ridge line is located along the northern boundary of the site. The landfill site slopes from about 152 m AHD in the north to about 119 m AHD in the south. 3.3 Geology

A number of previous assessments and audit reports have been conducted on the Hyland Highway Landfill site, including reports by GHD and Meinhardt between 2006 and 2010.

According to information collected in those reports, the geology in the vicinity of the landfill consists of from youngest to oldest:

. Upper Tertiary (uTa) Haunted Hills Formation; . Middle Tertiary (mTa) brown coal deposits of the Latrobe Valley Coal Measures; . Middle Tertiary (mTa) Older Volcanics (Thorpdale Volcanics) which depending on location may be absent. It is understood that the youngest flows may be interbedded in to the lower sequences of the Latrobe Valley Coal Measures . Early Tertiary (eTa) Childers Formation . Lower Cretaceous Strzelecki Group (bedrock) The Haunted Hills Formation (uTa) sediments, which are fluvial in origin and consist of cross-bedded and lenticular gravels, sands and clays. The Haunted Hills Formation is the predominant surface geological unit in the area (Warragul geological map sheet 1:250,000 and Geology of Victoria, Birch).

The Latrobe Valley Coal Measures (mTa) include the Morwell Formation which is widespread. This formation is comprised of thick brown coal seams with subordinate interseam sediments. The Older Volcanics (mTa) are described as olivine basalt, titan augite basalt, associated pyroclastics plugs and dykes.

The Childers Formation (eTa) consists of alluvial fans, braided streams and point bar sand deposits consisting of sand, conglomerate, clay and gravels with thin brown coal seams.

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The Lower Cretaceous Strzelecki Group basement rocks are comprised of interbedded non-marine greywackes, mudstones, sandstones, conglomerates, minor coals and volcanics. The Strzelecki Group is the dominant formation of the Strzelecki Ranges to the south of the landfill site (Meinhardt, 2010).

Meinhardt (2010) comments on the installation of a groundwater monitoring bore in 2010 and provides details of landfill site geology. They advise of the following which is consistent with the above geological description

. 0 m to 20-30 m Haunted Hills Formation silty sand, sandstone, sandy clay and clayey sands. . 20 m-30 m – 50 m Latrobe Valley Coal Measures (coal) . > 50 m Childers Formation (high proportion of sand compared to clay) 3.4 Hydrogeology 3.4.1 Aquifers

According to Meinhardt (2010), the regional hydrogeology consists of four major regional aquifer systems:

. The Upper Tertiary Aquifer (uTa) includes the Haunted Hills Formation and is interconnected with the recent alluvium deposits in the nearby streams. . The Middle Tertiary Aquifer (mTa) includes the younger Older Volcanic deposits interbedded with the Latrobe Valley Coal Measures. Water quality is typically potable and the yields vary with lithology. In the case of coal and Older Volcanic deposits the aquifer is relatively low yielding. . The Early Tertiary Aquifer (eTa), comprised of the Childers Formation and the Older Volcanics units in the area. This aquifer is considered to be a significant regional groundwater resource with groundwater typically of potable quality in the vicinity of the landfill site. . The Bedrock Aquifer includes the Strzelecki Group which forms the Strzelecki Ranges to the south. 3.4.2 Watertable level

Four bores have been drilled in the vicinity of the landfill site for groundwater monitoring purposes. Their locations are shown in Figure 6. During the drilling of the initial groundwater bores (i.e. BH1, BH2 and BH3) it was originally intended to screen the bores above and below the coal seam to monitor both the upper (uTa) and early Tertiary (eTa) aquifers. It was discovered that there was no saturated layer above the coal layers, therefore, bores were screened in the deeper eTa only.

It is assumed that the groundwater table within the eTa is significantly depressed considering the close proximity of the Loy Yang open cut mine and could potentially continue to be lowered depending on pumping rates in the mine.

The screened interval for each of the bores BH1 to BH3 is between approximately 47 and 73 m below ground surface (BGS). The standing water levels were reported by Meinhardt (2010). The levels were about 96 mAHD in BH3 (to the north) and about 45 m AHD in BH1 (to the south). BH2 was dry. Refer Section 5.2.1 for further information. Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Hyder Consulting Pty Ltd-ABN 76 104 485 289 Page 15 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

When Meinhardt installed the groundwater bores (BH1, BH2 and BH3), all bores had measurable water tables. However, since the installation, one of the bores (BH2) has been reported as dry. The other two bores have had lower water levels during each subsequent monitoring event.

According to Meinhardt 2010, the watertable depth within the Childers Formation aquifer the indicates that the aquifer is not hydraulically connected to the recent alluvium deposits in the nearby streams overlying the Haunted Hill Formation or the surrounding surface water features.

In June 2011, LCC engaged Meinhardt to install a fourth groundwater monitoring bore (BH4) in the uTa, above the underlying coal seam (Meinhardt 2011). The proposed bore location was determined based on recommendations in Meinhardt (2010). There is the potential that sand lenses in the Haunted Hill Formation, above the coal seam, could become saturated following a significant storm event. If considerable saturation were to occur, water would most likely migrate to and accumulate at the topographic low point of the coal seam. This was estimated to be about 33 mBGS in the vicinity of BH2. Thus the new groundwater monitoring bore (BH4) was installed in the vicinity of existing BH2.

The screened interval for bore BH4 is between 17 and 20.6 mBGS and standing water level within the bore was observed in 2011 to be at 18.8 mBGS (101 mAHD) (Meinhardt, 2011). This confirms the presence of perched water at this location. Refer Section 5.2.1 for further information. 3.4.3 Recharge, discharge and groundwater movement

Recharge to the aquifer will be via rainfall infiltration.

Due to limited information on groundwater levels, the groundwater gradient and flow direction is uncertain. Groundwater levels seem to indicate that the groundwater flow is in the southerly direction, however, the large difference in head across the landfill site suggests that the water levels may represent two separate aquifers or localised perching of water. A southerly groundwater flow direction is also inconsistent with the impact of the 200m deep Loy Yang open cut mine to the north, which, together with surrounding topographical influences, is estimated (see Section 3.4.3) to result in groundwater flow both towards Traralgon Creek to the west and to the open cut mining area in the north.

The groundwater flow direction is therefore considered ambiguous. 3.4.4 Salinity

Analytical results indicate that groundwater salinity (as measured by TDS concentration) in the Early Tertiary aquifer for monitoring bore BH3 is in the range 140 to 172 mg/L (2009 to 2010) and for bore BH1 it was 272 mg/L in 2009.

Recently installed bore BH4 was not sampled. 3.4.5 Other groundwater quality considerations

The Loy Yang coal mine overburden, interseam sediments and associated inferior coal are disposed in a 13.5 km2 surficial dump north of the landfill. The iron-sulphide bearing interseam sediments/inferior coal have caused several acidic seeps to develop (Elders 2001, as referenced in Meinhardt 2010).

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3.4.6 Beneficial uses

The beneficial uses of groundwater to be protected are specified by the State Environment Protection Policy (Groundwaters of Victoria) and are based on TDS concentrations.

Based on the salinity ranges described above, the groundwater within the Early Tertiary aquifer is classified as being within Segment A1 for which the beneficial uses to be protected include:

. Potable water supply (possible); . Potable mineral water supply (possible); . Maintenance of ecosystems (current); . Agriculture, parks and gardens (current); . Stock watering (current); . Industrial water use (possible); . Primary contact recreation (likely); and . Buildings and structures (possible). The ecosystems likely to require groundwater inflows to maintain their beneficial uses are the Shingle and Traralgon Creeks (see Section 3.5). As the local area is an agricultural region the agricultural and stock watering beneficial uses apply.

As the Traralgon Creek is used recreationally primary contact recreation is a likely beneficial use.

Based on the Victorian Resources online database map, the groundwater within the Upper (uTa) and Middle (mTa) Tertiary aquifers is understood to be classified as being within Segment A2 and A1 respectively. The beneficial uses to be protected for Segment A2 include all those listed above with the exception of potable water supply. 3.5 Surface water 3.5.1 Streams

According to the topographic map (DPI), there are no major surface water receptors within 1 km of the landfill site. A minor water course is located to the south-west of the site. The minor water course joins Traralgon Creek which, at its nearest point, is 1.1 km west of the landfill site. 3.5.2 Channels and drains

There were no major nearby channels and drains identified. 3.5.3 Beneficial uses

Under the SEPP (Waters of Victoria) the site and surrounds is located within the “Cleared Hills and Coastal 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:

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. 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 & molluscs for human consumption. Due to the distance to the nearby major water bodies (Traralgon Creek is more than 1 km to the west from the landfill area) and the extensive plantation activity in the immediate surrounds of the landfill site, the EPBC database has not been searched for indigenous and non-indigenous cultural and spiritual heritage sites. 3.6 Vegetation

To our knowledge, based upon a review of documents provided in the reference list and the landfill site inspection, there is unlikely to be native vegetation of significance within the licensed premises.

The Works Approval Application (GHD 2007a) indicated that the Environment Protection and Biodiversity Conservation (EPBC) Act Search Tool was used to conduct a search of Matters of National Environmental Significance. This search indicated that World Heritage Properties or National Heritage Places are not located in the vicinity of the proposed landfill.

Biosis (2006) conducted a flora and fauna assessment of the landfill site. The plantation was found to be in poor ecological condition, with negligible significance for nature conservation. Biosis did, however, identify one small remnant of Swampy Riparian Woodland within the plantation at the southern end of the western drainage line. This remnant was found to be in moderate condition and is believed to have high local conservation significance.

A search of the EPBC Act Protected Matters Search Tool by Biosis indicated that the landfill site has the potential for species or species habitat to occur within the area for 17 threatened species, 8 migratory species, and 12 listed marine bird species. However, the Biosis field survey determined that the study area has little or no potential to support listed threatened flora and fauna. As such, the proposal to develop this site as a landfill, is unlikely to constitute a ‘controlled action’ under provisions of the EPBC Act 1999 and the preparation of a referral to the Australian Environment Minister under the EPBC Act is unnecessary.

In order to protect and conserve the small, but highly locally significant Swampy Riparian Woodland, LCC partitioned off this section of the landfill to protect it during construction. 3.7 Nearby receptors 3.7.1 Residences, school and industry

The nearest residence is located approximately 1.2 km south-west of the landfill site. There are no schools within 1 km of the landfill site.

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The nearest industry is the Loy Yang power station and open cut mine located more than 2.5 km and 3.5 km, respectively, to the north of the landfill site. A motor cross track is located about 600 m to the northwest of the landfill site.

The Traralgon South township is the nearest residential town and is situated more than 2 km to the southwest of the landfill site. 3.7.2 Underground services and conduits

To our knowledge, no major underground services or conduits connecting the site with sensitive receptors are present in the existing landfill. However, a search for the location of major on-site services has not been undertaken. LCC advised that there will be underground power provided to the leachate sump pump and stormwater pump in Cell. 3.7.3 Protected groundwater and surface water ecosystems

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. 3.7.4 Groundwater users

Surrounding the site According to the Victorian Data Warehouse database, there are significant numbers of groundwater bores within 2km of the landfill site (refer Figure 4). There are around 300 active observation bores within about 2km of the landfill site. We are not aware of any bores within this area which are used for water supply purposes.

The depth of the exploration bores varies from shallow (3-10m) to deep (around 350m), likely targeting the Early or Middle Tertiary aquifers, up to the Upper Tertiary Haunted Hills Formation.

No up-to-date lithological, chemical or physical parameters were available on the database for the identified bores. 3.7.5 Surface water

The surface water surface water receptors down-gradient the landfill are described in Section 3.5.1 and shown in Figure 5.

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Figure 4 Groundwater nearest potential receptors (2km radius, extract from the Victorian Data Warehouse))

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Figure 5 Surface Water nearest potential receptors

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4 RISK ASSESSMENT

The environmental management goals and objectives for the landfill site are to:

. Comply with the licence conditions; . Comply with the Environment Protection Act 1970 and relevant regulations and State Environment Protection Policies; . Assess the impacts of landfill operations on groundwater, surface water, land, and air. . Prevent off-site discharges of contaminated stormwater, groundwater, offensive odour, nuisance airborne particles and litter; and . Provide monitoring program inputs into the Annual Performance Statement (APS). These goals and objectives have been used to drive the development of the risk assessment scope and methodology. 4.1 Scope and methodology

The risk assessment scope has involved the following activities:

. Consultation with LCC officers to source information, to assist in developing an understanding of the landfill’s history, and to discuss hazards and potential impacts. . Collation of relevant documents and data; . Development of conceptual site model; . Identification of hazards, pathways and receptors; . Adoption of risk analysis matrix. . Development of risk register; . Population of risk register; and . Identification of high and medium risks which are to inform the development of the monitoring program. The conceptual site model is presented in Sections 2 and 3 of this report. This includes a description of the potential receptors and pathways. The hazards or aspects are listed in the risk registers presented in Attachment D and described in Section 4.3.

The risk analysis matrix is described in Section 4.2. This is a qualitative risk assessment matrix which is in general accordance with guidance provided in AS/NZS 31000:2009 Risk Management and EPA Publication 1321.1.

The medium and greater risks (as presented in the risk registers in Appendix D) are tabulated in Section 4.5.

It is noted that the landfill has not been identified as a “Low-Risk landfill” in accordance with Appendix 3 of the EPA Publication 1323.1 as it is underlain by Segment A1 groundwater and receives more than 20 000 T/yr of waste.

The Auditor has reviewed the risk assessment methodology and advised that it is acceptable and adequate to undertake the risk assessment and to prepare the environmental monitoring program.

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4.2 Risk analysis matrix

The level of risk is a combination of the likelihood of a risk event occurring and the consequence if it does. The level of risk posed can be determined from the matrix shown in Table 4.1.

Table 4.1: Qualitative risk assessment matrix

Consequences Likelihood

Almost certain Likely Probable Not likely Rare

Severe V V V V H

Significant V V V H H

Medium V H H M M

Minor H H M L L

Negligible H M L L L

Legend: V = Very High risk, immediate action required H = High risk, management required by senior staff M = Medium risk, specify required risk L = Low risk, manage with standard operating procedure

The qualitative measures of consequence, as listed in Table 4.1 above, are provided in Table 4.2.

Table 4.2 - Qualitative Measures of Consequence/Impact

Rating Indicator Descriptor(1)

Human deaths, operations cause catastrophic off-site impacts, 5 Severe immense financial losses

Extensive human injuries, operations cause substantial off-site 4 Significant impacts, major financial losses

Some health impacts to human, operations cause some external 3 Medium impacts, large financial loss

First aid treatment, operations cause some minimal off-site 2 Minor impacts, small financial loss

Operations cause no injuries, negligible off-site impacts, negligible 1 Negligible financial loss

(1)Assessment of potential on-site and off-site operational impacts has considered all relevant beneficial uses

The qualitative measures of likelihood, as listed in Table 4.1 above, are provided in Table 4.3.

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Table 4.3: Qualitative Measures of Likelihood

Rating Indicator Description Frequency

Multiple incidents have been Is expected to occur almost all of 5 Almost certain recorded the time

Several incidents have been Is expected to occur most of the 4 Likely recorded time

3 Probable Some incidents have been recorded Might occur

2 Unlikely Few incidents have been recorded Might occur but not expected to

No recorded or known incidents Only expected to occur under 1 Rare atypical conditions

4.3 Risk register

Two risk registers have been prepared for the risk assessment of the Hyland Highway landfill. These are:

. Attachment D-1: Landfill Risk Assessment Register . Attachment D-2: Landfill Compliance Risk Register 4.3.1 Landfill risk assessment register

The Landfill Risk Assessment Register presented in Attachment D-1 documents the hazards and environmental aspects of the landfill’s activities, their potential impact and an analysis of the level of risk posed.

For each of the identified risks the register identifies:

. Location (where the risk is likely to come from); . Environment category (the element the risk relates to, e.g. air, water, land); . Aspects (the environmental aspects and hazards of the landfill site); . Description of potential impacts (description of impacts should the risk occur); . Pathways for risk; (factors influencing the likelihood of the risk occurring); . Existing controls (controls in place to prevent or mitigate the risk); . Licence conditions (relevant licence conditions applicable to the risk); . Likelihood (likelihood of the risk occurring; . Consequence (consequence if the risk should occur (including the impact on receptors); . Risk (risk level based on likelihood and consequence); and . Comments.

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4.3.2 Landfill compliance risk register

The Landfill Compliance Risk Register (Attachment D-2) assesses the risks associated with landfill site operational activities environmental hazards as they relate to licence requirements and the criteria presented in the Landfill BPEM. 4.3.3 Beneficial uses applicable to the registers

The beneficial uses to be protected for groundwater and surface waters are described in Sections 3.4.6 and 3.5.3 respectively.

The SEPP (Control of Noise from Commerce, Industry and Trade No. N1) noise related beneficial use is as follows:

“The normal domestic and recreational activities including, in particular, sleep in the night period”.

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. The SEPP (Prevention and Management of Contaminated Land) beneficial uses are based upon the agriculture segment. They are as follows:

. Modified ecosystems; . Human health; . Buildings & structures; . Aesthetics; and . Production of food flora and fibre. 4.4 Groundwater risk assessment by GHD

Southern Rural Water (SRW) addressed a request to GHD to clarify the potential impact on the landfill on groundwater in the Haunted Hills Formation and Morwell Formation if groundwater depressurisation ceases and groundwater in the two shallow aquifers returns to pre-coal mining levels. In response, GHD undertook Hydrologic Evaluation of Landfill Performance (HELP) and POLLUTE modelling. The HELP models is used to estimate water balances for municipal landfills, while the POLLUTE model estimates the migration of contamination.

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HELP modelling demonstrated that the BPEM cap designed for the landfill will result in the majority of precipitation being removed by evapotranspiration and runoff before it infiltrates the landfill cap, and that less than 0.01% of incident rainfall is predicted to infiltrate the cap. The predicted seepage rate through the base liner was zero at year 20, but over the long term, diffusion and seepage would be expected to occur. The POLLUTE modelling predicted chloride concentration exiting the base liners for the landfill would be approximately 480 mg/L after a 500 year simulation time. The POLLUTE model predicted chloride concentrations in groundwater after mixing with leachate would be approximately zero for the landfill. The conclusions from the geological and hydrogeological investigations, and the HELP and POLLUTE modelling were that the landfill site complies with SEPP (Groundwaters of Victoria) and clauses 13 & 16 of the Waste Management Policy (Siting, Design and Management of Landfills).

Based on the outcomes of the modelling GHD provided the following comments:

“Based on the historical pre mining hydrogeological information the Haunted Hills aquifer is considered highly unlikely to become saturated in the event of mining related depressurisation ceasing. The relatively thin nature of the aquifer and location of the site on the elevated margin of the Latrobe Valley where greater depths to groundwater would be anticipated, are likely to be the primary reasons why the Haunted Hills aquifer was unsaturated.

The historical records show the Morwell Formation ranged from unsaturated at the north west of the site to groundwater being struck in the basal sands at depths of 45 and 68 m and therefore these conditions were taken into consideration for the groundwater modelling.

A conservative approach to the groundwater modelling was adopted which set the depth to the aquifer at 43 m based on the highest aquifer depth recorded from both the recent on site drilling and historical SEC drillers logs. Therefore it is considered that the groundwater modelling as presented in the hydrogeological assessment is more conservative than the current conditions and is representative of pre mining conditions. The hydraulic conductivity assigned for the 43 m of strata overlying the uppermost aquifer was based on the lithological descriptions of the variable geological strata across the site and is independent of groundwater extraction related depressurisation and considered to be relevant to represent the conservative pre mining hydrogeological conditions” 4.5 Initial screening of off-site landfill gas risks

The methodology developed and applied to the initial screening of off-site LFG risks is based on that provided in Appendix 2 of EPA Publication 1323.1. In summary, this follows a systematic process of identifying the risks, as well as their likelihood and significance, resulting in a qualitative assessment of consequences, as outlined in Tables 4.1 to 4.3 above. The process includes:

 Development of a conceptual site model (CSM) of the landfill and its surrounds, including evaluation of potential sources, pathways, receptors and controls;

 Identification of hazards and risk screening; and

 Simple Quantitative Risk Assessment.

Section 2 (Landfill Description and Activities) and Section 3 (Regional Physical Features) of this report provide the basis for the conceptual site model.

Potential pathways and mechanisms for LFG to migrate from landfills and then have an impact on air quality and/or occupational health and safety as diffuse flow from the soil Risk Assessment and Environmental Monitoring Program 2011—Hyland Highway Landfill Page 26 Hyder Consulting Pty Ltd-ABN 76 104 485 289 aa003889 - latrobe landfill ra and mp - hyland highway (final v2)

surface, or to enter structures (underground or above surface), are summarised in the following table.

Table 4.4: Pathways for LFG Migration

Exposure Route Comment

Soil zones allowing LFG to LFG may migrate laterally and/or horizontally and may migrate from site and possibly the accumulate in sub-surface utility structures, garden sheds or ground surface other small structures placed directly on the soil or in basements installed below the soil

Tension cracks through the cap These are a common feature of landfill caps and should be of the landfill or damage to the anticipated at most landfill sites cap

Cracks or unsealed penetrations it should be assumed that such cracks occur unless in concrete slabs of buildings demonstrated otherwise

Vertical structures in the ground These structures would need to be hollow (or have an open (flagpoles, fence posts, lighting annulus) to allow the passage of LFG and reach a depth where towers, electrical poles, etc.) sufficiently permeable soils with high LFG are penetrated

Sub-surface migration through LFG often collects in the permeable backfill around such the soil or along underground structures in the vicinity of landfills, which then act as conduits service pits, trenches and for LFG migration. The significance of this depends on the roadways. presence of preferred flow paths (e.g. permeable soils or tension cracks discharging at high rates to the surface)

LFG investigation bores These are a pathway for LFG migration to surface if their caps are removed or destroyed, or the annulus is not sealed

Construction works involving Construction / excavation works may remove surface cover/cap excavation or boring and/or expose waste material providing pathway for migration of LFG.

Direct release to atmosphere Lateral emissions from the landfill through the surface cap and boundaries result from pressure differentials.

The most likely pathways for LFG to migrate from the landfill site are considered to be:

 Soil zones allowing LFG to migrate from site and possibly the ground surface;

 Sub-surface migration through the soil or along underground service pits, trenches and roadways; and

 Construction works involving excavation or boring.

Based on the understanding of the conceptual site model for the Hyland Highway landfill and the potential pathways/exposure routes, the risk of off-site landfill gas migration to the nearest sensitive receptors (residential and commercial/industrial structures) is assessed to be low, primarily based on the following key issues:

. The landfill is engineered and lined (base and sides) to meet Landfill BPEM requirements thus minimising the potential for lateral migration off-site; . The landfill active cell (combined Cell1/2) has interim cover which helps minimise odour but also allows landfill gas to preferentially permeate through the cover rather than migrate laterally off-site; . The proximity of nearest residences is more than 1 km from the site;

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. The proximity of nearest commercial/industrial buildings is more than 600 m to the north-west (Loy Yang motor cross track) and 3.5 km to the northwest of the site (Loy Yang power station); . Both the residential and commercial/industrial premises exceed the recommended buffer distance of 500 m for “buildings or structures” specified in Table 5.2 of the Landfill BPEM for Type 2 landfills; . Whilst the landfill accepts a significant annual volume of waste (45 000 T/year), the landfill is currently less than three years old; and . There have been no proven incidents of off-site odour associated with the landfill. 4.6 Medium and greater risks

Risks identified in the two risk registers that are considered to have a risk rating of medium and greater are presented in Table 4.5.

Table 4.5: Summary of medium and high risk ratings

Environmental Aspect Pathways for risk Relevant Risk Category licence Rating condition

Water - Leachate Seepage of leachate DL1, L4, L6 Low to groundwater seepage through landfill floor. medium

Water - Seepage of Seepage of contaminated DL1, L6 Low to groundwater contaminated stormwater through landfill medium stormwater floor and other areas.

Water – surface Leachate Seepage of leachate DL1, L4, L6 Low to water seepage through landfill floor and/or medium along conduits.

Water - surface Overflow of Failure to maintain DL1, L4 Medium water leachate and/or adequate freeboard in to High stormwater leachate and/or stormwater dams dams. Excessive leachate generation. Storm event.

The risks presented in Table 4.5 inform the environmental monitoring program (Section 5) and assist in targeting management actions to reduce the risk. The management actions involve:

. Checking existing control measures for effectiveness; . Updating existing controls to make them more effective; and . Incorporating and implementing new control measures to prevent or lower the level of risk.

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5 MONITORING PROGRAM

This section details the actions, responsibilities and timeframes of the monitoring program. It includes the following elements:

1. Monitoring objectives; 2. Review of the former monitoring program; 3. Description of local environment and activities; 4. Monitoring locations; 5. Appropriate indicators and trigger levels; 6. Sampling and inspection frequency; 7. Sampling procedures and quality assurance; 8. Reporting; 9. Future reviews; and 10. Section 53V Environmental Audit program. The LCC, as the licence holder, is responsible for ensuring the monitoring program is implemented. The Site Manager has day to day responsibility for monitoring. He/she reports to LCC’s Landfill Services Co-ordinator who is authorised on behalf of the LCC to ensure that the monitoring is undertaken in accordance with this program. 5.1 Monitoring objectives

The monitoring program objectives are to:

. Confirm baseline groundwater conditions; . Monitor the environmental impacts of the landfill operations; . Assess whether the maximum leachate head above the lowest point of the drainage layers in open cells does not exceed 0.3 m; . Determine and demonstrate compliance with licence conditions; and . Assess the effectiveness of management actions or process controls. These objectives are based on the outcomes of the risk analysis so that fit-for-purpose data are collected that will enable the licence holder and EPA to determine compliance with the licence. The risk ratings arising out of the risk assessment are presented in Attachment D and Section 4.3. 5.2 Review of the former monitoring program 5.2.1 Groundwater monitoring

GHD 2007a, “Report in support of Works Approval Application”, indicated that groundwater would be sampled quarterly.

Condition 3.8 of the former EPA Waste Discharge Licence No. LS65990 specified at least four groundwater monitoring bores at the landfill site. Three groundwater monitoring bores (BH1 to BH3) were installed at the landfill site in 2009, with an additional bore (BH4) installed in June 2011.

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The bores installed during 2009 were sampled at least once annually before approval by EPA of a monitoring program required by the new format EPA Licence. Bore BH4 has not yet been sampled. The bore locations (approximate) and aquifers monitored by these bores are listed in Table 5.1 and shown in Figure 6. Table 5.1 also includes information regarding bore screening and water levels measured during 2009-2010 (BH1 to BH3) and 2011 (BH4).

Table 5.1: Monitoring bore summary

Bore Location Formation Screened Bentonite ToC level Standing ID Monitored interval Seal (mAHD) water (mBGS) (mBGS) level (mAHD)

BH1 South-western corner, Early Tertiary 47-66 43-46 112 44.96- and near the leachate 45.16 pond (69 m deep)

BH2 Southern boundary of Early Tertiary 59-72 55-58 118.5 Dry the landfill, near the south eastern corner of Cell 1 (74 m deep)

BH3 Northern boundary Early Tertiary 49-73 45-48 141.4 96.37- (69.7 m deep) 96.59

BH4 Southern boundary of Upper Tertiary 17-20.6 15.5-16 120.6 101.0 the landfill, near the (Haunted Hills south eastern corner of Formation) Cell 1 (20.7 m deep)

The initial sampling round was carried out by Meinhardt following the installation of the groundwater bores to indicate the quality of the groundwater. Thiess Services were then engaged by LCC to undertake subsequent groundwater monitoring.

According to Meinhardt 2010 report, groundwater bore BH1 was not sampled by Thiess Services as they reported the water to be below the screen level. Groundwater bore BH2 was observed to be dry during all sampling periods, therefore, sampling from this bore was not possible. During the most recent sampling round in 2010 it was noted that bore BH3 was possibly bent and sampling was not possible.

During the landfill site visit on 19 April 2011, it was noted that the BH1 surface casing and cap was damaged and BH2 could not be found, possibly as it was covered by sediment and/or water. However, LCC advised that BH2 is visible under normal conditions.

Groundwater sampling was undertaken by Meinhardt in 2010 to determine compliance with the adopted groundwater guidelines and parameters. The exceedances observed during the sampling are shown in Table 5.2. Standing water levels in the bores are shown in Table 5.1.

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Figure 6 Current Monitoring Map

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Meinhardt (2010) concluded that the exceedances and changes in groundwater observed on the landfill site were not due to leachate from the Hyland Highway landfill as the groundwater is at significant depth and the engineered barriers in the cells and leachate pond would have prevented leachate migration to the groundwater. Additionally, the presence of a coal layer above the water table and the numerous clay layers in the soil profile would mean that leachate could not have permeated the groundwater in the 12 months between when the cells opened and the sampling was undertaken. Hence the exceedances are regarded as representative of the background groundwater conditions only.

Table 5.2 - Groundwater criteria exceedances (2010)

Analyte Bore ID Concentration Criteria Criteria Source (mg/L) (mg/L)

Ammonia BH3 <0.01-0.06 0.05 Ecosystems – Freshwater 95% species (as N) protection (ANZECC & ARMCANZ 2000)

0.01 Recreation (ANZECC & ARMCANZ 2000)

Iron BH1 0.98 0.3 Drinking (NHMRC & NRMMC 2004)

0.3 Recreation (ANZECC & ARMCANZ 2000)

0.2 Irrigation (ANZECC & ARMCANZ 2000)

pH BH3 4.03 – 5.3 6.5 – 8.5 Drinking (NHMRC & NRMMC 2004)

6.5- 8.0 Ecosystems – Freshwater 95% species protection (ANZECC & ARMCANZ 2000)

BH1 5.02 6.5 – 8.5 Recreation (ANZECC & ARMCANZ 2000)

4.9 – 9.0 Irrigation (ANZECC & ARMCANZ 2000)

8.0 – 10.0 Industrial (ANZECC, 1992)

5.2.2 Leachate

GHD 2007a, “Report in support of Works Approval Application”, indicated that leachate would be sampled quarterly.

The older format EPA licence required leachate levels from the leachate collection sumps to be measured relative to ground level and referenced to Australian Height Data (AHD) on each occasion that groundwater was sampled.

Based on Meinhardt 2010, one round of leachate sampling has been carried out to test the landfill leachate, pre-treatment and post Reverse Osmosis (RO) treatment. 5.2.3 Surface Water

GHD 2007a, “Report in support of Works Approval Application”, indicated that surface water at Traralgon Creek would be sampled annually, with the first suite of samples to be taken before any landfilling activities are undertaken; to ensure a complete background set of data is obtained.

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Meinhardt 2010 conducted a search of the Victorian Water Resources database which showed that a number of physical and chemical parameters are available for Traralgon Creek for years 2005 to 2007 which were measured upstream (i.e., to the south) of the landfill. No surface water testing is being undertaken downstream (i.e., to the north) of the landfill. Some water flow measurements were taken between 1997 and 1999 for the Loy Yang outfall to Traralgon Creek indicating discharges from the power station operations.

No off-site surface water monitoring has been undertaken during the annual audits of the Hyland Highway landfill. 5.2.4 Gas monitoring

There is no landfill gas monitoring conducted at the landfill site. 5.3 Description of local environment and activities

The local environment at and surrounding the landfill is described in Section 3 of this report. The landfill design, construction and current operation are described in Section 2. 5.4 Monitoring locations

This section describes the monitoring locations that will be used for monitoring of groundwater, surface water, leachate, landfill gas and other parameters. These locations are specific for the monitoring of Cell1/2. Further monitoring may be required for future cells.

The location of all fixed monitoring points is shown in Figure 7. 5.4.1 Groundwater

The following groundwater monitoring shall be adopted:

. Inspect and confirm the functional status of all existing groundwater monitoring bores for water level measurement and sampling; . Maintain existing groundwater monitoring bores, where these are functional; . Repair all damaged bores if possible to return them to functional status; . Decommission and redrill all dry or irreparably damaged bores, with screening limited to a single aquifer formation (the aquifer formations applicable to each bore are shown in Table 5.1); and . Survey of all groundwater monitoring bores shall be undertaken to establish coordinates (easting and northing) and the relative level of the ground surface and top of casing measured to Australian Height Datum (AHD) All redrilled monitoring bores shall be installed to a depth such that groundwater is intercepted in the applicable aquifer formation (see Table 5.1), and that the intercepted groundwater is at least 3 m above the top of the screen.

The frequency of sampling is presented in Section 5.6.

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Figure 7 Proposed monitoring network

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5.4.2 Surface water

The following surface water monitoring shall be adopted:

. Stormwater (secondary) dam; and . Traralgon Creek (upstream), approximately 900 m to the south-west of the landfill, at the closest safely accessible location to the extrapolated intersection of Traralgon Creek Road and Callignee South Road (refer Figure 7); and . Traralgon Creek (downstream), approximately 1 200 m to the west of the landfill, at the closest safely accessible location to the extrapolated intersection of Traralgon Creek Road and the site access road which forms the northern boundary of the landfill site (refer Figure 7). Sample point markers shall be established for each surface water sample location, including GPS or survey reference.

The frequency of sampling is presented in Section 5.6. 5.4.3 Leachate

With reference to EPA Publication 1323.1 Landfill Licensing Guidelines, the maximum leachate head above the lowest point of the drainage layer in open cells is not to exceed 0.3 m.

It is noted that the current (amended) EPA Licence does not specify a requirement for the maximum leachate head to be 1.5 metres below the groundwater table.

The following leachate monitoring shall be adopted:

. The leachate pond shall be sampled; . A water level indicator shall be installed in the deepest point of the leachate pond and calibrated to mAHD; . The level of the leachate pond shall be measured in mAHD; . One vibrating wire piezometer (VWP) shall be installed at or as close as practicable to the lowest point of each active cell to monitor the head of leachate within the waste mass; . The leachate levels as read from the piezometers shall be measured in mAHD; . The level of the lowest point of the drainage layer (top of liner) at the leachate sump shall be surveyed to AHD; and . The volume of leachate pumped from each of the primary leachate collection layer and the secondary leachate collection layer to the leachate pond shall be separately recorded (by use of flow meters). Sample point markers shall be established for the leachate sample locations, including GPS or survey reference.

The frequency of sampling is presented in Section 5.6. 5.4.4 Landfill gas

The interim cap on Cells 1 and 2 is comprised of a final daily cover with material sourced on site.

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Given the best practice landfill cell (base and side) lining systems, the relatively short waste deposition period (since June 2009), and the sparse nature and significant buffer distances to the nearest sensitive receptors (nearest residential premises >1 km), no landfill gas monitoring or infrastructure is proposed for the site at this stage.

LCC shall undertake preliminary gas monitoring and periodic site inspections when the landfill cap is completed for Cell1/2, and actions will be taken to achieve greenhouse gas off‐setting. 5.4.5 Other (visual inspections)

Visual inspections (and corresponding records) will be undertaken to determine:

. Presence of pathways for off-site movement of contaminated stormwater from uncapped landfill surfaces (around perimeter of the premises); . Any significant changes in surface cover (e.g. erosion, denuded grass cover, impacted vegetation, etc); and . Spillages (fuel/chemical storages or refuelling and in areas where mobile equipment is working). 5.5 Indicators and triggers

Indicators have been developed following consideration of:

. Historical indicators; . An indicator’s responsiveness to management actions and systematic controls; . Potential impact at receptors; . Factors in the receiving environment that have the potential to confuse the data; . Cost-effective indicators for monitoring the priority risks. 5.5.1 Groundwater, leachate and surface water

The groundwater, leachate and surface water indicators, with trigger levels, are presented in Table 5.4. The trigger levels are consistent with the SEPP (Groundwaters of Victoria) water quality objectives and are based upon the Segment A1 beneficial uses. In addition, groundwater, leachate and surface water shall be monitored for total petroleum hydrocarbons (TPH) and benzene, toluene, ethylene and xylene (BTEX).

It is understood that the Hyland Highway landfill lies outside the Schedule F3 Gippsland Lakes and Catchment segment areas defined in SEPP Waters of Victoria. As such, the “General Surface Waters” indicators and objectives outlined in the SEPP Waters of Victoria are understood to apply and are considered consistent with the key indicators listed below.

The ANZECC (2000) Ecosystem Freshwater criteria will act as preliminary surface water triggers given that:

 the aquatic ecosystem is considered to be slightly to moderately modified,

 there are no surface water bodies within 1 km of the site which are used to supply water for drinking water purposes; and

 beneficial uses include human consumption after appropriate treatment.

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Table 5.4: Groundwater, leachate and surface water indicators and triggers

Indicator Unit Australian ANZECC ANZECC ANZECC Drinking (2000) (2000) (2000) Water Ecosystem Agriculture Stock Guidelines Fresh Water Parks and watering (2004) (90%) Gardens

Field parameters

Temperature ºC

EC µS

pH -

redox potential mV

Dissolved oxygen %

Laboratory parameters

pH - 6.0-8.5 6.0-8.5

total dissolved solids mg/L 500 2 000

ammonia nitrogen mg/L 0.5(A)

nitrate as N mg/L 50 0.16 90

bicarbonate mg/L - (as bicarbonate)

Chloride mg/L 250(A)

Sulphate mg/L 500 2 000

Sodium mg/L 180(A)

potassium mg/L -

calcium mg/L - 1 000

magnesium mg/L - 2 000

total iron mg/L 0.3(A) 1 0.2

manganese mg/L 0.5 1.9 0.2

total organic carbon mg/L -

A – Aesthetic guideline limit only

The groundwater triggers from the Australian Drinking Water Guidelines in Table 5.4 only apply to the Early Tertiary aquifer. 5.5.2 Landfill gas

No monitoring requirements for landfill gas are proposed at this stage.

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5.5.3 Non-analytical indicators and triggers

Landfill surface Visual indicators of possible shift of groundwater, surface water and litter related risks are:

. Erosion; . Waste spillage; . Oil or fuel spills; . Defined stormwater channels with high sediment loads; and . Nearby waterlogging. Registers Incident register and complaints register will be established and maintained. Triggers The trigger for action and/or review of non-analytical indicators, such as landfill site inspections will be observations of activities/incidences that result in licence non- compliances or unacceptable risks to the environments as outlined in the assessment risk register and the compliance risk register. 5.6 Sampling and inspection frequency

The risk profile of a landfill influences the intensity of monitoring, the implementation period for new monitoring infrastructure and the frequency of monitoring.

Table 5.5 has been used to guide the monitoring programs sampling and inspection frequency.

Table 5.5: Risk - Sampling and inspection frequency matrix

Risk Typical timing for Monitoring Implications Ranking implementation

Very High Structural and operation changes required Immediate

High Extensive monitoring with high frequency, six monthly 3 months auditor review

Medium Moderate monitoring network with quarterly to annual 12 months frequency, annual auditor review

Low Baseline monitoring network with annual frequency, every 2 to 3 years two to three year auditor review

Very Low Monitoring not required, Auditor review not required. N/A

As the monitoring infrastructure relates to risks classified as medium or higher, any new infrastructure (including repairs to existing infrastructure) shall be installed by 30 June 2012.

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The sampling and inspection frequency presented in Table 5.6 below considers the landfill age, past monitoring results, data gaps, and the risk profile of the landfill, including the significant buffer distance to residential and other sensitive receptors. The monitoring frequency shall be reviewed at the time of the next s53V environmental audit. The frequency of auditing is discussed in Section 5.10.

Whilst the risk assessment has not identified any high risk issues (with the exception of potential for overflow from leachate and/or stormwater ponds), EPA Publication 1323.1 indicates “selection of a half-yearly monitoring frequency must be justified by reference to past monitoring results”, otherwise quarterly monitoring is the default option. In consultation with the auditor, the lack of previous monitoring data has indicated that quarterly monitoring is warranted in the short term. This will be reviewed at the time of each Section 53V audit.

Table 5.6: Sampling and inspection frequency

Indicator Monitoring Point Frequency

Groundwater level Groundwater monitoring bores Quarterly (Nov, Feb, May (BH1 to BH4) & Aug)

Groundwater sampling Groundwater monitoring bores Quarterly (Nov, Feb, May (BH1 to BH4) & Aug)

Surface water Stormwater dam on-site (SW1), Quarterly (Nov, Feb, May sampling Traralgon Creek (upstream) (SW2), & Aug) Traralgon Creek (downstream) (SW3)

Leachate level Lowest point of each cell (vibrating wire Quarterly (Nov, Feb, May piezometers) & Aug)

Leachate sampling Leachate pond Quarterly (Nov, Feb, May & Aug)

Leachate volume Volume of leachate conveyed from the Weekly primary leachate collection layer to the leachate pond; Volume of leachate conveyed from the secondary leachate collection layer to the leachate pond

Landfill site General landfill site extent Monthly inspections

When incident reported

When complaint reported

5.7 Sampling procedures and quality assurance 5.7.1 Groundwater, leachate and surface water

Groundwater, leachate and surface water sampling and quality assurance shall be undertaken in accordance with the following guidelines and standards:

. Groundwater Sampling Guidelines, Publication 669 (EPA; 2000)

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. Sampling and Analysis of Waters, Wastewaters, Soils and Wastes, Publication No. IWRG701 (EPA; 2009); . Australian/New Zealand Standard: Water Quality – Sampling – Part 11: Guidance on Sampling of Groundwaters, AS/NZS 5667.11-1998 (Standards Australia & Standards New Zealand 1998). An outline of the water sampling procedures is presented in Table 5.7.

Table 5.7: Outline of Water Sampling QA/QC procedures

Task Comment

Personnel Sampling to be undertaken by qualified, experienced personnel.

Calibration All equipment used should be calibrated prior to use.

Recording All field records and calibrations should be recorded on field data sheets.

Bore gauging Monitoring bores should be gauged for level prior to purging/sampling

Bore purging Monitoring bores should be purged until field parameters (electrical conductivity, pH and temperature) stabilise.

Bore sampling Sampling should be conducted using a low flow Down hole Submersible Pump. Pumping should continue until chemical equilibrium is reached in accordance with the EPA Publication 669 requirements. This method requires that only small volumes of water, typically at a pumping rate of between 0.1 L/min to 0.5 L/min.

QA sample QA/QC samples should be collected in accordance with the minimum collection requirements of the relevant sampling guidelines for each sampling episode. These should include: field blank; equipment / rinsate blank blind replicates (inter and intra-laboratory); and calculation of Relative Percent Differences (RPD). Data validation checks should also be undertaken

Decontamination Sampling equipment should be decontaminated and rinsed with deionised water Procedure between bores.

Sample Samples should be filtered and preserved while on site and in transit to the Preservation laboratory.

Chain of Custody Each sample designated for analysis should be recorded on a Chain-of-Custody Forms form which details: name of the person transferring the samples; name of person receiving the samples, e.g. laboratory staff; time and date the samples were taken; time and date the samples were received; analytes to be determined.

Sample Holding Laboratory specified sample holding times should be adhered to. Times

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Task Comment

Laboratory analysis All should be undertaken by a National Association of Testing Authority (NATA) accredited laboratory for the analysis of indicators listed in Section 5.5 above. Laboratory analytical limits of reporting (LOR) shall be such that they meet or better the trigger levels used to assess impacts under the SEPP Groundwaters of Victoria (groundwater samples) and SEPP Waters of Victoria (surface water samples).

5.7.2 Landfill gas

Landfill gas sampling is not proposed at this stage. 5.8 Reporting

All monitoring data shall be recorded in a spreadsheet after each sampling event.

The results of the monitoring must be reported in an annual (July to June) landfill monitoring report which presents the data, plots trends and assesses whether the triggers have been exceeded. This report shall be submitted to the EPA appointed environmental auditor by 31 July each year.

In addition, a six-monthly report to 31 December 2012 must be reported by 30 January 2013. It shall be submitted by EGSC to the EPA appointed environmental auditor by 4 February 2013.

This report should include an appendix with all groundwater monitoring bore construction details and lithological logs as well as surveyed Map Grid of Australia (MGA) ground surface and Top of Casing AHD data. 5.9 Future reviews

The risk assessment and monitoring program shall be reviewed following the next full year of monitoring data, including a review of environmental audit frequency based on any potential adverse environmental impact identified through the monitoring results and/or landfill site observations. 5.10 Environmental audit frequency

As part of the monitoring program a Section 53V audit program has been established.

The first Section 53V audit to be conducted under this monitoring program must cover the period up to 31 December 2012 and shall be submitted by 31 March 2013.

An environmental audit frequency of every two years is proposed given the risk profile described in Section 4 of this report. This frequency should be reviewed as part of the first Section 53V audit.

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6 REFERENCES

ANZECC (Australian and New Zealand Environment Council) (2000) Australian Water Quality Guidelines for Fresh and Marine Water.

ANZECC & ARMCANZ (Agriculture and Resource Management Council of Australia and New Zealand) (2000), Australian and New Zealand Guidelines for Fresh and Marine Water Quality.

Biosis (2006), “Flora and fauna assessment of a potential landfill site at Callignee South, Victoria “, November 2006.

Birch, W. D. (ed), 2003. "Geology of Victoria". Geological Society of Australia Special Publication 23. Geological Society of Australia (Victorian Division)”, Groundwater section by J. Leonard

Department of Primary Industries Victoria, “Topographic map – Traralgon region”.

Department of Primary Industries Victoria (2008) “Victorian Resources Online: La Trobe Valley Tertiary Brown Coal Deposits”. http://vro.dpi.vic.gov.au/dpi/vro/wgregn.nsf/pages/wg_lf_sig_moe13

EPA (2000), “Groundwater Sampling Guidelines”, Publication 669.

EPA (2008), “Latrobe City Council, EPA Works Approval WA61581”, issued on 4 March 2008 (for the ‘construction of a landfill on Callignee South Road, Loy Yang’).

EPA (2009), “Sampling and Analysis of Waters, Wastewaters, Soils and Wastes”, Publication IWRG701.

EPA (2009), “Latrobe City Council, EPA Waste Discharge Licence LS65990”, issued on 4 June 2009.

EPA (2010a), “Licensing Assessment Guidelines – Guidelines for Using a Risk Assessment Approach to Assess Compliance with Licence Conditions”, Publication No. 1321.1, May 2010.

EPA (2010b), “Landfill Licensing Guidelines”, Publication 1323.1, June 2010.

EPA (2010c) “Best Practice Environmental Management Siting, Design, Operation and Rehabilitation of Landfills”, Publication 788.1.

EPA (2010d), “Latrobe City Council, EPA Licence LS65990”, for Hyland Highway landfill issued on 4 June 2009 and last amended on 30 June 2010.

EPA (2010e) “Best Practice Environmental Management Siting, Design, Operation and Rehabilitation of Landfills, Publication 788.1, September 2010.

EPA (2010f), “Latrobe City Council, EPA Notice to Amend Works Approval WA61581”, issued on 4 October 2010.

Golder Associates (2010) “Environmental Audit Report: Performance of Landfill Liner and Leachate Collection Systems, Hyland Highway Landfill, Callignee”; Report Number: 097615024 006 R Rev1. Accessed at: www.latrobe.vic.gov.au/WebFiles/Landfill/642332_a%20Final%20Audit%20Report.pdf

GHD (2007a), “Report in support of Works Approval Application”

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GHD (2007b), “Letter report in response to SRW request for additional information on groundwater modelling”, April 2007.

GHD (2007c), “Report for Proposed Callignee Landfill – Draft Construction Quality Assurance Plan”, January 2007.

GHD (2007d), “Report for Proposed Callignee Landfill, Assessment of Works Approval Application” (January 2007).

GHD (2007e), “Report for Proposed Callignee Landfill - Detailed Design Calculation for Leachate Pond Size and Liner Performance”, April 2007.

GHD (2007f), “Report for Proposed Callignee South Road Landfill, Documentation Supporting Works Approval Application” (January 2007).

GHD (2007g), “Report for Alternative Landfill Cell Design Options, Callignee South Road Landfill”, November 2007.

GHD (2007h), “Report for Callignee Landfill Soil Investigation (Soil Analysis)”, May 2007.

GHD (2007i), “Draft Report for Proposed Landfill - Callignee, Documentation Supporting Works Approval Application”, January 2007.

GHD (2007j), “Report for Proposed Callignee South Road Landfill, Documentation Supporting Works Approval Application”, January 2007.

GHD (2009), “Verification of Cell 1 & 2 Liner and Leachate Pond Construction - Callignee South Road Landfill, Loy Yang, Victoria; Environmental Audit”, May 2009.

Golder Associates (2010), “Environmental Audit Report - Performance of Landfill Liner and Leachate Collection Systems, Hyland Highway Landfill, Callignee”, June 2010.

Government of Victoria (1988), “State Environment Protection Policy (Waters of Victoria)”.

Government of Victoria (1989), “State Environment Protection Policy (Control of Noise from Commerce, Industry and Trade No. N1).

Government of Victoria (1997), “State Environment Protection Policy (Groundwaters of Victoria)”.

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

Latrobe City Council (2010), “Annual Performance Statement 2009-2010”.

Latrobe City Council (2011), “Annual Performance Statement 2010-2011”.

Loy Yang Power (2010) “LYP and Alcoa Joint Media Release: New power contracts create a platform for the future”, 01 March 2010. www.loyyangpower.com.au/documents/nr/2010/LYP_Alcoa_joint_media_release.pdf

Meinhardt (2010),”Hyland Highway Landfill EPA Licence Compliance”, prepared for Latrobe City Council (December 2010).

Meinhardt (2011), “Hyland Highway Landfill Groundwater Bore Installation (draft report)”, August 2011.

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Standards Australia & Standards New Zealand (1998), “Australian/New Zealand Standard: Water Quality – Sampling – Part 11: Guidance on Sampling of Groundwaters”, AS/NZS 5667.11-1998.

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ATTACHMENT A

SITE PHOTOGRAPHS

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