IR-T04 Decision Report Template · 2020. 6. 9. · L8730/2013/1 IR-T04 Decision Report Template...

L8730/2013/1

IR-T04 Decision Report Template v2.0 (July 2017) i

Review of Existing Premises

Division 3, Part V Environmental Protection Act 1986

Licence Number L8730/2013/1

Applicant

Fremantle Plumbing Service Pty Ltd

ACN 008 737 068

File Number 2013/000474

Premises Fremantle Plumbing Services

107 Garling Street O’CONNOR WA 6163

Legal description -

Lot 138 on Deposited Plan 6759

Certificate of Title Volume 1276 Folio 970

Date of Report 29 May 2020

Status of Report Final

This licence is granted to the licence holder, subject to the attached conditions, on 8 June 2020, by:

Melissa Chamberlain A/MANAGER WASTE INDUSTRIES REGULATORY SERVICES

An officer delegated under section 20 of the Environmental Protection Act 1986 (WA)

Decision Report

2

Licence number: L8730/2013/1

IR-T04 Decision Report Template v2.0 (July 2017)

Table of Contents

1. Definitions of terms and acronyms .................................................................. 5

2. Purpose and scope of assessment .................................................................. 7

3. Background ........................................................................................................ 7

3.1 Exclusions to the Premises .................................................................................... 7

4. Location and siting ............................................................................................ 7

4.1 Siting context ......................................................................................................... 7

4.2 Residential and sensitive Premises ........................................................................ 8

4.3 Specified ecosystems ............................................................................................ 9

4.4 Groundwater and water sources .......................................................................... 10

4.5 Other site characteristics ...................................................................................... 10

4.6 Soil type ............................................................................................................... 10

5. Overview of Premises ...................................................................................... 10

5.1 Operational aspects ............................................................................................. 10

5.2 Infrastructure ........................................................................................................ 12

5.3 Waste acceptance ............................................................................................... 12

5.4 Waste receipt and treatment processes ............................................................... 13

Liquid waste receipt ...................................................................................... 15

Sludge / slurry waste receipt ......................................................................... 16

Liquid waste treatment .................................................................................. 17

Waste disposal process ................................................................................ 23

6. Legislative context ........................................................................................... 24

6.1 Planning Approvals .............................................................................................. 24

6.2 Lease agreement ................................................................................................. 25

6.3 Contaminated sites .............................................................................................. 25

6.4 Trade Waste Permit ............................................................................................. 25

6.5 Part V of the EP Act ............................................................................................. 26

Applicable regulations, standards and guidelines .......................................... 26

Works Approval and Licence history ............................................................. 26

7. Compliance review ........................................................................................... 27

7.1 Waste Acceptance Review................................................................................... 27

7.2 Complaints ........................................................................................................... 28

7.3 Compliance inspections ....................................................................................... 29

7.4 Annual Audit Compliance Reports ........................................................................ 35

7.5 Environmental Protection Notice CEO182/18 ....................................................... 36

7.6 Air Quality Review ................................................................................................ 37

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8. Risk assessment .............................................................................................. 39

8.1 Determination of emission, pathway and receptor ................................................ 39

8.2 Consequence and likelihood of risk events .......................................................... 43

8.3 Acceptability and treatment of Risk Event ............................................................ 44

8.4 Risk Assessment - Odour .................................................................................... 44

General Hazard Characterisation and Impact ............................................... 44

Criteria for assessment ................................................................................. 46

Licence Holder controls................................................................................. 46

Consequence ................................................................................................ 48

Likelihood of consequence ............................................................................ 48

Overall rating ................................................................................................ 48

8.5 Risk Assessment – Noise .................................................................................... 48

General Hazard Characterisation and impact ................................................ 48

Criteria for Assessment ................................................................................. 48


Consequence ................................................................................................ 49


Overall rating ................................................................................................ 49

8.6 Risk Assessment – Liquid waste runoff and fire water run-off impact ................... 49

General hazard characterisation and impact ................................................. 49


Consequence ................................................................................................ 51


Overall rating ................................................................................................ 51

8.7 Risk Assessment – Emissions to air in the event of a fire /explosion .................... 51

General hazard characterisation and impact ................................................. 51

Criteria for assessment ................................................................................. 51


Consequence ................................................................................................ 52


Overall rating ................................................................................................ 52

8.8 Summary of acceptability and treatment of Risk Events ....................................... 53

9. Regulatory controls ......................................................................................... 54

9.1 Waste characterisation ......................................................................................... 55

9.2 Acceptance and throughput restrictions ............................................................... 55

9.3 Waste type restrictions and classification ............................................................. 55

9.4 Waste processing ................................................................................................ 55

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9.5 Infrastructure and equipment ............................................................................... 56

9.6 Operational controls ............................................................................................. 56

9.7 Treated wastewater monitoring ............................................................................ 56

9.8 Reporting requirements ........................................................................................ 56

10. Determination of Licence conditions ............................................................. 57

11. Applicant’s comments ..................................................................................... 57

12. Conclusion ........................................................................................................ 57

Appendix 1: Key documents ................................................................................... 58

Appendix 2: Summary of applicant’s comments on risk assessment and draft conditions ................................................................................................................. 60

Appendix 3: Site plans ............................................................................................. 63

Appendix 4: Copy of Water Corporation Trade Waste Permit .............................. 66

Appendix 5: DER Pollution Response Report ........................................................ 69

Appendix 6: Environmental Protection Notice CEO182/18 ................................... 86

Appendix 7: Odour Remediation Plan .................................................................... 90

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1. Definitions of terms and acronyms

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

Table 1: Definitions

Term Definition

AACR Annual Audit Compliance Report

ACN Australian Company Number

AER Annual Environment Report

AHD Australian Height Datum

Category/ Categories/ Cat.

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

CS Act Contaminated Sites Act 2003 (WA)

Compliance Report

means a report in a format approved by the CEO as presented by the Licence Holder or as specified by the CEO (guidelines and templates may be available on the Department’s website).

Controlled Waste has the definition in Environmental Protection (Controlled Waste) Regulations 2004

CW Regs Environmental Protection (Controlled Waste) Regulations 2004

Decision Report refers to this document.

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

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

DWER Department of Water and Environmental Regulation

EFR Environmental Field Report, which is a means for DWER to advise a person or company that they appear to be in breach of environmental legislation, and request certain actions to be taken by the person or company to rectify the alleged breaches.

EP Act Environmental Protection Act 1986 (WA)

EPN Environmental Protection Notice CEO182/18, issued under s. 65 of the EP Act

EP Regulations Environmental Protection Regulations 1987 (WA)

Existing Licence The Licence issued under Part V, Division 3 of the EP Act and in force

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Term Definition

prior to the commencement of, and during this Review

IBC Intermediate Bulk Containers (1000 litres)

ICMS Incidents and Complaints Management System

Licence Holder Fremantle Plumbing Service Pty Ltd

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

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

Prescribed Premises

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

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

Primary Activities as defined in Schedule 2 of the Revised Licence

Review this Licence review

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

Risk Event As described in Guidance Statement: Risk Assessment

RIWI Act Rights in Water and Irrigation Act 1914

UDR Environmental Protection (Unauthorised Discharges) Regulations 2004 (WA)

Waste Code means the Waste Code assigned to the type of controlled waste for purposes of tracking and reporting as specified in the Department of Environment Regulation ‘Controlled Waste Category List’ (April 2015), as amended from time to time.

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2. Purpose and scope of assessment

The Department of Water and Environment Regulation (DWER) has determined that a risk-based review (Review) of Licence L8730/2013/1 (Licence) is required. The Review was initiated following an investigation of odour complaints emanating from the Premises, and the subsequent issuing of Environmental Protection Notice CEO182/18 (EPN) to Fremantle Plumbing Service Pty Ltd (Licence Holder) on 2 March 2018. The key requirements of the EPN necessitated the Licence Holder to cease operations of waste treatment equipment and processes not authorised under the Licence and prepare an odour remediation plan. The investigation identified that the Premises was likely to be a significant contributor to the odour complaints received.

3. Background

The Premises, located at 107 Garling Street, O’Connor WA 6163, is currently licensed under Part V, Division 3 of the EP Act as a Category 61 Liquid waste facility as defined in Schedule 1 of the Environmental Protection Regulations 1987 (EP Regs) and as outlined in Table 2.

The Licence Holder began liquid waste operations at the Premises in 2013.

Table 2: Prescribed Premises Category in the Existing Licence

Classification of Premises

Description Production or design capacity or throughput

Category 61

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

40,950 tonnes per year

The facility has been listed as a waste facility in DWER’s Controlled Waste Tracking System (CWTS). The listing of a waste facility in the CTWS assists facility occupiers in complying with their obligtaions under the Environmental Protection (Controlled Waste) Regulations 2004 (CW Regs).

3.1 Exclusions to the Premises

Fremantle Plumbing Service also operates a plumbing and tank washing business from the Premises. These activities do not meet the description of a Prescribed Premises category as outlined in Schedule 1 of the EP Regs, nor are they a directly related activity that will give rise to emissions and discharges, therefore they have not been considered in this assessment.

4. Location and siting

4.1 Siting context

The Premises lies within the City of Fremantle and is approximately 5148 m² in area. The site is surrounded by commercial/industrial properties to the south, east and west. The suburb of Willagee a medium-high density residential dwelling is approximately 46 metres north of the site and is within the City of Melville.

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Figure 1: Site location and siting map

4.2 Residential and sensitive Premises

The distances to residential and sensitive receptors are detailed in Table 3.

Table 3: Receptors and distance from activity boundary

Residential and Sensitive Premises Distance from Prescribed Activity

Willagee residential area

(medium-high density residential dwellings)

46 m to the north

Commercial/industrial property Immediately adjacent to the east, west and south

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4.3 Specified ecosystems

The Existing Licence does not authorise any discharges to air, land or water. As a result the Delegated Officer has only considered specified ecosystems within a 1000 m radius of the Premises which may be impacted by fugitive emissions. A review of available geographic information systems (GIS) datasets did not identify any specified ecosystems within this proximity.

The closest specified ecosystem outside of the 1000 m radius as shown in Figure 2, is a Bush Forever site (site 59) approximately 1,100 m to the south followed by a perennial lake approximately 1,200 m east on Le Souef Drive Kardinya (within Frederick Baldwin Park); based on groundwater flow contours for the area this lake is considered to be up-hydraulic gradient of the Premises.

All other identified specified ecosystems lie beyond 2,000 metres from the Premises.

Figure 2: Specified Ecosystems

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4.4 Groundwater and water sources

The distances to groundwater and water sources are shown in Table 4.

Table 4: Groundwater and water sources

Groundwater and water sources

Distance from Prescribed Premises Environmental value

Groundwater Depth to water table is 12.0 metres (relative to ground

level) and 2.0 metres AHD (according to DoW groundwater

atlas)

RIWI Groundwater Act – Perth Groundwater area – within

the Premises boundary (Designated Area under the EP

Act)

The Premises is within a hydraulic catchment for the Swan-

Avon

Groundwater is inferred to flow in a

westerly direction towards the Swan

River

Groundwater salinity 500 – 1000 TDS

mg/L

Groundwater is suitable for use in

domestic irrigation and other non-

potable uses.

Swan river 3,300m to the north-east and 3,700m north-west Conservation category wetland

4.5 Other site characteristics

There are two drainage reserves located 37 m to the east along Landar Street and 48 m north-west of the Premises within Harry Bailey Park.

4.6 Soil type

The Premises is located on Tamala Limestone that typically contains various proportions of quartz sand, fine to medium-grained shell fragments, and minor clayey lenses (McPherson and A. Jones). In the absence of site-specific hydraulic data, default hydraulic conductivity values (K) for limestone and calcarenite has a hydraulic conductivity between 100-1000 (m/d) (Davidson, W.A., 1995, Bulletin 142: Hydrogeology and Groundwater Resources of the Perth Region, Western Australia, Geological Survey of Western Australia.

5. Overview of Premises

5.1 Operational aspects

The Licence Holder operates a liquid waste treatment facility that accepts stores and treats a broad range of bulk and packaged liquid wastes produced by industry and commercial sectors.

The Licence Holder receives mainly the following liquid wastes for treatment: water-based paint washings; waste oil and emulsions from the automotive industry; engine coolants from automotive and mining industries; wetting agents from composting processes; galvanizing liquid wastes (acids); concrete tuck and batching plant wash down (alkalis); and low strength industrial wash water (mainly car and truck wash water and contaminated industrial wash water); and drilling mud.

The treatment process employed on-site involves the operation of an oily water separator, electro-coagulation and ozone treatment with treated wastewater disposed of directly to sewer. Precipitates from the various treatment processes are solidified with sawdust to a spadeable form, which is subsequently removed from the Premises for landfill disposal.

Figure 3 shows the main operational areas of the Premises.

The Licence Holder has a Trade Waste Permit with Water Corporation to discharge treated

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wastewater to sewer (see section 6.4 and Appendix 4).

A review of waste acceptance and waste treatment processes/methods is presented in section 5.4.

Figure 3: Main operational areas

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5.2 Infrastructure

The liquid waste facility infrastructure as it relates to Category 61 activities is detailed in Table 5 and with reference to the Site Plans provided in Appendix A.

Table 5: Liquid waste facility Category 61 infrastructure

Existing Infrastructure

Treatment of liquid waste

1 Area 1:

• Wastewater treatment system comprises:

a) Electro-coagulation plant with a capacity of 55,000L;

b) pH adjustment unit, sand filtering unit and recirculating oxygenation facilities;

c) Biological Oxygen Demand (BOD) reduction circuit which includes oxygenation

and UV treatment tanks;

d) Oxy/redox meter and oxidation circuit;

e) UV-ozone reactor;

f) Reverse osmosis treatment unit; and

g) Oily water plate separator

2 Area 2:

• Wastewater treatment system comprises:

a) 20 kL oily water settling tank;

b) Two 22 kL receivable storage tanks;

c) Two sumps with a capacity of 2 kL each;

d) Dissolved air flotation (DAF) system dsigned to treat 50 kL of wastewater per

10 hour day; and

e) Sharples Centrifuge

• graded hardstand to take tanker trucks, draining to a petrol and oil trap with pumping to

above ground storage tanks for the recovery of oils and sludges. Storage for

intermediate bulk container (IBC) and drums.

3 Area 3:

• Storage tank area comprises:

a) Two 55 kL untreated wastewater storage tanks;

b) 55 kL treated wastewater storage tank;

c) Four 40 kL storage tanks; and

d) 5 kL hydrocarbon tank

4 Area 4:

• Tankered waste receival area

• Activated carbon filter

• Solids and sludge treatment area

• Belt press equipment

5 Area 5:

• Stockpiling of treated material

5.3 Waste acceptance

The Licence Holder accepts and treats liquid waste from numerous controlled waste carriers for treatment. The Existing Licence allows the Licence Holder to accept and treat the following bulk and packaged controlled waste types, as detailed in Table 6.

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Table 6: Current waste acceptance as authorised on the Existing Licence

Liquid waste type

Wastewater treatment system

Controlled waste code1

Waste type Quantity limit (tonnes per annum)

B100 Acidic solutions or acids in solid form 250

C100 Alkali solutions 100

F100 Aqueous based waste from production, formulation and use of inks, dyes, pigments, paints, lacquers and varnish

50

J100 Waste mineral oils unfit for their intended purpose

30,000 (combined total)

J120 Waste oil and water mixtures or emulsions, and hydrocarbon and water mixtures or emulsions

J130 Oil interceptor waste

L100 Car and truck wash waters

50 (combined total) L150 Industrial wash waters contaminated with a controlled

waste

M130 Non-halogenated organic chemicals (engine coolants only)

250

Solidification process

M250 Surfactants and detergents 250

N120 Solids contaminated with a controlled waste (drilling mud) 10,000

Total 40,950

Note 1: The Controlled Waste category list arranges the controlled wastes listed in Schedule 1 of the CW Regs into 15 broad waste groups and assigns a waste code to each waste type within the group. The waste codes are used by industry and DWER regulation for waste tracking and reporting purposes.

5.4 Waste receipt and treatment processes

The Licence Holder has advised that the majority of wastes accepted are regularly scheduled loads from repeat controlled waste customers. Only a small portion of irregular/unusual loads are accepted.

A summary of waste receipt and treatment processes that were in place prior to the issue of the EPN is included in Table 7.

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Table 7: Waste processes

Waste code

Waste type Receipt and treatment summary

B100 Acidic solutions or acids in solid form

Acids are delivered in 1,000L IBCs as dilute acids and are temporarily stored in Area 5.

Acidic solutions accepted into a polypropylene tank.

Dilute acids are bled into the waste stream while the pH is monitored to be maintained >pH 7.

Receival to a synthetic polymer tank to replace an existing steel tank, Area 1. pH adjusted to 9.5 with settling out of metals. Residual metals removed by flocking process. Processing equipment subject to Intellectual Property agreement not yet in place.

C100 Alkali solutions Alkali solutions accepted into the untreated wastewater storage tank.

Dilute alkalis are bled into the waste stream while the pH is monitored to be maintained >pH 7.

Residual concrete tanker sludges accepted in Area 4 for leaching and treatment to spadable consistency.

Cement residues are subject to flocking process under pH adjustment. Residual wastewater to be treated prior to discharge to sewer.

Solids treated to spadable consistency in Area 4 prior to disposal to landfill.

F100 Aqueous based waste from production, formulation and use of resins, latex plasticers, glues and adhesives

Water-based paint brush and roller washings accepted in small drums.

Residual tanker sludges accepted in Area 4 for leaching and treatment to spadable consistency prior to landfill disposal.

Treatment via settlement and filtering. Solids via spadable consistency to landfill. Residual water treated prior to discharge to sewer/

J100 Waste mineral oils unfit for their intended purpose

Oils accepted into the untreated wastewater storage tank.

Residual tanker sludges accepted in Area 4 for leaching and treatment prior to being subject to solidification into spadable consistency prior to disposal to landfill.

J120 Waste oil and water mixtures or emulsions, and hydrocarbon and water mixtures or emulsions


Oils are treated by settlement, electrocoagulation and centrifuge.

Oils for recycling are stored in Tank 11.

Residual tanker sludges accepted in Area 4 for leaching and treatment prior to being subject to solidification into a spadable consistency prior to landfill disposal.

J130 Oil interceptor waste


Oils are treated by settlement, electrocoagulation and centrifuge.

Oils for recycling are stored in Tank 11.

Residual tanker sludges accepted in Area 4 for leaching and treatment prior to being subject to solidification into a spadable consistency.

L100 Car and truck Industrial wash water accepted into the untreated wastewater storage tank.

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Waste code

Waste type Receipt and treatment summary

wash waters Residual tanker sludges accepted in Area 4 for leaching and treatment prior to being subject to solidification into a spadeable consistency.

L150 Industrial wash waters contaminated with a controlled waste

Industrial wash water accepted into the untreated wastewater storage tank.

Residual tanker sludges accepted in Area 4 for leaching and treatment to spadeable consistency.

M130 Non-halogenated organic chemicals (engine coolants only)

Engine coolants contain ethylene glycol are accepted either in drums or IBCs for temporary storage within bunded Area 5.

Engine coolants are separately treated to remove metals and chemical BOD content via a reverse osmosis process within the main shed prior to discharging to sewer. Testing of treated wastewater for BOD will be via samples sent to NATA laboratory.

Small volumes of waste are accepted in drums & IBCs into Area 5 to be incorporated with residues into a spadable consistent prior to being disposed of to landfill.

M250 Surfactants and detergents

Small volumes accepted in drums and IBCs.

Directed to Area 4 for incorporating with residues into a spadable solid prior to being disposed of to landfill.

N120 Solids contaminated with a controlled waste (drilling mud)

Accepted in IBCs and bulky bags.

Content of bulky bags to be dumped to skips to allow water drainage. When drainage has stopped the solids are incorporated with other residues and disposed of to landfill.

Key Findings for waste processing:

1. The Delegated Officer notes that prior to the issue of the EPN, certain waste processes were occurring other than in accordance with the Licence, particularly in relation to fixating wastes other than surfactants, detergents and drilling mud (other than drilling mud contaminated with hydrocarbons) within the mixing pit.

2. The Delegated Officer also notes that upon issue of the EPN, waste processes at the Premises were modified to be consistent with the requirements of the Licence.

Liquid waste receipt

On arrival at the Premises, controlled waste carriers notify the Licence Holder of the type of liquid waste being delivered and then the pH of the waste is tested using litmus test by operators on-site. If considered suitable for treatment the waste is discharged into an open metal IBC as shown in Figure 4.

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Figure 4: Image of steel container used for waste unloading in Area 2

From the open IBC, waste is passed to a primary settlement tank and then through solids separation via a rotary screen and then transferred into liquid storage tanks. The recovered solids are transferred to a storage bin for disposal at an approved off-site facility. All runoff from this area is directed to a sump and contained.

Once liquid waste has been unloaded, Controlled Waste Carriers often washout the residual liquid waste with clean water. Vehicle wash-waters are disposed of into the open sump in Area 4 (see Figure 5) and subject to solidification processes prior to disposal to landfill. The Premises does not wash down other Trucks or vehicles that are not associated with the Premises activities.

Oil that separates in the primary settlement tank or liquid storage tanks is pumped to the oil storage tanks. The waste water that separates in the oil storage tanks is pumped back to the liquid storage tanks. Sludge that accumulates in the liquid and oil storage tanks is pumped to the sludge tanks and then sent to the centrifuge prior to mixing with other wastes and disposal to landfill or fed into off-site composting processes.

Key Findings for liquid waste acceptance and procedures:

The Delegated Officer notes that:

3. The Licence Holder has not presented waste acceptance (or rejection) criteria for the waste types received at the Premises. Wastes accepted at the Premises should meet criteria authorised in the Licence and be suitable for mixing or processing on the Premises, for example solubility, acidity/ alkalinity, toxicity and chemical composition

4. The current use of Controlled Waste criteria does not provide sufficient detail regarding the specific nature of wastes received.

5. There are no documented procedures to prevent the mixing of incompatible wastes. All bulk wastes appear to be consolidated in tanks prior to treatment. Some acids such as sulphuric, nitric, and organic acids should not be mixed with other liquid wastes as it may cause oxidation reactions.

6. There are no documented procedures to ensure that there is sufficient capacity on site to accept and store liquid wastes.

Sludge / slurry waste receipt

Surfactants and detergents (wetting agents) (M250) and drilling muds (N120) are delivered to the site and unloaded into the open concrete sump in Area 4 (refer to Appendix 3 – Site plans).

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Figure 5: Area 4 open sump

Liquid waste treatment

Waste water from liquid storage tanks is treated by a number of processes to remove residual oil, solids and sludge materials, as well as to adjust pH for final disposal to sewer.

These processes include:

• clarification;

• filtration (mesh screen, bag filters, sand filter);

• Dissolved Air Flotation (DAF);

• centrifugation (to remove sludge) in a Sharples centrifuge;

• coalescing plate oil/water separator;

• electrocoagulation pre-treatment;

• reagent mixing (e.g. limewater, ferric chloride, aluminum chloride, hydrochloric acid); and

• pH adjustment (hydrochloric acid / sodium hydroxide dosing).

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Figure 6: Process flow

Dissolved Air Flotation (DAF)

DAF is used to accelerate the flocculation and coagulation rates for suspended materials for separation from aqueous phase.

Pre-treated waste water is transferred to the DAF plant via an enclosed pipe line. Waste water is injected/mixed with polymer flocculation agent EMA8845MBL for suspended solids, precipitate and BOD reduction.

Treated water is then transferred to a settling tank for further solid / precipitate settlement prior to polishing via reverse osmosis filtration and / or to a discharge settling tank for further solid / precipitate settlement prior to polishing via reverse osmosis filtration and / or to a discharge storage tank. Resulting treated waste water is discharged to the sewer after confirmation of acceptable water quality.

Sharples Centrifuge

The Sharples centrifuge physically separates heavy solids from waste liquids, with all sludge collected in either an enclosed bunded pit (gravity fed from tanks) or in the DAF sludge tank (via sludge / hydrocarbon removal scrapers). Sludge can also be processed through the Sharples centrifuge for further de-watering.

Electrocoagulation

Electrocoagulation is utilised for:

• removal of surfactants, detergent and phosphates from industrial wash water which could affect further treatment processes (i.e. flocculation);

• removal of emulsified oil and total petroleum hydrocarbons;

• removal of suspended solids larger than 30µm;

• stabilise / neutralise pH of the waste water; and

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• post water polishing of BOD and heavy metal reduction.

Electrocoagulation involves the process of physio-chemical reactions for the treatment of wash water, wastewater and industrial processed water. Electrocoagulation applies an electrical charge to the water allowing suspended matter to form an agglomeration. It removes suspended solids to sub-micrometre levels, breaks emulsions such as oil and grease or latex, and oxidises, eradicates heavy metals and destroys bacteria and viruses.

According to information on the Water Corporation Waste Trade Permit, the electro-coagulation operates at 3,000 L/hr in accordance with manufacturer specifications.

Figure 7 displays the Electro-coagulation infrastructure.

Figure 7: Electro-coagulation

UV-Ozone Reactor

Ozone treats liquids with high BOD / Chemical Oxygen Demand (COD) content (BOD greater than 3,000 mg/L, COD greater than 6,000 mg/L).

Such waste water is processed through pre-treatment and DAF processes then stored in an isolated tank before being processed via the UV-Ozone reactor until BOD and COD levels achieve the Water Corporation discharge standards.

The UV-Ozone reactor can be linked to an anaerobic / aerobic glycol digestion attachments to remove glycol in waste engine coolant. Processed waste is monitored with BARTS BOD tester and Brix reader for BOD and glycol levels.

The ozone generator is used to break down pollutants in the water source. The generators convert oxygen into ozone by using ultraviolet radiation or by an electric discharge field. Using ozone can kill bacteria and oxidises substances such as iron and sulphur so that they can be filtered out of the solution.

The oxidation reactions are achieved through the synergistic action of high intensity UV light with ozone (O3) and hydrogen peroxide (H2O2). The UV/oxidation process generates highly reactive hydroxyl radicals that react with and destroy most organic chemical compounds. If complete mineralization is achieved in the reaction, the final products of the process are carbon dioxide, water and salts.

Figure 8 displays the on-site ozone treatment equipment / infrastructure.

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Figure 8: Ozone treatment

Reverse Osmosis Filtration

Waste water with high salinity (EC greater than 3,000 µs/cm) can be processed through reverse osmosis filters or diluted with low salt processed water in small quantities to achieve target EC.

Reverse osmosis uses a semi-permeable membrane to remove ions, molecules and larger particles from water. Figure 9 displays the on-site reverse osmosis treatment equipment/infrastructure.

During a site visit on 12 January 2017, DWER Officers identified that the Licence Holder had installed reverse osmosis treatment equipment on the Premises. No Part V approvals were sought to authorise the installation and operation of this equipment. The Licence Holder has advised that they are not currently operating this equipment.

Figure 9: Reverse osmosis treatment

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Hydrocarbon Recovery

The oily water separator equipment on the Premises consists or a tilting plate/coalescing separator utilising differences in specific gravity.

Figure 10 displays the on-site oily water separator equipment.

Figure 10: Oily water separator

All free oil is removed during processing stages including settlement, coalescing plate separator and electrocoagulation, then stored in a designated oil storage tank or bunded pit / oil traps. Hydrocarbons are not permitted to be cross contaminated with liquids in water storage tanks. All pipework and hoses used for hydrocarbon transfers are separated from water pipework and hoses, or thoroughly cleaned before using for different purposes.

Hydrocarbons in the oil storage tank are settled and de-watered several times until the water content is as low as possible. Emulsion separating agent is added if oil contains high levels of emulsions before further de-watering is carried out.

Interface waste is collected in an isolated tank for later processing through the Sharples centrifuge and electrocoagulation treatment when extracted from tanks, and / or trucks.

The final hydrocarbon product is sampled and tested by a licensed oil recovery operator then decanted to an approved road tanker by the licensed oil recovery operator for export from the Premises.


Surfactants, detergents (wetting agents) and drilling muds are accepted in a slurry/sludge state into a concrete sump within Area 4 and mixed with residual sludge material from the wastewater treatment systems.

From here the sludge mixture is pumped through a belt press to remove liquid with the residual solid component captured and directed to Area 4 for mixing with saw-dust as part of the solidification processes. Liquids are directed back into the wastewater treatment process.

Figures 11 and 12 display the on-site belt press equipment/infrastructure within Area 4.

Figure 13 displays images of the on-site solidification process where-by liquid wastes are mixed with solid wastes (mainly saw-dust) to produce a spadeable waste material that is then disposal of to landfill (Area 4).

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Figure 11: Belt press – equipment and infrastructure (Area 4)

Figure 13: Solidification process (Area 4) – mixing and absorption of liquid wastes into a solid waste matrix (saw-dust)

Key Findings of waste treatment processes


7. There are no documented maintenance records for the various treatment equipment and infrastructure on-site.

8. There is limited information on the efficiency of the different treatment processes due to the custom nature of equipment.

9. Based on the Water Corporation Waste Trade Permit identifying that the electro-coagulation unit and coalescing plate separators operate at 3,000L/ hr; assuming a 24 hour day operation, then the maximum treatment capacity for the plant is 26,280 kL per annum.

Figure 12: Belt press – equipment and infrastructure (Area 4)

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Waste disposal process

Liquid waste

The Water Corporation Discharge Permit 12574 (Appendix 4) allows for the discharge of treated wastewater from controlled waste categories oils and low strength waste waters only. Treated liquid waste is tested prior to discharge to sewer in accordance with the wastewater discharge permit issue by Water Corporation. The Existing Licence allows for treated wastewater from paints, resins, alkalis, engine coolants and acids to sewer.

The sewer network connected to the Premises conveys reticulated sewerage (consolidated drainage) to the Woodman Point Waste Water Treatment Plant (WWTP) managed by Water Corporation. Waste treated at this WWTP is then discharged to the Woodman Point ocean outfall.

Figure 24: Discharge to sewer point

Fixated waste disposal

The Licence Holder has advised DWER that fixated waste, as Class I, II or III waste types dependent upon contaminant thresholds, is taken off-site to premises licensed to accept those particular waste types.

Regulation 3 of the CW Regulations states:

“these Regulations do not apply to controlled wastes that can be lawfully accepted at a Class I, II or III landfill site (as determined by reference to the waste types set out in the document entitled “Landfill Waste Classification and Waste Definitions 1996” published by the CEO and as amended from time to time), other than —

• asbestos; or

• clinical or related waste; or

• tyres; or

• encapsulated, chemically fixed, solidified or polymerised controlled wastes”.

It is considered that fixated wastes processed at the Premises are not encapsulated, chemically fixed, solidified or polymerised.

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Key Findings of the disposal procedures


10. The Water Corporation permit only allows treated wastewater from oils (category J) and low strength wastewaters (category L) which is dissimilar to DWER’s licence. Water Corporation has advised it will be reassessing the permit for the Premises.

11. Based on the Water Corporation Trade Waste Permit, the Licence Holder must meet specific discharge criteria and discharge to the sewer at a rate not exceeding 3L/second.

6. Legislative context

6.1 Planning Approvals

The Site is in an area zoned as ‘industrial’ within the City of Fremantle. The City of Fremantle has provided advice that Fremantle Plumbing has planning approval under DA0389/12 issued on 8 November 2012 for ‘installation of concrete slab for tank stand’, DA0407-15 issued on 14 September 2015 for ‘warehouse addition to existing industrial buildings’.

According to the City of Fremantle’s Local Planning Scheme No. 4 Scheme Text, 8 March 2007 (Amended October 2016) ‘Industry – general (licensed)’ includes liquid waste treatment and processing facilities.

The Licence Holder has advised DWER that the “City of Fremantle TPS4 defines any industry specified under Schedule 1 of the EP Regulations as a Noxious Industry”. “LPS4 Table 2 – Zoning, Noxious Industrial is accorded Symbol Index A: that the use is not permitted unless the Council has exercised its discretion and has granted planning approval after giving special notice (advertising) in accordance with clause 9.4”.

The requirements of Clause 9.4 include:

• notice of the proposed use or development shall be served on nearby owners and occupiers who, in the opinion of the Council are likely to be affected by the granting of planning approval

• notice of the proposed use or development shall be published in a newspaper

• sign or signs displaying notice of the proposed use or development to be erected in a conspicuous position on the land for the specified period from the date of publication of the notice”.

Correspondence from the City of Fremantle dated 24 May 2016 advised that while the existing use on-site has been operational since 1960 the City of Fremantle’s records are silent on a valid planning approval being issued.

DWER sent a letter to City of Fremantle dated 12 April 2017, advising that it considers the site a Prescribed Premises; “Based on the advice you have provided, DWER understands that the land use for the site is therefore classified as Industry – Noxious pursuant to the City’s Local Planning Scheme No. 4 (LPS4) and that the current use of the Premises is not a permitted use.”

Key Findings:

12. The Delegated Officer notes that the Premises does not possess valid planning approval from the City of Fremantle for the prescribed activity.

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6.2 Lease agreement

The Premises is jointly owned by Fremantle Plumbing Service of 107 Garling Street, O’Connor and M.L Roberts of 10 Ravenswood Road, Ravenswood WA 6208.

The Director of Fremantle Plumbing Service Pty Ltd (ACN: 008 737 068) is Wayne Francis Roberts, whom has been in this position since 22/06/1990.

Mr Roberts is also a Shareholder of Controlled Waste Disposal Pty Ltd (ACN: 163 120 803), of which William John Warren has been the Director since 22/05/2013.

6.3 Contaminated sites

On 26 February 2013 the Department received a complaint regarding the discharge of hydrocarbon contaminated water onto unsealed ground on the Premises. After an investigation of this complaint, the Licence Holder had constructed a concrete pad on the land where the alleged spill had taken place.

As a result, the Premises was classified as ‘Possibly contaminated – investigation required’ under the Contaminated Sites Act 2003 (the CS Act) on 26 July 2016.

6.4 Trade Waste Permit

The Licence Holder has a Trade Waste Permit (Permit No. 12574) with Water Corporation to discharge treated wastewater to sewer (see Appendix 4). The Trade Waste Permit details the equipment for wastewater treatment which includes balancing or holding tank, centrifuge, dissolved air flotation unit, coalescing plate separator, electro-coagulation unit, steriliser unit, activated carbon unit and a static screen.

The limits of this Permit are as follows:

• The total petroleum hydrocarbon (TPH) concentration is not to exceed 30 mg/L

• The concentration of BTEX mush not exceed; benzene 0.08 mg/L, ethyl benzene 1.0 mg/L, toluene 1.3 mg/L, xylene 1.4 m/L

• The rate of discharge of trade waste to sewer is not to exceed 3 L per second

• The volume of trade waste discharge is not to exceed 60 kL/day, in any one day.

Key Findings:

13. The Delegated Officer has determined that the Licence Holder has occupancy of the Premises, as the owner of the property is a shareholder of the Licence Holder.

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6.5 Part V of the EP Act

Applicable regulations, standards and guidelines

The overarching legislative framework of this assessment is the EP Act and EP Regulations. The guidance statements which inform this assessment are:

• Guidance Statement: Regulatory Principles (July 2015)

• Guidance Statement: Setting Conditions (October 2015)

• Guidance Statement: Land Use Planning (February 2017)

• Guideline: Decision Making (June 2019)

• Guidance Statement: Risk Assessments (February 2017)

• Guidance Statement: Environmental Siting (November 2016)

• Guideline: Industry Regulation Guide to Licensing (June 2019)

Works Approval and Licence history

Table 8 summarises the works approval and licence history for the Premises.

Table 8: Works approval and Licence history

Instrument Issued Nature and extent of works approval, licence or amendment

W5289/2012/1 18/01/2013 Construction of the facility and associated infrastructure. The works approval was issued with a throughput for 10,400 tonnes per annual period.

W5666/2014/1 7/08/2014 Additional waste categories including paints and resins, low strength wastewater, oils and emulsions, engine coolants and wetting agents, emulsifiers, acids, alkalis and drilling mud and an increase of throughput to 100,000 tonnes per annual period.

L8730/2013/1 27/03/2013 Operation of a Category 61 liquid waste facility with a design capacity of 10,400 tonnes per year

L8730/2013/1 8/10/2015 Licence was amended in line with the works approval W5666/2014/1 for the additional waste categories and increase of throughput. However, the throughput was amended from 100,000 tonnes per annual period to 40,950 tonnes per annual period which is in line with the calculations provided by the Works Approval Application and considered acceptable on-site, given the location and the close sensitive receptors.

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7. Compliance review

7.1 Waste Acceptance Review

The Delegated Officer has cross-checked records from DWER’s CWTS to verify waste acceptance at the Premises between 1 October 2018 and 30 September 2019. The details recorded on the CWTS are described in Table 9.

Table 9: 2016 Controlled waste types received at the Premises

Category Group1

Waste Code1

Waste Type (Description) Reported waste acceptance between 1 October 2018 and 30 September 2019

Litres kg Normalised total (tonnes2)

B Acids B100 Acid solutions or acids in solid form

863,680 30,360 1066.84

C Bases C100 Basic (alkaline) solutions or bases (alkalis) in solid form

633,163 196,881 1,019.994

F Paints, Resins, Inks and Organic Sludge

F100

Aqueous based waste from the production , formulation and use of inks, dyes, pigments, paints, lacquers and varnish

47,002 2,456 63.564

J Oils

J100 Waste oils unfit for their intended purpose

1,222,703 31,503.1 1,131.94

J120 Waste oil and water mixtures or emulsions and hydrocarbon and water mixtures or emulsions

11,666,438 133,177 11,801.82

J130 Oil interceptor waste 854,468 55,078 912.55

J1803 Oil sludge 4,000 0 3.6

L Industrial Wash Water

L100 Car and truck wash waters 20,900 0 20.94

L150 Industrial wash waters contaminated with a controlled waste

48,000 13,000 614

M Organic Chemicals

M130 Non halogenated organic chemicals

241,630 0 217.47

M250 Surfactants and detergents

122,820 67,173 189.99

N Soils and Sludge

N1205 Soils contaminated with a controlled waste

178,085 1,018,884 1,219.66

Total 15,902,889 1,548,512 17,709

Note 1: The Controlled Waste category list arranges the controlled wastes listed in Schedule 1 of the CW Regs into 15 broad waste groups and assigns a waste code to each waste type within the group. The waste codes are used by industry and DWER Regulation for waste tracking and reporting purposes.

Note 2: Department of the Environment and Energy, 2017, Unit Conversion Factors, Blue Environment Pty Ltd, viewed 11 August 2017, <http://www.environment.gov.au/system/files/resources/a16491f5-6697-4f1b-bba0-074963e78957/files/hazardous-waste-unit-conversion-factors.pdf>; Roger Walker, 2016, Density of Materials, viewed 11 August 2017, <https://www.simetric.co.uk/si_materials.htm>

Note 3: Accepted waste types are not currently authorised for acceptance on the Existing Licence.

Note 4: Accepted waste types exceeded waste acceptance limits as specified in Condition 1.3.1 on the Existing Licence.

Note 5: Identified as T120 in the Existing Licence.

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Between 1 October 2018 and 30 September 2019 the Licence Holder accepted approximately 17,709 tonnes of liquid waste. Of this, 3.6 tonnes comprised a controlled waste type that the Licence Holder is not currently licensed to accept (refer to grey shaded cells in Table 9). Records from the CWTS also indicate that the Licence Holder exceeded waste acceptance limits as specified on the Existing Licence for several waste types (refer to bolded figures in Table 9).

7.2 Complaints

From 1 November 2015 to 26 June 2018, DWER has received 211 complaints in relation to emissions arising from the Premises. Of these complaints:

• 211 related to odour emissions;

• 10 of these complaints specifically relating to a perfumed chemical type odour; and

• The odour emission descriptions included foul, rotten egg, gas / chemical type odour, burnt oily smell, foul sewerage type odour.

DWER received a number of complaints from the public regarding odour with some complainants reporting the health impacts including vomiting, irritation of the throat and headaches. The exposure route for odour is from inhalation.

It is noted that complaints were received by the Department in November 2015 following a licence amendment in October 2015 that authorised an increase in the acceptance and treatment of liquid waste from 10,400 tonnes per annum to 40,950 tonnes per annum and included additional waste categories such as paints and resins, low strength wastewater, oils and emulsions, engine coolants and wetting agents, emulsifiers, acids, alkalis and drilling mud on the licence.

DWER Officers have been in attendance at the site, as a result of odour complaints, where the odour neutralisation spray has been in operation and have advised that the spray masks the chemical odour with a chemical sweet smell. It has been identified by DWER Officers that since the ‘de-odourising agent’ was installed, many complaints have specifically referred to the agent. The majority of the odour complaints have been received between January 2017 and June 2018.

Following the issue of the EPN to the Premises (see section 7.5 for further details), which stipulated numerous odour reduction measures, reports of odour complaints have dramatically reduced. DWER has received 7 complaints pertaining to odour from the Premises since March 2018, with no complaints having been received since December 2018.

Key Findings:


15. The complaints relating to odour started in November 2015, following a Licence amendment in October 2015 which included additional waste categories and an increase of throughput.

16. Since the issue of the EPN in March 2018, DWER has received 7 complaints pertaining to odour from the Premises. However, no complaints have been received

Key Findings:

14. The Delegated Officer notes that the combined total tonnage of accepted liquid waste was below the approved production or design capacity as specified on the Existing Licence. However, the Licence Holder exceeded waste acceptance limits for waste types B100, C100, F100 and L100/L150, and accepted J180 which is not currently a permitted waste type.

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since December 2018.

7.3 Compliance inspections

A number of inspections were carried out in response to community odour complaints allegedly emanating from the Premises.

Table 10: Summary of compliance inspections and findings

Date Purpose Findings Corrective action taken

11/11/15 Investigate complaint from community - strong effluent odour emanating from the Premises

• DWER identified 20-30 IBC’s of brown liquid as well as approximately 20-30 drums (120L) of AFFF (Aqueous Film Forming Foam Liquid)

• AFFF was mixed with saw dust to create a spadeable mixture and taken off-site by Solo Pty Ltd to landfill.

• DWER officers detected a distinct odour approximately 3 out of 6 in intensity. There was a mix of green liquid (determined to be Fluorescein), viscous black engine oil, paints and thinners that were visible in the discharge pit.

• The drainage grate, located along the southern boundary capturing wastewater run-off from the sawdust blending area, was being aerated and emitting a very strong sweet effluent odour approximately 4 out of 6 in intensity.

• Licence Holder advised that at the current rate there was 30T of liquid waste received each day and 60T of solid waste removed per month. This was generally taken by Solo Pty Ltd to a Class III landfill in Henderson.

Odour investigation initiated to ascertain potential for odour emissions from the Premises. Concluded with the issue of the EPN.

4/12/15 Response to a complaint that Licence Holder had dug a hole in the ground and was emptying chemical waste from IBCs into the hole. Strong chemical odour reported.

• A dark stain was observed on unsealed compacted soil on the eastern side of the Premises. DWER was advised that the concrete hardstand area had been washed down by staff, causing contaminated water to discharge onto the compacted soil area. The contaminated water consisted of waste that had been received on-site and was likely a range of chemicals including oil, sulphur, iodine and chlorine.

• IBCs containing waste including drilling mud and oily water were observed to be stored outside of the concrete bunded area.

• Granulated sulphur was observed of top of the pile of fixated chemical waste. DWER collected a sample of the sulphur using a dedicated glass sediment jar. A head space analysis was conducted using a MultiRae Lite gas detector fitted with a SO² chemical sensor. A maximum SO² of 0.1ppm was observed.

• Environmental Field Report (EFR) No. 4575 was issued in relation to hydrocarbon stained soil on the eastern side of the Premises

Hydrocarbon contaminated soil on the eastern side of the Premises, subject to EFR No. 4575, was collected and disposed of via the solid waste disposal bin on-site. An inspection conducted on 17 December 2015 verified these actions were completed.

8/12/15 Strong chemical odour from waste at the Premises turned over with

• A strong chemical odour was detected by DWER and described as a strong chemical odour 4 out of 6 on the German Olfactory Determination of Odour Intensity Scale VDI 3882 (1992) was observed at the Premises


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equipment. eastern side gate.

• An IBC was observed to be discharging a brown liquid into a pool surrounded by saw dust bund. DWER was advised that this was drilling mud.

• A controlled waste contractor was observed emptying a truck load of oily water into the open concrete hardstand area.

• DWER officers conducted an odour assessment investigation in the neighbouring residents of Jagoe Loop. A distinct chemical odour 3 out of 6 on the German Olfactory Determination of Odour intensity scale VDI 3882 (1992) was observed. The odour was the same as the odour observed at the Premises. The same odour was observed along Lander Street and Garling Street and was 4 out of 6 on the scale.

• EFR no. 4577 was issued for the emission of unreasonable odour related to waste processing.

17/12/2015 Environmental Inspection to determine compliance with Licence

A number of issues were raised during the inspection. The following non-compliances were identified:

• Approximately 680 tonnes of industrial wash water had been received on-site, in exceedance of 50 tonne limit from licence. The acceptance of 750L of ethers and highly flammable hydrocarbons and 4000L of dry-cleaning wastes containing perchloroethylene during the period is also contrary to the requirements of Table 1.3.1. EFR No. 0054 issued.

• Table 1.3.2 requires that ‘sludge from the wastewater treatment system is to be stored in a tank located on a hardstand prior to removal off-site’. Sludge from the treatment plant is blended into the leach pit with saw dust and then awaiting delivery to Millar Road Class III landfill, which is contrary to condition 1.3.3. EFR No. 0052 issued.

• Controlled waste carrier cleans out the carrier tank after the delivery of the waste product with the wash water material entering the leach pit. This is contrary to condition 1.3.3 as the licence requires all waste except for M250 and T120 are only accepted into enclosed containers for process through the wastewater treatment system.

• Officers identified that drums with alkalis, paints or resins were being stored in an area deficient of bunding, contrary to the requirements of Condition 1.3.3.

The blending of sludge resulting from the wastewater treatment system with sawdust ceased, with the sludge situated in storage tanks until such time that a viable option is proposed.

15/03/2016 Compliance Inspection as a result of an odour complaint – strong industrial / burnt / oily /

• DWER officers detected an acrid chemical type odour at the Premises approximately 23 times while on-site with an intensity of 3/6 based upon the FIDOL protocol (a means to characterise the effects of an odour annoyance by its frequency, intensity, duration, offensiveness and location)


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sewerage smell • Officers identified the odour source to be emanating from the oily-water separator equipment that was treating bilge water from the HMAS Sydney.

• Ozone was also being used to treat the waste and Officers identified a slight ozone odour also.

• Officers noted that the door immediately behind the oil-water separator was open at the time and the wind was blowing in that direction towards the complainant’s location.

• Officers attended a nearby site that was upwind of the odour and could not detect the odour at that location.

• It was determined at the time that the oil-water treatment was most likely the odour source.

15/04/16 Environmental Inspection to determine compliance with Licence and follow-up 17/12/2015 findings

A number of issues were raised during the inspection. The following non-compliances were identified:

• Officers identified that the hardstand area is inadequate to capture all potentially contaminated stormwater with the contouring resulting in discharge/s to the environment, contrary to the requirements of Condition 1.2.4.

• Approximately 680 tonnes of industrial wash water had been received on-site, in exceedance of 50 tonne limit from licence. The acceptance of 750L of ethers and highly flammable hydrocarbons and 4000L of dry-cleaning wastes containing perchloroethylene during the period is also contrary to the requirements of Table 1.3.1. EFR No. 0054 issued.

• Table 1.3.2 requires that ‘sludge from the wastewater treatment system is to be stored in a tank located on a hardstand prior to removal off-site’. Sludge from the treatment plant is blended into the leach pit with saw dust and then awaiting delivery to Millar Road Class III landfill, which is contrary to condition 1.3.3. EFR No. 0052 issued.

• Controlled waste carrier cleans out the carrier tank after the delivery of the waste product with the wash water material entering the leach pit. This is contrary to condition 1.3.3 as the licence requires all waste except for M250 and T120 are only accepted into enclosed containers for process through the wastewater treatment system.

• Officers identified that drums with alkalis, paints or resins were being stored in an area deficient of bunding, contrary to the requirements of Condition 1.3.3.

• A concrete lip was installed along the perimeter of the hardstand area to prevent potentially contaminated stormwater from entering the open area. Potentially contaminated stormwater is directed, via contouring, to a series of contained sumps. Officers confirmed these actions during an inspection conducted on 27/09/2016.

• The identified steel drums were immediately relocated onto a portable bund to rectify the matter. Officers confirmed these actions during an inspection conducted on 27/09/2016.

27/09/16 Environmental Inspection to determine compliance with Licence and follow-up 15/04/2016

• The Licence Holder was found to be accepting J180 (oil sludge – 135 tonnes) for the period 17 June 2016 (the date of issue of the previous inspection report) to 21 September 2016. This was contrary to Condition 1.3.1. EFR No. 0059 was issued.

• Approximately 293 tonnes of Industrial wash

Further re-inspection undertaken.

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findings water (L100 and L150) had been received during the same period in exceedance of the 50 tonne limits specified in Condition 1.3.1. EFR No. 0058 was issued.

• Officers observed 14 open bulk bags containing residual sludge from the wastewater treatment system contrary to Condition 1.3.3, which requires sludge from the wastewater treatment system to be stored in a tank located on a hardstand area prior to removal off-site. EFR No. 0057 was issued.

15/01/2018 Targeted inspection in response to complaints and incidents regarding odour emissions caused by waste processing and storage practices.

• Acceptance of waste was not in accordance of Table 1.3.1, 6 tonnes of N120 waste accepted on site in 2017-2018 period, the Licence Holder has exceeded the quantity limit throughput for C100, F100 and L100/150.

• The Licence Holder has accepted waste that did not meet the criteria in Table 1.3.1 and has not removed waste to an authorised facility as soon as possible. The Licence Holder has accepted oil contaminated soil which was treated at the Premises.

• Controlled Waste vehicles clean out the tanks after the delivery of the waste product with the wash water and sludge material entering the leach pit. This is contrary to condition 1.3.3 as the licence requires all waste, except for M250 and T120, to only be accepted into the untreated wastewater storage tanks for processing through the wastewater treatment system.

• Sludge from the desludging of the wastewater treatment system is directed to a bulker bag rather than a tank as required by Table 1.3.2

• The Licence Holder has emitted an unreasonable emission from the Premises. DWER has received numerous complaints from residents in the area surrounding the Premises. DWER officers have responded to these complaints on numerous occasions and have identified FPS as the source of the unreasonable odour. The latest batch of complaints was over the period 8-13 January 2018 where 11 different residents made at least 21 different complaints over the period.

• The licensee has caused an unreasonable emission to be emitted from the Premises by: allowing wastes to be accepted contrary to licence condition 1.3.1 (hydrocarbons accepted to leach pit), installing wastewater treatment equipment without approval in contravention of s53(1) of the EP Act; and storing sludge from the wastewater treatment system contrary to condition 1.3.3 (not in a tank located on a hardstand).

• The licensee has installed wastewater treatment equipment (DAF and Reverse Osmosis) which has potentially altered the odour to be emitted. This equipment has been installed without a Works Approval or licence condition authorising the installation or operation of the equipment.

• At the time of the inspection it was found that

The licensee ceased using the DAF treatment system.

Concluded with the issue of the EPN.

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the licensee was in contravention of licence conditions 1.3.1, 1.3.2 and 1.3.3. The licensee has previously been found to be in contravention of these conditions during inspection conducted in September 2016 and December 2015.

• Receipts given to drivers/carriers for waste received at the facility are issued in the name of Controlled Waste Disposals Pty Ltd which is not the licensed occupier of the Premises.

26/06/2019 Targeted inspection of EPN requirements

• The CWTS records show that 400 L of F120 was accepted at the facility which is not authorised.

• The waste volumes for Acids (253.18 tonnes), Alkalis (919.49 tonnes), Paints & Resins (60.95 tonnes) and Industrial Wash Water (57.3 tonnes) accepted at the Premises have exceeded the Quantity Limits for those items.

• The licensee submitted the AACR for the period 29 January 2018 to 16 January 2019 however the annual period as per Condition 1.1.2 of the licence is the inclusive period from 1 January until 31 December in the same year.

• The licensee declared that there were no non-compliances during the reporting period however an inspection conducted on 15 January 2018 found the licensee to be non-compliant with condition 1.3.3 in that controlled waste vehicles transporting wastes other than M250 and T120 (N120) are cleaned out after delivery with wash water and sludge entering the leach pit. A review of the CWTS system also found that the licensee was non-compliant with condition 1.3.1.

Licensee to ensure that waste quantities are within authorised limits.

Follow-up inspection to be undertaken to determine if accepted quantities for the current year are within limits.

Table 11 summarises the Environmental Field Reports issued to the Premises as a result of the inspections listed in Table 10.

Table 11: Environmental Field Report’s (EFR) issued

Date EFR Issue Corrective action taken

3/12/2015 4575 Issued to John Warren, Managing Director of Fremantle Plumbing Pty Ltd for placing hydrocarbons in a place that may allow a discharge into the environment on compacted area near site hardstand.

Following the issue of the EFR, the potentially contaminated material was immediately collected and disposed of via the solid waste disposal bin on-site, complying with the EFR actions. An inspection conducted on 17 December 2015 verified these actions were completed. The matter has been closed.

8/12/2015 4577 Issued to John Warren Managing Director of Fremantle Plumbing Pty Ltd for allowing an unreasonable odour emission related to the processing of waste to the environment.

Following the issue of the EFR, the Licence Holder trialled an odour neutralising unit from CoolMist Systems Australia at the leach pit. The unit was dosed with

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AiReactor OWD (Organic Waste and Decomposition Odour Counteractant Concentrate) to neutralise potential odours via a misting spray. While the EFR is considered closed, further odour complaints have resulted in a review of controls at the Premises.

19/02/2016 0052 Issued to John Warren, Managing Director of Fremantle Plumbing Pty Ltd for breach of condition 1.3.3. As advised by the Licence Holder, the blending of sludge resulting from the wastewater treatment system with sawdust no longer occurs, with the sludge deposited in storage tanks until such time that a viable option is proposed.

This was confirmed during the 27 September 2016 inspection. However, a further breach was identified as per EFR No. 0057, as discussed below. Matters associated with EFR No. 0052 have been closed.

8/04/2016 0054 Issued to John Warren, Managing Director of Fremantle Plumbing Pty Ltd for breach of licence condition 1.3.1. The acceptance of ethers and highly flammable hydrocarbons and dry-cleaning wastes containing perchloroethylene ceased as per information sourced from the Controlled Waste Tracking System. However, the acceptance of industrial wash water continued contrary to the quantity limit exceedance. This matter was also raised during the 27 September 2016 inspection, resulting in the issue of EFR No. 0058.

EFR No. 0054 was not complied with within the required timeframe, but was closed due to compliance with the issue of EFR No. 0058.

27/09/2016 0057 Issued to John Warren, Managing Director of Fremantle Plumbing Pty Ltd on for breach of condition 1.3.3, due to residual sludge from the wastewater treatment system being stored in14 open bulk.

The matter is closed following the completion of remediation works required by the EPN.

27/09/2016 0058 Issued to John Warren, Managing Director of Fremantle Plumbing Pty Ltd for breach of condition 1.3.1 (waste quantity limit).

The acceptance of industrial wash water was ceased as per information provided within the Controlled Waste Tracking System. The matter is considered closed.

27/09/2016 0059 Issued to John Warren, Managing Director of Fremantle Plumbing Pty Ltd for breach of condition 1.3.1 (waste type acceptance).

Following issue of the EFR, the acceptance of J180 (oil sludge) was ceased as per information provided within the Controlled Waste Tracking System. The matter is considered closed.

09/03/2017 2681 Issued for breach of s. 49(5) of the EP Act for the discharge of unreasonable odours

Processes suspected of odour emissions were ceased. The matter is considered closed.

21/03/2017 2866 Issued for breach of s. 58(1) of the EP Act, whereby the Licence Holder was found to be non-complaint with Licence condition 1.3.1 (acceptance of non-conforming material)


21/03/2017 2867 Issued for breach of s. 58(1) of the EP Act, whereby the Licence Holder was found to be non-complaint with Licence condition 1.3.1 (breach of acceptance quantity limits)


10/05/2017 2872 Issued for breach of s. 58(1) of the EP Act, whereby the Licence Holder was found to be non-complaint with Licence condition 1.3.1 (breach of acceptance quantity limits)


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29/08/2017 2878 Issued for breach of the Environmental Protection (Unauthorised Discharges) Regulations 2004


28/12/2017 0801 Issued for breach of s. 49(5) of the EP Act for the discharge of unreasonable odours


Key Findings:


17. DWER has received over 200 odour complaints, of which DWER officers have responded to these complaints on numerous occasions and have identified the Premises as the source of the unreasonable odour.

18. At least one complaint resulted in Department of Fire and Emergency Services (DFES) attending the complainant’s residence and providing medical assistance due to the effects of the odour emission.

19. DWER Officers have attended the site on numerous occasions, eight of these have been official Inspections that identified non-compliances of Licence conditions, mainly relating to:

a) Condition 1.3.1 and Table 1.3.1 waste acceptance requirements including the type and limits that can be accepted on site;

b) Condition 1.3.3 and Table 1.3.2 waste processing requirements; and

c) Condition 1.3.4 and Table 1.3.3 containment infrastructure.

20. Since the issue of the EPN in March 2018, DWER has received 7 complaints pertaining to odour from the Premises. However, no complaints have been received since December 2018.

7.4 Annual Audit Compliance Reports

2015 Report

Annual Audit Compliance Report (AACR) and Annual Environmental Reports (AER) were submitted in accordance with condition 3.1.3 and condition 3.2.1 during the period 1 January to 31 December 2015.

Following a review of the AACRs and AERs as a part of this assessment it is noted that the Licence Holder stated that they were compliant with the conditions of the Licence for the 2015 reporting period. However there were a number of non-compliances identified through compliance inspections including:

• Non-compliance with condition 1.3.1 acceptance of waste – 4,000L of chemical AFFF accepted on-site;

• Non-compliance with condition 1.3.1, 1.3.3 and 1.3.4 liquid wastes accepted in a large concrete sump and mixed with saw dust that is non-compliant with condition 1.3.1 and 1.3.3 waste processing requirements and condition 1.3.4 containment infrastructure.

• The Licence Holder also advised that there were no complaints in the 2015 reporting period, however DWER officers were in attendance on-site in relation to odour complaints on 12 November 2015, 4 December 2015 and 8 December 2015 and

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issued Environment Field Notices in relation to the odour complaints. 2016 Report

The Licence Holder stated that they were compliant in the 2016 Annual Audit Compliance Report. However, there are a number of non-compliance issues on site specifically acceptance and processing of waste on site. The Annual Environmental Report was not submitted as part of the 2016 reporting period.

2017 Report

The 2017 Annual Audit Compliance Report and Annual Environmental Report as required by condition 3.1.3 and condition 3.2.1 for the 2017 reporting period was not submitted.

2018 Report

The Licence Holder stated that they were compliant in the 2018 Annual Audit Compliance Report, with the Annual Environmental Report presenting the annual volumes for waste acceptance and treatment. Assessment of the AACR identified the following issues:

• Condition 1.3.1 - Controlled Waste Tracking System (CWTS) records indicate that 400 litres of F120 was accepted at the facility which is not authorised.

• Condition 1.3.1 - The waste volumes for Acids (253.18 tonnes), Alkalis (919.49 tonnes), Paints & Resins (60.95 tonnes) and Industrial Wash Water (57.3 tonnes) accepted at the Premises have exceeded the Quantity Limits specified in Table 1.3.1 for those items.

• Condition 3.1.3 - The licensee submitted the AACR for the period 29 January 2018 to 16 January 2019 however the annual period as per Condition 1.1.2 of the licence is the inclusive period from 1 January until 31 December in the same year.

• Condition 3.1.3 - The licensee declared that there were no non-compliances during the reporting period however an inspection conducted on 15 January 2018 found the licensee to be non-compliant with condition 1.3.3 in that controlled waste vehicles transporting wastes other than M250 and N120 were cleaned out after delivery, with wash water and sludge entering the leach pit.

7.5 Environmental Protection Notice CEO182/18

From 8 January 2018 to 13 January 2018, the Department received 11 residents made 21 complaints in regards to the impacts of chemical odours allegedly emanating from the Premises. In response to this, the Department attended the Premises and undertook an inspection (see Table).

Given the number of non-compliances identified at the Premises and in response to the community impacts from unreasonable odour emissions, the Department issued an EPN under section 65 of the Environmental Protection Act 1986 to Fremantle Plumbing Service Pty Ltd and Mervyn Leslie Roberts on 2 March 2018 (see Attachment 7). The Notice was issued because the Department suspected that there were emissions of odours from the Premises and the emissions caused pollution, being a direct alteration of the environment to its detriment.

The key requirements of the EPN were to immediately:

• Cease operations of waste treatment equipment and processes not authorised under Licence L8730/2013/1;

• Cease use of the receival pit, also known as the mixing pit and / or leach pit, completely empty the pit, clean all residues from the receival pit;

37



• Once cleaned, the receival pit is only to receive, handle, treat and stored surfactants & detergents and drilling mud (other than drilling mud contaminated with hydrocarbons); and

• Within one week of the Notice being issued, prevent the emission of unreasonable odours from the Premises by ensuring all wastes except surfactants, detergents and drilling muds, are received, stored and processed in tanks, vessels or fully enclosed buildings.

It was also identified through this investigation, that a detailed investigation into the source of odours and controls by a specialised consultant is required, therefore the EPN also required:

• Within 14 days of the Notice, the Owner to engage an Environmental Consultant to prepare a Remediation Plan, for the prevention control or abatement on odour emissions.

It was the intention of the Department that the proposed controls would then be captured within the Licence Review as improvements to ensure odour emissions are controlled.

The Licence Holder submitted a Remediation Plan prepared by Strategen Environmental consultants on 20 April 2018 in response to the EPN. The Department reviewed the Remediation Plan and provided comments/ queries to the Licence Holder on 16 May 2018. The Licence Holder then submitted an updated Remediation Plan on 21 June 2018, with DWER providing confirmation of approval of the Remediation Plan on 16 July 2018.

7.6 Air Quality Review

On August 31 2016, DWER’s Air Quality Officers carried out a site visit of the Premises. The following observations were made from this site visit, and discussions with the Premises General Manager, Mr J. Warren:

• Waste is delivered either in enclosed containers or in bulk and then stored in enclosed storage tanks;

• Most of the aqueous waste is diluted and disposed of into the sewer;

• Non-halogenated organic compounds are received and processed in batches through a dedicated process that has limited odour emissions;

• The Dissolved Air Flotation (DAF) process has a limited surface area footprint exposed to air. Scum or sludge has a limited emission similar to that expected when entering a mechanic’s garage;

• Limited volumes of scum or sludge are mixed with sawdust to get ‘spadeable consistency’ before sending to landfill. None of the material that receives this treatment has been identified as highly odorous;

• An increase in throughput is unlikely to have a significant role in changing odour emissions, since neither the management nor the treatment process will vary.

• Ethylene glycol present in engine coolant should have sufficiently low volatility to pose minimal odour risk. It can be noted that non-halogenated organic compounds may comprise more odorous components (e.g. amyl acetate or some aliphatic amines).

• The vast majority of the liquid waste accepted by the plant is aqueous, and is treated by dilution and disposal to the sewer at a rate specified separately in a license issued by the Water Corporation. The treatment of liquid waste by combination with sawdust is applied only to the scum removed from the surface of such waste. This constitutes a much lower fraction of the plant throughput than is implied in the report, and is much less likely to result in unacceptable odour impacts.

• The 40 kL tanks are not open to the atmosphere, which reduces the possibility of odour emissions.

38



Key Findings


21. During the site visit with Air Quality Officers there was no waste accepted into the open sump.

22. The odour fogger system is not likely to mitigate odour impacts.

39



8. Risk assessment

8.1 Determination of emission, pathway and receptor

In undertaking its risk assessment, DWER will identify all potential emissions pathways and potential receptors to establish whether there is a Risk Event which requires detailed risk assessment.

The identification of the sources, pathways and receptors to determine Risk Events are set out in Table 12 below.

40



Table 12. Identification of emissions, pathway and receptors

Risk Events Continue to detailed risk assessment

Reasoning

Sources/Activities Potential

emissions Potential receptors

Potential pathway

Potential adverse impacts

Waste water

treatment plant

Liquid waste acceptance, storage and treatment via wastewater treatment system

Odour Residential receptors – Nearest residence approx. 46 m north.

Air / wind dispersion

Public health and amenity impacts

Yes See Section 8.4

Commercial/industrial receptors – Immediately adjacent to the east, south and west.

Yes See Section 8.4

Particulates and noxious gases (in the event of a fire from the mixing of incompatible waste types)

Residential receptors – Nearest residence approx. 46 m north.



Yes See Section 8.7


Yes

See Section 8.7

Noise generated by wastewater treatment equipment, vehicle movements and delivery and pickup of wastes





Yes See Section 8.5

Liquid waste discharge including foreseeable events spills / leaks/ fire water run-off

Drainage reserves and adjacent land

Direct spills and contaminated stormwater surface run-off. Fire water run-off

Reduction of soil quality and/or contamination of land and underlying groundwater

Yes See Section 8.6

Underlying soil and land Direct spills and seepage to ground (land)

Reduction of soil quality and/or contamination of land

Yes See Section 8.6

41




Reasoning



Potential pathway


Underlying groundwater Direct spills and infiltration to groundwater

Reduction of groundwater quality and/or contamination of groundwater

Yes See Section 8.6

Down-hydraulic gradient bore water users – either for domestic, commercial or industrial purposes

Groundwater seepage


Yes See Section 8.6

Surface water receptors >1 km from Premises (see Section 5.3)

Direct spills and contaminated stormwater surface run-off

Reduction in surface water quality and/or contamination of surface water

No

The Delegated Officer considers that the risk to down-hydraulic gradient bore users is unlikely given the depth to groundwater, and the distance to surface water bodies.

Sludge acceptance, storage and processing / solidification (addition of sawdust)

Odour




Yes See Section 8.4




Yes See Section 8.4

Pollution / hazard; fire / explosion risk – air emissions (particulates and noxious gases)




Yes See Section 8.7




Yes See Section 8.7

42




Reasoning



Potential pathway


Liquid waste discharge Including foreseeable events spills / leaks

Fire water run-off

Drainage reserves and adjacent land

Direct spills and contaminated stormwater surface run-off

Reduction of soil quality and/or contamination of land and underlying groundwater

Yes See Section 8.6

43



8.2 Consequence and likelihood of risk events

A risk rating will be determined for risk events in accordance with the risk rating matrix set out in Table 13 below.

Table 13: Risk rating matrix

Likelihood Consequence

Slight Minor Moderate Major Severe

Almost certain Medium High High Extreme Extreme

Likely Medium Medium High High Extreme

Possible Low Medium Medium High Extreme

Unlikely Low Medium Medium Medium High

Rare Low Low Medium Medium High

DWER will undertake an assessment of the consequence and likelihood of the Risk Event in accordance with Table 14 below.

Table 14: Risk criteria table

Likelihood Consequence

The following criteria has been

used to determine the likelihood of

the Risk Event occurring.

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

Environment Public health* and amenity (such as air

and water quality, noise, and odour)

Almost

Certain

The risk event is

expected to occur

in most

circumstances

Severe • onsite impacts: catastrophic

• offsite impacts local scale: high level

or above

• offsite impacts wider scale: mid-level

or above

• Mid to long-term or permanent impact to

an area of high conservation value or

special significance^

• Specific Consequence Criteria (for

environment) are significantly exceeded

• Loss of life

• Adverse health effects: high level or

ongoing medical treatment


public health) are significantly

exceeded

• Local scale impacts: permanent loss

of amenity

Likely The risk event will

probably occur in

most circumstances

Major • onsite impacts: high level

• offsite impacts local scale: mid-level

• offsite impacts wider scale: low level

• Short-term impact to an area of high

conservation value or special

significance^


environment) are exceeded

• Adverse health effects: mid-level or

frequent medical treatment


public health) are exceeded

• Local scale impacts: high level

impact to amenity

Possible The risk event

could occur at

some time

Moderate • onsite impacts: mid-level

• offsite impacts local scale: low level

• offsite impacts wider scale: minimal


environment) are at risk of not being met

• Adverse health effects: low level or

occasional medical treatment


public health) are at risk of not being

met

• Local scale impacts: mid-level

impact to amenity

Unlikely The risk event will

probably not occur

in most

circumstances

Minor • onsite impacts: low level

• offsite impacts local scale: minimal

• offsite impacts wider scale: not

detectable


environment) likely to be met


public health) are likely to be met

• Local scale impacts: low level impact

to amenity

Rare The risk event may

only occur in

exceptional

circumstances

Slight • onsite impact: minimal


environment) met

• Local scale: minimal to amenity


public health) met

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

44



* In applying public health criteria, DWER may have regard to the Department of Health’s Health Risk Assessment (Scoping) Guidelines. “onsite” means within the Prescribed Premises boundary.

8.3 Acceptability and treatment of Risk Event

DWER will determine the acceptability and treatment of Risk Events in accordance with the Risk treatment Table 15 below:

Table 15: Risk treatment table

Rating of Risk Event

Acceptability Treatment

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

High May be acceptable.

Subject to multiple regulatory controls.

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

Medium Acceptable, generally subject to regulatory controls.

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

Low Acceptable, generally not controlled.

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

8.4 Risk Assessment - Odour

General Hazard Characterisation and Impact

There is potential for odour emissions during operation of the liquid waste facility from the:

• acceptance of odorous liquid wastes such as oily wastewater;

• operation of the oily wastewater treatment plant and emissions from the venting of storage and treatment tanks;

• washing out of trucks;

• bacterial build up in tanks due to increased sludge levels and lack of maintenance;

• deodoriser agent used to mask odour; and

• handling, processing and storage of packaged liquid waste and residual oily sludge/solids on the Premises.

Strategen has submitted an Odour Remediation Plan on behalf of the Licence Holder and has identified the emissions sources in relation to odour. Table 16 has been taken from this report. Strategen also notes that many of the sources are diffuse in nature and that a subjective odour emissions assessment has been carried out that is informed from site visit and understanding of the processes that give rise to odour. The assessment undertaken by Strategen indicated that the key sources of odour emissions occur during unloading, loading oil to export tankers, filtration processes, washing of tankers and open process vessels.

Table 16: Process elements, odour emissions and controls

45



Process element Existing emissions controls Nature of emissions

Waste receivals area Nil General background of odour from this location.

Tanker unloading points

Nil No obvious odours from discharging process when closed coupling hose used.

Odour from liquid waste detected at point of transfer when open coupling from tanker hose to receivals hose was used.

Solids catch box Nil No obvious odours from catch box.

Tanker wash Nil Assessment carried out during site visit of 5 April.

Odour detected during tanker washing.

Primary Filter Enclosed vessel No obvious odour from filter (enclosed).

Receival Storage Tanks

Enclosed tanks reduce emissions potential but vents will release some odour

Not possible to assess odours from vents.

However, likely that odours substances dissolved in waste waters will partition to headspace and therefore be available for discharge to atmosphere.

Receivable Oily Water Settling Tank

Enclosed tank reduces emissions potential but vents will release some odour

Not possible to asses odours from vents.

However, likely that odours substances dissolved in waste waters will partition to headspace and therefore be available for discharge to atmosphere.

Oil storage tanks Enclosed tanks reduce emissions potential but vents will release some odour

Not possible to assess during site visit.

However, tank headspace vapours will discharge to atmosphere via tank vent as tank fills.

Oil export Nil Tankers are vented to atmosphere during loading, likely source of hydrocarbon odour emissions.

Electro-coagulation Nil General odour evident from area around EC units.

Oil/water plate separator

Nil Open vessel, hydrocarbon odours evident.

Dissolved air flotation (DAF)

Plastic shroud installed over vessel with activated carbon filter installed on air exhaust duct

DAF is currently not approved in the Licence and is not operational.

Likely to be significant odour source due to outgassing of hydrocarbon vapours.

Solids and sludge treatment

Nil Treatment process involved addition of soil / sawdust to solids and sludge to generate spadable material for landfill or possible use as compost.

General hydrocarbon odour noted from sludge in open pit.

Compost stockpile Nil Negligible odour detected during site visit.

However, some odour emissions may occur during addition of sludge and solids to stockpile and reclaim of stockpile, and if aeration rate is

46



Process element Existing emissions controls Nature of emissions

excessive.

Reverse Osmosis Filtration

Enclosed vessels RO plant off-line (not in service)

UV-ozone reactor Nil Negligible odour detected during site visit.

IBC receivals and storage

Nil Odours were not detected in locations where IBCs containing wastes were stored.

It is expected that some odours would be released when these wastes were processed.

Odour emissions are primarily associated with the release of volatile organic compounds. The frequency of potential odour emissions at the Premises is expected to vary throughout the day depending on the type of waste and processing undertaken on-site. The Premises occasionally operates 24 hours a day, therefore odour emissions may occur at any time.

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

The Premises is located within an industrial area that has a number of businesses that could potential contribute to the odour sources in the area. For example, a category 31 chemical manufacturing and category 33 chemical blending or mixing premises operates approximately 86 m south east of the Premises.

As discussed in section 7.2, the Premises has been subject to a number of odour complaints, many of which DWER officers have attributed to the Premises activities. DWER has also been advised that ATCO Gas have attributed odour complaints to the Premises.

The complaints made to DWER include reports of health impacts including vomiting and headaches. An increase in complaints has been correlated to the October 2015 licence amendment which significantly increased throughput (10,400 tonnes per annum to 40,950 tonnes per annum) and increased the number of waste types accepted. Odour complaints have also been made regarding a de-odourising agent.

Criteria for assessment

There are no set threshold or concentration criteria for odour assessment. Under section 49(5) of the EP Act, it is an offence to emit or cause to be emitted, an unreasonable emission from any premises.

An unreasonable emission is defined in the EP Act (section 49(1)) as an emission or transmission of noise, odour or electromagnetic radiation which unreasonably interferes with the health, welfare, convenience, comfort or amenity of any person.

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

Licence Holder controls

Strategen submitted an Odour Remediation Plan on behalf of the Licence Holder and proposed controls to mitigate odour emissions and proposed priority for implementation. Table 17 has been taken from the Odour Remediation Plan.

47



Table 17: Process elements, odour emissions and proposed controls

Process element Proposed odour controls Priority for odour mitigation

Waste receival areas

Enclosed area with air extraction and activated carbon filtration of exhaust air.

High

Tanker unloading points

Tanker parked in enclosed area to capture any odour emissions during unloading.

High

Solids catch box Catch box located in enclosed area to capture any odour emissions during tank washing.

Low

Tanker wash Tanker parked in enclosed area to capture any odour emissions during tank washing.

Waste pit located in enclosure with air extraction and activated carbon filtration of exhaust air.

High

Primary filter Filter located in enclosed area. Low

Receivable storage tanks

Installation of ductwork from vent to enclosed receival area for activated carbon filtration.

OR

Installation of activated carbon filter onto vent to allow passive filtration of vented air.

Medium

Receivable oily water settling tank

Installation of ductwork from vent to enclosed receival area for activated carbon filtration.

OR


High

Oil storage tanks Installation of ductwork from vent to enclosed receivable area for activated carbon filtration. OR


Medium

Oil export Tanker vent to be connected to storage tank to provide closed loop vapour return system.

Medium

Electro-coagulation Extraction hood fitted above the EC unit and feed tank with activated carbon filter on exhaust air.

Medium

Oil/water separator Extraction hood fitted above the vessel with activated carbon filter on exhaust air.

Medium

Dissolved air flotation (DAF)

Shroud fitted to top of DAF unit with passive venting through activated carbon filter.

High

Solids and sludge treatment

Enclosure over pit and blending hardstand area sludge with air extraction through activated carbon filter.

Medium

Compost stockpile Install enclosure over stockpile area with air extraction through activated carbon filter.

Low

48



Process element Proposed odour controls Priority for odour mitigation

Reverse osmosis filtration

Not required, enclosed unit. Not required

UV-Ozone reactor Exhaust air repot to extraction hood for dilution with incoming air then activated carbon filtration.

Low

IBC receivable and storage

Location of IBCs during decanting inside enclosure with air extraction and activated carbon filtration of exhaust air.

Medium

The Odour Remediation Plan was approved by DWER on 16 July 2018, with the implementation of the proposed controls completed as at the time of this assessment.

Consequence

The Delegated Officer has determined that based on the sensitivity of the nearest residential receptor, and the potential for odours generated from waste processing, the impacts of odour emissions may result in mid-level local scale impacts to amenity. Therefore, the Delegated Officer considers the consequence to be Moderate.

Likelihood of consequence

The Delegated Officer has determined that based on the controls proposed by the licence holder, the likelihood of impacts to amenity from odour emissions could occur at some time. Therefore, the Delegated Officer determines the consequence to be Possible.

Overall rating

The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 14) and determined that the overall risk rating for the risk of odour on sensitive receptors during operation with the proposed controls is Medium.

8.5 Risk Assessment – Noise

General Hazard Characterisation and impact

Noise is generated from normal operations on-site including the wastewater treatment equipment, vehicle movements and delivery and pickup of wastes. The Premises periodically operates 24 hours a day, 7 days a week and therefore noise emissions may occur at any time.

Noise impacts may result in reduced wellbeing, amenity and comfort of sensitive noise receptors (residential dwellings) located approximately 46 metres north of the Premises and commercial / industrial premises located adjacent to the Premises.

Criteria for Assessment

The current applicable criteria for noise levels are detailed in the Environmental Protection (Noise) Regulations 1997.

Key Finding:

23. The proposed controls within the Odour Remediation Plan, submitted in accordance with the EPN, have been implemented, with no odour complaints received by DWER regarding the Premises since December 2018.

49




The Licence Holder has not specified any controls that directly relate to mitigating potential noise emissions, however the wastewater treatment system is undertaken within an existing shed.

Key Findings:

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

24. There are a number of potential receptors for noise emissions including residential properties and commercial properties. For the purpose of this assessment the nearest resident will be considered the most affected receptor.

25. There are no records of noise complaints attributable to the Premises.

Consequence

The Delegated Officer has determined that based on the sensitivity of the nearest residential receptor, and potential 24 hour operation, the impacts of noise emissions may result in specific consequence criteria (for public health) being at risk of not being met. Therefore, the Delegated Officer considers the consequence to be Moderate.


The Delegated Officer has determined that based on the sources of noise and operations occurring predominantly within a shed, the likelihood of impacts to amenity from noise emissions will probably not occur in most circumstances. Therefore, the Delegated Officer determines the consequence to be Unlikely.

Overall rating

The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 14) and determined that the overall rating for the risk of noise impacts on sensitive receptors during operation is Medium.

8.6 Risk Assessment – Liquid waste runoff and fire water run-off impact

General hazard characterisation and impact

There are no point source emissions of wastewater to surface water, groundwater or land associated with the operation of this Premises. However, emissions of controlled waste (liquid waste) may occur from the following sources and result in overland flow to soil and surface water and seepage into groundwater:

• Spillages of liquid waste at the Premises;

• Contaminated stormwater runoff;

• Tank, hardstand and bunding failure (containment failure); and

• Overflow of bunded areas.

Emissions of liquid wastes and leachates (including contaminated stormwater) from the Premises may contain heavy metals, chemicals and hydrocarbons. Contaminants from the liquid waste accepted on-site will vary considerably and may be toxic and persistent within the environment (resistant to environmental degradation).

Emissions of liquid waste directly onto the soil and land within the Premises or directly adjacent

50



may result in seepage and contamination of groundwater or overland flow to drainage reserves. The soil at the Premises has a hydraulic conductivity between 100-1000 mm/day which is highly variable. The depth to groundwater is approximately 12.0 metres (relative to ground level).


The Licence Holder’s primary control to reduce and manage liquid waste and leachate emissions is that approximately 60% of the site is situated on a concrete hardstand with bunding and collection sumps.

Key Findings:

The Delegated Officer has reviewed the information regarding the impacts on land from liquid wastes from the Premises and has found:

26. The acceptance, storage and treatment of liquid waste has the potential to impact soil and groundwater if not appropriately contained. Foreseeable events such as spills and containment failure also have the potential to impact on soil and groundwater.

27. DWER officers have observed that there is insufficient bunding on-site and some of the bunding has cracking in the hardstand which may compromise the integrity of the hardstand.

28. DWER Officers noted during a site visit that Area 5 is on a concrete hardstand but has no bunding on the eastern boundary.

29. DWER Officers noted during a site visit that the mixing of sludge with sawdust occurs within Area 4.

30. A portion of the site that is used for the site office also contains numerous IBC’s and chemicals that are not on a concrete hardstand and not bunded.

31. During a site visit, DWER Officers noted that pipes from storage tanks leading into the shed and wastewater treatment system are located outside of the bunding.

32. The Licence Holder has an obligation to comply with the Environmental Protection (Unauthorised Discharges) Regulations 2004 (UDR’s) which prohibit materials listed in Schedule 1 of the UDR’s to be discharged to the environment.

33. The Premises is already classified as ‘Possibly contaminated – investigation required’ under the CS Act.

51



Consequence

Based upon the numerous hazardous chemicals received on-site the Delegated Officer has determined that the impact to the Premises and adjoining land, surface water and groundwater will be mid-level off-site impacts on a local scale and therefore the Delegated Officer considers the consequence to be Moderate.


Based upon the Licence Holder’s controls, including failure to store contaminants on bunded hardstand areas, and cracks identified in the hardstand, the Delegated Officer has determined that the likelihood of Moderate impacts will be Likely.

Overall rating

The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 14) and determined that the overall rating for the discharge of liquid waste to land is High.

8.7 Risk Assessment – Emissions to air in the event of a fire /explosion

General hazard characterisation and impact

Inappropriate storage, treatment and consolidation (mixing) of liquid wastes can result in adverse chemical reactions taking place which may lead to an explosion or fire incident at the Premises.

Explosions and fires can emit toxic air emissions and fine particulates that are able to travel into the lungs presenting acute or chronic health impacts for nearby receptors. Amenity impacts from visible fire plume and deposition of material on vehicle dwellings and clothing may also occur.

Toxic air emissions and particulates from fire or explosion may travel through the air and depending on the climatic conditions at the time of the event, may result in health impacts being experienced by individuals located 46 m north of the Premises.

Criteria for assessment

There are no set threshold or concentration criteria for emissions to air in the event of a fire and/or explosion.

Under section 49(5) of the EP Act, it is an offence to emit or cause to be emitted, an unreasonable emission from any premises. An unreasonable emission is defined in the EP Act (section 49(1)) as an emission or transmission of noise, odour or electromagnetic radiation which unreasonably interferes with the health, welfare, convenience, comfort or amenity of any person.


The Licence Holder stated that the pH of the liquid waste being accepted is tested testing on-site by the Licence Holder prior to acceptance.

Key Findings:

The Delegated Officer has reviewed the information regarding the particulates and noxious gases from fire / explosion from the Premises and has found:

34. Pre-acceptance protocols must ensure that wastes are adequately characterised to prevent in-compatible waste types from being accepted.

52



35. Waste compatibility must be determined prior to consolidation (mixing) and/or treatment.

36. The Licence Holder has limited procedures in place to verify waste acceptance / types (pre-acceptance sales process and testing)

Consequence

Based on the distance to the nearest receptor the Delegated Officer has determined that the impact could have adverse health effects of noxious gases and particulates from fires / explosion at the Premises. Therefore the Delegated Officer considers the consequence to be Severe.


Based upon the Licence Holder’s controls the Delegated Officer has determined that the likelihood of impacts from fire / explosion will probably not occur in most circumstances. Therefore the Delegated Officer considers that the consequence to be Unlikely.

Overall rating

The Delegated Officer has compared the consequence and likelihood ratings described above for the Risk Criteria (Table 14) and determined that the overall rating for the risk of fire / explosion impacts on sensitive receptors is High.

53



8.8 Summary of acceptability and treatment of Risk Events

A summary of the risk assessment and the acceptability or unacceptability of the risk events set out above, with the appropriate treatment and control, are set out in Table 18 below. Controls are described further in section 9.

Table 18: Risk assessment summary

Emission Pathway and Receptor

Applicant controls

Risk Rating

Acceptability with treatment (conditions on instrument)

Type Source

1. Noise Vehicle movements and equipment

Airborne to nearest residential area 46m north of the Premises.


N/A Moderate

Unlikely

Medium

Acceptable, generally subject to regulatory controls.

No controls are proposed – EP Noise Regulations acceptable

2 Odour WWTS Airborne to nearest residential area 46m north of the Premises.


See Strategen’s Odour Remediation Plan (Appendix 8)

Moderate

Possible

Medium



Moderate

Possible

Medium


Truck washout Moderate

Possible

Medium


3. Liquid waste discharge

WWTS


Truck washout

Storage / containment

Fire water run-off

Direct spills / seepage to ground (land)

Approximately 60% of the site is on a concrete bunded hardstand

Moderate

Likely

High

May be acceptable. Subject to multiple regulatory controls

4. Explosion / fire risk

Storage and mixing of non-compatible waste materials

Airborne to nearest residential area 46m north of the Premises.


Testing of pH Severe

Unlikely

High

May be acceptable. Subject to multiple regulatory controls

54



9. Regulatory controls

A summary of regulatory controls determined to be appropriate for the Risk Event is set out in Table 19. The risks are set out in the assessment in section 10 and the controls are detailed in this section. DWER will determine controls having regard to the adequacy of controls proposed by the Licence Holder. The conditions of the Revised Licence will be set to give effect to the determined regulatory controls.

Table 19. Summary of regulatory controls to be applied

Controls

(references are to Sections below setting out details of controls)

9.1

Waste

ch

ara

cte

risati

on

9.2

Accep

tan

ce a

nd

thro

ug

hp

ut

restr

icti

on

s

9.3

Waste

typ

e

restr

icti

on

s a

nd

cla

ssif

icati

on

9.4

Waste

pro

cessin

g

9.5

In

frastr

uctu

re a

nd

eq

uip

men

t

9.6

Op

era

tio

na

l

co

ntr

ols

9.7

Tre

ate

d w

aste

wate

r

mo

nit

ori

ng

9.8

Rep

ort

ing

Ris

k Ite

ms

(see r

isk a

naly

sis

in

Secti

on

8)

1. Odour from waste handling and storage

• • • • • •

2. Seepage and runoff from spills and containment failure

• • • • • • •

3. Explosion/ fire risk from storage and mixing of incompatible wastes

• • • • •

55



9.1 Waste characterisation

The Licence Holder is required to ensure that liquid wastes are adequately characterised prior to entering any treatment process to prevent incompatible waste types being mixed in the treatment process.

Grounds: This Review has found that the current and proposed controls submitted by the Licence Holder are insufficient. The control proposed are deemed necessary due to the high risk of air emissions in the event of a fire / explosion.

9.2 Acceptance and throughput restrictions

The Licence Holder shall be subject to total annual mass limitations of throughput of 40,950 tonnes of liquid waste.

The Licence Holder will be required to record the type and volume of waste incoming and out-going from the Premises. This will inform DWER on how much waste has been accepted at the Premises in accordance with the conditioned throughput limits.

Grounds: This Review has been carried out due to a number of odour issues at the Premises and an increase of throughput would increase the risk associated with odour and potentially increase the likelihood of seepage and runoff from spills and containment failure.

The Licence Holder is currently licensed to accept 40,950 tonnes per annual period and DWER has issued an EPN for the Licence Holder to cease the operation of waste treatment and processes not authorised under Licence L8730/2013/1. Therefore the throughput limit has remained the same as the current Licence.

9.3 Waste type restrictions and classification

The Licence Holder must only accept those waste types that are authorised under the current Licence. The Licence Holder must comply with a number of acceptance criteria including that wastes must either be tankered onto the Premises or delivered in intermediate bulk containers (IBC).

The Licence Holder will not be authorised to accept solid waste.

Grounds: This Review has been carried out due to a number of odour issues at the Premises, the types of wastes accepted and processed on site will impact the risk associated with odour.

DWER has issued an EPN for the Licence Holder to cease the operation of waste treatment and processes not authorised under Licence L8730/2013/1. Therefore the waste accepted has remained the same as the current Licence.

9.4 Waste processing

The Licence Holder will be permitted to only accept and treat liquid waste which consists of acids, alkalis, paints and resins, waste oils, oily water, industrial wash water, non-halogenated organic chemicals (engine coolants), (refer to Section 9.2) for physiochemical processing (separation, electro-coagulation, ozone and reverse osmosis) and physical storage prior to on-site discharge to Water Corporation sewer or off-site disposal (refer to Section 4).

The Licence Holder will be permitted to accept and treat surfactants and detergents (wetting agents and emulsifiers) and Drilling mud (other than drilling mud contaminated with hydrocarbons) for handling, mixing and physical storage prior to removal off site to a licensed landfill.

The Licence Holder must ensure that all wastes received for consolidation and/or treatment shall be assessed by a suitably qualified person to ensure compatibility and to verify the required treatment level prior to formal acceptance.

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The Licence Holder must ensure that all liquid waste is accepted, receipted, consolidated, processed, stored and handled within the Premises which comprises a hardstand area capable of preventing surface run-on and run-off.

The Licence Holder shall ensure that IBC’s containing residual solid waste are only stored within the Premises which comprises a hardstand area capable of preventing surface run-on and run-off.

The Licence Holder is required to record and document how Liquid Waste Types are treated and to what extent.

Grounds: This Review has found that the current and proposed controls submitted by the Licence Holder are insufficient. The controls proposed are deemed necessary due to the high risk of odour emissions, air emissions in the event of a fire / explosion and risks of liquid waste runoff and seepage at the Premises.

9.5 Infrastructure and equipment

The Licence Holder will be required to maintain specified infrastructure and equipment for the storage and treatment of liquid wastes.

Infrastructure requirements within the Licence have been amended to be consistent with the infrastructure and processes installed as proposed by the Odour Remediation Plan.

The following condition has been included on the Licence and is considered improvement conditions that will require works undertaken by the Licence Holder:

• Within six months of the issued revised Licence, a bunded concrete hardstand with a permeability of at least 1x10-9 m/s. to be installed and operational.

Grounds: This Review has found that the odour emissions from the Premises prior to the issue of the EPN were unacceptable. The controls proposed by Strategen’s Odour Remediation Plan have been implemented and as such, have been included as licence conditions to mitigate odour emissions at the Premises. This Review has also found that the Premises does not have sufficient controls to prevent contamination of land and groundwater through liquid waste spills, therefore the entire site needs to be on a bunded hardstand.

9.6 Operational controls

The Licence Holder will be required to immediately clean any spills of liquid waste outside the hardstand area.

The Licence Holder will be required to discharge treated liquid waste to sewer and transfer solid waste to an appropriately licensed landfill.

Grounds: Operational controls have been imposed to ensure that any spills are cleaned immediately to prevent contamination of land or groundwater. Additionally liquid waste must only be discharged to sewer and solids wastes to landfill. Composting on site is not approved.

9.7 Treated wastewater monitoring

The Licence Holder will be required to monitor treated wastewater discharges to sewer and prior to removing solid waste off-site.

Grounds: Monitoring is currently being undertaken by the Licence Holder. Ongoing monitoring provides a useful tool to assess the effectiveness of the infrastructure on site.

9.8 Reporting requirements

The Licence Holder will be required to report waste acceptance and waste removed from the

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Premises quarterly.

Grounds: Reporting requirements have bene included to ensure appropriate information is submitted to assess impacts.

10. Determination of Licence conditions

The conditions in the revised Licence have been determined in accordance with the Guidance Statement: Setting Conditions.

Table 20 provides a summary of the conditions to be applied to this licence.

Table 20: Summary of conditions to be applied

Condition Ref Grounds

Waste acceptance and throughput restrictions – Condition 1

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

Pre-acceptance requirements – Condition 2

These conditions are valid, risk-based and contain appropriate controls (see Section 9 of this Decision Report)

Waste receipt – Conditions 3, 4, 5 and 7

Waste processing – Condition 7

Infrastructure and equipment – Conditions 8, 9 and 10

Operational controls – Conditions 11 and 12

Monitoring – Conditions 13 and 14

Records and reporting – Conditions 15, 16, 17, 18 and 19

These conditions are valid and are necessary administration and reporting requirements to ensure compliance.

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

11. Applicant’s comments

The Licence Holder was provided with the draft Decision Report and draft issued Licence on 30 March 2020. The Licence Holder provided comments on 22 May 2020, which are summarised, along with DWER’s response, in Appendix 2.

12. Conclusion

This assessment of the risks of activities on the Premises has been undertaken with due consideration of a number of factors, including the documents and policies specified in this Decision Report (summarised in Appendix 1).

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

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Appendix 1: Key documents

Document title In text ref Availability

1. 1 Licence L8730/2013/1 Fremantle Plumbing Service Pty Ltd

Licence accessed at www.der.wa.gov.au

2. 3 Environmental Protection Notice CEO182/18 EPN DWER records (A1627726)

3.

Australian Standards:

• AS 1940-2004. The storage and handling of flammable and combustible liquids;

• AS/NZS 3833:2007. The storage and handling of mixed classes of dangerous goods, in packages and intermediate bulk containers;

• AS/NZS 4452:1997.The storage and handling of toxic substances; and

• AS/NZS 4681:2000. The storage and handling of Class 9 (miscellaneous) dangerous goods and articles

AS1940

AS3833

AS4452

AS4681

Accessed at

https://www.saiglobal.com/online/

4.

Controlled Waste Disposals Odour

Remediation Plan, Prepared for Controlled

Waste Disposals by Strategen

Environmental, June 2018

ORP DWER records (A1662375)

5. 3 DER, July 2015. Guidance Statement: Regulatory principles. Department of Environment Regulation, Perth.

DER 2015a

accessed at www.der.wa.gov.au

6. 4 DER, October 2015. Guidance Statement: Setting conditions. Department of Environment Regulation, Perth.

DER 2015b

7.

DER, May 2016. Guidance Statement: Publication of Annual Audit Compliance Reports. Department of Environment Regulation, Perth.

DER 2016a

8. 5 DER, August 2016. Guidance Statement: Licence duration. Department of Environment Regulation, Perth.

DER 2016b

9. 6 DER, September 2016. Guidance Statement: Environmental Standards. Department of Environment Regulation, Perth.

DER 2016c

10. DER, November 2016. Guidance Statement: Environmental Siting. Department of Environment Regulation, Perth.

DER 2016d

11. DER, February 2017. Guidance Statement: Land Use Planning. Department of Environment Regulation, Perth.

DER 2017a

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

https://www.saiglobal.com/online/

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

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12. 7 DER, February 2017. Guidance Statement: Risk Assessments. Department of Environment Regulation, Perth.

DER 2017b

13. 8 DWER, June 2019. Guideline: Decision Making. Department of Water and Environmental Regulation, Perth.

DWER 2019a

14. 9

DWER, June 2019. Guideline: Industry Regulation Guide to Licensing. Department of Water and Environmental Regulation, Perth.

DWER 2019b

15. DWER, June 2019. Guideline: Odour emissions. Department of Water and Environmental Regulation, Perth.

DWER 2019c

16.

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

ANZECC /

ARMCANZ

2000

Accessed at:

http://www.agriculture.gov.au/SiteC

ollectionDocuments/water/nwqmsgu

ideline-4-vol1.pdf

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



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

Condition Summary of Licence Holder comment DWER response

1 (Table 1) The Licence Holder requests the inclusion of waste type J180 (oil sludge) and the inclusion of D300 given the equipment and methodology to process the waste. The exclusion of J180 in the previous Licence was an oversight and was always intended to be accepted at the Premises.

The comments state that “oil sludges can be accepted into Area 4 for leaching and treatment prior to being subject to solidification into a spadeable consistency”. The acceptance and treatment of J180 will be included within the Licence, consistent with the acceptance and treatment of other oil waste types for the Premises. As such, the processing of J180 will be in accordance with Table 2 of the licence.

The acceptance and treatment of D300 waste, being non toxic salts, has never been previously applied for, and as such, has not been assessed in this review.

2, 3, 4 and 5 The Licence Holder requests that Conditions 2, 3, 4 and 5 are deleted. The inclusion of these conditions, specifically the requirement for the assessments and verification of waste to be carried out by a suitably qualified Chemist, will impose significant restrictions and costs on the operation of the business, and will introduce additional and unnecessary administrative burden.

DWER accepts that the use of a suitably qualified Chemist may pose additional costs upon the Licence Holder. The intent of the condition, however, will remain with amendment to the qualified person definition, recognising that such measures are currently implemented at the Premises. As referenced in the Licence Holder’s DWER Compliance Procedure -Waste Liquids Receivals, provided to DWER on 22 May 2020, “other than pure product chemicals and laboratory chemicals, no wastes shall be accepted at the installation without sampling, checking, and testing being carried out.” Further, “(the) operator shall ensure that the installation personnel who may be involved in the sampling, checking and analysis procedures are suitably qualified (AQF

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qualified chemistry technician or higher) and adequately trained”.

As such, the condition is amended to replace suitably qualified Chemist with an Australian Qualifications Framework (AQF) Diploma level qualified chemistry technician or equivalent.

Existing condition 3 has been removed as existing condition 16 incorporates the maintaining of records.

9 (Table 3, Row 1) The Licence Holder requests that the requirement to install the bunded hardstand is extended from three months to six months in recognition of the fact that the operation is likely to move to another site within the same timeframe.

DWER allows the extension of the timeframe.

10 and 11 The Licence Holder requests that Conditions 10 and 11 are deleted as the requirement to have the hardstand approved by a suitably qualified Geotechnical or Civil Engineer is not relevant or appropriate the nature and specification of the new infrastructure.

The conditions have been amended to have the construction of the bunded hardstand certified by a suitably qualified expert, defined as a Building practitioner authorised under the Building Services Registration Act 2011.

13 The Licence Holder requests that Condition 13 is deleted as it seeks to regulate the off-site transfer and disposal of waste and not emissions or discharges from the Premises. As it stands, the condition is too restrictive; e.g. it prohibits the Licence Holder sending liquid waste to other licensed premises or the transfer of solid waste to facilities other than landfills.

The condition has been amended to allow the transfer of wastes to any facility licensed for the acceptance of that waste.

Decision Report 6.4 and Appendix 4

The Trade Waste Permit has been superseded with a new version.

The Trade Waste Permit and references have been updated.

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Decision Report 8.6.1 and 8.7.1

The Licence Holder requests that the references to an historic incident at a separate waste facility is removed from the risk assessment section of the Decision Report as the descriptions of the general hazard characterisation and impacts for the relevant risk events should be based on site-specific information.

DWER has removed such reference, noting that the assessment undertaken is site-specific. In applying the likelihood Criteria, DWER may have regard to previous experience of similar activities, as per Guidance Statement: Risk Assessments (February 2017).

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Appendix 3: Site plans

Site Layout Plan 1 – Identification of defined areas on-site

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Site Layout Plan 2 – Identification of tank infrastructure (existing and proposed)

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Site Layout Plan 3 - Wastewater treatment infrastructure in Area 1

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Appendix 4: Copy of Water Corporation Trade Waste Permit

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Appendix 5: DER Pollution Response Report

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Appendix 6: Environmental Protection Notice CEO182/18

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Appendix 7: Odour Remediation Plan

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101



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IR-T04 Decision Report Template · 2020. 6. 9. · L8730/2013/1 IR-T04 Decision Report Template...

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