environmental standard for composting - der.wa.gov.au · draft es, rather than in other documents....

PAPER

PAPER

Environmental Standard for composting

Consultation Paper

Version: Final

March 2016

Department of Environment Regulation

ii Consultation Paper: Environmental Standard for composting (March 2016)

Produced and published by Department of Environment Regulation 168 St Georges Terrace, Perth, Western Australia March 2016

Copyright © State of Western Australia 2016 All material is the copyright of the State of Western Australia. Permission is not given for any commercial use or sale of this material. No part of the contents of the publication may be reproduced by any process, electronic or otherwise, distributed, adapted, broadcast, performed in public or communicated to the public without the written consent of Department of Environment Regulation, except as permitted under the Copyright Act 1968.

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The State of Western Australia is committed to providing quality information and has made every attempt to ensure the accuracy, currency, reliability and correctness of the information contained in this document. However, changes in circumstances and legislation after the time of publication may impact on the correctness or quality of this information.

In addition the accuracy, currency, reliability and correctness of links or references to information sources referred to or provided by third parties is outside the control of State of Western Australia and it is therefore the responsibility of the user to make their own decisions on information found on those external sites. Confirmation of any of the information provided in this document may be sought from the relevant originating bodies or the department providing the information; however, users of this material should verify all relevant representations, statements and information with their own professional advisers.

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Questions regarding this report should be directed to:

Strategy and Reform Locked Bag 33 Cloisters Square PERTH WA 6850

Phone: +61 8 6467 5225 Fax: +61 8 6467 5562 Email: [email protected] Web: www.der.wa.gov.au

Accessibility This document is available in alternative formats and languages on request.

mailto:[email protected]

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


iii Consultation Paper: Environmental Standard for composting (March 2016)

Contents

1. Background ........................................................................................................... 1

2. Submissions.......................................................................................................... 1

3. Main Issues ........................................................................................................... 2

3.1.1 Application and Scope ................................................................................. 2

3.1.2 Definitions .................................................................................................... 2

3.1.3 Risk Based Approach and Outcomes .......................................................... 2

3.1.4 Reference to New South Wales and Victorian Guidelines ............................ 2

3.1.5 Siting and Separation Distances .................................................................. 2

3.1.6 Infrastructure ............................................................................................... 3

3.1.7 Leachate Storage Capacity .......................................................................... 3

3.1.8 Septic and Sludge Acceptance .................................................................... 3

3.1.9 Contaminants in Feedstock.......................................................................... 3

3.1.10 Composting Method .................................................................................... 4

3.1.11 Groundwater Monitoring ............................................................................. 4

3.1.12 Pathogen Limits .......................................................................................... 4

3.1.13 Product Specifications and AS 4454 ........................................................... 4

4. Procedural and implementation issues .............................................................. 5

5. Technical inputs .................................................................................................... 5

5.1 Department of Water ................................................................................................ 5

5.2 Department of Agriculture and Food ........................................................................ 5

6. Responding to this Consultation ......................................................................... 5

Appendix 1 ................................................................................................................... 6


1 Consultation Paper: Environmental Standard for composting (March 2016)

1. Background

The draft Environmental Standard: Composting (draft ES) was released for public consultation in June 2015.

Since the release of the draft ES, a stakeholder working group was formed to discuss issues arising from the draft ES. DER convened four workshops with the stakeholder working group from September to November 2015.

Between November 2015 and February 2016, DER also liaised and obtained technical input from the Department of Water (DoW) and the Department of Agriculture and Food, Western Australia (DAFWA).

The public consultation period for the Draft ES closed on 30 November 2015. For the submissions received (see below), DER thanks all respondents for taking the time to respond to the consultation.

Having considered the issues raised, inputs from DOW, DAFWA and the comments made in the public consultation process, a revised draft ES has been prepared.

This Consultation Paper sets out the main changes in the revised draft ES. A table comparing the revised draft ES with the original draft ES (June 2015) is set out in Appendix 1.

2. Submissions

In addition to the stakeholder working group (comprising representatives of approximately 14 organisations), submissions were also received from the following:

Australian Pork Limited

Australian Chicken Meat Federation Inc. and Australian Egg Corporation Limited

Bioscience Pty Ltd

Bunbury Harvey Regional Council

ChemCentre

City of Kwinana

Department of Health

Eastern Metropolitan Regional Council

Western Australian Local Government Association

Waste Management Association of Australia

Shire of Murray

Southern Metropolitan Regional Council

West Australian Pork Producers Association Inc

Water Corporation



3. Main Issues

Set out below is a summary of the main issues arising from the public consultation submissions and how DER has responded to the issues. Each submission has also received an individual response from DER. Submissions and responses will be available on DER’s webpage.

3.1.1 Application and Scope

Submissions requested clarification of the application and scope of the draft ES.

DER confirms that the ES will apply to all prescribed premises in Category 67A of Schedule 1 to the Environmental Protection Regulations 1987 (Regulations) on which organic material (excluding silage) or waste is stored pending processing, mixing, drying or composting to produce commercial quantities of compost or blended soils and have a production or design capacity of 1,000 tonnes or more per year and includes premises which undertake composting as an ancillary process.

The ES does not apply to other industries, commercial operators or residential premises that may carry out some composting activities but are under the production or design capacity threshold of 1,000 tonnes per year.

Contributory activities that contribute to the nature and type of emissions from the primary activity may be subject to conditions in works approvals and licences for prescribed premises in accordance with DER’s draft Guidance Statement: Licensing and works approvals process.

3.1.2 Definitions

Submissions suggested defined terms be included.

DER has revised the draft ES to include a definitions section.

3.1.3 Risk Based Approach and Outcomes

Submissions queried the Draft ES with DER’s risk-based approach and the use of prescriptive language.

DER has developed a standard, not a guideline as other jurisdictions have developed, hence the stricter wording. DER has however, revised the draft ES to present a risk-based approach to requirements and to include environmental objectives and examples of ways to achieve those objectives. Additionally, variation from the specified requirements is possible as described in the Department’s Guidance Statement: Environmental Standards.

3.1.4 Reference to New South Wales and Victorian Guidelines

Submissions were made as to the application of guidelines from other jurisdictions to the Western Australian context.

The draft ES has been revised following input from DoW and DAFWA to ensure consideration of the Western Australian context.

3.1.5 Siting and Separation Distances

Submissions raised concerns as to the siting and separation distance requirements.

DER has amended the draft ES to specify separation distances to sensitive receptors in the draft ES, rather than in other documents. DER notes that where facilities do not meet siting and location requirements to specified ecosystems (eg wetlands), additional regulatory controls may then be required to works approvals and licences to manage risks.



3.1.6 Infrastructure

Submissions were made that the infrastructure controls are too conservative.

DER has reviewed these controls and they have now been amended to reflect a risk-based approach to requirements.

DER has revised the Draft ES to focus on desired environmental outcomes with specific technical design criteria provided as examples to guide new facilities.

3.1.7 Leachate Storage Capacity

Submissions were received as to the appropriateness of the leachate storage capacity specified.

DER has revised the draft ES to specify a reduced containment volume, sufficient to contain a 1 in 20 year storm event (24 hour duration), based on 100% runoff from the leachate collection area.

DER acknowledges that normal run-off from a hardstand would be less than 100% in most circumstances, except in extreme rainfall events. DER has taken this into consideration in determining the reduction of the required leachate storage capacity.

3.1.8 Septage and Sludge Acceptance

Submissions were made regarding the acceptability of sewage, septic and sludge as feedstocks.

DER has amended the draft ES to clarify the following:

untreated septage and sludge refers to untreated waste from septic tanks (commonly referred to as sewage) and is not acceptable as a feedstock (including where dewatering but no treatment has occurred);

treated septage and sludge refers to waste from septic tanks or waste water treatment plants which has undergone treatment to a level to significantly reduce pathogens and microorganisms, and includes biosolids (meaning sludge which has been treated (eg by liming or anaerobic digestion) and then dewatered); and

dewatering refers to waste which has moisture content removed.

DER in considering the risk to public health and the environment, has not amended Section 6.1 of the draft ES as it relates to prohibiting raw sewage and raw septic tank waste. The draft ES has been amended to refer to untreated septage and sludge and to clarify these terms.

DER considers that dewatered untreated sewage remains an unacceptable feedstock as although there is less moisture content, it is still untreated sewage. Table 4 of the draft ES has been amended by removing dewatered sewage from the feedstock risk categories.

The inclusion of treated septage and sludge and clarification of these terms are now specified in Table 4.

In circumstances where an unacceptable feedstock is considered for processing, a licensee may, on a case-by-case basis, seek to have the feedstock assessed for approval by the CEO.

3.1.9 Contaminants in Feedstock

Submissions sought clarification on the use of the term “contaminant”.

A contaminant is a substance or object in contact or mixed with a material that poses a risk of harm to human health or the environment.



3.1.10 Unacceptable Feedstocks

Submissions were received regarding the feedstock classifications in the draft ES.

DER has amended the draft ES to reflect the suggested definition for hazardous waste; redrafted Section 6.1 to clarify that operators cannot accept loads entirely made up of materials listed in Section 6.1; and removed the reference to ‘limits on volumes of feedstock to be accepted’ from Section 6 of the Draft ES.

In considering the risk to public health and the environment, DER has not amended Section 6.1 of the Draft ES as it relates to prohibiting raw sewage and raw septic tank waste.

3.1.11 Composting Method

Submissions were received as to the restrictive specification of the composting method.

DER has amended this section in the revised draft ES and has referred more generally to additional controls being required rather than specifying composting methods or operations.

3.1.12 Groundwater Monitoring

Submissions were made regarding the appropriateness of the approach to groundwater monitoring.

DER has revised the groundwater monitoring requirements to include a two tiered monitoring approach. The first tier is based upon ‘in field’ monitoring to provide early warning triggers for more detailed monitoring and the second tier is based on a case-by-case site assessment, implemented via the site licence.

3.1.13 Pathogen Limits

A number of submissions queried the pathogen limits.

Subsequent to the advice from DoW , DER has removed the testing requirements for Helminth ova (Ascaris sp. and Taenia sp.) and enteric viruses and replacing these with Helminth viable ova (Strongyloids and hookworm) and coliphages.

DER considers it necessary for the end product to be tested for pathogens to ensure that unacceptable public health and environmental risks are mitigated. DER has updated this section of the draft ES in accordance with advice from DoW.

DER advises that the limits have been obtained from the AS 4454-2012 standard, not National Environment Protection Measures.

DER has amended the draft ES in relation to contamination limits.

3.1.14 Product Specifications and AS 4454

Submissions were made as to the appropriate use of AS 4454 in the draft ES.

DER has noted that AS 4454 does not cover all types of composted product.

The draft ES has been revised to clarify that all materials produced from composting facilities will be considered as materials. A Product refers to a material that meets the Product Standards in the ES. The draft ES has been amended to clarify that the Product Standards must be met for material that is intended to be, or is available to be, sold to small retail customers (being non-commercial customers who purchase less than 5m3 of product in a single transaction).

DER is of the view that large customers can appropriately manage product specification through their contractual arrangements with the compositing facility.



4. Procedural and implementation issues

Submissions were received regarding procedural and implementation issues.

DER advises that a review period of 5 years has been included in the revised draft ES.

DER acknowledges the need to ensure that its officers are trained before and during the implementation of the ES to ensure that a consistent risk-based approach to regulation is administered.

DER will ensure that existing facilities will be assessed on a case-by-case, risk-based approach, to determine the environmental performance of the facility and whether changes are required.

5. Technical inputs

DER has finalised the revised draft ES with technical input from experts within DoW and DAFWA. DER thanks the officers from these Departments for the timely advice and support provided.

5.1 Department of Water

DoW provided input on all sections of the revised draft ES. DER especially notes the technical input provided for the sections regarding risks to groundwater and permeability requirements.

5.2 Department of Agriculture and Food

DAFWA provided general input on the revised draft ES. DER especially notes the input provided in relation to soil types and permeability.

6. Responding to this Consultation

DER seeks input on any aspect of the revised draft ES. Feedback received during consultation will be considered in the finalisation of the ES after the consultation period has ended.

Responses must be received by 6 June 2016.

Please return comments:

by email to: [email protected] with the words “Environmental Standard Composting” in the subject line or

by post to: Environmental Standard Composting Consultation Department of Environment Regulation Locked Bag 33 CLOISTERS SQUARE WA 6850

mailto:[email protected]



Appendix 1

Section No Amendment

1. Purpose

Include the intended audience for the ES.

Include clarification of when the ES applies (may also apply to agricultural facilities where the threshold for Category 67A is breached): This document applies to all prescribed premises where the threshold for category 67A is met.

Include Contamination of soil as a potential risk.

Include Contamination of surface water as a potential risk

Insert public heath as follows: This Environmental Standard sets out the minimum standards that apply to composting facilities under the following categories of regulatory control, in order to reduce environmental and public health risks to an acceptable level.

Include (e) monitoring: tier 1 and tier 2 groundwater monitoring and surface water monitoring and remove sentence ‘This ES sets out standards for groundwater monitoring’

Glossary of definitions to be included in section 1.1. Move existing definitions in document to section 1.1

1.1 Definitions Include definition for commercial waste: all waste other than domestic waste is classified as commercial

Definition of compost and composting to be revised to include the unintentional anaerobic processes which may occur during aerobic composting.

Include definition for contaminant: Contaminant means any substance or object in contact or mixed with a material that poses a risk of harm to human health or the environment (Taken from the Western Australian guidelines for biosolids management, 2012, DEC)

Include definition for contaminated organic waste

Include definition for domestic waste

Revise definition for hazardous waste as follows: Hazardous waste means waste which by its characteristics poses a threat or risk to public health, safety or the environment (includes substances which are toxic (including mutagenic, carcinogenic and teratogenic, infectious, explosive, flammable, corrosive, oxidising and radioactive)

Include definition for hydraulic conductivity

Include definition for Natural Geological Barrier (NGB)

Include definition for quarantine waste

Include definition for contaminated organic waste

Include definition for domestic waste

2. Application Clarify the application of the ES as per the Guidance Statement Environmental Standards so that the ES is a standalone document.

3. Acknowledgements Acknowledgement to the Composting Industry Working Group to be included.

4. Siting requirements Revise the design and siting standards to ensure they correlate with the risk posed to the environment.

Revise section 4 to mirror the format of Rural Landfill ES with the following headings:

Excluded locations;

Separation distances;

Risk to Groundwater (risk-based assessment for infrastructure requirements); and

Stormwater and Surface Water.




4.1 Excluded locations Amend text as follows: (a) Priority 1 and Priority 2 Public drinking water source areas (i.e.

catchment areas, water reserves or underground water pollution control area proclaimed under the Country Areas Water Supply Act 1947 or Metropolitan Water Supply and Sewerage Drainage Act 1909;

(b) the projected 1 in 20 (5%) AEP flood extent; or (c) within the portion of the 1 in 100 (1%) AEP floodplain that would

detrimentally affect the existing flooding regime (i.e. raise flood levels).

(Note. The term 1 in 100 annual exceedance probability flood (or 1% AEP) is also referred to as the 100 year average recurrence interval flood (100 year ARI). This flood has a 1% chance of being equalled or exceeded in any year)

Revise to ensure consistency with relevant State Planning Policies (revised as per DoW table of advice).

Water supply area – definition to be clarified as per DoW advice. (excluded locations section)

Include details as to how this applies to existing facilities located in these areas. Where separation distances are not met, the applicant will be required to demonstrate that sufficient controls are in place to mitigate the risk to an acceptable level.

4.2 Separation distances

Maximum seasonal groundwater to be updated to 3m (vertical separation) from the base of any infrastructure to the highest historic water level.

500m Separation distance from any domestic potable groundwater well/bore to be reduced to 300m and include any surface water sources that supply drinking water.

Change Guidance for the Assessment of Environmental Factors: Separation Distances between Industrial and Sensitive Land Uses, Environmental Protection Authority of Western Australia, June 2005 to Guidance Statement: Separation Distances, Department of Environment Regulation and change environmental receptor to sensitive land use

Separation distances of 250metres relating to greenwaste composting has been removed. ‘Greenwaste composting’ is not considered to be composting by DER so has been removed from the ES.

Reference to additional controls required where separation distances are not met. Included the following statement: “Where separation distances are not met, the applicant will be required to demonstrate sufficient controls are in place to mitigate the risk to an acceptable level” A risk-based approach has been included for infrastructure requirements (composting hardstand and leachate requirements) and operational requirements.

5. Infrastructure Update infrastructure specifications to reflect a risk-based approach to requirements (10

-9 not required in all circumstances). Section has been

revised to be incorporated into the location and siting section.

Revise infrastructure requirements including examples reflecting the WA context.

Include statement: Where alternatives to examples for achieving permeability are proposed, testing and expert reports may be required to demonstrate that the infrastructure will meet the permeability requirements.

Remove the requirement for greenwaste feedstock and all of F1 category from being stored on a hardstand as this are of low risk.




5.1 Composting Hardstand

Amend text as follows: Performance standard: composting hardstands should avoid risk of contamination to the surrounding environment.

Beneficial water:

Classification TDS Groundwater Value

G1 <1500 mg/L Drinking water

G2 1500 – 7000mg/L

Non-potable

G3 Greater than 7000mg/L

Other (eg. saline, hypersaline)

Include 5 risk categories for the depth to groundwater in alignment with the DRASTIC vulnerability mapping as below:

Risk category Depth to groundwater

W1 Very high 3 metres or less

W2 High 3 – 10 metres

W3 Moderate 10 – 25 metres

W4 Low 25 – 30 metres

W5 Very Low 30 metres or greater

Soil categories

Risk Category

Soil type

Very high Fine to course gravel

High Fine to coarse sand, karstic limestone or fill

Moderate Silt, limestone, sandstone, clayey sand, vesicular basalt or fractured rock

Low Sandy clay, unjointed sandstone or weathered/fractured crystalline rock

Very Low Clay, shale or unfractured crystalline rock

The following risk matrix has been included and specific design requirements specified.

Groundwater risk category

W1 W2 W3 W4

So

il r

isk c

ate

go

ry

S1 Very high Very high

High High

S2 Very high High High Moderate

S3 High High High Low

S4 High High Moderate Low

S5 Moderate Moderate Low Very Low




Drainage standard revised to read:

Hardstand must have a minimum 1% (1:100) drainage gradient to ensure the free drainage of all leachate to the leachate collection infrastructure.

Drainage infrastructure must be of at least berm and swale (or other structures) of a suitable standard to prevent run-on and run-off of surface water, including a 1 in 20 year storm event (20 year ARI) of 24 hours duration.

Table 2 - Reword design and construction standard for liners to “…without compromising the integrity of the liner…” removing the words ‘distortion, cracking or otherwise’.

Include gradient ratio in Table 2 (Drainage) in addition to percentage gradient.

Change the gradient to >1% (1:100)

Last paragraph (and throughout ES) - refer to hydraulic conductivity where impervious materials are described.

Risk based approach to leachate requirements included based on the risk to groundwater and surface water and feedstock risk categories.

5.2 Leachate collection system

Include “surface water must be diverted so that it does not come in contact with feedstock”

Reword performance standard as follows: (a) Any surface water or stormwater that comes into contact with

feedstock, compost windrows or completed compost/product is collected and directed as leachate;

Requirement has been removed and performance centre updated.

5.3 Leachate storage infrastructure

Requirement for sediment/detritus trap to be removed

Table 3 - Remove the batter slope specification for ponds

5.4 Leachate storage capacity

Change ‘and’ to ‘or’ in respect of the minimum capacity to store the total of…

The leachate storage pond capacity has been reduced to contain a 1 in 20 year (24 hour) rainfall event.

5.6 Construction quality assurance (CQA)

CQA section to be removed. To be addressed in works approval instruments.

6. Operating methods Remove (b) ‘limits on volumes of feedstock to be accepted’

6.1 Unacceptable feedstock

Redraft to clarify that operators cannot accept loads entirely dedicated to materials in section 6.1. Include clarification that the classification of feedstocks in sections 6.1 and 6.4 are a general approach to classification of waste as many waste streams contain small amounts of waste from various other classifications to the bulk of waste.

6.4 Composting method

Table 4 – Two options to be included for municipal source separated kerbside waste (controlled) and (not controlled)

Table 4 – Controlled greenwaste kerbside collections to be moved to low risk with garden and landscape organics.

Table 4 - Include ‘partially treated sludge’ as a waste type in the MEDIUM risk category.

Table 4 – Move biosolids to the medium-high risk category

Table 4 – Remove reference to ‘dry matter greater than 35% from the Biosolids and aged manure waste type.

Remove meat from F3 – mixed source separated kerbside garden waste/food waste and change to ‘other food scraps’

Composting method revised to two columns ‘open environment’ and ‘controlled environment or additional controls’




6.5 Liquid waste Insert new feedstock risk category for liquid waste. Liquid waste may only be accepted where the following can be satisfied:

1. It is of benefit to the biological process contributing to making the compost and

2. The quantity ratio can be specified.

7. Products Clarify how the Draft ES will apply to restricted use composts and that the product standards in the ES allow composting to be sold for unrestricted use.

Section revised to refer to material specifications. Product only where AS4454 requirements are met, otherwise considered a material.

Delete reference to US and retain reference to AS 4454.

7.2 Pathogen and contamination limits

Remove noxious weeds from Table 6: pathogen limits and insert into a separate table.

Table 6. Pathogen limits Replace Helminth Ova (Ascaris sp. and Taenia sp.) and Enteric Viruses with Helminth viable ova (Strongyloids and Hookworm) and coliphages, matching the WA Biosolids Guidelines.

Table 7 – The annotation of the limit for PCBs has been amended to <0.2mg/kg.

8. Groundwater monitoring

Include requirement for a hydrological engineer or competent person to determine the position, depth and location of monitoring bores only for Tier 2 monitoring.

Requirement to undertake all water quality analysis by a laboratory accredited by NATA for the specific parameters is to include an exclusion where special circumstances may exist (e.g. NATA laboratories are not available in Australia for testing some of the parameters). Only for Tier 2 monitoring.

Tier 2 monitoring is triggered where a 10% change in background levels is detected.

Include ‘material’ in the outcome as below: The composting facility is not to change the material background levels in the existing environment.

Include a risk-based two tiered approach to groundwater monitoring.

Tier 1 suggested in-field monitoring parameters – pH, electrical conductivity, total nutrients (N and P), temperature and REDOX potential.

Include units for parameters in Table 8 – Groundwater and surface water monitoring

9. Transition A new section to be included relating to the transition of existing facilities and how the ES will be applied to these facilities.

Bibliography A bibliography of references used to inform the Draft ES to be included.

Review period Include a period for review of the final ES – 5 years.

General Include linkages to DER and other government documentation where appropriate. Reference links to documents to be included before release

Use a risk and outcome based approach to requirements.

Use examples of requirements that are relevant to WA.

Revise Draft ES to ensure consistent use of terminology and definitions throughout.

environmental standard for composting - der.wa.gov.au · draft es, rather than in other documents....

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