waste oil recycling oil co ( aust ) pty ltd... · environmental assessment report hagen oil, oil...

ENVIRONMENTAL ASSESSMENT REPORT

Waste Oil Recycling

8 Venture Court, Invermay

Gourmet Oil Company (Australia) Pty Ltd Trading as Hagen Oil

Board of the Environment Protection Authority

July 2014

Environmental Assessment Report Hagen Oil, oil recycling facility, Venture Court, Invermay

I

Environmental Assessment Report

Proponent Gourmet Oil Company (Australia) Pty Ltd

Proposal Oil Recycling Facility

Location 8 Venture Court Invermay

NELMS no. 9013

Permit application no. DA0434/2013

Folder EN-EM-EV-DE-238586

Document. H279694

Class of Assessment 2A

Assessment process milestones

5/11/13 Permit application submitted to Council

3/12/13 Application received by Board

16/1/14 EER Guidelines issued

10/5/14 Start of public consultation period

26/5/14 End of public consultation period

13/6/14 Supplementary information submitted to Board

Acronyms

Board Board of the Environment Protection Authority

EER Environmental Effects Report

DPIPWE Department of Primary Industries, Parks, Water and Environment

EIA Environmental impact assessment

EMPC Act Environmental Management and Pollution Control Act 1994

EMPCS Environmental management and pollution control system

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)

LUPA Act Land Use Planning and Approvals Act 1993

PCB, PBB Polychlorinated and polybrominated biphenyls

RMPS Resource management and planning system

SD Sustainable development


II

Report summary

This report provides an environmental assessment of Gourmet Oil Company (Australia) Pty Ltd’s, trading as Hagen Oil (Hagen Oil) proposed oil recycling facility at 8 Venture Court, Invermay. The proposal involves the separation of oil product from waste mineral oil and oil water mixtures by passive settlement and concentration. This report has been prepared based on information provided by the proponent in the Environmental Effects Report (EER) and EER Supplement. Relevant government agencies and the public have been consulted and their submissions and comments considered as part of this assessment. Further details of the assessment process are presented in section 1 of this report. Section 2 describes the statutory objectives and principles underpinning the assessment. Details of the proposal are provided in section 3. Section 4 reviews the need for the proposal and considers the alternatives to the proposal. Section 5 summarises the public and agency consultation process. The detailed evaluation of environmental issues is contained in section 6. The report conclusions are contained in section 7. Appendix 1 contains details of comments made and issues raised in the consultation process. Appendix 2 contains the environmental permit conditions for the proposal. Attachment 2 of the permit conditions contains the table of commitments from the EER.

Table of Contents

1 Approval process ..................................................................................... 1

2 SD objectives and EIA principles .............................................................. 1

3 The proposal ............................................................................................ 2

4 Need for the proposal and alternatives ..................................................... 6

5 Public and agency consultation ................................................................ 6

6 Evaluation of environmental issues .......................................................... 7

7 Report conclusions ................................................................................. 13

8 Report approval...................................................................................... 13


1

1 Approval process

An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Launceston City Council on 5 November 2013. The proposal is defined as a ‘level 2 activity’ under clause 1(c), schedule 2 of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being the conduct of works at which used oil is refined or reprocessed by filtration and separation. Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The application was received by the Board on 3 December 2013. The assessment has been undertaken by the Director, Environment Protection Authority under delegation from the Board. The Board required that information to support the proposal be provided in the form of an Environmental Effects Report (EER). Several drafts of the EER were submitted to the EPA Division for comment prior to its finalisation and acceptance on behalf of the Board. The EER was released for public inspection for a 14-day period commencing on 10 May 2014. An advertisement was placed in The Examiner newspaper and a notice was published on the EPA website. The EER was also referred at this time to relevant government agencies for comment. Three public submissions in support of the proposal were received. On 6 June 2014, the Board requested that the proponent submit supplementary information to address Council comments on the EER. Satisfactory supplementary information was submitted by the proponent on 13 June 2013.

2 SD objectives and EIA principles

The proposal must be considered by the Board in the context of the objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) (both sets of objectives are specified in Schedule 1 the EMPC Act). The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to further the RMPS and EMPCS objectives. The Board must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment Principles defined in Section 74 of the EMPC Act.


2

3 The proposal

Hagen Oil proposes to produce a maximum of 2900 tonnes of oil product per annum at 8 Venture Court, Invermay (Figure 1). The site currently is a vacant lot. It is proposed to construct an enclosed shed with a bunded floor within which the activity is to be conducted (Figure 2). The shed floor is to be divided into 3 separately bunded areas, each with a blind sump. These areas are a vehicle loading bay, a processing area and a storage area. The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section B of the EER. Table 1: Summary of the proposal’s main characteristics

Activity

The filtration and separation of a maximum of 2900 tonnes of oil product per year from waste oil, oil/water mixtures and oil contaminated materials.

Location and planning context

Location 8 Venture Court, Invermay.

Land zoning EER states light Industrial (Launceston interim planning scheme map shows the area to be zoned General Industrial).

Land tenure Private land.

Existing site

Land Use Site is an in-filled flood plain, previously used for bus parking.

Topography Flood plain.

Geology and soils

The EER states the subsurface consists of dredged silty clays and old port gravel to greater than 1m depth.

Hydrology Site filled to above local flood levels. Site has a slight fall eastwards.

Fauna and fauna Site surface consists of compacted gravels.

Local region

Surrounding land zoning, tenure and uses

Land to the north, west and adjacent to the east and south is zoned General Industrial. The proposal site is adjacent to a bus depot and other recycling industries. The Tee-Tree Bend wastewater treatment plant is located approximately 180m to the north.

Land to the southeast is zoned General Residential. The nearest residence is located 65m to the south east (the EER states the residence is to the south west but this is assumed to be an error).

Species of conservation significance

Not discussed.

Proposed infrastructure

Major equipment A number of linked settling tanks (number and volume not provided)

Enclosed bunded shed.

Other infrastructure

Potential for effluent pre-treatment infrastructure.


3

Inputs

Water None.

Energy No heating is proposed.

Other raw materials

Waste oils oil/water mixtures and oil contaminated materials.

Wastes and emissions

Liquid Section C7 of the EER states that the average daily discharge to sewer of effluent (consisting of the water fraction of received wastes) will be 40,000L and the maximum daily discharge will be below 100,000L.

Atmospheric A Background oily smell may be detected on site but is not expected to be noticeable off-site.

Solid Approximately 50 tonnes per annum of general solid waste are to be removed from the site periodically for disposal at a Landfill.

Controlled wastes

The EER states that approximately 70kg per week, equating to one 205L drum every 3 weeks, of solid residues and sludges will be produced.

Noise From approximately 20 truck movements per day to and from the site and occasional use of pumps on site.

Greenhouse gases

EER states the proposed activity is a climate change positive industry. Truck movement will generate greenhouse gas emissions.

Construction, and operations

Proposal timetable

Not discussed.

Operating hours (ongoing)

0700 to 1730 hours. Occasional truck movement may occur outside these hours.


4

Figure 1: Location of the Proposal Site


5

Figure 2: Oil recycling shed floor plan


6

4 Need for the proposal and alternatives

The proposal entails the relocation of an existing oil recycling business to a new larger yard to enable more efficient and expanded operations. Section B4 of the EER states that Hagen Oil provides a critical service in the processing industry chain by handling used oil from the maritime, automotive, hydraulic, mining and forestry industries, as well as many others. It is further stated that the lack of an expanded oil and liquid waste reprocessing facility will hamper Tasmania’s economic expansion.

5 Public and agency consultation

A summary of the public representations and government agency/body submissions is contained in Appendix 1 of this report. Three public representations were received. These representations were all in support of the proposal. The following reasons were provided:

Provision of expanded oil recycling capacity in the State.

Improved oil recycling services. The EER was referred to the then Department of Economic Development Tourism and the Arts (DEDTA), Workplace Standards, Taswater and Launceston City Council (LCC). Taswater provided comment directly to the proponent. DEDTA responded in support of the proposal. LCC raised the following relevant issues:

A recommendation that the site yard be sealed.

Noise of truck reversing on site.

Poor quality of plans and lack of clarity regarding site capacity. Relevant EPA Division specialists and regulatory officers were consulted throughout the assessment. The EER Supplement prepared by the proponent provides a response to each of the relevant environmental issues raised by the public and government agencies/bodies.


7

6 Evaluation of environmental issues

The environmental issues considered relevant to the proposal have been evaluated by the EPA Division. Details of this evaluation, along with the permit conditions required by the Board are discussed below.

Issue 1: Containment of hazardous materials

Description of potential impacts

Hagen Oil collects waste oils, oil contaminated water and oil contaminated materials (such as oil filters and drums) from a large range of businesses and industries. The EER lists a typical total volume of oil/water waste collected per year at 1.5ML at Hagen Oil’s current facility.

A maximum quantity of 2900 tonnes of oil product is to be generated at the site per annum. The EER states that the site will generate approximately one 205 litre drum of controlled waste solids and sludges every 3 weeks.

Without appropriate containment on site, these materials and other environmentally hazardous materials may be spilled or otherwise released to the environment resulting in stormwater contamination, discharge of pollutants to the sewerage system and contamination of land.

Management measures proposed in EER

Commitment 1 – a database of materials stored on site is to be maintained. Materials received are to be pre-tested if necessary.

Commitment 2 - Materials handling, processing and storage is to take place in a purpose-built shed. The shed floor is to be completely bunded.

Commitment 10 - Spill clean-up equipment will be maintained on site.

Public and agency comment

Launceston City Council recommended the following:

1. The site yard to be sealed. 2. More detailed plans to be provided to demonstrate that the site has sufficient space and

capacity for the proposed use.

Evaluation

The conduct of site operations within an enclosed bunded shed is supported (commitment 2). A plan of the shed floor is provided in the EER showing 3 bunded areas (loading bay, processing area and storage area), however, no details are provided of the capacity of the bunds or quantity of hazardous materials to be stored at the site. Clear A3 plans were provided by the proponent as part of the EER supplement. These plans did not directly specify the shed dimensions.

To ensure the level of risk associated with waste storage and operations and be ascertained and to enable auditing of the volume of environmentally hazardous materials on site against available capacity, Condition CN1 requires that prior to commencement of operation, as constructed plans are provided to the Director and the capacity of bunded areas identified.


8

Condition G5 ensures the Director is made aware of the expected date of commencement of operations. Conditions H1 and H2 specify the bunding standards for the storage of environmentally hazardous materials.

It is not considered necessary to require the yard be sealed given requirements to conduct all operations involving environmentally hazardous materials within appropriately bunded areas.

The presence of spill management equipment on site is supported (commitment 10) and required by condition H3.

To ensure the design storage capacity of bunded areas is not exceeded the maintenance of an inventory is supported (commitment 1) and is required by condition H4.

Conclusion

The proponent will be required to comply with the relevant EER commitments summarised above.

The proponent will be required to comply with conditions CN1, G2, G5, G6, H1, H2, H3 and H4.

Issue 2: Materials receival and handling


Hagen Oil intends to collect and process waste oil and oil water mixtures from a large array of industry types. Without proper record keeping, controls on the type of materials received, and appropriate handling procedures, the potential exists for increased risk of environmental impacts through chemical reaction, discharge of contaminants to sewer or deposition of contaminants within the solid waste fraction.


Waste types which will not be received are listed in the EER as PCB and PBB material, solvents, pesticides and grease trap waste. Waste types that will be accepted are listed as Oily water mixtures and materials containing ethylene glycol. It is also indicted that oil filters and used drums will be accepted for processing.

Commitment 5 – Materials which cannot be processed are to be labelled and stored in bunded areas.

Commitment 7 -Controlled wastes are to be managed as specified in a Controlled Waste Handler Certificate [issued under the Environmental Management and Pollution Control (Controlled Waste Tracking ) Regulation 2010 (CWT regs)].


The Waste tracking officer has confirmed Hagen Oil’s is a registered waste controlled waste handler.

Evaluation

It is considered necessary to specify materials that can be received and those that cannot be received (condition OP1). This is to ensure that the only materials received are:

1. Those amendable to passive separation of an oil product without significant co-contaminants or other environmental risks.

2. Other materials which are readily managed at the facility proposed, these being materials co-collected, received for disposal only or otherwise inadvertently collected.

Maintenance of records of waste received and dispatched is required (condition OP2) for management and auditing purposes.


9

The proponent’s commitment regarding storage of materials other than for processing is supported (commitment 5). Where environmental hazardous these materials should be kept separate and be clearly identified, as required by condition OP3.

Handling of controlled waste in accordance with the proponents requirements under the CWT Regs is appropriate (commitment 7).

Applying heat during the separation process would significantly increase the potential for emission of volatiles, chemical reaction or other incidents or accidents. Without significant additional management measures and assessment, heat should not be used in the separation process (condition OP4).

Conclusion


The proponent will be required to comply with conditions G8 and OP1, OP2, OP3 and OP4.

Issue 3: Waste disposal


The volume of effluent, consisting of the water fraction following oil separation, is estimated in the EER at an average of 40 kL per day.

Controlled waste that will be generated by the activity includes residue sludges from processing (stated as one 205L drum each 3 weeks) and potentially effluent pre-treatment waste such as flocs and activated carbon.


Commitment 4 - Waste discharged to sewer are to be consistent with [legal] obligations.

Commitment 6 – an investigation into suitable reuse/disposal options for “legacy” waste will be completed within 6 months of the issue of a permit for the activity.

NB: “Legacy waste” is a term used in the EER to refer to waste sludges generated at the proponent’s oil recycling activity at a previous site.


EPA Division waste officers have indicated that treatment options are likely to be available for sludges generated by the proponent’s proposed activity. It was noted that depending on the results of chemical analysis of similar materials it may be necessary to transport such waste interstate for further treatment and disposal.

Evaluation

The only disposal option considered for effluent generated by the proposal is to discharge the effluent to sewer (Commitment 4). This is required by condition E1.

TasWater is responsible for the management of the sewerage system. It is likely that discharge will only be allowed in accordance with a trade waste agreement. TasWater have engaged in separate discussion with the proponent.

To achieve discharge limits effluent pre-treatment may be required. Common pre-treatment options include the use of flocculants and/or activated carbon to remove contaminants. It is considered that sufficient pre-treatment capacity can be readily installed at the site as necessary, thus enabling discharge of effluent to sewer as required.


10

Although the determination of disposal options for legacy controlled waste is appropriate (commitment 6) it cannot be considered as part of this assessment. It is however expected that similar waste will be generated by this proposal. Other controlled wastes that may be generated at the site include waste floc and/or activated carbon from effluent pre-treatment. No treatment or disposal options for these waste types are identified in the EER.

It is not appropriate to allow the proposed operation to commence without assurances that re-use, treatment or disposal options are available for the controlled wastes likely to be produced. Condition H5 requires identification of potential options prior to the commencement of operations. Furthermore, it is considered necessary to require identified options are actively pursued and implemented once operations are commenced. Condition H6 requires a Controlled Waste Management Operations Plan within 6 months of commencement, which places limits on the quantity of controlled wastes to be stored, and the further development and implementation of re-use, treatment or disposal options for controlled wastes.

Condition M1 ensures any sampling required to characterise waste is carried out in accordance with appropriate standards.

The EER states that solid waste is to be stored in skip bins and removed from the site periodically by waste contractors for disposal at a waste depot. This is considered appropriate for materials which can be disposed of in such a manner. Information contained in Schedule 3 OI1 of the permit is relevant in this regard.

Conclusion


The proponent will be required to comply with conditions E1, H5, H6 and M1.

Issue 4: Stormwater management


Processing and handling operations are to take place within an enclosed bunded shed. If environmentally hazardous materials are spilled or otherwise leaked outside of the shed then they have the potential to contaminate stormwater discharging from the site.


Commitment 3 - Yard stormwater is to be discharged from the site through a triple interceptor trap of appropriate size for the yard area.


None

Evaluation

The conduct of all storage handling and process operations within an enclosed bunded shed provides significant mitigation of the potential for stormwater contamination. The prevention of stormwater ingress into the shed is considered appropriate to prevent the capacity of bunded areas from being compromised (condition SW1). Ingress of significant stormwater would result in increased effluent volumes and increase risks of release of contaminants from the shed.

A general requirement to ensure contaminated stormwater is appropriately treated and is not discharged from the land (commitment 3) is considered merited (condition SW2)

Conclusion


The proponent will be required to comply with conditions SW1 and SW2.


11

Issue 5: Noise emissions


The site is located within an industrially zoned area adjacent a number of similar industries including a bus depot and Veolia Environment Services yard. The EER states the year will operated from 7:00 am to 5:30pm daily, although some vehicles may move to and from the site outside those hours. Pumps will occasionally be operated on the yard although the EER states most of the pumps will be inside tanks.

The site backs onto a residential area. The nearest residence is 65m from the site. Excessive noise on the land has the potential to cause an environmental nuisance.


Commitment 8 - A noise survey will be conducted if verified noise complaints are received.


LCC noted that based on figure 6 of the EER that some truck reversing may occur in the site and requested clarification of tuck movements.

LCC requested the days of operation (as well as the hours).

The EPA noise specialist recommended noise emission limits consistent with the industrial setting of the proposal and the location of other source of traffic noise in the area (East Tamar Highway).

Evaluation

Commitment 8 is supported. Condition G7 requires the maintenance of a complaints register.

The EER states approximately 20 truck movement a day are expected. The EER supplements states the site will operate Monday to Friday and limited truck reversing will occur in site.

The proposed activity is not considered to have a significant potential to cause a noise nuisance given the level of ambient noise likely in the local area. Condition N1 sets noise emission limits of 55dB(A) daytime, 45 dB(A) evening and 40 dB(A) at night.

Conclusion


The proponent will be required to comply with condition N1.


12

Issue 6: Fire Management


A fire on the site has the potential to release noxious gases and other contaminants to the environment.


Commitment 11 - A fire management plan will be developed and the approval of the Tasmanian Fire Service (TFS) sought.


none

Evaluation

Standard condition OP5 requires a fire management plan approved by the TFS be provided to the Director.

Conclusion


The proponent will be required to comply with condition OP5.

Issue 7: Decommissioning and Rehabilitation


The site is in an area zoned for industrial use and upon decommissioning the concrete slab is to be left on site.

The yard is to be compacted gravel on a historically in-filled flood plain. Without appropriate rehabilitation any on-site contamination would pose an ongoing risk of causing ground and surface water contamination.


Commitment 9 - A decommissioning and rehabilitation plan (DRP) is to be prepared and implemented 6 months prior to site closure.


none

Evaluation

Commitment 9 is supported. Standard decommissioning and rehabilitation requirements are considered appropriate

Conclusion

The proponent will be required to comply with the relevant DPEMP commitments summarised above.

The proponent will be required to comply with conditions DC1, DC2, DC3 and DC4.


14

9 References

SEAM; Environmental Effects Report for Hagen Oil, Recycling Plant, May 2014.

SEAM; EER Supplement for Hagen Oil Recycling Facility, 13 June 2014


15

10 Appendices

Appendix 1 Summary of public and agency submissions Appendix 2 Permit conditions, includes Attachment 2 - EER commitments

Environmental Assessment Report Hagen Oil. oil recycling facility, 8 Venture Court, Invermay

Appendix 1

Appendix 1 Summary of public and agency submissions

In the following tables, EER means the Environmental Effects Report for Hagen Oil Recycling Plant, May 2014.

A. Public representations

Representation Issue Comment Further information required by EPA

General

3 representations

Support for the proposal

Relocation will provide opportunities for improved collection, treatment and disposal of hydrocarbon impacted water in Tasmania.

n/a

It is considered the proposal will provide expanded processing capacity for oil contaminated wastewaters.

n/a

B. Referral agency comments Nil

C. Launceston City Council comments Please note that the EPA Division information requirements must be addressed for the EPA Boards assessment to be continued. Council may separately require the comment it has made be satisfactorily addressed prior to making its determination.

EER section

Comment Further information required by EPA

B.1, p7 para1

Details required in relation to days of operation.

C.2, p1, para2

States uncovered areas of site will have compacted gravels, recommend that these surfaces are sealed.

Further information is required regarding the use of the yard including driveway and parking areas. In particular details are required of any storage of any kind on yard surfaces.

C.9, p22, para 2

States that the proposed yard will be constructed to enable vehicles to drive through and avoid reversing which can be a noisy operation. However, Figure 6 on page 16 indicates that vehicles will need to reverse on site.

Require clarification on truck movements on site and impact that this may have on nearby residents if trucks need to reverse on site.

Environmental Assessment Report Hagen Oil. oil recycling facility, 8 Venture Court, Invermay

Appendix 1

B.3, p14-15

Figure 4 shows an area proposed to be used as a bunded area for drum processing, while in Figure 5 the same area is shown as being proposed to be used for a tank farm and treatment tanks. This should be clarified and a site plan provided to demonstrate all uses of the site, such as drum storage, tank farm, settling tanks, storage of legacy waste, drum washing, waste bins, car parking. This may help to also clarify and demonstrate that the site has sufficient available space & capacity for the proposed use, particularly in relation to the statement that some of the settling processes may take up to several months to achieve the objective of separation for reuse or management, (statement on page 8).

The original plan text on figures 4, 5, 6 and 7 is not legible. Please provide legible A3 figures, detailing the information requested by Council, using the original plans as a basis (it is noted the original plans were provided with the development application and thus are available for use as a template).

Please clarify discrepancies in terminology between figures 4 and 5.

Environmental Assessment Report Hagen Oil, oil recycling facility, 8 Venture Court, Invermay

Appendix 2

Appendix 2 Permit conditions - Environmental

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