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Works Approval Application

Waste to Energy Facility – Dandenong South Prepared for Great Southern Waste Technologies 23 October 2019

SMEC INTERNAL REF. 30041688

Document Control

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WORKS APPROVAL APPLICATION Waste to Energy Facility – Dandenong South Prepared for Great Southern Waste Technologies

SMEC Internal Ref. 30041688 23 October 2019

Document Control Document: Works Approval Application

File Location: I:\Projects\30041688\

Project Name: Waste to Energy Facility – Dandenong South

Project Number: 30041688

Revision Number: 0

Revision History

REVISION NO. DATE PREPARED BY REVIEWED BY APPROVED FOR ISSUE BY

Preliminary Draft 18 April 2019

Brigette Gwynne

Kate Beard

Sari Woods

Nicole Philps

Julian Howard

Matt Fraser

Lukas McVey

Draft 21 May 2019 Julian Howard Lukas McVey Lukas McVey

Rev 0 23 October 2019 Julian Howard

Jenna Forbes

Lukas McVey Lukas McVey

Issue Register

DISTRIBUTION LIST DATE ISSUED NUMBER OF COPIES

Great Southern Waste Technologies 23 October 2019 1

Environment Protection Authority Victoria (EPA) 23 October 2019 1

SMEC Company Details

Approved by: Lukas McVey

Address: Tower 4, 727 Collins Street, Docklands, Vic 3008

Signature:

Tel: +61 4 27 739 716 Fax: +61 3 9514 1502

Email: [email protected] Website: www.smec.com

The information within this document is and shall remain the property of: SMEC Australia Pty Ltd

http://www.smec.com/

Table of Contents

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Table of Contents EXECUTIVE SUMMARY ........................................................................................................................................................ 1

GENERAL INFORMATION ......................................................................................................................................... 8 Primary Information ..................................................................................................................................... 8 Report Objectives ....................................................................................................................................... 11 Supporting Documents............................................................................................................................... 11 Proposed Scheduled Activity ...................................................................................................................... 11 Exclusions from the Application ................................................................................................................. 11 Site Selection .............................................................................................................................................. 12 Land Use ..................................................................................................................................................... 12 Company Details ........................................................................................................................................ 13

REGULATORY COMPLIANCE ASSESSMENT ............................................................................................................ 15 Legislative Context ..................................................................................................................................... 15 Statewide Waste and Resource Recovery Infrastructure Plan (SWRRIP) ................................................... 17 Metropolitan Implementation Plan ........................................................................................................... 17

COMMUNITY ENGAGEMENT ................................................................................................................................. 18

PROCESS AND INTEGRATED ENVIRONMENTAL ASSESSMENT .............................................................................. 22 Proposed Facility ........................................................................................................................................ 22 Waste Feedstock (Fuel) .............................................................................................................................. 37 Traffic Impacts ............................................................................................................................................ 52 Fire Management ....................................................................................................................................... 54 Environmental Best Practice Assessment .................................................................................................. 58

ENVIRONMENTAL INFORMATION ......................................................................................................................... 64 Energy Use and Greenhouse Gas Emissions .............................................................................................. 64 Air Emissions .............................................................................................................................................. 69 Human Health Risk Assessment ................................................................................................................. 75 Noise Emissions .......................................................................................................................................... 82 Water ......................................................................................................................................................... 88 Land and Groundwater .............................................................................................................................. 91 Waste ......................................................................................................................................................... 92

ENVIRONMENTAL MANAGEMENT ........................................................................................................................ 99 Environmental Objectives .......................................................................................................................... 99 Risk Assessment ......................................................................................................................................... 99 Assessment of Environmental Risk ............................................................................................................ 99 Climate Change ........................................................................................................................................ 103 Operational Management ........................................................................................................................ 106 Construction Impact Management .......................................................................................................... 108

OTHER APPROVALS .............................................................................................................................................. 111 Commissioning Plan ................................................................................................................................. 111 Environmental Approvals ......................................................................................................................... 111 Post Decision Requirements .................................................................................................................... 112

IMPORTANT NOTICE ............................................................................................................................................ 113

REFERENCES ........................................................................................................................................................ 114

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Appendices PLANNING PROPERTY REPORT

CULTURAL HERITAGE DUE DILIGENCE

PRELIMINARY AND DETAILED SITE INVESTIGATIONS

TRAFFIC IMPACT ASSESSMENT

FIRE RISK ASSESSMENT

AIR EMISSIONS MODELLING AND IMPACT ASSESSMENT

ENVIRONMENTAL NOISE ASSESSMENT

STORMWATER MANAGEMENT PLAN

SITE ENVIRONMENTAL MANAGEMENT PLAN

LITTER MANAGEMENT PLAN

EMISSIONS DATA FROM REFERENCE PLANT

STAKEHOLDER AND COMMUNITY ENGAGEMENT AND CONSULTATION PLAN

GREENHOUSE GAS LIFECYCLE ASSESSMENT

ENVIRONMENTAL RISK ASSESSMENT

HUMAN HEALTH RISK ASSESSMENT

WASTE AUDIT

FUEL SPECIFICATION

SARPSBORG 2 PERMIT

FLY ASH MSDS

BOTTOM ASH ANALYSIS

CFA MEETING MINUTES

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List of Tables Table 0-1: Maximum measured modelled GLCs (99.9th percentile for all except PM2.5 and HF which are 100th percentile)........................................................................................................................................................................... 5

Table 0-2: EU Limit modelled GLCs (99th percentile for all except PM2.5 and HF which are 100th percentile).................... 5

Table 1-1: Project and site details ...................................................................................................................................... 8

Table 1-2: Sensitive Receptors .......................................................................................................................................... 12

Table 1-3: Review of relevant legislation and approvals .................................................................................................. 13

Table 1-4: Company details .............................................................................................................................................. 14

Table 3-1: Stakeholders Contacted for Face-to-Face Meetings ........................................................................................ 18

Table 3-2: General Questions ........................................................................................................................................... 19

Table 3-3: Community and Stakeholder Engagement Timeline ....................................................................................... 20

Table 4-1 Process flow descriptions ................................................................................................................................. 28

Table 4-2 Consumable Data .............................................................................................................................................. 31

Table 4-3 Key Outputs ..................................................................................................................................................... 32

Table 4-4: Key Process Controls ........................................................................................................................................ 36

Table 4-5 Publicly Available Council General Waste Bin Audit Data ................................................................................ 41

Table 4-6 Standardised sampling and analysis methodologies applied by HRL Technology for MSW analysis. .............. 44

Table 4-7 Winter Waste Audit Composition Summary (source: HRL, 2018) .................................................................... 45

Table 4-8 Winter Waste Audit Composition Summary – Weighted Average Results (source: HRL, 2018) ...................... 47

Table 4-9: Fuel Characteristics (Energos, 2018c) .............................................................................................................. 48

Table 4-10 Permissible Concentrations in Feedstock (Energos, 2019b) ........................................................................... 48

Table 4-11: Reference Facility Waste Combustion Results............................................................................................... 50

Table 4-12 Key Fire Protection Measures......................................................................................................................... 55

Table 5-1: Estimated greenhouse gas emissions, comparison emissions ......................................................................... 67

Table 5-2: Sensitive receivers nearby the proposed facility ............................................................................................. 70

Table 5-3: Emissions Modelling Reference Facilities ........................................................................................................ 71

Table 5-4: Project relevant SEPP (Air quality management) Schedule E emissions limits for stationary sources ............ 71

Table 5-5: Industrial Emissions Directive 2010/75/EU emissions limits ........................................................................... 72

Table 5-6: Project-Relevant SEPP (Air Quality Management) Design Criteria .................................................................. 72

Table 5-7: Sarpsborg 2 Maximum Monthly Average Emissions........................................................................................ 73

Table 5-8: Maximum measured modelled GLCs (99.9th percentile for all except PM2.5 and HF which are 100th percentile)......................................................................................................................................................................... 73

Table 5-9: EU Limit modelled GLCs (99th percentile for all except PM2.5 and HF which are 100th percentile).................. 74

Table 5-10: Emissions During Start Up.............................................................................................................................. 74

Table 5-11 Summary of Contaminants of Concern and Exposure Pathways .................................................................... 76

Table 5-12 Review of acute exposures and risks (maximum location anywhere) ............................................................ 77

Table 5-13 Calculated chronic inhalation risks* ............................................................................................................... 78

Table 5-14 Calculated chronic inhalation risks for selected receptors* ........................................................................... 79

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Table 5-15 Summary of risks for multiple pathway exposures – rural residential areas (represented by receptor 2) .... 80

Table 5-16 Summary of risks for multiple pathway exposures – residential area of Somerfield Estate (represented by receptor 6) ........................................................................................................................................................................ 81

Table 5-17 Summary of Relevant Noise Sensitive Receptors ........................................................................................... 82

Table 5-18 Adopted Ambient Background Noise Levels ................................................................................................... 84

Table 5-19 Site Noise Emission Source Summary ............................................................................................................. 84

Table 5-20 SEPP N-1 Limits ............................................................................................................................................... 86

Table 5-21 Adopted Design Objective Values for the Acoustic Assessment. ................................................................... 87

Table 5-22 Predicted Noise Levels at Receptors Located to the East of Perry Rd ............................................................ 87

Table 5-23 Predicted Noise Levels at Receptor Located to the West of Perry Rd (within approximately 200m of Perry Rd) ..................................................................................................................................................................................... 87

Table 5-24 Predicted Noise Levels at Receptor Located to the West of Perry Rd (Greater than 200m setback west of Perry Rd) ........................................................................................................................................................................... 88

Table 5-25: Operational residues generated by the facility ............................................................................................. 92

Table 5-26 Fly Ash Chemical Composition (MSS, 2011) .................................................................................................... 93

Table 5-27 Bottom Ash Analysis (ALS, 2019) .................................................................................................................... 94

Table 5-28: Management options for PIW hazard categories (EPA, 2009) ...................................................................... 96

Table 6-1: Qualitative measures of likelihood ................................................................................................................ 100

Table 6-2: Qualitative measures of consequence/ impact ............................................................................................. 100

Table 6-3: Risk analysis matrix ........................................................................................................................................ 101

Table 6-4 Climate Projections for Greater Melbourne (Climate-Ready Victoria, 2019) ................................................. 104

Table 6-5 Expected impact of climate change on the proposed facility ......................................................................... 105

Table 6-6: Dangerous Goods and Hazardous Substances ............................................................................................... 107

Table 6-7: Storage and Handling Requirements ............................................................................................................. 107

Table 6-8: Proposed structure of the CEMP ................................................................................................................... 109

Table 7-1: Review of relevant legislation and approvals ................................................................................................ 111

Table 7-2: Operational requirements ............................................................................................................................. 112

List of Figures Figure 0-1 Plant Overview................................................................................................................................................... 2

Figure 0-2 Site Plan ............................................................................................................................................................. 3

Figure 1-1 Site Locality ........................................................................................................................................................ 9

Figure 4-1 Site Layout (source: RPC Architects) ................................................................................................................ 23

Figure 4-2 High Level Plant Overview ............................................................................................................................... 27

Figure 4-3 Process Flow Diagram of Waste to Energy Plant ............................................................................................. 27

Figure 4-4 Energos plants – operational & under construction ........................................................................................ 30

Figure 4-5 Resource Efficiency Diagram ........................................................................................................................... 37

Figure 4-6 MSW Composition (MWRRG, 2018) ................................................................................................................ 39

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Figure 4-7 City of Melbourne Commercial and Industrial General Waste Bin Audit Data (Source: Melbourne City Council, 2019) ................................................................................................................................................................... 43

Figure 4-8 Whitehorse City Council General Waste Bin Audit Data (Source: Whitehorse City Council, n.d.) .................. 43

Figure 4-9: Existing Road Network (Source: VicRoads Map of Declared Roads) .............................................................. 53

Figure 4-10 Waste Hierarchy (EPA, 2017c) ....................................................................................................................... 61

Figure 5-1 Noise Measurement Locations (WMG, 2019) ................................................................................................. 83

Figure 5-2 Existing Site Drainage (extract from existing conditions survey [SMEC, February 2018]) ............................... 89

Executive Summary

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Executive Summary Great Southern Waste Technologies Pty Ltd (GSWT) is proposing to develop a Waste-to-Energy (WtE) facility accepting Municipal Solid Waste (MSW) and Commercial and Industrial Waste (C&I) at 70 Ordish Road, Dandenong South, Victoria (the facility).

The facility will receive approximately 100,000 tonnes annually of MSW and C&I waste, likely from the south east Melbourne region and generate approximately 7.9 megawatts (MW) of baseload electricity to be fed into the grid.

The power generated by the facility is sufficient to power approximately 7,000 homes and will divert MSW and C&I from landfill. In Australia over 21 million tonnes of waste is sent to landfill each year, losing the embodied energy of the wastes while increasing greenhouse gas emissions through methane and carbon dioxide generation along with a range of other greenhouse gases.

The facility will use proven technology developed by Energos - AS (Norway) (Energos) to recover this energy from the waste and enable it to be exported into the grid as base load power, available to both commercial and residential customers. This source of energy is considered a renewable energy, capturing the calorific value within the otherwise landfilled waste. Utilising this valuable resource through recovery of the energy offers a sustainable improvement to waste management services currently being provided in Dandenong South, whilst reducing the overall greenhouse gas emissions and the potential environmental impacts associated with landfilling.

About GSWT

GSWT is a Melbourne-based Australian company. GSWT believes WtE has a pivotal role in Melbourne’s waste management future and supports recycling and resource recovery programs while delivering improved environmental, economic and social outcomes for residual waste management.

In particular, WtE is a higher-order waste management option than disposal to landfill. It addresses the economic issue of waste being a lost resource and avoids the potential adverse environmental outcomes associated with issues which may arise from landfilling waste, including leachate management and groundwater contamination, which can require ongoing management well beyond the operational life of landfill sites.

WtE facilities have the potential to reduce the waste sent to landfill by up to 80 per cent (or around 95 per cent where, as is proposed for the facility, ash products are diverted from landfill for beneficial reuse by the construction industry), minimising dependency on new and expanded landfills and ensuring that existing landfill capacity is retained for contingencies and unrecoverable materials into the future.

The Facility

Prior to selecting the technology for the facility, GSWT undertook extensive worldwide research of available WtE technologies. GSWT has entered into an exclusive license and engineering agreement with Energos for the design and supply of the gasification technology to be used at the facility. A key factor in GSWT’s selection of Energos technology is its successful operational record in Scandinavia and proven ability to meet stringent European Union (EU) Industrial Emissions Directive (2010/75/EU) performance criteria. Energos gasification plants have completed over 1 million operational hours of reliable performance.

The facility will receive waste seven days per week, receiving approximately 100,000 tonnes per year, however is modular and can be scaled as required, without any loss of performance. The facility will be situated within an enclosed purpose built building, with all operations, including waste unloading, within the building.

Energos technology, which will be utilised for the facility, is a two-stage thermal process that includes drying, pyrolysis, gasification and oxidation. The gasifier unit is divided into a primary chamber where drying, pyrolysis and gasification of the solid waste takes place, and a secondary chamber where the oxidation of primary gases is completed. Figure 0-1 presents a perspective view of the proposed plant, noting that this is for a single-line plant, whereas the proposed facility is dual-line.

Executive Summary

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Figure 0-1 Plant Overview

The gasification process consists of two thermal conversion stages:

1. Gasification stage: Partial oxidation and gasification of the waste to a synthetic gas (syngas) takes place in the primary chamber on a fixed grate. The waste is fed into the primary chamber at a controlled rate where it is directed onto a grate. Drying, pyrolysis and gasification of the waste occurs in the primary chamber, where the syngas is produced. There is also a carbon burnout section before the decarbonised waste falls into a water bath / air lock where it is removed and transported as bottom ash. Temperatures are maintained at a minimum of 820 degrees Celsius in the primary chamber.

2. The second thermal conversion stage is combustion. The syngas generated in the primary chamber flows through to the secondary chamber, where oxygen is introduced, and the syngas is fully combusted. The temperature in the secondary chamber maintains a minimum 850 degrees Celsius for a minimum of two seconds.

The heat of the combustion gases from the second thermal conversion stage is then transferred to a boiler system where high pressure steam is produced for powering a turbine for the production of electricity.

The gasification process has many advantages in maintaining and managing emissions. A key benefit of the process is that it is able to achieve low nitrous oxide (NOx) emissions without the need for additional ammonia, which is typically the case with Mass Burn Incineration technologies.

Fuel preparation is critical in ensuring the performance and emissions profile are consistent. A key aspect of Energos technology that ensures high thermal efficiency and low emissions is the pre-treatment of waste to ensure a sufficiently high surface-to-volume ratio and a low content of metals. The facility will pre-treat the waste using a shredder and ferrous metal separation to achieve this.

The facility will generate a number of residues as part of routine operation. The residues generated will fall within two broad categories:

• Bottom ash (also known as grate ash): this is the solid residue removed from the combustion chamber after the waste has been combusted

• Fly ash: this comprises boiler ash, the part of the fly ash that is removed from the boiler; and Air Pollution Control (APC) residues (also known as Flue Gas Treatment (FGT) residues) from the APC equipment.

Executive Summary

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It is expected that bottom ash will likely be categorised as ‘non-prescribed industrial waste’, while fly ash (boiler ash and APC residues) will likely be categorised as either ‘Category B prescribed industrial waste (PIW)’ or ‘Category C PIW’.

Both bottom ash and fly ash are solid industrial wastes as defined by the EPA Industrial Waste Resource Guidelines Solid Industrial Waste Hazard Categorisation and Management (IWRG631). Both types of ash have significant potential as a reusable product. The potential of future reuse is reliant on the key characteristics of the waste from an engineering perspective, the chemical properties, including leachability of chemicals of concern and the market demand.

Site

The proposed site for the facility is located at 70 Ordish Road, Dandenong South within the City of Greater Dandenong on land described as Lot 1 on TP205351.

Figure 0-2 Site Plan

The site has a total area of approximately 1.27 hectares and is currently utilised as a sand blasting and industrial painting facility.

The proposed site is appropriately positioned to establish a WtE facility as it is located within an industrial zone (IN2Z) and surrounded by existing industrial land, including other waste handling facilities, with buffers of greater than 500 meters to the nearest sensitive receptors.

The Statewide Waste and Resource Recovery Infrastructure Plan (SWRRIP) also identifies Ordish Road, Dandenong South as one of 22 waste and resource recovery hubs of state importance. These hubs are identified as potentially suitable sites to support future waste and resource recovery development due to existing infrastructure located within the hub.

Executive Summary

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Community Engagement

Ongoing community and stakeholder engagement is being conducted by GSWT, with support from consulting and stakeholder engagement organisations. This stakeholder and community engagement process has supported the development of the EPA's works approval assessment process (EPA Publication 1658 Works Approval Application). A detailed community and stakeholder engagement plan has been developed and is being implemented in relation to the development of the WtE project.

A summary of community and stakeholder engagement conducted to date and ongoing is provided below.

The key outcomes of the pre-construction community engagement, which has been underway since mid-2018, include:

• Provision of information about the proposed facility to the community and seeking initial feedback • Primary community concerns raised during the community engagement related to air quality, noise, amenity,

traffic congestion, water management and flooding, and reporting and accountability of the facility • Identified community concerns were further assessed through the assessment phase and addressed in the design

process.

Ongoing consultation with Greater Dandenong City Council and Environment Protection Authority Victoria has also occurred, to address potential issues through the assessment and design phase. The specific community engagement activities that have been undertaken to date include: • Completed 10 face-to-face meetings with stakeholders • Completed phone consultations of the project • Completed a public forum on 20 March 2019 • Developed and distributed information sheets • Distributed information sheets • Updated and maintained website

Greenhouse Gas Emissions

It is estimated that the facility will result in a greenhouse gas emissions net benefit of 142,800 tonnes of carbon dioxide equivalent (tCO2e) per year. The facility is estimated to produce net emissions of 9,500 tCO2e per year, however, through diversion of 85,000 tonnes of MSW and 15,000 tonnes of C&I from landfill to the facility, 137,000 tCO2e will be avoided (as estimated for business as usual waste disposal through landfill).

Additionally, useful products recovered from the facility may lead to further greenhouse gas emissions reductions through the replacement of virgin materials. Start2See (2019) estimated the benefit associated with recovery of material to be 15,300 tCO2e per year.

Data sources and emission factors used to inform this assessment are presented in the greenhouse gas lifecycle assessment (Appendix M).

Air Emissions

Impacts associated with air emissions from the combustion of waste to produce energy were identified as a potentially high risk if unmitigated during the design and operation of the facility. As such, the management of air emissions has been a key focus of the design development and has been informed by the air emissions modelling and impact assessment.

The air quality and emissions modelling impact assessment details:

• an overview of the legislative and policy context relevant to air quality in Victoria and relevant to the operation of the facility

• an assessment of the baseline air quality • modelling of potential ground level concentrations (GLCs) of air emissions from the facility • an assessment of the modelled emissions against relevant standards, guidelines and policies including State

Environment Protection Policy (SEPP) (Air Quality Management).

The methodology used in the assessment was based on the requirements of SEPP Air Quality Management and EPA Guideline 1551: Guidance Notes for Using the Regulatory Model AERMOD in Victoria (EPA, 2013a).

Executive Summary

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Emissions were modelled for three scenarios using both the measured and maximum concentrations from similar plants, and relevant European Union (Industrial Emissions Directive – 2010/75/EU) limits (EU Limits). The scenarios modelled were:

1. Maximum measured emissions – emissions at the maximum concentrations reported for selected reference facilities using the same technology in Europe

2. EU Limits – Emissions at the reported European Union IED 2010/75/EU limits 3. Start Up Conditions – emissions at the maximum rates reported during start up for reference facilities using

the same technology in Europe

Ground level concentrations were assessed for each of these three emissions scenarios.

The modelling was based on point source emissions from the facility stack location and height. GLC thresholds were taken primarily from the SEPP (Air Quality Management), except for dust, for which the SEPP (Ambient Air Quality) threshold was adopted. Dust emissions were conservatively assumed to be particulate matter less than 2.5 micrometres (PM2.5).

Modelled GLCs were added to background concentrations, where available, and compared to corresponding SEPP (Air Quality Management) design criteria.

As there are no similar facilities currently operating in Australia, air emissions from the facility were modelled based on reference facilities operating overseas (based on data provided by Energos).

The modelled GLCs (excluding background) for the facility, based on the maximum measured emissions profiles for the comparable reference facilities, were all below relevant assessment criteria (Table 0-1). Most parameters were between 0.02 per cent and 5.9 per cent of the assessment criteria, except nitrogen dioxide (NO2), which was 11 per cent of the assessment criteria.

Background concentrations were also considered for substances where data was available (NO2 and PM2.5). When modelled GLCs and highest recorded hourly average GLCs were considered, the overall GLCs were still below the assessment criteria.

Table 0-1: Maximum measured modelled GLCs (99.9th percentile for all except PM2.5 and HF which are 100th percentile)

PARAMETER AVERAGING

TIME MODELLED VALUE

(mg/m3) SEPP ASSESSMENT CRITERIA (mg/m3)

MODELLED PERCENTAGE OF CRITERIA

PM2.5 24 h 1.2 x 10-4 0.025 0.49 %

Hg 3 min 1.9 x 10-6 3.3 x 10-4 0.59 %

Cd 3 min 1.9 x 10-6 3.3 x 10-5 5.9 %

CO 1 h 6.5 x 10-3 29 0.02 %

HF 24 h 5.8 x 10-5 0.0029 2.0 %

HCl 3 min 2.2 x 10-3 0.25 0.9 %

NO2 1 h 2.0 x 10-2 0.19 11 %

NH3 3 min 4.7 x 10-3 0.6 0.8 %

SO2 1 h 6.8 x 10-3 0.45 1.5 %

Dioxins 3 min 1.9 x 10-11 3.7 x 10-9 0.52 %

The modelled GLCs, based on EU (IED) emissions limits for WtE facilities, were all below relevant assessment criteria, with cadmium (29 per cent) and nitrogen dioxide (22 per cent) having the highest modelled percentage of the assessment criteria, as presented in Table 0-2.

Table 0-2: EU Limit modelled GLCs (99th percentile for all except PM2.5 and HF which are 100th percentile)

Executive Summary

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PARAMETER AVERAGING TIME

MODELLED VALUE (mg/m3)

SEPP ASSESSMENT CRITERIA (mg/m3)

MODELLED PERCENTAGE OF CRITERIA

PM2.5 24 h 5.8 x 10-4 0.025 2.3 %

Hg 3 min 9.7 x 10-6 3.3 x 10-4 2.9 %

Cd 3 min 9.7 x 10-6 3.3 x 10-5 29 %

CO 1 h 1.1 x 10-2 29 0.04 %

HF 24 h 5.8 x 10-5 0.0029 2.0 %

HCl 3 min 1.2 x 10-2 0.25 4.7 %

NO2 1 h 7.8 x 10-2 0.19 22 %

NH3 3 min 1.9 x 10-3 0.6 0.32 %

SO2 1 h 2.1 x 10-2 0.45 4.7 %

Dioxins 3 min 1.9 x 10-11 3.7 x 10-9 0.52 %

The air emissions modelling also considered background concentrations for nitrogen dioxide and sulfur dioxide, based on data obtained from the Dandenong and Alphington monitoring stations (EPA AirWatch). When background concentrations were considered, GLCs due to emissions from the facility were still well below the assessment criteria for relevant substances where background data is available.

The chemical with the highest modelled value relative to the acceptance criteria was cadmium, with a modelled result of 29 per cent of the GLC criteria. Background concentrations for cadmium were not available, and therefore was assumed to be zero.

The modelling and impact assessment identified that modelled ground level concentrations of exhaust gas emissions would be below the relevant assessment criteria specified in the SEPP (Ambient Air Quality) and SEPP (Air Quality Management).

A detailed Human Health Risk Assessment has also been carried out which considered that the modelled air emissions resulting from the facility will result in negligible risks to human health.

Continuous emissions monitoring systems for oxides of nitrogen (NOx), sulfur dioxide (SO2), hydrogen chloride (HCl), carbon monoxide (CO), particulates and total organic carbon (TOC) will be included in the design and operation of the proposed facility, and data reported as required under any licence conditions imposed for the facility.

Operations at the facility will also include non-continuous monitoring for heavy metals, dioxins and furans at a frequency to be outlined in the relevant environmental management plan, and as required by the EPA.

The facility is enclosed and operated under conditions creating a slight negative air pressure to minimise odour release. Air from within the hall and bunker area is utilised as the combustion air injected into the oxidation chamber(s), where odours, hydrocarbons and volatile compounds will be destroyed. Based on evidence from similar facilities currently operating overseas, this will eliminate most, if not all, odours. Regular monitoring for odours will be a requirement of the operational monitoring plan.

Noise

Operation of the facility will generate noise from vehicle movements and the use of blowers, tower turbines, boilers and other equipment. All equipment will have point source noise limits based on WorkSafe requirements, and will be operated to comply with the Noise from Industry in Regional Victoria (EPA, 2011). Where required, equipment will be enclosed to ensure compliance with noise limits. An Environmental Noise Assessment was undertaken for the facility. Based on the results of the predicted noise levels, the operation of the facility will comply with the relevant SEPP N-1 noise limits and the proposed design objectives for each of the identified noise sensitive receptors. Compliance with the noise limits and design objectives is reliant on the mitigation measures proposed in the assessment.

Conclusion

The facility will implement gasification technology, using best practice techniques, allowing for diversion of approximately 100,000 tonnes of MSW and C&I waste from landfill for use in the production of energy. The proposed

Executive Summary

7



site is in an existing industrial area and identified waste and resource recovery hub of state importance, with surrounding industrial land uses including other waste handling facilities.

The facility will result in the diversion of up to 100,000 tonnes per year of waste from landfill (disposal) to higher-order uses in the waste hierarchy including ‘recovery of energy’ and potentially ‘reuse’. This will also result in a significant reduction in greenhouse gases emitted to the atmosphere.

The facility will provide renewable energy as baseload power to the grid, by capturing the calorific value within the otherwise landfilled waste. This provides a sustainable waste management solution, whilst also mitigating the negative environmental impacts often associated with landfilling and reducing the overall greenhouse gas emissions.

Ground level concentrations modelled based on emissions from the facility based on reference facility data and maximum emissions at EU limits (IED) were below SEPP (Air Quality Management) and SEPP (Ambient Air Quality) assessment criteria.

Environmental and human health impacts associated with the facility have been assessed through a risk assessment and specialist studies, to identify potential impacts to the environment and receptors. These assessments have concluded that provided the proposed controls are implemented at the facility, the residual impacts will be acceptable.

General Information

8



General Information Primary Information

SMEC Australia Pty Ltd (SMEC) has been engaged by Great Southern Waste Technologies Pty Ltd (GSWT) to prepare a Works Approval Application to the Environment Protection Authority (EPA) Victoria for a combined Municipal Solid Waste (MSW) and Commercial and Industrial Waste (C&I) Waste-to-Energy (WtE) facility (the facility) at 70 Ordish Road, Dandenong South, Victoria.

Table 1-1 summarises the key particulars of the project. The location of the proposed facility is presented in Figure 1-1.

Table 1-1: Project and site details

ITEM DETAILS

Address 70 Ordish Road, Dandenong South VIC 3175

Proposed Activity Waste to Energy Facility

Proposed Scheduled Activity A08 – Waste to Energy

Premises which recover energy from waste at a rated capacity of at least three megawatts (MW) of thermal capacity or at least one megawatt of electrical power.

Site Area 12,709 m2

Parcel SPI Lot 1 on TP205351

Municipality City of Greater Dandenong

Planning Zone Industrial 2 Zone (IN2Z)

Planning Overlays None

MT. HIRA COLLEGE

DANDENONG CREEK

LOCALITY PLAN

WA-01

1

JUN 2019

1952_WA

MM

PROPOSED WASTE TO

ENERGY FACILITY AT

70 ORDISH ROAD,

DANDENONG SOUTH.

PROJECT:

JOB No.:

1952

DRAWING TITLE:

WRITTEN DIMENSIONS TO TAKE PRECEDENCE OVER

SCALE. BUILDER SHALL CHECK AND VERIFY ALL

DIMENSIONS ON SITE. DISCREPENCIES TO BE BROUGHT

TO THE ATTENTION OF THE ARCHITECT. THIS DRAWING

IS TO BE READ IN CONJUNCTION WITH ALL OTHER

ARCHITECTURAL DRAWINGS AND SPECIFICATIONS AND

ALL OTHER CONSULTANTS DRAWINGS AND

SPECIFICATIONS.

CLIENT:

ISSUE: DATE: AMENDMENT:

NORTH:

102 Poath Road, Hughesdale

PO Box 5111, Hughesdale 3166

P 03 9564 6000

F 03 9564 6099

E [email protected]

W www.rpcarchitects.com.au

RPC

ARCHITECTS


DRAWING No.:

ISSUE: DATE:

REF:

DRAWN BY:

1 02.10.19 WORKS APPLICATION ISSUE -

LOCALITY PLAN

0 10050

SCALE IN METRES 1:5000 @ A1

150 25050 200

RECEPTOR ANALYSIS

160m 1 DANDENONG CREEK

600m 2 RESIDENTIAL PROPERTIES (KEYSBOROUGH)

1.4km 3 RELIGIOUS WORSHIP CENTRE (BUDDHIST TEMPLE)

1.4km 4 SCHOOL (MT HIRA COLLEGE)

1.5km 5 RELIGIOUS WORSHIP CENTRE (SIKH TEMPLE)

1.5km 6 RESIDENTIAL PROPERTIES (SOMERFIELD)

1.9km 7 FREEMASONS VICTORIA

SUBJECT SITE

FREEMASONS VICTORIA

7

4

1

BUDDHIST TEMPLE

36

SOMERFIELD ESTATE

5

SIKH TEMPLE

2

KEYBOROUGH

RESIDENTIAL

I.L

4.95

Proposed DN150

UPVC-DWV

SCH10 SEWER PIPE

FALL

1:80

EXISTING SEWER

PROPERTY

CONNECTIONProposed DN150 SEWER

INSPECTION SHAFT

(I.L +8.08)

Existing DN 375

VC SEWER

MAIN

Existing DN 375

VC SEWER

MAIN

FALL

FALL

I.L

4.65

Existing DN 150 VC

SEWER

MAIN

PROPOSED DN150 UPV-DWV SCH10

LONG RADIUS Y-TEE FOR CONNECTIONS

SEWER NOTES:

1. The design is preliminary and subject to

change

2. All llevels shown are in mAHD

3. The information abouit existing reticulation

sewer is based on south east water GIS. It

shall be verified on site

DRAINAGE NOTES:

1. It is assumed that the legal point of discharge

(LPOD) will be the SEP at the front of the site

2. Invert levels will be confirmed at the detailed

design stage

300

900

900

1050

SITE PLAN

WA-02

1

JUN 2019

1952_WA

MM

PROPOSED WASTE TO

ENERGY FACILITY AT

70 ORDISH ROAD,

DANDENONG SOUTH.

PROJECT:

JOB No.:

1952

DRAWING TITLE:

WRITTEN DIMENSIONS TO TAKE PRECEDENCE OVER

SCALE. BUILDER SHALL CHECK AND VERIFY ALL

DIMENSIONS ON SITE. DISCREPENCIES TO BE BROUGHT

TO THE ATTENTION OF THE ARCHITECT. THIS DRAWING

IS TO BE READ IN CONJUNCTION WITH ALL OTHER

ARCHITECTURAL DRAWINGS AND SPECIFICATIONS AND

ALL OTHER CONSULTANTS DRAWINGS AND

SPECIFICATIONS.

CLIENT:


NORTH:

102 Poath Road, Hughesdale

PO Box 5111, Hughesdale 3166

P 03 9564 6000

F 03 9564 6099

E [email protected]

W www.rpcarchitects.com.au

RPC

ARCHITECTS


DRAWING No.:

ISSUE: DATE:

REF:

DRAWN BY:

1 02.10.19 WORKS APPLICATION ISSUE -

PROPOSED SITE PLAN - OVERALL

0 10.010.0

SCALE IN METRES 1:500 @ A1

STORMWATER/DRAINAGE CONCEPT DEVELOPED BY

SMEC PTY LTD, WITH DETAILS SUBJECT TO CHANGE

DURING DETAILED DESIGN DEVELOPMENT PHASE

20.0 30.0 40.0

PROPOSED FENCED BOUNDARY: 242.00M. 268°56'40"

PROPOSED BOUNDARY: 242.00M. 88°56'40"

PARTIALLY VACANT LAND

PR

OP

OS

ED

B

OU

ND

AR

Y: 52.53M

. 357°44'40"

PR

OP

OS

ED

B

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ND

AR

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. 177°44'40"

O R

D

I S

H

R

O

A

D

INDUSTRIAL

BUILDINGS / USE

EXISTING METAL

CLAD INDUSTRIAL

BUILDING

EXISTING

METAL CLAD

INDUSTRIAL

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EXISTING

COVERED

AREA

EXISTING BRICK

INDUSTRIAL

BUILDING

EXISTING METAL

CLAD INDUSTRIAL

BUILDING

EXISITNG BRICK

INDUSTRIAL

BUILDING

16000 20000 18654 111580 69750

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00

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BUNKER

FUEL

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MAIN HALL

TURBINE ROOM

STORE

COOLING UNIT

PEDESTRIAN WALKWAY PEDESTRIAN WALKWAY

FUEL TANK

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TELSTRA

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2 PITS

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EQUIPMENT ROOM

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HRSG

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FUEL HOPPER top @ +10.20

AutoCAD SHX Text

THERM. OIL SKIDS

AutoCAD SHX Text

COOLING WATER SKIDS

AutoCAD SHX Text

HYDRAULIC SKIDS

AutoCAD SHX Text

-8m

AutoCAD SHX Text

-8m

AutoCAD SHX Text

TUBE BUNDLE CLEANING AREA & LAYDOWN AREA FOR CRANE

AutoCAD SHX Text

WxH 4500x8000

AutoCAD SHX Text

POWER PACK

AutoCAD SHX Text

AIR COMPRESSOR

AutoCAD SHX Text

AIR COMPRESSOR

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AIR DRYER

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AIR TANK

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AIR TANK

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WITHDRAWAL AREA

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FUEL HOPPER top @ +10.20

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WITHDRAWAL AREA

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+5m

AutoCAD SHX Text

TRANS- FORMATOR

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BOILER DRAIN TANK

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PROCESS WATER TANK

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STAND-BY GENERATOR

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0m

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RECOVERED WATER TANK

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0m

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-4,5m

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SILO

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STACK

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WxH 4500x8000

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WxH 4500x8000

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TRANSFORMER

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SWITCH- ROOM

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33kV SWITCHROOM

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0m

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BOTTOM ASH BUNKER APPROX 580M3

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CRANE MAINTENANCE AREA

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SILO

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TECHNICAL ROOM

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STORAGE WORKSHOP

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0m

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0m

General Information

11



Report Objectives The objectives of this Works Approval Application are to:

• Document the Works Approval Application to address EPA guidelines and application requirements applicable to the Works Approval Application

• Provide a summary of technical studies undertaken to support the Works Approval Application process • Demonstrate that the proposed works will meet EPA requirements for issuing a works approval to enable the

development and operation of a WtE facility at 70 Ordish Road, Dandenong South.

Supporting Documents This Works Approval Application should be read in conjunction with the following supporting documents:

• Planning Property Report (DELWP 2019) - Appendix A • Cultural Heritage Due Diligence Assessment (Biosis, 2019) - Appendix B • Preliminary Site Investigation (SMEC 2018a) - Appendix C • Detailed Site Investigation (ESP, 2018) – Appendix C • Traffic Impact Assessment (SMEC 2019e) - Appendix D • Fire Safety Study (RiskCon Engineering 2019) - Appendix E • Air emission modelling and impact assessment (Synergetics 2019) - Appendix F • Environmental Noise Assessment (WMG 2019)-Appendix G • Stormwater Management Plan (SMEC 2018b) - Appendix H • Site Environmental Management Plan (SMEC 2019d) - Appendix I • Litter Management Plan (SMEC 2019c) - Appendix J • Emissions Data from Reference Facilities (Energos) – Appendix K • Stakeholder and Community Engagement and Consultation Plan and Fact Sheets (Equilibrium 2019) - Appendix L • Greenhouse Gas Lifecycle Assessment (Start2See 2019) - Appendix M • Environmental Risk Assessment (SMEC, 2019a) – Appendix N • Human Health Risk Assessment (SMEC 2019b) - Appendix O • Auditing and Combustion Characteristics of MSW (HRL, 2018) – Appendix P • Fuel Specification (Energos, 2018c) – Appendix Q • Sarpsborg 2 Terms of Permit – Appendix R • Fly Ash MSDS and Analysis (Marchwood Scientific Services, 2011). – Appendix S • Bottom Ash Analysis (ALS, 2019) – Appendix T • CFA Meeting Minutes (CFA, 2017) – Appendix U

Proposed Scheduled Activity GSWT is proposing to construct and operate a WtE facility and is seeking a works approval under Section 19B of the Environment Protection Act 1970 (EP Act) for the production of energy at the site.

The proposed WtE facility falls under Schedule 1 of the Environment Protection (Scheduled Premises) Regulations 2017 (S.R. No. 45/2017) (the “Regulations”). Schedule type A08 – Waste to Energy provides the following description for a facility requiring a works approval and/or licence:

Premises which recover energy from waste at a rated capacity of at least three megawatts of thermal capacity or at least one megawatt of electrical power.

Exclusions from the Application GSWT is seeking a works approval for activities within the proposed works approval boundary only, as identified within Figure 1-1.

Items excluded from the works approval include:

• Waste disposal from the facility

General Information

12



• Future legislative requirements • Changes following submissions.

Site Selection The proposed site for establishing the WtE facility is situated on Lot 1 on TP205351 and located at 70 Ordish Road, Dandenong South within the City of Greater Dandenong Council (Figure 1-1). The site has a total area of approximately 1.27 hectares and is currently utilised as a sand blasting and industrial painting facility.

The proposed site is appropriately positioned to establish a WtE facility as it is located within an industrial zone (IN2Z) and surrounded by existing industrial land with buffers of greater than 500 meters to sensitive receptors. The Statewide Waste and Resource Recovery Infrastructure Plan (SWRRIP) (SV, 2018) also identifies Ordish Road, Dandenong South as one of 22 waste and resource recovery hubs of state importance. These hubs are identified as potentially suitable sites to support future waste and resource recovery development due to existing infrastructure located within the hub.

The adjacent lots to the north, south and east contain other industrial enterprises including waste-handling facilities and an existing hazardous waste incineration facility. Land to the east and west of the proposed site is zoned Industrial 1 Zone (IN1Z), which seeks to develop the land for more intensive industrial land uses. North of the proposed site is land zoned Industrial 3 Zone (IN3Z), which permits industrial land uses but also seeks to provide an appropriate transition between industrial land uses and residential land uses.

The nearest sensitive receptors, as defined as places and environs that have the potential to be impacted by the project, or industry in the local area, are presented in Table 1-2.

Table 1-2: Sensitive Receptors

RECEPTOR SEPARATION DISTANCE FROM PROPOSED SITE (m) LOCATION

Dandenong Creek 160 West

Residential Properties (Keysborough) 600 West/South West

School (Mt Hira College) 1,400 North-west

Residential Properties (Somerfield) 1,500 North-west

Religious Worship Centre (Sikh Temple) 1,500 North-west

Religious Worship Centre (Buddhist Temple) 1,400 North-west

Freemasons Victoria 1,900 North-west

EPA Publication 1518 Recommended Separation Distances for Industrial Residual Air Emissions (EPA, 2013b) provides advice on recommended separation distances between industrial land uses that emit odour or dust, and sensitive land uses. However, for ‘Advanced Resource Recovery Technology Facilities’, the Publication notes that separation distances are to be assessed on a ‘case by case’ basis. Although no specific separation distance is provide for Waste to Energy facilities in EPA Publication 1518, the maximum recommended separation distance for provided waste management land uses is 500 m.

Further discussion regarding potential emissions from the facility and impacts to receptors are presented in the air emissions assessment (Section 5.2) and human health risk assessment (Section 5.3).

Land Use 1.7.1 Planning and other approvals

The proposed site is zoned Industrial 2 Zone (IN2Z) pursuant to the City of Greater Dandenong (Council) Planning Scheme. Under the Planning Scheme the facility is defined as an Industry, and a planning permit is required. A planning permit application is currently being prepared by GSWT and will be submitted to Council concurrently with the works approval, noting that a joint process is not being utilised.

General Information

13



No planning overlays apply to the site. Those parts of the site within 200m of the Dandenong Creek are mapped as an area of Aboriginal cultural heritage. (refer to Table 1-3). The site is not located within a designated bushfire prone area and no special bushfire construction requirements apply. A Planning Property Report is included in Appendix A. Table 1-3 below provides a summary of other environmental approvals which are relevant to the proposed facility.

Table 1-3: Review of relevant legislation and approvals

LEGISLATION PROJECT PHASE APPLICABLE DESCRIPTION/RECOMMENDATION

COMMONWEALTH

Environment and Biodiversity Conservation Act 1999 (EPBC Act)

Construction No The project will not be referred to the Minister for Environment as the project will not have a significant impact on any Matters of National Environmental Significance (MNES) protected under the EPBC Act

STATE

Planning and Environment Act 1987 (PE Act)

Construction Yes A planning permit is required under the City of Greater Dandenong Planning Scheme. A planning permit application has been prepared and submitted separately by a third party.

Environmental Effects Act 1978 (EE Act)

Construction No The requirement for an Environmental Effects Statement (EES) referral for the project is not triggered under the referral criteria.

Environment Protection Act 1970

Commissioning Yes Subject to a works approval, GSWT will need to apply for a commissioning approval to allow for emissions during the commissioning phase of the project.

Heritage Act 2017 Construction No A permit is not required for the proposed works as there are no Heritage Places or Heritage Overlays within the site boundary or immediate surrounds. Results of the cultural heritage due diligence assessment are included in Appendix B.

Aboriginal Heritage Act 2006

Construction No The site is located partially within an Area of Cultural Heritage Sensitivity due to being within 200m of Dandenong Creek. Due to the high level of previous land disturbance at the site, it is considered highly unlikely to retain any Aboriginal cultural heritage values and does not trigger the requirement for a mandatory Cultural Heritage Management Plan (CHMP). Results of the cultural heritage due diligence assessment are included in Appendix B.

Flora and Fauna Guarantee Act 1988 (FFG Act)

Construction No No FFG Act-listed species or communities are to be impacted by the proposed works. Additionally, a permit under the FFG Act is not required on private land.

Occupational Health and Safety Act 2004

Operation Yes Dangerous Goods - there is a requirement to consult with the CFA regarding storage and handling arrangements for Dangerous Goods.

Catchment and Land Protection Act 1994 (CaLP Act)

Construction / Operation

Yes No further actions under the CaLP Act are required for this project. A Construction Environmental Management Plan (CEMP) will be implemented to manage weeds during construction.

Water Act 1989 Construction / Operation

No As works will not impact on any adjacent waterways, no further action under the Water Act 1989 is required for this project.

Company Details GSWT is a Melbourne-based Australian company that believes WtE has a pivotal role in Melbourne’s waste management future. WtE can support Government and community objectives by supporting good recycling and resource recovery programs and delivering improved environmental, economic and social outcomes for residual

General Information

14



waste management. Additionally, WtE provides a significantly improved outcome regarding greenhouse gas emissions when compared to the alternative of landfilling.

In a relatively short period of approximately three years, GSWT has established:

1. A greenfield research and development facility in Dandenong South for the trialling of waste processing technologies and auditing of local municipal and commercial waste streams as a prelude to the development of full scale AWT (alternative waste treatment) waste processing facilities, initially in Melbourne. Trials and audits in cooperation with the State Government’s Metropolitan Waste and Resource Recovery Group (MWRRG) and Greater Dandenong Council have been conducted at this site since 2017.

2. During the last two years, GSWT’s parent company SJC Contractors Pty Ltd designed and developed Australia’s largest waste transfer station for Cleanaway at Thomas Murrell Crescent, Dandenong South, of which it retains ownership.

3. Following extensive worldwide research of available WtE technologies, GSWT has established an exclusive license and engineering agreement with Energos - AS (Norway) for the design and supply of proven and leading-edge technology for the first MSW and C&I Waste to Energy facility to be built in Dandenong South.

GSWT has also been involved in the following projects.

• Cleanaway Waste Transfer Station - Dandenong South (2015) • GSWT: Funded and trialled investigation of alternatives to the disposal of clean Green Waste – solution found • GSWT: Funded and trialled food de-packaging equipment • GSWT: Funded to seasonally audit MSW for the Dandenong area • GSWT: Funded to look at best fit community size WtE Technology from globally available information • GSWT: Funded to advance all costs relative to lodgement of Town Planning and EPA/WA for 70 Ordish Rd

Dandenong South

Table 1-4: Company details

INFORMATION DETAILS

Registered Name Great Southern Waste Technologies Pty Ltd

ABN

ACN

74 606 159 175

606 159 175

Registered Address C/of:

KMS Financial Solutions Pty Ltd

Suite 4, 259 Whitehorse Rd, Balwyn, Vic 3103 T 03 9880 4999 F 03 9880 4962

Company contact details GSWT Project Manager: Mr. Denis James

P: +61 418 390 584

E: [email protected]

mailto:[email protected]

Regulatory Compliance Assessment

15



Regulatory Compliance Assessment Legislative Context

Section 1A(3) of the Environment Protection Act 1970 (EP Act) requires the EPA to consider the environment protection principles set out in the EP Act in its assessments and decisions. Applicants for a works approval are required to demonstrate how they have considered the environment protection principles, and this information is considered during an assessment of the application.

In assessing a Works Approval Application against the environment protection principles, EPA publication 1565 Application of environment protection principles to EPA's approvals process (2014) is applied. This publication details how applicants should consider the environment protection principles when developing proposals and preparing applications for an EPA approval.

The following key principles of the EP Act were identified for this WAA and are described below:

• Section 1B Integration of economic, social and environmental considerations • Section 1C The Precautionary Principle • Section 1l Waste Hierarchy.

Sections 5.2, 5.3 and 5.4 of this Works Approval Application outlines how the application has been developed with consideration for the principles of environment protection and how the application meets the objectives of environmental protection principles.

2.1.1 Section 1B - Integration of economic, social and environmental considerations

The purpose of this principle is to allow effective integration of economic, social and environmental considerations in decision-making processes to improve community wellbeing and the benefit of future generations

GSWT anticipates that the facility will receive and treat approximately 100,000 tonne per annum of waste being used in the gasification process to generate 7.9 MW of electricity to be fed into the grid, the power generated by the facility is sufficient to power approximately 7,000 homes and will divert MSW and C&I from landfill. Waste is likely to be sourced from local Councils, however may also be sourced from the broader Melbourne Metropolitan Area.

In Australia over 21 million tonnes of waste is sent to landfill each year, losing the embodied energy of these wastes and increasing greenhouse gas emissions by producing methane. The facility will use proven technology to recover this energy from the waste and enable it to be exported into the grid to benefit industry and the community. This will “close the loop” on this valuable resource and reduce overall greenhouse gas emissions while offering a sustainable improvement to waste management services currently being provided in Dandenong South. Implementation of this project will provide environmental benefits for future generations through effective management of waste and will not have a negative impact on health, diversity or productivity.

Economic, social and environmental benefits to be realised through implementation of this project include:

• Diversion of waste away from landfills and thereby managing the risk of increasing volumes of waste being generated in Victoria adversely impacting the environment through landfilling and increasing landfill capacities

• Generation of renewable energy which will decrease dependence on fossil fuels and assist in providing a stable renewable power supply for Victoria

• Renewable energy produced will be available 24 hours a day, seven days a week regardless of the time of day or weather conditions, providing base load renewable energy

• Private investment in much-needed waste infrastructure and will alleviate some of the rising demand for power expected from anticipated population and industry growth within the region and diversify the power supply

• Creation of 20 direct operational jobs, and an additional 150 jobs during construction.

On the basis of the benefits discussed above, it can be considered that the Works Approval Application meets the principle of integration of economic, social and environmental considerations.


16



2.1.2 Section 1C - The Precautionary Principle

The Precautionary Principle should be applied where there are threats of serious or irreversible damage. Lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. In the application of this precautionary principle, decisions should be guided by:

• Care and evaluation to avoid, where practicable, serious or irreversible damage to the environment • Assessment of the risk-weighted consequences of various options.

WtE is a well-established, regulated industry that occurs globally, including in compliance with the European Union’s Industrial Emissions Directive 2010/75/EU (IED). Potential environmental risks and impacts are well known, with evolving improvements in emission containment, control and monitoring technologies.

The proposed technology has been subject to rigorous feasibility evaluation in terms of site selection and operational impacts. The technology selected is proven, with numerous operational facilities in Europe, successfully operating within IED emissions limits (as further discussed in Section 5.2).

A risk assessment has been undertaken for key and relevant environmental factors associated with the project, informed by specialist studies and site investigations (see Appendices). Modelling for noise, emissions and greenhouse budgets have been undertaken.

Appropriate controls on waste feedstock and monitoring programs will form licence conditions of the works approval. This will include a Continuous Emissions Monitoring System so air emissions can be monitored, and actions implemented to mitigate potential impacts to sensitive receptors.

Specialist studies have provided a number of improvements to be implemented at the facility, which will further minimise potential impacts, with residual impacts considered to be acceptable. On the basis of the findings presented in this application, it is be considered that the Works Approval Application meets the Precautionary Principle.

2.1.3 Section 1I - Waste Hierarchy

The waste hierarchy is one of eleven principles of environmental protection contained in the EP Act, and its application has been considered throughout the development of the proposal. Further information regarding the waste hierarchy is detailed in Section 4.5.5.2.

The waste hierarchy is fundamental to EPA’s assessment of waste management facilities. The hierarchy establishes an order of preference for waste management. Recovery of energy from wastes that would otherwise have been landfilled is a preferential outcome in accordance with the waste hierarchy and avoids the potential adverse environmental outcomes associated with reduced landfill capacity and ongoing issues which may arise from landfilling waste, including leachate management and contamination which can require ongoing management well beyond the operational life of landfill sites.

WtE provides the best practicable environmental outcome for the management of waste when it has a gross calorific value that can be recovered. WtE should be considered where generation of waste cannot be avoided, and waste cannot be recovered for productive purposes through re-use and recycling.

The operating philosophy to be employed at the proposed facility will be to not negatively impact on higher-order waste management, those being recycling, reuse, and avoidance. Prior to reaching the facility, feedstock waste will have undergone source separation to remove recyclable waste. Separation of ferrous and non-ferrous metals will be undertaken during the process.

It is currently proposed that bottom ash and fly ash will be disposed to landfill, however future reuse of waste ash remains a possibility and will be further investigated by GSWT, providing a more preferable option on the waste hierarchy by moving from “disposal” to “re-use” in the waste hierarchy. The reduction by volume from the incoming waste once completion of the gasification and oxidation stages results in an approximate 10 fold reduction by volume of the received material, further reducing landfill capacity demand if the bottom ash and fly ash is not able to be beneficially reused.

Diversion of waste from landfill represents best practice for both waste management and environmental protection. It is considered the Works Approval Application is consistent with the objectives and preferences of the waste hierarchy.


17



Statewide Waste and Resource Recovery Infrastructure Plan (SWRRIP) The SWRRIP (SV, 2018) was developed by Sustainability Victoria on behalf of the Victorian Government. The SWRRIP provides a long-term vision and roadmap to guide planning of future waste and resource recovery in Victoria. It includes a number of goals and strategic direction to improve waste management through maximising recovery and minimising adverse impacts on the community, environment and public health.

The SWRRIP identifies the need to consider new technologies that promote recovery of energy from residual waste and reduce reliance on landfills (Strategic Direction 2). The SWRRIP specifically supports strategically located waste to energy facilities, as a means of processing material where higher order recovery is not viable.

The SWRRIP also identifies Ordish Road, Dandenong South as one of 22 waste and resource recovery hubs of state importance. These hubs are identified as potentially suitable sites for new infrastructure, noting the existing infrastructure located within the hub to support future waste and resource recovery development.

The draft Works Approval Application was reviewed by Sustainability Victoria (25 June 2019) to assist EPA to determining whether the proposal is in accordance with Section 50c of the Environment Protection Act 1970.

(1) The Authority may refuse to consider an application for a works approval or an application for the issue or amendment of a licence in relation to a waste management facility if –

a. The operations of the facility could be inconsistent with the Statewide Waste and Resource Recovery Infrastructure Plan or a relevant Regional Waste and Resource Recovery Implementation Plan.

The response received from Sustainability Victoria indicates that the proposed WtE facility could be considered consistent with the SWRRIP, noting the role waste to energy has to play in reducing reliance on landfill, and the facility’s proposed location within the identified waste and resource recovery hub of Ordish Road.

Metropolitan Implementation Plan The Metropolitan Implementation Plan was developed by the Metropolitan Waste and Resource Recovery Group (MWRRG) in 2016, in response to the SWRRIP. The Implementation Plan was developed specifically for the wider metropolitan region, consisting of 31 municipalities, with an aim to reduce landfilling by making use of resource recovery infrastructure and alternative technologies. The Implementation Plan is intended to support community, local governments, industry and Victorian Government organisations with a range of initiatives to achieve a step change in how Melbourne manages waste.

Strategic Objective 1 of the Implementation Plan aims to “Reduce waste sent to landfill”. The objective seeks to increase the availability of viable resource recovery infrastructure to reduce the reliance on existing landfills and the need for new facilities. Four actions have are detailed in the Implementation Plan (MWRRG, 2016) to achieve Strategic Objective 1, being:

(1) Facilitate and establish new infrastructure that can recover resources from residual municipal waste through the re-tendering of MWRRG’s landfill services contracts

(2) Create opportunities for aggregating priority commercial waste material streams and other place based recovery solutions

(3) Support local government to progressively increase recovery of materials from municipal waste streams (4) Facilitate the growth of the metropolitan resource recovery centre/transfer station network in order to

manage future waste volumes and increase resource recovery.

The draft Works Approval Application was reviewed by MWRRG (13 June 2019) to assist EPA in determining if the proposal is consistent with the Metropolitan Implementation Plan. As the proposed facility is consistent with Strategic Objective 1 and the general objectives of the Implementation Plan, MWRRG confirmed the proposed facility aligns to the strategic intent of the Implementation Plan.


18



Community Engagement Community and stakeholder engagement is being conducted by GSWT, with support from consulting and stakeholder engagement organisations, as is required by the works approval process (EPA Publication 1658 Works Approval Application). A summary of community and stakeholder engagement conducted by GSWT to date is provided below.

The key outcomes of the pre-construction community engagement, which has been underway since mid-2018 include:

• Provision of information about the proposed facility to the community and seeking initial feedback. • Primary community concerns raised during the community engagement related to air quality, noise, amenity,

traffic congestion, water management and flooding, and reporting and accountability of the facility. • Identified community concerns were further assessed through the assessment phase and addressed in the design

process.

Ongoing consultation with Greater Dandenong City Council and Environment Protection Authority Victoria has also occurred, to address potential issues through the assessment and design phase.

The specific community engagement activities that have been undertaken include:

• Identified stakeholders • Documented a community and stakeholder engagement plan • Documented stakeholders and mapped stakeholder issues • Completed 10 face-to-face meetings (see presented in Table 3-1) • Completed phone consultations of the project • Organised a public forum (held on 20 March 2019) • Developed information sheets (as presented in Appendix L) • Distributed information sheet • Updated and maintained website.

A summary of stakeholders met and contacted is presented in Table 3-1.

Table 3-1: Stakeholders Contacted for Face-to-Face Meetings

ORGANISATION MET/CONTACTED MEETING REPRESENTATIVES

Residents Against Toxic Waste in South East (RATWISE) Met Meet with three RATWISE members. (Met on the 26th October

2018) Greater Dandenong Environmental Group Met Meeting with two representatives. (Meeting on the 24th January

2019) Dandenong Councillors Met Mr Matthew Kirwan, Ms Angela Long (Red Gum Ward)

Environment Victoria Met Meet with Dr Nicholas Aberle (Met on the 8th October 2018)

EPA Met GSWT and SMEC contacted Dandenong Council: Senior Staff Met Mr Brett Jackson, Ms Julie Reid, Mr Phil Robertson

Metropolitan waste and resource recovery group Met Mr Rob Millard and Mr Paul Clapham

Victorian Waste Management Association Contacted Mr Mark Smith

Waste Management Association of Australia Contacted Ms Gayle Sloan

National Waste and Recycling Industry Council Contacted Ms Rose Read

Clean Energy Council Contacted Ms Maryanne Coffeey

Total Environment Centre Contacted/Phone Consultation Mr Jeff Angel

Australian Conservation Foundation Contacted Ms Kelly O’Shannassy

Stop the Tip Contacted/Phone Consultation Interested in project but did not want to meet.


19



ORGANISATION MET/CONTACTED MEETING REPRESENTATIVES

Environmental Justice Australia Contacted/Phone Consultation Ms Emily Morrison and Ms Sarah Brugler (To meet later)

Dandenong Council: Contacted all Councillor’s

Contacted/Phone Consultation

Lightwood Ward, Paperbark Ward, Mr Jim Memeti, Silverlead Ward

DELWP Met Ms Angela Hoefnagels

Sustainability Victoria Met Mr Guy Pritchard

Phone consultations were conducted with stakeholders who did not have time to meet one-on-one with the GSWT team. The phone calls included a general overview of the project with specific information such as planned throughput tonnages, environmental outputs and timelines. Each participant was encouraged to get back in contact with the stakeholder engagement team if they had anymore queries or questions following the phone call. All organisations contacted in the table above were given the opportunity to meet with the GSWT team or ask further questions over the phone.

A public forum was held on 20 March 2019 at Quest Dandenong, which provided further opportunity for the community to be informed of the project and for GSWT to hear any issues arising. The public forum, which was held from 4pm to 6pm, had 10 members of the community and neighbours visit to ask questions and discuss the project with the representatives of GSWT.

A variety of organisations were represented with community groups attending such as Residents Against Toxic Waste In South East (RATWISE) and Greater Dandenong Environment Group, neighbouring businesses such as U-Neek Bending and the general community with interest in the project. Ace Waste, a direct neighbour to 70 Ordish Rd, was unable to attend the event but advised they were still interested in receiving information. GSWT passed on the fact sheets and had discussions with Ace Waste about the project separately to the forum.

The main question raised by attendees was the amount of waste that will be consumed by the plant each year. This was explained by GSWT representatives that the plant offers a local based waste management solution and that approximately 100,000 tonnes of waste would be diverted from landfill each year, the approximate equivalent of three councils.

This was seen positively by the attendees as the facility is a local based waste solution and not a large plant. Another issue raised by a member of the community was the impact of geotechnical forces due to the geology and if this is considered in the design of the plant. They were advised the facility will comply with relevant provisions of the National Construction Code which will ensure that earthquake risks are considered as part of detailed design. Overall the participants all saw the project in the positive light and understood its advantages to landfill.

In addition to the general questions above the following questions were raised at the meeting, with all questions answered on the day by GSWT representatives.

Table 3-2: General Questions

QUESTION RESPONSE

How will the project be funded, is it government funded? GSWT explained that the site will be financed without government funding.

What are the environmental implications of the project?

GSWT discussed how the facility will deliver improved environmental outcomes by diverting waste from landfill and generating energy and reducing greenhouse gas impacts.

Where will the waste come from? Representatives explained that this size plant provided a localised solution in which waste would be collected to the equivalent of three councils within the local area.

How much noise will the plant make? The plant is not expected to generate excessive noise beyond what is already generated in close proximity to the site.


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QUESTION RESPONSE

Does GSWT own the technology? GSWT has not developed the technology however GSWT has secured the Australian rights for the technology.

Where is Energos from? Energos has experience throughout Europe with seven plants currently operating in Norway, where Energos was established.

A summary of community and stakeholder engagement completed to date is presented in Table 3-3.

Table 3-3: Community and Stakeholder Engagement Timeline

2018

Month Activity and engagement

April

27th – Greater Dandenong Council staff meeting and briefing (Brett Jackson, Julie Reid, Phil Robertson

10th – Department of Environment, Land, Water and Planning staff meeting and briefing (Angela Hoefnagels, Christopher Lane)

10th – Sustainability Victoria (Guy Peritchard)

30th – Environment Protection Authority Victoria (Tim Eaton, Tim Faragher)

May Offered meetings to stakeholders

June 21st – Cr Angela Long (Red Gum Ward)

25th – Cr Matthew Kirwan (Red Gum Ward)

July Offered meetings to stakeholders

August Offered meetings to stakeholders

September Offered meetings to stakeholders

October 8th – Nick Aberle, Environment Victoria

26th – Residents Against Toxic Waste In South East

2019

January 24th – Greater Dandenong Environmental Group

February Email set up, phone number set up, website under development

March

Website live

Phone number live

11th - Advertisement released for community meeting on 20th March 2019

20th - Dandenong Ranges Renewable Energy Association, members attended community meeting

20th - Community meeting- 10 attendees, all issues addressed at the forum (see summary in attached consultation report)

April Fact sheets updated in website, monitor phone line, email, website

May Monitor phone line, email, website

June Monitor phone line, email, website

July Monitor phone line, email, website


21



The Community and Stakeholder Engagement and Consultation Plan (Equilibrium, 2019) is presented in Appendix L.

GSWT will remain available for further stakeholder consultation, should it be deemed necessary through the Works Approval Application phase.

Process and Integrated Environmental Assessment

22



Process and Integrated Environmental Assessment Proposed Facility

4.1.1 Site Layout

The site for the proposed facility is located at 70 Ordish Road Dandenong South, Victoria (see Figure 1-1). The site forms part of a larger lot (the remainder now incorporated into 64-68 Ordish Road) which contains a large, undeveloped grassy area backing on to Eastlink Freeway and Dandenong Creek to the west of the site. The adjacent lots to the north, south and east contain other industrial enterprises, including waste-handling facilities and a hazardous waste incineration facility.

The site is located within the Greater Dandenong local government area and is zoned as an Industrial 2 Zone (IN2Z). Eastlink Freeway occurs to the west, Greens Road to the north and Ordish Road to the east. The site is located within an industrial precinct with the only environmental receptor of note being Dandenong Creek which is approximately 160m from the western boundary of the site.

A carpark will be located along the road frontage of Ordish Road, with vehicle entrance located along the southern boundary and vehicle exit along the northern boundary. The site office and weighbridge are located adjacent to the entrance. The main facility is positioned in the centre of the site on the existing hardstand area. The turbine room and condenser are situated along the western boundary of the site.

As part of the Waste to Energy facility, there will be a Visitor/Education Room. This room will have direct access to an internal glass partition which will enable visitors to view the receival of waste, overhead crane operation, waste pre-treatment and fuel bunkers and be used for community and school group educational programs.

The proposed site layout is presented in Figure 4-1.


23



Figure 4-1 Site Layout (source: RPC Architects)


24



4.1.2 Site Access and Road Infrastructure

The facility will be accessed from Ordish Road. Emergency vehicles will also be able to access the facility via this entrance. Weighbridges will be provided at the northern and southern side of the property along Ordish Road to enable both control and weighing of vehicles entering and vacating the site. In the event of a weighbridge closure, vehicles will be able to both enter and vacate the site from either access point. Each ingress lane has the capacity to store two trucks prior to the weighbridge, which allows for a storage of five trucks at the entrance point into the facility including a truck stopped at the weighbridge. The facility will accommodate a total of 13 trucks within the waste acceptance bays, forecourt area and weighbridge at any given time. An assessment of the vehicle processing capacity of the facility, available waste storage and arrival truck volumes, has determined that there is unlikely to be vehicle queuing on Ordish Road (refer to Appendix D).

The maximum speed limit at the facility is proposed to be limited be 5 kilometres per hour. On-site speed limits will be clearly displayed and monitored as part of the facility’s safety management system.

Further detail regarding traffic movements and vehicle access to the site are presented in Appendix D.

4.1.3 Site History

4.1.3.1 Preliminary Site Investigation

As part of the Preliminary Site Investigation (PSI) (SMEC 2018a; Appendix C), SMEC reviewed the site history, covering a period between 1968 and 2018. Aerial imagery was used to complete the review. A summary of the key findings of the investigation are provided below:

• A fence was installed on the eastern boundary of the site prior to 1968 • The site was cleared for what is assumed to be agricultural activities prior to 1968 • The site was utilised for industrial purposes between 1968 and 1977; lots to the north and south of the site were

utilised for industrial purposes during this period. Infrastructure built on site during this period includes factories and plant

• A substantial water treatment plant was built approximately 200m to the north of the site between 1968 and 1977

• The site continued to be used for industrial purposes from 1977 to 1989 • The water treatment plant was decommissioned between 1989 and 2009 • The existing factory was built on the site between 1989 and 2009 • The existing carpark was built on the eastern side of the site in 2010 • The existing open air storage bays were built on the site in 2016 • There were no visible changes to the site from 2016 to 2018.

A search of the current and historic certificates of title confirmed that the site has changed ownership on five occasions since 1982 and has been solely used for industrial purposes since this time.

A search of the Victorian EPA Priority Site Register has confirmed that the site is not listed as an EPA Priority Site.

A review of the EPA list of Environmental Audits was conducted to determine if any audits had been undertaken within a 500 m radius of the site. Environmental Audits assess the nature and extent of contamination, or potential risk to the beneficial uses, to the environment associated with activities on the land. No audits were identified in this review.

Findings of the Detailed Site Investigation are discussed in Section 5.6.

4.1.4 Hours of Operation

The facility will receive waste seven days per week, receiving approximately 100,000 tonnes per year (+/- 10 per cent) from approximately 48 waste collection vehicles visitations per day. The facility will be operational 24 hours a day, although waste arrivals are expected to typically coincide with morning and afternoon kerbside collections (nominally 9-10am and 1-2pm). Plant maintenance periods for up to a total of four weeks each year are anticipated.

4.1.5 Process and Technology

The waste hierarchy (refer to Figure 4-10) is one of eleven principles of environment protection contained in the EP Act. The proposed process and technology to be utilised in the facility will be diverting residual municipal and suitable


25



commercial and industrial waste from landfill disposal, the least preferred method of management, to recovery of energy, the fourth most preferred method of management.

4.1.5.1 EPA Requirements

Section 5.3 of the Works Approval Application (Publication 1658) requires proponents to provide a description of their proposed development including the key technical processes, inputs, outputs and process controls. The following information responds to these requirements and provides the basis for subsequent assessment of environmental risks associated with the project.

4.1.5.2 Selection of Process and Technology

Recovery of energy from waste is a higher-order waste management option than landfill (disposal), addressing the economic issue of waste being a lost resource. Landfills also have the potential to impact the environment and communities long after they have stopped receiving waste (e.g. odour; groundwater pollution; surface water pollution; gaseous emissions). As such, the period of aftercare management (from when the site is closed) can be up to 30 years for licensed sites and buffer distances are required to remain during the post-closure period to address potential risks.

WtE facilities have the potential to reduce waste sent to the landfill by up to 80 per cent (or around 95 per cent if it is practicable for the ash products to be diverted from landfill for beneficial reuse by the construction industry), minimising dependency on new and expanded landfills and ensuring that existing landfill capacity is retained for contingencies and unrecoverable materials into the future. As compared to traditional landfilling, WtE facilities provide a controlled and measurable system of all inputs and outputs.

As outlined in Section 1.8, GSWT has a background in the waste management industry, with experience encompassing waste transfer stations and research into waste processing technologies. GSWT has undertaken extensive worldwide research of available WtE technologies and has established an exclusive licence and engineering agreement with Energos - AS (Norway) for the design and supply of proven and leading-edge gasification technology. A key factor in GSWT’s selection of Energos Technology is its successful operational record in Scandinavia and consistent ability to meet European Union (EU) environmental performance criteria. Energos gasification plants have completed over 1 million operational hours of reliable performance.

The GSWT concept for alternatives to landfill is compatible with WtE technology and comprises:

• Safe, reliable and proven technology functioning over many years and achieving world’s best practice environmental outcomes and greenhouse gas reductions

• Scale that allows local/regional waste management solutions and avoids the need and increased carbon footprint to double-handle waste through transfer stations

• Modular design that allows ease of expansion as population and waste volumes increase and availability of landfill airspace diminishes

• Module size that minimises impact on customers during maintenance shutdown • Accepts MSW and C&I waste inputs similar to Australian waste currently going to landfill • Process design and flexibility capable of handling changes in infeed wastes over time, especially as new

recycling markets arise.

Over almost 15 years GSWT management has reviewed and met with most of the major global alternative-to-landfill-technology suppliers, visiting technology plants in Singapore, EU, UK, USA and Canada, observing the following technologies:

• Mass burn moving grate systems. • Fluidised bed systems. • Static grate gasification systems. • Updraft and downdraft gasification systems. • Plasma arc systems. • Anaerobic Digestion plants. • MBT and RDF plants.

As a result of the above considerations, GSWT identified Energos as the most suitable technology partner that best aligned with the GSWT corporate vision and objectives. GSWT considers that the future of waste management lies in


26



regional solutions which minimise costly transportation requirements and associated environmental emission impacts. It is considered that the scale of the Energos system proposed for this development meets this regional solution philosophy. A benefit of the Energos system is that it is a modular design that can be easily upgraded in the future to cater for increased waste feedstock, and conversely can be scaled back without a decrease in performance. The relatively small footprint of WtE technology allows for a number of benefits including:

• Siting of the facility close to users of electricity generated from the site • Minimising the capital and maintenance costs and energy losses of electricity transmission infrastructure • Low building elevation (as compared to similar facilities) minimising the visual impact of the proposed facility.

As landfill airspace is depleting across Victoria, the Energos WtE technology provides a solution that reduces the reliance on landfills, delivers improved environmental (reduced greenhouse gases; improved resource recovery) outcomes, and contributes new, reliable and partially renewable base load power to the Melbourne population.

Another benefit of the Energos technology is its capability to cope with a varying range of MSW and C&I feedstock mixtures, moisture contents and calorific values.

4.1.5.3 Technology Description

The Energos WtE technology is classified as a gasification process as it converts solid waste into a synthetic gas (syngas) which is thermally converted. The energy captured is then utilised for steam production which can be utilised in electricity generation.

Energos technology which will be utilised for the facility is a two-stage thermal process, which eliminates the need for sophisticated flue gas cleaning systems. The process includes drying, pyrolysis, gasification and oxidation. The gasifier unit is horizontally divided into a primary chamber where drying, pyrolysis and gasification of the solid waste takes place, and a secondary chamber is where the oxidation of primary gases is completed.

The Energos gasification process consists of two thermal conversion stages:

1. Gasification stage: Partial oxidation and gasification of the waste to syngas takes place in the primary chamber on a fixed grate at sub-stoichiometric oxygen conditions (where the air to fuel ratio=λ=0.5 - 0.8). The waste is fed into the primary chamber at a controlled rate where it is directed onto a grate. At the ‘cooler’ input side of the primary chamber, the dominant process occurring is drying of the waste. Then follows a section of pyrolysis and then gasification where the syngas is produced. There is also a carbon burnout section at the ‘hot’ end, before the decarbonised waste falls into a water bath / air lock where it is removed and transported as bottom ash. Temperatures are maintained at a minimum of 820 degrees Celsius in the primary chamber.

2. The second thermal conversion stage is combustion. The syngas generated in the primary chamber flows through to the secondary chamber where oxygen is introduced, and the syngas is fully combusted. The temperature in the secondary chamber maintains a minimum 850 degrees Celsius for a minimum of two seconds.

The heat of the combustion gases from the second conversion stage is then transferred to steam in a heat recovery system for the generation of electricity. Formation of nitrous oxides (NOx) is minimised and any dioxins in the feed are destroyed in the combustion chamber. Rapid cooling occurs in the energy recovery system such that reformation of dioxins is avoided. A key benefit of the process is that it is able to achieve the low NOx emissions without the need for additional ammonia which is typically the case with Mass Burn Incineration technologies.

A key aspect of Energos’ technology that ensures high thermal efficiency and low emissions is the pre-treatment of waste to ensure a sufficiently high surface-to-volume ratio and a low content of metals (see Section 4.1.10).

Further performance details of the existing Energos facilities in Europe are included below in Section 4.1.6, with existing facilities performing in accordance with requirements of “Directive 2010/75/EU of the European Parliament” and the Council of 24 November 2010 on the incineration of waste by use of cost-efficient flue-gas cleaning.

4.1.5.4 Process Description

Figure 4-2 shows a perspective view of the proposed plant. Note this is for a single-line plant, whereas the proposed plant is dual-line. The process flow diagram outlined in Figure 4-3 shows the dual lines which are proposed at the Dandenong South site. A description of all processes is included in Table 4-1.


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Figure 4-2 High Level Plant Overview

Figure 4-3 Process Flow Diagram of Waste to Energy Plant

Waste in

7-8

9

16

10-14

2

1 3-6


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Table 4-1 Process flow descriptions

STEP COMPONENT

1

Waste bunker: Waste will be delivered to the site by waste collection vehicles and unloaded in the waste bunker located within the purpose built building. The waste bunker will be sized to receive feedstock at a rate which can supply a product suitable for gasification at a nominal rate of 12.8 t/hr. An initial visual inspection by the operator will be undertaken to identify any obvious materials that could pose a risk to operation of the facility or the environment and require immediate removal (refer to Section 4.2). An overhead crane system feeds the shredder which reduces the waste to a uniform particle size. The shredder discharges to the fuel bunker from where the overhead crane system loads the fuel into the gasification chamber. The pre-treatment system includes the waste receipt bunker, overhead cranes, shredder with belt conveyors, magnetic belt for metal separation, a pick-up crane to remove unwanted material and finally the fuel bunker.

The overhead crane system is utilised to deliver the required quantity and composition of fuel to the shredder (i.e. select the desired mix of waste materials to achieve the optimum fuel mix in terms of moisture, calorific value and rate of supply).

2

Shredder: The shredder, which will be a METSO 6000 or similar type, shreds the fuel to a uniform particle size to maximise the efficiency of the gasification process and minimises the ash and emissions. The shredder will have contingency in its load capacity to manage materials such as logs greater than 500mm diameter and bricks, although it is expected these products will not make it to the shredder. Prior to shredding, the pick-up crane will be used to pick out obvious unwanted material from the incoming waste. The overhead crane then loads waste into the shredder. Following the shredding process, ferrous metals remaining within the shredded waste are extracted via an overbelt magnet and transferred to storage containers for recycling. Shredded waste (fuel) is then unloaded in the fuel bunker.

3-6

Fuel bunker: The shredder and fuel pre-treatment system directly discharges into the fuel bunker. Fuel is transferred from the fuel bunker by an automatic overhead crane and unloaded into the feed hoppers which directly load into the feeding chamber of each gasification chamber. The fuel mixture is subsequently conveyed from the feeding chamber into the gasification chamber. The bunker hall (waste bunker, shredder and fuel bunker) is managed via a continual negative air pressure system which assists the air flow management for the gasification chamber. The use of this air pressure and control system manages odour emissions from the facility by restricting air flow from the bunker hall and directing all flows through the gasification process.

7 – 8, also 15

Thermal Conversion (Gasification & High Temperature Oxidation): Thermal conversion commences in the gasification chamber. Drying, pyrolysis and gasification (production of syngas) of the fuel is carried out in the primary (gasification) chamber. In the secondary (high temperature oxidation) chamber, a staged oxidation is facilitated by multiple injections of air and recycled flue-gas and energy is produced in the form of heat.

The gasification chamber is equipped with a fixed horizontal oil-cooled grate that is divided into several separate sections, each with a separate air supply. This configuration allows the grates to move independently of each other allowing a consistent gasification process to occur. A hydraulically operated water-cooled plunger feeds the fuel directly onto the gasifier grate providing a constant and consistent stream of fuel loading. Assisting the complete gasification process and consistency of process, a water-cooled guillotine is installed at the inlet of the gasification chamber to contribute to controlling the thickness of the fuel bed. A hydraulically operated water-cooled feeder (duplex feeder) ensures transportation of the fuel along the grate maintaining maximum exposure of the fuel to the gasification process. The duplex feeder maintains the longitudinal transport of the fuel through the gasification chamber and facilitates a good local mixing on the moving fuel bed to ensure maximum gasification and minimal ash and emissions are produced. The main control system regulates the fuel-feeding rate into the gasification chamber as well as transportation along the grate. The bottom ash is discharged from the gasification chamber at the end of the grate. The discharged bottom ash is cooled in a water basin and transported to the bottom ash storage. The stored bottom ash is transported for disposal to a suitable landfill by truck at regular intervals, or beneficial reuse where suitable opportunities are identified.


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STEP COMPONENT The synthetic gas (syngas) produced in the gasification chamber is transferred via a direct channel feed to the high temperature oxidation chamber. Injection of air and re-circulated flue-gas through distributed nozzles in the high temperature oxidation chamber ensures temperature control and complete high-temperature oxidation of the syngas from the gasification chamber.

9

Heat Recovery Steam Generator (HRSG): Each HRSG that recovers the energy from the flue-gas is connected downstream of each high temperature oxidation chamber. The HRSG is a water-tube boiler with an economiser. The water tube boiler section consists of water tube bundles (evaporator and super-heater) that are easily removable for service and maintenance. The system is equipped with a feed-water tank, feed-water pumps, make-up water system, blow-down system and facilities for cleaning of the heat transfer surfaces (flue-gas side) during operation.

10-14

Flue-gas cleaning system: The facility is supplied with a dry flue-gas cleaning system located downstream of each HRSG. The flue-gas cleaning system consists of an adsorbent silo, a bag-house filter and a storage silo for filter dust. The cleaning of the flue gas is based on injection of adsorbent (lime and carbon) into the flue-gas for absorption of acid components, adsorption of heavy metals, mercury, organic carbon (TOC) and dioxins. Fly ash and adsorbents are separated from the flue-gas in a bag house filter.

Residue from the filter is collected at the bottom of the filter and pneumatically transported to the filter dust storage silo. The silo is emptied at regular intervals through a sealed system into designated trucks for transport and disposal in accordance with statutory regulations, or beneficial reuse where suitable opportunities are identified.

16

Steam turbine and air-cooled condenser: Steam from the two HRSG units is passed to a common condensing steam turbine for generation of electricity. Exhaust steam from the steam turbine is condensed by use of an air-cooled condenser and the condensate is passed back to the feed-water tank.

The gross power output is dependent on the load the facility is operated at, which is dependent on the net calorific value of the feedstock waste at maximum nominal fuel consumption.

14

Flue-gas fan and stack: The flue-gas fan is located downstream of each bag-house filter. The flue-gas fans maintain the required draft in the gasification and high temperature oxidation chambers and discharge the flue-gas to the atmosphere via a common flue-gas stack. A portion of the flue-gas is recycled to the high temperature oxidation chamber by use of a re-circulated flue-gas fan.

Not shown

Control and monitoring system: The plant is equipped with a control and monitoring system, which performs automatic control of the process. The plant operators interact with the control system via the human machine interface (HMI) in the control room. The HMI presents all important process data, including flue-gas emissions. An independent emergency shutdown system (ESD) takes control during emergency situations and secures the plant into a safe state to avoid damage to humans, environment and equipment. Emission monitoring of flue-gas components is performed according to IED 2010/75/EU.

The facility will also include a solar panel system and a roof rainwater collection system to further enhance environmental sustainability.

4.1.6 Reference Facilities

Figure 4-4 presents Energos facilities referenced in this application. Further detail regarding reference facilities is provided in in Section 5.2.4.


30



Figure 4-4 Energos plants – operational & under construction

FACILITY DETAIL

Forus Plant

Location: Norway

Commissioned: 2002

Fuel Capacity: 39,000 tonnes/year

Energy Production: CHP 105 GWh/year

The facility has one line, accepting 80% MSW and 20% C&I

Sarpsborg 1 (SAE 1) Plant

Location: Norway

Commissioned: 2002


Energy Production: 105 GWh/year

The facility has two lines, accepting residual municipal and industrial waste

Sarpsborg 2 (SAE 2/Hafslund)

Location: Norway

Commissioned: 2010


Energy Production: 256 GWh/year

The facility has two lines, accepting:

70% C&I and 30% MSW (2010 to 2013)

30% C&I and 70% MSW (2014 to current)

4.1.6.1 Sarpsborg 2 Reference Facility

The Sarpsborg 2 facility would be considered most comparable to the proposed facility, due to the type and volume of waste received. The Sarpsborg 2 Waste to Energy Facility (also known as Hafslund) is located in Sarpsborg, Norway. The facility was commissioned in 2010 and processes approximately 78,000 tonnes of residual MSW and C&I waste per year, with a thermal capacity of 32.4 MW. The facility supplies steam to Borregaard Industries biorefinery and is the second double line gasification plant to be constructed at the complex, following construction of the original plant (Sarpsborg 1 - commissioned 2002). The facility is owned and operated by Hafslund ASA, a Norwegian power company.

The Sarpsborg 2 plant includes the following features:


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• Two identical gasification lines each capable of processing 39,000 tonnes of waste per year • Two-stage thermal reactor consisting of a primary gasification zone and secondary thermal oxidation

(combustion) chamber) • Waste is delivered to the facility via road and tipped to the waste bunker • The pre-treatment system includes a shredder with belt conveyors and metal separation via a magnetic overbelt. • The shredder is fed via an automated overhead crane system, with metal extracted from the shredded waste and

transferred to containers. Shredded waste is unloaded into the fuel bunker • Fuel is transferred from the fuel bunker and unloaded into hoppers via the overhead crane, before entering the

feeding chamber of each gasification chamber • The primary gasification chamber incorporates a fixed horizontal oil-cooled grate. Thickness of fuel (waste) on

the bed is controlled (in part) by a water-cooled guillotine installed at the inlet to the gasification chamber. Waste is transported along the grate by the hydraulically operated and water cooled duplex

• Syngas is produced in the gasification chamber, which passes into the combustion chamber, where the heat is used to generate steam

• Air pollution controls include the gasification and oxidation stages to control combustion, adsorbent silo, baghouse filter and storage silo for filter dust. The cleaning of flue gas is based on injection of adsorbents (lime and carbon) into the flue gas for absorption of acid components, adsorption of heavy metals, mercury, TOC and dioxins

• Formation of NOx is minimised through controlled combustion in the thermal oxidation zone • Bottom ash is approximately 15 per cent of the input waste feed by weight, which is discharged from the

gasification chamber and transported to the outdoor bottom ash storage. APC residue is approximately 7 per cent of the input waste feed by weight

The Sarpsborg 2 facility operating Permit is presented in Appendix R, which includes technical operating requirements, and requirements for emissions to air; emissions to water; residual products; and noise. The Permit was translated by Melbourne Translation Services, a certified National Accreditation Authority for Translators and Interpreters (NAATI) company.

4.1.7 Key Inputs

The facility will receive approximately 100,000 tonnes of waste per year (+/- 10 per cent). In addition to the waste feedstock, the other key material inputs are summarised in Table 4-2. It is anticipated the split of waste will be approximately 80-85 per cent residual (source separated) municipal solid waste and 15-20 per cent non-prescribed commercial and industrial waste, noting that the waste stream will be subject to typical seasonal variation.

Table 4-2 Consumable Data

Total Power Consumption Approx. 1400 kW or approx. 12 GWh/yr

Water Approx. 5 ML/yr

Lime Max. 20 kg/tonne fuel* ^

Activated Carbon 0.8 kg/tonne fuel (4% of lime consumption)

Fuel oil/gas consumption for auxiliary burners Approx. 2.4 GWH/a

*Typical consumption for household waste: chlorine, sulphur and fluoride content of 0.7%, 0.3% and 0.01% respectively on dry weight basis

^ Consumption of lime is based on emission limit values given in Directive 2010/75/EU, normalized to 11% oxygen, dry flue-gas. The flue-gas concentrations at normal operation are oxygen O2 > 7% and moisture H2O > 15 %.

Refer to Section 4.2 for further discussion of waste feedstock.

4.1.8 Key Outputs

Key outputs from the process will be heat, electricity, filter dust, bottom ash and metallic waste recovered for recycling. Based on previous waste stream analysis, it is anticipated the electricity generation for a 100,000 tonne per


32



annum plant will be approximately 7.9 MW. It is noted that metal recovery quantities are dependent on the waste feedstock and will be confirmed through future waste audits.

By-products from the plant would be flue-gas (refer to Section 5.2 for modelled air emissions), waste heat, filter dust, bottom ash and fly ash. The expected quantities for these outputs are summarised in Table 4-3.

Table 4-3 Key Outputs

OUTPUTS VALUE

Electricity Approximately 7.9 MW

(9.3 MW gross, less 1.4 MW parasitic load)

Fly Ash 4-6% per tonne fuel consumed

Bottom ash 15-20% per tonne fuel consumed

Metals for Recycling 1-3% of fuel

Heat 35.8 MW

The plant is designed to prevent any emissions of waste water to environment / surroundings. The requirement for connection to sewer and disposal via a Trade Waste Agreement will be further assessed during the detailed design phase. Alternatively, disposal via tankers to waste water treatment facilities may be considered as an alternative.

It is noted that the potential for beneficial reuse of bottom and fly ash (i.e. concrete, road base etc) is currently being investigated by the proponent for commercial viability. All solid wastes not beneficially reused will be disposed of in a municipal landfill in accordance with statutory requirements.

4.1.9 Materials Mass Balance

Mass balance is the accepted approach to outline the pathway of how materials come and go during any given process. It is applied to most applications where inputs change state to provide a more beneficial or required output. A mass balance typically provides a number of snapshots along the process journey, which enables an understanding of how a process will perform and what the likely products will be and at what concentration, be it heat, power etc.

In a WtE plant understanding the mass balance is critical in determining the plant performance from a process, output/input and environmental performance perspective and further validates the feedstock and emissions baseline data and overall plant performance. In calculating the mass balance for the facility the key inputs as outlined in Section 4.1.7 and the feedstock characteristics in Section 4.2 provide a number of inputs which are considered variable, from which a true actual static value must be determined/assumed and justified. The mass balance process allows for the variability through referencing other plant performance in both feedstock and emissions profile and assuming a realistic value for calculation purposes.

The mass balance assumes a steady fuel delivery rate of 6.4 tonnes/hour per line of processed and homogenised fuel (mixed for consistency of CV) at an average CV of 12 MJ/kg, with a potential energy of 21.33 MW. Through the gasification and oxidation process a residual energy potential of 21.11 MW remains. The net loss at this stage is via thermal radiation through the furnace infrastructure and heat loss out via ash discharge.

The process of heat recovery and conversion to superheated steam sees further net loss through thermal radiation to emissions, blow down and boiler loss. At this stage a combined (both lines) energy potential of 41.44 MW remains.

Superheated steam from both lines is combined to feed the turbines where energy conversion of 9.35 MW occurs along with further energy potential loss through condensation, thermal radiation, conversion to low pressure steam, which are returned to the feeder tank, retaining some energy through residual heat. In the process of power production, without the ability to capture heat or steam the residual energy of 24.37 MW is lost through thermal radiation. The process flow is presented below.

NOTES:

GSWT Dandenong Plant - Sankey DiagramCombustion air: 0.00 MW Combustion air, 0.000 MW 1. Reference states:

T (air, flue gas, ash) 25 °CT (water) 0 °CP 1 atm

Ingress air: Ingress air0.00 MW 0.000 MW

Bottom ash (6): 0.05 MW Bottom ash (6): 0.05 MW

Furnace loss & cooling (A): 1.20 MW Furnace loss & cooling (A): 1.20 MW

Feedwater (12): 2.88 MW Feedwater (12): 2.88 MW

Saturated steam (13): 0.00 MW

Blowdown (16): 0.07 MW Blowdown (16): 0.07 MW

Boiler loss (B): 0.49 MWBoiler loss (B): 0.49 MW

Recirc FG (5): 1.02 MW Recirc FG(5): 1.02 MW

Sat. steam (13): 0.00 MW

Stack (4): 1.72 MW Water supply (11): 0.01 MW Stack (4): 1.72 MW

Loss & cooling: 0.541 MW

Bleed (14): 5.05 MW Condensate (15): 3.27 MW

Heat recoveryfrom Furnace cooling (C):1.13 MW = 2 x 0.565 MW

Gross electricity (D): 9.35 MW0 26/08/2019 Issued for information OyG

Rev Date Description Made by Checked Approved

Condensate (10): 2.14 MW PROJECT TITLE

DRAWING TITLE

CONTRACT No. REV.

—CLIENT DRG. No. REV.

—ENERGOS DRG. No. SHEET REV.

1/1 0

ANY AND ALL INTELLECTUAL PROPERTY RIGHTS IN OR ARISING OUT OF THIS DOCUMENT ARE THE SOLE, EXCLUSIVE AND ABSOLUTE PROPERTY OF ENERGOS AS. THIS DOCUMENT IS ISSUED FOR USE BY THE RECIPIENT ONLY AND MAY NOT BE DISCLOSED TO OTHERS, MODIFIED, EXPLOITED OR REPRODUCED WITHOUT THE WRITTEN CONSENT OF ENERGOS AS. THIS DOCUMENT MAY ONLY BE USED STRICTLY FOR THE PURPOSE FOR WHICH IS WAS ISSUED.

78765 GSWT Dandenong Plant

SANKEY DIAGRAM

78765-PP-PA-0002 R0

—

—

Fuel flow, 6.4t/h @ 12 MJ/kg (1):21.33 MW

Furnace (Gasification unit)

Furnace (High temperature oxidation unit)

Hot Flue Gas (2):21.11 MW

Heat Recovery Steam Generator

Superheated Steam (9):20.72 MW

Feed water tank

Low pressure steam (F):26.51 MW

Air Cooled Condenser

Turbine

Cooling to ambient (G):24.37 MW

Fuel flow, 6.4t/h @ 12 MJ/kg (1):21.33 MW

Furnace (Gasification unit)

Furnace (High temperature oxidation unit)

Hot Flue Gas (2):21.11 MW

Heat Recovery Steam Generator

Superheated Steam (9):20.72 MW

40-HP-001


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4.1.10 Key Process Controls

Waste Feedstock Quality Control

Waste feedstocks processed at the facility will have undergone source separation by residents and commercial operators through utilisation of multiple bin systems, which promote separation of waste into recyclables, organic/green waste and general waste. Only residual MSW and non-prescribed C&I waste will be accepted at the facility.

Process and quality controls for the acceptance of incoming waste streams include a contractual agreement with all waste suppliers prior to acceptance of waste at the facility. Supply contracts will require representative samples of waste with independent inspection and analysis to prove materials are within specification. Penalties will occur if waste criteria is not satisfied. A routine audit process will be implemented by GSWT during operation of the facility to allow for inspection and analysis of waste feedstocks to monitor suitability of the material and compliance with the fuel specification.

Fuel samples will be sent to a certified laboratory for further processing and analysis in accordance with a statistically representative methodology.

In addition, visual inspection of the waste will be conducted by the waste bunker crane operator when loading material from the waste bunker to the shredder. Undesirable materials, such as large metal bodies, concrete blocks, plasterboard etc. will then be removed using a separate picker crane. Refer to Section 5.7.4.2 for further detail regarding rejected waste.

Thermal Conversion

The plant is equipped with a control and monitoring system, which automatically controls the thermal conversion process as the return data from the monitoring data feed loop is produced. The feed loop is a system that captures a range of real time data inputs, which drive process adjustments as required. The plant operators interact with the control system via the human machine interface (HMI) in the control room. The HMI presents all important process data, including flue-gas emissions, temperatures, and oxygen concentrations in the primary chamber (gasifier) and secondary chamber (oxidiser). During upset conditions or emergency shutdown events an independent emergency shutdown system (ESD) takes control and secures the plant into a safe state to avoid inconsistent performance impacts to the receiving environment, personnel, adjoining properties, plant and equipment. Emission monitoring of flue-gas components (NOx, sulfur dioxide (SO2), hydrogen chloride (HCl), carbon monoxide (CO), particulates and total organic carbon (TOC) is performed to maintain emissions below IED 2010/75/EU limits. The online continuous emissions monitoring system (CEMS) measurements of the flue-gas control the adjustment of lime (control HCl and SO2) and Powdered Activated Carbon (PAC) (control impurities; dioxins and heavy metals)-dosing supplied to the dry cleaning / filter based flue gas abatement system. The injection of lime and activated carbon occurs in the dry flue-gas cleaning system located downstream of each HRSG and serves the purpose of both locking up and absorbing target compounds and emissions. The flue-gas cleaning system consists of an adsorbent silo, a bag-house filter and a storage silo for filter dust. The cleaning of the flue-gas targets the neutralisation of acidic gases within the flue gas, and adsorption of heavy metals, mercury, organic carbon and dioxins. Fly-ash and adsorbents are separated from the flue-gas in a bag house filter.

Residue from the filter is collected at the bottom of the filter and pneumatically transported to the filter dust storage silo. The silo is emptied at regular intervals through a sealed system into designated trucks for transport to disposal for reuse or in accordance with statutory regulations.

During planned plant shutdowns, fuel supply to the fuel hopper will be stopped and the fuel chute closed (such that no more fuel can be added to the hopper). There will be fuel remaining in the fuel bunker that is not gasified which will be processed at start up, alternatively in multi-line Dandenong South facility, the fuel will be transferred to the other operational process line if still in operation.

During restart or shut down of one line in multi-line plants the complete conversion of the remaining fuel on the grate takes place by continued operation of the duplex (that moves the fuel across the grate) until all fuel is processed (gasified) and ash delivered to the ash system (emptied into the wet ash conveyor). The fuel grate is cleaned, and the ash system operated until the ash is delivered to the ash bunker.

In an immediate shut down situation, such as during an emergency shut down controlled by the ESD system, the plant/furnace is brought to a safe state by stopping the duplex and induced draft fans, and closing the feed opening and fuel chute to prevent feeding of fuel both into the hopper and onto the grate. During an ESD, flue gas emission


35



control is still in operation. Following satisfactory resolution of the ESD cause, the operator resets the ESD system and continues plant operation by starting up the fuel feeding system (hydraulics) and the combustion air/recirculated flue gas fans.

Water from the process (boiler system; blowdown water) is recovered during operation of the steam production process. The water and any make-up water is managed by the water treatment plant which is a closed system allowing for a consistent quality and control of water quality for steam production. There are no emissions to the environment of steam production water.

Flue Gas Cleaning

Combustion air is required in both the gasifier and oxidizer to control the rate of process. Air is supplied via the use of forced draft fans which provide air for direct injection into both chambers. The volume of combustion air supplied is adjusted by the furnace control system which utilises the data feed loop to increase/decrease airflow to maintain a consistent operation/process.

The gasifier and oxidation chamber both require independent inputs to regulate airflow. The volume of combustion air required in the gasifier is determined by the stoichiometric air/fuel ratio which is continually monitored in situ and provides input back into the data feed loop.

The volume of combustion air required in the oxidizer is determined by the oxygen levels in the gas detected at the point of exit of the oxidizer chamber. The air flow control system is independent to the emission control.

The emission control injection blower system is used to inject lime and PAC into the bulk flue gas prior to the filter. The amount of lime and PAC is automatically adjusted based on the concentrations of SO2 and HCl (mg/Nm3) in the flue gas after filtration.

The concentration values of SO2 and HCl (mg/Nm3), which dictate the injection rate of PAC and lime, are selected to be less than the IED 2010/75/EU 24-hour limit concentrations to ensure that the 24-hour average concentrations will be less than the emission limit values. The system is designed so that the dynamic response of the control system is in accordance with expected dynamic response characteristics of an instantaneous supply and demand system based on data loop feedback.

The system requires the ability to manage variable concentration values of SO2 and HCl (mg/Nm3) as these fluctuate due to the following changes in fuel characteristics:

• Increase in certain chlorine containing plastics which increase the concentration of HCl in the flue gas; and • Increase in plaster / gypsum containing materials in the fuel (may be a part of C&I waste; however - such

materials should be sorted out from the fuel) which will increase the concentration of SO2 in the flue gas. The variability of SO2 and HCL is managed through the feedstock specification which provides the basis for the dosing range which the flue-gas detection system operates.

Emergency Shut Down (ESD)

The facility features an Emergency Shut Down (ESD) system. The ESD function is powered by an Uninterruptible Power Supply (UPS) and when triggered, overrides the Process Control System (PCS).

External conditions and internal operational scenarios which may trigger the ESD include, but are not limited to:

• Power failure • Internal plant and equipment failure • Pressure and temperature levels exceeding safe operating limits in the furnace, boiler and cooling medium • The operator activating the ESD button, located in plant room. Environmental impacts which may result from activating the ESD system are as follows: • Blow-out of flue gas • High steam pressure leading to steam release.

Mitigation measures in the process design to address these environmental impacts are presented in the risk assessment ( Appendix N

Upset conditions may also result in a requirement for management measures to be implemented. Upset conditions may result when irregularities in the operation of the facility are detected through the monitoring system. Upset conditions may include:


36



• Leakage from piping • Refractory requiring replacement • Duplex malfunction.

The upset condition pathway triggers an identical response to the ESD management approach.

A summary of air emissions key process controls is presented in Table 4-4.

Table 4-4: Key Process Controls

COMPONENT EU LIMIT 24 HOUR AVERAGE (MG/Nm3, DIOXINS ng/Nm3)

FURNACE (GASIFIER AND THERMAL OXIDISER)

BOILER (HEAT RECOVERY AND STEAM GENERATOR)

FILTER (FLUE GAS TREATMENT)

CO 50 1st stage: Gasification with limited injection of primary air (5 zones through the grate) to enable partial combustion to occur. The amount of air is sufficient to burn out the fixed carbon and the heat from this partial combustion is used to chemically convert the remaining hydrogen and carbon into a syngas.

2nd stage: Controlled oxidation of the syngas with injection of secondary air (2 zones) and injection of recirculated flue gas (2 zones)

An advanced process control system

- -

TOC 10

NOx 200

NH3 10

No injection of ammonia required due to low excess air and low temperature in the process

-

No Selective Non-Catalytic Reduction/Selective Catalytic Reduction required

Dioxins 0.1 -

Rapid cooling of flue gases to minimise dioxin reformation (400⁰C - 250⁰C)

Injection of activated carbon

Dust 10

- -

Bag filter to capture particles. Lime (for HCl, HF and SO2 capture) and activated carbon (for Hg and Dioxins capture) are injected upstream of the filter. Lime and activated carbon can be injected separately or as a premix with approximately 4% of lime consumption as activated carbon. Pressure drop measuring activates air injection inside filer bags for cleaning.

Hg 0.03

Cd+Ti 0.05

Metals 0.5

HF 1.0

HCl 10

SO2 50


37



COMPONENT EU LIMIT 24 HOUR AVERAGE (MG/Nm3, DIOXINS ng/Nm3)

FURNACE (GASIFIER AND THERMAL OXIDISER)

BOILER (HEAT RECOVERY AND STEAM GENERATOR)

FILTER (FLUE GAS TREATMENT)

Separated dust falls to bottom of filter and is discharged to fly ash silo

4.1.10.1 Resource Efficiency Diagram

Figure 4-5 below shows a Resource Efficiency Diagram outlining key processes, inputs, outputs and controls. It is noted that the potential for beneficial reuse of bottom and fly ash (i.e. concrete, road base etc) is currently being investigated by the proponent for technical and environmental viability.

Figure 4-5 Resource Efficiency Diagram

Waste Feedstock (Fuel) The WtE feedstock would comprise residual MSW (approximately 80-85 per cent by weight) and non-prescribed C&I (approximately 15-20 per cent by weight) which represents a relatively predictable baseload feedstock having relatively consistent compositions.

C&I waste supply contracts will be selected with consideration to the industry and type of waste, noting that certain industries may generate waste types not desirable for the facility. GSWT will consider industry type when sourcing waste to be utilised as fuel for the plant.

The following waste types will not be accepted as feedstock at the facility:

• Asbestos • Radioactive waste • Construction and demolition waste (e.g. construction debris, soil, concrete, plasterboard) • Electrical waste (in large quantities) • Smouldering waste • Poisonous substances • Liquid and volatile waste (e.g. grease trap waste, oil, solvent, paint, cleaning fluid) • Chemical waste • Medical/biohazard waste • Explosive and highly flammable substances • Animal waste (e.g. animal carcasses) • Residential ‘hard waste’ (e.g. mattresses, white goods, bicycles, tyre rims)


38



• Pharmaceutical waste • Motor vehicle parts or components • Insulation material • Polyvinyl chloride (PVC) waste, such as PVC pipes, film and upholstery • Fire retardants • Acids, caustics and corrosive substances • Polychlorinated compounds PCBs (e.g. those used in transformers and capacitors) • Prescribed industrial waste.

4.2.1 Proposed Feedstock

4.2.1.1 Municipal Solid Waste

The primary inputs to the facility would likely be local council residual MSW waste collections, however waste may also be sourced from the broader Melbourne Metropolitan region. It is proposed that appropriate waste streams be sourced from local councils within the Melbourne Metropolitan area. Currently, council-managed MSW entering landfill includes:

• weekly household collections • regular public place litter bin collections • street sweeper waste • council community drop-off wastes to transfer stations • annual or bi-annual nature strip collections (hard waste).

It is proposed that the facility would initially accept only weekly household waste (residual municipal solid waste). GSWT will also consider acceptance of public place litter collections, following proposed characterisation of this waste stream to ensure it remains within operating parameters of the facility and will not result in any additional unacceptable air emissions.

The council-managed waste streams noted above (public place collections, street sweeper waste, community drop offs to transfer stations and hard waste) are not excluded from diversion to the facility, however would be subject to waste characterisation and assessment for suitability and inclusion as feedstock to the facility and approval by EPA. GSWT does not intend to secure these waste types initially.

Characterisation of MSW was conducted as part of the MWRRG Alternative Waste and Resource Recovery Technologies: Metropolitan Regional Business Case and Procurement Strategy (September 2018). MWRRG commissioned a review of 67 waste composition audits conducted by metropolitan councils in recent years. The review found that the information obtained from the review was not sufficiently robust to inform a procurement process for residual waste treatment options (such as WtE), however provides indicative residual MSW composition for the metropolitan region.

In addition to the large percentage (approximately 50 per cent by weight) of high moisture content food scraps and non-recyclable packaging placed in the household kitchen tidy bins, the other objects of a much lower percentage by weight ending up in the residual MSW bin, include but are not limited to:

• Paper/cardboard • Plastic beverage containers • Aluminium cans • Steel cans • Liquid paperboard packaging • Small electrical whitegoods • Car parts • Garden clippings and wood • Rubble and concrete objects • Children’s toys • Used clothing and old textiles/rags • Small non-rechargeable batteries


39



• Lead based car batteries • Partly-filled paint tins • Old engine oil containers • Used garden pesticide containers • Old fluoro tubes • Out of date medicines.

The above list is generally consistent with the findings of the MWRRG Regional Business Case and Procurement Strategy (MWRRG, 2018), as presented in Figure 4-6.

Figure 4-6 MSW Composition (MWRRG, 2018)

Collection of residual MSW occurs through 80L, 120L and 240L wheelie bins, with contents placed in the bin by hand by the individual householder. Bins are collected from individual properties using side-lift trucks.

Based on the data sourced from MWRRG (2018), the average weight of MSW from each residential house in the Melbourne metropolitan area is approximately 600 kg/annum, where FOGO systems have not been implemented. As at November 2018, 19 Victorian councils were operating a FOGO service, with five others undergoing trials, allowing food and garden organics to be diverted to the organic collections bin.

As MSW waste composition data is somewhat limited, MWRRG intends to conduct local government waste composition audits to improve the quality of waste data to support informed procurement for alternative waste technologies. Funding has been secured to support the audit for metropolitan councils, which will aim to better understand spatial and seasonable variability in the composition of residual MSW.

GSWT is aware MWRRG is in the process of engaging and implementing the 12-month audit of residual MSW of all 15 local Councils in the south east metropolitan region. The specification for that audit is detailed in the July 2019 MWRRG Tender for waste auditing services ‘Appointment of Waste Composition Auditors to an Audit Panel’.

GSWT understand the MWRRG sponsored audit process will provide a comprehensive classification of residual household MSW, utilising published Sustainability Victoria waste characterisation methodologies and sampling procedures, consistent with the methodology utilised by HRL in the June 2018 audit (HRL, 2018 – refer to Section 4.2.2). The MWRRG-sponsored audit will focus on waste composition and will not include assessment of moisture content, calorific value, or elemental analysis of the audited MSW, however these parameters may be included in later audits.


40



It is understood the reports from this MWRRG audit process will be made available to respondents to the upcoming MWRRG Expression of Interest and tender process seeking alternative to landfill waste management solutions. These audit reports are expected to be provided to respondents progressively on a season-by-season basis as they are completed.

GSWT intends to rely upon the MWRRG MSW audit data, combined with the HRL laboratory analysis (refer to Section 4.2.2), to inform anticipated waste compositions.

A desktop review of available municipal bin audit data from local government areas located in metropolitan regions of Victoria was undertaken to provide an understanding of the composition of waste found within household general waste (garbage) bins. A summary of the available data is provided in Table 4-5.

The specifics of waste audit data streams altered between councils. A high-level summary of the waste data is provided below:

• Food and garden waste generally made up the largest portion of waste material within the general waste stream • Following organic waste, typically the second largest waste stream was residual / other waste.


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Table 4-5 Publicly Available Council General Waste Bin Audit Data

LOCAL GOVERNMENT AREA MELBOURNE GREATER

DANDENONG CARDINIA FRANKSTON KNOX MANNINGHAM WHITEHORSE LA TROBE

MORNINGTON PENINSULAR BANYULE HUME

Audit Year N.d. 2013 2015 2013 2012 2011 2015 2009 2008 2015 N.d.

Hous

ehol

d G

ener

al w

aste

bin

com

posit

ion

% (b

y w

eigh

t) O

rgan

ics

Food 50 46 32 - 46.1 - 44 35.7 24 40 41.3

Garden 10 5 2 - 1.7 - 6 3.8 6 6 18.6

Not defined - - - 33.9 - 62.37 10 - - - -

Recyclables (not defined or other)

- - - - - - - - 19.4 - 3

Paper/cardboard 15 6.3 14 7.7 2.8 17.27 8 - 23 5 6.4

Glass 4 2 1 2.9 - 2.11 2 - - 2 -

Plastic 13 2.19 16 4.5 5.8 9.3 12 - 28 3 1.8

Metal - 1 4 2.7 0.2 2.65 3 - - 2 -

E-waste - - - 0.2 - - - - - 1.2 -

Polystyrene - - - - 1 - - - - - -

Nappies - - - 5.1 - - - - - 10 6.6

Textiles - - - - - - - - - 3 -

Hazardous - - - - - - - - - - 0.1

Residual Waste / other 8 37.5 31 43 43.3 6.3 14 41.1 19 28.8 22.2

Sources:

Melbourne City Council (2019)

City of Greater Dandenong (n.d.)

Cardinia Shire Council (2017)

Frankston City Council (n.d.)

Knox City Council (2013)

Manningham City Council (2012)

Whitehorse City Council (n.d.)

La Trobe City Council (2010)

Mornington City Council (2009)

Banyule City Council (n.d.)

Hume City Council (n.d.)


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4.2.1.2 Commercial and Industrial Waste

The Alternative Waste and Resource Recovery Technologies: Metropolitan Regional Business Case and Procurement Strategy (MWWRG, 2018) recognises that C&I waste is highly variable and there is limited reliable information on its composition. To help address this situation, Sustainability Victoria is undertaking further work to investigate the generation and composition of C&I waste (MWRRG, 2018).

The C&I waste collections intended to be diverted to the facility are expected to be primarily sourced from C&I collections in the south eastern suburbs of Melbourne. C&I waste streams are collected by private waste companies, and are not linked to waste streams controlled by local councils.

C&I waste will likely be predominately sourced from small to medium enterprises (SME’s), including but not limited to the following industry sectors:

• Food and beverage industries • Timber and joinery Industries • Office blocks including government • Large Shopping Centres • Domestic building sites • Panel beaters • Strip shop outlets • Schools and other education • Cafés and restaurants • Printers • Importers • Various manufacturing industries.

The dominant C&I solid waste collections include those collected by the following systems:

3m3 front-lift bin collections from a broad range of commercial and industrial facilities, mostly SMEs, and to a lesser degree large-scale factories. Front lift waste materials are generally placed in the front lift bins by hand. Front-lift bins are required to have closable plastic lids for litter prevention, so it is rare that the lids are fully opened to allow a forklift to tip materials in to this type of bin • Rear lift loaded 120L and 240L wheelie bin collections, are primarily collected from SME’s and are all manually

loaded in to the back of rear lift compaction trucks by the collection truck crew • Hook-lift bulk bins, normally ranging between 20 to 30m3 in volume, either top loaded at industrial/commercial

facilities, potentially by forklifts or front-end loaders, or via a compaction system in to a fully enclosed compactor bin

• C&I collections may include Mechanised Street sweepings from freeways and major roads.

GSWT intends to initially focus on and characterise front-lift and rear-lift bins and collections systems.

Other C&I waste collections, such as hook lift bulk bins, that are collected from individual C&I facilities such as large industrial processes or shopping centres, will likely contain waste mixes that are suitable for the proposed facility. As such, these waste streams are not excluded from disposal to the facility, however will not form initial C&I waste feedstock streams. Suitability of these feedstocks will be assessed at a later date, if likely to be received at the facility.

There are over 16,000 business establishments in the City of Melbourne local government area, producing approximately 57 per cent of the waste generated in the municipality (City of Melbourne, 2019). The composition of C&I waste produced in the City of Melbourne is provided in Figure 4-7.

Whitehorse City Council published waste audit data relative to five specific C&I industries; retail, health services, hospitality, small manufacturing and professional services. The findings of the industry specific waste audit results are provided in Figure 4-8.

The waste composition information in Figure 4-7 and Figure 4-8 indicates the prominent waste streams in C&I waste are organic waste and other waste (residual). This is similar to the stream observations made for MSW.


43



Figure 4-7 City of Melbourne Commercial and Industrial General Waste Bin Audit Data (Source: Melbourne City Council, 2019)

Figure 4-8 Whitehorse City Council General Waste Bin Audit Data (Source: Whitehorse City Council, n.d.)

4.2.1.3 MSW Chemical Composition

Research has been conducted by the Commonwealth Scientific and Industrial Research Organisation (CSIRO) to characterise the thermochemical properties and chemical composition of municipal solid waste and green waste in Brisbane, Australia (Hla and Roberts, 2015). The Hla and Roberts (2015) study found the following:

• Aside from moisture and ash content, chemical properties of green waste samples reported similar values, despite being collected from three different transfer stations

• The observed energy content (Lower Heating Value wet basis [LHVwb]) of the green waste samples ranged from 7.8 to 10.7 MJ/kg


44



• The heating values of the green waste samples saw greater impacts from the variation in moisture and soil content, rather than chemical composition. Moisture content in green waste samples is impacted by the local weather conditions and soil content is impacted by the handling and sorting processes

• MSW was categorised in ten categories, of which nine categories (food waste, garden waste, printing paper, packaging paper, packaging plastic, other plastic, textiles, wood waste, other combustibles) were combustible and the tenth category was non-combustible. The MSW samples were collected as individual components at volumes representative of typical MSW compositions. Non-combustible material samples were not collected, but weights were recorder to be included in the chemical characterisation of the MSW stream

• The energy content (lower heating value, wet basis - LHVwb) of the MSW sample (inclusive of combustible and non-combustible components) was 7.9 MJ/kg

• The energy content of MSW was impacted by moisture content, weight percentage of high-energy components (plastics) and weight percentage of non-combustibles

• The energy content of the MSW was relatively high and was reported above the World Bank-recommended energy minimum for waste-to-energy applications

• The study was undertaken in February, Brisbane’s wettest months. Waste composition data is impacted by seasonal changes and as such further testing should be conducted to confirm the above findings.

4.2.2 Waste Audit

A waste audit of MSW has been undertaken by HRL. An audit was conducted on each day of the week, totalling six audits across the City of Greater Dandenong region. The audit comprised 501 bins, reaching a total mass of 5760.1 kg of MSW audited. The audit was conducted during the winter period, with additional audits of municipal waste to be undertaken, to capture waste seasonality (as discussed in 4.2.6). At the time of the audit, Greater Dandenong City Council was not operating a separate FOGO collection service.

The waste audit was established with reference to the guidance provided by the Sustainability Victoria (SV) document ‘Guidelines for the auditing of Kerbside Waste in Victoria’, as well as method statements supplied by GSWT. The standard methods for subsampling, storage and transportation that HRL complied with include:

• I.S. EN14899: ‘Characterisation of Waste – Sampling of Waste Materials – Framework for the Preparation and Application of a Sampling Plan’ and,

• I.S. EN15443: ‘Solid Recovered Fuels – Methods for Preparation of the Laboratory Sample’.

The key steps from the guide regarding ‘determination of a sampling and audit plan’ were followed by HRL Technology to develop the method for waste collection and auditing:

i. Purpose of Audit ii. Classification of component types

iii. Audit sample size iv. Area selection and the type of audit v. Seasonal variability

vi. Bin collection methods vii. OHSE requirements for audit activities

viii. Physical auditing of collected waste materials ix. Drawing analysis subsamples x. Additional information and/or guidance

These points are discussed in depth in the HRL Technology audit report (refer to Appendix P).

HRL Technology follows internationally recognised sampling and analysis methodologies (EN methods) when sampling and analysing the waste materials. The standard methods are listed in Table 4-6 with their corresponding method numbers.

Table 4-6 Standardised sampling and analysis methodologies applied by HRL Technology for MSW analysis.

TEST / TASK STANDARD METHOD REFERENCE NUMBER

Subsampling for analysis I.S. EN 15413:2011 &

I.S. EN 15443:2011

Ash Yield I.S. EN 15403:2011


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TEST / TASK STANDARD METHOD REFERENCE NUMBER

Biomass Content I.S. EN 15440:2011

Calorific Value I.S. EN 15400:2011

Carbon, Hydrogen, Nitrogen I.S. EN 15407:2011

Halides (Total Sulphur and Chlorine) I.S. EN 15408:2011

Major Elemental Analysis I.S. EN 15410:2011

Moisture Content I.S. EN 15414:2010

Trace Elemental Analysis I.S. EN 15411:2011

Volatile Matter & Fixed Carbon I.S. EN 15402:2011

The waste audit provides analytical data of the combustion parameters of the waste material including: moisture content, ash content, calorific value (CV), chlorine and sulphur for waste during the winter season. The audit also provides laboratory analysis data of the major and trace elements in the waste materials categorised during the audit.

The sampling guidelines recommend that a sample size of 250 properties (or bins) should be collected for Multi-Unit Developments (MUDs) and another 250 for Single Unit Developments (SUDs) for each survey, or, in this case, designated council area. The guidelines also recommend that samples should be collected at least twice a year to account for seasonal variability.

The audit assessed kerbside waste, excluding recycling and green waste / organic waste bins, as this residual MSW is the proposed source material for the facility.

The audit process commenced with a review of key demographic information of suburbs within each council region to assess information such as: population, gross income, housing structure (MUD or SUD), and people per dwelling. The review data was then collated and analysed, with reference to the following Australian and International standards to determine which areas will be part of the sample region:

• Sustainability Victoria (2009) Guidelines for Auditing Kerbside Waste in Victoria: Leading practice for measuring kerbside waste, recycling and green organics.

• European Commission (2004) Methodology for the Analysis of Solid Waste (SWA-Tool).

Audits were undertaken in the City of Greater Dandenong from suburbs; Dandenong, Dandenong North, Noble Park, Springvale and Keysborough. The waste audit collected bins from single unit developments and multi-unit developments. Each audit run targeted a development type (SUD vs MUD) and the waste from targeted households was separated from the general waste run and aggregated into a truck by HRL, to protect the privacy of individual households.

The waste was then sorted by hand and categorised into the following categories: paper, dense plastic, flexible plastic, textiles, glass, non-ferrous metals, ferrous metals, food, nappies, wood, mix, non-combustibles, hazardous, fines and PVC. The audit waste composition results are summarised in Table 4-7.

Table 4-7 Winter Waste Audit Composition Summary (source: HRL, 2018)

CATEGORY MUD AUDIT 1 (%)

SUD AUDIT 2 (%)

MUD AUDIT 3 (%)

SUD AUDIT 4 (%)

SUD AUDIT 5 (%)

MUD AUDIT 6 (%)

TOTAL SUDS (%)

TOTAL MUDS (%)

TOTAL SUDS AND MUDS (%)

Paper 10.5 13.2 14.2 10.2 12.9 13.3 6.0 6.3 12.3

Dense Plastic 2.9 3.5 4.2 3.3 4.3 4.0 1.9 1.9 3.7

Flexible Plastic 7.9 8.7 8.4 10.4 8.6 8.3 4.7 4.1 8.8


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CATEGORY MUD AUDIT 1 (%)

SUD AUDIT 2 (%)

MUD AUDIT 3 (%)

SUD AUDIT 4 (%)

SUD AUDIT 5 (%)

MUD AUDIT 6 (%)

TOTAL SUDS (%)

TOTAL MUDS (%)

TOTAL SUDS AND MUDS (%)

Textiles 6.8 3.9 2.4 2.4 2.1 3.1 1.4 1.9 3.3

Glass 1.0 0.8 1.4 0.8 1.2 1.3 0.5 0.6 1.1

Non-Ferrous Metals 0.5 0.6 0.8 0.5 0.5 0.6 0.3 0.3 0.6

Ferrous Metals 1.1 1.0 1.3 0.7 1.3 1.3 0.5 0.6 1.1

Food 36.0 47.7 43.0 49.7 49.9 45.0 24.9 20.6 45.5

Nappies 12.8 7.4 13.9 8.6 5.2 7.5 3.6 5.5 9.2

Wood 0.4 0.1 0.2 0.4 0.3 0.3 0.1 0.1 0.3

Miscellaneous Non-Combustibles

3.4 0.9 0.8 1.6 1.6 5.5 0.7 1.6 2.4

Hazardous 1.2 0.9 1.4 1.0 1.6 1.3 0.6 0.7 1.2

Fines <20mm 14.8 10.7 7.5 10.1 9.5 8.2 5.1 4.9 10.0

PVC 0.6 0.4 0.7 0.3 0.9 0.4 0.3 0.3 0.6

An analytical chemical composition was undertaken (e.g. silicon, aluminium, iron etc) and chemical analysis of ash following combustion of samples (ash yield, chemical composition of ash). The chemical composition results are summarised in Table 4-8.


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Table 4-8 Winter Waste Audit Composition Summary – Weighted Average Results (source: HRL, 2018)

CATEGORY GREATER DANDENONG AVERAGE

Ash Yield

Ash Yield, % (db) 30.2

Total Moisture

Moisture, % (ar) 52.9

CHN (Ultimate analysis)

Carbon, % (db) 40.6

Hydrogen, % (db) 6.0

Nitrogen, % (db) 1.17

Volatile Matter

Volatile Matter, % (db) 65.5

Fixed Carbon, % (db) 3.8

Halides

Sulphur, % (db) 0.19

Chlorine, % (db) 0.73

Biomass Content

Biomass Content, % 59.6

Calorific Value (at constant volume)

Gross Dry CV, MJ/kg (db) 19.1

Gross Wet CV, MJ/kg (ar) 9.0

Net Wet CV, MJ/kg (ar) 7.2

Further waste characterisation activities planned by GSWT are discussed in Section 4.2.6.

4.2.3 Managing Waste Composition

Waste supply contracts for both MSW and C&I will require specific acceptance criteria (as per the agreed fuel specification – refer to Section 4.2.4) for waste accepted at the facility. Penalties will be included within any supply contract entered which will detail offset costings and other penalties to be incurred should the waste specification not meet required standards. Additionally, GSWT will regularly liaise with waste suppliers to provide feedback on composition of waste being received at the facility and opportunities to improve the quality of the waste stream.

The supply contracts between GSWT and the local councils are expected to be coordinated by the MWRRG, following a staged expression of interest and tender process that is expected to commence in the last quarter of 2019, with successful bidders for the councils waste supply to be nominated by mid-2021. The waste feedstock GSWT intends to secure for the proposed facility is likely to be predominantly sourced from the south eastern suburbs of the Melbourne metropolitan area. The formal supply contracts between GSWT and the local councils will contain detailed terms and conditions describing the responsibilities of each party, including defining the acceptable type and source of the waste, definitions of what are Accepts and what are Contaminants with agreed maximum percentages by weight, and


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definitions of what is a Prohibitive waste that is not permitted to be received by GSWT, e.g. Prescribed Industrial Waste and Liquid Wastes. Waste composition will also be managed through source separation of recyclable materials and hazardous waste by households and commercial operations, to separate these materials from the general waste stream being accepted by the facility.

Inspection and monitoring of incoming waste will occur as part of a routine audit process. Routine analysis of fuel will be undertaken through analysis of fuel samples from each fuel hopper, with regard to the parameters of the fuel specification. A waste audit bay within the purpose built building is also included as part of the waste receival area to allow for inspection of incoming waste. A routine audit process will be implemented by GSWT during operation of the facility to allow for inspection and analysis of waste feedstocks to monitor suitability of the material and compliance with the fuel specification.

Pre-treatment of the waste feedstock is critical to ensure optimum performance of the facility and includes the shredding of the waste and removal of ferrous metals (magnetic separation). Following shredding and removal of metal, the waste feedstock is mixed to ensure a homogenous fuel with respect to maintaining a consistent net calorific value and other properties such as moisture content. Shredding of waste and metal removal ensures a more a complete burn occurs and minimises the bottom ash generation volumes.

4.2.4 Fuel Specification

The objective of the fuel specification is to define the parameters that form the basis of design for the facility. The parameters for fuel characteristics and permissible elemental concentrations are still to be confirmed through the detailed design phase, however will be reflective of likely waste compositions (following further audits) and based on facilities operating in Europe. Typical criteria are presented in Table 4-9 and Table 4-10, noting that these are indicative only and will be refined during the detailed design phase of the project.

The fuel specification provided below is reflective of the Sarpsborg 2 and Forus facility fuel specifications.

The fuel specification is provided in Appendix Q.

Table 4-9: Fuel Characteristics (Energos, 2018c)

COMPONENT UNIT VALUE

Net calorific value MJ/kg 8-18

Moisture content weight % (wet) <60

Ash content weight % (dry) 6-32

Nitrogen content weight % (dry) <1.5

Sulphur content weight % (dry) <0.4

Chlorine content weight % (dry) <1.0

Fluorine content weight % (dry) <0.01

Table 4-10 Permissible Concentrations in Feedstock (Energos, 2019b)

COMPONENT UNIT INDICATIVE MAXIMUM VALUE

Cadmium [mg/kg (dry)] 25

Thallium [Tl] [mg/kg (dry)] 7

Mercury [Hg] [mg/kg (dry)] 2

Antimony [Sb] [mg/kg (dry)] 750

Arsenic [As] [mg/kg (dry)] 15


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COMPONENT UNIT INDICATIVE MAXIMUM VALUE

Lead [Pb] [mg/kg (dry)] 450

Chromium [Cr] [mg/kg (dry)] 500

Cobalt [Co] [mg/kg (dry)] 45

Copper [Cu] [mg/kg (dry)] 500

Manganese [Mn] [mg/kg (dry)] 300

Nickel [Ni] [mg/kg (dry)] 120

Vanadium [V] [mg/kg (dry)] 120

4.2.4.1 Comparison on Waste Audit Data to Fuel Specification

A comparison of chemical composition results from the initial waste audit (HRL, 2018 – refer to Section 4.2.2) to the fuel specification has been conducted. A summary of the comparison is presented below, however in general:

• Net calorific value (NCV) for the MSW is 7.2 MJ/kg; less than specification limit. However, NCV will be adjusted / increased by combining with C&I (Approximately 15-20 per cent) and would also increase through the implementation of FOGO separation

• Other requirements in the Energos fuel specification are fulfilled except: − Relatively high fraction of non-combustibles (glass, metals and other non-combustibles) at approximately

5.2 per cent (It is noted the Audit (HRL, 2018) did not consider removal of metals).

Fuel Characteristics/Composition

• Requirements for ash content, moisture content, nitrogen, sulfur and chlorine are fulfilled (note fluorine analysis not conducted)

• The average NCV is equal to 7.2 MJ/kg: − Fuel feedstock to the site is expected to be a mixture of MSW (80-85 per cent) and C&I (15-20 per cent) and

therefore the average NCV is likely to increase to the required level; i.e. between 8 and 18 MJ/kg − Implementation of FOGO would reduce organic waste content and increase calorific value of waste, as is

expected in the near future. Trace Element Concentrations (as per Table 4-10) • Audit 1: All trace elements concentrations were less than the maximum limit defined in the Energos fuel

specification • Audit 2: All trace elements concentrations were less than the maximum limit defined in the Energos fuel





specification.

Comparison of the waste audit chemical composition results to the fuel specification indicates trace elements are all below the maximum limit specified in the fuel specification.

A summary of the comparison of the fuel specification to the waste audit chemical composition data is presented in Appendix Q.


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4.2.4.2 Comparison of Reference Facility Waste Data to Fuel Specification

Waste composition and chemical composition data for the Sarpsborg 2 reference facility was provided by Energos (Energos, 2019a) from March 2011, June 2011 and December 2011, which included 25 sets of fuel analysis data. The chemical composition data were compared to the fuel specification to assess whether fuel from the reference facility, comprising 70 per cent C&I and 30 per cent MSW, was within the required limits.

The typical composition of the C&I waste accepted at the Sarpsborg 2 reference facility (measured as wet base), was as follows (Energos, 2019a):

• Moisture: 25.3% • Plastics: 16.5% • Metal: 2.8% • Plasterboard: 1.4% • Glass: 2.6% • Stone/Gravel: 4.4%.

Results of the comparison of chemical composition data to the fuel specification are presented in Table 4-11.

Table 4-11: Reference Facility Waste Combustion Results

ENERGOS SPECIFICATION REFERENCE

FUEL1 Parameter Value Unit

Fuel characteristics

NCV 8 to 18 MJ/kg 11.1

Moisture / H2O < 60 % (weight, wet) 31.7

Ash / A 6 to 32 % (weight, dry) 12

Nitrogen / N < 1.3 % (weight, dry) 0.8

Sulphur / S < 0.4 % (weight, dry) 0.34

Chlorine / Cl < 1.0 % (weight, dry) 0.33

Fluorine / F < 0.01 % (weight, dry) -

Contamination in fuel

Cadmium / Cd 25 mg/ kg (dry) 2.6

Thallium / Tl 7 mg/ kg (dry) -

Mercury / Hg 2 mg/ kg (dry) 0.1

Antimony / Sb 750 mg/ kg (dry) 4.8

Arsenic / As 15 mg/ kg (dry) 10.8

Lead / Pb 450 mg/ kg (dry) 258.5

Chromium / Cr 500 mg/ kg (dry) 58.5

Cobalt / Co 45 mg/ kg (dry) 3.2

Copper / Cu 500 mg/ kg (dry) 336.5

Manganese / Mn 300 mg/ kg (dry) 153.1

Nickel / Ni 120 mg/ kg (dry) 20.7

Vanadium / V 120 mg/ kg (dry) 12.3

Density Min 250 kg/m3 -

Max 350 kg/m3 -


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ENERGOS SPECIFICATION REFERENCE

FUEL1 Parameter Value Unit

Average - kg/m3 187

Particle size of fuel

Less than 150 mm 90 % (by weight) -

Less than 200 mm 97 % (by weight) -

Particle volume less than 300 cm3 -

Contents and size of non-combustibles and hard objects

Non-combustibles (metals, rock, concrete) < 0.5 % (by weight) 9.16

Maximum weight of non-combustible hard object with

length exceeding 40 mm < 350 g -

1 Hafslund Reference Facility Note: Heavy metals only available for six samples and no analysis for fluorine or thallium

Comparison of provided waste chemical composition data (Energos, 2019a) to the fuel specification indicates that the Sarpsborg 2 reference facility fuel is within the fuel specification limits.

4.2.5 Summary

A comparison of the waste audit chemical composition data (HRL, 2018) to the indicative fuel specification was conducted to assess whether the waste was likely to be a suitable feedstock for the proposed facility. Although net calorific value was outside the fuel specification range, addition of C&I will likely increase calorific value, as will implementation of FOGO source separation (through implementation of Council collections), by reducing organic matter. As such, it is anticipated that NCV of the waste feedstock is likely to be within the required range.

Non-combustibles from the waste audit were also outside the fuel specification limits, however non-combustibles do not impact on emissions from the facility, rather the mechanical operation of the plant.

All trace element concentrations from the waste audit were less than the maximum limit defined in the fuel specification.

A comparison of provided Sarpsborg 2 reference facility waste chemical composition data to the fuel specification was also conducted and indicated that provided waste composition data were within the fuel specification limits.

Air emissions data (refer to Section 5.2) for the Sarpsborg 2 reference facility indicate that emissions were below the Industrial Emissions Directive limits. As the Sarpsborg 2 waste chemical composition results indicate the feedstock was within the fuel specification limits, it is likely the emissions from the facility will also be below the IED limits, as waste feedstock (as per the waste audit) was also within the fuel specification limits.

Outcome

In summary, based on data provided and assessed, proposed waste feedstocks are likely to be within the fuel specification range and emissions to air from the proposed facility are unlikely to exceed the IED emissions limits.

4.2.6 Data Gaps/Proposed Audits

Although numerous investigations have been conducted to characterise the proposed waste feedstock, including waste audits and review of available literature, gaps in feedstock compositional data exist.

Review of available literature concludes that Australian Federal, State and Local Government publications contain primarily compositional data of Melbourne metropolitan council solid waste streams currently going to landfill, describing the material type and breakdown by percentage by weight. These publications put focus on the determination of waste material composition varying from a one, two, or three-year basis without regarding variability characteristics such as demographic conditions and seasonal fluctuations in waste type. The research concludes that the available published data contains significant gaps in chemical and elemental detail required for alternative waste technology processes, and often vague and varied definitions of material categories used for


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collecting/collating data; in many of the publications, large portions of the material are often labelled “Other Materials” with no further detail provided.

The available literature data was not audited, and the methodologies used were not designed with characterisation for waste to energy solutions as the ultimate objective. Currently available audit data, even of the residual MSW waste going to landfill, has been focused on recyclability as the main objective, with no focus on the mix of waste materials from a WtE perspective.

The C&I waste streams proposed to be diverted to the facility would be sourced from suburbs in Melbourne’s south east from specific industry types. However, at present, there is no representative C&I waste characterisation data for the proposed facility. Further baseline C&I characterisation will be carried out to confirm that this waste stream will comply with the proposed fuel specification.

Additionally, other than the initial MSW audit (HRL, 2018), no other specific MSW data has been provided for characterisation and assessment of suitability for the proposed facility. The validity and reliability of analysis from the initial audit, in addition to seasonal variability, would need to be confirmed through further waste audits. Additional compositional data is intended to be obtained through the MWRRG sponsored audit, however the audit is not expected to include assessment of moisture content, calorific value or elemental (major and trace) composition of MSW.

Gaps in the residual MSW and C&I waste characterisation data are proposed to be addressed over time, to include seasonality coverage, plus completion of to be agreed, further statistically valid representative sampling and characterisation to satisfy works approval conditions.

GSWT intends to rely upon the MWRRG MSW audit data, combined with independent laboratory analysis, to inform anticipated waste compositions. GSWT will report to EPA on a regular basis as the waste characterisation process progresses through the seasons and the MWRRG audit data becomes available.

Further works to be conducted prior to commissioning the facility, to sufficiently characterise the waste feedstock and address current data gaps include: • Perform seasonal audits on MSW for summer, spring, and autumn, consistent with June 2018 audit methodology • Complete seasonal auditing, including compositional analysis, on identified C&I waste feedstock • Compare elemental characteristics from proposed audits against proposed fuel specification • Finalisation of specific fuel specification for proposed facility, in conjunction with Energos.

Whilst GSWT has conducted works to characterise the proposed feedstock (refer to Section 4.2.1 and 4.2.2), it is agreed that additional characterisation of waste is required to further understand the seasonable variability, chemical composition and other relevant characteristics. GSWT proposes to undertake additional works to further characterise the intended waste stream, including additional waste audits and comparison to fuel specification.

Traffic Impacts A traffic survey was conducted on 7 June 2018 by Trans Traffic Survey Consultants. The traffic surveys were undertaken in the morning period (06:00 to 09:00) and afternoon period (16:00 to 19:00) to capture the AM and PM peak hours. Refer to Appendix D for the Traffic Impact Assessment (SMEC, 2019e).

The existing road network adjacent the proposed facility consists of Ordish Road, Greens Road and Eastlink: • Eastlink (M3) is a Freeway that lies immediately west of the facility and runs in a north-south direction. There is a

two-way volume of 17,000 vehicles per day operating on this section of Eastlink • Greens Road is a declared main road under the care and management of VicRoads and exists as a two-lane road.

Greens Road crosses over Eastlink at diamond interchange with the Eastlink Freeway • Ordish Road is classified as a local road and intersects Greens Road at a signalised intersection with dedicated

turning lanes. The proposed facility would be accessed from Ordish Road.

The existing road network is shown in Figure 4-9. Vehicles entering or leaving the facility will be required to give way to other road users in accordance with the provisions of Road Rules Victoria.


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Figure 4-9: Existing Road Network (Source: VicRoads Map of Declared Roads)

Trips going to and from the site will fall into three basic categories:

• Trips associated with the transfer of waste material to the site • Trips associated with employees on the site travelling to and from work • Trips associated with visitors to the site during the working day.

MSW and C&I waste will be delivered from surrounding communities to the proposed facility by approximately 48 heavy vehicles per day. At full capacity, the proposed facility would receive approximately 100,000 tonnes of waste per annum which is around 1,923 tonnes of waste per week. Deliveries will coincide with morning and afternoon pickups resulting in about 24 heavy vehicles in both the morning and afternoon. The heavy vehicles will unload the waste into any one of four tipping bays, which would take a maximum time of 15 minutes for unloading.

The facility will generally only receive waste from Monday to Friday, however, there may be requirements for the facility to accept waste on weekends. The facility will receive around 385 tonnes of waste per day based on the maximum capacity of the facility.

A total of 96 two-way trips are expected to account for heavy vehicle movements at the proposed facility on a daily basis. The proposed facility would also receive approximately two semi-trailers carrying MSW or C&I waste per day and delivery of activated carbon and lime every few days. Fly ash and metal would accumulate at the proposed facility as a result of the process and would be transported from the facility as required. This waste and recyclables removal would generate between two to five traffic movements per week.

There will be around 12 permanent office staff and four maintenance staff at the facility during the day and two maintenance staff at night. Any additional traffic movement generation for operational purposes will be negligible. Operational vehicles will be parked in designated areas within the operational boundary.

Most of the operational traffic from the facility will move through the intersection of Greens Road and Ordish Road. This intersection is currently operating at a level of service (LoS) C, although the northern approach is operating at a LoS E during the AM peak.

The performance of the Greens Road and Ordish Road intersection was assessed for the 2018 base year and the 2025 year (five years post development full build out) and includes traffic volumes as a result of the proposal and future traffic volume from the road network. The results indicate acceptable performance levels are achieved in the AM


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peak, with no change to the LoS. Performance during the PM peak period for the south to west left turn movement presented a level of service ‘F’. The low LoS apparent on the south approach and the significant traffic volume growth relates to the continued growth of the entire precinct next to Ordish Road. The change to the Ordish Road / Greens Road intersection traffic volumes cannot be attributed to the low additional traffic volumes to be generated by the facility.

The facility would have a minor impact on the operation of Ordish Road and a negligible impact on the operation of the surrounding road network. The Traffic Impact Assessment report (SMEC 2019e) is provided in Appendix D.

Fire Management The following scenarios were identified as being a potential source of fire during operation of the facility:

• Ignition of waste in incoming vehicles • Ignition of waste in waste and fuel bunker and fire • Ignition within the shredder and fire • Ignition of waste in fuel bunker and bunker fire • Powdered Activated Carbon (PAC) dust liberation, ignition and explosion (storage silo) • PAC ignition in bag filters and fire • Release of process oils, ignition and fire • Steam turbine fire • Transformer oil spill, ignition and bund fire.

The facility will be protected by sufficient monitor(s) to ensure a deep-seated fire can be combatted effectively, particularly in the waste and fuel bunkers. The monitor(s) would be remotely operated to ensure they can be effectively utilised in a fire event. The design and installation of a visual fire detection system (i.e. infrared detection) will be considered during detailed design of the facility.

The hydrant system will provide full coverage of the proposed facility including waste and fuel bunkers. Hydrants will be located outside of the impact distance. A sprinkler system will be installed to protect the fluid lines, turbine and generator bearings, and areas beneath the turbine which may be subject to oil flow.

An air extraction system will be installed to prevent the accumulation of dust within the waste bunker hall.

The PAC silo will be subject to a hazardous area classification in accordance with the requirements of AS/NZS 60079.10.2:2011. Electrical equipment required to be installed within the PAC hazardous area will be controlled as per the requirements of AS/NZS 60079.14.1:2009. All thermal and hydraulic oil storage areas will be bunded to contain any hydrocarbon releases.

GSWT met with the Country Fire Authority (CFA) Dandenong on 11 December 2017 to discuss the project. Minutes from the meeting are provided in Appendix U.

The Fire Safety Study (RiskCon Engineering, 2019) is provided in Appendix E, with controls to be implemented presented in Table 4-12.


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Table 4-12 Key Fire Protection Measures

AREA CONTROLS

Waste Bunker The waste bunker shall be protected by sufficient monitor(s) to ensure a deep-seated fire within the waste bunker can be combat effectively.

The hydrant system shall be designed to provide full coverage of the waste bunker.

Hydrants shall be located such that they provide full coverage to the waste bunker; however, they shall be located such that hydrants designed to combat fires in the waste bunker are located outside of the impact distance

Monitor(s) installed to protect against a fire in the waste bunker shall be remotely operated to ensure monitor(s) can be effectively utilised in a fire event.

An appropriately sized air extraction system designed to prevent the accumulation of dust within the waste bunker hall should be considered to extract dust generated in the tipping process at both low and high levels (i.e. elevation).

The extracted air shall pass through a bag filter to prevent discharge of dust external to the facility.

Where possible, flat surfaces within the tipping hall should be minimised (i.e. designed as a sloped surface) to minimise the potential for dust accumulation which may escalate an incident if dislodged.

The site shall be subject to regular housekeeping practices to prevent the accumulation of dust on surfaces.

Consideration will be given to the design and installation of a visual fire detection system (i.e. infrared detection).

Shredder Inclusion of an appropriately sized sprinkler system within the shredder unit should be considered.

If a sprinkler system is included in the design, the shredder should be de-energised upon activation of the sprinkler system.

The hydrant systems shall be designed to ensure coverage of the shredder unit.

Fuel Bunker The fuel bunker shall be protected by sufficient monitor(s) to ensure a deep-seated fire within the bunker can be combat effectively.

The monitor(s) shall be located such that they are accessible in the event of a fire.

The hydrant system shall be designed to provide full coverage of the fuel bunker.

Hydrants shall be located such that they provide full coverage to the fuel bunker; however, they shall be located such that hydrants designed to combat fires in the waste bunker are located outside of the impact distance shown in Figure 5-3.

Monitor(s) installed to protect against a fire in the fuel bunker shall be remotely operated to ensure monitor(s) can be effectively utilised in a fire event.

An appropriately sized air extraction system designed to prevent the accumulation of dust within the waste bunker hall should be considered to extract dust generated in the waste fuel bunker at both low and high levels (i.e. elevation).


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The extracted air shall pass through a bag filter to prevent discharge of dust external to the facility.

Where possible, flat surfaces within the tipping hall should be minimised (i.e. designed as a sloped surface) to minimise the potential for dust accumulation which may escalate an incident if dislodged.

The site shall be subject to regular housekeeping practices to prevent the accumulation of dust on surfaces.

Consider the design and installation of a visual fire detection system (i.e. infrared detection).

Fuel Hopper The hydrant and monitor system shall be designed to provide full coverage of the fuel hopper and chute

Gasification & Oxidisation Chambers

The hydrant system shall be designed to provide full coverage to gasification and oxidation chambers.

PAC Storage The PAC silo shall be subject to a hazardous area classification per the requirements of AS/NZS 60079.10.2:2011.

Where electrical equipment is required to be installed within the PAC hazardous area it shall be controlled per the requirements AS/NZS 60079.14.1:2009.

Installation of explosion vent panels shall be considered on the PAC silos as part of the design review.

Bag Filters The particulates collected from the bag filters should be tested for combustibility (i.e. is the overall powder combustible).

If the particulates are found to be combustible, the bag filters shall be subject to a hazardous area classification per the requirements of AS/NZS 60079.10.2:2011 and the appropriate protection associated with electrical equipment per the requirements of AS/NZS 60079.14:2009 shall be adhered to.

The inclusion of sprinklers within the bag filters should be considered as part of the design review.

The hydrant system shall be designed to provide full coverage to bag filters.

Process Oils The hydrant system shall be designed to provide full coverage to the thermal and hydraulic oil process lines.

The hydrant system shall be designed to provide full coverage to the thermal and hydraulic oil storage areas.

The thermal and hydraulic oil storage areas shall be bunded to contain any releases within the bunded area.

Turbine Hall Inclusion of a sprinkler system to protection the fluid lines, turbine and generator bearings, and areas beneath the turbine which may be subject to oil flow should be considered as part of the design review.

The area beneath the turbine should be bunded to contain any oil flows preventing a spreading fire impacting other areas of the facility.

The hydrant system shall be designed to provide full coverage to the turbine.


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Hydrants shall be located such that they provide full coverage to the turbine hall; however, they shall be located such that hydrants designed to combat fires in the turbine hall are located outside of the impact distance.

Transformer The hydrant system shall be designed to provide full coverage to the site transformers

The transformer shall be bunded to contain any oil releases within the bunded area.

Hydrants shall be located such that they provide full coverage to the transformer hall; however, they shall be located such that hydrants designed to combat fires in the transformer hall are located outside of the impact distance .

General Once a detailed design has been completed for the hydrant system pressure, loss calculations shall be prepared for the most hydraulically disadvantaged hydrant to demonstrate compliance with the requirements of AS 2419.1-2017. • The Fire Study shall than be updated to include the pressure loss calculations.

The site shall be designed to contain at least 558 m3 of potentially contaminated water. This may be achieved via a combination of bunding in the building, diversion to storage bunkers, grading of the site, oversizing stormwater pipework.

A stormwater isolation point (i.e. penstock isolation valve) shall be incorporated into the design. The penstock shall automatically isolate the stormwater system upon detection of a fire (sprinkler activation) to prevent potentially contaminated liquids from entering the water course.

The building shall be fire protected per the requirements of the Building Code of Australia.

An Emergency Response Plan shall be developed for the site.


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Environmental Best Practice Assessment An environmental best practice assessment (BPA) was undertaken to demonstrate that the facility meets best practice in terms of techniques, methods, processes and technology to minimise potential environmental impact. Meeting environmental best practice criteria is a requirement under the Environment Protection Act 1970, State Environment Protection Policy (SEPP) (Ambient Air Quality), and SEPP (Air Quality Management) for the following activities:

• Solid waste treatment facility • Energy use and greenhouse gas emissions • Discharges to air • Noise emissions.

The SEPP (Air Quality Management) provides the following definition of best practice:

“The best combination of eco-efficient techniques, methods, processes or technology used in an industry section or activity that demonstrably minimises the environmental impact of a generator of emissions in that industry sector or activity.”

… where ‘eco-efficiency’ is defined as:

“Producing more goods with less energy and fewer natural resources, resulting in less waste and pollution.”

The definition of best practice varies somewhat between the SEPPs, however all require that all practicable measures be taken in a cost-effective manner, proportionate to the environmental issue being considered.

The SEPP (Air Quality Management) also states that all class 3 indicators (e.g. hazardous pollutants such as dioxins and furans) must be reduced to the maximum extent possible, placing less emphasis on cost and more on minimising human health and environment risks.

The best practice assessment was conducted in accordance with EPA Guideline 1517.1 – Demonstrating Best Practice (EPA, 2017a), and included:

• Defining the scope - the outcomes of the environmental risk assessment (Section 6.1) were used to guide the scope of the environmental best practice assessment

• Analysis of options (site, technology, processes) • Undertaking a best practice analysis, including:

− Literature review − Benchmarking − Application of the waste hierarchy − Economic, social and environmental considerations − Integrated environmental management

• Environmental best practice assessment and preferred option selection.

4.5.1 Risk Assessment

An environmental risk assessment was undertaken to identify appropriate controls that were either currently implemented or would be implemented during construction and operation of the proposal to mitigate environmental risks to an acceptable level. Further details are provided in Section 6.1.

The risk assessment identified residual risks considered ‘low’ to ‘medium’ resulting from plant operation, which are able to be managed to an acceptable level through the implementation of controls.

Impacts related to construction were also rated ‘low’ to ‘medium’ and are to be managed in accordance with the Site Environmental Management Plan.

4.5.2 Site Selection

The environmental best practice assessment applies to the site selection, layout, operation and management systems put in place to guarantee that human health, amenity, and the environment, are protected.

The principles of environmental best practice were applied to the site selection for the proposal, including:


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• Location – the surrounding road network directly links the proposed site to several main roads including Eastlink, the Monash Freeway, and Princes Highway, to allow for efficient delivery of waste materials

• Surrounding land use – the proposed site is in an industrial area, surrounded by existing industrial activities • Industrial zone – the proposed site is zoned industrial with limited sensitive receivers in close proximity, reducing

likelihood of odour and/or noise impacts.

The proposed site for the facility covers approximately 1.27 hectares and is currently utilised as a sand blasting and industrial painting facility. The proposed site is located within an industrial zone, surrounded by existing industrial land uses, including waste-handling facilities. Lots directly surrounding the site are zoned for industrial use (IN2Z), allowing development for intensive industrial land use such as manufacturing, storage and distribution of goods. Lots further to the north of the proposed site are zoned IN3Z, allowing industrial land use but also providing a transition between industrial land use and residential land use.

The selection of a proposed site within a large existing industrial estate minimises the impact the facility would have on sensitive receivers/areas. The surrounding land uses, including sensitive receivers/areas include:

• North - Industrial zoned land extending to approximately 2.2 km north of the proposed facility to Dandenong Bypass. Residential suburb of Dandenong located north of Dandenong Bypass

• East – Industrial zoned land extending to approximately 4.9 km east of the proposed facility. Eumemmerring Creek extends in a north-east to south-west direction, located 3.4 km east of the site. The residential suburb of Hampton Park is located east of South Gippsland Freeway (4.9km from site)

• South – Industrial zoned land extending to approximately 2.2 km south of the facility, with the Eastern Treatment Plant further south beyond Eumemmerring Creek

• East - Dandenong Creek is located 160 metres to the west of the proposed facility. Low density residential properties extend west from approximately 600 meters west of the proposed facility. The Somerfield residential area and Sikh Temple (Keysborough) are located approximately 1400 metres to the north-west.

4.5.3 Operation

The principles of environmental best practice will be applied to the operation of the facility, including:

• Best practice equipment would be used in the operation of the proposed facility at the site, with higher efficiency technologies and emissions mitigation measures employed

• The operation of the proposed site would implement accredited environmental and quality management systems.

4.5.4 Process and Technology Selection

The process and technology to be implemented at the site has been selected as it offers a local solution to produce low-cost electricity, exceeds the requirements of the EU Emissions Standard (2000/76/EC) and minimises impact on the environment. The use of this technology has been demonstrated in Europe.

Process and technology considerations for the potential release of emissions, particulate matter (PM10, PM2.5), and dust (total suspended particles) from industrial processes are outlined in the SEPP (Air Quality Management) and SEPP (Ambient Air Quality).

The European Union’s Industrial Emissions Directive 2010/75/EU (IED) also specifies certain process and technology requirements for WtE facilities, many of these are discussed in subsequent sections.

4.5.5 Best Practice Assessment

4.5.5.1 Benchmarking

The EPA Guideline 1559: Energy from Waste (EPA, 2017b) requires an existing or proposed facility to comply with the European Union’s Industrial Emissions Directive 2010/75/EU (IED) and Victorian regulatory requirements. The IED is considered the global benchmark for managing air emissions from WtE facilities, and outlines emissions limits and monitoring requirements, which are discussed further in Section 5.2. The proposed facility would adhere to the requirements of the IED.

For thermal processes, the proponent must demonstrate that the proposal targets genuine energy recovery, as specified in EPA Publication 1559. For WtE facilities, the thermal efficiency of the facility it to be demonstrated using the R1 Efficiency Indicator as defined in the European Union’s Waste Framework Directive 2008/98/EC (WID) and


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presented in EPA Publication 1559. For a plant to be considered a genuine energy recovery facility, R1 should be equal to or greater than 0.65.

The R1 Efficiency Indicator has been calculated using the following formula, in accordance with EPA Publication 1559. An estimate of the energy efficiency of the facility (R1) was calculated as 0.85, subject to minor revision following confirmation of the Net Calorific Value of the waste feedstock (fuel) subsequent to proposed waste audits.

Ep: Annual energy produced as heat or electricity. Calculated with energy in the form of electricity being multiplied by 2.6 and heat produced for commercial use multiplied by 1.1 (GJ/year) Ef: Annual energy input to the system from fuels contributing to the production of steam (GJ/year) Ew: Annual energy contained in the treated waste calculated using the net calorific value of the waste (GJ/year) Ei: Annual energy imported excluding Ew and Ef (GJ/year) 0.97: Factor account for energy losses due to bottom ash and radiation

The following assumptions were used in the R1 calculation:

• Electricity generation: 7.9 MW (refer to Section 4.1.8) • Annual energy input to the system from fuels: 2.4 GWh/year (refer to Table 4-2) • Net calorific value of feedstock (waste): 7.2 MJ/kg (refer to Table 4-8) • Annual energy imported: 12 GWh/year (refer to Table 4-2)

4.5.5.2 Waste Hierarchy

The waste hierarchy (Figure 4-10) is one of eleven principles of environmental protection contained in the EP Act, and its application has been considered throughout the development of the proposal. Wastes for the proposed facility would comprise municipal solid waste and commercial and industrial wastes, representing a relatively predictable baseload feedstock with consistent composition.

The operating philosophy to be employed at the proposed facility will be to not negatively impact on higher-order waste management, those being recycling, reuse, and avoidance. All waste used for Waste to Energy will be post-source separation.

Diversion of solid wastes from landfill to produce energy is a higher-order use of waste – from “disposal” to “recovery of energy”. Waste will be sourced from recycling facilities, as the treatment of co-mingled recycling typically generates about 10 per cent of residual waste, which would traditionally be sent to landfill.

Prior to reaching the facility, feedstock waste will have undergone source separation to remove recyclable waste. Separation of ferrous metals will be undertaken through magnetic separation.

It is considered likely that bottom ash and fly ash will be disposed to landfill given the lack of apparent demand for such waste products for beneficial reuse (i.e. as road base, cement). However, future reuse of waste ash remains a potential possibility, subject to further assessment, providing a more preferable option on the waste hierarchy by moving from “disposal” to “re-use” in the waste hierarchy.

Diversion of waste from landfill, as well as potential reuse of some of the WtE where practicable by-products represents best practice for both waste management and environmental protection.

Water

Water management at the facility aims to reduce the amount of potable water use by reusing process waste stream and subsequently reducing effluent outflows. Potable water is used for cooling and blow-down and treated recovered process water is used for wash-down in the fuel bunker and bottom ash conveyor. An effluent sump is provided for effluent outflow which will vary in quality depending on the effluent source, such as from the ash bunker run-off and boiler lines. The requirement for a permanent connection to sewer will be assessed during detailed design.

Based on the design loads, 5 to 6m3/hour of water at 100°C will discharge to atmosphere and 1 m3/hour of effluent will discharge to the effluent sump at 60°C.


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Figure 4-10 Waste Hierarchy (EPA, 2017c)

4.5.5.3 Greenhouse Gas Reduction

Transitioning up the waste hierarchy from least preferable to most preferable provides an additional benefit of reducing greenhouse gas emissions, through the reduction of wastes going to landfill. It is estimated that the facility will result in a greenhouse gas emissions net benefit of 142,800 tonnes of carbon dioxide equivalent (tCO2e) per year. The facility is estimated to produce net emissions of 9,500 tCO2e per year, however, through diversion of 85,000 tonnes of MSW and 15,000 tonnes of C&I from landfill to the facility, 137,000 tCO2e will be avoided (as estimated for business as usual waste disposal through landfill).

Additionally, useful products recovered from the facility may lead to further greenhouse gas emissions reductions through the replacement of virgin materials. Start2See (2019) estimated the benefit associated with recovery of material to be 15,300 tCO2e per year.

The proposal will also identify further best practice energy use and greenhouse gas reduction initiatives to implement during operations, in accordance with the Protocol for Environmental Management – Greenhouse Gas and Energy Efficiency in Industry (EPA, 2002).

Refer to Section 5.1 for further discussion.

4.5.5.4 Air Emissions

Impacts associated with air emissions were identified as a high risk if unmitigated during operation of the facility. As such, the management of air emissions is a key focus of the design development and is primarily informed by the air emissions modelling and impact assessment (Section 5.2). The assessment identified that modelled ground level concentrations of exhaust gas emissions would be below the relevant assessment criteria specified in the SEPP (Air Quality Management) and NEPM (Ambient Air Quality).

In addition, the IED outlines emissions limits and monitoring requirements for WtE facilities, including the requirement for continuous emissions monitoring for the following;

• particulate matter • sulphur dioxide (SO2) • oxides of nitrogen (NOx) • hydrogen chloride (HCl) • carbon monoxide (CO) • total organic carbon


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• hydrogen fluoride (HF).

Continuous emissions monitoring systems (CEMS) will be included in the design and operation of the facility.

Operations at the facility will also include non-continuous monitoring for heavy metals, dioxins and furans at a frequency to be outlined in the relevant environmental management plan, and as agreed between the proponent and as required by the EPA.

The IED also mandates that WtE processes ensure that combustion or co-combustion gases are maintained at 850 °C or more for at least two seconds after the last injection of air, to facilitate the complete combustion of waste and volatile organic compounds (VOCs), and minimise the risk of formation of dioxins and furans.

The proposal will operate in accordance with the IED, and as such, would operate as best practice in terms of air quality management.

4.5.5.5 Emissions Control and Reduction Technologies

The proposed facility will adopt flue gas emissions controls that are based on the European Commissions’ Integrated Pollution Prevention and Control Reference Document on Best Available Technology for Waste Incineration (EC BREF, 2018).

The selection of flue gas treatment was based on the proposed facility meeting the requirements of:

• EPA Guideline 1559.1: Energy from Waste (EPA, 2017b) • EU IED 2010/75/EU • SEPP (Air Quality Management), where it regulates additional pollutants or stricter thresholds than those

outlined in the IED.

The following technical specifications will be included in the design of the proposed facility:

• online flue gas oxygen measurement at the boiler economiser exit to maintain optimum furnace air supply for complete combustion with a design excess oxygen target of 6 per cent volume or greater

• flue gas recirculation for control of combustion and of oxides of nitrogen.

4.5.5.6 Odour

The main sources of odour from the proposed facility will be from the waste receival areas – the tipping hall and waste bunker. These areas will be entirely enclosed and operated under conditions creating a slight negative air pressure to minimise odour release. Air from within the hall and bunker area are utilised as the combustion air injected into the oxidation chamber(s), where odours, hydrocarbons and VOCs will be destroyed. Based on evidence from similar facilities currently operating overseas, this will eliminate most, if not all, odours. Regular monitoring for odours will be a requirement of the operational monitoring plan.

4.5.5.7 Noise

Operation of the proposed facility will generate noise from vehicle movements and the use of blowers, tower turbines, boilers and other equipment. All equipment will have point source noise limits based on WorkSafe requirements, and their operation will comply with the Noise from Industry in Regional Victoria (EPA, 2011). Where required, equipment will be enclosed to ensure compliance with noise limits. An Environmental Noise Assessment was undertaken for the facility. A summary of this is provided in Section 5.4.

4.5.5.8 Economic, social and environmental considerations-

Economic, social and environmental factors have been considered through the facility development proposal, including in the selection of a technical solution, and in the environmental risk assessment. Project-wide economic, social, and environmental initiatives adopted in addition to those outlined in the best practice assessment include:

• Returning about 7.9 MW per annum of energy to the market • Creation of about 20 direct operational jobs, and an additional 150 jobs during construction • Diversion of up to 100,000 tonnes per annum of MSW and C&I waste from landfill to a higher order use such as

recovery of energy. • A net reduction in greenhouse gas emissions of about 142,800 tonnes CO2e per year.


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4.5.6 Conclusion

The facility can be considered environmental best practice as it proposes to divert waste from landfill and use it in the production of energy. Other best practice considerations have been applied to the design and development of the proposal including:

• The facility is in an existing industrial area, with surrounding industrial land use including other waste handling facilities

• The facility will be designed and operated in accordance with the IED, including the installation and operation of an accredited CEMS

• Flue gas will be recirculated to control the production of NOx in the furnace • Process water treatment and reuse reduces the effluent discharge amount and potable water consumption • Opportunities will be explored for beneficial reuse of bottom and fly ash where practicable • Diversion of up to 100,000 tonnes per year of MSW and C&I waste from landfill (disposal) to higher order uses in

the waste hierarchy including ‘recovery of energy’ potentially ‘reuse’.

Environmental Information

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Environmental Information Energy Use and Greenhouse Gas Emissions

This section details how the facility meets the requirements of the SEPP (Air Quality Management), as well as the Protocol for Environmental Management – Greenhouse Gas Emissions and Energy Efficiency in Industry (2002), including discussion and/or assessment of:

• State and Commonwealth Government regulatory and policy framework • Estimated energy and non-energy related greenhouse gas emissions resulting from the operation of the

proposed facility • Comparison of estimated emissions against landfill operations • An outline of best practice measures being incorporated in the design and operation of the proposed facility to

minimise greenhouse energy use and gas emissions.

5.1.1 Victorian EPA Policy Requirements

The greenhouse gas and energy regulatory and policy framework against which the Victorian Government assesses compliance of works approvals is detailed below.

5.1.1.1 Climate Change Act 2017

The facility will be deemed a ‘Scheduled Premises’ under the Victorian Scheduled Premises and Exemptions Regulations 2007, and therefore will be subject to the provisions of the Victorian Climate Change Act 2017 (CC Act). The CC Act sets a target to achieve net-zero carbon emissions by 2050. The policy framework and pathway of the Act is consistent with objectives of the Paris Agreement, aimed at minimising global temperature increase below 2 °C above pre-industrial levels.

Section 17 of the CC Act states that “Decision makers must have regard to climate change”. Sub-sections 17(2), (3) and (4) require decision makers to have regard to greenhouse gas emissions and climate change impacts, specifically:

17(2) “A person making a decision or taking action referred to in subsection (1) must have regard to:

a) the potential impacts of climate change relevant to the decision or action b) the potential contribution to the State’s greenhouse gas emissions of the decision or action c) any guidelines issued by the Minister under section 18.

17(3) “In having regard to the potential impacts of climate change, the relevant considerations for a person making a decision or taking an action are:

a) potential biophysical impacts b) potential long-and short-term economic, environmental, health and other social impacts c) potential beneficial and detrimental impacts d) potential direct and indirect impacts e) potential cumulative impacts.

17(4) “In having regard to the potential contribution to the State’s greenhouse gas emissions, the relevant considerations for a person making the decision or taking an action are:

a) potential short-term and long-tern greenhouse gas emissions b) potential direct and indirect greenhouse gas emissions c) potential increases and decreases in greenhouse gas emissions d) potential cumulative impacts of greenhouse gas emissions.

5.1.1.2 Environment Protection Act 1970

The Environment Protection Act 1970 (EP Act) provides the legal framework to protect the environment in the State of Victoria and applies to emissions to air, water and land environments. SEPP (Air Quality Management) is subordinate legislation made under the provisions of the EP Act to provide more detailed requirements for the application of the EP Act to air quality emissions. Provisions in SEPP (Air Quality Management) relevant to greenhouse gas emissions include:

• clause 18 – general requirements – including definition of the management of emissions, generators of emissions, and requirements to comply with the policy. This clause requires generators of emissions to manage


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their activities and emissions in accordance with the provisions of the SEPP (Air Quality Management) and to pursue continuous improvement in environmental management practices

• clause 19 – requirements for the management of new sources of emissions – this clause requires generators of new sources of emissions to apply best practice to the management of emissions

• clause 33 – requirements to implement the Protocol for Environmental Management of Greenhouse Gases. This clause specifies that greenhouse gases must be managed in accordance with clause 18 and clause 19.

5.1.1.3 Protocol for Environmental Management: Greenhouse Gas Emissions and Energy Efficiency in Industry 2002

The Protocol for Environmental Management: Greenhouse Gas Emissions and Energy Efficiency in Industry (2002) (GHG PEM) outlines the measures that businesses must take to demonstrate compliance with SEPP (Air Quality Management) regarding greenhouse gas emissions and energy efficiency. The GHG PEM states that a greenhouse gas assessment is required as part of an EPA Works Approval Application. The objectives of the GHG PEM are to:

“Ensure that Victorian businesses subject to EPA works approvals and licencing system that have an impact on the environment in terms of their energy consumption and greenhouse gas emissions:

a) take up cost-effective opportunities for greenhouse gas mitigation, noting that in many cases they will achieve cost-savings through greater energy efficiency

b) integrate consideration of greenhouse and energy issues within existing environmental management procedures and programs.

The GHG PEM also streamlines procedures to minimise duplication of requirements with other policies that a business might be involved with such as the Commonwealth Government’s National Greenhouse and Energy Reporting Act 2007, or the Sustainable Energy Authority’s Energy Smart Businesses.

5.1.1.4 Environmental Effects Act 1978

The Environmental Effects Act 1979 (EE Act) prescribes the requirement of an Environmental Effects Statement (EES) to be prepared where there is likelihood of a regional or state significant adverse effect on the environment from an activity. In relation to greenhouse gas emissions, the EE Act requires an EES if it is estimated that there would be “potential greenhouse gas emissions exceeding 200,000 tonnes of carbon dioxide equivalent per annum, directly attributable to the operation of the facility”.

Estimated annual greenhouse gas emissions (Section 5.1.4) for the facility were below this threshold and, therefore the requirement for an EES is not triggered by this criterion .

5.1.2 Commonwealth Government and International Policy

5.1.2.1 National Greenhouse and Energy Reporting Act 2007

The National Greenhouse and Energy Reporting (NGER) Act 2007 established the National Greenhouse and Energy Reporting Scheme, a single national framework for reporting and disseminating information on company’s greenhouse gas emissions, energy production, energy consumption, and other information specified under NGER. Among other objectives, the scheme was established to inform government policy, and avoid duplication of similar reporting requirements in the states and territories.

The NGER Measurement Determination 2017, is a subordinate legislation of the NGER Act, which is updated annually. The determination describes methods, standards and criteria to be applied when estimating greenhouse gas emissions, energy production and energy consumption.

5.1.2.2 Greenhouse Gas Protocol

The Greenhouse Gas Protocol was developed by the World Business Council for Sustainable Development and the World Resource Institute. The protocol establishes a comprehensive global standardised framework to measure and manage greenhouse gas emissions from private and public-sector operations. It also established and defined scope 1, 2 and 3 greenhouse gas emission categories, which are now used in most national government greenhouse gas reporting legislation.

5.1.2.3 ISO 14064-1:2006

Greenhouse Gases – Part 1 specifies requirements and principals at the organisation level for quantification and reporting of greenhouse gas emissions and removals, including requirements for the design, development, management, reporting and verification of an organisation’s greenhouse gas inventory.


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5.1.3 Methodology

Start2See Lifecycle Assessment undertook a lifecycle assessment of the facility and compared it with a business-as-usual case of sending waste to landfill, assuming 80-85 per cent MSW and 15--20 per cent C&I.

The LCA methodology is based on ISO 14040:2006 and ISO 14044:2006 standards. The carbon footprints have been determined using the Global Warming Potentials from the IPCC’s Fourth Assessment Report (AR4).

The Lifecycle Assessment (Start2See, 2019) is presented in Appendix M.

5.1.3.1 Scope and boundary

The scope of this assessment includes a greenhouse gas emissions assessment for the operation of the facility. The assessment compared the operation of the facility against a baseline of operation where waste is directed to landfill, with all of the energy required to operate the plant being delivered by fossil fuels.

GHG emissions attributable to the following items are omitted from the system boundaries for both scenarios (waste to landfill or waste to energy):

• Infrastructure • Capital goods • Human labour and transport for employees

The following life cycle stages were included in the assessment:

• Collection of waste and transport to the Dandenong South Facility • Operation of GSWT’s facility • Export of surplus electricity generated from the MSW/C&I waste • Extraction of ferrous and non-ferrous metals (recyclables)

5.1.3.2 Emissions sources

This greenhouse gas assessment mainly considered emissions of:

• carbon dioxide (CO2) • methane (CH4)

Methane is reported as carbon dioxide equivalents.

As discussed, the Greenhouse Gas Protocol categorises greenhouse gas emissions sources into three scopes:

• scope 1 – direct emissions resulting from sources that are owned or operated by a reporting organisation (e.g. combustion of fuel used in on-site machinery)

• scope 2 – indirect emissions associated with the use of energy form another source (e.g. purchased electricity) • scope 3 – other indirect emissions (other than scope 2 energy imports) which are a direct result of the operations

of a reporting organisation, but from sources not owned or operated by that organisation (e.g. embedded emissions in raw materials).

Only scope 1 and scope 2 emissions were considered in this assessment. Scope 3 emissions were not considered in this assessment as they are not required to be reported under the National Greenhouse and Energy Reporting Act 2007.

As such, the following emissions were calculated for the facility:

• fossil fuel component stack gas emissions (scope 1) • operating power consumption emissions (scope 2) • pre-treatment power consumption emissions (scope 2) • auxiliary burner fuel/oil consumption emissions (scope 1) • abated emissions from electricity generation.

Data utilised in the assessment was obtain from GSWT and literature reviews, as presented in Appendix M.

A number of assumptions were made in completing this assessment (Start2See, 2019), including:

• The quantity of MSW and C&I waste diverted from landfill is based on current plant capacity modelling by GSWT


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• The energy content of MSW is presumed to be 10 GJ/t (based on communication from GSWT) • The energy content of C&I waste is presumed to be 10 GJ/t. This is a conservative estimate (based on

communication from GSWT) • The percentage biomass in MSW is estimated to be 66 per cent by mass / 39 per cent by energy content (based

on Australian Greenhouse Office - Guideline for Renewable Components in Waste) • The percentage biomass in C&I is presumed to be 66 per cent by mass / 39 per cent by energy content (assumed

similar to MSW) • The model differentiates between biogenic and non-biogenic stack emissions from the facility. Biogenic

emissions do not count towards the total GHG emissions • The destination of waste under the BAU scenario is landfill. This is currently the most reasonable assumption • The facility is expected to be largely self-sufficient from an energy perspective. This is based on current modelling

by GSWT − Around 1.4 MW of the electricity generated by GSWT is used for parasitic loads (Energos 2017); surplus

electricity (7.9 MW) will be exported to the grid. Although the electricity is exported to the Victorian grid, the emissions factor used for calculating the carbon dioxide equivalent net abatement amount is based on the National Electricity Market (NEM) in accordance with [CFI 2017].

− Natural gas is projected to be used to start up the process after interruptions, and to assist the process when required.

− Diesel fuel for the wheel loader, bobcat and forklift is supplied from external sources. • Start2See has estimated which virgin products are being replaced by the secondary materials generated by

GSWT • Bottom ash is assumed to go to landfill. Start2See has calculated the emissions from bottom ash in landfill using

the NGER determination method [NGER 2008] for solid waste disposal on land, applying a Total Organic Carbon content of 1.4 per cent w/w as Degradable Organic Carbon

• Transport distances / loads / modes have been provided by GSWT based on current estimates of waste sources. • The assessment excludes emissions embodied in the building, plant and other capital goods. A sensitivity analysis

shows that the emissions in the building are immaterial over the lifetime of the plant.

It should also be noted that some of the parameters used in the assessment would change over the life of the proposed facility, including:

• waste composition – various factors will influence the composition of waste coming into the proposed facility, which would affect the calorific value of the waste, influencing both biogenic and non-biogenic fractions

• grid electricity – Victoria’s electricity grid will likely become less carbon dominated, with a move toward greater renewable sources. While this would not affect the quantity of electricity offset, the emissions offset would decrease.

5.1.4 Estimated Emissions

Table 5-1 provides the emissions estimates for the facility; landfill waste produced emissions that are flared, and; landfill waste emissions that are captured for electricity generation. All estimates are based on 100,000 tonnes of waste per year and provided as tonnes carbon dioxide equivalent per year (tCO2e/year).

Table 5-1: Estimated greenhouse gas emissions, comparison emissions

SOURCE GREENHOUSE GAS EMISSIONS

tCO2e/year

WtE facility net emissions 9,500

BAU Landfill greenhouse gas emissions (85,000 tonnes MSW; 15,000 tonnes C&I) 137,000

Recovered products net benefit 15,300

Difference between business as usual and WtE plant 142,800

Greenhouse gas emissions estimates for the WtE facility (Table 5-1) show that the facility would have net benefit greenhouse gas emissions (i.e. displacing more emissions than they are generating) of 142,800 tCO2e/year. In


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considering total greenhouse emissions, the facility is estimated to produce net emissions of 9,500 tCO2e/year. These emissions estimates were compared with emissions resulting from the same quantity of waste being diverted to landfill of 137,000 tCO2e/year.

Additionally, useful products recovered from the facility may lead to further GHG emissions reductions through the replacement of virgin materials. Start2See (2019) estimated the benefit associated with recovery of material to be 15,300 tCO2e/year.

5.1.5 Best Practice Energy and Greenhouse Gas Management

The best practice assessment for energy use and greenhouse gas management has included the application of the waste hierarchy and the integration of economic, social and environmental considerations as discussed in Section 4.5. The proposal is committed to using best practice in the selection and operation of the facility plant and equipment, and to deliver the emissions savings identified in this chapter.

5.1.5.1 Construction

Energy and greenhouse gas emissions reduction opportunities will be included in the design, procurement and construction of the facility. This may include:

• identifying opportunities to use biofuel during construction of the plant • identifying opportunities to use alternative materials in construction, such as fly ash as a supplementary

cementitious material (to replace traditional cement) and reclaimed aggregate • identify opportunities to use recycled steel (where technically possible and cost effective).

5.1.5.2 Operation

Waste management and environmental best practice during operation of the proposed WtE facility is considered in detail in Section 5.7.

Although the project would have direct emissions of greenhouse gases from non-biogenic (fossil) waste components, these are offset by the estimated electricity produced to provide a net greenhouse gas emissions benefit

The total greenhouse gas emissions reduction benefits from the facility detailed in this section are based on the current Victorian electricity emissions factor of 1.08. As the Victorian grid switches to lower carbon forms of generation, this factor will decrease, increasing the total relative emissions from the facility. However, adopting an emissions factor of 0.6, which may represent the life of the facility, still provides a greenhouse gas emissions reduction from the facility (non-biogenic only) of approximately 75 per cent compared to landfill.

As stated in the Climate Change Act 2017, Victoria is aiming to become carbon neutral by 2050. The facility will assist the state in achieving this through recovery of energy by diverting waste from landfill and generating electricity from the renewable component (organic) of waste.

The proponent will also seek to beneficially reuse residues from the operation, which may include:

• use of bottom ash as a substitute aggregate for, e.g. road base. This would offset the use of virgin aggregate manufacture, providing a sustainable alternative

• fly ash may be able to be bound into a concrete-like mixture, providing a further offset to the use of virgin aggregate material.

5.1.6 Conclusions

This assessment was conducted in accordance with Victorian EPA and Commonwealth Government guidelines. Greenhouse gas emissions were calculated for the operation of the facility only (not construction). These were divided into biogenic and non-biogenic sources, and displaced emissions through the generation of electricity.

The assessment concluded that the greenhouse gas benefits from the facility amount to 142,800 t CO2e per year through the diversion of 100,000 tonnes of MSW and C&I from landfill.

The results of the assessment are based on current design parameters and generic data. The BAU scenario assumes that MSW and C&I goes to landfill.

Construction greenhouse gas emissions were not assessed; however, these are likely to be dominated by embedded emissions in construction materials. Many of the materials required to construct the plant will be manufactured off-site and transported to site. Aside from construction materials, fuel used on the construction site is likely to be the


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next largest source of emissions. Based on information presented in other proposed facilities works applications, scope 3 emissions (i.e. embedded) may contribute up to 80 per cent of construction emissions.

Air Emissions Emissions to air from the facility were a key consideration of the environmental planning assessment. To inform the Works Approval Application, an emissions modelling and impact assessment was undertaken (Synergetics, 2019). Refer to Appendix F for emissions modelling and impact assessment report.

To protect both human health and the environment the facility has adopted SEPP (Air Quality Management) as well as relevant European emissions standards, as detailed in Section 5.2.2.

5.2.1 Air Emissions Assessment

The air quality and emissions modelling impact assessment included:

• an overview of the legislative and policy context relevant to air quality in Victoria and relevant to the operation of a WtE facility

• an outline of baseline air quality • modelling of potential ground level concentrations (GLCs) of emissions • assessment of modelled emissions against relevant standards, guidelines and policies

The air quality assessment evaluated modelled concentrations against relevant guidelines. The methodology was based on that outlined in the SEPP (Air Quality Management) and EPA Guideline 1551: Guidance Notes for Using the Regulatory Model AERMOD in Victoria (EPA, 2013a).

Meteorological data was sourced from Bureau of Meteorology from Moorabbin Airport station, which is approximately 10 kilometres from the site. Upper atmosphere data was sourced from Melbourne Airport station. Five years of data was processed in accordance with EPA (2013a). Background air quality data was obtained from EPA (EPA, 2017); however, background concentrations for several key parameters were not available.

Emissions were modelled for three scenarios using both the measured and maximum concentrations from similar plants, and relevant European Union (Industrial Emissions Directive – 2010/75/EU) limits (EU Limits). The scenarios modelled included:

4. Maximum measured emissions – emissions at the maximum concentrations reported for selected reference facilities in Europe (refer to Section 5.2.4)

5. EU Limits – Emissions at the reported EU emission (IED) limits 6. Start Up Conditions – emissions at the maximum rates reported during start up for similar reference facilities

in Europe

Ground level concentrations were assessed for each of the three emissions scenarios.

The modelling was based on point source emissions from the facility stack location and height. GLC thresholds were taken primarily from the SEPP (Air Quality Management), except for dust, for which the NEPM (Ambient Air Quality) threshold was adopted. Dust emissions were assumed to be PM2.5.

Modelled GLCs were added to background concentrations, where available, and compared to corresponding SEPP (Air Quality Management) design criteria.

5.2.2 Policy context

The Victorian Government is committed to enabling a waste and resource recovery system that protects the environment and public health, while maximising the productive value of resources and minimising long-term costs to the community. To facilitate this, the following legislative instruments and guidelines pertaining to air quality and emissions have been developed:

• Environment Protection Act 1970 • State Environmental Protection Policy (Ambient Air Quality) • State Environmental Protection Policy (Air Quality Management) • EPA Industrial Waste Management Policy (Protection of the Ozone Layer) • EPA Guideline 1559.1: Energy from Waste (EPA, 2017b)


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• EPA Protocol for Environmental Management: Greenhouse Gas Emissions and Energy Efficiency in Industry (EPA, 2002)

• EPA Guideline 1551: Guidance Notes for Using the Regulatory Model AERMOD in Victoria (EPA, 2013a).

The facility is located in the Port Phillip Air Quality Control Region as defined under Schedule F of the SEPP (Air Quality Management). The facility would be regarded as a new stationary source by the EPA and therefore the emissions limits detailed in Schedule E of the SEPP (Air Quality Management) apply.

The following Commonwealth legislation also applies:

• National Environment Protection (Ambient Air Quality) Measure.

Relevant international standards include:

• European Union’s Industrial Emissions Directive (IED) 2010/75/EU • European Commissions Integrated Pollution Prevention and Control Reference Document on Best Available

Technology for Waste Incineration (EC BREF, 2018) • European Commission’s Waste Framework Directive (2008/98/EC).

5.2.3 Air Emissions Sources

The EPA AirWatch monitoring program, provides real-time air quality data from numerous sites around Victoria. The monitoring parameters include dust/particulate matter (PM2.5, PM10), nitrous oxides (NOx), sulfur dioxide (SO2) and ozone (O3). The closest to the proposal site is located at Greaves Reserve, Dandenong, about two kilometres to the north, however sulfur dioxide readings were only available from the Alphington monitoring station. Background levels of all parameters measured at this site are reported as very good (0-33 air quality index).

Sensitive receivers nearby the facility are detailed in Table 5-2. Ground level concentrations (GLCs) were modelled using information relating to the location of sensitive receivers and the proposed facility.

Table 5-2: Sensitive receivers nearby the proposed facility

RECEPTOR DISTANCE (m) LOCATION

Dandenong Creek 160 West

Residential Properties (Keysborough) 600 West/South West

School (Mt Hira College) 1,400 North-west

Residential Properties (Somerfield) 1,500 North-west

Religious Worship Centre (Sikh Temple) 1,500 North-west

Religious Worship Centre (Buddhist Temple) 1,400 North-west

Freemasons Victoria 1,900 North-west

5.2.4 Reference Facilities

As there are no similar facilities currently operating in Australia, air emissions from the facility were modelled based on reference facilities operating overseas (based on data provided by Energos).

A summary of the reference facilities utilised for emissions modelling is presented in Table 5-3.


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Table 5-3: Emissions Modelling Reference Facilities

SITE (YEAR OF COMMISSIONING) WASTE TYPE AND VOLUME1 DATA PERIOD

Energos FORUS (2002) 39,000 tonnes/year

MSW (100%)

19 March to 21 March 2017

10 November 2017

Energos Sarpsborg 1 (SAE-1) (2003) 78,000 tonnes/year

MSW (80%) and C&I (20%) 26 November to 28 November 2016

Energos Sarpsborg 2 (Hafslund Varme/SAE-2) (2009)

78,000 tonnes/year

MSW (30%) and C&I (70%) – 2010 to 2013

MSW (70%) and C&I (30%) – 2014 to current

Highest Daily Average 2013 and January to August 2014

22 November to 24 November 2016

Emissions during start up:

18 and 19 October 2014; and 18 and 19 April 2015

1 Exact fuel mix unknown during referenced emissions periods. The numbers provided are indicative.

Emissions data provided for reference facilities include daily samples covering emissions over a four day period (FORUS and SAE 1) and 20 months of daily averages for the Sarpsborg 2 plant which has a similar feedstock profile to the facility.

Refer to Appendix K for reference facility emissions data.

5.2.5 Air quality management best practice

The facility would be regarded as a new stationary source by the EPA. A new stationary source is defined as “a source of emissions of wastes to air from commercial or industrial premises that is stationary during normal operations”. Therefore, the emissions limits detailed in Schedule E of the SEPP (Air Quality Management) must be met. Those relevant to the operation of the facility are detailed in Table 5-4.

Table 5-4: Project relevant SEPP (Air quality management) Schedule E emissions limits for stationary sources

EMISSION TYPE EMISSION LIMIT (mg/Nm3)

Particulate matter (PM) 250

Carbon monoxide (CO) 2500

Oxides of nitrogen (NOx) – gas fuel 350

Oxides of nitrogen (NOx) – solid fuel 500

The EPA Guideline 1559.1: Energy from Waste (EPA, 2017b) specifies that:

“Health protection must be an inherent feature during the design, approval process and operation of [energy from waste] facilities. In the case of air emissions, EPA currently considers thermal treatment technology as best practice if:

• emissions of class 3 indicators [extremely hazardous substances that are carcinogenic, mutagenic, teratogenic, highly toxic or highly persistent, and which may threaten the beneficial uses of the air environment] as set out in SEPP (Air Quality management) are reduced to the maximum extent achievable which involves the most stringent measures available

• emissions discharges, under both steady and non-steady state operating conditions, meet all the emissions standards set in the [European Union’s IED 2010/75/EU]. The IED sets stringent emissions limits and monitoring requirements which include: − continuous emissions monitoring of total particulate matter; sulphur dioxides (SO2); oxides of nitrogen (NOx);

hydrogen chloride (HCl); carbon monoxide (CO); total organic carbon; hydrogen fluoride (HF). In addition, there must be at least non-continuous monitoring of other pollutants such as heavy metals, dioxins and furans, a minimum of two measurements per year, which should be more frequent during the initial operation of the plant. This monitoring should capture seasonal variability in waste feedstock and characteristics

− additionally, in order to guarantee complete combustion, the IED requires all plants to keep the combustion or co-combustion gases at a temperature of at least 850 °C for at least two seconds after the last injection of


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air. If waste with a content of more than 1 per cent of halogenated organic substances, expressed as chlorine, is combusted, the temperature must be raised to 1100 °C for at least two seconds after the last injection of air.

The combustion of waste or RDF as fuel replacement in an existing facility should have comparable or reduced emissions to atmosphere in comparison to the emissions from the standard fuel it replaces, with appropriate risk controls in place.”

In addition to the emissions limits specified in Table 5-4, the EPA Guideline 1559.1: Energy from Waste (EPA, 2017b) specifies that emissions of other harmful substances must meet the European Union’s IED 2010/75/EU, as outlined in Table 5-5.

Table 5-5: Industrial Emissions Directive 2010/75/EU emissions limits

POLLUTANT EMISSION LIMIT – 100TH PERCENTILE

(mg/Nm3)

EMISSION LIMIT – 97TH PERCENTILE (mg/Nm3) AVERAGING TIME

Total dust 10 - 24 hours

Total organic carbon (TOC) 10 - 24 hours

Hydrogen chloride (HCl) 10 - 24 hours

Hydrogen fluoride (HF) 1 - 24 hours

Sulphur dioxide (SO2) 50 - 24 hours

Oxides of nitrogen (NOx) 200 - 24 hours

Carbon monoxide (CO) 50 - 24 hours

Total dust 30 10 0.5 hour

Total organic carbon (TOC) 20 10 0.5 hour

Hydrogen chloride (HCl) 60 10 0.5 hour

Hydrogen fluoride (HF) 4 2 0.5 hour

Sulphur dioxide (SO2) 200 50 0.5 hour

Oxides of nitrogen (NOx) 400 200 0.5 hour

Carbon monoxide (CO) 100 - 0.5 hour

Carbon monoxide (CO) 150 - 10 minutes

Cadmium (Cd) +Thallium (Tl)1 0.05 - 0.5 hour

Mercury (Hg)1 0.05 - 0.5 hour

Antimony (Sb), arsenic (As), lead (Pb), chromium (Cr), cobalt (Co), copper (Cu), Manganese (Mn), Nickel (Ni), vanadium (V)1

0.5 - 0.5 hour

Dioxins / furans 0.1 (ng/Nm3) - 6 hours 1All metals include their compounds

The SEPP (Air Quality Management) sets design criteria for certain substances, which are limits for GLCs. The design criteria for class 1, class 2, and class 3 indicators, for assessing proposals for new emissions sources, are defined in Schedule A of the SEPP (Air Quality Management). Project relevant SEPP (Air Quality Management) design criteria are provided in Table 5-6.

Table 5-6: Project-Relevant SEPP (Air Quality Management) Design Criteria


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PARAMETER CLASSIFICATION AVERAGING

TIME

DESIGN CRITERIA

(mg/m3)

DESIGN CRITERIA

(ppm)

Carbon monoxide (CO) Toxicity 1 hour 29 25

Oxides of nitrogen (NOx) Toxicity 1 hour 0.19 0.1

Particulate matter 2.5 PM2.5 Toxicity 1 hour 0.05 -

Particulate matter 10 PM10 Toxicity 1 hour 0.08 -

Sulphur dioxide (SO2) Toxicity 1 hour 0.45 0.17

Polycyclic aromatic hydrocarbons (PAH) as BaP Carcinogen 3 minutes 0.053 0.017

5.2.6 Air quality impact assessment

The facility would adopt flue gas emissions controls, selected based on the EC BREF (2018). The selection of a flue gas treatment option was dictated by meeting statutory compliance requirements.

24-hour and 30-minute emission limits have been obtained from the waste incineration limits published by the EU (EU, 2010). Modelling was based on the most conservative of the 24 hour or 30-minute emissions limits. A summary of maximum monthly average (2013 and January to August 2014) reference facility emissions data for the Sarpsborg 2 plant and EU limits is presented in Table 5-7.

Table 5-7: Sarpsborg 2 Maximum Monthly Average Emissions

EMISSION COMPONENT EU LIMIT (24 HR)

(mg/Nm3)

EU LIMIT (0.5 HR)

(mg/Nm3)

MAXIMUM MONTHLY AVERAGE (SARPSBORG 2 PLANT)1

(mg/Nm3)

Dust 10 30 0.5

CO 50 100 4.1

HCl 10 60 8.0

TOC 10 20 1.6

NOx 200 400 58.9

SO2 50 200 40.3

1 Emissions data provided by Energos (Energos, 2014a), (Energos, 2014b)

The modelled GLCs (excluding background), based on maximum measured emissions profiles for reference facilities, were all below relevant assessment criteria (Table 5-8). Most parameters were between 0.02 per cent and 5.9 per cent of the assessment criteria, except nitrogen dioxide, which was 11 per cent of the assessment criteria.

Background concentrations were also considered for substances where data was available (NO2 and PM2.5). When modelled GLCs and highest recorded hourly average GLCs (2013-2017) were considered, the overall GLCs were still below the assessment criteria.

Table 5-8: Maximum measured modelled GLCs (99.9th percentile for all except PM2.5 and HF which are 100th percentile)

PARAMETER AVERAGING

TIME MODELLED VALUE

(mg/m3) SEPP ASSESSMENT CRITERIA (mg/m3) PERCENTAGE OF CRITERIA

PM2.5 24 h 1.2 x 10-4 0.025 0.49 %

Hg 3 min 1.9 x 10-6 3.3 x 10-4 0.59 %

Cd 3 min 1.9 x 10-6 3.3 x 10-5 5.9 %

CO 1 h 6.5 x 10-3 29 0.02 %


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PARAMETER AVERAGING

TIME MODELLED VALUE

(mg/m3) SEPP ASSESSMENT CRITERIA (mg/m3) PERCENTAGE OF CRITERIA

HF 24 h 5.8 x 10-5 0.0029 2.0 %

HCl 3 min 2.2 x 10-3 0.25 0.9 %

NO2 1 h 2.0 x 10-2 0.19 11 %

NH3 3 min 4.7 x 10-3 0.6 0.8 %

SO2 1 h 6.8 x 10-3 0.45 1.5 %

Dioxins 3 min 1.9 x 10-11 3.7 x 10-9 0.52 %

The modelled GLCs, based on EU (IED) emissions limits for WtE facilities, were all below relevant assessment criteria, with cadmium (29 per cent) and nitrogen dioxide (22 per cent) having the highest modelled percentage of the assessment criteria, as presented in Table 5-9.

Table 5-9: EU Limit modelled GLCs (99th percentile for all except PM2.5 and HF which are 100th percentile)

PARAMETER AVERAGING TIME

MODELLED VALUE (mg/m3)

SEPP ASSESSMENT CRITERIA (mg/m3) PERCENTAGE OF CRITERIA

PM2.5 24 h 5.8 x 10-4 0.025 2.3 %

Hg 3 min 9.7 x 10-6 3.3 x 10-4 2.9 %

Cd 3 min 9.7 x 10-6 3.3 x 10-5 29 %

CO 1 h 1.1 x 10-2 29 0.04 %

HF 24 h 5.8 x 10-5 0.0029 2.0 %

HCl 3 min 1.2 x 10-2 0.25 4.7 %

NO2 1 h 7.8 x 10-2 0.19 22 %

NH3 3 min 1.9 x 10-3 0.6 0.32 %

SO2 1 h 2.1 x 10-2 0.45 4.7 %

Dioxins 3 min 1.9 x 10-11 3.7 x 10-9 0.52 %

Modelling also considered background concentrations for nitrogen dioxide and sulfur dioxide, as per data obtained from Dandenong and Alphington monitoring stations respectively (EPA AirWatch). When background concentrations were considered, GLCs due to emissions from the facility were still below the assessment criteria for relevant substances where background data is available.

The substance with the highest modelled value relative to the acceptance criteria was cadmium, with a modelled result of 29 per cent of the GLC criteria. Background concentrations for cadmium were not available, and therefore was assumed to be zero.

5.2.7 Special Air Emission Assessment

Emissions during start up were also considered, with modelling conducted based on data from the Energos Sarpsborg 2 (SAE-2) facility. Data from the two start up events is presented Table 5-10.

Table 5-10: Emissions During Start Up

SUBSTANCE

19 OCTOBER 2014 18 APRIL 2015 MAXIMUM VALUE

(mg/Nm3) FIRST 30 MINUTES

(mg/Nm3)

SECOND 30 MINUTES (mg/Nm3)

FIRST 30 MINUTES (mg/Nm3)


Dust 0.2 0.1 1.1 7.3 7.3


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SUBSTANCE

19 OCTOBER 2014 18 APRIL 2015 MAXIMUM VALUE

(mg/Nm3) FIRST 30 MINUTES

(mg/Nm3)


FIRST 30 MINUTES (mg/Nm3)


Hg N/A N/A N/A N/A -

Cd+Tl N/A N/A N/A N/A -

Metals N/A N/A N/A N/A -

CO 7.4 0.9 3.5 41.4 41.4

HF N/A N/A N/A N/A -

HCl 9.7 9.4 15.5 22.5 22.5

TOC 3.1 2.0 0.0 0.0 3.1

NOx 207.9 183.3 140.9 163.0 207.9

NH3 N/A N/A N/A N/A -

SO2 10.1 2.1 154.4 297.9 297.9

Dioxides and Furans (TEQ) N/A N/A N/A N/A -

N/A – values were not provided (assumed they are not monitored during start up) Data provided for Energos Sarpsborg 2facility (Energos, 2015a/b)

Significant variability in start-up emissions was noted over the two events. Modelling was conducted assuming that one of the two lines was operating at the highest concentration (as presented in Table 5-10), while the other line was operating under steady emissions at the maximum value (as presented in Table 5-7).

Modelling of emissions during start up found that all substances, where emissions concentrations were available, were below the SEPP (Air Quality Management) assessment criteria.

Discussion regarding the flue gas control system, which impacts on emissions from the facility, is presented in Section 4.1.

Human Health Risk Assessment The process of thermal treatment of waste has the potential to emit a range of noxious chemicals which can have deleterious impacts on both the air shed and surrounding receptors. To assess the potentially damaging effects of the facility, SMEC engaged the services of Environmental Risk Sciences (EnRiskS) to conduct a comprehensive Human Health Risk Assessment (HHRA) to assess the likely effects of the facility on the surrounding population. The HHRA is presented in Appendix O and summarised herein.

5.3.1 HHRA process and principles

The HHRA was undertaken in accordance with the following guidance and regulations:

• enHealth 2012. Environmental Health Risk Assessment: Guidelines for Assessing Human Health Risks for Environmental Hazards (enHealth 2012a)

• enHealth 2012. Australian Exposure Factor Guidance – Guidelines for Assessing Human Health Risks for Environmental Hazards (enHealth 2012b)

• Guidance and guidelines available for the National Environment Protection Council in relation to ambient air quality (NEPC 2016) and contaminated land (NEPC 1999 amended 2013b)

• Victorian State Environment Protection Policies relevant to the assessment of air quality (EPA Victoria 2001) and others as relevant to the assessment.


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A comprehensive HHRA was undertaken to assess the risks to persons most likely to be affected by the emissions from the proposed facility. This included the development of a conceptual site model (CSM) as well as modelling and calculating the risks from the identified contaminants of concern (CoC) via their possible routes of exposure, being acute inhalation exposures, chronic inhalation exposures and multi-pathway exposures.

5.3.2 Issue Identification

A CSM was developed by EnRisks to determine the CoC, at risk populations, and most likely exposure pathways. A summary of the CoC and routes of exposure is provided in Table 5-11.

Inhalation was identified as the most likely route of exposure for most CoC. Emissions of NO2, SO2, HCl, HF, NH3 and CO are emitted in gaseous phase and are most likely to come into contact with people in the close surrounding area (defined in models as a 10 km x 10 km area with the proposed plant in the centre). Fine particulate matter less than 2.5 micrometres (PM2.5) will remain suspended in surrounding air and inhalation is the only exposure pathway.

Other CoC such as metals and dioxins are bound to heavier particulate matter and may be deposited on the ground. There is potential for dermal exposure by direct skin contact with soil as well as ingestion by eating foods that have been grown or raised in the soil (i.e. vegetable gardens, fruit trees, eggs). The HHRA examined all routes of exposure to determine the likely risks and impacts on all residents in proximity to the facility including any specifically at-risk populations identified in the CSM.

Table 5-11 Summary of Contaminants of Concern and Exposure Pathways

SUBSTANCE ROUTE OF EXPOSURE

Nitrogen dioxide (NO2) Inhalation only – Gaseous compounds

Sulfur dioxide (SO2)

Hydrogen chloride (HCl)

Hydrogen fluoride (HF)

Carbon monoxide (CO)

Ammonia (NH3)

PM2.5

Inhalation only as these pollutants are small enough to remain suspended in air. It is noted that other exposure pathways have also been assessed for the individual chemical substances bound for these particles. These other pathways relate to the individual chemical substances, rather than the physical size of the particulates.

Cadmium + thallium Inhalation of these pollutants adhered to fine particulates

Ingestion and dermal contact with these pollutants deposited to soil

Ingestion of produce grown in soil potentially impacted by these pollutants (i.e. produce originating from homegrown vegetable gardens, fruit trees, eggs and meat products where potential bioaccumulation can occur)

Mercury

Dioxins & furans

5.3.3 Methodology

5.3.3.1 Modelled Air Impacts Methodology

The modelled air impacts sought to determine the airborne concentration of emissions from the facility. The study area was defined as a 10 km x 10 km area with the proposed facility at the centre. EnRisks used emissions data provided by Energos based on measured representative emissions from comparable facilities in Europe using a similar waste feed stock (i.e. reference facilities) to create a predictive model. From this data the maximum measured emissions have been:

• The EU emission limits for comparable facilities, based on the conditions applied to Energos facilities in Europe; and


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• Emissions at start up based on measured data from two facilities in Norway (as provided by Energos).

Emissions to air were modelled using data provided by Synergetics (2019) using the AEROMOD air dispersion model for all modelled grid receptors, for the maximum predicted 1-hour average, 24-hour average and annual average ground level concentration.

5.3.3.2 Multiple Pathway Exposure Methodology

Multiple pathway exposures occur as a result of dust deposition where the dust contains bound contaminants. Exposure can occur via dermal contact or by incidental ingestion by ingesting fruits, vegetables and foodstuffs grown or raised in the aforementioned study area. To evaluate these pathways accurately a dust deposition rate is required. Dust deposition was not specifically modelled by Synergetics (2019). The California Office of Environmental Health Hazard Assessment (OEHHA) states that a facility where particulate matter control devices are implemented such as a WtE facility; a default deposition rate of 0.02 m/s can be adopted. This deposition rate was utilised in the approach taken by EnRisks to determine multiple pathway exposure rates.

5.3.4 Summary of HHRA Outcomes

Based on the data available EnRiskS was able to determine information presented below in Section 5.3.4.1 in relation to air shed pollution on surrounding receptors from the facility.

5.3.4.1 Inhalation Exposure Risk

Risks to human health associated with acute or chronic exposures are negligible. This includes risks to pollutants presenting as gasses, particulate matter and pollutants bound to particulates. Assessment of acute exposures and risks, and chronic inhalation risks are presented in Table 5-12, Table 5-13 and Table 5-14.

Table 5-12 Review of acute exposures and risks (maximum location anywhere)

POLLUTANTS ACUTE AIR GUIDELINE (1 -HOUR AVERAGE) (mg/m3)

MAXIMUM 1-HOUR AVERAGE CONCENTRATION (mg/m3)

CALCULATED HAZARD INDEX (HI)

Maximum based on emissions from reference plant

NEPM pollutants

Nitrogen dioxide (NO2) 0.221 0.073 0.33

Sulfur dioxide (SO2) 0.51 0.024 0.049

Carbon Monoxide (CO) 301 0.023 0.00078

Other Pollutants

Hydrogen chloride (HCl) 0.662 0.0044 0.0067

Hydrogen fluoride (HF) 0.062 0.00038 0.0064

Ammonia 0.592 0.0092 0.016

Cadmium 0.00542 0.0000038 0.00074

Mercury (as elemental) 0.00063 0.0000038 0.0064

Dioxin 0.000134 3.8x10-11 0.0000003

Total HI (for other pollutants) 0.036

Maximum based on EU limits for emissions

NEPM pollutants




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POLLUTANTS ACUTE AIR GUIDELINE (1 -HOUR AVERAGE) (mg/m3)

MAXIMUM 1-HOUR AVERAGE CONCENTRATION (mg/m3)

CALCULATED HAZARD INDEX (HI)


Other Pollutants



Ammonia 0.592 0.0038 0.0065

Cadmium 0.00542 0.000019 0.0035


Dioxin 0.000134 3.8x10-11 0.0000003


Maximum – Start-up conditions

NEPM pollutants




Other Pollutants



Ammonia 0.592 0.0065 0.011

Cadmium 0.00542 0.0000038 0.00071


Dioxin 0.000134 3.8x10-11 0.0000003


Target (acceptable/negligible HI) ≤1

References for health-based acute air guidelines (1-hour average): 1= NEPM health based guidelines (NEPC 2016) 2= Guideline available for the Texas commission on environmental Quality (TCEQ), https://www.tceq.texas.gov/toxicology/dsd/final.html 3= Guideline available from California Office of Environmental health Hazard Assessment (OEHHA) https://oehha.ca.gov/air/general-info/oehha-acute-8-hour-and-chronic-reference-exposure-level-rel-summary 4= Guideline available from the USEPA as Protective Action Criteria (PAC), where the most conservative value has been adopted https://www.energy.gov/ehss/protective-action-criteria-pac-aegls-erpgs-teels-rev-29-chemicals-concern-may-2016

Table 5-13 Calculated chronic inhalation risks*

https://www.tceq.texas.gov/toxicology/dsd/final.html

https://oehha.ca.gov/air/general-info/oehha-acute-8-hour-and-chronic-reference-exposure-level-rel-summary

https://oehha.ca.gov/air/general-info/oehha-acute-8-hour-and-chronic-reference-exposure-level-rel-summary

https://www.energy.gov/ehss/protective-action-criteria-pac-aegls-erpgs-teels-rev-29-chemicals-concern-may-2016


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POLLUTANTS MAXIMUM ANNUAL

AVERAGE CONCENTRATION (mg/m3)

MAXIMUM CALCULATED HI – RESIDENTIAL EXPOSURES1

MAXIMUM CALCULATED HI – COMMERCIAL/INDUSTRIAL

EXPOSURES2

Maximum based on emissions from reference plant

NEPM pollutants



Carbon Monoxide (CO) 0.00053 0.000053 0.000012

Other Pollutants

Hydrogen chloride (HCL) 0.00010 0.0039 0.00085


Ammonia 0.00021 0.00065 0.00014

Cadmium 0.000000087 0.0081 0.0018


Dioxin 8.7 x 10-13 0.000088 0.000019

Total HI (other pollutants) 0.013 0.0029

Maximum based on EU limits for emissions

NEPM pollutants



Carbon Monoxide (CO)** 0.00087 0.000087 0.000019

Other Pollutants

Hydrogen chloride (HCL) 0.00052 0.020 0.0044


Ammonia 0.000087 0.00027 0.000059

Cadmium 0.00000043 0.041 0.0089


Dioxin 8.7 x 10-13 0.000088 0.000019

Total HI (for other pollutants) 0.062 0.014

Negligible risk ≤1 ≤1

*refer to Appendix B of EnRisks Health Risk Assessment for the equations adopted, and appendix D for the calculations **calculations based on an 8-hour average concentration guideline 1 residential inhalation exposures calculated on the basis of exposures that occur at the same location 24 hours per day, 265 days per year for 35 years 2 commercial/industrial inhalation exposures calculated on the basis of exposures that occur at the same location 8 hours per day, 240 days per year for 30 years

Table 5-14 Calculated chronic inhalation risks for selected receptors*


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RECEPTOR AND NATURE OF EXPOSURE (RESIDENTIAL OR COMMERCIAL)

CALCULATED HI (OTHER POLLUTANTS)

Reference plant emissions

EU limit emissions

Receptor 1 – Recreational** 0.0012 0.0058

Receptor 2 – Residential 0.0010 0.0046

Receptor 3 – Workplace 0.00054 0.0026



Receptor 6 – Residential 0.0015 0.0069


Negligible risk ≤1 ≤1

*Refer to Appendix B of EnRisks Health Risk Assessment for the equations adopted, Appendix D for the calculations **HI presented based on workplace exposures, which are inhalation exposure for 8 hours per day for 240 days per week, which is highly conservative for recreational use of this area, but protective of exposures for workers in premises located adjacent to the reserve

5.3.4.2 Multiple pathway exposures:

Risks to human health associated with chronic exposures to pollutants, bound to particulates are negligible. The sum of risks associated with multiple exposures is presented in Table 5-15 and Table 5-16.

Table 5-15 Summary of risks for multiple pathway exposures – rural residential areas (represented by receptor 2)

EXPOSURE PATHWAY

CALCULATED HI – REFERENCE PLANT EMISSIONS CALCULATED HI- EU LIMIT EMISSIONS

Adults Children Adults Children

Individual exposure pathways

Inhalation (I) 0.00098 0.00098 0.0046 0.0046

Soil ingestion (SI) 0.000099 0.00092 0.00040 0.0037

Soil dermal contact (SD) 0.000078 0.00016 0.00020 0.00041

Ingestion of homegrown fruit and vegetables (F&V) 0.00022 0.00049 0.0010 0.0021

Ingestion of homegrown eggs (E) 0.000025 0.000050 0.000031 0.000063

Ingestion of homegrown beef (B) 0.00084 0.0021 0.00085 0.0021

Ingestion of homegrown milk (M) 0.0015 0.0060 0.0022 0.0087

Multiple pathways (I.e. combined exposure pathways)

I + SI + SD 0.0012 0.0021 0.0052 0.0087

I + SI + SD + F&V 0.0014 0.0025 0.0062 0.011


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EXPOSURE PATHWAY



I + SI + SD + E 0.0012 0.0021 0.0052 0.0088

I + SI + SD + F&V + E 0.0014 0.0026 0.0062 0.011

I + SI + SD + B 0.0020 0.0041 0.0060 0.011

I + SI + SD + M 0.0027 0.0081 0.0074 0.017

I + SI + SD + F&V + E + B + M 0.0038 0.011 0.0093 0.022

Negligible risk ≤1 ≤1 ≤1 ≤1

Refer to appendix D of EnRisks Health Risk Assessment for detailed risk calculations for each exposure pathway

Table 5-16 Summary of risks for multiple pathway exposures – residential area of Somerfield Estate (represented by receptor 6)

EXPOSURE PATHWAY



Individual exposure pathways

Inhalation (I) 0.0015 0.0015 0.0069 0.0069

Soil ingestion (SI) 0.00015 0.0014 0.00060 0.0056

Soil dermal contact (SD) 0.00012 0.00023 0.00031 0.00061

Ingestion of homegrown fruit and vegetables (F&V) 0.00033 0.00074 0.0015 0.0032

Ingestion of homegrown eggs (E) 0.000038 0.00075 0.000047 0.000094

Multiple pathways (I.e. combined exposure pathways)

I + SI + SD 0.0017 0.0031 0.0078 0.013

I + SI + SD + F&V 0.0021 0.0038 0.0093 0.016

I + SI + SD + E 0.0018 0.0032 0.0078 0.013

I + SI + SD + F&V + E 0.0021 0.0039 0.0094 0.016

Negligible risk ≤1 ≤1 ≤1 ≤1

Refer to appendix D of EnRisks Health Risk Assessment for detailed risk calculations for each exposure pathway

5.3.5 Conclusion

The results of the HHRA represents a hypothetical scenario based on emission characteristics from data relating to similar European facilities using a comparable feedstock. It is noted that the results from the dispersion modelling are conservative and were modelled using the highest reported (average) values.


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The approach taken to quantify multiple pathway exposures has overestimated actual exposures and risks. Changes to the assumptions used in creating this quantitative model will result in lower levels of risk rather than higher levels of risk.

Based on the results and modelled data as it relates to receptors and exposure pathways identified in the CSM, the following is concluded:

• Inhalation exposures: risks to human health associated with acuate or chronic exposures are negligible • Multiple pathway exposures: risks to human health associated with chronic exposures to pollutants, bound to

particulates, that may deposit to surface and taken up into homegrown produce relevant to surrounding areas where rural residential and low density estates are present, are negligible.

Noise Emissions Activities and equipment associated with the facility would also result in potential noise emissions. This section details how the facility complies with the of State Environment Protection Policy (Control of Noise from Commerce, Industry and Trade) No. N-1 (SEPP N-1).

5.4.1 Detailed Noise Impact Assessment

A detailed noise impact assessment was undertaken by Watson Moss Growcott Acoustics (WMG). The assessment is provided in Appendix G and summarised in the sections below.

5.4.1.1 Determining Ambient Background Levels

The site is located within the Dandenong South industrial precinct and abuts Ordish Road to the east, existing industrial land to the north and south and the Eastlink toll road to the west. The surrounding area is occupied by industrial land, used for industrial purposes. The closest potential noise sensitive receptors are located over 800m to west of the facility, across the Eastlink toll road and a number of industrial buildings. The relevant noise sensitive receptors are provided in Table 5-17.

Table 5-17 Summary of Relevant Noise Sensitive Receptors

RESIDENTIAL ADDRESS

LAND ZONING WHERE DWELLING IS CONSTRUCTED

DIRECTION FROM SITE DISTANCE FROM SUBJECT SITE BOUNDARY

239 Perry Rd IN1Z (Industrial) NW 830 metres

245-251 Perry Rd IN1Z (Industrial) W 600 metres

270 Perry Rd GWAZ (Green Wedge) W 815 metres

280 Perry Rd GWAZ (Green Wedge) SW 820 metres

7 Keys Rd GWAZ (Green Wedge) SW 880 metres

24 Keys Rd GWAZ (Green Wedge) SW 950 metres

Noise limit calculations were conducted in accordance with SEPP N-1 methodology, by considering the land zoning surrounding the relevant noise sensitive receptors and the existing ambient background noise levels which the noise sensitive receptors are exposed.

WMG undertook noise monitoring at locations representative of the relevant residential receptors, which was carried out in 2017 across six (6) attended locations and one (1) unattended location during the following dates and times: • Attended noise level survey between 6:00pm and 7:00pm on Friday 17th March 2017 • Attended noise level survey between 4:30pm and 6:00pm on Monday 20th March 2017 • Attended noise level survey between 11:00pm and 12:00am on Monday 20th March 2017 • Unattended monitoring during the period Monday 20th March to Monday 27th March 2017.

Noise level measurements locations are provided in Figure 5-1.

During the attended surveys, the attending engineer observed light breezes blowing from a southerly direction in parallel with the Eastlink toll road located to the east of the residential receptors. The findings of the day time


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attended survey periods identified that ambient noise emissions from locations near Perry Road and Keys Road were mainly from localised traffic movements. The findings of the evening and night time periods identified ambient noise levels were mainly comprised of distant vehicle movements along the Eastlink toll road located to the east of the residential receptors.

Noise level values were recorded during varying breeze conditions during the unattended noise logging period.

WMG undertook further noise monitoring events in 2019, to determine if any of the newly constructed buildings erected between the residential receptors and the facility have impacted the ambient background noise levels.

The 2019 monitoring period was conducted at locations 1, 4, 5 and 6 during the following dates and times:

• Attended noise level survey between 2:00pm to 5:00pm on Wednesday 20th March 2019 • Attended noise level survey between 12:30am and 1:30am on Thursday 21st March 2019 • Location 3 was not monitored as the new construction works has made this location redundant.

The results of the 2019 monitoring event confirmed breeze conditions to be light and occurring from a southerly direction, as per 2017 conditions. The findings of the day time attended survey periods identified locations near Perry Road and Keys Road were mainly localised traffic movements, as per the 2017 findings. The findings of the evening and night time periods identified ambient noise levels were mainly comprised of distant vehicle movements along the Eastlink toll road located to the east of the residential receptors, as per the 2017 findings. Additionally, noise sources (tonal beepers and occasional ‘bangs’ which sounded like materials being dropped) from the industrial uses located to the east of the Eastlink toll road were also observed to be audible on occasions.

Figure 5-1 Noise Measurement Locations (WMG, 2019)


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The adopted ambient background levels at each of the relevant residential receptors are presented in Table 5-18. The adopted ambient background levels have been based on a worst-case scenario in which light breezes assist the propagation of noise from the facility in the direction of the relevant residential receptors.

Table 5-18 Adopted Ambient Background Noise Levels

NOISE SENSITIVE RECEPTOR ADOPTED AMBIENT BACKGROUND NOISE LEVELS

Day Period Evening Period Night Period

239 Perry Rd 48 dB(A) Leq 43 dB(A) Leq 40 dB(A) Leq

245-251 Perry Rd 48 dB(A) Leq 43 dB(A) Leq 40 dB(A) Leq




7 Keys Rd 46 dB(A) Leq 41 dB(A) Leq 38 dB(A) Leq


Residential Dwellings Setback from Perry Rd by 200-500m

Within SEPP N-1 Neutral Range



5.4.1.2 Noise Emission Sources

Activities associated with the Facility will generate noise emissions from equipment such as large fans, generators, turbines, as well as truck movements.

The site layout consists of hardstand areas, the main building and an independent turbine room (refer to Figure 4-1) The main building will be composed of the following main functional areas:

• Waste delivery area (inclusive of waste bunker and fuel bunker) • Technical room • Main Building.

Noise sources associated with the facility will be located internally within either the main building or turbine room, as well as external to the buildings in designated hardstand areas and above the roof of the facility buildings. A summary of the equipment that will be used on-site within each building or area is provided in Table 5-19.

Table 5-19 Site Noise Emission Source Summary

BUILDING DESIGNATION RELEVANT NOISE SOURCES PROVIDED BY CLIENT

Waste Receival Building − Shredder

− Power Pack (shredder)

Technical Room − Hydraulic Skid (Furnace)

− Thermal Oil Skid

− Cooling Medium Pump

− Feed Water Pumps

Main Building − 4 x Purge Air Fan

− 2 x Flue Gas Fan

− 4 x Reticulated Flue Gas Fan

− 14 x Combustion Air Fan

Turbine Building − Turbine

− Generator

External. − Stack


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BUILDING DESIGNATION RELEVANT NOISE SOURCES PROVIDED BY CLIENT

− Filter Dust Silo Cleaning

− Ventilation Fan

− Flue Gas Filter Cleaning

− Air Cooled Heat Exchanger (ACHE)

− Air Cooled Condenser (ACC)

− Steam Silencer

− Air Cooler Heat Exchanger (ACHE) - turbine building

− Truck driving and reversing on site

Base Building − Generator

− Power Transformer

Sound power level information is provided in Appendix 10.1 of the WMG report (refer to Appendix G of this report). The power level information is based on equipment used previously at similar sites. This information should be treated as indicative and may be different for the proposed site due to ducting, design solutions and plant layout.

The site will operate 24 hours per day, seven days per week. Waste and delivery truck movements will likely occur between 9am to 3pm, Monday to Friday, with occasional truck deliveries potentially occurring outside of the indicated hours.

Trucks will enter/exit the site from Ordish Road in a forward direction via an internal access road. During peak periods of waste disposal, it is understood that truck movements on the site will be in the order of 16 vehicles per 30-minute period.

To complete waste disposal and deliveries, trucks will likely undertake the following:

• Travel at low speeds of 5-10 km/h • Perform a reversing manoeuvre to prop into required positions using reverse beepers • Rev vehicle engines when elevating trays to dump waste • Idle in position whilst waiting.

5.4.1.3 Best practice noise control measures

WMG provided noise control strategies to satisfy Clause 19 of SEPP N-1, which states ‘‘where equipment is to be replaced or new equipment installed, the quietest equipment available should be used where a significant noise reduction in sensitive areas can be expected to occur’’.

The noise control strategies are as follows:

Mobile Equipment Reversing Beepers

‘New generation’ broadband reverse alarms, which vary their noise output according to the ambient noise level, will be fitted to any vehicle which is permanently located or forms day-to-day operations at the facility.

The new generation reversing alarms must not include a tonal character and should be set to the lowest noise level allowing safe operation.

Cooling Tower Fan Speed Operation

To mitigate the predicted noise results, the large ACC fans located adjacent to the site’s western boundary may be fitted with Variable Speed Drives (VSD) to operate at 66 per cent between the EPA-defined night period of 10:00pm and 7:00am. However, the need for VSD or other engineering options to mitigate predicted noise will be reviewed during the detailed design phase of the project.

Building Construction

Based on the noise level calculations, building structures can be constructed using 0.42mm COLORBOND® steel cladding and achieve the relevant design objectives for the project.

External Façade Openable Sections and Ventilation Openings


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All external façade openable sections (e.g. roller doors) of the overall base building and turbine building are to be closed during the EPA-defined night period of 10:00pm and 7:00am. The waste receival openable sections may remain open at all times, although it is noted that rapid open/close roller doors will be installed on waste receival bays and normally closed.

It is unlikely that any small ventilation openings in the external facades of the base building will require specific attenuation. If the detailed design phase identifies small ventilation openings require attenuation, treatments would likely include acoustically lined steel ductwork sections or acoustic louvres.

Sound Absorption to Internal Surfaces

It is anticipated that noise levels within the base building and turbine room would be amplified by the acoustically reflective wall, roof and floor surfaces, should these structures not include sound absorbing materials.

It is expected that the building structures may require conventional sisalation and insulation installed to the underside of the roof structures of each of the buildings to assist thermal comfort.

With non-perforated sisalation surfaces the insulation treatments will not assist with providing sound absorption within each of the relevant base building and turbine building spaces.

Sound absorbing surfaces is required to mitigate the noise levels generated by the shredder unit within the waste receival building. Suitable materials will include 50-100mm thick x 32kg/m3 fibreglass fibrous insulation faced with perforated sisalation or perforated metal. The materials will be installed to a minimum 80 per cent of the roof area of the space.

The requirement for sound absorbing materials for all of the relevant base building and turbine building roof surfaces will be assessed during the detailed design phase.

As mentioned in Section 5.4.1.2, the sound power level information should be treated as indicative. Should alternate equipment, initiatives or provisions be incorporated within the development, the noise control measures provided would require amendment at the approval of a qualified acoustic consultant.

5.4.1.4 Noise Impact Assessment

The calculated SEPP N-1 noise limits relevant to the noise sensitive receptor is identified in Table 5-20.

Table 5-20 SEPP N-1 Limits

NOISE SENSITIVE RECEPTOR ADOPTED AMBIENT BACKGROUND NOISE LEVELS Day Period Evening Period Night Period








50 dB(A) Leq 44 dB(A) Leq 39 dB(A) Leq

As per the “SEPP N–1 and NIRV Explanatory Notes” (EPA publication 1412, October 2011), WMG calculated the design objective values which consider noise from existing or anticipated future industry for the acoustic assessment periods at each of the relevant residential receptors.

Adopted design objective noise levels for relevant residential receptors are presented in Table 5-21. These values are based on the SEPP N-1 noise limits minus 5 dB(A).


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Table 5-21 Adopted Design Objective Values for the Acoustic Assessment.

NOISE SENSITIVE RECEPTOR ADOPTED AMBIENT BACKGROUND NOISE LEVELS Day Period Evening Period Night Period








45 dB(A) Leq 39 dB(A) Leq 34 dB(A) Leq

Noise emission modelling was conducted using DataKustik CadnaA 2018 environmental noise modelling software. The parameters considered included geometrical spreading; atmospheric absorption; ground attenuation; meteorological effects; source/receiver height effects; and barrier attenuation due to the surrounding environment including existing buildings/structures.

The predicted noise emissions associated with the subject site considered at each of the off-site noise sensitive receptor locations is provided in Table 5-22, Table 5-23 and Table 5-24.

Table 5-22 Predicted Noise Levels at Receptors Located to the East of Perry Rd

NOISE SENSITIVE RECEPTOR PREDICTED NOISE LEVEL DURING RELEVANT ASSESSMENT PERIOD Day Period Evening Period Night Period

239 Perry Rd 31 dB(A) Leq (30-minute) 31 dB(A) Leq (30-minute) 31 dB(A) Leq (30-minute)

245-251 Perry Rd 33 dB(A) Leq (30-minute) 33 dB(A) Leq (30-minute) 33 dB(A) Leq (30-minute)

SEPP N-1 Noise Limits 60 dB(A) Leq (30-minute) 53 dB(A) Leq (30-minute) 49 dB(A) Leq (30-minute)

Compliance with SEPP N-1 Noise Limits at existing dwellings ✔ ✔ ✔

Project Design Objectives 55 dB(A) Leq (30-minute) 48 dB(A) Leq (30-minute) 44 dB(A) Leq (30-minute)

Compliance with Project Design Objectives at existing dwellings ✔ ✔ ✔

Table 5-23 Predicted Noise Levels at Receptor Located to the West of Perry Rd (within approximately 200m of Perry Rd)




7 Keys Rd 31 dB(A) Leq (30-minute) 31 dB(A) Leq (30-minute) 31 dB(A) Leq (30-minute)

24 Keys Rd 31 dB(A) Leq (30-minute) 31 dB(A) Leq (30-minute) 31 dB(A) Leq (30-minute)


Compliance with SEPP N-1 Noise Limits at existing dwellings

✔ ✔ ✔


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Compliance with Project Design Objectives at existing dwellings

✔ ✔ ✔

Table 5-24 Predicted Noise Levels at Receptor Located to the West of Perry Rd (Greater than 200m setback west of Perry Rd)


Residential Dwellings Setback from Perry Rd by 200-500m <30 dB(A) Leq (30-minute) <30 dB(A) Leq (30-minute) <30 dB(A) Leq (30-minute)


Compliance with SEPP N-1 Noise Limits at existing dwellings

✔ ✔ ✔


Compliance with Project Design Objectives at existing dwellings

✔ ✔ ✔

Based on the results of the predicted noise levels provided in Table 5-22, Table 5-23 and Table 5-24, the operation of the facility will comply with the relevant SEPP N-1 noise limits and the proposed design objectives for each of the identified noise sensitive receptors. Compliance with the noise limits and design objectives is reliant on the mitigation measures presented in Section 5.4.1.3.

Water 5.5.1 Water Use

The facility will source potable water from Melbourne Water which is predominantly required for wash-down and cooling purposes as well as onsite domestic uses.

The facility will consume an average of 0.6kL/hour of potable water, equating to approximately 14kL/day for 24-hour operation. The actual water consumption depends on the operating mode of the plant. The maximum potable water consumption with the turbine and ACC not in operation is 31.25 kL/hour. The expected annual water usage is approximately 5 ML/yr.

The process is designed to reduce potable water consumption through the use of dry flue-gas cleaning and by allowing for internal process water treatment and reuse within the facility. The first fill involves filling of the process water tanks with potable water at a nominal maximum flow rate of 31.25kL/hour, which is used directly by the wash-down hoses in the waste receival hall, furnace cooling and the cooling water system.

Potable water is then treated to achieve boiler feed water quality using Reverse Osmosis (RO) which is sized at 25kL/hour, with a total water capacity for two lines of 120kL, and is conveyed to the 60kL boiler feed water tank for storage.

A 60kL boiler drain tank allows drainage of the boiler during planned maintenance stop periods preventing discharge. On commencement of boiler operation, the operator may return the recovered boiler water to the boiler or return it to the feed water tank without treatment.

Recovered water is reused for ash-quench water make-up, consisting of the following sources:

• Boiler blow down • RO retentate • Ash bunker run-off


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• Overflow from process water tank, feed water buffer tank and boiler drain tank.

The majority of process water will be recovered for onsite reuse. A small amount of effluent generated from bottom ash, boiler water and blow down water will be stored in a below ground effluent sump with a holding volume of 1 kL to facilitate a route out of the plant for potential effluent overflow. An external tanker connection point will be provided to facilitate offsite disposal of any effluent stream. The need for connection to sewer and disposal via a Trade Waste Agreement will be further assessed during the detailed design phase.

Generation of leachate is not anticipated from the waste stored at the facility, due to the short retention time (less than 4 days).

5.5.2 Stormwater Management

5.5.2.1 Existing

The regional topography based on Nearmap (2018) elevation data indicates the site is gently sloping towards the south-west, towards Dandenong Creek. Dandenong Creek flows in a southerly direction towards the outfall located at Carrum. A Land Subject to Inundation Overlay (LSIO) under the Greater Dandenong Council planning provision occurs approximately 50 m to the west of the site, however the site is not subject to any flooding overlays. This indicates there is a preferential pathway for surface water runoff west of the site.

Figure 5-2 Existing Site Drainage (extract from existing conditions survey [SMEC, February 2018])

The site currently has an average slope of <1 per cent towards Ordish Road to the east as show in Figure 5-2. Stormwater is conveyed to the stormwater pipes on the eastern side of Ordish Road, which discharges to Dandenong Creek.

Currently approximately 15 per cent of the site, or 1,900 m2 consists of buildings. The remainder of the site is predominantly gravel, with a small hardstand area for parking along the eastern boundary of the site.

5.5.2.2 Proposed

The proposed layout the buildings will cover approximately 3,807 m2, or 30 per cent of the total site area. Rainwater tanks will be installed to capture runoff from the main building rooftop, with an approximate roof area of 3,807 m2. Stormwater runoff will discharge from the remainder of the site. The site will consist of hard pavement surrounding the buildings, with a small area of vegetation in the north-eastern corner of the site.

Potential for Contamination

Runoff from outdoor areas frequently trafficked by vehicles will be discharged offsite. There is very low potential for this runoff to be contaminated by suspended solids, hydrocarbons, vehicle oil and grease, at a rate similar to the nearby roadways. There is to be no contamination of runoff with leachate or process water, as an indoor bunded area will be utilised for the unloading of waste trucks.

Collection and Containment

Runoff from processing and vehicle washdown areas will be contained within an enclosed building. Bunding of the vehicle wash areas will be installed in accordance with EPA Publication 347.1 Bunding to segregate contaminated water from uncontaminated stormwater runoff.


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Stormwater runoff from outdoor impervious areas will be diverted towards a discharge point at the south-east corner of the site based on localised topography mapping. The stormwater runoff will be conveyed to the Melbourne Water stormwater drains located on the eastern side of Ordish Road.

Treatment

Process water and leachate will not be discharged to stormwater. Given the payment of the drainage scheme contribution, runoff from paved areas does not require treatment prior to discharge. Refer to Appendix H for further details regarding the drainage scheme contribution.

Flood Retention

As a result of the development there will be a minor increase in the runoff, correlating to the increase in impervious area. As the site sits within a drainage scheme the hydraulic offset will be required to be paid, with the flows being retarded offsite.

The Stormwater Management Plan (SMEC 2018b) is presented in Appendix H.

5.5.3 Drainage and Wastewater

A drainage and wastewater concept design for on-site stormwater and wastewater management has been prepared, as summarised below.

Existing conditions

Survey data and contour information indicate that the site drains in a south-easterly direction from 10.03 mAHD to 8.76mAHD RL. Dial Before You Dig (DBYD) documentation indicated a 300mm PVC drain and a 375mm PVC sewer main to the east of the site, both running south along Ordish Road. Existing junction pits within the vicinity of the site boundary were also noted.

Drainage information including layout and longitudinal plans were obtained from the Melbourne Water Ordish Road North Drainage Scheme and existing reticulation sewer information was based on the South East Water GIS. Alignments and pipe sizes of council drains along Ordish Road were available however invert level information was not available. There are no external catchments draining through the site. Invert levels of the stormwater drains are to be confirmed at the detailed design phase.

Design Methodology

SMEC developed a Stormwater Management Plan for the facility in April 2019. Water sensitive urban design options such as swales were considered for stormwater connection. However, given space constraints at the site and potential sediment build-up due to the industrial land type, this option was deemed unsuitable. The study concluded that it is not suitable to include onsite detention or stormwater treatment. Based on this, an underground drainage system is proposed for the site.

The stormwater conveyance system was sized to accommodate for a 1-in-20 year AEP flow (for industrial sites), based on the Melbourne Water Hydrologic and Hydraulic design guidelines. Flows from the site were estimated using the rational method as per the new Australian Rainfall and Runoff Guidelines, 2016. The layout of the stormwater drain and capture devices are shown in Figure 1.

The sewer design (should it be required) was based on the following approach: 1. Wastewater is to be discharged into the nearby existing sewer network owned by South East Water. 2. It is assumed wastewater is to be treated within the site to a discharge standard acceptable by South East

Water. 3. A formal deed application for the proposed connection works shall be applied to South East Water. 4. The sewer levels are to be determined based on the downstream connection level at the reticulation

network. Free gravity discharge in the sewer line is assumed in the design. No pumping is required. 5. UPVC-DWV pipe material is specified for cost and durability purpose. 6. Inspection shaft at the end of the sewer line is to be provided for inspection and rodding.

Design Specifications

Both stormwater and sewer connections are to be located on the southern boundary of the site. A layout of both systems (should connection for trade waste disposal be required) is presented in Figure 1.

Drainage design specifications have been summarised below:


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• Stormwater connection will comprise of a 300mm diameter RRJ RCP piping to the southern boundary of the site • Standard trench pits are to be accommodated in each carpark as well as grated pits adjacent to downpipes on

the southern boundary • The location of the legal point of discharge (LPOD) is assumed to be the existing SEP in front of the site.

Attempts were made to contact Council, however this assumption shall be confirmed with Council during detailed design.

Sewer design specifications include the following (requirement for sewer connection to be further assessed during detailed design phase):

• The wastewater from the site would be discharged into the existing DN375 across Ordish Road. According to the South East Water GIS, the invert level of the existing property connection is +11.495mAHD. This level is fixed and forms a site constraint to the sewer design

• The sewer line within the site is proposed to be located with 1.2m offset from the site boundary. This meets the current MRWA offset requirements for the property connection and allows for space for construction, operations and maintenance of the sewer. A grade of 1:80 of the sewer is specified to allow for proper gravity discharge of sewage from the facility

• The sewer is DN150 in size and the material class is UPVC-DWV Sch 10 • The exact points of sewage outlet from the development are to be determined. At this stage, a total of 4 nos. of

long radius y-tee stubs are reserved to pick up the connections • At the far upstream end of the sewer, an inspection shaft is provided to allow for inspection and rodding of the

sewer, if required in future.

Land and Groundwater As stated in Section 11 of EPA Victoria Publication 1658 (June 2017) ‘Works Approval Application’ a land and groundwater impact assessment is required when the proposed works involve any of the following:

• Underground storage of petroleum • Pipeline transfer of petroleum • Groundwater extraction • Injection of waste to groundwater.

The proposed development does not involve any of the above listed activities and no land and groundwater impact assessment was deemed necessary.

However, as the site has a long history of industrial use a Preliminary Site Investigation (PSI) (SMEC, 2018a) was conducted to determine the likelihood of land and groundwater contamination existing at the site. The PSI report is presented in Appendix C.

Based on the findings of the PSI, SMEC made the following recommendations:

• Conduct a scan of the site with Ground Penetrating Radar to ensure all underground infrastructure is identified and potential underground sources of contamination (Underground Storage Tanks etc.) are identified prior to commencing earthworks at the site

• Conduct soil sampling and analysis for Acid Sulfate Soil as the probability of occurrence of Acid Sulfate Soil was deemed ‘High’

• A NEPM-compliant Detailed Site Investigation (DSI) should be conducted to further examine potential contaminants of concern and ensure the protection of the site beneficial uses. If soil contamination is found to exist and is not able to be delineated, an investigation of groundwater contamination should be included within the DSI.

A Detailed Site Investigation (DSI) was conducted by Environmental & Safety Professionals (ESP) in August 2018. The DSI included a soil and groundwater assessment, with objectives to provide an assessment of site contamination and establish a site contamination status baseline prior to site development. ESP (2018) concluded:

• Results of soil sample analysis did not indicate exceedances of the adopted ecological criteria, except for at one location which was delineated, suggesting an isolated occurrence rather than a site-specific issue


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• No exceedance of the adopted human health criteria were reported, indicating the soils at the site would be suitable for the proposed industrial land use

• Results of groundwater sampling identified several analytes in excess of adopted investigation levels and therefore if groundwater is to be extracted from the site advice should be sought from a suitably qualified person to ensure it is suitable for its intended use.

The findings of the DSI indicate that the site is suitable for the proposed industrial land use, noting that no groundwater extraction is intended. The DSI will be used to inform development of the CEMP, including storage and handling of potential contaminated soils.

Waste The primary instrument for the regulation of waste in Victoria is the EP Act.

‘Industrial Waste’ is defined under the EP Act as:

• Any waste arising from commercial, industrial or trade activities or from laboratories • Any waste containing substances or materials which are potentially harmful to human beings or equipment.

Municipal waste is defined under the EP Act as:

• Any waste arising from municipal or residential activities, and includes waste collected by, or on behalf of, a municipal council, but does not include any industrial waste.

The EPA publication Industrial Waste Resource Guideline IWRG600.2 (Waste Categorisation) states that Prescribed Industrial Wastes (PIWs):

• Have the potential to adversely impact human health and the environment. They may either be from a manufacturing source or be contaminated soils.

5.7.1 Industrial Waste Generation

Approximately 20 per cent and three per cent of the waste input will require disposal as bottom ash or fly ash, respectively, which equates to approximately 23,000 tonnes per year. At this stage the intention is to dispose of the fly/bottom ash to landfill, however there are alternative reuse options, such as in cement, and civil engineering applications such as aggregates and roadbases. Assessment of potential reuse options is ongoing; however, this proposal assumes disposal to landfill for fly ash and bottom ash.

The facility will generate a number of residues as part of routine operation. The residues generated will fall within two broad categories:

• Bottom ash (also known as grate ash): this is the solid residue removed from the combustion chamber after the waste has been combusted

• Fly ash: this comprises boiler ash, the part of the fly ash that is removed from the boiler; and Air Pollution Control (APC) residues (also known as Flue Gas Treatment (FGT) residues) from the APC equipment.

It is expected that bottom ash will likely be categorised as ‘non-prescribed industrial waste’, while fly ash will likely be categorised as either ‘Category B PIW’ or ‘Category C PIW’, with the potential for some of the heavy metal species to exceed thresholds for Category A.

Table 5-25 provides an overview of the facility waste streams that will be generated with their anticipated waste categorisations.

Table 5-25: Operational residues generated by the facility

WASTE STREAM ANTICIPATED CATEGORY VOLUME GENERATED

Fly Ash (incl. APC residues and boiler ash) Category C or B PIW Approx.4,000-6,000 t/yr

Bottom Ash Non-Prescribed Industrial Waste Approx. 15,000-20,000 t/yr

5.7.2 Bottom Ash and Fly Ash Characteristics

Both bottom ash and fly ash are solid industrial wastes as defined by the EPA Industrial Waste Resource Guidelines Solid Industrial Waste Hazard Categorisation and Management (IWRG631). Both types of ash have significant


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potential as a reusable product. The potential of future reuse is reliant on the key characteristics of the waste from an engineering perspective, the chemical properties, including leachability of chemicals of concern (CoC) and the market demand.

5.7.2.1 Fly Ash

Fly ash is identified as the material which is captured beyond the oxidation chamber and satisfies all solid matter criteria which is not considered liquid or steam. Fly ash is typically a grey fine powder with a particle size of 0.3 to 250 µm. Fly ash is not combustible but does pose handling risks due to its corrosive nature when wet or ingested. A typical Material Safety Data Sheet (MSDS) for fly ash is presented in Appendix S. The typical chemical characteristics of fly ash are presented in Table 5-26 and Appendix S, with analysis of data obtained from the Isle of Wight WtE facility in 2011. This plant was utilising Energos technology in the conversion of the MSW to power. In comparing the laboratory analysis to the Industrial Waste Guidelines, the ash would be typical classified as Category B Industrial Waste. It is anticipated that the fly ash from the proposed facility will exhibit similar characteristics to this representative sample. This fly ash is typical of what is used as mineral addition in the production of Portland Cement.

Table 5-26 Fly Ash Chemical Composition (MSS, 2011)

PARAMETERS CONCENTRATION ELUATE LEACHED CONTAMINATE CONCENTRATION

THRESHHOLDS

Liquid: Waste Ratio 2:1 8:1 2:1 10:1 Industrial Waste Upper Limits

pH 9.6 10.2

Temperature © 20.0 20.0 ASLP0 TC0

Conductivity (uS/cm) 7760.0 2340.0

mg/L mg/L mg/kg mg/kg mg/L mg/kg

Arsenic <0.001 <0.001 <0.002 <0.01 0.35 500

Barium3 0.1 0.1 0.2 0.2 35.0 6250

Cadmium <0.001 <0.001 <0.002 <0.01 0.1 100

Chromium (VI) 9.8 3.9 19.6 18.5 2.5 500

Copper 0.0 0.0 <0.04 <0.08 100 5000

Mercury <0.001 <0.001 <0.002 <0.01 0.05 75

Molybdenum 0.2 0.0 0.3 0.3 2.5 1000

Nickel <0.003 <0.003 <0.006 <0.03 1 3000

Lead <0.009 <0.009 <0.018 <0.09 0.5 1500

Antimony <0.003 <0.003 <0.006 <0.03 1.0 75

Selenium <0.003 <0.003 <0.006 <0.03 0.5 50

Zinc <0.02 <0.02 <0.04 <0.2 150 3500

Chloride 11215 1315 22430 21670 12500 NA

Fluoride 0.3 0.2 0.5 0.9 75 10000

Sulphate 2189 1175 4378 4007 NA NA

Total Dissolved Solids 7122 2250 14244 17234 NA NA

Phenol Index 21.9 6.7 43.8 41.3 NA NA

Dissolved Organic Carbon 34.8 12.8 69.6 73.8 NA NA

5.7.2.2 Bottom Ash

The bottom ash is a clinker type product which is ejected from the gasification chamber once full conversion of available calorific value product has occurred. Its composition is typical of products which are not gasified or completely destructed during the greater than 850˚C temperatures encountered during the oxidation process. The physical appearance of the product is an irregular sized and shaped slag ranging in particle size of < 1 mm up to 120 mm. The slag or clinker (interchangeable) is grainy in nature dominated with silica/glass fusion by-products, molten and subsequent solidified metals, some thermally resistant metals, ceramics and other inert substances. Its specific


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gravity is typically greater than that of fly ash which is less than 1 at greater than 1.3. The Forus Stavanger plant in Norway utilising Energos technology provided a 20 kg random sample from the discharge belt, typically product which was feed stock 1 hour earlier. This facility has a similar feedstock specification (80 per cent MSW and 20 per cent C&I) to the proposed facility. It was noted on the day of sampling the receipt hall was fed by side lift MSW collection vehicles. The 20 kg sample was transported back to Australia and analysed, with the analysis presented in Table 5-27. The laboratory report is presented in Appendix T.

Analysis of the Forus bottom ash sample (ALS, 2019) indicates the material would be classified as ‘industrial waste’, pending leachability analysis and further characterisation in accordance Industrial Waste Resources Guidelines. It is anticipated that further investigations into classification of the bottom ash will be ongoing and any beneficial reuse of the bottom ash (and fly ash) will be subject to further assessment to confirm that it is suitable for the intended purpose.

Table 5-27 Bottom Ash Analysis (ALS, 2019)

GROUP PARAMETER

INDUSTRIAL WASTE CATEGORY C CATEGORY B SAMPLE (WS1) ASLP0 TC0 ASLP1 TC1 ASLP2 TC2

(mg/L) (mg/kg) (mg/L) (mg/kg) (mg/L) (mg/kg) (mg/kg)

Inorganic species

Antimony 1 75 2 75 8 300 9.8

Arsenic 0.35 500 0.70 500 2.80 2000 <1.0

Barium 35 6250 70 6250 280 25000 9

Beryllium 0.50 100 1 100 4 400 7

Boron 15 15000 30 15000 120 60000 500

Cadmium 0.1 100 0.2 100 0.80 400.00 <1

Chromium (VI) 2.5 500 5 500 20 2000 60

Copper 100 5000 200 5000 800 20000 <1

Lead 0.5 1500 1 1500 4 6000 621

Mercury 0.05 75 0.1 75 0.4 300 83

Molybdenum 2.5 100 5 1000 20 4000 <2

Nickel 1 3000 2 3000 8.00 12000 19

Selenium 0.5 50 1 50 4 200 <5

Silver 5 180 10 180 40 720 <2

Tributyltin oxide 0.05 2.5 0.1 2.5 0.4 10 14

Zinc 150 35000 300 35000 1200 140000 236

Anions

Chloride 12500 N/A 25000 N/A N/A N/A 19

Cyanide (amenable) 1.75 1250 3.5 1250 14 5000 <1

Cyanide (total) 4 2500 8 2500 32 10000 <1

Fluoride 75 10000 150 10000 600 40000 510

Iodide 5 N/A 10 N/A 40 N/A <0.5

Nitrate 2500 N/A 5000 N/A 20000 N/A <0.01

Nitrite 150 N/A 300 N/A 1200 N/A <0.01

Organic species

Benzene 0.05 4 0.1 4 0.4 16 <0.2

Benzo(a)pyrene 0.0005 5 0.001 5 0.004 20 <0.5 C6-C9 petroleum hydrocarbons6 N/A 325 N/A 650 N/A 2600 <10

C10-C36 petroleum hydrocarbons6 N/A 5000 N/A 10000 N/A 40000 <50


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GROUP PARAMETER



Carbon tetrachloride 0.15 12 0.3 12 1.2 48 <0.01

Chlorobenzene 15 1200 30 1200 120 4800 <0.02

Chloroform 3 240 6 240 24 960 <0.02

2 Chlorophenol 15 1200 30 1200 120 4800 <0.03

Cresol (total) 100 8000 200 8000 800 32000 - Di (2 ethylhexyl) phthalate 0.5 40 1 40 4 160 <5

1,2-Dichlorobenzene 75 6000 150 6000 600 24000 <0.02

1,4-Dichlorobenzene 2 160 4 160 16 640 <0.02

1,2-Dichloroethane 0.15 12 0.3 12 1.2 48 <0.02

1,1-Dichloroethene 1.5 120 3 120 12 480 <0.01

1-2-Dichloroethene 3 240 6 240 24 960 <0.02 Dichloromethane (methylene chloride) 0.2 16 0.4 16 1.6 64 <0.02

2,4-Dichlorophenol 10 800 20 800 80 3200 <0.03

2,4-Dinitrotoluene 0.07 5.2 0.13 5.2 0.52 21 <1.1

Ethylbenzene 15 1200 30 1200 120 4800 <0.5 Ethylene diamine tetra acetic acid (EDTA)

12.5 1000 25 1000 100 4000 <0.1

Formaldehyde 25 2000 50 2000 200 8000 <1

Hexachlorobutadiene 0.04 2.8 0.07 2.8 0.28 11 <0.02

Methyl ethyl ketone 100 8000 200 8000 800 32000 -

Nitrobenzene 1 80 2 80 8 320 <1.1

PAHs (total) N/A 50 N/A 100 N/A 400 <0.5 Phenols (total, non-halogenated) 7 560 14 560 56 2200 <1

Polychlorinated biphenyls N/A 2 - - - - -

Styrene 1.5 120 3 120 12 480 <0.5 1,1,1,2-Tetrachloroethane 5 400 10 400 40 1600 <0.01

1,1,2,2-Tetrachloroethane 0.65 52 1.3 52 5.2 210 <0.02

Tetrachloroethene 2.5 200 5 200 20 800 <0.02

Toluene 40 3200 80 3200 320 12800 <0.5 Trichlorobenzene (total) 1.5 120 3 120 12 480 <0.01

1,1,1-Trichloroethane 15 1200 30 1200 120 4800 <0.01

1,1,2-Trichloroethane 0.6 48 1.2 48 4.8 190 <0.04

Trichloroethene 0.25 20 0.5 20 2 80 0.05 2,4,5-Trichlorophenol 200 16000 400 16000 1600 64000 <0.05

2,4,6-Trichlorophenol 1 80 2 80 8 320 <0.05


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GROUP PARAMETER



Vinyl chloride 0.02 1.2 0.03 1.2 0.12 4.8 <0.02

Xylenes (total) 30 2400 60 2400 240 9600 <0.5

Pesticides

Aldrin + dieldrin 0.02 1.2 0.03 1.2 0.12 4.8 <0.03

DDT + DDD + DDE 1 50 2 50 N/A 50 <0.05

2,4-D 1.5 120 3 120 12 480 <0.02

Chlordane 0.05 4 0.1 4 0.4 16 <0.03

Heptachlor 0.02 1.2 0.03 1.2 0.12 4.8 <0.03 ASLP: Australian Standard Leaching Procedure TC: Total Concentration

5.7.3 Prescribed Industrial Waste (PIW) Management

Based on the assigned hazard category there is an associated management option as demonstrated in Table 5-28.

Table 5-28: Management options for PIW hazard categories (EPA, 2009)

CATERGORY MANAGEMENT OPTION

A

Prescribed industrial wastes which require a very high level of control and ongoing management to protect human health and the environment. Wastes in this category cannot be accepted at a disposal facility without prior treatment to reduce or control the hazard.

B

Prescribed industrial wastes which require a high level of control and ongoing management to protect human health and the environment. Solid prescribed industrial wastes in this category can be accepted at a facility licenced by EPA to receive this category of waste.

C

Prescribed industrial wastes which pose a low hazard, but require control and/or ongoing management to protect human health and the environment. Solid prescribed industrial wastes in this category are able to be accepted at best practice municipal landfills licensed by EPA to accept such waste.

Industrial waste

Industrial wastes are not regulated as prescribed industrial wastes, but when disposed of to landfill, continue to be controlled by EPA. These wastes can be accepted at solid inert landfills (non-putrescible) or municipal solid waste landfills (putrescible) licenced by EPA to accept this type of waste.

The transport of any industrial waste must meet with relevant vehicle requirements. Contractors transporting any Prescribed Industrial Waste (PIW) (more than 50 kilograms) must carry relevant permits complying with Section 53F of the EP Act. PIW must not be transported or permitted to be transported from any premise to another premises unless the receiving premises is licensed under the Act to receive that category of prescribed industrial waste, or the receiving premises is exempt from requiring a licence to treat or dispose of PIW at the premises, or transport has been otherwise approved by the EPA.

Transport requirements for ‘Industrial Wastes’ and ‘PIW Category B or C’ will likely need to be complied with for facility waste ash outputs. Additional transport requirements may apply should testing during commissioning determine a higher risk level waste categorisation (i.e. ‘PIW Category A’) is applicable.

5.7.4 Waste Handling and Treatment

5.7.4.1 Proposed Operation

Industrial Waste/PIW Handling


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Residue from the filter (fly ash) is collected at the bottom of the filter and pneumatically transported to the filter dust storage silo. The silo is emptied at regular intervals through a sealed system into designated trucks for transport and disposal in accordance with statutory regulations.

Bottom ash will be stored within the ash bunker outside of the main building to allow the front-end loader to collect the ash and load it into appropriate trucks for transportation and disposal. The ash bunker will be an ‘at grade’ installation that will be roofed in the conveyor drop zone, with the floor graded so any run off will drain back to the internal ash pit. As the bottom ash is not expected to contain any free running water when it is despatched, it is expected that the loader operation and loading out of the ash can be performed on the external slab area adjacent to the ash bunker.

A PIW producer must complete a transport certificate for each consignment of PIW transported from the premises reporting on information as outlined in Part A of Schedule 3 of the Environment Protection (Industrial Waste Resource) Amendment Regulation 2016 (the Amendment Regulation). Alternatively, an accredited agent can carry out reporting requiring on behalf of the waste producer.

The waste transporter must also complete a transport certificate for each consignment of PIW providing information on the waste producer before the waste is transported from the premises, and provide waste information to the waste receiver at the time of delivery of the waste as outlined in Part B of Schedule 2 of the Amendment Regulation 2016 (e.g. vehicle registration number, date of transport etc).

The waste receiver is required to report to the waste transporter (at the time of receipt of the waste), and to the appropriate authority (EPA) (within 7 days) as specified in Part C of Schedule 3 of the Amendment Regulation 2016 (e.g. date of receipt, amount of waste, type of treatment etc). Records must be retained for 24 months from the date on which the waste was transported. These special requirements will only apply to the facility in the case that the facility generates waste ash outputs that are categorised as PIW (Category A, B or C). Waste categorisations of ash outputs will be determined during commissioning.

5.7.4.2 Rejected Wastes

Should waste (feedstock) be received at the facility that is unwanted or not approved, it will be removed from the waste bunker through use of the overhead crane and placed in bins within the quarantine area for appropriate collection and disposal or recycling.

Ferrous and non-ferrous metals will be removed during the process and transferred to storage bins for recycling.

Other incompatible waste will be managed in the following ways:

• Whitegoods and other large items will be sent to local scrap metal recyclers • Discarded gas bottles and fire extinguishers will be sent to a licensed contractor for de-gassing and metal

recycling • Batteries will be sent to a licensed contractor for recycling • Asbestos and asbestos containing materials will not be permitted to be disposed of at the facility. It is

acknowledged however that small quantities of asbestos or asbestos containing materials may occasionally be present in some waste loads. Asbestos received at the facility will be managed and disposed in accordance with the Occupational Safety and Health Act 2004 and accompanying regulations and the requirements of the Code of Practice for the Safe Removal of Asbestos 2nd Edition [NOHSC: 2002 (2005)]

• Chemical and liquid waste will be removed, where possible, and stored within appropriate bins prior to collection and disposal.

Collection and removal of unwanted waste will occur through engagement of appropriately licenced and qualified contractors, in accordance with relevant legislation and regulations.

5.7.5 Best Practice Waste Management

As previously discussed, the waste hierarchy is one of eleven principles of environment protection contained in the EP Act. The application of the waste hierarchy has been an active part of Project decision-making processes. The facility feedstock would comprise MSW and C&I waste, which represents a relatively predictable baseload feedstock with relatively consistent compositions.

Any ferrous metal present in input feedstocks is effectively cleaned of contaminants that could inhibit recycling processes, and will remain with the bottom ash after the combustion process. These metals will be separated and sorted from bottom ash and sent for recycling. By-product wastes that are transported directly from their premises for


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disposal will be tested and categorised. If wastes are treated offsite, they will need to be categorised by the waste treater prior to disposal.

Waste characterisation will involve identification of contaminants likely to be present in the waste, as well as sampling and analysis for each of the contaminants. Documented evidence to support the categorisation must include the results of a sampling and analysis program.

It is noted that the potential for beneficial reuse of bottom and fly ash (i.e. concrete, road base etc) is currently being investigated by the proponent for commercial viability. All solid wastes not beneficially reused will be disposed of in a municipal landfill in accordance with statutory requirements. The development of ash for beneficial use as road base or cement would see a further transference from “Disposal” to “Reuse”.

Environmental Management

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Environmental Objectives GSWT’s environmental objectives for the facility are defined in the Site Environmental Management Plan (SEMP). GSWT has a strong commitment to environmentally sustainable practices and procedures. GSWT will responsibly manage its operations by striving to achieve environmental practices that are acceptable to the relevant authorities and the community.

GSWT environmental management objectives are to actively promote an environmentally responsible approach to all activities undertaken throughout the entire company. In particular GSWT will actively promote:

• Environmental training throughout all levels of the organisation • Compliance with best practice air quality standards • Reduction in energy consumption through selection of appropriate waste fuel sources • Water conservation and recycling • Waste reduction, reuse and recycling.

GSWT is aware of its responsibility to prevent and mitigate incidents, to reduce risks and to minimise effects of its activities on the environment. GSWT is committed to taking a risk-based approach to environmental management, and as such the Environmental Risk Assessment will be subject to continuous updates and improvement.

Risk Assessment An environmental risk assessment was conducted to identify environmental risks, guiding the application of Best Practice technology during construction, routine operations and non-routine operations. The risk assessment is intended to identify risks and controls to reduce risks to an acceptable level. The risk assessment identified both social and environmental risks associated with the project.

The Environmental Risk Assessment (ERA) has been conducted by:

• Completion of specialist technical studies including noise, waste, fire and air emissions assessments • Environmental risk assessment utilising the concept designs and known process components • Risk assessment workshops involving the project team and environmental specialists to identify technical and

project risks.

The above activities resulted in the development of a qualitative Environmental Risk Register, presented in Appendix N. The ERA has been conducted using the principles of the Guidelines for using a risk assessment approach to assess compliance with licence conditions, EPA Publication 1321.2 (EPA, 2011a) which were adapted for the project. The ERA has been conducted in general accordance with AS/NZS ISO 14004:2004 (Environmental Management Systems) and AS/NZS ISO 13000:2009 (Risk Management).

Assessment of Environmental Risk Central to the assessment process is the consideration of whether the project is likely to cause a significant adverse environmental impact. This is irrespective of the scale or type of development. The interpretation of significance is context-dependent and relative to multiple elements (e.g. spatial, temporal, cultural, ecological, social, economic or institutional).

An adverse environmental impact may be considered significant if:

• the environmental function, system, value or entity that might be adversely impacted by the development proposed is significant, or

• the cumulative or incremental effect of the development proposed might contribute to a substantial adverse impact on an environmental function, system, value or entity.

In deciding whether an adverse environmental impact is significant, the following is considered:

• the kind, size, frequency, intensity, scope and duration of the impact • the sensitivity, resilience and rarity of the environmental function, system, value or entity likely to be affected.


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The consideration of ‘significance’ during the ERA process is used to determine the level of potential impact and is intended to assist in determining the requirement for risk mitigation and controls.

6.3.1 Evaluating Likelihood

The likelihood of an impact occurring is best described in terms of probability. Overlying this is the need to recognise the uncertainty that may be associated with potential impacts, particularly during the risk assessment process. Best practice dictates that where there is scientific uncertainty, a cautious approach is warranted, which will in turn identify a higher level of risk.

Each identifiable potential impact is assigned a likelihood between ‘rare’ and ‘almost certain’.

Table 6-1 presents the criteria used to determine the likelihood of an impact.

Table 6-1: Qualitative measures of likelihood

RATING INDICATOR DESCRIPTION PROBABILITY FREQUENCY

5 Almost certain Expected to occur more than once during the project

>99% > Once a year

4 Likely Expected to occur once during project >50% Once every 2 years

3 Possible Not likely to occur during the project, however some incidents have been recorded

10% Once every 10 years

2 Unlikely Could occur at some time during the project, however, few recorded or known incidents

1% Once every 100 years

1 Rare May only occur in exceptional circumstances No recorded or known incidents

< 1% Only expect to occur under atypical conditions

6.3.2 Evaluating Consequence

The consequences of an impact require a degree of subjective assessment, as the likely consequences of an impact may consist of several elements. The elements considered are illustrated in Table 6-2. Several of the elements are interrelated and a consequence is considered to be major if any one of the elements has a predicted major impact.

The consequence of an impact used in the risk assessment is the reasonably foreseeable consequence. If there is a large amount of uncertainty, then the consequence may be worse. Table 6-2 presents qualitative measures of consequence or impact.

Table 6-2: Qualitative measures of consequence/ impact

RATING INDICATOR HUMAN FACTOR ENVIRONMENT ECONOMIC

5 Severe Death or several permanent injuries Catastrophic offsite impact Immense financial loss

4 Significant Extensive injuries/ illness Substantial offsite impacts Major financial loss

3 Moderate Some health impacts requiring medical treatment

Minor, uncontained offsite impacts Large financial loss

2 Minor First aid treatment Minor, contained offsite impacts Small financial loss


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RATING INDICATOR HUMAN FACTOR ENVIRONMENT ECONOMIC

1 Insignificant Operations cause no injuries No off-site impacts Negligible financial loss

Based on the assessment of likelihood and consequence, any foreseeable impact can be assigned a risk rating.

Table 6-3 illustrates the risk rating process as a matrix. The resulting juncture of consequence and likelihood produces the risk rating on a scale of negligible to significant.

Table 6-3: Risk analysis matrix

Likelihood Consequence

Severe (5) Significant (4) Moderate (3) Minor (2) Insignificant (1)

Almost certain (5)

Extreme Extreme Extreme High Low

Likely (4) Extreme Extreme High Medium Low

Possible (3) Extreme High High Medium Low

Not likely (2) High Medium Medium Low Low

Rare (1) Low Low Low Low Low

6.3.3 Non-Routine Operations

The project could result in environmental impacts under upset or non-routine operation conditions. Consideration of the environmental impacts of non-routine operations has been included as part of the ERA. The non-routine operation conditions that could result in environmental impacts are:

• Power failure • Loss of water supply • Loss of feedstock supply • Plant and equipment failure • Leaks, spills and releases • Uncontrolled fire. In addition, the facility requires four planned plant stops per year of a duration of one week for maintenance and refurbishment.

6.3.3.1 Emergency Shut Down

The facility features an Emergency Shut Down (ESD) system. The ESD function is powered by an Uninterruptible Power Supply (UPS) and when triggered, overrides the Process Control System (PCS). Triggering of the ESD may occur due to external conditions and internal operational scenarios including, but not limited to:

• Power failure • Internal plant and equipment failure • Pressure and temperature levels in the furnace, boiler and cooling medium • Operator push button located in plant room

The risk assessment identified the following potential environmental impacts resulting from ESD of the facility:

• Blow-out of flue gas • High steam pressure leading to steam release.

Measures implemented in the process design to address these risks are presented in the risk assessment.


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6.3.3.2 Leaks, spills and releases

The presence of potentially hazardous chemicals and substances onsite poses a potential environmental risk in the event of leaks, spills and releases. No landfill leachate is expected to be generated at the site. Other potentially hazardous chemicals and substances that will be present onsite are:

• Flue and bottom ash (solid) • LPG fuel (liquid) • Transformer and lubricant oils • Diesel fuel (liquid) • Hydraulic and cooling oil (liquid) • Lime (solid) • Powdered Activated Carbon (solid) • Petroleum fuel (liquid).

Accidental release of these substances to the environment may cause environmental impacts. As discussed in the risk assessment, bunding and stormwater controls will be implemented to contain any leaks, spills and releases. Operational procedures are to be put in place to ensure safe and effective clean-up of any spills that may occur onsite.

6.3.3.3 Feedstock variation

Significant feedstock variation is not considered likely due to the pre-sorted nature of municipal, commercial and industrial waste accepted at the facility. Additionally, waste feedstocks accepted at the facility will be homogenised by mixing with the overhead crane, to occur within the waste bunker and during feeding of the shredder, and shredding of waste into the fuel bunker. This two-stage process of waste feedstock homogenisation promotes a consistent gasification process and reduces the likelihood of variable conditions during gasification, therefore reducing the risk of abnormal emissions.

Furthermore, removal of unwanted or not approved waste from the waste bunker will occur through use of the overhead crane and placed in bins within the quarantine area for appropriate collection and disposal or recycling. This will further promote waste consistency and reduce potential feedstock variation.

The facility has been designed to accommodate a range of operating conditions to cater for feedstock energy content typical of MSW and C&I waste. Inferior feedstock energy content typically increases the amount of bottom ash produced. Contractual requirements regulating input quality as well as feedstock testing and ferrous metals separation also works to reduce variability in feedstock quality.

6.3.4 Outcomes

The ERA identified residual project risks rated as a medium risk to the environment. The construction aspects of the facility with the potential for environmental risks to arise at the site are: • Exposure of historical soil and groundwater contamination during demolition and excavation • Noise and amenity impact to nearby receptors during construction • Management of shallow groundwater during excavation and construction of the below ground fuel bunker. The operational aspects of the facility with the potential for environmental risks to arise at the site are: • Emergency plant shutdown resulting in temporary process failure • The handling and transportation of waste generating odour and air impacts • Vehicle movements to, from and within the Site • Storage and handling of potentially hazardous solid and liquid substances, including inputs and process by-

products.

The non-routine aspects of the facility with the potential for environmental risks to arise at the site are:

• Ignition of chemicals, waste and/or fuels resulting in uncontrolled fire • Blow-out of flue gas during ESD.

All other identified risks are rated low due to the design and contingency measures presented in Appendix N. Design measures included in Appendix N have been incorporated into the conceptual design and some elements require further development as part of the detailed design process. Contingency measures during the construction phase will be included as part of the CEMP. Contingency measures required during the routine and non-routine operation have been incorporated into the process design and operational measured will be incorporated into the SEMP.


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Climate Change Climate change projections have been developed by CSIRO based on a range of Representative Concentration Pathways (RCPs) which model the global warming resulting from plausible scenarios of greenhouse gas and aerosol concentrations and land use change. The four scenarios are based on the amount of radiative forcing (in watts per square metre) due to atmospheric carbon dioxide concentrations. The Victorian Government has produced a climate projections data sheet for Greater Melbourne based on two RCP scenarios developed by CSIRO:

• RCP8.5 – higher scenario - little curbing of emissions (the current trajectory) with concentrations reaching 940ppm by 2100

• RCP4.5 – lower scenario - substantial curbing of emissions, with concentrations reaching 540ppm by 2100.

The resulting impacts on temperatures and climatic conditions for the Greater Melbourne region is presented in Table 6-4.


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Table 6-4 Climate Projections for Greater Melbourne (Climate-Ready Victoria, 2019)


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The climate projections for Greater Melbourne presented in Table 6-4 indicate:

• Average temperature will increase by 1 degree C on average, and temperature increase is consistent across all seasons

• Average rainfall will decrease by 2 per cent on average, with the greatest decrease occurring in Spring • Evaporation will increase by 4 per cent on average, in accordance with the increases in temperature. The

greatest increase occurs in winter • Solar radiation will increase by approximately 2-3 per cent, with the greatest increase occurring in winter • Soil moisture will decrease by approximately 3 per cent • Sea level is expected to rise by up to 0.39m, measured at Williamstown and Stony Point.

CSIRO also predicts the following changes for Southern Australia:

• Hot days will become more frequent and hotter • Sea levels will rise • Oceans will become more acidic • Extreme rainfall events are likely to become more intense.

The expected impact of these climatic changes relevant to the facility are summarised in Table 6-5.

Table 6-5 Expected impact of climate change on the proposed facility

CLIMATE CHANGE IMPACT RISK TREATMENT

Increase in temperature of input cooling water resulting in reduced boiler and overall plant efficiency. Significant increases may exceed the operational parameters for the plant, resulting in plant shutdown during hot days

Water cooled components are much less vulnerable to changes in ambient temperature than air cooled components. The majority of operational activities can be undertaken in the air conditioned indoors environment, minimising risk to workers of heat exposure

Reduction in feedstock moisture content resulting in a higher calorific value feedstock. This could improve plant efficiency and result in an opportunity to process greater volumes of waste (on a dry mass basis)

The range of operational conditions for the facility are able to accommodate the expected level of change in feedstock moisture content

Extreme ambient temperatures affecting electricity supply network, resulting in more frequent and/or prolonged plant shutdown

Measures in place to ensure environmental impacts are managed during ESD

Contingency delivery of waste to landfill to ensure accumulation of waste beyond the appropriate fuel bunker capacity

Reduced availability of potable water supply due to reduced rainfall The facility’s water use is considered minimal in relation to

other industrial uses Increased evaporation results in more efficient cooling, however slightly more water is required

Impacts of flooding on the delivery of feedstock to the facility, resulting in reduced plant operation and/or plant shutdown

The site’s location within an urbanised stormwater catchment means impacts of flooding of road networks are likely to be short-term

Impacts of flooding on the facility infrastructure due to the Site’s location near the Dandenong Creek Land Subject to Inundation Overlay

The site’s construction consists predominately of hardstand pavement and channelised stormwater drainage, which reduces risk of erosion

The majority of the process components are located within the main building, reducing the need to traffic outdoors during heavy rainfall events

Increase in odour due to temperature increases Current mitigation measures proposed are sufficient to address potential increases in odour of feedstock waste


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CLIMATE CHANGE IMPACT RISK TREATMENT

Decrease in soil moisture content resulting in potential geotechnical instability of the structure

Building constructed on slab foundations to be designed to accommodate a range of soil moisture conditions

The climate change impacts identified in Table 6-5 are considered acceptable if the proposed risk treatment measures are implemented.

Operational Management 6.5.1 Site Environmental Management Plan

A Site Environmental Management Plan (SEMP) has been developed to address the potential risks occurring during routine and non-routine events. The SEMP has been developed to establish procedures to identify environmental risks, manage impacts in accordance with agreed standards, objectives or targets, and monitor overall environmental performance during operation of the proposed WtE plant. The SEMP includes:

• A description of activities to be undertaken during operation • An environmental risk analysis to identify the key environmental performance issues associated with the

operation phase • Statutory and other obligations that the proponent is required to fulfil during operation, including approvals,

consultations and agreements required from authorities and other stakeholders under key legislation and policies

• Overall environmental policies, guidelines and principles to be applied to operation • Roles and responsibilities for relevant employees involved in operation, including relevant environmental

training and induction requirements incident and contingency management procedures • Details of how environmental performance would be managed and monitored to meet acceptable outcomes,

including what actions would be taken to address identified potential adverse environmental impacts.

The approach used to identify best practice in managing these environmental risks has included:

• Employing the hierarchy of control – that is, prevention is the best option • Control procedures will be integrated into the OEMS to ensure a consistent approach to control • Management and measurement of risk to the environment • Leveraging the expertise of the Engineering, Procurement and Construction(PC) contractor to identify best

practice in other parts of the world.

The SEMP is intended to be a working document that is subject to ongoing change. It is likely that the SEMP will need to be updated as the site operations and practices evolve and to address regulatory changes.

6.5.2 Management and Storage of Combustible Recyclable and Waste Materials

To reduce the risk of fires at waste and resource recovery facilities the Victorian EPA requires compliance with the Waste Management Policy (Combustible Recyclable and Waste Materials).

Compliance with the policy requires combustible recyclable and waste materials (CRWM) at waste and resource recovery facilities (WRRF) to be managed and stored in a manner that minimises risk of harm to human health and the environment from fire.

To support compliance with the policy, an updated ‘Management and storage of combustible recyclable and waste materials’ guideline (publication 1667.2) (the guideline) was developed by EPA, Country Fire Authority (CFA) and Metropolitan Fire Brigade (MFB) in consultation with a wide range of government and waste industry representatives.

This guideline provides practical guidance on how to comply with the Waste Management Policy (Combustible Recyclable and Waste Materials).

To assess compliance against the guideline a Fire Safety Study was commissioned (RiskCon Engineering, 2019). This study identified and assessed potential hazards and risks under different fire scenarios so that the facility is designed with the appropriate fire protection requirements.


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The study identified several fire scenarios which may result in substantial radiant heat impacts which could render fire protection systems inoperable.

Key recommendations to be implemented are summarised in Table 4-12.

Upon the implementation of the recommendations of the report, the systems should be capable of combating the modelled fire scenarios.

6.5.3 Dangerous Goods and Hazardous Substances

Hazardous substances are classified on the basis of their potential health effects, which may be acute (immediate) or chronic (long term). Hazardous substances can be any substance that may cause harm to an individual’s health.

Dangerous goods are classified on the basis of immediate physical or chemical effects, such as explosion, fire, poisoning and corrosion.

Management of dangerous goods and hazardous substances at the facility will be conducted in general accordance with the following Guidelines and Regulations:

• Occupation Health and Safety Regulations S.R. No 22/2017 • Dangerous Goods (Storage and Handling) Regulations 2012 • Occupational Health and Safety Act 2004 • Australian Standard AS1940: The Storage and Handling of Flammable and Combustible Liquids.

Dangerous goods and hazardous substances likely to be stored at the facility are presented in Table 6-6.

Table 6-6: Dangerous Goods and Hazardous Substances

LIQUID DANGEROUS GOOD CLASS QUANTITY

Liquid Petroleum Gas (forklift fuel) 2.1 TBC

Powdered Activated Carbon 4.2 50 m3

Transformer Oil 4.2 TBC

Calcium Hydroxide NDG TBC

MSW and C&I NDG 5,000 m3

Thermal Oils Non-Dangerous Good TBC

Lubricating Oils and Diesels Non-Dangerous Good TBC

Storage of liquids will be conducted in general accordance with the relevant Regulations, as presented in Section 6.5.3.1.

A Fire Safety Study was commissioned which included recommended measures to reduce the risk of fire at the facility, including those associated with storage of hazardous liquids. Refer to Section 4.4.

In accordance with the relevant Regulations, the requirements presented in Table 6-7 will be implemented at the facility prior to commissioning.

Table 6-7: Storage and Handling Requirements

REQUIREMENT ACTIONS

Inductions and Training

• All persons involved in the handling or storage of dangerous goods and hazardous substances will be inducted and suitably trained to ensure they are aware of the risks posed by the materials and appropriate measures in the event of an incident.

Material Safety Data Sheet (MSDS) • MSDS for all dangerous goods and hazardous substances used and stored at the facility to be retained at the premises


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REQUIREMENT ACTIONS

• MSDS to be readily accessible to any employees or contractors who may be exposed to the substance.

Register of Substances

• A register for all dangerous goods and hazardous substances will be stored and maintained at the facility, containing a list of product identifiers

• Register to be readily accessible to any employees or contractors who may be exposed to the substance.

Labelling and Signage

• All containers of dangerous goods and hazardous substances located at the facility will be labelled with the manufacturer’s supplier’s label.

• Safety signs will be appropriately situated at the premises to warn workers and visitors of the risks associated with the chemicals on site.

Risk Assessment and Controls

• An assessment of risk associated with hazardous substances and dangerous goods will be conducted and controls implemented to reduce the risk, so far as is reasonably practicable.

• Required controls to be determined during detailed design phase of the project.

Emergency Procedures and Incident Management Plan

• Actions to minimise harm to site personnel, the environment and the operations of the facility will be detailed in the Management Plan.

• The incident response plan will include procedures for dealing with incidents, personnel and responsibilities in the event of an incident, and site plans showing the locations of emergency equipment and hazardous/dangerous goods.

• The Management Plan will contain Material Safety Data Sheets

The SEMP(SMEC 2019) will be reviewed and updated prior to commissioning of the facility to detail specific inspection, maintenance and incident management requirements for dangerous goods and hazardous substances stored at the facility.

6.5.3.1 Liquid Storage and Handling

Storage and handling of liquid substances at the facility will be conducted in general accordance with the relevant Guidelines and Regulations, including:

• Australian Standard AS1940: The Storage and Handling of Flammable and Combustible Liquids • EPA Publication 1698 Liquid Storage and Handling Guidelines (June 2018).

Hazardous liquids are to be stored within designated undercover containment areas with appropriate secondary containment to reduce the potential risk of stormwater contamination and unintended release to the environment. Sizing and location of secondary containment areas will be designed in accordance with Australian Standard AS1940: The Storage and handling of flammable and combustible liquids, during the detailed design phase of the project.

Uncontaminated stormwater is to be diverted away from liquid and waste storage areas to prevent contamination of stormwater.

An inspection and monitoring program for storage vessels/containers and bunds will be detailed in the revised SEMP, which will include incident management and spill response requirements (as per Section 6.5.3)

Construction Impact Management During construction activities there is the potential to impact upon the environment if appropriate control measures are not put in place. This section outlines an approach to environmental management that can be utilised during the construction of the facility to minimise impacts to the environment.

6.6.1 Construction preliminary environmental risk assessment

The following environmental aspects associated with construction of the site have been identified as potentially having moderate to high risk of impact if controls are not implemented:


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• Dust control

• Noise and vibration

• Water quality management (stormwater and waste water)

• Waste and amenity management (including litter and lighting)

• Hazardous materials (fuels and chemicals)

• Contaminated sites

• Acid sulfate soils and dewatering.

6.6.2 Construction Environmental Management Plan

A Construction Environmental Management Plan (CEMP) is a site-specific document detailing the specific actions to be taken to mitigate the risk of environmental harm during the project’s construction phase. A CEMP will be required for the site, and will be developed following completion of a detailed design and construction specification. The principal contractor is generally responsible for the development of the CEMP, which will be reviewed and administered by GSWT.

The CEMP will be prepared in accordance with the Environmental Guidelines for Major Construction Sites, EPA Publication 480 (EPA, 1996) and address relevant environmental aspects. The CEMP will outline the proposed measures to be implemented to help achieve and maintain acceptable levels of environmental impact. The CEMP is developed to ensure that all contractors, sub-contractors, employees and site visitors comply with environmental requirements and that environmental risks are properly managed during construction activities.

The CEMP must be site specific and detail appropriate management measures. The CEMP should be considered a dynamic document which must be reviewed if conditions onsite change and consequently influence specific management measures. In addition to this, contractors may be audited against the details of the CEMP.

It is the contractor’s responsibility to ensure that appropriate actions are documented and implemented to mitigate potential environmental impacts associated with construction activities.

The CEMP should be displayed on site during construction operations. This will aid in communication of environmental management procedures and address construction environmental management requirements in a focussed manner.

The CEMP should be prepared in accordance with the GSWT environment and sustainability policies once developed, with the objective of minimising impact upon the environment during the construction phase of the project. All personnel involved in the construction of the facility, including sub-contractors must be inducted into the and comply with the requirements of the CEMP.

Table 6-8 outlines the proposed structure of the CEMP document.

Table 6-8: Proposed structure of the CEMP

ELEMENT DESCRIPTION

Environmental Legislation, Regulations and Guidelines

The legislation, policies, standards and other requirements that apply to the key environmental issues

Roles and responsibilities

To ensure effective implementation and ongoing maintenance of a site-specific CEMP, responsibilities will be assigned to key project personnel.

It is essential that all personnel associated with the project comply with the requirements of all applicable environmental legislation, regulations, codes of practice and standards.

Environmental training, awareness and competence

All persons working onsite must be aware of their environmental responsibilities and receive training to help them to meet those responsibilities.

Training can take various forms including site induction, toolbox talks and meetings.

Documentation and records management

GSWT will maintain records that demonstrate the environmental obligations are being addressed and verify the status of those matters.

Environmental management records should include but is not limited to the following:


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ELEMENT DESCRIPTION

• Records of inspections, non-conformances

• Corrective actions

• Audits

• Training records (including training and induction matrix)

• Monitoring data

• Complaint and incident reports

• Licences and permits

• Any other relevant documents and reports as required

The Project Manager will be responsible for ensuring all documentation is appropriately stored and available for effective functioning of the CEMP.

The CEMP is a live document and will be reviewed and updated regularly during the construction process as required.

Reporting

GSWT will report to the EPA results of environmental monitoring programs, environmental incidents and any non-conformances in accordance with the EPA Licence, works approval, associated environmental conditions and the CEMP. A reporting register and monitoring checklists will be developed and maintained by the Project Manager to assist with managing ongoing reporting requirements.

Audits and review

In addition to environmental monitoring, regular auditing during construction activities will be undertaken to assess compliance with the CEMP. Auditing can be undertaken utilising a combination if internal and external auditors, with the annual environmental audit to be undertaken by a suitably qualified environmental specialist.

The CEMP Auditor will aim to evaluate performance, identify areas of potential deficiencies and develop procedures that continually improve the GSWT environmental management system to ensure that it continues to be relevant and effective.

The CEMP will be reviewed regularly during site construction activities.

Environmental incident management and reporting

In the event of any incident, the first priority shall be the safety of all personnel, including site workers, visitors and the community in the immediate vicinity. Following this, all practical measures will be taken to minimise the risk of further environmental damage as soon as possible after the event through the implementation of appropriate incident management or contingency plan procedures.

Complaints management

Any complaints received shall be directed to the Site Manager who will liaise with the complainant to ensure a suitable and timely response. Complaints from any source (e.g. Public, Government Authorities) must be registered using a complaint record, the complaint investigated by the Site Manager (or delegate) and action taken to enable satisfactory closeout.

Communications All environmental issues specific to the project (e.g. Incidents, complaints) will be communicated through regular site and tool box meetings. Records of communications will be documented in a project file.

Environmental management measures

This section details Environmental Management Measures (EMM) for each potential environmental issue associated with site construction activities. Each issue is addressed by a set of management measures or operational instructions that can be implemented at the site and if required supported by specific managements plans.

Other Approvals

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Other Approvals Commissioning Plan

Following the receipt of a works approval, a Commissioning Plan will be submitted to the EPA in order to obtain commissioning approval. This plan will detail risks unique to plant start-up, which are generally considered to occur within the first three to six months of operation of the plant. The Plan will detail the environmental, operational and Occupational Health and Safety (OHS) inspections and documentation that will be completed prior to operation of the facility. The Plan will seek to ensure that all plant and equipment components are suitable for operation prior and that the environmental risks identified within this works approval are being mitigated as planned.

Environmental Approvals Table 7-1 below provides a summary of other environmental approvals which are relevant to the facility.

Table 7-1: Review of relevant legislation and approvals


COMMONWEALTH

Environment and Biodiversity Conservation Act 1999 (EPBC Act)

Construction No The project will not be referred to the Minister for Environment as the project will not have a significant impact on any Matters of National Environmental Significance (MNES) protected under the EPBC Act

STATE

Planning and Environment Act 1987 (PE Act)

Construction Yes A planning permit is required under the City of Greater Dandenong Planning Scheme. A planning permit application is currently being prepared separately by a third party and will be submitted to Council once the detailed building design and associated infrastructure are completed.

Environmental Effects Act 1978 (EE Act)

Construction No An Environmental Effects Statement (EES) referral for the project is not triggered under the referral criteria.

Environment Protection Act 1970

Commissioning Yes Subject to a works approval, GSWT will need to apply for commissioning approval to allow for emissions during the commissioning phase of the project.

Operation Following acceptance of the EPA Works Approval Application, EPA will issue GSWT with an EPA licence subject to conditions relating to the ongoing operation and monitoring of the site.

Heritage Act 2017 Construction No A permit is not required for the proposed works as there are no Heritage Places or Heritage Overlays within the site boundary or immediate surrounds. Results of the cultural heritage due diligence assessment are included in Appendix B.

Aboriginal Heritage Act 2006

Construction No The site is located partially within an Area of Cultural Heritage Sensitivity due to being within 200m of Dandenong Creek. Due to the high level of previous land disturbance at the site, it is considered highly unlikely to retain any Aboriginal cultural heritage values, and does not trigger the requirement for a mandatory Cultural Heritage Management Plan (CHMP). Results of the cultural heritage due diligence assessment are included in Appendix B.

Flora and Fauna Guarantee Act 1988 (FFG Act)

Construction No No FFG listed species or communities are to be impacted by the proposed works. Additionally, a permit under the FFG Act is not required on private land.

Other Approvals

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Occupational Health and Safety Act 2004

Operation Yes Dangerous Goods - There is a requirement to consult with the CFA regarding storage and handling arrangements for Dangerous Goods.

Catchment and Land Protection Act 1994

Construction / Operation

Yes No further actions under the CaLP Act are required. A Construction Environmental Management Plan (CEMP) will be implemented to manage weeds during construction.

Water Act 1989 Construction / Operation

No As works will not impact on any adjacent waterways, no action under the Water Act 1989 is required for this project.

Post Decision Requirements Table 7-2 below confirms the information requirements under Section 15 of the EPA Publication 1658 (EPA, 2017c).

Table 7-2: Operational requirements

POST DECISION – OPERATIONAL REQUIREMENT COMMENTS

Financial assurance Not applicable to H01 scheduled activity

PCBs Management Not applicable – the process does not involve storing, handling and/or transporting PCBs.

Monitoring A monitoring plan will be developed for the proposed facility that meets the requirements of EPA Publication 1321 Licence Assessment Guideline.

Reporting annual performance Annual performance statements (APS) will be prepared and submitted in accordance with the licence requirements.

Important Notice

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Important Notice This report is provided solely for the purposes of the Works Approval application for the proposed Waste to Energy facility at 70 Ordish Road, Dandenong South. This report is provided pursuant to a Consultancy Agreement between SMEC Australia Pty Limited (‘SMEC’) and Great Southern Waste Technologies, under which SMEC undertook to perform a specific and limited task for Great Southern Waste Technologies. This report is strictly limited to the matters stated in it and subject to the various assumptions, qualifications and limitations in it and does not apply by implication to other matters. SMEC makes no representation that the scope, assumptions, qualifications and exclusions set out in this report will be suitable or sufficient for other purposes nor that the content of the report covers all matters which you may regard as material for your purposes.

This report must be read as a whole. The executive summary is not a substitute for this. Any subsequent report must be read in conjunction with this report.

The report supersedes all previous draft or interim reports, whether written or presented orally, before the date of this report. This report has not and will not be updated for events or transactions occurring after the date of the report or any other matters which might have a material effect on its contents or which come to light after the date of the report. SMEC is not obliged to inform you of any such event, transaction or matter nor to update the report for anything that occurs, or of which SMEC becomes aware, after the date of this report.

Unless expressly agreed otherwise in writing, SMEC does not accept a duty of care or any other legal responsibility whatsoever in relation to this report, or any related enquiries, advice or other work, nor does SMEC make any representation in connection with this report, to any person other than Great Southern Waste Technologies. Any other person who receives a draft or a copy of this report (or any part of it) or discusses it (or any part of it) or any related matter with SMEC, does so on the basis that he or she acknowledges and accepts that he or she may not rely on this report nor on any related information or advice given by SMEC for any purpose whatsoever

References

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Biosis, 2019. Cultural Heritage Due Diligence Assessment for an Industrial Facility at 70 Ordish Road, Dandenong South, Victoria, 18 October 2019

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City of Greater Dandenong (n.d.). Waste and Litter Strategy 2015 - 2020. City of Greater Dandenong, p. 54

DELWP, 2019. Planning Property Report. Department of Environment Water Land and Planning, Available from: www.planning.vic.gov.au [accessed 16 April 2019].

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Energos, 2014a. Export from Energos Reporting tool, Hafslund Varme Both Lines, Daily average 2013, Dated 8 September.

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Energos, 2015a. Export from Energos Reporting tool, Hafslund Varme Line 1, 19-10-2014, Dated 19 October.

Energos, 2015b. Export from Energos Reporting tool, Hafslund Varme Line 1, 19-04-2015, Dated 19 October.

Energos, 2016. Excerpt from emissions presentation, detailing measurements taken in Nov 2016.

Energos, 2017. Description of an Energos gasification plant type 52-6-41 to produce energy from waste, 13 November 2017.

Energos, 2018a. Emissions: EU limits and TUV reports from ENERGOS plants in operation.

Energos, 2018b. Firing Diagram - Dandenong South WTE, 11 June

Energos, 2019a. RE: 30041688: Draft Works Approval Application – 70 Ordish Road, 01/07/19, email received 30 July 2019

Energos, 2019b. Standard Specification, Appendix D, Fuel Specification.

enHealth, 2012. Environmental Health Risk Assessment Guidelines for assessing human health risks from environmental hazards

EPA, 1991. Construction Techniques for Sediment Pollution Control, Environment Protection Authority Publication 275.

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EPA, 2008. Noise Control Guidelines. Environment Protection Authority Publication 1254.

EPA, 2009. Industrial Waste Resources Guidelines: Solid Industrial Waste Hazard Categorisation and Management, Publication IWRG631, June 2009.

EPA, 2011. Noise from Industry in Regional Victoria, Publication 1411. October 2011.

EPA, 2011a. Licence Assessment Guidelines, EPA Publication 1321.2, June 2011

EPA, 2013a. Guidance Notes for Using the Regulatory Model AERMOD in Victoria, Publication 1551, 7 October 2013.

EPA, 2013b. Recommended Separation Distances for Industrial Residual Air Emissions. Environment Protection Authority Publication 1518, issues March 2013.

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EPA, 2017. Air Monitoring Report 2016 – Compliance with the National Environment (Ambient Air Quality) Measure. Environmental Protection Authority.

EPA, 2017a. Demonstrating Best Practice Environment Protection Authority Publication 1517.1, issued October 2017.

EPA, 2017b. Energy from Waste Guideline. Environment Protection Authority Publication 1559.1, issued July 2017

EPA, 2017c. Works Approval Guidelines. Environment Protection Authority Publication 1658, issued June 2017.

EPA, 2017d. Environment Protection (Scheduled Premises) Regulations 2017, S.R. No. 45/2017.

EPA, 2018a. Liquid Storage and Handling Guidelines. Environment Protection Authority Publication 1698, issued June 2018

EPA, 2018b. Management and storage of combustible recyclable and waste materials. Environment Protection Authority Publication 1667.2, issued 30 October 2018.

Equilibrium, 2019. Great Southern Waste Technologies Stakeholder and Community Engagement and Consultation Plan, 21 October 2019

EU, 2010. Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on Industrial Emissions (integrated pollution prevention and control).

EC, 2006. Integrated Pollution Prevention and Control - Reference Document on the Best Available Techniques for Waste Incineration. European Commission, August 2006.

Frankston City Council (n.d.). Frankston City Council Waste Minimisation and Management Plan 2015–2020. Frankston, Frankston City Council, p. 21

Geological Survey of Victoria, 2015. Energy and Earth Resources, State Government of Victoria, Available from: http://earthresources.efirst.com.au/ [April 2018].

Hla, S.S. and Roberts, D. 2014. Characterisation of chemical composition and energy content of green waste and municipal solid waste from Greater Brisbane, Australia. Waste Management 41, 12-19.

HRL, 2018. Auditing and Combustion Characteristics of Municipal Solid Waste (MSW)

Hume City Council (n.d.). Waste Management Strategy 2012 - 2016. Hume City Council, p. 15

Knox City Council, 2013. Waste Management Plan 2014-2021. Wantirna South, Knox City Council, p. 26

La Trobe City Council, 2010. Latrobe City Council Waste Management Strategy 2010 – 2017. La Trobe City Council, p. 21

Manningham City Council, 2012. Interim Waste Management Strategy 2012 - 2017. Manningham City Council, p. 29

MSS (Marchwood Scientific Services), 2011. Waste Acceptance Testing for a Sample of Ash. Isle of Wight, 5 May 2011.

Melbourne City Council, 2019. Waste and Resource Recovery Strategy 2030. Melbourne: Melbourne City Council, p.24

Metropolitan Waste and Resource Recovery Group (MWRRG) Alternative Waste and Resource Recovery Technologies: Metropolitan Regional Business Case and Procurement Strategy (September 2018)

Mornington City Council, 2009. Municipal Waste Management Strategy. Mornington Shire Council, p. 17

MWRRG Metropolitan Waste and Resource Recovery Implementation Plan 2016, September 2016

Nearmap, 2018. Website: https://www.nearmap.com/au/en, viewed July 2018.

NGER, 2007. National Greenhouse and Energy Reporting Act No 175, 2007.

RiskCon Engineering, 2018. Fire Safety Study – 70 Ordish Road, Dandenong South.

SEPP, 1999. State Environment Protection Policy (Ambient Air Quality), No. S19, Gazette 9/2/1999.

SEPP, 2001. State Environment Protection Policy (Air Quality Management), No. S240, Gazette 21/12/2001.

SMEC, 2018a. Preliminary Site Investigation.

SMEC, 2018b. Stormwater Management Plan – Waste to Energy Facility.

SMEC, 2019a. Environmental Risk Assessment –Dandenong South Waste to Energy Project

https://www.nearmap.com/au/en

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SMEC, 2019b. Human Health Risk Assessment – Dandenong South Waste to Energy Facility

SMEC, 2019c. Litter Management Plan – Dandenong South Waste to Energy Project

SMEC, 2019d. Site Environmental Management Plan – Dandenong South Waste to Energy Project.

SMEC, 2019e. Traffic Impact Assessment – Proposed Waste to Energy Plant at 70 Ordish Road, Dandenong South.

Start2See, 2019. Streamlined GHG LCA of 100 KTPA MSW/C&I Waste-to-Energy Project. 30 August 2019

Synergetics, 2019. Dandenong South waste to energy emission modelling and impact assessment. 12 September 2019

SV, 2018. Statewide Waste and Resource Recovery Infrastructure Plan, Sustainability Victoria. 15 March 2018

Whitehorse City Council (n.d.). Rubbish to Resource! Waste Management Strategy 2018 – 2028. Whitehorse City Council, p. 18

Appendix A Planning Property Report



Planning Property Report

Appendix B Cultural Heritage Due Diligence



Cultural Heritage Due Diligence

Appendix C Preliminary and Detailed Site Investigations



Preliminary and Detailed Site Investigations

Appendix D Traffic Impact Assessment



Traffic Impact Assessment

Appendix E Fire Risk Assessment



Fire Risk Assessment

Appendix F Air Emissions Modelling and Impact Assessment



Air Emissions Modelling and Impact Assessment

Appendix G Environmental Noise Assessment



Environmental Noise Assessment

Appendix H Stormwater Management Plan



Stormwater Management Plan

Appendix I Site Environmental Management Plan



Site Environmental Management Plan

Appendix J Litter Management Plan



Litter Management Plan

Appendix K Emissions Data from Reference Plant



Emissions Data from Reference Plant

Appendix L Stakeholder and Community Engagement and Consultation Plan



Stakeholder and Community Engagement and Consultation Plan

Appendix M Greenhouse Gas Lifecycle Assessment



Greenhouse Gas Lifecycle Assessment

Appendix N Environmental Risk Assessment



Environmental Risk Assessment

Appendix O Human Health Risk Assessment



Human Health Risk Assessment

Appendix P Waste Audit



Waste Audit Commercial in confidence

Appendix Q Fuel Specification



Fuel Specification

Appendix R Sarpsborg 2 Permit



Sarpsborg 2 Permit

Appendix S Fly Ash MSDS



Fly Ash MSDS

Appendix T Bottom Ash Analysis



Bottom Ash Analysis

Appendix U CFA Meeting Minutes



CFA Meeting Minutes

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