WAG consulted with an environmental scientist with professional experience in the regulation of NSW landfills to prepare this part of our submission and have identified a large number of serious issues with the proposed remediation of the Alexandria Landfill site, the planned construction of the St Peters Interchange on this site, and AECOM’s assessment of it:
The new clean-up notice issued by the Environmental Protection Authority (EPA) is not even mentioned in the EIS. This means that information about sampling, testing and removing asbestos is also not included.
There are unacceptable high levels of ammonia which would not have been expected from a landfill that supposedly only accepted inert materials. There is no provision for an industrial discharger to allow material to be safely released into the sewer. There is no explanation for this in the EIS.
Groundwater issues – This EIS outlines an inadequate testing and assurance framework involving potentially dangerous compounds.
Capping of landfills is a crucial issue during landfill closure. The EIS proposes a level of capping which preferences minimising capping over best practice.
No discharge license could be found for RMS. If it has no licence, it is illegal.
No details are provided for how phenolics are being handled. This is a serious oversight.
No leachate modelling is provided in the EIS. The requirement for this was mentioned many times in the Landfill Guidelines.
These issues occur in the context of long-term problems with the Alexandria Landfill site which have continued since the proponent and then the NSW Roads and Maritime Services (RMS) took over the site. WAG is extremely concerned about these matters, which could directly affect the land, groundwater, and health and safety for thousands of residents and businesses over a long period.
In December 2014, the former WestConnex Delivery Authority forcibly acquired the massive Alexandria Landfill own by Dial a Dump. This is the site on which it plans to build the massive St Peters Interchange. Like all long term landfills, it is a highly polluted site.
The community experienced countless pollution problems with the site during the years that Dial a Dump owned it. Eventually, after a Sydney Morning Herald expose of environmental problems with the site, including that it was used for illegal dumping of asbestos , the NSW Environmental Protection Authority (EPA) issued Clean Up notice to remove asbestos from what is known as Stockpile 21 in the south west corner of the site. When Dial a Dump failed to comply with this notice, the EPA extended the notice. The asbestos had still not been removed when the proponent quietly and compulsorily acquired the contaminated site. The landfill site closed and the Clean-Up notice lapsed.
Since 2015, the proponent has been moving material including asbestos contaminated waste from the site and taking it to Erskine Park in Sydney’s West. There have been serious allegations that the proponent did not have relevant approvals for these activities or for the huge amount of excavation and other work that is being carried out on the site. There have been numerous complaints to the EPA about poor practices in the removal of asbestos and more recently noise complaints due to very loud rock crushing. Legal investigations are continuing into these matters.
After the WestConnex Delivery Authority was turned into the private Sydney Motorway Corporation in October 2015, the land was again transferred to RMS. In November 2015, NSW EPA issued a fresh clean-up notice for Stockpile 21. In fact, residents had observed and photographed activities on this stockpile for many months before the fresh notice had even been issued. There were media reports that the proponent was not consistently following regulations of wetting contaminated soil before removal, both at St Peters and Erskine Park where it was dumped.
In addition to the $13 million of public funds, AECOM has been paid to produce this EIS, it also received an additional contract of nearly $2 million to develop a plan for an environmentally safe way to close the site. This is an unacceptable conflict of interest, and it would be disturbing if that had any impact on the substandard quality of this analysis.
Detailed objections to issues with this EIS and its assessment of the Alexandria Landfill
1. New Clean-Up notice not mentioned in EIS
The Clean-up notice issued on 6 November 2015 for License 12594 was not mentioned in EIS. The matters raised were discussed with the EPA prior to 6 November and well before the public release of the EIS. Why wasn’t this matter included in the EIS?
This Clean up notice requires RMS to:
· commence sampling, testing and removal of asbestos waste material in accordance with the Proposal by no later than 7 December 2015. It is essential that this compliance be reported as part of the EIS program to provide surety for the community that RMS is competently managing this contamination issue. What are the results of this testing?
· must undertake air monitoring carried out for the detection of airborne asbestos fibres in accordance with the Air Monitoring Regime during the removal of any material from Stockpile 21 (asbestos stockpile). These results must be publicly released to provide residents with confidence that their health has not been compromised. RMS should disclose the results of this testing.
· When sampling, testing and removal of asbestos waste in accordance with this notice is occurring Stockpile 21 must be sectioned off and access restricted to all staff or any other persons. What evidence is there that these security measures were completed in time to meet the conditions of this notice?
· No leachate modelling is set out in the EIS. This was required by the Secretary of Planning
2. Ammonia Release
Ammonia is released in solid waste landfill through protein degradation under anaerobic conditions. If this landfill had been an inert waste landfill and a resource recovery facility for the last 30 years, where did these elevated ammonia concentrations originate? This is evidence that there was a significant putresible component to the waste in the past which means there needs to be a level of protection during closure commensurate with international best practice which includes the NSW Draft Environmental Guidelines: Solid Waste Landfills 2nd edn JN 2015-0111.
Sydney Water’s ammonia Trade Waste Limit for the site is 100 mg/L (as NH3-N). The average concentration was reported to be 127 mg/L and the maximum was 404 mg/L. Normally, Sydney Water would require an Industrial discharger to commence a project to meet their criteria. Failing to do so would mean that the discharge to sewer can no longer continue. The technology to install a simple nitrification cell is not complex and most large landfills and other industrial dischargers with high ammonia levels have these in place. It is unclear why Sydney Water has not made this a specific requirement for the Alexandria Landfill. The EIS did not identify plan B should Sydney Water cancel the discharge license.
Where would RMS dispose of 730,000 litres of leachate a day if it cannot be discharged to sewer?
3. Other Groundwater contamination/Leachate Issues
· Historically, total recoverable hydrocarbons was an indicator parameter used as an inexpensive means to determine what other contaminants may be present. Testing results show that the TRH C34 to C40 concentrations were elevated. Organic contamination in this carbon range includes Polycyclic aromatic hydrocarbons (PAHs). The EIS identified this group of compounds as one of the contaminants of concern following AECOM’s Phase 2 investigation. Given this level of contamination and concern noted in the phase 2 investigation, it seems unlikely that Naphthalene was the only PAH detected in the leachate. Were other PAHs tested and identified? If not, why not?
· This project’s environmental consultants have contracted Australian Laboratory Services (ALS) as their accredited service provider for analytical testing. Section M3 of EPL licence 4627 requires that all testing be done by methods on NSW EPA’s Approved Methods list. ALS sulfate testing is by their in-house method EN/ED041 G (Sulfate by discrete analyser method) which is not on the list of approved methods.
· ALS have a variety of testing methods that are priced on the basis of detection level and sensitivity. Like many other laboratories ALS have a less expensive GCMS option for straight injection of extracted solvent in the GCMS (EP075/76) for quantifying phenol containing compounds. This method routinely under represents many compounds like pentachlorophenol as it requires derivatisation for full quantitation. As this is a more expensive option, inexperienced consultants will choose this compound. It is noted that pentachlorophenol is commonly found in leachate samples found to contain phenol.
· Section 4 of EPA’s Landfill Guidelines specify that the ionic balance should be ± 5 %. It was found to be up to 10 % during this assessment which is twice the guideline value. This is seen as another indicator of the poor quality assurance framework and lack of environmental expertise associated with this entire investigation.
4. Closure Cover
· Landfills continue to emit contamination for more than 50 years following site closure. For this reason it is essential to follow prescribed practices to ensure that public health and the environment are not at risk. Capping (the top layer of a closed landfill) is designed to inhibit infiltration of water through the landfill to ensure that leachate generation is minimised. The NSW EPA established benchmark techniques in the Landfill Guidelines for capping to ensure that all landfills are designed to control environmental emissions. The capping advocated in the M5 EIS has a greater focus on minimising the depth of the capping layer rather than meeting EPA benchmark requirements. As there is evidence that significant putresible waste was received at the facility, it is essential that the capping material meet the requirements from the guidelines that will be in place as it is closed. The EIS purports to include the Landfill Closure and Management Plan (LCMP) but the details in the EIS are inadequate to be considered as a closure plan. The EIS clearly states that the proponents negotiated with the EPA for a closure program which would result in standards that fall well below targets in the Environmental Guidelines: Solid Waste Guidelines. ( Ed: AECOM were paid $2 million in addition to $13 million for the whole EIS to develop this plan.)
· Looking at the “Alexander landfill Closure Plan Typical Capping Layer” (Figure M5-LDS-SKT-700-320-DR-7805A) as a benchmark, the following deficiencies are noted in relation to the Landfill Guideline Benchmark:
· The Alexander Landfill cap has a re-vegetation level set at 500 mm. The EPA guideline is a revegetation layer at least 1000 mm thick and comprising clean soils and vegetation with root systems that will not penetrate into lower layers. The upper 200 mm should be a topsoil layer, which can include compost to help with vegetative establishment and growth. The revegetation layer should promote water removal by evapotranspiration and runoff; protect the sealing layer from desiccation and/or damage; and sustain microbial populations that oxidise a proportion of any methane passing up through the cap. Clearly the proposed vegetation level does not meet the benchmark.
· The proposed Alexander Landfill cap has a minimum 500 millimetre thick low permeability material layer with permeability of 10 -8 metres per second. The EPA requirement for solid waste landfills is a composite sealing layer, comprising a lower compacted clay layer and an upper flexible membrane liner. The compacted clay layer should be at least 600 mm thick, with an in-situ saturated hydraulic conductivity of less than 1 x 10–9 m/s. The clay should contain no rock or soil clumps greater than 50 mm in any dimension. The Alexander landfill is 17 % less thick and the permeability is 10 times greater than the benchmark. Using simple maths (83 % x0.1), the Alexander landfill is only about 8.3 % as effective as the guideline benchmark.
· The EPA Landfill Guidelines permit a lower level of protection in only two cases, when there was no putresible waste disposed or landfills located in remote arid zones. This was not the case for the Alexander Landfill.
5. Botany Sands Groundwater Extraction Bores
· The groundwater collected in the groundwater extraction bores from the landfill was collected in 50,000 L tanks and discharged into the stormwater drains. An examination of all licences held by RMS could not locate any legal discharge licence near the Alexander Landfill. If RMS does not have a EPL discharge licence than these discharges have been illegal ever since the RMS took control of the site. There is no evidence of any contaminant assessment of these discharges nor comparison compliance with water guideline values.
6. Gas Testing Results
· Table 12 shows vinyl chloride levels as high as 485 ppb in the test samples of landfill gas. This data in 184.108.40.206 is reported without commentary. Since this compound was found at relatively high concentrations in the gas, it is likely that it will be detectable in the ground water and should be tested. Vinyl chloride comes from break down of compounds like trichloroethene and perchloroethene by dehydrohalogenation alkyl halides. For these reasons, not testing nor reporting on the presence of this group of compounds (volatile halocarbons) is seen as an oversight.
· In Section 220.127.116.11 for estimating landfill gas generation rates it was assumed that food waste was removed from the C&I waste stream. This assumption is baseless given the types of gases present and the ammonia level in the landfill leachate. What were the qualifications of the team that made these assumptions? Does a new landfill EIS need to be developed?
7. Table 14
The Landfill Guidelines require phenols be tested as Total phenolics which is identified as the summation of 17 individual phenol-containing compounds identified by USEPA Method 8040 (USEPA 1992). This usually requires GCMS testing following derivatisation in modern accredited laboratories. Many inexperienced consultants often attempt to test for total phenol using the 4 amino-antipyrine (AATP) colourimetric method or GCMS testing without derivatisations since these options are much cheaper. The EIS does not provide details of the specific methods undertaken in this investigation. This is a serious oversight. The 4 AATP method suffers from two problems, it routinely underestimates phenolic concentrations and it does not identify the phenol compound present. Phenol containing compounds have grossly different toxicities so it is important to know which compound is present. Chlorinated phenolics also have lower acceptable concentrations when discharging to sewer.
8. Water Modelling
Landfill environmental management is centred on the need to control water as it moves through a landfill. There are several management options but to make correct decisions it is necessary to conduct a thorough water modelling assessment to examine the mass balance of water entering the system from above and below. This EIS CLMP did not address the issue or strategy for water modelling. Leachate modelling was identified as a necessary requirement in Section 2.3 of the Landfill Guidelines and was mentioned over 50 times throughout the guidelines. Failure to provide any real modelling is a a serious oversight.
· As stated previously, vinyl chloride and other halogenated volatiles found in the landfill gas testing should be analysed in the groundwater as these are often a good markers of landfill contaminated groundwater since they are often in the front of the plume.
WAG formally rejects the EIS’s assessment of the Alexandria Landfill impacts and requests that the Minister reject this proposal.