appendix h - epa.vic.gov.au/media/files/landfill operations... · ensure the lfg management system...

PROPOSED MRL EXTENSION

APPENDIX H Landfill Gas Management Plan

February 2016 Report No. 1528407-007-R

February 2016

LANDFILL OPERATIONS PTY LTD

Landfill Gas Management Plan, Melbourne Regional Landfill, Ravenhall VIC

RE

PO

RT

Report Number. 1528407-023-R-Rev0

Distribution:

1 copy Landfill Operations Pty Ltd

1 copy Golder Associates Pty Ltd

Submitted to:

Landfill Operations Pty Ltd C/- Norton Rose Fulbright

MRL LANDFILL GAS MANAGEMENT PLAN

February 2016 Report No. 1528407-023-R-Rev0 i

Table of Contents

1.0 INTRODUCTION ........................................................................................................................................................ 2

1.1 Scope ........................................................................................................................................................... 2

2.0 LEGISLATIVE OVERVIEW ....................................................................................................................................... 2

2.1 Environment Protection Act 1970 ................................................................................................................. 2

2.2 State Environment Protection Policy (Ambient Air Quality) ........................................................................... 2

2.3 State Environment Protection Policy (Air Quality Management) ................................................................... 2

2.4 Landfill Licensing Guidelines (EPA Publication 1323.2) ............................................................................... 2

2.5 Environmental Guidelines for Reducing Greenhouse Gas Emissions from Landfills and Wastewater

Treatment Facilities (EPA Publication 722) .................................................................................................. 3

2.6 Best Practice Environmental Management, Siting, Design, Operation and Rehabilitation of Landfills

BPEM (EPA Publication 788.3)..................................................................................................................... 3

3.0 SITE OVERVIEW ....................................................................................................................................................... 3

3.1 Topography................................................................................................................................................... 3

3.2 Hydrogeology................................................................................................................................................ 4

3.3 Surrounding Land Use .................................................................................................................................. 4

3.4 Other Site Activities ...................................................................................................................................... 4

3.5 Buffer Zones and Easements ....................................................................................................................... 5

3.6 Final Land Use .............................................................................................................................................. 5

4.0 EXISTING LFG MANAGEMENT SYSTEM ................................................................................................................ 5

5.0 ESTIMATION OF LFG GENERATION ...................................................................................................................... 6

5.1 Methodology ................................................................................................................................................. 6

5.1.1 Uncertainty .............................................................................................................................................. 6

5.2 Input parameters ........................................................................................................................................... 7

5.2.1 Waste Input Rates................................................................................................................................... 7

5.2.2 Waste Breakdown ................................................................................................................................... 8

5.2.3 Cap and Liner Details .............................................................................................................................. 9

5.2.4 Waste Moisture Content and Degradation Rate ...................................................................................... 9

5.3 Model Results ............................................................................................................................................... 9

6.0 LANDFILL GAS RISK ASSESSMENT .................................................................................................................... 13

6.1 Objectives and Methodology....................................................................................................................... 13

6.2 Conceptual Site Model ................................................................................................................................ 13


February 2016 Report No. 1528407-023-R-Rev0 ii

6.2.1 Potential Sources of LFG ...................................................................................................................... 13

6.2.2 Potential Pathways................................................................................................................................ 13

6.2.3 Potential Receptors ............................................................................................................................... 14

6.3 Hazard Identification and Screening ........................................................................................................... 14

6.3.1 Assessment of Hazard .......................................................................................................................... 14

6.3.2 Assessment of Pathways ...................................................................................................................... 15

6.3.3 Assessment of Receptors ..................................................................................................................... 15

6.4 Risk Assessment ........................................................................................................................................ 16

7.0 MONITORING PROGRAM ...................................................................................................................................... 24

7.1 Landfill Subsurface Emissions Monitoring .................................................................................................. 24

7.2 Landfill Gas Surface Emissions Monitoring ................................................................................................ 26

7.3 Landfill Gas Accumulation Monitoring ......................................................................................................... 26

7.4 Reporting .................................................................................................................................................... 26

8.0 CONTINGENCY PLANNING ................................................................................................................................... 26

8.1 Subsurface Gas Emissions ......................................................................................................................... 26

8.2 Surface Gas Emissions .............................................................................................................................. 27

8.3 Accumulation of LFG in Buildings ............................................................................................................... 27

8.4 Ambient Air Emissions ................................................................................................................................ 27

8.5 Odour .......................................................................................................................................................... 28

9.0 LANDFILL GAS CONTROL MEASURES ............................................................................................................... 28

9.1 Landfill Gas Containment System ............................................................................................................... 28

9.2 Landfill Gas Extraction System ................................................................................................................... 29

9.3 Landfill Gas Treatment Strategy ................................................................................................................. 29

10.0 CONCLUSIONS ....................................................................................................................................................... 31

11.0 REFERENCES ......................................................................................................................................................... 32

12.0 IMPORTANT INFORMATION RELATING TO THIS REPORT ............................................................................... 32

TABLES

Table 1: GasSim Model Calibration for Total Bulk Landfill Gas Produced........................................................................... 7

Table 2: Predicted Waste Volumes ..................................................................................................................................... 8

Table 3: Cap and Base Liner Details ................................................................................................................................... 9

Table 4: GasSim Model Results ........................................................................................................................................ 10

Table 5: GasSim LFG Collection Efficiency Estimate (%) ................................................................................................. 11

Table 6: Likelihood categories ........................................................................................................................................... 16


February 2016 Report No. 1528407-023-R-Rev0 iii

Table 7: Severity categories .............................................................................................................................................. 16

Table 8: Severity likelihood matrix ..................................................................................................................................... 17

Table 9: Risk evaluation .................................................................................................................................................... 17

Table 10: Assessment of risk ............................................................................................................................................ 18

Table 11: BPEM landfill gas action levels.......................................................................................................................... 24

Table 12: Typical construction details for landfill gas well construction ............................................................................. 25

Table 13: Containment System design details .................................................................................................................. 28

Table 14: BPEM landfill gas management hierarchy ......................................................................................................... 29

PLATES

Plate 1: Total Bulk Landfill Gas Produced ......................................................................................................................... 10

Plate 2: GasSim Results for LFG Treatment System for 90th Percentile LFG Production ................................................. 11

Plate 3: 90th Percentile Estimated Residual Gases .......................................................................................................... 12

Plate 4: Conceptual cross section for lateral LFG emissions ............................................................................................ 25

APPENDICES

APPENDIX A Figures

APPENDIX B Existing LFG Management System

APPENDIX C GasSim Model Output

APPENDIX D Important Information Relating to this Report


February 2016 Report No. 1528407-023-R-Rev0 1

ABBREVIATIONS

AHD Australian Height Datum

C&D Construction and Demolition

C&I Commercial and Industrial

CCL Compacted Clay Liner

EPA Environment Protection Authority Victoria

FID Flame Ionisation Detector

GCL Geosynthetic Clay Liner

HDPE High Density Polyethylene

IQZ Intermittent Quarry Zone

LFG Landfill Gas

LLDPE Linear Low Density Polyethylene

MRL Melbourne Regional Landfill

MSW Municipal Solid Waste

NGER National Greenhouse and Energy Reporting (Measurement) Determination

ppm parts per million

SEPP State Environment Protection Policy



1.0 INTRODUCTION

Golder Associates was engaged by Landfill Operations Pty Ltd (Landfill Ops) to prepare a Landfill Gas

Management Plan to support a Works Approval Application for the proposed extension to the MRL facility

(the Extension). This report presents the results of our assessment and must be read in conjunction with the

main Works Approval Application report.

1.1 Scope

The Extension will be categorized as a Type 2 municipal waste landfill; accordingly landfill gas (LFG)

production is expected. The scope of this LFG Management Plan is to ensure that air quality objectives are

met in accordance with relevant legislative requirements including the BPEM, SEPP’s and Works Approval

Guidelines, in particular Part B Section 12.4.4.4.

The proposed LFG Management system is designed to control the migration of LFG from the proposed

extension to MRL to meet the following objectives;

Prevent impacts to human health, safety and the environment;

Minimise greenhouse gas emissions;

Prevent off site nuisance odours; and

Meet regulatory requirements.

The Plan provides a summary of existing site conditions and LFG management systems and addresses

management of LFG for the proposed extension to the MRL facility. A site conceptual model and LFG risk

assessment has been prepared as a basis for the LFG management and monitoring strategy. The treatment

options were evaluated in accordance with the estimated LFG generation rates projected for Extension.

2.0 LEGISLATIVE OVERVIEW

2.1 Environment Protection Act 1970

The Environment Protection Act is a key piece of legislation in Victoria that aims to prevent pollution and

environmental damage by setting environmental quality objectives. The Environment Protection Act

establishes the Environment Protection Authority (EPA) as the Regulator for environmental management.

2.2 State Environment Protection Policy (Ambient Air Quality)

The State Environment Protection Policy (Ambient Air Quality) (Victorian Government 1999) sets air quality

objectives for Victoria. Ambient air quality standards are specified for six common air pollutants including

CO, NO2, SO2, ozone, particulates and lead. There are no ambient air quality standards set for methane.

2.3 State Environment Protection Policy (Air Quality Management)

The State Environment Protection Policy (Air Quality Management) (Victorian Government 2001) establishes

a framework for the management of air pollutant emissions in Victoria. Management protocols are provided

to satisfy air quality objectives. Under this policy, emission limits for stationary sources are defined. MRL is

located within the Port Phillip Quality Control Region.

2.4 Landfill Licensing Guidelines (EPA Publication 1323.2)

The Landfill Licensing Guidelines dated August 2011, (EPA Publication 1323.2) provides a guide to

satisfying landfill gas management licensing conditions. An approach to performing a LFG risk assessment

is provided.



2.5 Environmental Guidelines for Reducing Greenhouse Gas Emissions from Landfills and Wastewater Treatment Facilities (EPA Publication 722)

EPA Victoria has provided information on best practice management of greenhouse gas emissions from

landfills and wastewater treatment facilities. The guidelines, published in November 2000, aim to assist

operators in preparing strategies for waste minimisation, reuse, recycling and energy recovery.

2.6 Best Practice Environmental Management, Siting, Design, Operation and Rehabilitation of Landfills BPEM (EPA Publication 788.3)

The objective of the BPEM guidelines in relation to LFG management is to establish a framework to minimise

risk of uncontrolled LFG emissions to the environment. The BPEM requires landfills to monitor and manage

LFG generated as a result of the biodegradation of the landfilled waste. This includes;

Undertake a site-specific LFG risk assessment.

All practicable measures must be taken to prevent exceedance of the landfill gas action levels.

Develop and implement an appropriate LFG management system.

Implement a LFG monitoring program in accordance with the Landfill licensing guidelines, EPA

Publication 1323.

Implement a landfill gas remediation action plan in the case that action levels are exceeded.

Ensure the LFG management system complies with the LFG management hierarchy.

Notify EPA Victoria within 24 hours of detection of any exceedances of the action levels, except for

those rectified within 24 hours.

3.0 SITE OVERVIEW

The site is located approximately 20 kilometres west of the Melbourne Central Business District in Ravenhall,

within the Melton City local government area. The site is bounded by Hopkins Road to the west, the Melton

Rail Line to the north, Christies Road to the east and Middle Road to the south. The site has a total area of

approximately 1,150 hectares. A site layout plan is provided in APPENDIX A.

Boral established a basalt quarry at the site in 1968. Quarried land is progressively released to Landfill Ops

for landfilling activities. Landfill Ops currently operate a landfill in the south east of the site, referred to as the

‘Existing Landfill’. Landfilling of the Existing Landfill began in 1999. The Existing Landfill operates seven

days per week and accepts municipal waste and waste from private waste companies and industries. The

remaining capacity of the Existing Landfill is approximately 7-10 years.

The Extension will comprise engineered cells with leachate and landfill gas collection and treatment systems

including interim and final capping as detailed in section 18.0 of the Works Approval Application. The

forecasted life of the Extension landfill is 30 years comprising approximately 13 years in the South Portion

and 17 years in the North Portion.

3.1 Topography

The topography of the site is dominated by the disturbed land caused by surrounding quarrying activities.

The quarry hole is typically excavated to an approximate depth of 10 metres below surface level. The

general slope of the quarry floor is from north to south.

The surrounding surface topography comprises undulating terrain with a rise in elevation towards Mt

Atkinson volcanic cone landform located to the north west of the site. The natural surface water flow is from

the North West to the south east.



Landfilling activities in the south east of the site at the Existing Landfill have resulted in elevated contours

with waste mounded above the surrounding land level. The highest point of the Extension is expected to be

approximately 40 metres above the natural surface level in the North Portion.

3.2 Hydrogeology

The site is located within the Werribee Plains Newer Volcanics, which consists primarily of basalt, scoria and

agglomerate with intervening weathered horizons and paleosols. The Newer Volcanics were likely erupted

from Mt Atkinson. The Newer Volcanics overlies the Brighton Group and Fyansford Formation which overlie

the Werribee Formation. Geological assessments have identified a number of separate basalt flow zones in

the walls of the former quarry. The quarry is located mainly in the upper basalt flow.

The three main hydrogeological units located at the site starting from uppermost are:

An unconfined aquifer in the Quaternary Age Newer Volcanics, comprising basalt and basal silty clays;

Unconfined or semi-confined deeper aquifers in the Newer Volcanics basalts; and

Basal Werribee Formation aquifer.

The uppermost aquifer flow occurs in fractures, joints, vesicular openings and in the contact zone between

basalt flows. Groundwater flows from northwest to south east and is primarily recharged by the infiltration of

rainfall.

3.3 Surrounding Land Use

The site is surrounded by the following land uses;

North: an industrial zone (IN3Z) acts as a buffer to low density residential areas of Caroline Springs,

Rockbank, Burnside and Deer Park.

South: the site is bounded by farming area (FZ) with land designated for urban growth (UGZ) beyond.

West: agricultural land (FZ) designated in the West Growth Corridor Plan for future industrial use

East: the land use designation to the east is divided into a farming zone (FZ) in the north and special

use zone (SUZ8) and land designated for public conservation and resource (PCRZ) in the south.

3.4 Other Site Activities

Several other activities are carried out on the site. The following facilities and buildings are located within the

site boundary;

Run Energy - Conversion of LFG to renewable energy at the bio gas plant;

Landfill Ops - Leachate and stormwater storage ponds;

Victoria Police training facility accessed from Christies Road;

Boral Asphalt plant;

Masonry plant;

Boral Concrete batching plant;

Quarry plant; and

Site offices.



3.5 Buffer Zones and Easements

The landfill cell design is restricted by several buffer zones and easements to comply with legislation and

planning schemes. The buffer zones and easements are shown on the Sensitive Receptors Plan (Appendix

A). The following buffer zones apply to the Extension;

Active quarry buffer: There is a 250 metre buffer zone between landfill working faces and active

quarrying. In the event that this buffer zone is entered, landfilling operations will need to evacuate the

area temporarily during blasting rock activities and resume works once the area has been cleared.

Residential buffer: a 500 metre buffer distance to sensitive receptors is maintained between landfill

cells and residential homes to the south west of the site in accordance with BPEM requirements.

Typical buffer distances are greater than 1 kilometre to residential zones.

Powerline easement buffer: An approximate 65 metre buffer zone is maintained for powerline

easements. A power line is located in the south east of the site (South Portion) and across the north

west corner (North Portion).

Surface water buffer: In accordance with BPEM requirements a 100 metre buffer zone is to be

maintained from surface waters. Skeleton Creek is located to the south west of the site and designated

as Land Subject to Inundation by the Melton Planning Scheme. Stream flow only occurs after heavy

rainfall events. This intermittent flow is referred to as an ‘ephemeral stream’, often dry with periods

when it is wet during heavy rainfall events.

Landscape buffer: A landscape buffer approximately 100 metres wide surrounds the existing quarry

operations adjacent to Hopkins Road (western boundary) and the Melton Rail Line (northern boundary)

as shown on Figure 4. The buffer along Riding Boundary Road, Christies Road and the southern site

boundary is approximately 60 metres wide, as shown on Figure 4. This landscape buffer includes

vegetation and earth bunds to visually screen the site from surrounding roads and to provide a wind

break. The landscape buffer zone is required to be progressively maintained by the quarry surrounding

all extraction areas.

3.6 Final Land Use

The remediated MRL site is currently intended to be used as public open space. The landscaping and

revegetation plan is designed to meet the requirements of the final land use. A shared pedestrian and

bicycle access track will allow future users to reach the landfill summit and a lookout point(s).

4.0 EXISTING LFG MANAGEMENT SYSTEM

The Existing Landfill includes an active LFG extraction system with flares and gas engines that consists of

perforated horizontal LFG collection pipes installed within the waste, located in certain sub-cells in Stage 2,

as shown on figure 27. The pipes are backfilled with gas drainage aggregate and positioned according to

the cap shape. In addition, vertical LFG wells are installed and connected to the gas collection system, as

shown in APPENDIX B. There are currently 24 gas collection wells installed in Stage 1 and 287 wells

installed in Stage 2 of the Existing Landfill. The gas collection network plan is provided in APPENDIX B. A

recent upgrade to the LFG collection system is underway to repair a LFG header line.

The LFG treatment system involves active extraction for electricity generation with off time flaring. The

existing landfill gas management infrastructure is owned by Landfill Ops and managed under contract by

Run Energy Pty Ltd. The first engine was installed in 2006. The LFG extraction system is planned to be

progressively installed to minimise uncontrolled LFG emissions. Condensate knock out pots are installed to

separate moisture from the gas prior to reaching the generators or flares. The condensate produced is

treated as leachate.



5.0 ESTIMATION OF LFG GENERATION

5.1 Methodology

A landfill gas simulation model, GasSim V2.5 (GasSim) has been used to model the potential LFG

generation for the MRL Extension. GasSim is a commercially available (and independently verified) LFG

resource assessment and risk assessment model developed by Golder for the Environmental Agency in the

United Kingdom.

Waste tonnages, waste breakdown and composition of individual waste streams are input into the model to

estimate the gas generation capability of the waste. GasSim follows a first-order decay model that estimates

landfill gas generation. Default values are provided for most parameters, however where available, site

specific data from the Existing Landfill was used to adapt the model to the proposed Extension. Where site

specific data is not available, assumptions have been made and published data, including GasSim default

values, were used to supplement the data inputs to the model. The model has a modular structure, where

each module incorporates the effects of additional processes.

The GasSim model was used to estimate potential landfill gas generation from the Extension. The

estimation of LFG generation contributes to the development of the conceptual site model for the Extension

used in the LFG risk assessment, as discussed below.

5.1.1 Uncertainty

It is noted the GasSim model is a predictive tool and should not be relied upon for exact landfill gas

generation rates, rather its purpose in this application is to provide an indicative order of magnitude estimate

of landfill gas generation from the MRL facility extension. The GasSim model uses a simplified first order

decay model of landfill gas generation to allow the application of equations to create a model. Variations to

the estimate of landfill gas generated may be influenced by complex site conditions not addressed in the

model, hence the results should be considered as estimates for the purpose of this Works Approval

Application.

Many properties and processes involved in landfill gas generation are naturally variable. GasSim uses

statistical distributions or Probability Density Functions (PDFs) to characterise most of the input parameters.

Each time a modelling iteration is carried out, a value from the defined input distributions is selected by

computer code. Each result is stored, such that after many repetitions an output distribution for gas

production is obtained.

The distribution output for the gas production is provided in terms of percentiles. These specify the

probability with which a certain value will not be exceeded. For this assessment, the results have been

presented at the 50th and 90th percentile probability of exceedance.

The model was calibrated using actual site data from the Existing Landfill collected during the period from

2011 to 2015. The gas flows from 250 landfill gas wells, engine output rates and volume of gas sent to the

flares was provided for comparison.

Table 1 presents the difference between the GasSim model output and real data collected between 2011 and 2014.



Table 1: GasSim Model Calibration for Total Bulk Landfill Gas Produced

Actual Data Set (m3/hr) GasSim Model – 90th Percentile (m3/hr)

2011 3 510 3 710

2012 3 820 4 140

2013 5 140 4 560

2014 5 160 5 320

The total bulk LFG produced for the Existing Landfill site was estimated based on the amount of LFG being

used by the generators and flares in the existing landfill gas compound. Collection efficiency was then

applied to estimate the total amount of LFG being produced by the waste. Lower collection efficiency was

adopted in the earlier life of the LFG collection system. The existing gas collection system was installed

retrospectively; therefore lower collection efficiency was applied to the model.

The GasSim model for the Extension uses idealised gas collection efficiencies that may vary from the actual

flare and generator utilisation rates. The collection efficiency is anticipated to increase for the MRL Extension

due to advances in technology over the life of the MRL facility. Also, the proposed progressive installation of

sacrificial horizontal gas collection trenches during waste filling within each landfill cell will lead to an

increase in the collection of landfill gas within the life of each landfill cell.

5.2 Input parameters

5.2.1 Waste Input Rates

Individual waste streams were input into the model to estimate the gas generation capability of the waste.

Where available, site specific data has been used. The Existing Landfill is licensed to accept;

Putrescible waste;

Non-putrescible waste;

Tyres shredded into pieces less than 250 mm; and

Category C (low level) contaminated soil.

The waste mix types permitted to be received by the MRL extension is expected to remain constant for

future cells 1 to 16. The estimated rate of landfilling was provided by Landfill Ops based on historical data

and predicted future waste catchment size.

The density of the modelled waste was characterised by a triangular distribution of 0.75 t/m3, 0.95 t/m3 and

1.2 t/m3. This assumes a minimum waste density of 0.75 t/m3, maximum waste density of 1.2 t/m3 and a most

likely waste density of 0.95 t/m3. Table 2 presents a breakdown of the predicted volumes and sequencing for

each cell of the Extension.



Table 2: Predicted Waste Volumes

Cell Capacity

(Million m3)

Estimated Tonnages

(Million t)1

Cell Life

(years)

Cell 1 3.3 3.1 1.9

Cell 2 3.8 3.6 2.2

Cell 3 3.9 3.7 2.2

Cell 4 3.2 3.0 1.8

Cell 5 3.6 3.5 2.1

Cell 6 3.4 3.2 1.9

Cell 7 2.2 2.1 1.2

Sub-Total South Portion

23.3 22.2 13

Cell 8 1.7 1.6 1.0

Cell 9 3.8 3.6 2.2

Cell 10 3.6 3.4 2.0

Cell 11 3.1 2.9 1.8

Cell 12 3.9 3.7 2.2

Cell 13 3.6 3.4 2.0

Cell 14 2.7 2.6 1.6

Cell 15 3.6 3.4 2.1

Cell 16 3.7 3.5 2.1

Sub-Total North Portion

29.7 28.2 17

TOTAL 53 50.4 30

Note 1 – waste density based on 0.95 t/m3

5.2.2 Waste Breakdown

To estimate the landfill gas production ability of the waste, GasSim requires definition of the waste

breakdown and composition of individual waste streams. The model waste composition is based on the

default values provided in the National Greenhouse and Energy Reporting (Measurement) Determination

2014 (NGER). The values for Victorian municipal solid waste (MSW), construction and demolition (C&D)

waste and commercial and industrial (C&I) waste were adopted.

The waste breakdown was estimated based on waste stream information from the Landfill Ops NGERS data

for the period up to 2015 and predicted waste volumes provided by Landfill Ops for the future period.

Information from Landfill Ops for the period up to 2015 has been included in order to calibrate the model.



5.2.3 Cap and Liner Details

For a landfill gas modelling assessment the cap and base liner details are used to estimate the partitioning

between lateral and surface emissions of landfill gas. The cap and base liner details for future Cells 1 to 16

comply with BPEM requirements for Type 2 municipal waste landfills. Table 3 presents the cap and base

liner details used in the GasSim model.

A progressive installation of sacrificial horizontal gas collection trenches is assumed to be installed 3 months

after the start of waste filling within each landfill cell as per Section 18.3.1 of the WAA (Works Approval

Application). The interim cap is assumed to be progressively constructed after the completion of waste filling

in each cell and a final cap is to be constructed two years after finalizing waste filling and progressively

capping each cell. The type and sequencing of capping affects the amount of uncontrolled landfill gas

surface emissions and thereby the proportion of gas that may be collected by the landfill gas extraction

system. We assumed that after installing the final cap it will take 3 months to construct and commission the

vertical LFG wells. Final capping is assumed to occur as per the sequence plan in the WAA. .

Table 3: Cap and Base Liner Details

Landfill Base Liner Construction Landfill Cap Construction

Existing Landfill

Stage 1

Single clay liner: 1 m CCL

Single clay cap: 1.5 m CCL

Existing Landfill

Stage 2A-2D

Single clay cap: 1.5 m CCL/Evapotranspiration Cap

Existing Landfill

Stage 2E- 2K Composite liner: HDPE Geomembrane and 1 m CCL

Existing Landfill

Stage 2L – 2M Composite liner: HDPE geomembrane, GCL, 0.5 m CCL

Existing Landfill

Stage B

Composite liner: HDPE geomembrane, GCL, 0.5m CCL

Composite cap: 0.6m CCL, LLDPE geomembrane, drainage geocomposite, 0.85 m subsoil, 0.15 m topsoil

Existing Landfill

Stage 3A – 3D

Existing Landfill

Stage 4A – 4C

Landfill Extension

Cells 1 - 16 Composite liner: HDPE geomembrane, GCL, 0.5m CCL

Composite cap: 0.6m CCL, LLDPE geomembrane, drainage geocomposite, 0.85m subsoil, 0.15m topsoil

5.2.4 Waste Moisture Content and Degradation Rate

The waste moisture content and degradation rate default values were used in the GasSim model. A

moderate degradation rate for average moisture conditions was assumed. The model used the default k-

value of 0.076. Compared to the NGER k-value range of 0.02 to 0.06, the GasSim degradation rate is

considered a conservative estimate. The model parameters assume the waste is inert for the initial three

months following waste deposition and then the waste begins to degrade to form landfill gas. The BPEM

supports this assumption that significant quantities of landfill gas (in particular methane) are typically

produced between 3 to 12 months following waste deposition.

The infiltration rate of rainfall through the uncapped waste is based on weather data from the RAAF Base

Laverton Bureau of Meteorology weather station (08731). The average annual rainfall was estimated to be

approximately 536 mm/year.

5.3 Model Results

The GasSim model estimates LFG generation for both the Existing Landfill and the Extension, from

commencement of the Existing Landfill in 1999 to the start of the Extension and then onwards to include the



Extension operational and post closure period. Based on the assumptions and future predictions stated

above, the results of the GasSim modelling suggests that peak LFG generation, in the order of 24 090

m3/hour, occurs in 2055 at completion of filling of the North Portion landfill cells. The predicted indicative gas

generation curve is shown in Plate 1.

The GasSim model estimates of landfill gas generation at the 50th and 90th percentiles are summarised in

Table 4. A summary of the GasSim model annual gas production estimate is attached in APPENDIX C.

Table 4: GasSim Model Results

Year

Model Gas Generated (50th percentile)

(m3/hr)

Model Gas Generated (90th percentile)

(m3/hr)

Total Bulk Landfill Gas Produced

2025 (Finish filling of Existing Landfill, Begin filling of Cell 1 the Extension)

13 140 (Existing Landfill)

13 560 (Existing Landfill)

2055 (maximum gas production) 23 550 (Extension) 24 090 (Extension)

Plate 1: Total Bulk Landfill Gas Produced

The model estimates that a total of 27 landfill gas engines will be required at peak LFG generation. This

assumes that the spark ignition engines have an operational capacity of 350 m3/hour to 650 m3/hour of LFG.

Plate 2 compares the total LFG combusted by the proposed flares and engines to the total LFG produced by

the landfill. The efficiency of the LFG collection system is summarised in Table 5. The model assumes a

triangular distribution for collection efficiency. For example, the final LFG collection system with final cap

constructed has a minimum collection efficiency of 90% and maximum of 97.5%, with a likely efficiency of

95%.

Existing

Landfill

Extension Post

Closure



For Cells 1 to 16, the following timeframe was assumed for installation of the LFG collection system;

Horizontal wells are installed 3 months after start of filling.

There is no cap during waste filling of the cell.

The interim cap is installed at the end of waste filling.

The final cap is constructed approximately one year after construction of the interim cap.

Table 5: GasSim LFG Collection Efficiency Estimate (%)

No Cap Interim Cap Final Cap

Horizontal Wells TRIANGULAR(10.0, 30.0, 50.0)

TRIANGULAR(40.0, 50.0, 60.0)

TRIANGULAR(55.0, 65.0, 75.0)

Vertical Wells (Final gas collection system)

TRIANGULAR(50.0, 60.0, 70.0)

TRIANGULAR(75.0, 85.0, 95.0)

TRIANGULAR(90.0, 95.0, 97.5)

Plate 2: GasSim Results for LFG Treatment System for 90th Percentile LFG Production

As shown on Plate 2 the proposed landfill gas system for the Extension will collect vast quantities of landfill gas. The majority of this gas will be converted into electricity and a limited amount will be flared associated with gas engine maintenance and operational capacity. The GasSim model estimated the quantity of residual gases. The residual gas is the LFG that is not collected by the engines and the flares and emitted through the surface and laterally. The residual gas is taken account of in the risk assessment that follows below. Plate 3 shows the 90th Percentile estimated total residual gases.

Post Closure

Existing

Landfill

Extension



Plate 3: 90th Percentile Estimated Residual Gases

Post Closure Existing Landfill Extension



6.0 LANDFILL GAS RISK ASSESSMENT

6.1 Objectives and Methodology

The objective of the LFG risk assessment is to address the potential hazards and risks associated with LFG

generation at the MRL Extension. This LFG risk assessment has been undertaken in general accordance

with the following guidelines;

Best Practice Environmental Management for Siting, Design, Operation and Rehabilitation of Landfills

(BPEM) Publication 788.3, dated August 2015.

The EPA Victoria Landfill Licensing Guidelines Publication 1323.2, dated August 2011.

Closed Landfill Guidelines, EPA Victoria (EPA) Publication 1490, dated December 2012.

Framework and principles described in the UK Environment Agency Guidance on the management of

landfill gas, dated 2004.

LFG monitoring data from the Existing Landfill, and the proposed design for the Extension were used to form

the basis of this LFG risk assessment. The following steps were taken to assess the site specific risks

associated with LFG generation;

A site specific conceptual model has been developed to evaluate the interaction between risk sources,

pathways and receptors and potential consequences.

Hazards were identified and risk screening undertaken.

The level of risk was assessed using a qualitative matrix by considering the likelihood of a risk occurring

and the magnitude of an adverse consequence.

It is anticipated this LFG risk assessment would undergo periodic review as part of the operation of the

landfill and would be progressively updated to include cell capping, landfill activities, monitoring results, and

rehabilitation works or changes to surrounding land uses.

6.2 Conceptual Site Model

The conceptual site model was developed to provide an understanding of potential risk sources, pathways

and receptors for the Extension. The aim of the model is to identify possible hazards associated with the

generation of landfill gas for the proposed Extension.

6.2.1 Potential Sources of LFG

As a municipal waste landfill, MRL is expected to produce a significant quantity of LFG, as described above.

LFG may be generated via three processes;

Bacterial decomposition: the majority of LFG is produced when naturally occurring bacteria within the

waste breaks down the organic material.

Volatilization: organic compounds present in the waste may change from a liquid or solid into a vapour

contributing to the generation of LFG.

Chemical reactions: certain chemicals within the waste may react to generate LFG.

The rate, volume and quality of LFG is dependent on the waste composition, age of the waste, moisture

content, presence of oxygen and temperature of the landfill. The projected indicative rate of LFG generated

at the Extension is estimated in Section 5.0.

6.2.2 Potential Pathways

The natural tendency of LFG is to diffuse and flow out of the landfill to the surrounding areas with lower gas

concentrations. LFG will tend to migrate from areas of higher pressure to lower pressure such as from the

landfill pressure to atmospheric pressure. The ability of LFG to migrate is restricted by the permeability of



the surrounding media. Gases that are lighter than air, such as the methane component of landfill gas, tend

to move upwards. However, where compacted or saturated waste layers and/or landfill caps are present to

impeded flow, the gas can migrate horizontally (lateral migration) as pressure driven flow until it can resume

the upward path. LFG that is heavier than air, such as the carbon dioxide component of landfill gas, tends to

accumulate at the bottom of subsurface structures such as services trenches or basements.

The potential pathways for LFG migration for the proposed site include:

Direct release to atmosphere from surface emissions, leachate extraction points and gas collection

points;

Subsurface migration via subsurface trenches, pipes and pits;

Subsurface migration via side wall and geological strata; and

Migration of dissolved LFG in leachate or groundwater.

6.2.3 Potential Receptors

Potential receptors include;

Employees, contractors and site visitors;

Residential properties near MRL;

Ecology of Skeleton Creek located to the south west of the site; and

Flora and Fauna of the Northern Grasslands reserve in the north east corner of site.

6.3 Hazard Identification and Screening

The LFG risk assessment assessed potential sources of risk, and associated pathways and receptors

identified in the conceptual model. The following process was undertaken to identify hazards and evaluate

their severity;

Hazard assessment: this considers the emission source and potential contaminants as well as events

or accidents throughout the different phases of the landfill.

Pathway assessment: the surrounding geology, hydrogeology, subsurface infrastructure, atmospheric

conditions are assessed to assess exposure to receptors.

Receptor assessment: The sensitivity of receptors was assessed including residents, surface water,

land of environmental significance, on site buildings and structures.

6.3.1 Assessment of Hazard

The main source of the hazard is identified as the degradation of waste deposited at the landfill. The source

was characterised in the conceptual model with the estimate of potential LFG generation rates (Section 5.0).

The modelling results indicate that LFG generation is a consideration for the MRL site.

The hazards associated with LFG include;

Impacts to humans;

Risk of explosion and or fire damage to persons, buildings and structures;

Particulate emissions from combustion;

Impacts on groundwater; and

Impacts on local habitat and human amenity.

Potential for asphyxiation in confined spaces.



6.3.2 Assessment of Pathways

The site is located within the Werribee Plains Newer Volcanics, consisting primarily of basalt, scoria and

agglomerate with intervening weathered horizons and paleosols. These areas present a risk for LFG

migrating through the fractured rock pathways. The upper basalt layer where the landfill is positioned has a

low hydraulic conductivity (0.1 to 0.5 m/day). The water table varies from approximately RL49 mAHD to

RL75 mAHD under the proposed landfill cells, with a minimum 2 metres of separation between the waste

and groundwater. Based on the surrounding geology and subsurface infrastructure the following pathways

were identified;

Gas migration through the sub-surface geology into buildings and structures.

Gas migration through the sub-surface geology into underground service trenches and pits and then

into buildings.

Direct release to atmosphere.

6.3.3 Assessment of Receptors

The key potential receptors for exposure to LFG at the site are considered to include;

Onsite:

Employees, maintenance workers and Contractors;

Site huts and buildings where employees congregate;

Visitors to the site; and

Workers in trenches and excavations.

Offsite:

Members of the public and residents; and

Offsite personnel and workers in offsite excavations or trenches.

The closest receptors or sensitive land uses to the site are shown on Figure 4 (APPENDIX A) and

summarised as follows:

The closest sensitive residential receptors are to the south west of the site approximately 500 metres

from the proposed landfill footprint.

The closest sensitive receptor to the east of the site is the Dame Phyllis Frost Centre, a women’s prison

compound at a distance of approximately 650m from the landfill.

The closest environmental receptor is Skeleton Creek which is designated as land of environmental

significance and land subject to inundation located approximately 100 metres at the closest point to the

west of the southern portions cells. The extent of the area of significance is defined by the Melton

Planning Scheme.

A designated Northern Grasslands reserve, located in the north eastern corner of the site, has been

identified as an environmental receptor.

Onsite industrial receptors include the buildings and plant associated with the Boral Quarry operations

including a concrete facility, quarry plant, asphalt plant, associated offices ,amenities and a third party

masonry facility.

A police training facility is located on the eastern edge of the site.



6.4 Risk Assessment

Our qualitative risk assessment rates the Extension as an ‘Acceptable’ risk as described below.

The qualitative risk assessment was adapted from the UK Environment Agency Guidance on the

management of landfill gas (2004). The likelihood categories, severity categories, severity likelihood matrix

and Risk evaluation scores are provided in Tables 6 to 9.

Table 6: Likelihood categories

Category Range

1 Extremely unlikely Conditions are theoretically possible, but are unheard of in the landfill industry

2 Very unlikely Conditions are rarely encountered in the landfill industry

3 Unlikely Conditions are encountered several times in the landfill industry, however it is reasonable to assume that these conditions will not present themselves onsite

4 Somewhat unlikely Conditions are assumed to present themselves onsite during the lifetime of the landfill

5 Fairly probable Conditions are assumed to present themselves onsite several times during the lifetime of the landfill

6 Probable Conditions are assumed to present themselves onsite

Table 7: Severity categories

Category Definition

1 Minor

No health impacts

Nuisance on site only

No off site complaint

2 Noticeable

Noticeable nuisance off-site .e.g. discernible odours, loose rubbish

Minor breach of permitted emission limits, but no environmental harm

One or two complaints from the public

3 Significant

Sustained nuisance, .e.g. strong offensive odours

First aid required

Numerous public complaints

4 Severe

Large environmental release or incident which directly affects offsite receptors

Hospital treatment required

Public warning and off-site emergency plan invoked

5 Major

Major evacuation of local population (residents)

Permanent disabling injuries sustained or fatality

Serious toxic effect on beneficial or protected species

Widespread but not persistent damage to land

6 Catastrophic

Substantial offsite impacts to broader environment, long-term environmental damage, extensive clean-up required

Complete failure of environmental protection controls

Site shutdown



Table 8: Severity likelihood matrix

Likelihood Severity of consequence

Minor Noticeable Significant Severe Major Catastrophic

Extremely unlikely 1 2 3 4 5 6

Very unlikely 2 4 6 8 10 12

Unlikely 3 6 9 12 15 18

Somewhat unlikely 4 8 12 16 20 24

Fairly probable 5 10 15 20 25 30

Probable 6 12 18 24 30 36

Table 9: Risk evaluation

Magnitude of risk Score

Insignificant 6 or less

Acceptable 8 to 12

Unacceptable 15 or more

The risk levels identified in Table 9 are described;

Insignificant: the risk is negligible or low impact to receptors, perhaps reported by the public as a

nuisance.

Acceptable: the risk to the receptors is considered to be acceptable due to control measures and

available monitoring data.

Unacceptable: the risk to receptors is considered high due to lack of data, or control actions.

Assessment of potential risks is based on the sensitivity of receptors, emission target limits and potential

impacts. Due to the proportion of putrescible waste estimated to be received by MRL, the associated LFG

generation rates are notable, as discussed in Section 5. Potential hazards include; fire, explosion,

asphyxiation, toxicity to humans, flora and fauna, odour, corrosive gases, emission of greenhouse gases,

and contribution to photochemical smog. However due to the location of the site and conservative buffer

zones, the risks are considered to be low.

The mitigation measures listed below control the migration of LFG to reduce the risk to health safety and the

environment.

The new cells in the Northern Portion are designed with a one kilometre buffer zone to future potential

sensitive receptors. The new cells in the South Portion are designed with a minimum 500 metre buffer

zone to sensitive receptors.

The base liner and capping systems are designed to BPEM standards to minimise the uncontrolled

migration of generated LFG.

Regular monitoring of LFG wells around the perimeter of the site detect if LFG is migrating outside the

landfill footprint.

Regular monitoring of surface emissions detects LFG emissions where they exceed EPA BPEM criteria

and identifies areas that require upgrading or rectification.

The landfill will also be progressively rehabilitated, with a gas extraction system, an interim capping

system being placed after completion of waste filling and the final cap to be constructed as per the

sequence plan.

Table 10 presents the results of the Risk Assessment.



Table 10: Assessment of risk

Location Hazard or Environmental Element/Aspect

Receptors Potential Impact Pathways for risk Existing Controls Likelihood Consequence Level of Risk

Within the site boundary

Lateral migration of Residual LFG generated within the waste deposited at MRL

Employees, Contractors, maintenance workers and site visitors.

Asphyxiation through accumulation of LFG in confined spaces.

Migration of LFG from the landfill through the rock/soil profile and underground services to onsite buildings.

Gas monitoring wells have been installed around the Existing Landfill and are monitored quarterly.

Gas monitoring wells are to be constructed around the perimeter of the Extension and monitored.

Construction of BPEM compliant side-wall liner and base liner in addition to installation of active gas extraction and treatment system.

2 Very Unlikely

5 Major 10 Acceptable

Explosion or fire of LFG in confined spaces.

2 Very Unlikely



Residual LFG venting through trenches or excavations


Asphyxiation through accumulation of LFG in confined spaces such as utility trenches, pits, manholes or drains. Migration of LFG from

the landfill through the soil/rock profile and underground services to trenches or excavations.

The risk posed by LFG migration within trenches will be addressed prior to excavations commencing. A works permit is required that documents health and safety requirements prior to commencing works.

Gas monitoring wells have been installed around the Existing Landfill site and are to be constructed for the Extension and are monitored quarterly.

All ignition sources are removed from the affected area.

2 Very Unlikely


Explosion of fire of accumulated gas in confined spaces, such as utility trenches, pits, manholes or drains.

2 Very Unlikely







LFG extraction system pulls in oxygen from outside of the cell.


Fire within the waste caused by the addition of excess oxygen.

Migration of LFG within the explosive limit through the gas collection system.

Automatic and manual isolation valves shut down the defective section of the gas collection system.

Quarterly monitoring of LFG composition detects high levels of oxygen and carbon dioxide which indicate the likelihood of a landfill fire. LFG temperature is also monitored.

Comprehensive data is collected in real time from the gas extraction system that provides information on gas composition.

2 Very Unlikely



Risk of odour, and impact to human health.


Odour caused by ineffective cap/ damage to cap and toxicity risk.

Direct release of LFG to the atmosphere through uncapped waste, leaks from gas collection infrastructure or leachate extraction wells.

Leak detection monitoring is carried out across the surface of the landfill on a biannual basis.

Periodic inspections of the integrity of the landfill cap during routine operations.

Regular use of daily cover and interim cover during the waste filling operations

BPEM compliant landfill cap and base liner and active gas extraction.

4 Somewhat Unlikely

2 Noticeable 8 Acceptable






Risk of explosion


Explosion caused by rupturing of gas lines by excavation or collision with plant, ignition of LFG at leak.

Direct release of LFG to the atmosphere through uncapped waste, leaks from gas collection infrastructure or leachate extraction wells.

BPEM compliant landfill cap and base liner and active gas extraction.

Quarterly monitoring of gas wells detects if LFG is within the explosive limit.

LFG infrastructure is clearly labelled and visible to plant operators.

All ignition sources are removed from the affected area.

Comprehensive data is collected in real time from the gas extraction system that provides information on gas composition with automatic isolation.

2 Very Unlikely



LFG condensate ecotoxicity

Skeleton Creek, local stormwater catchment.

Contamination of stormwater system and damage to water quality and wetland habitat and wildlife.

Condensate overflows from knock out pots due to pump failure entering the surface water drains and stormwater catchment.

A failsafe is triggered when the pump fails to shut down or isolate the knock out pot. Notification is sent to the system operator.

The capacity of knock out pots is measured and leak detection monitoring carried out during the biannual site walkover.

A compressed air driven pump is utilised to transport the condensate into leachate pits to

2 Very Unlikely

2 Noticeable 4 Insignificant





prevent condensate overflow.


Residual impacts caused by LFG power generation, operation of landfill gas engines and landfill gas flares


Noise above the acceptable limit for workers and site visitors.

Direct release of noise, GHG or odour to the atmosphere.

The potential receptors are located a considerable distance from the noise source at least 500m to >1km from the landfill gas compounds and are considered very unlikely to be affected by the landfill gas infrastructure

2 Very Unlikely

3 Significant 6 Insignificant Odour emitted from landfill gas engines or flares.

The Pacific Environment report provides discussion on odour emissions from the landfill gas infrastructure.

Contribution to greenhouse gas emissions.

The amount of GHG emitted is insignificant compared to the GHG reduction due to the destruction and treatment of methane.

Outside the site Boundary to the North, South, West and East of the site

Lateral migration of LFG through the soil/rock sub surface geology

Offsite persons

Asphyxiation through accumulation of LFG in confined spaces such as basements or voids under buildings.

Migration of LFG from the site through the surrounding geology and underground services to residential properties and other buildings.

Potential receptors are located a considerable distance from the landfill typically at least 500m to >1km from the landfill and are considered very unlikely to be affected by the landfill

The pathway is considered to be incomplete to the north, east and south-west as the landfill waste is placed above the quarry floor there is no direct lateral pathway, i.e. there is a gap between the edge of the waste and the quarry walls, as

2 Very Unlikely


Explosion or fire of LFG accumulated in confined spaces such as basements or voids under buildings.

2 Very Unlikely






shown in the conceptual model, Plate 3.

Gas monitoring wells around the perimeter of the landfill will be regularly monitored to provide early warning of offsite migration of landfill gas.

Methane and carbon dioxide emitted indirectly to the atmosphere through the soil or rock are likely to be dissipated and diluted shortly after release.

Offsite workers in trenches or excavations

Asphyxiation through accumulation of LFG in confined spaces such as utility trenches, pits, manholes or drains.


The pathway is considered to be incomplete to the north, east and south-west as the landfill waste is placed above the quarry floor there is no direct lateral pathway, i.e. there is a gap between the edge of the waste and the quarry walls, as shown in the conceptual model, Plate 3.

Gas monitoring wells are to be constructed around the perimeter of the landfill and

2 Very Unlikely


Explosion or fire of LFG accumulated in confined spaces, such as utility trenches, pits, manholes or drains.

2 Very Unlikely






regularly monitored to provide early warning of offsite migration of landfill gas.

Migration of dissolved methane in leachate or groundwater.

Offsite workers in trenches or excavations, offsite residents and workers.

Impact to human health and contamination of groundwater.

Migration of LFG from the site through the surrounding geology and dissolving into the groundwater system.


Monitoring of groundwater and LFG monitoring wells for dissolved methane will be undertaken on an as needs basis.

The pathway is considered to be incomplete as there is a minimum of 2m and typically >5m vertical separation between the landfill cell waste and the groundwater level.

2 Very Unlikely




7.0 MONITORING PROGRAM

Based on the results of the risk assessment for the Extension to the MRL a monitoring program is required to

monitor the perimeter gas monitoring wells and to undertake periodic monitoring of landfill gas emissions

from the facility. This section includes further information on the proposed monitoring program.

The monitoring program proposed for the Extension takes into consideration a landfill gas monitoring

program for the Existing Landfill that has been implemented and verified by an Environmental Auditor. The

program is designed to demonstrate compliance with the existing EPA licence (12160) issued 10 August

2015 for the Existing Landfill and to monitor potential environmental impacts.

The monitoring program performance is measured using the BPEM LFG action levels provided in Table 11

and SEPP air quality trigger concentrations. The surface emissions monitoring point of measurement is 50

mm above the landfill surface. The point of measurement for the monitoring of LFG emissions from

penetrations is 50 mm from the point of penetration. Sampling and monitoring is carried out in accordance

with the EPA Draft Landfill Gas Fugitive Emissions Monitoring Guidelines (reference 10).

Table 11: BPEM landfill gas action levels

Location Parameter(s) Action level and unit

Landfill surface final cap Methane concentration in air 100 ppm

Within 50mm of penetrations through the final cap

Methane concentration in air 100 ppm

Landfill surface intermediate cover areas

Methane concentration in air 200 ppm

Within 50 mm of penetrations through the intermediate cover

Methane concentration in air 1 000 ppm

Biofilters Methane flux 1.0 g/m2/hr

Subsurface geology at the landfill boundary

Methane and Carbon Dioxide concentrations

1% v/v Methane or 1.5% Carbon Dioxide above background

Subsurface services on and adjacent to the landfill site

Methane concentration 10 000 ppm

Building/structures on and adjacent to landfill site

Methane concentration in air 5 000 ppm

Landfill gas flares Methane and Volatile Organic Compounds

98% destruction efficiency

7.1 Landfill Subsurface Emissions Monitoring

LFG monitoring wells detect the migration of lateral emissions of landfill gas. The geology of the site has

been classified as basalt in most areas. The spacing and location of monitoring wells is specific to

geological conditions as outlined in the BPEM requirements. The wells are to be sited a minimum of 20

metres from the waste boundary.

Where the cell wall abuts the quarry face the surrounding geology is considered to be fissure or fracture

flow-dominated strata. For fractured strata with no development within 250 metres, the BPEM defines

criteria for the gas monitoring well spacing and allows for site specific conditions to be taken into account.

The location of monitoring wells will be agreed with EPA as the Extension is developed taking account of

BPEM criteria and will be subject to the oversight of the Operations Environmental Auditor.

In the majority of the Extension where the cell boundary is set back from the quarry face, the risk of lateral

migration is reduced. This is attributed to the approximate 10m vertical height difference between the

boundary surface level and quarry floor, the large horizontal gap between the edge of the waste and the

perimeter rock face, and the confining nature of the water table in regards to the lateral flow path, as shown

indicatively on the conceptual cross section on Plate 4. Therefore, it is considered that a greater distance



between gas monitoring wells would be used where the landfill cells are not directly abutting the quarry face.

The location of monitoring wells will be agreed with EPA as the Extension is developed taking account of

BPEM criteria and will be subject to the oversight of the Operations Environmental Auditor.

Plate 4: Conceptual cross section for lateral LFG emissions

The BPEM provides specifications for the design and construction of LFG monitoring wells as provided in

Table 12. Each well is designed to have a gas tight seal with adequate security cover to prevent damage by

vandals, animals, natural processes and operational machinery. To meet construction quality assurance

requirements, LFG monitoring well installation is to be carried out by a suitably qualified person and records

of drilling and installation logs kept.

Table 12: Typical construction details for landfill gas well construction

Component Value

Drilled bore diameter (mm) 100 – 150

Pipework casing – outer diameter (mm) 50

Depth to top of bentonite seal (m) 1

Length of solid casing below ground level (m) 1

Perforated casing pipework (% open space) 10 – 15

Pipework casing – size of slots / perforations (mm) 2 – 4 but no more than 5

Size range of gravel back fill Less than or equal to 100mm

Gravel type Washed gravel to be rounded to sub-rounded and non-calcareous (<5% carbonate)

There are currently 27 LFG monitoring wells installed adjoining the Existing Landfill that are monitored on a

monthly basis in accordance with EPA licence requirements. Sampling at each well is undertaken using a

calibrated landfill gas monitor

Future gas well installation is planned to be staged with the development of the Extension landfill cells and

monitored in accordance with the current EPA approved protocol. The BPEM action levels for subsurface

geology at the landfill boundary are provided in Table 11. The number of monitoring wells will be agreed with



EPA as the Extension is developed and will be subject to the oversight of the Operations Environmental

Auditor.

7.2 Landfill Gas Surface Emissions Monitoring

The objective of surface gas emission monitoring is to demonstrate that the landfill cover, capping and gas

extraction system are effective in controlling the migration of LFG. Surface emission monitoring is currently

carried out on a bi-annual basis. This involves a 25m grid site walkover with a flame ionisation detector (FID)

or laser diode monitor to detect methane concentrations in parts per million (ppm). Inspection of the LFG

infrastructure is included in the site walkover. This includes penetrations through the final cap and

intermediate cover. The site walkover is designed to identify any point sources or fissures that may be

emitting LFG. Sampling is carried out in accordance with Victorian EPA Publication 440.1 (Reference 9).

Surface emissions monitoring is reviewed annually during an annual review of LFG monitoring. It is

proposed this monitoring will continue for the Extension.

7.3 Landfill Gas Accumulation Monitoring

Buildings or structures on or adjacent to MRL are monitored for the accumulation of LFG. The objective of

monitoring of Methane build up in buildings and structures is to protect human health. Monitoring is

undertaken on a quarterly basis for all site buildings within 250 m of waste filled areas. Similar to surface

emissions monitoring, an FID or laser diode monitor is used to detect Methane concentrations in parts per

million. It is proposed this monitoring will continue for the Extension.

7.4 Reporting

Periodic risk assessments are undertaken using monitoring results and reports to evaluate the effectiveness

of the MRL air quality management systems. The monitoring results are compared to the monitoring program

to identify any areas for improvement or further investigation. The monitoring programs will be updated

progressively throughout the operational life of the landfill such that LFG monitoring appropriately reflects

site conditions and activities.

Environmental audits are conducted by EPA Victoria appointed Environmental Auditors in accordance with

the Environment Protection Act 1970. The audits are performed on a two yearly basis. It is proposed these

Operations Audits will continue for the Extension.

8.0 CONTINGENCY PLANNING

Management systems will be in place to control the migration of LFG from the site to comply with the LFG

action levels set out by BPEM (Table 11). The MRL LFG management strategy is developed from the risk

assessment in Section 6.4.

When action levels are exceeded, the EPA will be notified within 24 hours unless rectified beforehand.

Remedial action will take place and further monitoring will be undertaken to demonstrate the effectiveness of

the remedial works. A landfill gas remediation action plan may be required to be prepared and forwarded to

the EPA that details specific control measures to be undertaken. Landfill Ops will appoint a team member

who is responsible for implementing LFG control actions.

The following remediation strategies are proposed as contingency measures in the event of a detection of

LFG exceeding BPEM trigger levels:

8.1 Subsurface Gas Emissions

If uncontrolled lateral LFG emissions that exceed EPA BPEM criteria are detected by subsurface LFG

monitoring the extent of the lateral migration will be established through increased monitoring frequency and

installation of additional monitoring wells if required. If subsurface BPEM action levels are exceeded;

remediation of uncontrolled LFG emissions is likely to be required. Remedial actions may include and are not

limited to;

Increased frequency of monitoring;



Confirmation of background levels;

Investigation into the source of the LFG;

Notify neighbour, workers, and EPA;

Installation of additional LFG extraction wells at the source;

Subsurface extraction drains.

8.2 Surface Gas Emissions

Corrective action for the exceedance of surface gas emission BPEM action levels may include;

Investigation into the source of the LFG surface emission;

Review of waste screening processes to ensure unacceptable waste is not being accepted at the Site;

Providing thicker cover material or changing the cover material to an alternative material;

Repairing or replacing cover material or landfill cap materials and surface erosion control methods such

has vegetation establishment;

Adjusting or installing gas venting or extraction equipment;

Installation of perimeter gas collection trenches; and/or

Repairing or replacing seals around cap penetrations.

Evaluation of effectiveness of gas collection system;

8.3 Accumulation of LFG in Buildings

Where there is an exceedance of 1% vol/vol methane inside a building or structure, BPEM advises

evacuation and immediate notification of emergency services. EPA and other relevant regulatory bodies will

also be notified. Daily testing will be undertaken until implemented control measures are proved effective.

These control measures include;

Improvement to ventilation within the building or structure;

Improvements to the landfill gas extraction infrastructure;

Increased frequency of monitoring; and/or

Identification and remediation of nearby LFG sources.


8.4 Ambient Air Emissions

For exceedance of SEPP trigger concentrations in ambient air, the following corrective actions may be taken;

Increased frequency of ambient air monitoring;


Capping or sealing of identified LFG leaks; and

Assess risks to sensitive receptors.



8.5 Odour

Odour complaints received by MRL are verified by the EPA. For off-site odour complaints, Landfill Ops

implements the following remedial actions;

Record complaint details in register;

Investigate the source of the odour;

Confirm if odour is caused by landfilling activities;

Undertake remedial actions at source of odour if required; and

Notify the complainant that investigation has been undertaken.

9.0 LANDFILL GAS CONTROL MEASURES

9.1 Landfill Gas Containment System

Based on discussions with EPA and modern landfill operational practices, the landfill gas containment

system will comprise:

A series of interconnected horizontal gas collection pipes in gravel filled trenches installed progressively

within the waste during the waste filling operations. These horizontal trenches aim to collect landfill gas

in the early phase to limit losses of fugitive gas emissions to the atmosphere while the cell is being

filled.

Once the waste placement reaches final height, Landfill Ops will install a series of vertical gas

extraction wells within the waste mass at minimum 40m to 50 m spacing that forms the permanent

vertical gas extraction system. A typical indicative section of the landfill gas collection system is

presented on Figure 15 – Landfill Gas Management Plan.

The gas trenches and vertical gas wells will be connected to an active gas extraction system comprising

a combination of blower units, ‘j’ traps and barometric traps and a gas cleaning system that transfers

landfill gas via solid wall HDPE transfer pipes to the gas treatment compounds, located on Figure 15.

Lateral emissions are contained by the side wall liner and surface emissions are minimised by the

capping layer. An interim cap is constructed at completion of cell filling to control LFG emissions prior to

installation of the final cap as an interim measure to control fugitive gas emissions. The design details

and permeability of the lining system is provided in Table 13.

Table 13: Containment System design details

Layer Thickness (m) Permeability (m/s)

Base liner

Compacted clay liner 0.5 1x10-9

Geosynthetic clay liner 0.006 3x10-10

HDPE Geomembrane 0.002 2x10-13

Drainage Layer 0.3 1x10-3

Interim Cap Moderately compacted clay 0.5 1x10-6

Final Cap

Compacted clay liner 0.6 1x10-9

LLDPE Geomembrane 0.001 2x10-13

Geocomposite Drainage Layer 0.005 0.2

Subsoil 0.85 5x10-7

Topsoil 0.15 3.7x10-6



9.2 Landfill Gas Extraction System

The objective of the LFG extraction system is to manage landfill gas to prevent impacts to health, safety and

environment and to minimise emissions through the surface of the landfill in order to minimise greenhouse

gas emissions, odours and airborne impurities. In the short term, sacrificial horizontal gas collection trenches

will be installed and interim cover placed over the waste to limit residual LFG emissions. The horizontal gas

collection trenches are designed to collect LFG during the operational phase of the cell up until the final cap

is completed. The US EPA assumes an average gas collection efficiency of 75% (Reference 12). The

collection efficiency is dependent on the time between waste placement and initial gas collection for

individual cells. With the installation of horizontal gas collection trenches, a greater LFG collection efficiency

is expected for the Extension.

In the long term a final cap will be constructed and a gas collection system with vertical wells is to be

installed as described above.

The installation of the final cap markedly limits LFG surface emissions and improves gas collection

efficiency. The cap is designed to be 1.6 metres thick with a composite liner comprising an LLDPE

geomembrane over a compacted clay liner. The capping and installation of vertical gas wells will be carried

out progressively as cells are filled. The moisture in the gas is separated using knock out pots. Knock out

pot readings and depth to leachate measurement will be carried out regularly to monitor for leaks in the

system. The condensate accumulated in the LFG collection system is to be collected and treated as

leachate.

9.3 Landfill Gas Treatment Strategy

A significant flow of LFG is expected at the Extension based on the estimated GasSim LFG generation rates

in the order of 24 000 m3 /hour. The LFG treatment strategy for gas generation greater than 1000 m3/hour

needs to be compliant with the BPEM recommendations and the LFG management hierarchy presented in

Table 14. It is intended that landfill gas from the Extension will be treated by power generation using landfill

gas engines with a backup system of high temperature enclosed Landfill Gas Flares consistent with the

BPEM criteria.

The estimated gas flows generated by the GasSim model indicate the Existing Landfill LFG management

system capacity will be significantly expanded to correspond to the increasing rate of landfill gas production

due to the extension of the MRL.

Table 14: BPEM landfill gas management hierarchy

LFG generation rate Potentially suitable LFG treatment technologies

> 1000 m3/hr

Combined heat and power generation

Substitute fuel

Power generation

Intermittent use and off-time flaring

High-temperature flaring

> 250 m3/hr - < 1000 m3/hr

Power generation

Intermittent use and off-time flaring


Low-calorific flaring

> 100 m3/hr – 250 m3/hr Power generation




LFG generation rate Potentially suitable LFG treatment technologies

Low-calorific flaring

Other oxidation and discharge (e.g. passive flares,

biofilters, biocover)

< 100 m3/hr Other oxidation technology and discharge (e.g. passive

flares, biofilters, biocover)

The proposed Extension will convert collected landfill gas to electricity via a series of landfill gas engines with

any remaining collected landfill gas treated in an enclosed gas flare in accordance with EPA BPEM criteria.

The Existing Landfill site currently operates four 1.1 MW spark ignition landfill gas engines that feed power

into the Victorian Electricity Grid. The gas compound generates sufficient electrical output to meet the

energy needs of approximately 4000 homes, 24 hours per day. Three landfill gas flares operate when the

landfill gas engine is not in operation (maintenance time) or when the generators reach their capacity; the

flares and generators have a combined capacity of 7000 m3/hour.

The flares design comprises auto ignition and includes a flame arrestor beneath the combustion zone. In the

short-term more engines will be progressively installed to accommodate the increasing LFG production rate

as cells are filled. The current gas compound was designed to accommodate 8 landfill gas engines. The

next four landfill gas engines will be installed over the next two years. The area surrounding the gas

compound has the capacity for future expansion. Alternatively, separate gas compounds are likely to be

constructed for the Extension South Portion and North Portion. Figure 15 indicates two potential sites for

gas compound expansion in the North Portion and South Portion with the combined capacity to contain

engines during peak LFG generation.

As waste filling progresses, data collected from gas wells will be used to assess when the LFG treatment

system capacity is required to be upgraded to meet the LFG generation demands. LFG quality data and

utilisation rates will also contribute to treatment methods used. Similarly the output data will be analysed to

assess the timeline for decommissioning of LFG management infrastructure at the end of landfilling activities.

The GasSim model estimated an indicative total of 27 additional landfill gas engines will be required at peak

LFG generation. The flaring capacity is to be matched to the capacity of the landfill gas engines in the event

that the generators are off line for maintenance and repairs.



10.0 CONCLUSIONS

Our qualitative landfill gas risk assessment rates the Extension as ‘Acceptable’.

This Landfill Gas Management Plan has been developed to address the requirements for LFG collection and

treatment systems for the extension to the MRL facility in accordance with BPEM criteria and air quality

objectives established in accordance with relevant legislative requirements including the SEPP’s and Works

Approval Guidelines. This Landfill Gas Management Plan was prepared to support the Works Approval

Application and may be subject to change during the future detailed design phase of the project.

The Extension will be categorized as a Type 2 municipal waste landfill; accordingly landfill gas (LFG)

production is expected. The proposed Extension site conditions were simulated to estimate the expected

LFG generation. Modelling results indicate a significant flow of LFG is expected in the Extension, with a

peak flow in the order of 24 000 m3/hour of landfill gas will be produced during the operational life of the

landfill and reducing markedly into the post closure period.

Based on this rate, LFG management strategies are proposed in line with the BPEM hierarchy of preferred

treatment methods. The proposed LFG Management system is designed to control the migration of LFG

from the proposed landfill extension to meet the following objectives;

Prevent impacts to health, safety and the environment;

Minimise greenhouse gas emissions;

Prevent off site nuisance odours; and

Meet regulatory requirements.

The Plan provides a summary of existing site conditions and LFG management systems and addresses

management of LFG for the proposed Extension. A site conceptual model and LFG risk assessment has

been prepared as a basis for the LFG management and monitoring strategy. Based on our risk assessment

it is concluded that potential risks are considered to be Acceptable.

The landfill gas collection, management and treatment options were evaluated in accordance with the

estimated LFG generation rates projected for the proposed site. Provided that Landfill Ops implements the

outcomes from this Landfill Gas Management Plan it is considered that landfill gas control measures

proposed for the Extension are in accordance with the BPEM objectives and required outcomes and relevant

legislation.



11.0 REFERENCES

1. Australia Government Department of the Environment, Technical Guidelines for the estimation of

greenhouse gas emissions by facilities in Australia, National Greenhouse and Energy Reporting

(Measurement) Determination 2008, dated July 2014.

2. Department of Transport, Planning and Local Infrastructure, Melton Planning Scheme, updated 11

June 2015.

3. Environment Agency UK, Guidance of the management of landfill gas, dated September 2004.

4. EPA Victoria, Best Practice Environmental Management - Siting, Design, Operation and

Rehabilitation of Landfills, Publication 788.3, dated August 2015.

5. EPA Victoria, Guideline for Works Approval Application, Publication 1307.10, dated April 2015.

6. EPA Victoria, Landfill Licensing Guidelines, Publication 1323.2, dated August 2011.

7. EPA Victoria, Environmental Guidelines for Reducing Greenhouse Gas Emissions from Landfills and

Wastewater Treatment Facilities, Publication 722, dated November 2000.

8. EPA Victoria, Closed Landfill Guidelines, Publication 1490, dated December 2012.

9. EPA Victoria, A Guide to the Sampling and Analysis of Air Emissions and Air Quality, Publication

440.1, dated December 2002.

10. EPA Victoria, Draft Landfill Gas Fugitive Emissions Monitoring Guidelines, Publication 1416, dated

September 2011.

11. Metropolitan Planning Authority, Draft Future Urban Structure Plan, Mt Atkinson Precinct Structure

Plan, dated April 2015.

12. US EPA, Background Information Document for Updating AP42 Section 2.4 for Estimating

Emissions from Municipal Solid Waste Landfills, EPA/600/R-08-116, dated September 2008.

12.0 IMPORTANT INFORMATION RELATING TO THIS REPORT

Your attention is drawn to “Important Information Relating to this Report” (LEG04, RL2), which is included as

APPENDIX D to this Report. The statements presented in this document are intended to advise you of what

your realistic expectations of this Report should be. The document is not intended to reduce the level of

responsibility accepted by Golder Associates, but rather to ensure that all parties who may rely on this report

are aware of the responsibilities each assumes in so doing.



GOLDER ASSOCIATES PTY LTD

LJY/ATG/ljy

A.B.N. 64 006 107 857

Golder, Golder Associates and the GA globe design are trademarks of Golder Associates Corporation.

j:\civil\2015\1528407 - tpi mrl ravenhall waa\correspondence out\023 - lfg management plan\1528407-023-r-rev0 landfill gas management plan.docx

DRAFT MRL LANDFILL GAS MANAGEMENT PLAN

February 2016 Report No. 1528407-023-R-RevB 35

APPENDIX A Figures

SOUTH PORTIONSOUTH PORTION


SOUTH PORTIONSOUTH PORTIONSOUTH PORTIONSOUTH PORTIONSOUTH PORTIONSOUTH PORTION

SOUTH PORTION

SOUTH PORTION

SOUTH PORTION

SOUTH PORTION

SOUTH PORTION


CELL 1

CELL 2

CELL 3

CELL 4

CELL 5

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NORTH PORTIONNORTH PORTION


NORTH PORTIONNORTH PORTIONNORTH PORTIONNORTH PORTIONNORTH PORTIONNORTH PORTION

NORTH PORTION

NORTH PORTION

NORTH PORTION

NORTH PORTION

NORTH PORTION


60 m

64 m

100 m

100 m

60 m

60 m

60 m

20 m

20 m

100 m

DAME PHYLLIS

FROST CENTRE

METROPOLITAN

REMAND CENTRE

EXISTING LANDFILLEXISTING LANDFILL


EXISTING LANDFILLEXISTING LANDFILLEXISTING LANDFILLEXISTING LANDFILLEXISTING LANDFILLEXISTING LANDFILL

EXISTING LANDFILL

EXISTING LANDFILL

EXISTING LANDFILL

EXISTING LANDFILL

EXISTING LANDFILL


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NORTHERN GRASSLANDNORTHERN GRASSLAND


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NORTHERN GRASSLAND

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TITLE BOUNDARIES SHOWN FROM CHARTER KECK CRAMER FILE J055627 1100-1152

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GAS MANAGEMENT PLAN

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INDICATIVE SECTION OF LANDFILL GAS COLLECTION SYSTEM

N.T.S.

EXTENT OF LANDFILL GAS COLLECTION SYSTEM

POTENTIAL SITE FOR GAS COMPOUNDS



APPENDIX B Existing LFG Management System

E

2

E

1

L

1

E

2

E

1

E

3

L

1

G

M04

G

M03

GM

09

G

M10

G

M11

G

M12

G

M13

MB

11 O

ld

M

B07 O

ld

GM17A GM17B

GM18B GM18A

GM15

GM16

GM02

GM20AGM20B

GM21AGM21B

GM22AGM22B

GM07

GM01

GM19B GM19A

GM14

GM06

G

M05

AS SHOWN

MONITORING BORES

GAS BORESSITE PLAN

J.StewartJ.StewartM.Bishop

05.06.15J.StewartM.Bishop 1SITE-MN-053

ORIGINAL ISSUE J.SM.B.04.06.151

DRAWING No

DRAWING CHECK

DESIGN REVIEWDESIGNED

DRAWN REVIEWED APPROVED

TITLE

REV

DRAWNREV DATE APP'DREV'D REVISION

SCALE

DATE DATE

A4

DATE: 20/08/2015 10:48:33 AM LOGIN NAME: MARK BISHOPLOCATION: G:\Design Drawings\Projects\AutoCAD\Drawings MGA\Site Plans\SITE-MN-053 A4 - GAS BORES.dwg

Melbourne Regional LandfillPO BOX 287DEER PARK VIC 3023Tel (03) 9360 4670

110-1152 CHRISTIES RDTRUGANINA VIC 3023AUSTRALIA

SP AUSN

ET EA

SEM

ENT

LAND RELEASE BOUNDARY

MIDDLE ROAD

CHRI

STIE

S RO

AD

RIDING BOUNDARY ROAD

500m

SCALE 1:10000 (A3)

4003002001000

GM10

LEGEND

GAS MONITORING BORE

AutoCAD SHX Text

N


February 2016 Report No. 1528407-023-R 37



Table 1: GasSim Model Output -Estimated Total Bulk LFG Produced

Year Total Landfill Gas Produced (m3/hour)

50th Percentile 90th Percentile 1999 30 40 2000 160 180 2001 320 340 2002 490 520 2003 690 730 2004 970 1010 2005 1210 1260 2006 1440 1480 2007 1770 1820 2008 2160 2220 2009 2590 2650 2010 3100 3180 2011 3600 3710 2012 4040 4140 2013 4440 4560 2014 5170 5320 2015 5820 5990 2016 6140 6320 2017 6880 7070 2018 7840 8140 2019 8750 9110 2020 9580 10000 2021 10370 10710 2022 11130 11500 2023 11830 12260 2024 12510 12890 2025 13140 13560 2026 13750 14180 2027 14540 14980 2028 15370 15910 2029 16110 16590 2030 17880 18460 2031 18750 19340 2032 19460 19960 2033 19810 20320 2034 20300 20760

February 2016 Reference No. 1528407-023-R 1/5



50th Percentile 90th Percentile 2035 20670 21180 2036 21810 22410 2037 21870 22450 2038 21270 21850 2039 21480 22070 2040 21390 22010 2041 21600 22240 2042 21830 22510 2043 21990 22580 2044 22100 22760 2045 22280 22890 2046 22500 23040 2047 22650 23180 2048 22820 23370 2049 22900 23470 2050 23070 23660 2051 23290 23850 2052 23460 23980 2053 23450 24010 2054 23520 24050 2055 23550 24090 2056 23140 23760 2057 21470 22040 2058 19870 20390 2059 18400 18880 2060 17060 17500 2061 15830 16230 2062 14710 15070 2063 13670 14000 2064 12720 13020 2065 11840 12130 2066 11040 11300 2067 10300 10540 2068 9610 9840 2069 8980 9190 2070 8400 8590 2071 7860 8040




50th Percentile 90th Percentile 2146 150 160 2147 150 150 2148 140 140 2149 130 130




APPENDIX D Important Information Relating to this Report

IMPORTANT INFORMATION RELATING TO THIS REPORT

The document (“Report”) to which this page is attached and which this page forms a part of, has been issued by Golder Associates Pty Ltd (“Golder”) subject to the important limitations and other qualifications set out below. This Report constitutes or is part of services (“Services”) provided by Golder to its client (“Client”) under and subject to a contract between Golder and its Client (“Contract”). The contents of this page are not intended to and do not alter Golder’s obligations (including any limits on those obligations) to its Client under the Contract. This Report is provided for use solely by Golder’s Client and persons acting on the Client’s behalf, such as its professional advisers. Golder is responsible only to its Client for this Report. Golder has no responsibility to any other person who relies or makes decisions based upon this Report or who makes any other use of this Report. Golder accepts no responsibility for any loss or damage suffered by any person other than its Client as a result of any reliance upon any part of this Report, decisions made based upon this Report or any other use of it. This Report has been prepared in the context of the circumstances and purposes referred to in, or derived from, the Contract and Golder accepts no responsibility for use of the Report, in whole or in part, in any other context or circumstance or for any other purpose. The scope of Golder’s Services and the period of time they relate to are determined by the Contract and are subject to restrictions and limitations set out in the Contract. If a service or other work is not expressly referred to in this Report, do not assume that it has been provided or performed. If a matter is not addressed in this Report, do not assume that any determination has been made by Golder in regards to it. At any location relevant to the Services conditions may exist which were not detected by Golder, in particular due to the specific scope of the investigation Golder has been engaged to undertake. Conditions can only be verified at the exact location of any tests undertaken. Variations in conditions may occur between tested locations and there may be conditions which have not been revealed by the investigation and which have not therefore been taken into account in this Report. Golder accepts no responsibility for and makes no representation as to the accuracy or completeness of the information provided to it by or on behalf of the Client or sourced from any third party. Golder has assumed that such information is correct unless otherwise stated and no responsibility is accepted by Golder for incomplete or inaccurate data supplied by its Client or any other person for whom Golder is not responsible. Golder has not taken account of matters that may have existed when the Report was prepared but which were only later disclosed to Golder. Having regard to the matters referred to in the previous paragraphs on this page in particular, carrying out the Services has allowed Golder to form no more than an opinion as to the actual conditions at any relevant location. That opinion is necessarily constrained by the extent of the information collected by Golder or otherwise made available to Golder. Further, the passage of time may affect the accuracy, applicability or usefulness of the opinions, assessments or other information in this Report. This Report is based upon the information and other circumstances that existed and were known to Golder when the Services were performed and this Report was prepared. Golder has not considered the effect of any possible future developments including physical changes to any relevant location or changes to any laws or regulations relevant to such location. Where permitted by the Contract, Golder may have retained subconsultants affiliated with Golder to provide some or all of the Services. However, it is Golder which remains solely responsible for the Services and there is no legal recourse against any of Golder’s affiliated companies or the employees, officers or directors of any of them. By date, or revision, the Report supersedes any prior report or other document issued by Golder dealing with any matter that is addressed in the Report. Any uncertainty as to the extent to which this Report can be used or relied upon in any respect should be referred to Golder for clarification.

GAP Form No. LEG04 RL2 July 2015 1/1

Golder Associates Pty Ltd

Caption Text

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