marsden park landfill proposed gas collection system and

The business of sustainability

www.erm.com

Blacktown Waste Services

June 2018

0430664_Final

Marsden Park Landfill Proposed Gas Collection System and Flare Unit

Statement of Environmental Effects

This disclaimer, together with any limitations specified in the report, apply to use of this report. This report was prepared in accordance with the contracted scope of services for the specific purpose stated and subject to the applicable cost, time and other constraints. In preparing this report, ERM relied on: (a) client/third party information which was not verified by ERM except to the extent required by the scope of services, and ERM does not accept responsibility for omissions or inaccuracies in the client/third party information; and (b) information taken at or under the particular times and conditions specified, and ERM does not accept responsibility for any subsequent changes. This report has been prepared solely for use by, and is confidential to, the client and ERM accepts no responsibility for its use by other persons. This report is subject to copyright protection and the copyright owner reserves its rights. This report does not constitute legal advice.

Prepared by: Matthew Errington

Position: Project Manager

Signed:

Date: 8 June 2018

Approved by: Paul Douglass

Position: Partner

Signed:

Date: 8 June 2018

Marsden Park Landfill

Proposed Gas Collection System and Flare

Unit

Statement of Environmental Effects

Blacktown Waste Services

June 2018

0340664 Final

www.erm.com

Document Control:

0430664 Marsden Park Landfill

Proposed Gas Collection System and Flare Unit

Version Revision Author

ERM Approval to Issue

Name Date

Draft 01 Matthew Errington Paul Douglass 28/11/17

Final 02 Matthew Errington Paul Douglass 12/06/18

CONTENTS

ABBREVIATIONS

EXECUTIVE SUMMARY

1 INTRODUCTION

1.1 OVERVIEW 1

1.2 BACKGROUND AND CONTEXT 1

1.3 LOCALITY AND SURROUNDING LAND USE 4

1.4 PROJECT AREA AND LAND OWNERSHIP 5

1.5 DA STATUS AND CONSULTATION FOR THE SOEE 6

2 PROJECT DESCRIPTION

2.1 SUMMARY OF PROPOSED WORKS 7

2.1.1 DRILLING GAS COLLECTION WELLS 8

2.1.2 FLOW LINES 8

2.1.3 REMEDIAL WORKS (TO SEAL LANDFILL CAP) 8

2.1.4 MANIFOLDS 10

2.1.5 CONDENSATE MANAGEMENT 10

2.1.6 INSTALLATION OF FLARE UNIT 10

2.2 WORKS PROGRAM 14

2.3 CONSTRUCTION WORKFORCE 14

2.4 CONSTRUCTION HOURS 14

2.5 SITE ACCESS AND EGRESS 14

2.6 CONSIDERATION OF ALTERNATIVES 14

2.6.1 PREFERRED OPTION 15

3 LEGISLATIVE AND POLICY CONSIDERATIONS

3.1 COMMONWEALTH LEGISLATION 16

3.1.1 ENVIRONMENTAL PROTECTION AND BIODIVERSITY

CONSERVATION ACT 1999 16

3.2 NSW LEGISLATION 16

3.2.1 ENVIRONMENTAL PLANNING AND ASSESSMENT ACT 1979 16

3.2.2 PROTECTION OF THE ENVIRONMENT OPERATION (CLEAN AIR)

REGULATION 2010 18

3.3 STATE ENVIRONMENTAL PLANNING POLICIES 20

3.3.1 STATE ENVIRONMENTAL PLANNING POLICY (SYDNEY REGION

GROWTH CENTRES) 2006 -MARSDEN PARK INDUSTRIAL PRECINCT

PLAN 2010 20

3.3.2 STATE ENVIRONMENTAL PLANNING POLICY NO 33— HAZARDOUS

AND OFFENSIVE DEVELOPMENT 20

3.4 LOCAL STATUTORY CONTEXT 21

3.4.1 BLACKTOWN LOCAL ENVIRONMENTAL PLAN 2015 21

3.5 DEVELOPMENT CONTROL PLANS 21

3.5.1 BLACKTOWN CITY COUNCIL GROWTH CENTRE PRECINCTS

DEVELOPMENT CONTROL PLAN 2014 (SCHEDULE 3 – MARSDEN

PARK INDUSTRIAL PRECINCT) 21

CONTENTS

4 ENVIRONMENTAL IMPACT ASSESSMENT AND

MANAGEMENT

4.1 FLORA AND FAUNA 22

4.1.1 EXISTING ENVIRONMENT 22

4.1.2 ASSESSMENT OF IMPACT 24

4.1.3 ENVIRONMENTAL MITIGATION 24

4.1.4 CONCLUSION 24

4.2 ABORIGINAL HERITAGE 24




4.2.4 CONCLUSION 25

4.3 NON-ABORIGINAL HERITAGE 25




4.3.4 CONCLUSION 26

4.4 GEOLOGY AND SOIL 26




4.4.4 CONCLUSION 27

4.5 WATER QUALITY AND HYDROLOGY 27



4.5.3 ENVIRONMENTAL MITIGATION MEASURES 28

4.5.4 CONCLUSION 29

4.6 AIR QUALITY AND GHG 29




4.6.4 CONCLUSION 30

4.7 NOISE AND VIBRATION 31

4.7.1 POLICY SETTING 31


4.7.3 NOISE MANAGEMENT LEVELS AND CRITERIA 33



4.7.6 CONCLUSION 39

4.8 TRAFFIC 39




4.8.4 CONCLUSION 40

4.9 WASTE AND MATERIALS MANAGEMENT 40

4.9.1 BACKGROUND AND EXISTING ENVIRONMENT 40


CONTENTS

4.9.3 ENVIRONMENTAL MITIGATION MEASURES 41

4.9.4 CONCLUSION 41

4.10 VISUAL AMENITY 41




4.10.4 CONCLUSION 46

4.11 HAZARD AND RISK 46

4.11.1 RISK MITIGATION 48

4.11.2 CONCLUSION 53

4.12 CUMULATIVE IMPACTS 54

5 SECTION 79C CONSIDERATIONS

6 CONCLUSION

7 REFERENCES

LIST OF PHOTOGRAPHS

PHOTOGRAPH 1.1 NEARBY COMMERCIAL FACILITIES SURROUNDING THE

MARSDEN PARK LANDFILL SITE.

5

PHOTOGRAPH 1.2 ENCLOSED GROUND FLARE UNIT FORMING PART OF THE

PROPOSED GCS.

10

PHOTOGRAPH 4.1 MARSDEN PARK LANDFILL SITE SHOWING INDICATIVE

GROUND FLARE UNIT LOCATION AND SITE OFFICE (RIGHT OF

PHOTOGRAPH).

41

PHOTOGRAPH 4.2 NEARBY SENSITIVE RECEIVERS NORTHEAST OF THE MARSDEN

PARK LANDFILL SITE.

42

PHOTOGRAPH 4.3 NEARBY SENSITIVE RECEIVERS SOUTHWEST OF THE MARSDEN

PARK LANDFILL SITE. 42

PHOTOGRAPH 4.4 SITE OFFICE AND EXISTING VEGETATION (TO THE RIGHT). 43

PHOTOGRAPH 4.5 VIEW TOWARDS LANDFILL SITE FROM THE CORNER OF

HAWTHORNE AVENUE AND DARLING STREET.

44

PHOTOGRAPH 4.6 NEARBY SENSITIVE RECEIVERS SOUTHWEST OF THE MARSDEN

PARK LANDFILL SITE (BEHIND VEGETATION BUFFER WITHIN

RED RECTANGLE).

45

CONTENTS

LIST OF FIGURES

FIGURE 1.1 SITE LOCALITY 3

FIGURE 1.2 LAND ZONING AND CADASTRAL BOUNDARIES (SOURCE: SEPP

2006) 4

LIST OF TABLES

TABLE 3.1 RELATIONSHIP BETWEEN PROPOSED WORKS AND MATTERS OF

NATIONAL ENVIRONMENTAL SIGNIFICANCE 16

TABLE 3.2 POLLUTANT DISCHARGE LIMITS (POEO REGULATION) 20

TABLE 4.1 THREATENED SPECIES (AND/OR THREATENED SPECIES HABITAT)

WITH POTENTIAL TO OCCUR WITHIN THE PROJECT AREA 23

TABLE 4.2 NSW OFFICE OF WATER REGISTERED BORES WITHIN PROJECT

VICINITY 28

TABLE 4.3 POLLUTANT DISCHARGE LIMITS 29

TABLE 4.4 RATING BACKGROUND NOISE LEVELS (RBL) 33

TABLE 4.5 CONSTRUCTION NOISE MANAGEMENT LEVELS (NML) - (LAEQ, 15

MINUTE) 34

TABLE 4.6 OPERATIONAL - PROJECT INTRUSIVENESS NOISE LEVEL - (LAEQ,

15 MINUTE) 34

TABLE 4.7 ROAD TRAFFIC NOISE CRITERIA 35

TABLE 4.8 SUMMARY OF PROJECT HAZARDS AND RISKS 47

TABLE 4.9 SUMMARY OF COMMISSIONING CHECKS 49

TABLE 5.1 SECTION 79C CONSIDERATIONS 55

ANNEX A FLARE EMISSION TESTING REPORT

ENVIRONMENTAL RESOURCES MANAGEMENT AUSTRALIA 0430664/FINAL/12 JUNE 2018

I

ABBREVIATIONS

Abbreviation Description

AHIP Aboriginal Heritage Impact Permit

AHIMS Aboriginal Heritage Information Management System

BC Act Biodiversity Conservation Act 2016

BCC Blacktown City Council

Bgl Below ground level

CIV Capital investment value

DA Development Application

DCP Development Control Plan

DP&E NSW Department of Planning & Environment

DECC NSW Department of Environment and Climate Change

(now NSW Office of Environment and Heritage)

EEC Endangered Ecological Community

EPA NSW Environment Protection Authority

EP&A Act Environmental Planning and Assessment Act 1979

ERM Environmental Resources Management Australia Pty Ltd

FM Act Fisheries Management Act 1994

GCS Gas Collection System

HT High Temperature

ICNG NSW Interim Construction Noise Guideline

INP NSW Industrial Noise Policy

JHR John Holland Group Pty Ltd

ISEPP State Environmental Planning Policy (Infrastructure) 2007

JRPP Joint Regional Planning Panel

LEMP Landfill Environmental Management Plan

LEP Local Environmental Plan

LFG Landfill Gas

LGA Local government area

MPIP Marsden Park Industrial Precinct

NES National Environmental Significance

NML Noise Management Level

NPI Noise Policy for Industry

NP&W Act National Parks and Wildlife Act 1974

NPWS NSW National Parks and Wildlife Service

NSW New South Wales

NV Act Native Vegetation Act 2003

OEH NSW Office of Environment and Heritage

PA Project Area

RBL Rating Background Level

RMS Roads and Maritime Services

RNP NSW Road Noise Policy

SEPP State Environmental Planning Policy

SIS Species Impact Statement

SoEE Statement of Environmental Effects

SWLs Standard water levels

TEC Threatened Ecological Community

TSC Act Threatened Species Conservation Act 1995

WM Act Water Management Act 2000


II

EXECUTIVE SUMMARY

Environmental Resources Management Australia Pty Ltd (ERM) was engaged by

Blacktown Waste Services Pty Ltd (BWS) to prepare a Statement of Environmental

Effects (SoEE) to support a Development Application (DA) for the installation and

operation of an active gas collection system and enclosed ground flare unit.

Development consent for the proposed works is being sought from Blacktown Council

under Part 4 of the Environmental Planning and Assessment Act 1979 (EP&A Act).

This SoEE has been developed to describe the proposed gas collection system

installation and operational activities, assesses the associated potential environmental

impacts and recommends management and mitigation measures.

The SoEE provides a review all relevant legislation and policy and finds that the

primary issues to consider in determining the DA are potential noise and air quality

impacts to nearby sensitive receptors.

The main noise source is associated with the operation of the flare unit which is not

anticipated to generate high noise levels. In order to attenuate anticipated noise

emissions, the flare unit will be fitted with an acoustic enclosure and strategically

located behind existing site infrastructure and vegetation to obscure the direct line of

sight towards potentially affected receivers. Regular maintenance, testing and

monitoring will be undertaken to ensure regulatory compliance. The Project is not

anticipated to have adverse noise impacts on nearby sensitive receptors.

With regards to potential air quality impacts, the flare unit will utilise the latest

technology to meet present and near future emissions standards. Pollutant emission

limits required by the Protection of the Environment Operations (Clean Air

Regulation) 2010 will not be exceeded during operation of the flare unit. Emission

compliance testing and monitoring will be undertaken by a NATA accredited

Contractor. The reduction in GHG emissions (in particular, methane) as a result of

the Project will have a beneficial environmental outcome and positive impact. The

Project will also reduce the potential for odorous landfill gases to dissipate to

surrounding receivers.

It is in the public interest to install and operate the GCS and flare unit, as it will assist

in the:

Reduction of GHG emissions reducing the effects of global warming

Reduction of the potential for dispersion of odorous and potentially harmful

landfill gases to nearby sensitive receivers; and

Achievement of the final land use goal of ‘low density industrial use’, which will

help stimulate economic growth within the local community by providing jobs to

community members.


III

The SoEE has given consideration to all relevant legislation and policies, and has

conducted an assessment of potential environmental impacts. It concludes that the

Project and its associated potential environmental impacts are unlikely to have a

significant negative impact on the environment and all identified minor risks and

impacts can be effectively managed through the implementation of mitigation

measures during the proposed works and during the long-term operation of the

project.

Additionally, the reduction in GHG emissions as a result of the operation of Project

means the overall environmental impact is considered positive, and such works are

considered viable for the Emissions Reduction Fund (subject to approval by the Clean

Energy Regulator). Other positive benefits include the significantly reduced risk of

sub-surface migration of landfill gas and potential for airborne odour at surrounding

receivers.


1

1 INTRODUCTION

1.1 OVERVIEW

Environmental Resources Management Australia Pty Ltd (ERM) was engaged

by Blacktown Waste Services (BWS) to prepare a Statement of Environmental

Effects (SoEE) to support a Development Application (DA) for the proposed

construction and operation of an active landfill Gas Collection System (GCS)

and enclosed high temperature ground flare unit at Marsden Park Landfill,

Blacktown, NSW (hereinafter referred to as the Project).

1.2 BACKGROUND AND CONTEXT

The Marsden Park Landfill is located on Richmond Road, Marsden Park,

NSW, approximately 9 km northwest of Blacktown City Centre, and is wholly

contained within the Blacktown City Council (BCC) local government area

(LGA). The location of the Marsden Park Landfill is shown in Figure 1.1.

The Marsden Park Landfill site is located in a predominantly industrial/

commercial area, with surroundings land uses including vacant lots,

warehouses, distribution centres and retail facilities. Marsden Park Industrial

Precinct (MPIP) surrounds the Project site and the IKEA Distribution Centre is

adjacent to the western site boundary. Residential areas are located to the

south and north-east.

Blacktown Waste Services (BWS) propose to construct and operate an active

gas extraction system and high temperature fully enclosed ground flare to

assist in the management of landfill gases associated with the operation of the

landfill site. The Project involves the installation of a series of vertical pipes

(collection wells) in the landfill waste mass. Piping will be connected to the

wells and reticulated by a blower fan installed on the flare unit. A vacuum

will be created and landfill gas containing methane is sent to a combustion

flare. The flare burns the methane at very high destruction rates to generate

carbon dioxide.

The flare unit will utilise the latest technology to meet present and near future

emissions standards. The resulting reduction of global warming potential

means the Project is eligible under the Emissions Reduction Fund (ERF),

enabling the offsetting of fossil fuel. Further information on the specifications

and design of the GCS and flare unit is provided in Section 2.

BWS has operated the Marsden Park Landfill site as a solid waste class 2

landfill since 2000, in accordance with Environmental Protection Licence (EPL)

11497. A Landfill Environmental Management Plan (LEMP) has been

developed and recently updated in 2015 (by MRA Consulting) for the landfill

component of operations. The updates to the LEMP addressed changes to site

boundaries and locations of environmental monitoring points.


2

A similar GCS and enclosed ground flare unit was recently approved at the

Horsley Park Landfill by the NSW Environment Protection Authority (EPA).

It is expected that, similar to the system at Horsley Park Landfill, the Project’s

potential adverse environmental impacts will be negligible. The reduction in

greenhouse gas (GHG) emissions (in particular, methane) as a result of the

Project will have a beneficial environmental outcome and positive impact.

An assessment of potential environmental impacts is provided in Section 4 of

this report.

!(

24/11/20170430664b_SOEE_G001_R5.mxd

A4

This figure may be based on third party data or data which has notbeen verified by ERM and it may not be to scale. Unless expresslyagreed otherwise, this figure is intended as a guide only and ERM doesnot warrant its accuracy.

Client:Drawn By:

Drawing No:Date: Drawing Size:

Reviewed By:

Marsden Park Landfill Statement of EnvironmentalEffects

Blacktown Waste Services (BWS)JLT TBCoordinate System: GDA 1994 MGA Zone 56

Site Locality F.1

0 100 200m [N

!(

LegendCadastreProposed gas collection system

!( Indicative flare unit location

Project Site

SITE OFFICE

Source:Imagery - Nearmap (image date 7/09/2017)Cadastre - NSW Department of Finance,Services & Innovation 2017

IKEA DISTRIBUTION CENTRE

Ric

hm

ond R

oad

Hawthorne Avenue

Fulton Road

So

uth

Str

ee

t

South Street

Darling Street

Harris

Avenue

Hollinsworth Road

Darling Stre

et

Harris

Avenue

Darlin

g S

treet


4

1.3 LOCALITY AND SURROUNDING LAND USE

The Marsden Park Landfill site is located at 920 Richmond Road, Marsden

Park (Lot 102 DP 1188147 and Lot 313 DP 1213756).

Under the State Environmental Planning Policy (Sydney Region Growth

Centres) 2006 (SEPP 2006), the following land use zoning applies to the site –

‘IN1’ General Industrial (refer to Figure 1.2):

Figure 1.2 Land Zoning and Cadastral Boundaries (Source: SEPP 2006)

Site Surroundings

The Project site is located within the MPIP, which comprises approximately

551 hectares of land, under various ownerships. The MPIP is bounded by

South Street to the north and west, the easement for the proposed Castlereagh

Freeway to the south, and Bells Creek to the east. The core development area

of the MPIP is roughly rectangular and is approximately 2.5 km from east to

west and approximately 2 km from north to south.

The MPIP currently contains the landfill itself, a number of commercial and

industrial properties including Bunnings, Home Consortium, McDonalds,

IKEA, some commercial/industrial uses located on Richmond Road, and the

Town and Country Estate, located approximately 890 m south west of the site.


5

Photograph 1.1 Nearby commercial facilities to the south-east of Marsden Park Landfill

site.

Potentially Sensitive Receptors

Potentially sensitive receptors include residential premises, schools, hospitals,

places of worship, parks and wilderness areas. The nearest residential areas to

the Marsden Park Landfill are located on Richmond Road and South Street,

which form the eastern and northern boundaries of the MPIP, and consist of a

mixture of low and medium-density residential zoning (refer to Section 4.7.2

for further details).

The Ahmadiyya Muslim Association Mosque is located near the southern

edge of the MPIP and is considered a sensitive receptor, however it is not

expected to be impacted by the Project.

1.4 PROJECT AREA AND LAND OWNERSHIP

The Project area is limited to the Marden Park Landfill site, which is owned

and operated by BWS. The Project area comprises the GCS located in the

landfill mass itself and the flare unit located near the site office.


6

1.5 DA STATUS AND CONSULTATION FOR THE SOEE

ERM understands that Ganian Pty Ltd was granted development consent (DA

98/2962) on 7 September 2000 by the Land and Environment Court of NSW to

operate a joint quarry and landfill at 920 Richmond Road, Marsden Park. The

Development Consent (DA 98/2962) covers quarrying, landfilling and

associated activities. However, under condition No. 54, separate planning

approvals must be obtained for any gas extraction facility. To fulfil this

requirement, ERM has prepared an SoEE for the Project to support a DA

under Part 4 of the Environmental Planning and Assessment Act 1979 (EP&A

Act).

A Pre-Application Meeting was undertaken on 21 September 2017 between

BWS and BCC representatives to discuss the outline Project scope, proposed

planning approval pathway and key issues for consideration and assessment.

A site visit and second meeting with BCC representatives was held on 20

October 2017 to inform the impact assessment process. The purpose of the site

visit and meeting was to:

discuss the detailed Project scope;

inspect the Project area and surrounding areas for potential sensitive

receptors and environmentally sensitive areas; and

discuss and agree on the scope of the SoEE, potential impacts and

mitigation and management measures.


7

2 PROJECT DESCRIPTION

2.1 SUMMARY OF PROPOSED WORKS

The GCS is comprised of wells and pipe lying beneath the surface of the site,

which is connected to a high temperature enclosed flare. The GCS will utilise

the natural gradient of the site to dewater condensate from the gas flow lines.

In summary, the Project includes the following scope of works:

Installation of approximately 40 gas collection wells in the waste mass;

Installation of 90 mm flow lines to reticulate landfill gas from extraction

wells to the 250 mm header line;

Remedial works to re-seal compacted clay cap over pipe trenching;

Manifolds to contain approximately 4-8 wells per manifold;

Each well will have individual control and measurement of gas flow,

pressure and composition;

Manifolds connected to main header line via a length of 125 mm pipe;

In-line barometric condensate traps installed to remove any condensate

build up within the main header line close to flare;

Installation of a 1000 m3/hr capacity high temperature enclosed ground

flare powered by on-site three phase power supply;

The flare will have automatic shutdown and restart with remote dial in

telemetry;

Commissioning and pressure testing of the GCS and flare to ensure they

meet performance requirements;

Fencing enclosing the flare for security purposes;

Construction Quality Assurance reporting;

Operations and maintenance; and

Monthly reporting.

Further details of the various Project components are provided below.


8

Note: Landfill closure planning is currently underway and BWS will seek to vary the existing landfill DA 98/2962, which is expected to involve updating the LEMP with the final agreed landfill level. The Project will need to consider the final landfill level and the wells, collection pipework, manifolds, etc. will not be able to be installed until the level is approved by BCC through the existing DA variation process. Once the final landfill level is agreed, the Project design will be updated, if required.

2.1.1 Drilling gas collection wells

Large diameter gas collection wells will be installed within the waste mass

using a TR100 Drilling rig. Wells will be drilled with a 500 mm diameter auger

and installed with a 160 mm diameter well screen. Extraction from these wells

will reduce the positive pressure build-up of landfill gas in the waste mass

and therefore reduce the potential for landfill gas to migrate laterally or

through the cap. The deep wells are installed to provide a uniform

overlapping radius of influence and low vacuum in the sub-surface to control

landfill gas. With 12 m deep collection wells spaced at 30 m, an effective zone

of vacuum will be exerted in the waste mass and soils surrounding the site.

Figure 2.1 provides an indicate layout of the GCS.

Well installation will be undertaken in accordance with the Environmental

Guidelines – Solid Waste Landfills (NSW EPA, 2016, 2nd Edition). The following

international guidelines will also be referred to:

UK Environment Agency Guidance on Pumping Trials to Determine Whether

Installation of Gas Flaring Systems at Landfill Sites Can Be Justified (2005);

UK Environmental Agency Guidance on Landfill Gas Management (2004);

UK Environmental Agency Guidance on Landfill Gas Flaring (2002);

Waste Management Industry Drilling into landfill waste, Industry Code of

Practice (2006); and

Industry Guidance Code Practice Perimeter Soil Gas Emission Criteria and

Associated Management (2011).

2.1.2 Flow Lines

Flow of landfill gas from the gas collection wells will be conveyed to the flare

via a 250 mm header line. The 90 mm diameter flow lines will be laid so that

condensate can fall back to the wells or to a condensate trap. The length of the

lines will be minimised to reduce the likelihood of introducing low points,

friction loss and build-up of condensate.

2.1.3 Remedial Works (to seal landfill cap)

Remedial works will be required by the Civil Contractor after excavation of

the landfill cap, in order to compact the clay liner back to its previous state.

44.00

44.50

45.00

45.00

45.50

46.00

51.00

51.00

51.00

ROAD No. 04

310.5

m468.3m

170.4

m

266.4m

108.3m

125.4m

CELL 2

CELL 1

GM10

GM11

GM9

GW12

GM8

GM2

GM7

GM4

GM6

GM5GM3

GM1

G2

G1

LEACHATE WELL

CELL 3

BLACKTOWN WASTE920 RICHMOND ROADMARSDEN PARK

DLA ENVIRONMENTAL3/38 LEIGHTON PLACEHORNSBY

920 RICHMOND ROAD

GAS WELL LOCATIONS

DRAFT

24/07/2017 SB AJM

4115 1 B

HISTORICAL VENT PIPE

INSTALLED GAS WELL

LFG MONITORING WELL

LEACHATE WELL

PROPOSED 125mm DIA15m DEEP PRODUCTION WELLPROPOSED 90mm DIAMIGRATION CONTROL WELL

KNOCK OUT POT

FLARE

250mm MAIN LINE

125mm MAIN LINE63mm FLOW LINEMANIFOLD


10

2.1.4 Manifolds

Each well will have individual control and measurement of gas flow, pressure

and composition. The tops of the wells will be constructed to enable ease of

removal for dipping, inspection and swapping between passive venting and

active extraction modes.

2.1.5 Condensate Management

Condensate refers to the moisture or liquid that is formed when collected

landfill gas cools. Many factors affect the quantity of condensate generated in

a collection system, including the gas temperature and flow rate. Condensate

will be removed passively at low points using barometric ‘traps’.

2.1.6 Installation of flare unit

A 1,000 m3/hr high temperature, fully enclosed ground flare unit will be

installed on site and connected to an existing three phase power source. This

eliminates the need to use diesel fuel in a portable generator and the use of

non-compliant elevated flares (non-high temperature).

The flare unit will be approximately 7 m high and located approximately 100

m south-west of the site office (refer to Figure 1.1). Figure 2.2 provides a

general arrangement for a similar flare unit and Photograph 2.1 shows an

example of a similar flare unit.

A bobcat excavator and small crane will be used to construct the concrete base

slab and install the flare unit. The works are minor in nature and will take

approximately 3 days to complete. The proposed design will assist with the

installation of the flare unit and make it easier and faster to construct. The

flare unit will be skid mounted and connected to ancillary equipment. By skid

mounting the unit and carrying out final assembly on site, it is possible to

carry out pre-delivery tests in the factory.

The flare unit provides industry best practice control over combustion air to

facilitate elevated temperatures, whilst ensuring complete combustion. All

flaring equipment on site will be compliant with the relevant Australian and

international standards, including:

AS 1375-Industrial Fuel Fired Appliances Code;

AS 3814/AG 501-Industrial and Commercial Gas-fired Appliances;

AS 5601/AG 601-Gas Installations;

Dangerous Substances and Explosive Atmospheres Regulations 2002

(DSEAR);

Implementing the Chemical Agents Directive 98/24/EC (CAD); and

The Explosive Atmospheres Directive 99/92/EC (ATEX 137).


12

Photograph 2.1 Enclosed ground flare unit

Key features of the flare unit are summarised below:

The flare unit will meet current NSW, Australian and European emissions

standards and is fully ATEX compliant.

The flare unit will have a demonstrable 98 to 99 % destruction efficiency.

A stainless steel condensate knockout pot located prior to the entry of the

gas booster ensures that no airborne liquids can pass into the gas booster.

An electric motor, with a direct-drive arrangement to a gas booster, will be

capable of delivering 1,000 m3/hr.


13

A booster motor will be fitted with an inverter drive for variable speed

control and reduced energy costs. By installing an inverter drive, the

booster speed can be set to control the gas flow and save around 50% of the

energy costs.

The flare unit with automatic flame temperature will burn with a

combustion chamber temperature of 1,200 0C when methane concentration

is above 35%. Minimum residence time will be 0.6 seconds.

The height from ground level to the top of the shroud will be between 6.5

and 7.5 m. The chimney will be fitted with two off-gas sampling ports for

emissions monitoring and a stainless steel sample line at 1 m above ground

for sampling.

A gas analyser will be calibrated to read methane, carbon dioxide, oxygen

in %v/v, hydrogen sulphide and carbon monoxide in parts per million. The

gas analyser will have double measuring cells so that incoming gas and

exhaust gas exiting from the chimney can be measured simultaneously.

When this is combined with volumetric flow rate and temperature a mass

balance can be calculated continuously. Hence, a running ‘real-time’

measurement of destruction efficiency can be transmitted on line via the

telemetry unit.

Actual flow in m3/hr and total (cumulative) flow in m3 will be displayed

and recorded.

Temperature gauges will be fitted on the inlet and outlet to the gas booster.

The fixing of the flare stack to the concrete base will comply with relevant

Australian Standards.

The radiation levels at ground level will be within acceptable levels.

All pipework will be manufactured from stainless steel.

A control panel will be weather-proofed and fitted with a 24 hr / 7-day

timer.

2.4 m palisade security fencing will be installed around the flare unit.

The flare will be monitored remotely with alarm set points on gas quality. The

temperature and other variables are recorded by the loggers and transmitted

to a database.

Following installation of the wells and pipework, the system will be pressure

tested and validated prior to the system ‘going live’. The flare will be

monitored so that the critical parameters can be trended to assess the current

conditions on the gas field. The system will be balanced so that the maximum

number of wells can be extracted upon at the maximum rate of flow.


14

2.2 WORKS PROGRAM

Subject to final staging and any weather delays, it is anticipated that

installation works will be completed over a period of approximately three

weeks, which is expected to include mobilisation and demobilisation at

commencement and completion respectively. Operation of the GCS is not

considered part of the works program.

As noted in Section 2.1, installation works will not commence until the final

landfill level is approved by BCC through the existing DA variation process.

2.3 CONSTRUCTION WORKFORCE

It is anticipated that the workforce will consist of approximately five

personnel on site at any one time.

2.4 CONSTRUCTION HOURS

It is anticipated that construction of the Project will be undertaken in general

accordance with the Interim Construction Noise Guideline (DECC, 2009), with

the standard hours of work being:

Monday to Friday: 7.00am-6.00pm;

Saturday: 8.00am-1.00pm; and

no works on Sunday or public holidays.

Construction works outside the standard construction hours may be undertaken in the following unlikely circumstances:

for the delivery of materials required outside the standard construction

hours by the NSW Police Force or other authorities for safety reasons; or

where it is required in an emergency to avoid the loss of lives, property

and/or to prevent environmental harm.

2.5 SITE ACCESS AND EGRESS

The proposed installation works will utilize Quarry Road via Richmond Road

for access to and egress from the Project area.

2.6 CONSIDERATION OF ALTERNATIVES

The following Project alternatives have been investigated as part of this SoEE

and are described below:


15

Do Nothing or Passive Approach (leave the landfill in its current state) –

This approach could result in:

Increased risk of sub-surface migration of landfill gas and other

contaminants in the event of failure of the system;

Increased emissions of un-oxidised methane direct to atmosphere acting

as a GHG; and

Increased risk of odours from organic compounds present in landfill gas.

Active Approach – This is the proposed installation of the GCS and flare

unit described above.

2.6.1 Preferred Option

The preferred option is to install the GCS and flare unit and this is the subject

of this application. Justification for the proposed works is provided below:

Removal of potentially hazardous landfill gases resulting in reduced health

and safety risks to nearby residents and community;

The removal of methane during gas collection and flaring will reduce GHG

emissions from the site, which makes the Project eligible under the ERF

enabling the offsetting of fossil fuel, which in turn results in a beneficial

environmental outcome and positive impact; and

The Project will contribute to the future rehabilitation and redevelopment

of the landfill site. The Project will assist in achieving the final land use goal

of ‘low density industrial use’, which will support the local community by

providing jobs and services, and in turn increasing cash flow throughout

the community.


16

3 LEGISLATIVE AND POLICY CONSIDERATIONS

3.1 COMMONWEALTH LEGISLATION

3.1.1 Environmental Protection and Biodiversity Conservation Act 1999

The Environment Protection and Biodiversity Conservation Act 1999 (EPBC

Act) streamlines the national environmental assessment and approvals

process, protects Australian biodiversity and integrates management of

important natural and cultural places. Referral under the EPBC Act is

required for actions that are likely to have a significant impact on any

matter protected by the EPBC Act, including Matters of National

Environmental Significance (NES) as listed under the Act.

Table 3.1 Relationship between proposed works and Matters of National

Environmental Significance

Matters of National

Environmental Significance Application to the proposed works

Relevant

Sections

World heritage properties Not identified within the Project area. Not applicable

National heritage places Not identified within the Project area. Not applicable

Ramsar wetlands of international

importance

Not identified within the Project area. Not applicable

Listed threatened species and

communities

Potential habitat of threatened species

may occur within surrounding areas

of the Project area.

No Threatened Ecological

Communities (TEC) are present

within the Project area, however may

be present within areas surrounding

the Project area.

Not applicable

Internationally protected migratory

species

Migratory species identified as

potentially occurring within areas

surrounding the Project area.

Not applicable

Commonwealth marine areas Not identified within the Project area. Not applicable

The Great Barrier Reef Marine Park Not identified within the Project area. Not applicable

Nuclear actions Not identified within the Project area. Not applicable

A water resource, in relation to coal

seam gas development and large

coal mining development

Not identified within the Project area. Not applicable

3.2 NSW LEGISLATION

3.2.1 Environmental Planning and Assessment Act 1979

The Environmental Planning and Assessment Act 1979 (EP&A Act) is the

principal planning legislation for NSW. Section 79C of the EP&A Act

requires the consent authority to take into consideration a range of matters

when undertaking an assessment of a DA. These matters are address in

Section 5.


17

‘Designated development’ refers to developments that are high-impact

developments (e.g. likely to generate pollution) or are located in or near an

environmentally sensitive area (e.g. a wetland). There are two ways a

development can be categorised as designated development:

1. the class of development can be listed in Schedule 3 of the

Environmental Planning and Assessment Regulation 2000 (EP&A

Regulation) as being designated development, or

2. a LEP or SEPP can declare certain types of development to be

designated.

For designated development an environmental impact statement is

required and third parties must be notified and can appeal against a

decision to grant consent.

Under the EP&A Regulation, Schedule 3, Clause 4, Part 1 lists the

following as designated development:

32 Waste management facilities or works (1) Waste management facilities or works that store, treat, purify or dispose of waste or sort, process, recycle, recover, use or reuse material from waste and:

(a) that dispose (by landfilling, incinerating, storing, placing or other means) of solid or liquid waste: (i) that includes any substance classified in the Australian Dangerous Goods Code or medical, cytotoxic or quarantine waste, or (ii) that comprises more than 100,000 tonnes of “clean fill” (such as soil, sand, gravel, bricks or other excavated or hard material) in a manner that, in the opinion of the consent authority, is likely to cause significant impacts on drainage or flooding, or (iii) that comprises more than 1,000 tonnes per year of sludge or effluent, or (iv) that comprises more than 200 tonnes per year of other waste material

The Project does not meet this definition of designated development in the

EP&A Regulation. There are also no LEPs or SEPPs which declare the

Project as designated development.

Schedule 4A of the EP&A Act identifies development for which Joint

Regional Planning Panels (JRPPs) may be authorised to exercise consent

authority functions of councils. The relevant provisions of Schedule 4A

applicable to the Project include:

‘general development’ that has a capital investment value of more than $20

million;

The Project has a capital investment value of approximately $495,000,

therefore this provision does not apply.


18

Private infrastructure and community facility development that has a capital

investment value of over $5 million for any of the following purposes: air

transport facilities, electricity generating works, port facilities, rail

infrastructure facilities, road infrastructure facilities, sewerage systems,

telecommunications facilities, waste or resource management facilities, water

supply systems, or wharf or boating facilities

The Project is less than $5 million and is not consistent with any of

those purposes, therefore this provision does not apply.

As none of the provisions above apply to the Project, the consent authority is

BCC and a DA with an accompanying SoEE will be lodged for determination

under Part 4 of the EP&A Act.

Part 4 of the EP&A Act identifies integrated development, where approval

must also be obtained from other public authorities before consent can be

granted. Integrated development applications require a permit listed in

Section 91 of the EP&A Act. For the Project to operate, an EPL is required

under Protection of the Environment Operations Act 1997. BWS will submit a

variation request to the NSW EPA to modify their existing EPL (11497) to

include the proposed works. A similar process was recently undertaken for

the Horsley Park Landfill.

3.2.2 Protection of the Environment Operation (Clean Air) Regulation 2010

Regulatory requirements for the combustion of landfill gas by the use of an

active GCS and flare unit is detailed within the New South Wales

Environmental Protection Agency (NSW EPA) Environmental Guidelines: Solid

Waste Landfills (2016) and Protection of the Environment Operations (Clean Air)

Regulation 2010 (POEO Regulation).

The key air pollutants of concern from the combustion of LFG include oxides

of nitrogen and sulphur, and un-combusted volatile organic compounds. The

POEO Regulation requires Group 6 Treatment Plants to comply with the

following conditions:

Condition 49:

a) any flare operated for the treatment of air impurities is operated in such a way

that a flame is present at all times while air impurities are required to be

treated, and

b) either or both of the following requirements relating to the operation of any

such plant are complied with:

i. the requirements in clauses 50 and 51,

ii. the requirements in clause 52.


19

Condition 50:

(2) An enclosed ground-level flare for the treatment of landfill gas must be operated

in such a way that the time between landfill gas entering and exiting the flare is

more than 0.6 seconds.

(3) For the purposes of this clause, the time elapsing between an air impurity

(including landfill gas) entering and exiting an afterburner or flare is to be

calculated:

a) using the volumetric flow rate for the air impurity, as determined in

accordance with TM-2 or CEM-6, and

b) using a 1 hour rolling averaging period.

Condition 51:


in such a way that the temperature for the combustion of landfill gas by the flare is

more than 760°C.

Condition 52:


in such a way that the destruction efficiency of the flare, in relation to landfill gas

entering the flare, is more than 98%.

Any liquid condensed from the landfill gas shall be handled in the same manner

as leachate. Because of the low pH and the potential odour it shall not be spray-

irrigated.

The discharge point(s) from any landfill gas combustion source should be

designed to promote good dispersion (i.e. by means of such factors as stack

height, diameter and discharge velocity) and ensure that the ground level

concentration criteria are not exceeded.

Additionally, Schedule 2 Clause 38 also requires that gas treatment discharge

limits which are to be complied with during operations (Table 3.2).


20

Table 3.2 Pollutant discharge limits (POEO Regulation)

Pollutant Standard of concentration

(mg/m3 )

Hydrogen sulphide (H2S) 5

Nitrogen dioxide (NO2) or nitric oxide (NO) or

both, as NO2 equivalent 350 (flare)

Sulfuric acid mist (H2SO4) or sulphur trioxide

(SO3) or both, as SO3 equivalent 100

Volatile organic compounds as n-propane

equivalent 40

Smoke (as a Group 6 category Treatment Plant)

No visible emission other than

for a total period of no more than

5 minutes in any 2 hours

Implications for the Project

The pollutant discharge limits set out in the POEO Regulation will not be

exceeded during operation of the Project. A similar flare unit was recently

approved by the NSW EPA at the Horsley Park Landfill Site, which contained

results from previous emissions tests, which demonstrated compliance with

these discharge limits. Refer to Section 4.6 for further details.

3.3 STATE ENVIRONMENTAL PLANNING POLICIES

3.3.1 State Environmental Planning Policy (Sydney Region Growth Centres) 2006 -

Marsden Park Industrial Precinct Plan 2010

The Marsden Park Landfill falls within the MPIP, which in itself contains a

plan within Appendix 5 of this SEPP (i.e. Marsden Park Industrial Precinct

Plan 2010). The site is zoned ‘IN1’ General Industrial, which permits

development of the following with consent:

Animal boarding or training establishments; Depots; Drainage; Earthworks;

Freight transport facilities; Light industries; Neighbourhood shops; Recreation

facilities (major); Registered clubs; Roads; Take away food and drink premises;

Warehouse or distribution centres; Waste or resource management facilities; Any

other development not specified in item 2 or 4

The Project does not fall into any of the developments listed above, or into any

of the prohibited developments listed in Item 4, as it is not ‘Waste or resource

management facilities’ or ‘Waste disposal facilities’. Therefore the Project is

permitted with development consent from BCC.

3.3.2 State Environmental Planning Policy No 33— Hazardous and Offensive

Development

In accordance with State Environmental Planning Policy 33 – Hazardous and

Offensive Development (SEPP 33), consideration has been made as to whether

the Project should be considered a hazardous or potentially hazardous

industry using the Applying SEPP 33 – Hazardous and Offensive Development

Application Guidelines (SEPP 33 Guidelines).


21

The Project will not involve the storage of hazardous materials within the site

or the transportation of hazardous materials to/from the site. In addition,

Appendix 3 of the SEPP 33 Guidelines provides a schedule of potentially

hazardous industries that may fall within SEPP 33. The proposed works are

not included in the schedule.

The Project is not deemed hazardous or potentially hazardous under SEPP 33

and therefore it is not considered applicable. Nevertheless, a high-level risk

assessment has been undertaken for the Project and is summarised in Section

4.11 of this report.

3.4 LOCAL STATUTORY CONTEXT

3.4.1 Blacktown Local Environmental Plan 2015

The Marsden Park Landfill site exists within the SEPP (Sydney Region Growth

Centres) 2006 zoning within the Blacktown LEP 2015. The site therefore is

assessed under the conditions of the SEPP, which takes preference over the

LEP.

3.5 DEVELOPMENT CONTROL PLANS

3.5.1 Blacktown City Council Growth Centre Precincts Development Control Plan

2014 (Schedule 3 – Marsden Park Industrial Precinct)

BCC has a consolidated Development Control Plan (DCP) for development

within the Blacktown LGA, being the BCC Growth Centre Precincts DCP 2014.

Site-specific controls for the MPIP support the controls in the DCP under

Schedule 3 – Marsden Park Industrial Precinct of the DCP. The DCP has been

prepared to provide guidance to applicants proposing to undertake

development in the BCC Growth Centre precincts in respect of the planning,

design and environmental objectives and controls.

There are no specific controls relating to the proposed works outlined in the

plan. The general development objectives and controls outlined in the Plan

have been considered in the preparation of the SoEE, as relevant to the Project

and its potential impacts, and included in the management and mitigation

measures.


22

4 ENVIRONMENTAL IMPACT ASSESSMENT AND MANAGEMENT

4.1 FLORA AND FAUNA

4.1.1 Existing Environment

A site inspection was undertaken at the Marsden Park Landfill on 20 October

2017 to inspect the site and surrounding areas for potential sensitive receptors

and other potential areas of impact to the surrounding environment.

Additional inspection was undertaken to observe any remnant vegetation or

signs of biodiversity value, to assist in the determination of the suitability of

the site as habitat for flora and fauna.

The findings from the site inspection indicated a lack of suitable habitat for

fauna within the Project area due to the degree of disturbance from the landfill

operation, and the lack of suitable vegetation necessary for foraging and

protection. The only vegetation within the Project area was a small stand of

mature gum tress located around the site office.

An EPBC Protected Matters Search was also undertaken on 31 October 2017 to

determine whether Matters of National Environmental Significance or other

matters protected by the Environment Protection and Biodiversity Conservation

Act 1999 were likely to occur within the area of interest. The search included a

1 km buffer around the Project area in all directions.

Threatened Ecological Communities

The results of the search indicated that four Threatened Ecological

Communities (TEC’s) have potential to exist within the area and surrounding

areas, including Castlereagh Scribbly Gum and Agnes Banks Woodlands of

the Sydney Basin Bioregion, the Cooks River/Castlereagh Ironbark Forest of

the Sydney Basin Bioregion, the Cumberland Plain Shale Woodlands and

Shale-Gravel Transition Forest and the Western Sydney Dry Rainforest and

Moist Woodland on Shale threatened ecological communities.

There is scarce remnant vegetation throughout the Project area, however due

to ongoing disturbance as a result of existing landfill operations, such

vegetation is not considered optimal for habitat for native fauna.

Threatened Flora and Fauna Species

No threatened species were observed within the Project area during the site

inspection. The results of the Protected Matters Search Tool identified 29

threatened species which have the potential occur based on the presence of

suitable habitat and records within the locality. Table 4.1 below provides

information on the listed threatened species with potential to exist within and

in areas surrounding the Project area.


23

Table 4.1 Threatened species (and/or threatened species habitat) with potential to occur

within the Project area

Value Type Scientific Name Common Name Conservation Status

BC Act EPBC

Birds Anthochaera Phrygia Regent Honeyeater CE CE

Birds Numenius

madagascariensis

Eastern Curlew, Far

Eastern Curlew

- CE

Birds Calidris ferruginea Curlew Sandpiper E CE

Birds Lathamus discolour Swift Parrot E CE

Birds Botaurus poiciloptilus Australasian Bittern E E

Birds Rostratula australis Australian Painted

Snipe

E E

Birds Grantiella picta Painted Honeyeater V V

Fish Macquaria australasica Macquarie Perch E E

Fish Prototroctes maraena Australian Grayling E V

Frogs Heleioporus australiacus Giant Burrowing Frog V V

Frogs Litoria aurea Green and Golden Bell

Frog

E V

Mammals Dasyurus maculatus

maculatus (SE mainland

population)

Spot-tailed Quoll,

Spotted-tail Quoll,

Tiger Quoll

(south-eastern

mainland population)

V E

Mammals Chalinolobus dwyeri Large-eared Pied Bat,

Large Pied Bat V V

Mammals Petauroides Volans Great Glider - V

Mammals Pseudomys novaehollandiae New Holland Mouse,

Pookila V V

Mammals Phascolarctos cinereus Koala V V

Mammals Pteropus poliocephalus Grey-headed Flying-

fox V V

Plants Allocasuarina glareicola - E E

Plants Genoplesium bauera Yellow Gnat-orchid E E

Plants Pimelea spicata Spiked Rice-flower E E

Plants Pterostylis saxicola Sydney Plains

Greenhood E E

Plants Acacia bynoeana Bynoe’s Wattle, Tiny

Wattle E V

Plants Acacia pubescens Downy Wattle, Hairy

Stemmed Wattle V V

Plants Haloragis exalata subsp.

exalata

Wingless Raspwort,

Square Raspwort V V


24

Value Type Scientific Name Common Name Conservation Status

BC Act EPBC

Plants Micromyrtus minutiflora - E V

Plants Pimelea curviflora var.

curviflora

- V V

Plants Pultenaea parviflora - E V

Plants Syzygium paniculatum Magenta Lilly Pilly,

Magenta Cherry,

Daguba, Scrub Cherry,

Creek Lilly Pilly, Brush

Cherry

E V

Plants Thesium austral Austral Toadflax,

Toadflax V V

CE = Critically Endangered, E = Endangered, V – Vulnerable

4.1.2 Assessment of Impact

No vegetation will be required to be cleared and the small stand of mature

gum tress located around the site office will not be impacted. Due to the

minimal environmental disturbance associated with the proposed works, it is

considered highly unlikely that any significant impacts to flora and fauna

would arise from the installation and operation of the GCS and flare unit.

4.1.3 Environmental Mitigation

Given the limited potential for any ecological impacts to occur, no

recommendations for mitigation and management measures are warranted or

provided in this SoEE.

4.1.4 Conclusion

The Project is not likely to result in a significant impact on any threatened

species or threatened ecological community listed under the BC Act or the

EPBC Act. The Project is not anticipated to have any significant impact upon

ecological values of the area and the environmental risk is considered to be

negligible.

4.2 ABORIGINAL HERITAGE


ERM undertook a targeted Aboriginal Heritage Information Management

systems (AHIMS) search on 9 November 2017, which revealed that four

Aboriginal sites had been previously recorded within the proximity of the

Project area. No artefacts or items of significance were declared within the

Project area.


25

It is expected that the existing Project area is of relatively low Aboriginal

archaeological significance and sensitivity, due to the highly disturbed and

modified landscape in which the landfill currently exists, and the limited

identified items (or areas) of significance within and surrounding the Project

area.


Due to the highly modified existing environment throughout and surrounding

the Project area and the results of the AHIMS search, it is considered unlikely

that any impacts to areas of Aboriginal or archaeological significance will

occur during the proposed works.


Given the limited potential for any Aboriginal heritage impacts to occur, no



4.2.4 Conclusion

Due to the current lack of declared Aboriginal heritage areas within and

surrounding the Project area, the Project is not anticipated to have any

significant impact upon Aboriginal heritage and the overall environmental

risk is considered to be negligible.

4.3 NON-ABORIGINAL HERITAGE


ERM undertook a search of relevant databases, inventories and registers,

including the NSW State Heritage Register, the NSW State Heritage Inventory,

the EPBC Act listings, Australian Heritage Register and the Blacktown LEP

2015 to determine if any items of non-Aboriginal Heritage (also referred to as

historic heritage) significance were found previously on or in the vicinity of

the Project area.

Searches of the abovementioned databases confirmed that no items of non-

Aboriginal significance exist within the Project area, with the closest item

being approximately 2.2 km north of the site.


Minimal disturbance to areas of non-Aboriginal heritage are expected during

the proposed works due to the distance from the closest item of significance

and the minor disruptive activities associated with the proposed works.


26


Given the limited potential for any non-Aboriginal heritage impacts to occur, no recommendations for mitigation and management measures are warranted or provided in this SoEE.

4.3.4 Conclusion

The Project is not expected to impact upon any listed items of non-Aboriginal

heritage significance and the environmental risk is considered to be negligible.

4.4 GEOLOGY AND SOIL

A desktop study of the landform, soils and geology along the Project area was

undertaken using the Soil Landscapes of the Penrith 1:100 000 sheet report

prepared by the Department of Land and Water Conservation, Sydney (Banks,

2001).


The Marsden Park Landfill exists within the Blacktown Soil Landscape, which

is comprised of:

Low hills and rises on Wianamatta Group Shale (shale, sandstone-lithic and

sandstone-quartz) in the Cumberland Plain, Hornsby Plateau and Picton

Hills. Local relief 10-50 m; altitude 10-202 m; slopes 0-9%; rock outcrop nil.

Extensively cleared woodland.

The landfill is located in a relatively anthropogenic environment (cleared vegetation and pre-existing disturbance from landfill operations) with minimal interaction with the soil. The landfill has a Flexible Membrane Liner.


Installation and operation of the GCS and flare unit is not expected to cause

any activities that may give rise to potential soil impacts. Only minor

excavation works will be required in the landfill mass itself and near the site

office for the installation of the concrete base slab. Futures settlement of the

landfill mass will not affect the operation of the GCS or flare unit.

Site personnel vehicles, heavy vehicles and plant and equipment will use

existing paved and sealed areas, which will not be disturbed by the works.


Due to the highly disturbed and industrial nature of the Project area, impacts

to soil and geographic landscape are expected to be minimal, however

mitigation measures will be in place to ensure that any potential impacts are

managed where practicable.


27

Sediment and erosion control devices will be established before any ground

disturbance begins and maintained as necessary until affected ground surfaces

have been adequately stabilised. The following general principles and

mitigation and management measures will be implemented during the

proposed works:

establishment and maintenance of sediment and erosion control devices

will be consistent with the Landcom Managing Urban Stormwater: Soils and

Construction (New South Wales Government, 2004), commonly referred to

as the ‘Blue Book’;

if the presence of contaminated soils is identified, removal will take place in

accordance with NSW EPA (2014) Waste Classification Guidelines;

appropriate PPE will be utilized during proposed works;

where practicable, maintenance of natural buffer zones between disturbed

areas and drainage lines will be implemented.

stockpiles of soil/landfill waste will be appropriately located away from

waterways and drainage lines; and

where areas have been disturbed and ongoing use of disturbed areas is not

required for operations, reinstatement of the natural ground level and

revegetation of disturbed areas will be undertaken.

4.4.4 Conclusion

By implementing the aforementioned mitigation measures, the Project is not

anticipated to have significant adverse impacts on local soils and the

environmental risk is considered to be negligible.

4.5 WATER QUALITY AND HYDROLOGY


The Project area is located within the Hawksbury-Nepean Catchment and

approximately 1.2 km west of Bells Creek. The creek generally flows

north/north-east until it reaches its confluence with Eastern Creek. Bells

Creek will be not be affected by the proposed works. A minor tributary of

South Creek is located to the west of the Project area, which will also be

avoided during the proposed activities.

A search of the NSW groundwater data resource All Water Data (DPI, Office

of Water) identified groundwater bores registered within 1 km of the Project

area. Three monitoring bores are located in the vicinity of the site, however

the Standing Water Level data was unavailable and has not been reproduced

within Table 4.3 below.


28

Table 4.2 NSW Office of Water Registered Bores Within Project Vicinity

Bore Number Co-ordinates Standing Water

Level (m bgl)

Final Depth

(m)

Use of Well

GW104308 N: 6268327.0

E: 298650.0

- 14 Monitoring

Bore

GW104310 N: 6268471.0

E: 299111.0

- 9 Monitoring

Bore

GW104311 N: 6268327.0

E: 299016.0

- 17 Monitoring

Bore

The nearest bore is located approximately 875 m to the north of the Project

area and will not be affected by the proposed works.


Potential water related impacts associated with the proposed activities

include:

erosion of any waste stockpiles (landfill waste, etc.);

water collected within the Project area following rainfall events may have

high sediment content and if not managed appropriately, could

contaminate surface waters;

potential accidental hydrocarbon spills from plant and equipment (burst

hoses, mechanical failures, leaking machinery, etc.); and

contamination of waterways from hazardous substances due to incorrect

storage (including drums and containers and spent oil filters, etc.).

4.5.3 Environmental Mitigation Measures

The following mitigation and management measures will be implemented

during the proposed works:

avoid and/or cover existing drainage infrastructure during proposed

works to reduce potential for contamination;

landfill waste will only be temporarily stockpiled and reinstated as soon as

practicable post installation of the GCS;

spill response plans/procedures will be prepared for the Project prior to

commencement of proposed works; and

spill kits will be made available in locations used for chemical storage,

where refuelling is undertaken, and in other sensitive work sites where

potential for spills from plant or equipment are in use.


29

4.5.4 Conclusion

By implementing the aforementioned mitigation measures, the Project is not

anticipated to have significant adverse impacts on water quality and

hydrology and the environmental risk is considered to be negligible.

4.6 AIR QUALITY AND GHG


Based on the surrounding land use, it is expected that existing air quality in

the locality is influenced by nearby industrial and commercial facilities, along

with the existing operations undertaken at the landfill site, including the

movement of vehicles to and from the site. During unfavourable (high wind)

weather conditions, it is possible that the landfill site impacts local air quality

due to the mobilisation of airborne odour particulates, and air quality

pollutants being emitted from vehicular movements associated with the

operation of the site (e.g. trucks delivering waste to the landfill site).


During the installation of the GCS in the landfill mass, there is the potential

for localised, short-term odour impacts from the drilling waste. The waste

will be taken to the active tip face and filled immediately.

The combustion of the landfill gas by the flare unit will result in the emission

of air pollutants. The key air pollutants of concern from the combustion of

landfill gas include oxides of nitrogen, sulphur and un-combusted volatile

organic compounds (VOCs). As such, discharge limits are applied to the

above pollutants under the Protection of the Environment Operations (Clean Air)

Regulation 2010 (Schedule 2), which will be adhered to during operation of the

flare unit (refer to Table 4.3).

Table 4.3 Pollutant discharge limits

Pollutant Standard of concentration

(mg/m3 )

Hydrogen sulphide (H2S) 5

Nitrogen dioxide (NO2) or nitric oxide (NO) or both,

as NO2 equivalent 350 (flare)

Sulfuric acid mist (H2SO4) or sulphur trioxide (SO3)

or both, as SO3 equivalent 100

Volatile organic compounds as n-propane

equivalent 40

Smoke (as a Group 6 category Treatment Plant)

No visible emission other than

for a total period of no more

than 5 minutes in any 2 hours


30

These pollutant discharge limits will not be exceeded during operation of the

flare unit, due to rigorous compliance testing which must be undertaken and

documented prior to installation. A similar flare unit was recently approved

by the NSW EPA at the Horsley Park Landfill Site, which contained results

from previous emissions tests, which demonstrated compliance with these

discharge limits. A typical flare emission testing report is provided in

AnnexA.

Following on-site commissioning of the GCS and flare unit, a National

Association of Testing Authorities (NATA) accredited Contractor will

undertake the compliance emission monitoring. The NATA contractor will be

independent of BWS and will meet the following requirements:

Testing procedures are NATA accredited in accordance with ISO/IEC

17025 and AS4323.1;

NATA accreditation number recorded; and

Principal and senior level technicians accredited under The American

Source Evaluation Society’s QSTI program.

The initial program of testing will be undertaken annually subject to passing

all compliance tests.


The following mitigation and management measures will be implemented

during the proposed works:

during installation, significant dust generating activities (if any) will be

avoided during unfavourable (high wind) weather conditions;

dust suppression may be used during installation, if required;

undertake regular operational compliance monitoring and maintenance of

the GCS and flare unit as described in Section 4.11 below;

4.6.4 Conclusion

The flare unit will utilise the latest technology to meet present and near future

emissions standards. By implementing the aforementioned mitigation

measures, the Project is not anticipated to have adverse impacts on air quality

and the environmental risk is considered to be negligible The reduction in

GHG emissions (in particular, methane) as a result of the Project will have a

beneficial environmental outcome and positive impact. The Project will also

reduce the potential for odorous landfill gases to dissipate to surrounding

receivers.


31

4.7 NOISE AND VIBRATION

Nuisance, or an unacceptable level of noise amenity, may arise from

construction or operational activities associated with new or existing

developments. This section addresses potential issues associated with noise

and vibration generated by the Project and provides recommendations for

mitigation and management measures. These measures are based on the

likely magnitude and extent of potential impacts, they are designed to reduce

noise and vibration levels as far as practicable and to assist achieve an

acceptable amenity for residential (dwelling) occupants and other sensitive

receptors surrounding the site.

The key noise issues potentially associated proposed works are mainly

operational noise emissions attributable to the operation of the GCS and flare

unit, with minor noise expected during installation activities. Potential noise

issues associated with road traffic from Project vehicles on public roads and

potential vibration issues associated with the proposed works are also

considered here but impacts are unlikely to occur, if at all.

4.7.1 Policy Setting

This noise and vibration assessment has been conducted with due regard to

and in accordance with the following key policy and guidelines. Other local

and international acoustical standards have been adopted where relevant to

the assessment.

NSW Environmental Protection Authority (EPA) – Noise Policy for Industry

(NPI), October 2017 (which supersedes the NSW Industrial Noise Policy

(INP), January 2000);

NSW Department of Environment and Climate Change – NSW Interim

Construction Noise Guideline (ICNG), July 2009;

NSW Department of Environment, Climate Change and Water – NSW Road

Noise Policy (RNP), March 2011; and

NSW Department of Environment and Conservation - Assessing Vibration:

A Technical Guideline (NSW Vibration Guideline), February 2006.

The key noise and vibration guideline applicable to this assessment is the NPI

and is associated with the proposed operation of the GCS and flare unit.


A key element in assessing environmental noise impacts is an understanding

of the existing noise conditions at areas surrounding, or in proximity to, a site.

In particular, the ambient and background noise levels at or in the vicinity of

the closest and/or potentially most affected receptors situated within the

potential area of influence of a project.


32

This is of particular importance (and a formal assessment requirement for

projects developed in NSW) as it assists to directly evaluate potential noise

impacts and prevents an incremental increase in background noise levels, the

result of which may both generate nuisance, or an unacceptable level of noise

amenity.

Existing vibration levels are not required to be measured as vibration criteria

are fixed values that do not depend on the existing conditions. Hence, this

section focuses on the existing noise environment.

Existing Noise Conditions

The existing environment in the vicinity of the Project is described as

‘suburban’. Although being in an area zoned ‘industrial’ within the State

Environmental Planning Policy (Sydney Region Growth Centres) 2006, the

area is consistent with the characteristics identified for suburban residential

receiver category outlined in the NPI.

The existing noise generating activities within the vicinity of the Project

include:

noise generated from nearby facilities, warehouses and commercial

premises;

noise generated by the activities undertaken on site in regards to the

operation of the landfill; and

road traffic noise from the roadways adjacent to the Project area, including

Richmond Road.

No other significant noise generating activities or sources have been identified

to occur in the area.

Potentially Sensitive Receptors

The NPI and the ICNG identify a number of sensitive receptor types that

should be considered when assessing noise and vibration impacts. These

receptor types include residential premises, schools, hospitals, places of

worship, recreational areas as well as commercial and industrial premises.

The nearest schools, hospitals and places of worship are all between

approximately 2 to 6 km away from the Project area. Residential properties

have been identified based on a review of aerial photography, and are located

approximately 750 m south, approximately 500 m to the north and

approximately 850 m northeast from the Project area. The nearest commercial

and industrial receptors are located approximately 400 m from the Project

area.


33

Estimated Background Noise Levels

In the absence of measured ambient and background noise level data for the

site and surrounding area, representative values have been estimated for the

purpose of this assessment. The ‘Rating Background Level’ (RBL) has been

established following a review of aerial photography and knowledge of

existing background noise levels for similar acoustical environments and a

review of the existing EPL (11497).

In accordance with the NPI the RBL is defined as the overall single figure

background level representing each assessment period; daytime, evening, and

night time. The RBL values considered in this assessment are presented in

Table 4.4 for each assessment period separated by northern and southern

receptors.

Table 4.4 Rating Background Noise Levels (RBL)

RBL (dBA)

Day Evening Night

Northern

Receptors 40 35 30

Southern

Receptors 35 30 30

1. In accordance with the NPI the assessment periods are defined as follows:

a) Day – the period from 7 am to 6 pm Monday to Saturday or 8 am to 6 pm on Sundays

and public holidays

b) Evening – the period from 6 pm to 10 pm

c) Night – the remaining periods.

4.7.3 Noise Management Levels and Criteria

All Project-specific Noise Management Levels (NML) and criteria have been

established in accordance with the NPI, ICNG and RNP as applicable to the

factor being addressed. For residential receptors these levels have been based

on the estimated RBL values presented in Table 4.4. NMLs and criteria for

other sensitive receptors are fixed values and do not rely on RBL.

For the purposes of the assessment the LAeq, 15 minute parameter has been

adopted for all receptors (including other sensitive receptors) assuming that

emissions will generally occur throughout the total duration of any given

assessment period. LAeq is an A-weighted noise level representing the

equivalent or average noise energy during a measurement period. The LAeq,

15minute noise descriptor simply refers to the LAeq noise level calculated over a

15 minute period. For road traffic noise, the LAeq parameter also applies with

assessment periods of one hour, nine hours or 15 hours depending on the type

of road and time of day.


34

Construction Noise

For construction noise, the NML values have been determined with due

regard to the ICNG utilising the RBLs described in Section 4.7.2. During

construction, the Highly Noise Affected Management Level (HNML) also

applies to residential receptors during standard daytime hours and is a fixed

value of LAeq, 15 minute 75 dB (dB or decibels is the unit used to measure sound

pressure levels. For A-weighted decibels, dBA may be used. A-weighting is an

adjustment made to sound-level measurement to approximate the response of

the human ear). Construction NMLs are presented in Table 4.5 below.

Table 4.5 Construction Noise Management Levels (NML) - (LAeq, 15 minute)

Receptor Type

NML (dBA)

Standard Hours Non-Standard Hours

Day Day Evening Night

Northern Residential 50 45 40 35

Southern Residential 45 40 35 35

Commercial Premises 70 70 70 70-

Industrial Premises 75 75 75 75

1. In accordance with the ICNG the recommended standard hours of construction are

Monday to Friday 7 am to 6 pm, Saturday 8 am to 1 pm and no work on Sundays or

public holidays.

In accordance with the ICNG, NML values for other sensitive receptors (i.e.

places of worship, commercial and industrial premises, schools or recreational

areas) are fixed levels based on usage. They are not derived from measured

ambient and background noise levels.

Operational Noise

All Project-specific operational noise management levels (project intrusiveness

noise level) are presented in Table 4.6. These values have been determined

with due regard to the NPI utilising the RBLs described above.

Table 4.6 Operational - Project Intrusiveness Noise Level - (LAeq, 15 minute)

Receptor Type RBL (dBA)

Day1 Evening2 Night3

Northern Residential 45 40 35

Southern Residential 40 35 35

1. Day – the period from 7 am to 6 pm Monday to Saturday or 8 am to 6 pm on Sundays

and public holidays

2. Evening – the period from 6 pm to 10 pm

3. Night – the remaining periods.


35

In accordance with the NPI, intrusiveness noise levels are only applied to

residential (dwelling) receptors. For other receptor types identified, only the

amenity levels outlined in the NPI apply.

Intrusiveness noise levels and amenity noise levels are not used directly as

regulatory limits. They are used in combination to assess the potential impact

of noise, assess reasonable and feasible mitigation options, and subsequently

determine achievable noise requirements.

Road Traffic Noise Criteria

The NPI and ICNG do not include any criteria to assess off-site traffic noise

associated with operation and construction. Criteria for off-site road traffic

noise applicable to ‘existing residences affected by additional traffic on

existing roads generated by land use developments’ are specified in the RNP.

Whilst these criteria do not specifically apply to construction/operational

traffic movements, they have been conservatively adopted for this assessment.

In accordance with the RNP, criteria values for residential receptors are fixed

levels. They are not derived from measured ambient and background noise

levels.

The project-specific road traffic noise criteria are presented in Table 4.7 below.

Table 4.7 Road Traffic Noise Criteria

Road Category Assessment Criteria - dBA

Day

(7 am - 10 pm)

Night

(10 pm - 7 am)

Freeway / Arterial / sub-

arterial roads 60 LAeq, 15 hour (external) 1 55 LAeq, 9 hour (external) 1

Local roads 55 LAeq, 1 hour (external) 2 50 LAeq, 1 hour (external) 2

1. Existing residences affected by additional traffic on existing freeways/arterial/sub-arterial

roads generated by land use developments; and

2. Existing residences affected by additional traffic on existing local roads generated by land

use developments.

Where existing traffic noise levels are above the noise assessment criteria, the

primary objective is to reduce these through feasible and reasonable measures

to meet the assessment criteria. A secondary objective is to protect against

excessive decreases in amenity as the result of a project by applying the

relative increase criteria outlined in the Section 2.4 of the RNP.

In assessing feasible and reasonable mitigation measures, an increase of up to

2 dBA represents a minor impact that is considered barely perceptible to the

average person. A relative increase of 12 dBA (as per the relative increase

criteria) represents slightly more than an approximate doubling of perceived

loudness (RNP, 2011) and is likely to trigger community reaction, particularly

in environments where there is a low existing level of traffic noise.


36

Vibration Criteria and Safe Limits

The effects of vibration in buildings can be divided into three main categories:

human comfort (annoyance); cosmetic damage; and structural damage. An

overview of the applicable standards and guidelines is provided below.

Human Comfort (Annoyance): the NSW Vibration Guideline provides

guidance for assessing human exposure (comfort or annoyance issues) to

vibration. The publication is based on British Standard (BS 6472–1992) –

Evaluation of Human Exposure to Vibration in Buildings (1 Hz to 80 Hz), dated

1992.

Cosmetic and Structural Damage: there is currently no Australian policy,

standards or guidelines for assessing the potential for building damage

(cosmetic and structural) from vibration. It is common practice however to

derive safe limit values for assessment purposes from international standards,

such as British Standard BS7385: Part 2-1993 (BS 7385) - Evaluation and

Measurement for Vibration in Buildings — Part 2 – Guide to Damage Levels from

Ground-borne Vibration, dated 1993 and German Standard DIN4150 Part 3-1999

(DIN4150-3) – Structural Vibration - Effects of Vibration on Structures, dated

1999.

The NSW Vibration Guideline, BS 7385 and DIN 4150 vary based on vibration

type, receptor type and are dependent on the component frequency of the

vibration event. To avoid presenting an exhaustive list of criterion values and

as vibration impacts are not expected (refer Section 4.7.4 below), the criteria

values from the NSW Vibration Guideline, BS 7385 and DIN 4150 were

considered in the assessment of potential impacts but are not reproduced here.


A quantitative assessment of potential noise and vibration impacts associated

with the installation and operation of the GCS and flare unit (including road

traffic) has not been undertaken. Instead, a qualitative assessment is provided

below.

Construction Noise

The construction and installation of the GSC would be completed over

approximately three weeks. These activities would be undertaken during the

daytime between recommended ICNG standard hours for construction.

Based on the type of works, activities and equipment that would be

undertaken or in use and proximity to the nearest sensitive receptors, it is not

expected that construction noise levels from the Project will exceed the

construction NMLs or the HNML for the duration of the Project.


37

Where receptors are situated at a greater distance from the Project works,

noise levels and associated impact will be reduced by comparison to works

and activities conducted in close proximity to receptors.

The ICNG focuses on minimising construction noise impacts, rather than only

on achieving numeric noise levels. Best practice noise mitigation and

management measures will be required to reduce noise levels as far as

practicable. In accordance with the intent of the ICNG, suitable

recommendations for noise mitigation and management measures are

provided in Section 4.7.5.

Operational Noise

The main noise emission source is associated with the 24 hour operation of the

flare unit. In order to attenuate the anticipated noise emissions, the flare unit

will be fitted with an acoustic enclosure and situated in a strategic location in

which existing site infrastructure and vegetation will obscure the direct line of

sight towards potentially affected receivers. In accordance with the NPI, this

qualitative assessment has considered modifying factors for annoying

characteristics and sleep disturbance.

Based on the information provided and the implementation of an acoustic

enclosure, the operation of the flare unit is not expected to exceed the

operational criteria at the nearby sensitive receptors identified in this

assessment. The predicted noise level associated with the new flare unit is 23

dBA LAeq, 15 minute at the closest and/or the potentially most affected

residential (dwelling) receptor (situated approximately 500 m north of the site

on South Street) near the site. Based on this, the introduction of the new

equipment to the Marsden Park Landfill site is not expected to significantly

increase the site’s noise level contribution or change its existing compliance

status with regards to EPL 11497. Given that the surrounding area is best

described as a suburban acoustic environment, it is expected that the new

equipment will be inaudible for the majority of the time and any impacts to

the adjacent community are expected to be minor.

Road Traffic Noise

Apart from delivery of pipe and materials at the start of the Project, any

impacts from Project-related traffic on public roads will be minimal, if any at

all. Furthermore, the vehicle movements (to and from the site) associated with

the Project works are insignificant when compared to that of the existing road

network. As such, it is expected that road traffic noise generated by the

Project would comply with the requirements of the RNP at the majority of

receptors and any temporary change in overall road traffic noise would be

barely perceptible to the average person.


38

Road traffic noise from the Project may be audible at times, but with the

implementation of the traffic management measures outlined in Section 4.8.3

below, any adverse effects would be maintained at acceptable levels.

Therefore, no further recommendations for road traffic noise mitigation and

management measures are warranted or provided in this SoEE.

Vibration

Based on the equipment and activities identified for the Project, potential

sources of vibration are limited and would only occur during the installation

works. This feature combined with the ≥ 400 m distance offset (vibration

dissipates rapidly with distance) to the closest receptor or buildings identifies

that vibration impacts are not anticipated as a result of the Project. It is

expected that vibration generated by the Project works would comply with the

requirements of the NSW Vibration Guideline, BS 7385 and DIN 4150.

Given the limited potential for any vibration impacts to occur, no further

recommendations for vibration mitigation and management measures are

warranted or provided in this SoEE.


To ensure noise emissions associated with Project construction works are kept

to acceptable levels, the following mitigation and management measures are

recommended:

install GSC in accordance with the construction quality assurance (CQA)

program and undertake commissioning checks and regular operational

maintenance, testing and monitoring as outlined in Section 4.11 below;

locate noisy equipment (in this case, the flare unit) behind structures that

act as barriers, or at the greatest distance from the noise-sensitive areas;

work and activities should be carried out during the ICNG recommended

standard hours (i.e. 7am to 6pm Monday to Friday and 8am to 1pm

Saturdays), with no work on Sundays or public holidays;

choose appropriate machines for each task and adopt efficient work

practices to minimise the total construction period and the number of noise

sources on the site;

ensure all machines used on the site are in good condition, with particular

emphasis on exhaust silencers, covers on engines and transmissions and

squeaking or rattling components;

all plant, equipment and vehicles movements should be optimised in a

forward direction to avoid triggering motion alarms that are typically

required when these items are used in reverse; and


39

if any noise complaints are received, attempts will be made to discuss with

the complainant how works can be adjusted to alleviate their concerns. If

this is not successful then operator attended noise measurements will be

undertaken to measure and compare the site noise level contributions

(LAeq, 15 minute) to the NMLs presented in this report. All site noise levels

would be measured in the absence of any influential source not associated

with the site. If the measured site noise levels comply with the NMLs

presented in this report, no further mitigation or management measures are

required. If the measured site noise levels are above those presented in this

report, further mitigation and/or management measures would be

implemented.

No further recommendations for mitigation and management to those

established by the findings of this qualitative assessment, and documented in

this SoEE report, are provided or warranted. BWS should however remain

aware of the potential for nuisance, or an unacceptable level of amenity, to

occur due to Project noise and continue to plan for and then manage Project

works accordingly.

4.7.6 Conclusion

Potential impacts associated with all construction and operational noise and

vibration aspects of the Project were qualitatively assessed. No impacts are

anticipated; however it is recommended that the acoustic enclosure is

implemented for operation of the flare unit as per the detailed design and

standard best practice mitigation and management measures outlined in

Section 4.7.5 are implemented to reduce noise and vibration levels associated

with construction as far as practicable.

The Project is therefore not anticipated to have significant adverse noise or

vibration impacts on nearby sensitive receptors and the environmental risk is

considered to be negligible.

4.8 TRAFFIC


The existing local road network within the locality of the landfill site includes

Richmond Road which is a major road allowing passage to and from

Blacktown and is approximately 800 m directly east of the site. Richmond

Road and South Street form part of the arterial road network of the proposed

MPIP precinct and are predicted to have future (2036) traffic flows in the

range 40,000 - 90,000 vehicles per day.

Existing traffic sources include heavy vehicles delivering landfill material to

the site on a daily basis, and light and heavy vehicles accessing the nearby

commercial and industrial facilities.


40


The Project is only expected to generate approximately five heavy vehicle

movements for the delivery of the materials required for the installation of the

GCS and flare unit. During construction, there will be approximately two light

vehicles used by site personnel travelling to and from site daily. No vehicles

will be required for the operation of the Project, expect for any unplanned

maintenance activities.

It is anticipated that the minor traffic generated by the Project will be easily accommodated by the existing road network and will not result in any significant impacts to road users.


Given the limited potential for any traffic impacts to occur, no



4.8.4 Conclusion

The Project may result in a minor increase in traffic during construction and

installation, however any local traffic impacts will be temporary. The Project is

therefore not anticipated to have significant adverse impacts on traffic and the

environmental risk is considered to be negligible.

4.9 WASTE AND MATERIALS MANAGEMENT

4.9.1 Background and Existing Environment

NSW OEH is responsible for initiating waste avoidance and resource recovery

strategies as a method of ensuring ecological sustainability.

The objectives of these schemes are to:

Minimise the consumption of natural resources;

Encourage resource recovery, including reuse, recycling and energy

recovery;

Provide for continual reduction in waste generation; and

Minimise the final disposal of waste.

The NSW Waste Management hierarchy will be incorporated into the waste

reduction and resource recovery strategies for the Project. The hierarchy is

formed on the principles: avoid, reuse, recycle/reprocess, and dispose.


41


Minimal waste is expected to be generated during the proposed works.

Existing waste contained within the landfill site is expected to be repositioned

during installation of the GCS, however no additional waste is expected to be

generated. Drilling waste will be taken to the active tip face and filled

immediately.

4.9.3 Environmental Mitigation Measures

Given the limited potential for waste generation, no recommendations for

mitigation and management measures are warranted or provided in this

SoEE.

4.9.4 Conclusion

Given the short-term nature of the proposed works and that limited quantities

of waste are anticipated to be generated, through the implementation of the

mitigation measures outlined in this assessment, the overall environmental

risk is considered to be negligible.

4.10 VISUAL AMENITY


The existing visual environment at Marsden Park Landfill site can be

described as cleared and anthropogenic, with remnant patches of vegetation

located around the site office and small warehouse/storage shed, as shown in

Photograph 4.1, 4.2 and 4.3 below.


42

Photograph 4.1 Site office and existing vegetation (to the right).

Photograph 4.2 Warehouse/storage shed


43

Photograph 4.3 View west towards the landfill mass from beside the warehouse/storage

shed


The proposed installation and operation of the GCS and flare unit is not

expected to impact the visual amenity of any nearby potentially sensitive

receivers. The flare unit will be approximately 7 m high and located

approximately 100 m south-west of the site office, near the warehouse/storage

shed.

Photograph 4.4 was taken from the landfill site boundary near the site office

looking towards nearby residential properties, which exist approximately 850

m north-east of the flare unit. Photograph 4.5 was taken from the corner of

Hawthorne Avenue and Darling Street (close to the residential properties),

looking towards the landfill site.


44

Photograph 4.4 View towards sensitive receivers north-east of the Marsden Park Landfill

site.

Photograph 4.5 View towards landfill site from the corner of Hawthorne Avenue and

Darling Street.


45

The existing vegetation located at the site office and the warehouse/storage

shed, which will obscure views towards the flare unit, coupled with the lay of

the land and distance of nearby receivers, means no impacts to visual amenity

are anticipated. From some public viewpoints closer to the landfill site, such as

roads, the top of the flare unit may be visible, however it will blend in with the

existing working landfill site infrastructure and not impact visual amenity.

The top of the flare will be at approximately the same height as the

warehouse/storage shed. Given that the flare unit is enclosed, no flame will

be visible during daytime or night time operations.

Photograph 4.6 is taken in the direction of receivers which exist approximately

750 m southwest. Due to the extensive vegetative buffer completely obscuring

vision towards the landfill site (and in particular, the flare unit) and the

overall distance from the site, it is expected that impacts to visual amenity at

this location will also be negligible.

Photograph 4.6 Nearby sensitive receivers southwest of the Marsden Park Landfill site

(behind vegetation buffer within red rectangle).


Given the limited potential for any visual amenity impacts to occur, no




46

4.10.4 Conclusion

The Project is not anticipated to have significant adverse impacts on visual

amenity and the environmental risk is considered to be negligible.

4.11 HAZARD AND RISK

Hazards and risks are evident throughout all projects, and identifying them is

crucial in ensuring the health and safety of the community and the

surrounding environment. This section of the report identifies potential

hazards and risks associated with the proposed works and provides strategies

to assist in their reduction through effective post-construction monitoring and

maintenance activities.

Table 4.8 below outlines the expected hazards and risks associated with the

proposed works, and the potential controls which may be adapted in order to

overcome and manage them.


47

Table 4.8 Summary of Project Hazards and Risks

Risk Potential Controls

Exposure to asbestos fibres

during construction, in

particular during excavation of

waste or drilling of wells.

Prepare and implement appropriate monitoring and

management procedures during construction.

Refer to site asbestos management plan provided in the

LEMP.

Exposure to chemicals such as

heavy metals, TPH, BTEX, PCBs

etc.

Develop plan to avoid exposure to chemicals.

Wear appropriate PPE.

Cover excavated material.

Landfill gas: fire or explosion

during construction.

Prepare and implement appropriate monitoring and

management procedures during construction, including

explosive limit monitoring.

Hot working permits to be implemented as required.

Prohibit smoking on site.

Landfill gas: fire, explosion or

exposure to landfill gas post-

construction.

Routine surface and subsurface gas monitoring.

Appropriate warning labels on all structures, such as head

walls, pipe outlets and leachate collection wells.

Hot working permits to be implemented as required.

Explosive limit monitoring.

A marker layer will be placed above buried pipes.

Interaction of construction

vehicles with other vehicles on

site (stockpiling and any other

works concurrently carried out

at the site).

Develop Traffic Management Plan.

Collapse of excavations and/or

vehicles sliding into excavation.

Excavation in waste always to be battered at no steeper than

2H:1V. Backfill excavations as soon as possible. Use fencing

where excavations have to remain open.

Striking services Contractor to do service search.

LDS to decommission services prior to construction.

Pipe welding: burns, landfill gas

fire.

PPE, landfill has monitoring.

Security of flare from

community during operations.

Flare to be fenced off. Final location will consider the risk

profile as a result of landscape layout and proximity to

community access.

Importing materials; road

accidents

Traffic management to consider the safest transport route.

Falls or accidents as a result of

working on steep slopes

Contractor to be made aware and to develop appropriate

work methodologies.

Slips, trips or falls during

operation and maintenance.

Vehicle accidents as part of

maintenance works.

Provide safe access to all locations requiring monitoring or

maintenance by staff.

Exposure of public to landfill

gas

Prevent access to landfill gas wells, valves and condensate

pumps by fencing or enclosure. Prevent access of public to

gas flare by fencing and co-locating flare within leachate

plant compound.

Securely lock landfill gas monitoring points.

Prepare management plan and communicate management

plan to future site users.

Differential settlement Annual survey of the top of cap levels to assess that

minimum gas pipe grades are met to ensure the drainage of

the collection network. Regular inspection of gas wellheads.


48

Risk Potential Controls

Lateral migration of landfill gas

and accumulation in subsurface

service trenches, pits or

buildings.

Regular monitoring of perimeter landfill gas monitoring

wells to detect lateral subsurface gas migration from the

landfill.

Condensate accumulation and

pipe blockage.

The system is designed so that defective sections of the GCS

may be isolated. Additional pumping at condensate sumps

can be used to clear the system.

Striking of GCS system

pipework in post-construction

excavations.

Pipework below marker layer in capping system. Header

pipes covered with a pea-gravel layer.

Prepare management plan and communicate management

plan to future users.

Flare shutdown leading to

uncontrolled methane emissions

Slam shut and failsafe valves fitted throughout. Flare is

remotely monitored using telemetry and checked by a

qualified Technician at least once every two weeks. Gas

system pipework is air tight and rigorously pressure tested

at commissioning stage. Therefore will not leak methane

when shutdown.

4.11.1 Risk Mitigation

GCS Construction Quality Assurance

Construction will employ proven techniques to ensure a well-built system,

and a construction quality assurance (CQA) program shall be implemented to

make sure that the system is built in accordance with the required design

considerations (such as pipe slopes and well depths). Field engineering

decisions will need to be made in some instances to account for unforeseen

conditions at the time of construction.

Before construction begins, a professional surveyor shall stake out each well

and collection piping routes. The surveyed elevations and well identification

numbers shall be recorded (and assigned) and written on stakes positioned at

each well location.

A qualified CQA engineer/scientist shall be present during construction to

provide CQA to monitor and document the techniques used. Typically, the

first step in construction of a GCS is drilling the vertical wells. As the driller

gets set to drill each well, the designated CQA engineer/scientist shall verify

the elevation and depth of the well to avoid drilling through the base of the

landfill.

The CQA engineer/scientist shall keep accurate records of the pipe depth,

pipe location, and the location of special fittings such as tees that mark where

a lateral pipe is joined to the header. Other important structures such as

condensate traps or condensate sumps shall be documented on the as-built

drawings to include any deviations from the design plan.


49

The flare supplier and CQA engineer/scientist will carry out operational

checks (refer to Table 4.9 below) prior to the Air Emission Contractor taking

samples (see following section).

Table 4.9 Summary of commissioning checks

Item Factors Involved Checks Comments

Flare

operational

Requirements

Flame/combustion

process

Yes Temperature, excess air and

retention time

Maintenance record Yes Available for inspection

Operations manual Yes Available for use

Operator training Yes Competent personnel on-call

General condition Yes Is the system fully operational?

Extraction

System

Well balancing Yes Effective balancing will be evident

from gas quality and site records.

Well balancing must be carried out

by technically competent and

trained staff

Oxygen content O2 at

acceptable

concentration

High O2 implies a leaking system or

over-extraction.

General condition Yes Is the system fully operational?

Liquid in gas

collection pipework

No Condensate blockages

characterised by a “sloshing”

sound and indicated by rapid

fluctuations in gas flow rate,

temperature and increasing

negative pressure

Site operational

requirements

Is the well

installation

programme

designed to control

migration

effectively?

Yes

Do the extraction

system and its

operation meet the

requirements of site

licence?

Yes Insufficient or poorly installed

wells may meet the letter, but not

the intention, of a licence

Are the operating

instructions

available for use by

the operators?

Yes

Is the emission

standard being

achieved

Yes Instrumental monitoring for

verification

Environmental

Compliance

Are there odours? No

Monitoring records

of inlet and outlet

gas quality

Available for inspection and up-to-

date, complete with regular written

reviews

Is the surrounding

radiative heat

excessive?

No


50

Item Factors Involved Checks Comments

Does the flame

temperature match

the specification?

Yes

Can the residence

time be ascertained?

No

Are there low-

temperature spots

within the

chamber?

Within the section designated as

meeting the design requirement

Is casual access by

the public

prevented?

Yes

Health and

Safety

Are clear

instructions on how

to stop and isolate

the unit readily

available?

Yes

Are emissions

monitoring

requirements being

complied with?

Yes

Is the type and

design of flare

suitable for the

location?

Yes

Are emergency

procedures in place

and effectively

disseminated and

understood?

Yes

Post-construction monitoring

The GCS and flare unit will operate on a continuous basis. Site conditions are

expected to change overtime and the rate of landfill collection will vary

temporally and across locations within the waste mass.

These changes will require periodic monitoring and adjustment of the vacuum

applied to each gas collection well to:

Maintain or increase collection efficiency;

Prevent excessive vacuum application;

Minimize the potential migration of landfill gas; and

Optimise flare combustion and potential shut-downs.


51

Monitoring will detect undesirable subsurface combustion that can result if

excessive vacuum is applied to the wellfield (introducing oxygen into the

waste mass). Monitoring will be conducted at sufficient frequency to promote

optimal system operation and to allow for effective system maintenance.

System monitoring will involve examining landfill gas conditions at the

wellheads and the waste mass surface. Wellhead monitoring parameters shall

include:

Volumetric flow rate and vacuum

Methane, carbon dioxide oxygen, balance gas concentration (%v/v), carbon

monoxide and hydrogen sulphide.

Measurements of carbon monoxide and hydrogen sulphide will be recorded

to provide information about the potential for subsurface fires as well as the

corrosive potential of the landfill gas to subsurface materials.

Effective system operation will generally be expected to fall within the

following approximate monitored ranges:

Methane: 20 to 60 %v/v

Oxygen: up to 10 %v/v (depending on extraction effort)

Carbon monoxide and hydrogen sulphide: less than 100 ppm

Gas temperature: 30 to 60 degrees Celsius.

The blower will be continuously monitored for unusual noise, temperature or

excessive vibration. For sustained operation, the flare must receive landfill gas

flow of sufficient methane content before steady-state operation can be

attained.

Maintenance

Detailed documentation of scheduled maintenance and GCS management will

be included within the GCS Maintenance and Management Plan, and will

include a maintenance history of equipment and contain trouble shooting of

potential problems. The GCS operation will depend on effective maintenance,

which generally falls into the following categories:

Planned – Maintenance scheduled at periodic frequencies such as daily,

monthly, annual and multiyear as appropriate to prevent system failure,

ensure reliability of meters and optimize operation.

Routine – Maintenance occurring in the normal course of operation or

during regular monitoring efforts.


52

Unplanned / Emergency – Not all maintenance is planned. Some

maintenance may be required by component failure or in emergencies. The

Site GCS Maintenance and Management Plan shall proactively consider

failures that will result in emergencies, plan maintenance to enact in these

events, and post signage to avoid compounding hazards resulting from

system failures. System or equipment failures shall be investigated to

determine causes and identify future preventative measures.

Planned maintenance of the flare system includes scheduled inspections of all

relevant components of the system to ensure safe, efficient and reliable

operation. Maintenance includes:

Visual inspection of the flare tips and flare stack for damage or

deterioration

Inspection of the exterior surface for indications of heat degradation, such

as paint discoloration

Monthly assessment of the overall integrity of the internal insulation. Tears

or wear of the insulation will be repaired if necessary

Removal of the flare tip for cleaning if an obstruction is suspected. This

includes measurement of the pressure differential between the flare inlet

flange and the flare tip exit, and cleaning of tips if necessary

Inspection of all thermocouple assemblies and replacement at least yearly

Quarterly inspection of the pilot assembly, ignition rod, electrode, and

insulators for damage, with repair or replacement if necessary

Verification of pilot gas supply pressure and pilot ignition

Inspection of the flame detection components and cleaning relevant

components

Verification of proper operation of the air damper louvers and lubrication if

necessary

Semi-annual removal and cleaning of the flame arrester element.

Measurement of the pressure differential across the element and cleaning, if

necessary

Monthly inspection of the condensate injection nozzles, including

confirmation of proper atomization and regular cleaning of nozzles.


53

The maintenance technician is responsible for daily operations and

maintenance, and scheduled maintenance, such as greasing blowers. The

technician will have a copy of the flare operations manual and plans for

scheduled se vicing and maintenance, and will follow those instructions as

specified and required.

The flare unit is to be inspected regularly, as per the manufacturer’s

recommendations, to ensure that proper service and maintenance is

performed in order to maximize optimum performance. Spare parts are to be

kept on-site and made available should they be required. The manufacturer is

also available as a contingency measure for additional resources or

troubleshooting should they be required.

The GCS is subject to a variety of stresses from the site environment such as

system collapse caused by waste settlement, corrosion or aging of materials

(including ultraviolet degradation), and damage as a result of heavy

equipment coming into contact with the wells and piping. GCS maintenance

activities may include:

Repair or replacement of damaged wells and valves

Removal of leachate and condensate blockages

Re-grading or replacement of pipe affected by settlement of the waste mass

Replacement of components that have failed as a result of aging or fatigue.

Major repairs may require the temporary shutdown of the blower and flare

system. Blowers are subject to vibration, belt wear, bearing deterioration and

seal damage. Wear necessitates regular routine and scheduled maintenance as

well as particular attention to sounds during system start-up and shutdowns.

Flares are subject to thermal stress that can be exacerbated if the flare is

operated at temperatures or flows above manufacturer recommendations.

Maintenance generally involves inspecting the flare for heat damage,

maintaining pilot fuel and igniters, preventing condensate build-up and

checking the general mechanical condition.

4.11.2 Conclusion

There are a number of hazards and risks associated with the proposed works,

however with the correct implementation of the proposed management

measures and effective monitoring and maintenance, the overall risk is

considered negligible.


54

4.12 CUMULATIVE IMPACTS

Cumulative impacts are an additional way in which a specific environmental

aspect may be affected by a new project or another development. Cumulative

impacts have two key characteristics:

they occur over a geographical area; and

they occur over time.

Potential cumulative traffic generation impacts associated with nearby

facilities, warehouses and commercial premises are unlikely, as the

cumulative traffic will be accommodated by the existing road network and an

appropriate level of service maintained.

The Project is anticipated to span over approximately three weeks and will

only involve the installation and operation of the GCS and flare unit. Due to

the short duration and negligible anticipated environmental impacts, it is

considered unlikely that the Project will result in any significant cumulative

impacts.

Additionally, due to the reduction in the emission of GHG as a result of the

Project, the overall environmental impact is expected to be positive.


55

5 SECTION 79C CONSIDERATIONS

Section 79C of the EP&A Act requires the consent authority to take into

consideration a range of matters when undertaking an assessment of a DA.

These are detailed in Table 5.1

Table 5.1 Section 79C Considerations

Section 79C Requirements Comment

(a)(i) any environmental planning

instrument

The Project is consistent with the requirements of

relevant environmental planning instruments as

detailed in Section 3.

(a)(ii) any proposed instrument that is or

has been the subject of public consultation

under this Act and that has been notified

to the consent authority (unless the

Secretary has notified the consent

authority that the making of the proposed

instrument has been deferred indefinitely

or has not been approved)

N/A

(a)(iii) any development control plan The Project is consistent with the general

development objectives and controls of the

Blacktown City Council Development Control

Plan 2016.

(a)(iv) any planning agreement that has

been entered into under section 93F, or any

draft planning agreement that a developer

has offered to enter into under section 93F,

N/A

(a)(v) the regulations (to the extent that

they prescribe matters for the purposes of

this paragraph)

N/A

(a)(vi) any coastal zone management plan N/A

(b) the likely impacts of that development,

including environmental impacts on both

the natural and built environments, and

social and economic impacts in the locality

The likely impacts of the development have been

assessed in Section 4.

(c) the suitability of the site for the

development

The Project is permissible with development

consent under State Environmental Planning

Policy (Sydney Region Growth Centres) 2006 -

Marsden Park Industrial Precinct Plan 2010 and

will not impact on the surrounding

industrial/commercial facilities.

(d) any submissions made in accordance

with this Act or the regulations,

Council is to take into consideration any

submission required as part of the notification

process.


56

Section 79C Requirements Comment

(e) the public interest The proposed works will provide the following

benefits:

Removal of potentially hazardous landfill

gases resulting in reduced health and safety

risks to nearby residents and community;

The removal of methane during gas collection

and flaring will reduce GHG emissions from

the site, which makes the Project eligible

under the ERF enabling the offsetting of fossil

fuel, which in turn results in a beneficial

environmental outcome and positive impact;

and

The Project will contribute to the future

rehabilitation and redevelopment of the

landfill site. The Project will assist in

achieving the final land use goal of ‘low

density industrial use’, which will support the

local community by providing jobs and

services, and in turn increasing cash flow

throughout the community.

ENVIRONMENTAL RESOURCES MANAGEMENT AUSTRALIA PTY LTD 0430664/FINAL/12 JUNE 2018

57

6 CONCLUSION

This SoEE has been prepared to assess the environmental impacts associated

with proposed installation and operation of an active GCS and enclosed

ground flare unit. The SoEE provides a review all relevant legislation and

policy and finds that the fundamental issues to consider in determining the

DA are potential noise and air quality impacts.

The main noise source is associated with the operation of the flare unit which

is not anticipated to generate high noise levels. In order to attenuate

anticipated noise emissions, the flare unit will be fitted with an acoustic

enclosure and strategically located behind existing site infrastructure and

vegetation to obscure the direct line of sight towards potentially affected

receivers. Regular maintenance, testing and monitoring will be undertaken to

ensure regulatory compliance. The Project is not anticipated to have adverse

noise impacts on nearby sensitive receptors.

With regards to potential air quality impacts, the flare unit will utilise the

latest technology to meet present and near future emissions standards.

Pollutant emission limits required by the Protection of the Environment

Operations (Clean Air Regulation) 2010 will not be exceeded during operation of

the flare unit. Emission compliance testing and monitoring will be undertaken

by a NATA accredited Contractor.

It is in the public interest to install and operate the GCS and flare unit, as it

will assist in the:

Reduction of GHG emissions reducing the effects of global warming

Reduction of the potential for dispersion of odorous and potentially

harmful landfill gases to nearby sensitive receivers; and

Achievement of the final land use goal of ‘low density industrial use’,

which will help stimulate economic growth within the local community by

providing jobs to community members.

The SoEE has given consideration to all relevant legislation and policies, and

has conducted an assessment of potential environmental impacts. It concludes

that the Project and its associated potential environmental impacts are

unlikely to have a negative impact on the environment and all minor risks and

impacts can be effectively managed through the implementation of mitigation

measures during proposed works and during the long-term operation of the

project.

Additionally, the reduction in GHG emissions as a result of the operation of

Project means the overall environmental impact is considered positive, and

such works are considered viable for the Emissions Reduction Fund (subject to

approval by the Clean Energy Regulator). Other positive benefits include the

significantly reduced risk of sub-surface migration of landfill gas and potential

for airborne odour at surrounding receivers.

ENVIRONMENTAL RESOURCES MANAGEMENT AUSTRALIA PTY LTD 0430664/FINAL/12 JUNE 2018

58

7 REFERENCES

British Standard (1992). BS 6472–1992) – Evaluation of Human Exposure to

Vibration in Buildings (1 Hz to 80 Hz).

British Standard (1993). BS7385: Part 2-1993 (BS 7385) - Evaluation and

Measurement for Vibration in Buildings — Part 2 – Guide to Damage Levels from

Ground-borne Vibration.

Clean Energy Regulator (2017) – Participate in the Emissions Reduction Fund

Commonwealth Department of the Environment and Energy (2013). Protected

Matters Search Tool - Environment Protection and Biodiversity Conservation Act

1999.

Department of Land and Water Conservation (2001) Soil Landscapes of the

Penrith 1:100 000 Sheet.

Department of Primary Industries (DPI) (undated) Key Fish Habitat in the

Blacktown LGA.

Department of the Environment and Energy (2017). Emissions Reduction Fund

Information Page.

http://www.environment.gov.au/climate-change/government/emissions-reduction-

fund/about

German Standard (1999). DIN4150 Part 3-1999 (DIN4150-3) – Structural

Vibration - Effects of Vibration on Structures.

Landcom (2004) Managing Urban Stormwater: Soils and Construction – Volume 1.

NSW Department of Environment and Climate Change (DECC) (2006).

Assessing Vibration: A Technical Guideline.

NSW DECC (2009) NSW Interim Construction Noise Guideline (ICNG).

NSW DECCW (2011) NSW Road Noise Policy.

NSW Environment Protection Authority (EPA) (2017). NSW Environmental

Noise Management – Noise Policy for Industry and relevant application notes.

NSW EPA (2014) Waste Classification Guidelines.

http://www.environment.gov.au/climate-change/government/emissions-reduction-fund/about

http://www.environment.gov.au/climate-change/government/emissions-reduction-fund/about

Annex A

Flare Emission Testing Report

ATTACHMENT 3: FLARE EMISSION TESTING REPORT

ERM has over 100 officesacross the followingcountries worldwide

Australia

Argentina

Belgium

Brazil

China

France

Germany

Hong Kong

Hungary

India

Indonesia

Ireland

Italy

Japan

Korea

Malaysia

Mexico

Netherlands

New Zealand

Peru

Poland

Portugal

Puerto Rico

Singapore

Spain

Sri Lanka

Sweden

Taiwan

Thailand

UK

USA

Venezuela

Vietnam

Environmental Resources Management

Level 15 309 Kent StreetSydney NSW 2000Locked Bag3012,

Australia Square NSW 1215

T: 61 2 8584 8888F: 61 2 8584 8800www.erm.com

marsden park landfill proposed gas collection system and

Documents