Lucas Heights Resource Recovery Park IEA

P:\605X\60534888\4. Tech work area\3. IEA\5. Reporting\Final Report\Rev1\FINAL_LHRRP IEA_Rev1.0.docxRevision – 20-Apr-2018Prepared for – SUEZ Recycling and Recovery Australia – ABN: 70 002 902 650

SUEZ Recycling and Recovery Australia20-Apr-2018

Lucas Heights ResourceRecovery Park IEAIndependent Environmental Audit

AECOM Lucas Heights Resource Recovery Park IEA


Lucas Heights Resource Recovery Park IEAIndependent Environmental Audit

Client: SUEZ Recycling and Recovery AustraliaABN: 70 002 902 650

Prepared byAECOM Australia Pty LtdLevel 21, 420 George Street, Sydney NSW 2000, PO Box Q410, QVB Post Office NSW 1230, AustraliaT +61 2 8934 0000 F +61 2 8934 0001 www.aecom.comABN 20 093 846 925

20-Apr-2018

Job No.: 60534888

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Quality InformationDocument Lucas Heights Resource Recovery Park IEA

Ref 60534888

Date 20-Apr-2018

Prepared by Katherine Dodd, Senior Environmental Scientist

Reviewed by Helen Onus, Principal Environmental Scientist

Revision History

Rev Revision Date DetailsAuthorised

Name/Position Signature

00 13-Apr-2018 Final Helen OnusLead Auditor,PrincipalEnvironmentalScientist

1.0 20-Apr-2018 Final (minor updates) Helen OnusLead Auditor,PrincipalEnvironmentalScientist



Table of ContentsExecutive Summary i1.0 Introduction 1

1.1 Background 11.2 Audit scope 11.3 Audit methodology 21.4 Documents reviewed 31.5 Personnel and timing 41.6 Format of report 4

2.0 Lucas Heights Resource Recovery Park Operations 52.1 Site description 52.2 Project Approval and licences 72.3 Description of site operations 82.4 Activities occurring during site inspection 9

3.0 Consultation 113.1 Department of Planning and Environment 113.2 Environment Protection Authority 113.3 Sutherland Shire Council 113.4 Department of Primary Industries, Office of Water 11

4.0 Compliance with Statutory Requirements 124.1 Performance categories 12

5.0 Environmental Performance 145.1 Incident management 145.2 Complaint management 155.3 Odour management 16

6.0 Site Inspection Observations 186.1 Site inspection observations 18

7.0 Review of Environmental Management Plans 317.1 OEMP 317.2 Air Quality and Odour 347.3 Groundwater Management 34

8.0 Summary of non-compliances and recommendations 358.1 Summary of report recommendations 368.2 Summary of non-compliances and conditions assessed as not verified 398.3 Summary of opportunities for improvement 57

9.0 Limitations 59Appendix A Compliance Tables AAppendix B 2015 IEA Recommendations BAppendix C DPE Audit Team Approval C

List of Figures

Figure 2-1 LHRRRP Site Layout (source: LHRRP OEMP, Figure 2.2, dated 13 October2017) 6

Figure 2-2 Re-profiling staging (Source: GHD, Proposed Reprofiling Development Plan,03.07.15, Appendix D the LHRRP OEMP) 9

Figure 5-1 LHRRP – Odour Complaints 2015-2017 (Source: SUEZ) 16



List of Tables

Table 1-1 Scope of Work 2Table 2-1 Summary of Scheduled and Fee Based Activities permitted under an EPL 7Table 4-1 Performance category 12Table 4-2 Risk Levels for Non-compliances 13Table 5-1 Summary of incidents recorded in during audit period 14Table 7-1 OEMP and Appendices Summary 32Table 8-1 Summary of Recommendations relating to management plans, site

observations and previous IEA recommendations 36Table 8-2 Summary of Conditions assessed as non-compliant or not verified 39Table 8-3 Recommendations for Conditions considered compliant for improved

compliance or continuous improvement 57



AbbreviationsAbbreviation Description

AECOM AECOM Australia Pty Ltd

ANSTO Australian Nuclear Science and Technology Organisation

ARRT Facility Advanced Resource Recovery Facility

CEMP Construction Environmental Management Plan

CoC Condition of Consent

Council Sutherland Shire Council

CRG Community Reference Group

DPE Department of Planning and Environment

DPI Water Department of Primary Industries, Office of Water

EIS Environmental Impact Statement

EMP Environmental Management Plan

EP&A Act Environmental Planning and Assessment Act 1979

EPA Environment Protection Authority

EPL Environment Protection Licence

EQS Environment, Quality and Safety

GO Facility Garden Organics Facility

IEA Independent Environmental Audit

IMS Integrated Management System

ISO International Standards Organisation

LHCA Lucas Heights Conservation Area

LHRRP Lucas Heights Resource Recovery Park

NSW New South Wales

OEH Office of Environment and Heritage

OEMP Operational Environmental Management Plan

OFI Opportunity for Improvement

PCYC Police and Community Youth Club

PIRMP Pollution Incident Response Management Plan

POEO Act Protection of the Environment Operations Act 1997

SIMS Incident and complaint management system

SITA SITA Australia Pty Ltd, now SUEZ Environment Pty Ltd

SOP Standard Operating Procedure

SSC Sutherland Shire Council

the ‘audit period’ 23 January 2017 to 23 January 2018

tpa tonnes per annum

VPA Voluntary Planning Agreement

WAMC Waste Assets Management Corporation – NSW Government.

WHS Work, Health and Safety

WSN Waste Services NSW



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Executive SummaryAECOM Australia Pty Ltd (AECOM) was engaged by SUEZ Environmental Pty Ltd (SUEZ) to carry outan Independent Environmental Audit (IEA) of the Lucas Heights Resource Recovery Park (LHRRP)(the ‘Site’), located on Little Forest Road, Lucas Heights in the Sutherland Shire Council (SCC) localgovernment area of New South Wales (NSW).

Approval to operate the LHRRP was received in November 1999 (DA 11-01-99). SUEZ (formerlySITA) acquired the Site from WSN in June 2011. DA 11-01-99 included a requirement for an IEA everythree years. The most recent IEA under that consent was conducted by URS (now AECOM) in 2015.At that time SUEZ was in the process of seeking approval to increase waste processing volumes atthe LHRRP through landfill re-profiling (stripping back covered areas and landfilling on top of existingwaste), extend the life of the landfill, relocate and expand the Garden Organics (GO) facility andconstruct and operate an Advanced Resource Recovery Treatment (ARRT) facility. Project Approval(SSD 6835) for the expansion was granted on the 23 January 2017 and included a requirement tomodify DA 11-01-99 to remove the conditions of that consent that relate to the LHRRP, with theintention that all activities undertaken at the LHRRP will be covered under Project Approval SSD 6835.

Condition D12 Project Approval SSD 6835 requires SUEZ to commission an IEA within one year of thedate of the approval, and every three years thereafter. The AECOM audit team was approved by theNSW Department of Planning and Environment (DPE) on the 1 November 2017 to undertake the IEA.The audit site inspection was undertaken on the 22 and 23 January 2018.

The audit was completed in accordance with Condition D12 and the AECOM proposal dated10 October 2017.

The audit methodology comprised the following activities:

· Initial discussions with SUEZ management to organise the audit, including the provision ofdocumentation, the Site visit and timing.

· Consultation with key government agencies and other relevant agencies as presented in thisReport.

· A two day Site inspection and interviews with key site personnel on 22 and 23 January 2018.

· Review of additional documentation provided by SUEZ after the Site inspection.

· Submission of a Draft Report to SUEZ outlining the audit findings.

· Finalisation of the Report based on comments from SUEZ.

This is the first IEA to be carried out under Project Approval SSD 6835 and for the purpose of thisaudit, the audit period has been defined as from the 23 January 2017 (date of approval) to 23 January2018 (date of site inspection conducted as part of this audit). This report presents the findings of thisaudit.

The IEA assessed compliance with relevant approvals, licences and management plans applicable tothe LHRRP. Detailed compliance registers identifying audit findings, comments and recommendationsare presented in Appendix A. Non-compliances identified against relevant approvals are identified anddiscussed in Section 8.0.

The LHRRP’s overall compliance status is summarised in Table_ES 1.



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Table_ES 1 Overall Compliance Assessment

Relevant ApprovalNo. ofConditionsCompliant

Number ofConditions Non-compliant

Number ofConditions NotVerified

Number ofConditions NotTriggered

Project Approval SSD6835

36 14 2 43

Environmental ProtectionLicence (EPL) 5065

46 8 0 27

EPL 12520 25 4 0 11

EPL 13114 15 1 0 20

Total 122 27 2 101

SUEZ complied with the majority (80%) of the Conditions of its Development Consent and EPLs. Ofthe non-compliances recorded, 11 were administrative non-compliances mostly relating to meetingspecified timeframes for the submission of reports and management plans, seven were consideredlow risk, eight were considered medium risk and one was considered high risk. The high risk non-compliance related to the observed ballooning of the liner of the main leachate pond. A significantportion of the conditions were not triggered as they related to the new GO Facility and the ARRTFacility which were yet to be constructed at the time of the audit.

The scope of the audit also included a review of the adequacy of the environmental managementplans for the site. The findings of the adequacy review of management plans are presented inSection 7.0. Continuous improvement opportunities were identified and are presented throughout thereport and summarised in Section 8.0.



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1.0 Introduction

1.1 BackgroundAECOM Australia Pty Ltd (AECOM) was engaged by SUEZ Recycling and Recovery Pty Ltd (SUEZ)to carry out an Independent Environmental Audit (IEA) of the Lucas Heights Resource Recovery Park(LHRRP) (the ‘Site), located on Little Forest Road, Lucas Heights in the Sutherland Shire Council(SCC) local government area of New South Wales (NSW).

Approval to operate the LHRRP was received in November 1999 (DA 11-01-99). SUEZ (formerlySITA) acquired the Site from WSN in June 2011. DA 11-01-99 included a requirement for an IEA everythree years. The most recent IEA under that consent was conducted by URS (now AECOM) in 2015.At that time SUEZ was in the process of seeking approval to increase waste processing volumes atthe LHRRP through landfill re-profiling (stripping back covered areas and landfilling on top of existingwaste), extend the life of the landfill, relocate and expand the Garden Organics (GO) facility andconstruct and operate an Advanced Resource Recovery Treatment (ARRT) facility. DevelopmentConsent (SSD 6835) for the expansion was granted on the 23 January 2017 and included arequirement to modify DA 11-01-99 to remove the conditions of that consent that relate to the LHRRP,with the intention that all activities undertaken at the LHRRP will be covered under DevelopmentConsent SSD 6835.

Condition D12 Project Approval SSD 6835 requires SUEZ to commission an IEA within one year of thedate of the approval, and every three years thereafter. The AECOM audit team was approved by theNSW Department of Planning and Environment (DPE) on the 1 November 2017 to undertake theaudit. The audit site inspection was undertaken on the 22 and 23 January 2018.

This is the first IEA to be carried out under Project Approval SSD 6835 and for the purpose of thisaudit, the audit period has been defined as from the 23 January 2017 (date of approval) to 23 January2018 (date of site inspection conducted as part of this audit). The recommendations and opportunitiesfor improvement identified in the 2015 IEA (under DA 11-01-99) have been reviewed as part of thisaudit to capture operational changes to Site. This report presents the findings of this audit.

1.2 Audit scopeThe audit was conducted in accordance with the requirements set out in SSD 6835, Schedule 2,Condition D12, and Section 2.2 of the DPE Independent Audit Guideline (the Audit Guidelines) (DPE,2015) as detailed in Table 1-1.



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Table 1-1 Scope of Work

Condition Requirement ReportReference

SSD 6835, Schedule 2, Condition D12,

D12 Within one year of the date of this consent, and every three yearsthereafter, unless the Secretary directs otherwise, the Applicant shallcommission and pay the full cost of an Independent Environmental Auditof the site. The audit must:

(a) be carried out by a suitably qualified, experienced and independentaudit team whose appointment has been endorsed by theSecretary;

Section 1.5;Appendix C

(b) assess the environmental performance of the site, and its effects onthe surrounding environment;

Section 5.0

(c) determine whether the site is complying with the relevant standards,performance measures and statutory requirements;

Section 8;Appendix A

(d) review the adequacy of the Environmental Management Plans forthe site,compliance with this consent, and any other licences and consents;and, if necessary; and

Section 7.0

Section 8;Appendix A

(e) recommend measures or actions to improve the environmentalperformance of the site, and/or any plan/ program required underthis consent.

Section 8

DPE Audit Guideline

2.2 The scope of the audit should detail:

the physical boundaries of the audit – it should cover the areaspecified by the relevant regulatory approvals

Section 2

the time period covered by the audit – the audit should address theperiod since the previous independent audit or where there hasbeen no previous independent audit, the period since the date ofthe approval (i.e. the period governed by the regulatory approval);and

Section 1.1

the organisational units, activities and processes that will becovered.

Section 2

Generally, independent audits should cover all organisational units,activities and processes relating to the development that arereferred to in the relevant regulatory approval(s).

Section 2.0

1.3 Audit methodologyThe purpose of this IEA was to assess environmental performance of the project and assesscompliance with the Conditions of Consent (CoC), licences and approvals that apply to the project andreview the adequacy of the Environmental Management Plans and/or Environmental MonitoringPrograms required under the CoC and EPLs.

The audit was completed in accordance with Condition D12 of SSD 6835 and the AECOM proposaldated 10 October 2017.

Compliance checklists were developed by AECOM and include a list of conditions and commitmentsto be assessed for compliance, including the CoC (SSD 6835), and Environment Protection Licence(EPL) 5065, EPL 12520 and EPL 13114.

The auditors assessed compliance by viewing evidence of documents associated with each aspect ofthe various approvals and associated plans, programs and strategies and observations made duringthe site inspection.



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The audit was carried out in accordance with ISO 19011:2003 Guidelines for quality and/orenvironmental management systems auditing.

The audit methodology comprised the following activities:

· Initial discussions with SUEZ management to organise the audit, including the provision ofdocumentation, the Site visit and timing.

· Consultation with key government agencies and other relevant agencies as presented in thisReport.

· Preparation of site compliance register and review of documentation provided by SUEZ.

· A two-day site inspection and interviews with key site personnel, on 22 and 23 January 2018.Tasks undertaken during the audit site inspection included:

- Opening meeting

- Site inspection with the NSW Landfill Advisor and New Illawarra Road Landfill Manager

- Review of relevant documentation provided by SUEZ

- Interviews with key personnel including the NSW Landfill Advisor and New Illawarra RoadLandfill Manager

- Close out meeting.

· Review of additional documentation provided by SUEZ after the Site inspection.

· Submission of a Draft Report to SUEZ outlining the audit findings.

· Finalisation of the Report based on comments from SUEZ.

This report provides a summary of findings including a discussion of the environmental performance ofthe site, details of identified non-compliances with the Development Consent and EPLs, review ofadequacy of management plans, and recommended actions to improve compliance status as well ascontinual improvement opportunities.

1.4 Documents reviewedThe following information was reviewed during the audit process:

· Regulatory approval.

· EPLs and Annual Returns.

· Management Plans as listed in Section 7.0.

· Selected Standard Operating Procedures (SOPs) and checklists.

· Selected correspondence with relevant government agencies and stakeholders (as provided andas relevant to the audit).

· Selected records of competency, induction and training.

· Selected meeting minutes.

· 2015 IEA (recommendations and opportunities for improvement) for DA 11-01-99.

· Selected reports.

· Evidence of monitoring and review.

Documents used as part of the audit are referenced as part of the text discussing compliance status inAppendix A.



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1.5 Personnel and timingIn accordance with Schedule 2, Condition D123 of SSD 6835, the audit was to be conducted by asuitably qualified, experienced and independent audit team whose appointment has been endorsed bythe Secretary. The audit team comprised of the following personnel, as approved by the DPE by letterdated 1 November 2017 (refer Appendix C).

· Helen Onus, Lead Auditor.

· Katherine Dodd, Auditor.

Helen Onus is registered by Exemplar Global as a Certified Auditor for Environmental Managementand Compliance Auditing. The site visit for the audit was conducted on 22 and 23 January 2018.

Personnel interviewed during the site visit included the following:

· Kim Ross, NSW Landfill Advisor.

· LC Chiang, Landfill Manager, New Illawarra Road Landfill.

1.6 Format of reportThe format of this report is as follows:

· Section 1.0 is introductory and defines the scope and nature of the audit.

· Section 2.0 describes the operations at the LHRRP as observed during the site inspection.

· Section 3.0 describes the consultation undertaken with relevant stakeholders.

· Section 4.0 describes the approach to the assessment against the relevant standard,performance measures and statutory requirements.

· Section 5.0 provides an assessment of the environmental performance of the development andits effects on the surrounding environment.

· Section 6.0 provides a summary of site observations made during the site visit.

· Section 7.0 presents the findings of the review of the adequacy of the EnvironmentalManagement Plans for the Site.

· Section 8.0 summarises the non-compliances and recommendations made throughout the report.

Appendix A is a tabulated review of the results of the assessment against the CoC and EPLconditions.

Appendix B provides an assessment of the status of implementation of the recommendations made inthe 2015 IEA.

Appendix C is a copy of the DPE approval of the audit team and a letter from DPE approving anextension for submission of this audit report.



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2.0 Lucas Heights Resource Recovery Park Operations

2.1 Site descriptionThe LHRRP is located on New Illawarra Road, Lucas Heights in the SSC local government areaapproximately 30 kilometres (km) south-west of the Sydney Central Business District.

The LHRRP occupies an area of approximately 205 hectares (ha) of which SUEZ owns 89.5 ha. Theremaining land (115.5 ha) falls within the Australian Nuclear Science and Technology Organisation(ANSTO) 1.6 km radius exclusion zone. Land owned by ANSTO is leased to SUEZ under the ANSTOAgreement. The ANSTO bushland areas border the site. The Police and Community Youth Club(PCYC) operates a minibike club on approximately 11 ha of rehabilitated landfill area near the south-eastern corner of the LHRRP area. The nearest residents are located at North Engadine,approximately two km to the east.

LHRRP is situated directly adjacent to the Lucas Heights Conservation Area (LHCA). Mill Creek, atributary of the Georges River, originates from to the western perimeter of the LHRRP and flows in anortherly direction through the LHCA towards the Georges River. To the north east of the site, LH1(closed since 1985) has been redeveloped into a sporting/recreation area.

The Sydney International Clay Target Association lease an area from SUEZ on the western boundaryof the LHRRP for clay target shooting.

Under Development Consent SSD 6835, dated 23 January 2017, SUEZ is responsible for:

· Landfill (also known as LH2))

· The PCYC minibike club (PCYC);

· The existing GO Facility;

· The proposed new GO Facility and ARRT Facility.

The scope of this audit is limited to the landfill, the PCYC and the existing GO Facility which areoperational. Construction and operation of the new GO Facility and ARRT Facility had not commencedduring the audit period.

The following areas were not assessed in detail as part of this audit:

· LH1, now active sporting and recreation areas (SSC responsibility);

· LHCA (ownership transferred to SSC in 2002);

· Electricity generation from landfill gas (Managed by EDL under a separate EPL);

· Area leased to the Sydney International Clay Target Association

Figure 2-1 provides a site layout.



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Figure 2-1 LHRRRP Site Layout (source: LHRRP OEMP, Figure 2.2, dated 13 October 2017)



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2.2 Project Approval and licencesDevelopment consent for landfilling activities on the LHRRP was originally granted by SCC in June1985. Consent for the expansion of landfilling was granted by the Minister for Urban Affairs andPlanning in November 1999 and governed by DA 11-01-99.

On 23 January 2017 the DPE granted Consent (SSD 6835) to increase landfill capacity, relocate andexpand the GO Facility and construct and operate a new resource recovery facility (the ‘ARRTFacility’).

Condition B8 of the Consent (SSD 6835) states that within 6 months of the date of this consent, theapplicant shall lodge an application to modify DA 11-01-99 to remove the conditions of that consentthat relate to the LHRRP. The modification is required to ensure all activities undertaken at the LHRRPare covered by consent (SSD 6835) only. This audit has only included an assessment of SSD 6835. Asummary of the recommendations and opportunities for improvement included in the 2015 IEA(conducted under DA 11-09-99) and a brief review of the actions taken to address these is included inAppendix B.

LHRRP operates under three EPLs, which specify minimum environmental obligations to be compliedwith. A summary of the scheduled activities associated with these EPLs is provided in Table 2-1.Table 2-1 Summary of Scheduled and Fee Based Activities permitted under an EPL

EPL # Premises Scheduled Activity Fee Based Activity

5065 Lucas Heights ResourceRecovery Park

Waste processing (non-thermal treatment)

Non-thermal treatment of liquidwaste: any annual processingcapacity

Waste disposal(application to land)

Waste disposal by application toland: any capacity

Waste storage Waste storage – other types ofwaste: any other types of wastestored

Waste storage Waste storage – waste tyres: >tonne stored

12520 Lucas Heights Wasteand Recycling Centre(existing GO Facility)

Composting Composting: >5,000-50,000 Tannual capacity to receiveorganics


Non-thermal treatment of generalwaste: any annual processingcapacity

13114 Lucas Heights PCYCminibike club area

Waste storage Waste storage – other types ofwaste: >0 T stored

SUEZ also entered into a Voluntary Planning Agreement (VPA), dated 17 March 2017, with SSC inaccordance with the requirements of the Environmental Planning and Assessment Act 1979 (EP&AAct). Under the VPA, SUEZ has committed to meeting a number of requirements related to the Site’senvironmental performance. The OEMP, discussed in Section 7.1, includes some of the requirementsof the VPA. Requirements of the VPA were not reviewed as part of this audit.



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2.3 Description of site operationsSUEZ manages the LHRRP as a solid waste landfill with associated waste management and recyclingactivities. LHRRP currently provides a range of waste management and resource recovery services tothe domestic, municipal and commercial sectors that include:

· Resource Recovery Centre;

· Garden organics processing;

· Small vehicles drop-off area;

· Electricity production;

· Engineered landfill;

· Native seedling nursery; and

· Major land rehabilitation.

At the time of the site inspection, landfill operations were operated by Select Civil under contract toSUEZ who oversees the operations of Select Civil.

Landfilling activities on the Site have been undertaken progressively in five stages (Stage 1 toStage 5), moving in a northerly direction. Landfilling of Stage 5 was still occurring during the siteinspection but will reportedly be put on hold while the re-profiling works take place.

SSD 5835 was granted on the 23 January 2017. During the audit period SUEZ continued to landfill asper the operations approved under the previous consent and EPL. Prior to the re-profiling workscommencing, EPL 5065 was varied on the 7 December 2017, which approved the following:

· Re-profiling, consistent with SSD 6835, subject to the requirements of the licence.

· Installation of the dual gas and leachate trench.

· Updates to the monitoring and discharge points.

Following approval of the EPL variation SUEZ began re-profiling of the landfilling in Area D (see areahighlighted in red in Figure 2-2), also referred to as Phase 2 in the staging plan provided in Figure 6.6of the EIS (GHD, 2015). SUEZ reported that the sequencing of re-profiling stages had been revised foroperational reasons relating to managing gas, leachate and surface water.

Construction of the GO Facility and ARRT Facility had not commenced during the audit period.



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Figure 2-2 Re-profiling staging (Source: GHD, Proposed Reprofiling Development Plan, 03.07.15, Appendix D theLHRRP OEMP)

2.4 Activities occurring during site inspectionOperations undertaken and infrastructure present at the time of the site inspection at LHRRP included:

· Receipt of waste at the weighbridge.

· A recycling and waste collection area, for waste collected from small vehicles.

· Hazardous waste collection point (waste oils and batteries for off-site treatment).

· A surface water diversion system directing clean water to Mill Creek.



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· Sedimentation treatment in a sediment dam (Sediment Dam 5 also referred to as Main Dam)located in the north-west corner of LHRRP. Sediment Dam 5 also operates as a water reusebasin with its water reuse volume provided below the zone actively managed for erosion andsediment control.

· Pre-treatment basin upstream of Sediment Dam 5 to help capture coarser sediment before entryto the dam and to reduce the maintenance requirements of Sediment Dam 5. The pre-treatmentbasin receives water via a newly constructed dirty water drain (which was installed alongside theexisting dirty water drain) and discharges water via a pipe to the existing dirty water drain whichflows to Sediment Dam 5.

· Resumption of the use of the stormwater treatment plant located in the north-west corner ofLHRRP (pH adjustment and flocculation). Water treatment for water retained in sedimentationponds (Dam 5). It is noted the stormwater treatment plant was offline for a large portion of timeduring the previous IEA.

· Stormwater management infrastructure works including: replacement of leachate ring mainbetween LP16 and LP17; installation of a new section of HDPE pipe and associated riser pipes;reinstatement of the pipeline and backfilling it with clay, forming a barrier between the edge of thecapping and the western dirty water drain and the removal of the French Water Drain;reconstruction of the dirty water drain, including gabion baskets.

· Storage of leachate in a permanent 9 ML leachate storage dam constructed in 2006, located inthe north-west corner of LHRRP.

· 10.2 ML emergency leachate storage dam adjacent to the main dam, constructed in mid-2014.

· Leachate from the leachate dams is directed (via pipeline) to the leachate treatment plant at LH1prior to discharge with consent to Sydney Water Corporation’s sewerage system under a TradeWastewater Agreement.

· Staged landfilling of municipal solid waste. At the time of the site visit, landfilling was continuing inStage 5 Cell 5.2B.

· Re-profiling works were taking place in Area D. A portion of the area had been stripped back (ofintermediate cover), and gas and leachate extraction infrastructure had been extended prior tofilling works.

· Filling and compaction of landfilled waste.

· Maintenance of vehicles and equipment in a workshop operated by Select Civil.

· Storage of stormwater from the workshop in a lined pond, constructed in 2017.

· Use of the Truck Parking Area (TPA) including basic maintenance of vehicles.

· Receipt of masonry, steel and other materials for reuse or recycling.

· Environmental management, monitoring and reporting including monitoring around the landfillincluding monitoring of air emissions (dust), surface water, odour, trade waste, groundwater,noise, surface gas, subsurface gas and leachate.

· Litter patrols around the boundary and general area of LHRRP.

· Treatment of surface water run-off from the existing GO Facility in an aerated dam with a capacityof 10 ML.

· Separation of accepted green waste into Type A Material which includes pallets, untreated woodwaste, timber offcuts and selected tree waste that does not contain weed species (~20%) andType B Material which includes garden waste and trees which may include noxious or gardenweeds (~80%).

· Production of products for mulch and compost at the existing GO Facility.



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3.0 ConsultationWhilst consultation was not specifically required by Condition D12 relating to the scope of the IEA,Section 4.2 the of the DPE Audit Guideline, requires that prior to the site inspection key agencies aswell as the Chair of the development’s Community Consultative Committee (if applicable) should becontacted to obtain feedback and draw the auditor’s attention to any key issues, within the agreedscope of the audit. As part of the audit process, AECOM contacted key government agencies to seektheir views on the environmental performance of the Site. It is noted the Chair of the CommunityReference Group (CRG) was not contacted as this role was held by a SUEZ employee during theaudit period. A summary of the consultation process and any feedback obtained is provided in thefollowing sections.

3.1 Department of Planning and EnvironmentFeedback was sought on 11 January 2018 from the DPE officer responsible for the Site. A responsewas not provided by the DPE.

3.2 Environment Protection AuthorityFeedback was sought on 11 January 2018 from the Environment Protection Authority (EPA) officerresponsible for the Site. A response was not provided by the EPA.

3.3 Sutherland Shire CouncilFeedback was sought on 15 January 2018 from the SCC officer responsible for the Site. The officerprovided a response to AECOM on the 22 January 2018 noting the following:

· During the audit period SCC has been involved in the review of documentation required underconditions of consent (e.g. management plans)

· SCC meets regularly with SUEZ to discuss management and monitoring at the LHRRP. This oftenincludes a site inspection.

· During May 2017 several odour complaints were received for the LHRRP which triggered thecomplaint threshold in the VPA between SUEZ and Council. This resulted in an internal audit ofthe odour source which identified remedial measures to manage the problem. SUEZ maintainedgood communication with Council during this process.

· Communication between SCC and SUEZ has dramatically improved since approval of SSD 6835.SUEZ regularly updates SCC on works on the site. Regular meetings are also held andenvironmental performance reports supplied to Council on a three monthly basis. This has helpedthe SCC keep the community informed and rapidly respond to any complaints.

3.4 Department of Primary Industries, Office of WaterFeedback was sought on 15 January 2018 from the Department of Primary Industries – Office ofWater (DPI Water) officer responsible for the Site. A response was not provided by DPI Water.



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4.0 Compliance with Statutory Requirements

4.1 Performance categoriesThe status of the LHRRP performance during the audit, in respect of each condition of the Consentand EPL is presented in Appendix A. Conditions considered to be not complied with, or not able to beverified, have been listed in Section 8.0 of this report.

Table 4-1 provides a summary of the performance categories in respect to the compliance status foreach requirement or commitment as defined in the Audit Guideline, October 2015, p7.Table 4-1 Performance category

Performance Category Definition

Compliant Currently in compliance. Sufficient verifiable evidence wasavailable to demonstrate that the intent and all elements of therequirement of the regulatory instrument had been complied withwithin the scope of the audit.

Non-compliant Currently not in compliance. Sufficient verifiable evidence wasavailable to demonstrate that the intent of one or more specificelements of the regulatory instrument has not been complied withwithin the scope of the audit.

Administrative non-compliance A technical non-compliance with a condition of the consent thatwould not impact on performance and that is considered minor innature (e.g. report submitted but not on the due date, failed monitoror late monitoring session). This would not apply to performancerelated aspects (e.g. exceedance of a noise limit) or where acondition had not been met at all (e.g. noise management plan notprepared and submitted for approval).

Not verified It has not been possible to determine whether compliance exists.Sufficient verifiable evidence to demonstrate that the intent and allelements of the requirement of the regulatory instrument have beencomplied with within the scope of the audit was not available.

Not triggered A regulatory approval requirement has an activation or timingtrigger that had not been met at the time of the audit inspection,therefore a determination of compliance could not be made.

Observation Observations are recorded where the audit identified issues ofconcern which do not strictly relate to the scope of the audit orassessment of compliance. Further observations are considered tobe indicators of potential non-compliances or areas whereperformance may be improved.

Noted A statement or fact, where no assessment of compliance isrequired.

Not assessed A condition has not been assessed as part of the scope of thisaudit

Table 4-2 provides a summary of the risk levels for non-compliances as defined in the Audit Guideline,October 2015, p8.



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Table 4-2 Risk Levels for Non-compliances

Risk Level Definition

High Non-compliance with potential for significant environmental consequences,regardless of the likelihood of occurrence

Medium Non-compliance with:· Potential for serious environmental consequences, but is unlikely to

occur; or· Potential for moderate environmental consequences, but is likely to occur.

Low Non-compliance with:· Potential for moderate environmental consequences, but is unlikely to

occur; or· Potential for low environmental consequences, but is likely to occur.

Administrative Non-compliance

Applied where the non-compliance does not result in any risk of environmentalharm (e.g. submitting a report to government later than required underapproval conditions).

Comments are provided beside each condition to explain aspects of the audit review. Whereconsidered relevant, observations have been made regarding specific compliance issues.

Conditions considered non-compliant are presented in Section 8.1. The table includes a discussion ofthe compliance status and recommendations for improvement where appropriate.

Where conditions are considered compliant; however it is considered there is an opportunity toimprove the compliance status of the condition, a recommendation has been made in the compliancetable. A summary of these Opportunities for Improvement (OFI) is provided in Section 8.3.



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5.0 Environmental Performance

5.1 Incident managementSUEZ utilises SIMS as its information database for electronic recording, management and statisticalreporting of incidents and complaints.

SUEZ has an Incident Reporting and Corrective Action Procedure (PROC008) which outlines howincidents (including environmental) and complaints should be managed. The procedure states that anInitial Incident Report must be raised in SIMS within 60 minutes and a Corrective Action Report (CAR)within 5 days. Incidents are prioritised according to a severity level as defined in the IncidentReporting and Corrective Action SOP. Severity levels are categorised as Minor, Moderate, Major andSevere. For environmental incidents these are considered:

· Minor: small containable on/off site environmental release. Easily cleaned up.

· Moderate: containable on/off site environmental release where there is no potential licencebreach. Moderate level of clean up required.

· Major: containable on/off site release where there is a potential licence breach and is notifiable tothe regulator. Major clean up required. Short term damage to the environment.

· Severe: uncontained on/off site environmental release which involves significant clean up andcauses serious actual or potential environmental harm or a licence breach that is notifiable to theregulator.

SUEZ provided a screenshot of the SIMS database filtered for the audit period and location (‘LucasHeights ORRF’ and ‘New Illawarra Road Landfill’). A review of this report indicated there were sixenvironmental incidents reported during the audit period. The six incidents have been summarised inTable 5-1.Table 5-1 Summary of incidents recorded in during audit period

Nature of Incident Landfill GO Facility

Fire 2 1Leaking leachate valve 1Litter 1Minor spill 1

Of the above incidents, the two fires at the landfill triggered the requirement for external reportingunder EPL 5065:

· Small Fire on the tarpomatic unit near the active tipping face on the 5 February 2017.

· Small fire on the landfill tipping face on the 5 May 2017.

Condition M8.7 of EPL 5065 requires that SUEZ record information such as the date, time, locationcircumstances which ignited the fire, action taken to extinguish the fire and action taken to prevent areoccurrence (amongst other things) for all fires occurring at the premises. This information wasprovided to the EPA for the above two fires.

SUEZ reported that no incidents of environmental harm occurred at Landfill or the GO Facility duringthe audit period.



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5.2 Complaint managementSUEZ has an Environment Report Hotline (1800 368 737) to receive feedback on environmentalmatters across all of its NSW facilities. The service is available 24 hours, 7 days a week and thenumber is advertised on SUEZ’s website. In addition SUEZ also operates a Customer Service Centre(1300 651 116) for the LHRRP which is operated between 9 am to 5 pm Monday to Friday. Thisnumber is also advertised on the SUEZ website and at the entrance to the LHRRP.

As described above the Incident Reporting and Corrective Action Procedure (PROC008) also appliesto the management of complaints. The procedure states that an Initial Incident Report and a CAR(using the Complaint CAR in SIMS) must be raised for complaints from the public, customers andcouncils. Incidents and complaints are prioritised according to a severity level as defined in theIncident Reporting and Corrective Action SOP. Severity levels are categorised as Minor, Moderate,Major and Severe. The procedure defines a complaint as “Any communication of an unacceptableservice level, environmental or OH&S risk or incident”.

48 complaints were received during the audit period, of these:

· 46 complaints related to odour.

· One complaint related to discharge of ‘sediment laden water to Mill Creek’.

· One complaint related to contamination at the TPA.

Odour complaints are discussed further in Section 5.3 and Appendix A.

The water management complaint was received via the EPA from a member of the public, reportingthat on Saturday 4 March 2017, water in Mill Creek was potentially contaminated with suspendedsediment from an overflow from the sediment dams at LHRRP following heavy rainfall over theweekend. The EPA provided this information to SUEZ for investigation and requested that SUEZprovide it with an update of the actions that SUEZ had undertaken to improve management ofstormwater discharges over the weekend. SUEZ responded to the EPA via letter dated 27 July 2017that the following works had been undertaken:

· Upgrading the STP control system from a manual system to a visual touch screen system(including new computer hardware and software).

· Installing an ultrasonic level detector in the sediment dam which is linked to the control systemallowing remote monitoring of the sediment dam.

· Enabling the control system to monitor any sediment dam overflow events and send notification tonominated site representatives via SMS.

· Revising the stormwater management plan to specify nominated personnel and the requiredactions to be undertaken outside of normal operating hours.

· Introducing a maintenance program for the stormwater plant including checking and verificationby SUEZ/Contractor.

· Installation of a freeboard marker in the sediment dam.

The complaint relating to contamination at the TPA was received via the EPA from an anonymoussource. The EPA requested SUEZ provide a response to its questions and photographs of the TPA.These were provided to the EPA by email dated 17 November 2017 and was not progressed furtherby the EPA. SUEZ had committed to extending the concrete within the TPA as per a recommendationin the 2015 URS IEA. At the time of the site inspection, these works had not been completed howeverSUEZ reported that they were planned in the coming weeks.



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5.3 Odour managementFigure 5-1 shows the odour complaints received at LHRRP from 2015 to 2017. As can be seen, themajority of odour complains were received in the period between March to August. In general, odourcomplaints have trended downwards since 2015 reflecting improvements in landfill gas and odourmanagement.Figure 5-1 LHRRP – Odour Complaints 2015-2017 (Source: SUEZ)

In 2017, 15 odour complaints were received from the community between the 15 to the 29 June. Inaccordance with the VPA and as documented in the SUEZ Complaint Investigation and RectificationProcess (Appendix K of the OEMP), when 15 or more complaints are received within any calendarmonth SUEZ undertakes an internal technical audit to investigate the area of concern.

The auditors reviewed the Internal Compliance Audit (Odour), dated 31 July 2017. Two actions wereimplemented following this investigation:

· Revision of the contractor checklist to include regular inspection of water traps.

· Revision of the existing GO Facility checklist to include inspection of the platform surface.

The Internal Compliance Audit identified that the management and mitigation measures outlined in theOEMP were in place as part of the day to day operations. SUEZ provided a copy of the odour audit toSCC. SCC noted that they were happy with the way SUEZ kept Council up to date with what washappening on site and were impressed with the way the problem was identified and resolved quickly.

During the site inspection, odours were not considered to be particularly offensive.



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SUEZ undertook the following measures to mitigate odour from the LHRRP:

· The tip face has been reduced in size.

· Waste is reportedly covered at the end of each day.

· An odour unit and odour fence is in place around the GO receivals area of the GO gardenorganics.

· Portable odour units were being used as required.

· The leachate and organics dams were reportedly aerated as required. At the time of the audit theleachate dam was at a very low level due to drought therefore no aeration was taking place.

· Weather conditions were monitored for when possible odorous works are undertaken.

· An odour patrol was undertaken in the mornings in and around the site to identify possible odour.The Auditors sighted the ‘Odour Assessment Diary 2017’ which records the date, time andlocation of odour patrol undertaken at the following two locations:

o Corner New Illawarra Rd and Heathcote Road

o Onsite inner perimeter road and carpark (two locations)

The Diary includes notes on the assessment (e.g. no odour detected, mild organics odour etc.).The Diary indicated assessments were being completed daily (Monday to Friday) during 2017.

· Ongoing installation of additional landfill gas collection wells.

· EDL, the operators of the gas infrastructure undertake inspections and identify areas that requireadditional wells or additional clay cover.

· A new odour unit and odour fence was installed on the south-eastern boundary of Area D. It wasreported that a second unit and odour fence was going to be installed on the western side ofArea D in early 2018.



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6.0 Site Inspection Observations

6.1 Site inspection observationsThis section provides a brief overview of key observations made during the Site inspection on 22 and23 January 2018.

The auditors were escorted around the Site by personnel (as listed in Section 1.5) who madethemselves available for this purpose.

Ref Comments

6-1 Landfill re-profiling

The tip-face for the landfillre-profiling, at Area D.


Stockpiles of soil are the strippedcover material and the browncolumns in the distance are theraised gas/leachate infrastructure.



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Ref Comments


Litter fencing to the west of theactive tip face at Area D.

6-4 Bund for stormwater drainage tothe west of Area D.



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Ref Comments

6-5 Example of the leachate and gasextraction infrastructure.

6-6 Odour fence and odour unit(‘OdourPro Vapourgard’) locatedwest of the landfill re-profilingArea D.



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Ref Comments

6-7 Dirty water drain constructed onthe western edge of the site.

6-8 This picture shows the westerndirty water drain with the firstbridge over the channel. In thedistance is Mill Creek (dry at thetime of the inspection) with thesmaller pedestrian bridge.

6-9 Dust deposition monitor on thewestern boundary of the Site.



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Ref Comments

6-10 The main leachate pond.

The leachate level was low at thetime of the site inspection. Thewhite area in the picture is theliner of the pond.

A section of the pond’s liner has‘ballooned’ between the twoaerators. This balloon in the linerwas observed during the 2015IEA. A recommendation of the2015 IEA was to “repair the linerwhich had lifted in main leachatedam”.

SUEZ reported that due to therain in 2016 and 2017, SUEZwas not able to empty the pondand do the repair however, it willbe in a better position to emptythe pond after the completion ofthe leachate treatment plantextension (on LH1) scheduled in2018.

Refer to 2018-IEA-REC07.

6-11 Leachate tank adjacent to themain leachate pond. The sitereported that these tanks were notcurrently in use as the leachatelevels were low.



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Ref Comments

6-12 Sediment Dam 5 (Main Dam).The dam water level was low dueto minimal rainfall over summer.

6-13 Stormwater treatment plant not inoperation at the time of the siteinspection.

6-14 The discharge point to Mill Creek.The small volume of water wasimpacted by Ibis waste.



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Ref Comments

6-15 Example of the area whereAcacia bynoeana was identifiedduring the EIS process. SUEZhas erected signs which state“Threatened Species ProtectedArea – contact SUEZmanagement before working nearthis area”, with a picture of thethreatened species.

6-16

Workshop

The workshop floor. In the 2015IEA the floor was identified asdamaged and a recommendationmade for its repair. This work wasundertaken since the previousaudit.

6-17 Workshop

Storage of oil containers stackedon top of each other in themaintenance yard on IBC bundedspill pallets. There is thepossibility that stacked containersmay topple outside the bundedpallet. It is also unlikely that thebund capacity is adequate for thevolume of products stored on it.

2018-IEA-REC01:

Review oil storage requirementsto enable drums to be storedwithout stacking and to ensurebunds have adequate capacity.



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Ref Comments

6-18 Workshop

Storage of IBCs and oil drumsand containers in themaintenance yard stored on IBCbunded spill pallets.

6-19 Workshop

The concrete bund waste watercollection tank access point. Asshown the soil was stained withhydrocarbons which indicates aspill had occurred.

2018-IEA-REC02:

Investigate the stained soil aroundthe underground waste oil pit nextto the maintenance yard andclean up and dispose of affectedsoil to an appropriately licensedfacility.

6-20 Workshop

The hydraulic oil bund. As shownin the picture there was productleaking over the bund wall,potentially from the inappropriatestorage of the hose.

2018-IEA-REC03:

Ensure hoses are correctly storedwhen not in use to prevent drips /spills outside of the bunded area.



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Ref Comments

6-21 Workshop

The 55,000 L diesel tankdiscussed in the previous auditreport was decommissioned(stored on site at the time of theaudit) and replaced with thisaboveground double-skinned selfbunded 60,000 L diesel tank.

6-22 Workshop

The area of fill placed below thetank shown above. Sedimentcontrols are shown in the distanceto minimise runoff of sediment.

6-23 Workshop

The drain for surface water fromthe workshop area to the oil waterseparator.

2018-IEA-REC04:

Ensure drains are inspected andcleaned regularly.



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Ref Comments

6-24 Workshop

The new lined and fencedstormwater pit at the maintenancearea. Water from the pit ismanually pumped into the dirtywater drain, as required. The Sitereported that it was reviewing theoperation of the stormwater pitand may upgrade the watertreatment to include sedimentcapture.

6-25 Refilling of the water truck.

6-26 Weather Station

The real time dust monitor wasinstalled during the audit period.



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Ref Comments

6-27 GO Facility

Stockpiles at the GO Facility. TheGO Facility EMP, Section 4.3,states that “organics stockpilesonsite are stored and stacked soas to be less than 4m in heightabove the surface level”. Many ofthe stockpiles appeared to be lessthan 4m (bottom picture) howevertwo stockpiles appeared to belarger than 4m (upper picture withexcavator).

2018-IEA-REC05:

Ensure stockpiles of organics aremaintained to be less than 4 m inheight as per the GO FacilityEMP.

6-29 GO Facility

The garden waste receivals area.

6-30 GO Facility

The garden organics leachatepond which was being aerated atthe time of the site inspection.



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Ref Comments

6-31 Truck Parking Area

The diesel tank located at thetruck parking area.

6-32 Truck Parking Area

Litter and broken bins observed atthe truck parking area.

Refer to 2018-IEA-OFI08.



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Ref Comments

6-33 Wheel Wash

The water treatment plant for thewheel wash facility.

6-34 Public Drop Off

Separate storage areas for oilsand paints.

6-35 Public Drop Off

General waste bins at the publicdrop off.



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7.0 Review of Environmental Management PlansSUEZ manages its environmental and WH&S performance on site through its Corporate InformationManagement System (IMS). The SUEZ IMS is structured on the requirements of AS/NZS 4801:2001and AS/NZS 14001:2004 and contains policies, procedures, management plans, EmergencyResponse Plans (ERPs), SOP and forms.

As required by the CoC D12, this section of the report includes a review of the adequacy of theEnvironmental Management Plans for the LHRRP.

A review of the following management plans has been undertaken as part of this audit:

· Operational Environmental Management Plan (OEMP)

· Air Quality and Odour Management Plan (AQOMP)

· Groundwater Management Plan (GMP)

7.1 OEMPTo satisfy the requirements of SSD 6835, SUEZ was required to update the Draft LHRRP OEMPprepared as part of the EIS (EIS, Appendix S). The OEMP for the new GO Facility or ARRT Facilityhad not been prepared at the time of the audit. SUEZ reported that these plans would be finalisedwhen the design and construction of the facilities was underway.

SUEZ updated the OEMP, dated 13 October 2017) which replaced the Landfill EnvironmentalManagement Plan (LEMP) for the Site. The OEMP was submitted to the DPE on the 23 August 2017.

The OEMP states that it has been prepared to address:

· environmental and operational activities associated with waste receivals, recycling and landfillinglocated at the landfill and RRC at the LHRRP;

· cumulative environmental impacts (i.e. odour) arising from all of the activities at the LHRRP; and

· certain aspects of LH1 which are required to support the environmental and operational activitiesat LHRRP.

The renewable energy generation at the LHRRP was being managed by Energy DevelopmentsLimited (EDL) through contractual arrangements with SUEZ and was therefore not included in theOEMP. EDL operates under its own EPL for the scheduled activity of generation of electrical powerfrom gas.

The OEMP states that it has been prepared to address the following statutory requirements:

· SSD 6835

· EPL 5065

· ANSTO Lease

· VPA.

The OEMP provides management strategies for surface water, groundwater, leachate, dust, landfillgas, odour, noise, litter, vermin and weeds, traffic and visual amenity. Table 7-1 includes a list of theAppendices included in the OEMP, including a summary of the latest known revision / review dates.



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Table 7-1 OEMP and Appendices Summary

Document Title Revision/ Review Date Regulatory Requirement

OEMP OEMP – LHRRP –PLANS004

13 October 2017 SSD 6835, Condition D4

Appendix A Conditions of Consent 23 January 2017 -

Appendix B Environment ProtectionLicence 5065

17 July 2017 -

Appendix C Reporting Template - -

Appendix D Indicative Staging Plan 03 July 2015 -

Appendix E Surface Water ManagementProgram &

Version 1 / July 2015 -

Surface Water MonitoringProgram

2009 EPL 5065, Condition U4.1

Appendix F Leachate Drainage SystemIntegrity

14 July 2005 EPL 5065, Condition U7

Appendix G Dust Management andMonitoring Plan


Appendix H Landfill Capping & QualityAssurance Plan

November 2008 -

Appendix I Landfill Gas ExtractionSystem


Appendix J Odour Management SOP65 20 May 2015 -

Appendix K Complaint Investigation andRectification Process

- VPA

Appendix L Weed Management Plan - -

Appendix M Emergency Response Plan 2 March 2017 SSD 6835, Condition D5

Appendix N Pollution Incident ResponseManagement Plan

15 June 2016 POEO Act

Appendix O Groundwater RemediationAction Plan

- Required under DA 11-01-99

Appendix P Landfill Surface GasMonitoring Program

February 2006 EPL 5065, condition M8.1

Appendix Q Landfill Subsurface Gas andAccumulation MonitoringProgram

July 2015 EPL 5065, condition M8.2

Appendix R Noise Management Plan(Truck Parking Area)

Rev 0 / 19 August 2010 Required under DA 11-01-99

Appendix S Lists of Threatened BiotaListed under the TSC Act

- TSC Act

It is noted that the Landfill Surface Gas Monitoring Program (Appendix P) and Landfill Subsurface Gasand Accumulation Monitoring Program (Appendix Q) are planned to be updated in March 2018, inaccordance with EPL 5065. A review of the OEMP identified that not all of the requirements ofSSD 6835, conditions D4 and D5 have been met. In addition, the OEMP was considered to be difficultto navigate and not very user-friendly which may have implications on its implementation. Theauditors have identified a number of areas where the OEMP can be further developed to improve itsadequacy.



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2018-IEA-REC06

It is recommended that the OEMP is revised to consider the following:

1. Update the OEMP to identify that the new GO Facility and ARRT Facility have not begunconstruction and that prior to their operation, the OEMP would be updated or a separate OEMP(s)prepared. The OEMP currently states that these OEMPs have been prepared.

2. Update ‘Section 1.6 Updates’ to include a clear list of times and events which would trigger theOEMP to be updated. In particular, include reference to the contents of CoC D8 which includes anumber of triggers for updating the OEMP and other strategies, plans and programs requiredunder SSD 6835.

3. Figure 2.1 does not clearly show the surrounding land uses as described in Section 2.1.3.Consider updating this figure to show the location of surrounding land uses and sensitivereceptors.

4. Section 2.2 of the OEMP includes a significant amount of information on the site characteristics.This level of information is considered unnecessary for an EMP and makes the OEMP difficult toread and less focused on its main objectives. It is recommended that this section is summarisedand pertinent information relating to the operation and environmental management controls bemoved to Section 8 ‘Environmental Management’. Reference can be made to the EIS for furtherdetailed information about the environmental characteristics of the area.

5. Figure 2.2 Site Layout identifies that that OEMP applies to the renewable energy generatingfacility and not the PCYC. Clarification is required around what activities are and are not includedin the OEMP.

6. Section 5.1 of the OEMP includes the requirements under s.66 of the Protection of theEnvironment Operations Act 1997 (POEO Act) to publish environmental monitoring data, requiredunder the EPL, on the company website within 14 days. It is noted that the requirement in theOEMP incorrectly states “or made available on request”. In accordance with s.66 (a) given SUEZmaintains a website that relates to the business or activity, the monitoring data must be madeavailable on the website. The auditors noted that all monitoring data required by EPL 5065 wasnot available on the website at the time of the audit.

7. Information on community complaints and incident management is repeated in multiple sectionsthroughout the OEMP (for example Sections 5.1, 6.3, 6.4, 6.5 and 7.13). It is recommended thisinformation be consolidated into one section to remove duplication and opportunity for errors andimprove the useability of the document.

8. Review references to superseded regulations, guidelines, approvals and licences for examplePOEO Waste Regulations 2005 should be POEO Waste Regulations 2014.

9. The OEMP includes detailed information on surface water, air quality and odour management andgroundwater management. It is recommended that this information is removed from the mainOEMP and instead include a reference to the Soil and Water Management Plan, GMP and AirQuality and Odour Management Plan. Referring to these plans would remove duplication andpotential errors when information is updated or changed. It is noted that the Soil and WaterManagement Plan needs to be updated with the requirements of SSD 6835.

10. Section 8.2 of the OEMP discusses surface water management. This section contains somedetails relating to the operation of the sediment dams however refers to the LHRRP EIS SurfaceWater Assessment (GHD 2015) for de-silting requirements. It would be more useful for this levelof detail as well as other information such as pumping and discharge requirements, maintenanceof freeboard, what to do before and during a rainfall event etc. to be included in the Soil andWater Management Plan or a specific Sediment Dam Procedure / Work Instruction.

11. Section 9 Monitoring requires updating to ensure all the relevant monitoring points, analytes andfrequencies listed in EPL 5065 (varied on 7 December 2017) are included.



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12. Following modification of DA 11-01-99, review the OEMP and remove or update any informationwhich relates to information required under DA 11-01-99. For example in Section 9.6.2.2 theOEMP discusses the requirement to have a Groundwater Remediation Action Plan, which hasbeen attached as Appendix O. This plan has been superseded by the GMP required under SSD6835, Condition C35, therefore the OEMP should refer to attach the most recent plan.

13. Section 9.10.1 and 9.11.1, monitoring points for landfill gas and noise, have not been completed.

14. Combine Sections 9.5 ‘Meteorological monitoring’ and 9.14 ‘Record of rainfall’.

15. Conduct a review and update appendices documents as required. Refer to Table 7-1 in this auditreport.

16. Include a section within the OEMP that states that the OEMP has been prepared to address therequirements of SSD 6835, Condition D4, D5 and D7, and identify where in the plan eachrequirement has been addressed.

17. Include a section which identifies which information will be made publically available on the SUEZcompany website in accordance with SSD 6835, D15 and other regulatory requirements.

18. Include the requirement to prepare an Annual Review in accordance with SSD 6835, ConditionD9.

19. Include a version control table in the front or back of the OEMP.

20. Whilst the OEMP identifies that the Site holds separate EPLs for the GO Facility and PCYC, itdoes not include the requirements of these EPLs. It is noted that the GO Facility has a separateEnvironmental Management Plan. It is recommended that the OEMP include the requirements ofthe EPL 13114 (for the PCYC) to ensure the monitoring and reporting requirements of this areaare not missed. In addition, the OEMP could cross-reference the GO Facility EMP.

21. As identified in the 2015 IEA, the management of the TPA is not discussed in the OEMP (2015-IEA-OFI09). The ongoing maintenance and operational requirements from the TPA CEMP shouldbe included in the OEMP.

22. Attach the AQOMP and GMP as an appendix to the OEMP, as required under SSD 6835,Condition D5.

7.2 Air Quality and OdourThe AQOMP, dated 13 December 2017, was prepared by SUEZ in response to SSD 6835, ConditionC11.

The auditors reviewed the AQOMP and consider that it adequately addresses the requirements ofSSD 6835. The following opportunity for improvement was identified:

2018-IEA-OFI01

Update Section 11 to include a reference to SSD 6835, Condition D8 which includes a number oftriggers for updating the strategies, plans and programs required under SSD 6835.

7.3 Groundwater ManagementThe GMP, dated 31 December 2018, was prepared by Douglas Partners on behalf of SUEZ inresponse to SSD 6835, Condition C35.

The auditors reviewed the GMP and consider that it adequately addresses the requirements of SSD6835. The following opportunities for improvement where identified:

2018-IEA-OFI02

1. Where the requirement to prepare the GMP is provided (Section 1.1) include reference to wherein the GMP each requirement has been addressed.

2. Include reference to the SSD 6835, Condition D8 which includes a number of triggers for updatingthe strategies, plans and programs required under SSD 6835.



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8.0 Summary of non-compliances and recommendationsRecommendations relating to observations of general environmental management, the adequacy ofthe various plans / programs and outstanding recommendations from the 2015 IEA are summarised inTable 8-1.

The auditors assessed compliance with Development Consent SSD 6835, EPL 5065, EPL 12520 andEPL 13114. The findings of this assessment is provided in Appendix A. The requirements consideredto be non-compliant as well as those where compliance could not be verified and the associatedrecommendations have been consolidated and are summarised in Table 8-2.

For a number of requirements that were assessed as compliant or not applicable, opportunities forimprovement (OFI) were made. These OFIs are summarised in Table 8-3.



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8.1 Summary of report recommendationsA summary of the recommendations made as a result of the adequacy review of the managementplans (Section 7.0) and site observations (Section 6.0) is provided in Table 8-1.Table 8-1 Summary of Recommendations relating to management plans, site observations and previous IEA

recommendations

Source # Recommendation / Opportunity for Improvement

Siteobservation

2018-IEA-REC01 Review oil storage requirements to enable drums to be storedwithout stacking and to ensure bunds have adequate capacity.

Siteobservation

2018-IEA-REC02 Investigate the stained soil around the underground waste oil pitnext to the maintenance yard and clean up and dispose ofaffected soil to an appropriately licensed facility.

Siteobservation

2018-IEA-REC03 Ensure hoses are correctly stored when not in use to preventdrips / spills outside of the bunded area.

Siteobservation

2018-IEA-REC04 Ensure drains are inspected and cleaned regularly.

Siteobservation

2018-IEA-REC05 Ensure stockpiles of organics are maintained to be less than 4m in height as per the GO Facility EMP.

OperationalEnvironmentalManagementPlan

2018-IEA-REC06 It is recommended that the OEMP is revised to consider thefollowing:

1. Update the OEMP to identify that the new GO Facility andARRT Facility have not begun construction and that prior totheir operation, the OEMP would be updated or a separateOEMP(s) prepared. The OEMP currently states that theseOEMPs have been prepared.

2. Update ‘Section 1.6 Updates’ to include a clear list of timesand events which would trigger the OEMP to be updated. Inparticular, include reference to the contents of CoC D8which includes a number of triggers for updating the OEMPand other strategies, plans and programs required underSSD 6835.

3. Figure 2.1 does not clearly show the surrounding land usesas described in Section 2.1.3. Consider updating this figureto show the location of surrounding land uses and sensitivereceptors.

4. Section 2.2 of the OEMP includes a significant amount ofinformation on the site characteristics. This level ofinformation is considered unnecessary for an EMP andmakes the OEMP difficult to read and less focused on itsmain objectives. It is recommended that this section issummarised and pertinent information relating to theoperation and environmental management controls bemoved to Section 8 ‘Environmental Management’.Reference can be made to the EIS for further detailedinformation about the environmental characteristics of thearea.

5. Figure 2.2 Site Layout identifies that that OEMP applies tothe renewable energy generating facility and not the PCYC.Clarification is required around what activities are and arenot included in the OEMP.



37


6. Section 5.1 of the OEMP includes the requirements unders.66 of the Protection of the Environment Operations Act1997 (POEO Act) to publish environmental monitoring data,required under the EPL, on the company website within 14days. It is noted that the requirement in the OEMPincorrectly states “or made available on request”. Inaccordance with s.66 (a) given SUEZ maintains a websitethat relates to the business or activity, the monitoring datamust be made available on the website. The auditors notedthat all monitoring data required by EPL 5065 was notavailable on the website at the time of the audit.

7. Information on community complaints and incidentmanagement is repeated in multiple sections throughoutthe OEMP (for example Sections 5.1, 6.3, 6.4, 6.5 and7.13). It is recommended this information be consolidatedinto one section to remove duplication and opportunity forerrors and improve the useability of the document.

8. Review references to superseded regulations, guidelines,approvals and licences for example POEO WasteRegulations 2005 should be POEO Waste Regulations2014.

9. The OEMP includes detailed information on surface water,air quality and odour management and groundwatermanagement. It is recommended that this information isremoved from the main OEMP and instead include areference to the Soil and Water Management Plan, GMPand Air Quality and Odour Management Plan. Referring tothese plans would remove duplication and potential errorswhen information is updated or changed. It is noted that theSoil and Water Management Plan needs to be updated withthe requirements of SSD 6835.

10. Section 8.2 of the OEMP discusses surface watermanagement. This section contains some details relating tothe operation of the sediment dams however refers to theLHRRP EIS Surface Water Assessment (GHD 2015) forde-silting requirements. It would be more useful for thislevel of detail as well as other information such as pumpingand discharge requirements, maintenance of freeboard,what to do before and during a rainfall event etc. to beincluded in the Soil and Water Management Plan or aspecific Sediment Dam Procedure / Work Instruction.

11. Section 9 Monitoring requires updating to ensure all therelevant monitoring points, analytes and frequencies listedin EPL 5065 (varied on 7 December 2017) are included.

12. Following modification of DA 11-01-99, review the OEMPand remove or update any information which relates toinformation required under DA 11-01-99. For example inSection 9.6.2.2 the OEMP discusses the requirement tohave a Groundwater Remediation Action Plan, which hasbeen attached as Appendix O. This plan has beensuperseded by the GMP required under SSD 6835,Condition C35, therefore the OEMP should refer to attachthe most recent plan.



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13. Section 9.10.1 and 9.11.1, monitoring points for landfill gasand noise, have not been completed.

14. Combine Sections 9.5 ‘Meteorological monitoring’ and 9.14‘Record of rainfall’.

15. Conduct a review and update appendices documents asrequired. Refer to Table 7-1 in this audit report.

16. Include a section within the OEMP that states that theOEMP has been prepared to address the requirements ofSSD 6835, Condition D4, D5 and D7, and identify where inthe plan each requirement has been addressed.

17. Include a section which identifies which information will bemade publically available on the SUEZ company website inaccordance with SSD 6835, D15 and other regulatoryrequirements.

18. Include the requirement to prepare an Annual Review inaccordance with SSD 6835, Condition D9.

19. Include a version control table in the front or back of theOEMP.

20. Whilst the OEMP identifies that the Site holds separateEPLs for the GO Facility and PCYC, it does not include therequirements of these EPLs. It is noted that the GO Facilityhas a separate Environmental Management Plan. It isrecommended that the OEMP include the requirements ofthe EPL 13114 (for the PCYC) to ensure the monitoringand reporting requirements of this area are not missed. Inaddition, the OEMP could cross-reference the GO FacilityEMP.

21. As identified in the 2015 IEA, the management of the TPAis not discussed in the OEMP (2015-IEA-OFI09). Theongoing maintenance and operational requirements fromthe TPA CEMP should be included in the OEMP.

22. Attach the AQOMP and GMP as an appendix to the OEMP,as required under SSD 6835, Condition D5.



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8.2 Summary of non-compliances and conditions assessed as not verifiedTable 8-2 Summary of Conditions assessed as non-compliant or not verified

Reference Condition/Requirement Compliance Status Comment RecommendationsSSD 6835,B8

Within 6 months of the date of this consent, the Applicant shall modify DA 11-01-99 to remove the conditions of that consent that relate to the LHRRP. Themodification shall be in accordance with the Environmental Planning andAssessment Regulation, 2000. The modification is required to ensure allactivities undertaken at the LHRRP are covered by this consent only.

Administrative non-compliance

An Application to Modify DA 11-01-99 was submitted to the DPE on the 13.09.17.As part of the process, SUEZ conducted a review of all of the conditions ofconsent for DA 11-01-99 and identified those conditions that should be removed ormodified.As Sutherland Shire Council (SSC) was a co-applicant for DA-11-01-99 its staffwere involved in the review.A letter was sighted from the EPA to the DPE (dated 11.10.17) stating that theEPA had no comments or objections to the modification.A letter was sighted from RMS dated 9.10.17 stating that RMS had no objections.At the time of the audit, the Modification was yet to be approved by the DPE asSUEZ was yet to receive land owner consent from ANSTO.The application was not submitted within 6 months of the date of the consent andon this basis, has been assessed as an administrative non-compliance.

SSD 6835,B11

The Applicant shall ensure that all plant and equipment used for theDevelopment are:(a) maintained in a proper and efficient condition; and(b) operated in a proper and efficient manner.

Non-compliant a) A number of procedures were in place to maintain plant and equipment in aproper and efficient condition, these included:

LandfillSelect Civil was responsible for maintaining plant and equipment used on thelandfill. Select Civil used a number of tools including:· Pre-start checklists.· The Plant Assessor database which tracks required regular maintenance

requirements and issues noted in pre-start checklists.· On-site maintenance workshop for non-major repairs. For major repairs plant

and equipment is sent off-site to Select Civils workshop.· Calibration/Inspection and Testing of Equipment Register.

During the site inspection the auditors observed that the liner of the main leachatepond was lifted (referred to as ‘whaling’ in the geomembrane). The 2015 IEAidentified the same issue and made the following recommendation (2015-IEA-REC34):· ‘Repair the liner which had lifted in the main leachate dam.’

The lift of the liner is caused by a build-up of gas below the membrane whichcannot escape. Whaling can lead to significant failures of the liner- at worst case itcan burst. It can also compromise the capacity of the leachate dam. SUEZreported that due to the rain in 2016 and 2017, it was not able to empty the pondand do the repair however, it will be in a better position to empty the pond after thecompletion of the leachate treatment plant extension (on LH1) scheduled in 2018.The extension works will commence subject to the approval of the DevelopmentApplication.

The emergency pond and leachate storage tanks are used to export leachate fromsite. The main leachate pond has pumps to allow transfer of leachate to either ofthese locations. This allows for a reduced volume of leachate to be stored in themain pond and reduce head pressure on the existing liner until furtherinvestigation into the liner integrity can be carried out.

SUEZ commissioned a structural adequacy review of the five concrete leachatetanks on 15.09.16. The inspection noted that four of the tanks, although they havesignificant cracking are considered structurally adequate. The report recommendsthat these tanks are inspected every two years. The fifth tank was not consideredstructurally adequate for use and should be emptied of any water and not used.During the audit inspection the five tanks were reportedly not in use. SUEZreported that Tank 5 had been decommissioned and is no longer in use.

2018-IEA-REC07:SUEZ should investigateif the integrity of the mainleachate pond liner hasbeen impacted by thewhaling of the liner andrepair it as required.



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Reference Condition/Requirement Compliance Status Comment RecommendationsGO FacilitySUEZ was responsible for maintaining the GO Facility plant and equipment. .SUEZ used a number of tools including:· Pre-start checklists.· The MAINPAC system which tracks required regular maintenance and issues

noted in pre-start checklists.

Water treatment plant and leachate treatment plantThe water treatment plant was being maintained by JPG Engineering. JPG useda number of tools including:· A Maintenance Leachate Inventory and Operations Checklist completed on a

daily basis.· Monitoring through SCADA which sends low flow, high level alarm alerts to

JPG Engineering. JPG view the SCADA system online and receiveemergency updates for example high-level alarms.

· JPG provide SUEZ with the records of maintenance. Auditors sighted thedaily records from JPG on the LH1 Leachate Treatment Plant.

· JPG Engineering provided a Monthly Operation and Plant Condition Reportto SUEZ. The report includes the weekly inspections for the wheel wash,stormwater treatment plant, leachate and ammonia treatment plant (LH1),leachate transfer pumps, Stage 5/3 leachate riser pump facility, grass drainstormwater recirculation pump, excavation water transfer pump, PCYC dustsuppression transfer pump.

Landfill GasEDL provide a monthly report to SUEZ which shows methane concentration, flowand gas volumes, broken monitoring points, which wells are not producing gas(due to malfunction or low gas volume). EDL operates under a separate EPL. Theauditors were provided with the December 2017 monthly report.

WeighbridgeThe Weighbridges are calibrated annually. The auditors sighted the weighbridgeRepair and Verification Reports, issued by Standard Scales and Services Pty Ltdfor In-bridge 1 (dated 10.11.17), In-bridge 2 (dated 30.05.17) and the Out-bridge(dated 28.07.17).

b) Each contractor on-site is contractually responsible for employing suitablytrained and competent staff.Select Civil reported that it completes a monthly forum which includes trainingon SUEZ Standard Operating Procedures (SOPs). Training records weresighted by the auditors for Dust Control (SC-SOP-024), dated 25.09.17, andLeachate Management (SC-SOP-018), dated 27.07.17. It was noted thattraining on the SUEZ OEMP and the conditions of consent in SSD 6835 hadnot been provided during the audit period but is reportedly planned.Training records for SUEZ staff were being maintained in SIMs. The ‘Landfill –Competency Skill Matrix’ is a register which maintains SUEZ staff trainingneeds and records.Operational meetings were held monthly with SUEZ, Select Civil, EDL andJPG to track project progress including training.

SUEZ implements a number of controls to maintain and operate plant andequipment in an efficient manner. However, this condition has been assessed asnon-compliant as no actions were taken to assess the integrity or repair the mainleachate pond liner.



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Reference Condition/Requirement Compliance Status Comment RecommendationsSSD 6835,B12

Prior to the commencement of construction, the Applicant shall:(a) prepare a dilapidation report of the public infrastructure in the vicinity of thesite (including roads, kerbs, footpaths, nature trip, street trees and furniture);and(b) submit a copy of this report to the Secretary and Council.


A dilapidation report was prepared by AECOM dated 20.04.17. A copy wassubmitted to the Secretary on the 07.07.17. A response from DPE, dated 10.07.17was sighted by the Auditors which confirmed it was received with no furthercomments.SUEZ was not able to find evidence of submission to SCC prior to constructioncommencing in January 2018. Internal SUEZ emails were reviewed by theauditors which indicated that they were going to send the report to Council, dated8.05.17. SUEZ emailed a copy of the dilapidation report to SCC on 2.03.18 (emailsighted by auditors).On the basis that the dilapidation report was not submitted to Council prior to thecommencement of construction, this requirement has been assessed as anadministrative non-compliance.

SSD 6835,B18

Where consultation with any public authority or community group is required bythe conditions of this consent, the Applicant shall:(a) consult with the relevant public authority or community group prior tosubmitting the required documentation to the Secretary for approval, whererequired;(b) submit evidence of this consultation as part of the relevant documentationrequired by the conditions of this consent; and(c) include the details of any outstanding issues raised by the relevant publicauthority or community group and an explanation of or agreement between anypublic authority or community group and the Applicant or any person acting onthis Development consent.

Non-compliant Consultation with public authorities and/or community groups has been discussedagainst the specific conditions below. The AQOMP and GMP include records ofconsultation with the relevant agencies as appendices, however not all plans /reports requiring consultation include these details, for example, the OEMP (D4),Emergency Response Plan (C63) and odour audit (Condition C12). On this basis,this condition has been assessed as not compliant.

2018-IEA-REC09:Ensure evidence ofconsultation is submittedto the DPE as part of therelevant documentationrequired by the conditionsof consent. This shouldinclude details of anyoutstanding issues raisedduring the consultationand an explanation of theagreement reached.

SSD 6835,C12

The Applicant shall conduct an odour audit of the landfill to validate the odourreductions described in the EIS have been achieved at the existing landfill. Theodour audit shall:(a) be prepared by a suitably qualified and experienced person in consultationwith the EPA and Council;(b) be submitted to the EPA, Council and the Secretary at least one monthprior to the commencement of landfill re-profiling;(c) include collection and analysis of odour samples in accordance with theEPA's Approved Methods for Sampling and Analysis of Air Pollutants in NSW;and(d) identify mitigation measures with a timeline for implementation, where theodour reductions identified in the EIS are not being achieved.

Non-compliant (a) A LHRRP Landfill Odour Audit was conducted by environmental consultants,GHD (report dated October 2017).SUEZ submitted the Odour Audit to SCC for consultation in an email dated25.09.17. SCC provided comments in an email dated 6.10.17, and noted therequirement for odour sampling and the relevance of the daily odourobservations, as SUEZ odour observations during June did not identify anyodour issues, however 15 complaints were received from the community.SUEZ submitted the Odour Audit to the EPA for consultation in an emaildated 25.09.17. A response from the EPA was received in a letter dated24.10.17. The EPA raised a number of concerns including:- The audit does not discuss the comparative effectiveness in odour

reduction from any specific measurements implemented and appears todraw conclusions based on a general reduction in odour in the sectionssurveyed.

- The EPA provided a number of factors that may have influenced theconclusions drawn in the Odour Audit.

- That the audit does not discuss the relationship between the workscompleted and the odour complaints received, which increased duringthe time period of the audit.

A response from SUEZ to SCC and the EPA was not provided to theauditors.

(b) Re-profiling commenced in January 2018. SUEZ submitted the Odour Auditto the DPE (email dated 26.10.17). SUEZ had not provided a copy of the finalOdour Audit to the EPA and Council at the time of the audit. SUEZ reportedthat it was reviewing the Odour Audit in conjunction with the Air Quality andOdour Management Plan.

(c) Odour samples were not collected as part of the audit. Section 3.1 of theOdour Audit Report states that “SUEZ advised GHD that it had previouslymet with the EPA and the EPA agreed that odour sampling was not needed,should observations made during the audit’s site inspection indicate thatsuitable odour reductions have been realised at the site”.

2018-IEA-REC11:Submit the final OdourAudit to SCC and EPA asper C12(b).



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Reference Condition/Requirement Compliance Status Comment RecommendationsSUEZ reported to the auditors that this correspondence was verbal during aface to face meeting held on the 11.07.17. Formal written evidence of thisdiscussion was not available. In addition, GHD recommended that “odoursampling is not to be undertaken in the main areas identified in 2014, as it isconsidered unlikely that the odour emitted from these areas would bedetectably at off-site receptors”.

(d) The Odour Audit found that the odour reductions described in the EIS in 2015have been achieved at the main odour emitting areas of the landfill. The auditnoted the following:- The landfill batters – no landfill gas was notifiable in the ‘rectangular

area south of the excavation stockpile’. However no landfill gas odourswere detected on site 150m downwind, which indicates that odouremissions from this area are limited.

- ‘v section’ – significant odour was not experienced off the new landfillbarriers or from the ‘v section’ as it no longer exists.

The Audit included a number of mitigation measures already identified andbeing implemented by SUEZ and recommended they continue to beimplemented.

On the basis that it could not be demonstrated whether the EPA and SCC’scomments on the Odour Audit report were addressed, and whether a Final versionof the Odour Audit was provided to the SCC and EPA prior to the commencementof landfill re-profiling, this condition has been assessed as non- compliant.

SSD 6835,C28

The Applicant shall routinely monitor leachate volumes from all sources and re-calibrate the leachate model included in the EIS, to ensure adequate storage,treatment and disposal capacity is maintained at all times. The Applicant shallreport the results of on-going monitoring and model calibration every year inthe Annual Review required under Condition D7.

Not verified Real-time monitoring of leachate volumes is conducted using a SCADA system.JPG provides a monthly “Leachate Inventory Status Report Spreadsheet” toSUEZ. The report includes the leachate volumes for sources across the site, forexample Harrington’s Quarry, LH2 Dam to Emergency Dam, LH2 storage dam,LH2 Stage 5/3 etc. Leachate Volumes are reported to the EPA every 12 months inthe Annual Return.The auditor reviewed email correspondence from the GHD technical lead for theleachate studies undertaken as part of the EIS, which stated that the intent of themitigation measures proposed in the EIS and Response to Submissions Reportwas for ongoing monitoring to facilitate periodic recalibration of the water balance.SUEZ reported that it would look into seeking a modification to have this conditionto align with the intent of the leachate studies. In the meantime, the AnnualReview is required to report on the leachate model calibration. As the submissionof the Annual Review for the 2017 calendar year fell outside of the audit period,this condition could not be verified.

2018-IEA-REC12:Ensure the 2017 annualreview includes acalibration of the leachatemodel included in the EISor seek a modification tothis requirement.

SSD 6835,C30

The Development shall comply with Section 120 of the POEO Act, whichprohibits the pollution of waters, except as expressly provided for in an EPL.

Non-compliant EPL 5065 includes concentration limits for pollutants discharged to waters fromPoints 1, 20, 21 and 22.Surface WaterSUEZ reported the following non-conformance with limits in EPL 5065 in theAnnual Return for the audit period (23.01.17 – 20.08.17):· Six exceedances of suspended solids at EPL Monitoring Point 1 on the

17.03.17, 18.03.17, 19.03.17, 25.03.17, 4.4.17 and 10.06.17· Five exceedances of suspended solids at EPL Monitoring Point 22 on the

17.03.17, 18.03.17, 19.03.17, 04.04.17 and 10.06.17· Four exceedances of dissolved oxygen levels at EPL Monitoring Point 1 on

the 03.03.17, 09.03.17, 18.03.17 and 25.03.17. The auditors note that theexceedance reported on the 25.03.17 was a concentration of 6 mg/Ldissolved oxygen. This is not considered a non-compliance as it is not lessthan 6 mg/L, which is the concentration limit in Condition L2.4 of the EPL.

SUEZ provided a copy of the laboratory reports for review of sampling data forEPL Points 1, 21, and 22. No other exceedances of surface water monitoring werereported by SUEZ.SUEZ received a letter from the EPA (dated 27.06.17), requesting an update ontwo areas of stormwater management:1. Stormwater management infrastructure works, undertaken by SUEZ to

improve ammonia levels in stormwater.



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Reference Condition/Requirement Compliance Status Comment Recommendations2. Stormwater discharge management on weekends in response to a

community complaint received identifying potential overflow from LHRRPstormwater dams on Saturday 4 March 2017 resulting in suspended solidsdischarging to Mill Creek. No sampling was conducted by SUEZ during thisdischarge over the weekend.

SUEZ provided a letter response to the EPA (dated 27.07.17) which reported thatthe following works had been undertaken:1. Stormwater management infrastructure works:· Replacement of leachate ring main between LP16 and LP17.· Installation of a new section of HDPE pipe and associated riser pipes.· Reinstatement of the pipeline and backfilling it with clay, forming a barrier

between the edge of the capping and the western dirty water drain.· Removal of the French Water Drain.· Reconstruction of the dirty water drain, including gabion baskets

2.Stormwater discharge management on weekends:· Upgrading the STP control system from a manual system to a visual touch

screen system (including new computer hardware and software).· Installing an ultrasonic level detector in the sediment dam which is linked to

the control system allowing remote monitoring of the sediment dam.· Enabling the control system to monitor any sediment dam overflow events

and send notification to nominated site representatives via SMS.· Revising the stormwater management plan to specify nominated personnel

and the required actions to be undertaken outside of normal operating hours.· Introducing a maintenance program for the stormwater plant including

checking and verification by SUEZ/Contractor.· Installation of a freeboard marker in the sediment dam.

A response from the EPA to SUEZ’ letter was not sighted by the auditors.The auditors observed the western ring main and new western dirty water drainduring the site inspection on the 22.01.17. Photos are provided in Section 6.1 ofthe main report.The GO Facility EPL (12520) and PCYC Minibike Club EPL (13114) do not includeconcentration limits for pollutants discharged to waters. The Annual Returns forthe GO Facility and PCYC Minibike Club did not report any incidents of pollution ofwaters. On the basis of the recorded exceedances with EPL 5065 pollutantconcentration limits during the audit period this condition has been assessed asnon-compliant.GroundwaterGroundwater monitoring was undertaken quarterly at 11 locations prior to EPL5065 variation dated 07.12.17. SUEZ publishes results of the monitoring on theSUEZ website.EPL 5065, condition R4.2 requires that SUEZ reports to the EPA levels ofammonia detected above 1 mg/L at Points 4, 7, 8, 16, 17, 18, 19 (and from07.12.12 Points 24, 25, 26, 27, 44, 45, 46, 47, 48 or 49. A review of the quarterlymonitoring results for Mar, Jun, September and December identified no instanceswhere ammonia levels greater than 1mg/L were detected. No other limits ongroundwater pollutants are specified in the EPL.



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Reference Condition/Requirement Compliance Status Comment RecommendationsSSD 6835,C35

The Applicant shall prepare a Groundwater Management Plan for the site. Theplan must:(a) be prepared by a suitably qualified and experienced person, in consultationwith the EPA and DPI Water;(b) be submitted to the Secretary, prior to the commencement of construction;(c) detail the groundwater monitoring network including location and frequencyof monitoring, the parameters for testing, relevant criteria and trigger levels foraction;(d) include a protocol for investigation, notification and mitigation of anyexceedances of the identified trigger levels; and(e) describe the measures that could be implemented to respond to identifiedgroundwater contamination.


SUEZ has prepared a Groundwater Management Plan (GMP), dated 31.01.18.(a) The plan was prepared by Douglas Partners, in consultation with the EPA

and DPI. SUEZ met with DPI Water for a consultation meeting on the28.07.17. Two letters were received from DPI Water on the 19.04.17 and10.08.17 providing a number of recommendations/ comments. DPI Waterprovided a number of comments in regards to preparation of the plan inaccordance with the requirements of Condition C35 (c), (d) and (e).The EPA was provided the GMP for consultation in an email dated 6.09.17.The EPA provided a response in a letter dated 10.10.17, in which a numberof recommendations / comments were made.

(b) The GMP was originally submitted to DPE on the 19.10.17. The DPEprovided comments on the GMP on the 30.10.17.The DPE noted that not re-establishing bores, as per Condition C5, requires a modification to SSD 6835(discussed further in C36).The GMP was updated in January 2018 and re-submitted to DPE via emaileddated 13.02.18.Construction commenced in January 2018.

Submission of the updated GMP to the EPA and DPI Water and confirmation thatthe agencies were satisfied that their comments had been addressed was notsighted by the auditors. On the basis that the updated plan addressing the EPAand DPI comments was not provided to the DPE prior to construction, thiscondition has been assessed as an administrative non-compliance.The GMP has been prepared to address the re-profiling of the existing landfill onlyand does not include the GO Facility or the ARRT Facility. DPE provided approval(letter dated 22.02.18) under SSD 6835, Condition B14, for the GMP to besubmitted in two stages, the re-profiling (Stage 1) and the GO Facility and ARRTFacility (Stage 2).The auditors conducted a high level review of the GMP (dated January 2018) andfound that the plan included:· Monitoring locations including EPL reference number for surface water,

leachate and groundwater, including figures.· Monitoring point analytes and frequency of monitoring,· Groundwater investigations trigger levels based on the National water quality

management strategy. Australia and New Zealand Guidelines for Fresh andMarine Water Quality 2000 (ANZECC), EPL Limits and National Health andMedical Research Council (2011) drinking water criteria.

· A procedure for investigation, notification and mitigation.· The measures that would be adopted if sampling of groundwater monitoring

bores indicates any abnormality in the groundwater tests (‘GroundwaterContamination Response Plan’).

2018-IEA-REC13:Submit the updated GMPto EPA, DPI Water andDPE.

SSD 6835,C36

The Applicant shall re-establish historic groundwater monitoring bores (BH24,BH31, MB021 and MB022) to improve detection of leachate in groundwatersystems to the north of the site. The Applicant shall monitor groundwater fromthese bores in accordance with the requirements of an EPL for the site and thegroundwater management plan required under Condition C35.

Not verified Section 5.1 of the GMP provides an assessment of the requirement to re-installBH24, BH31, MB021 and MB022. Douglas Partners recommends that BH31,MB021, BH24, MB022 are not re-instated. They have identified a gap inmonitoring on the western site boundary, south of points MB305 and MB306, andtherefore recommend installation of two bores in this area, prior to thecommencement of operations at the GO Facility and ARRT Facility.Correspondence from DPI Water dated 10.08.17 also made the followingrecommendations:· Refurbishment of MB022.· An additional monitoring bore is strongly recommended to be installed

approximately positioned 100 to 120 m north-northwest of bores MB038 –MB039. This new monitoring bore site is considered by DPI Water as analternative to re-establishing the three northern bores (BH31, MB021 andBH24) referred to in C36.

· Installation of this new nested monitoring bore site is strongly recommendedby DPI Water and is proposed to be included as part of the ongoingdevelopment of the monitoring network and the landfill site. This additionalmonitoring bore is to be a nested bore, including two screens, a shallowscreen and a deeper screen of similar depth to MB022.

2018-IEA-REC14:Submit a modification tohave this conditionremoved if the EPA andDPI Water agree thatthese bores are no longernecessary.



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Reference Condition/Requirement Compliance Status Comment RecommendationsSUEZ has acknowledged the last two recommendations and undertaken theinstallation of two new monitoring wells in December 2017. The installation reportfor these two new monitoring wells is provided in Appendix H of the GMP. TheGMP identifies that MB022 will not be reinstated.The four monitoring bores have not been added to the EPL in the December EPLVariation.The auditors have not been able to adequately assess compliance against thiscondition, based on the ongoing consultation with DPI Water on the requirement toinstall these wells. The updated GMP should be submitted the EPA, DPI Waterand DPE. Following their review, if agreed, SUEZ should seek a modification toremove/ modify this condition.

SSD 6835,C61

Within one month of the date of this consent, the Applicant shall submit SiteImpact Recording Forms to OEH for the four previously impacted Aboriginalheritage sites, AHIMS 52-2-1 108, 52-2-1029, 52-2-1030 and 52-2-1031 , asdescribed in the EIS.


Consent was granted on the 23.01.17. Site Impact Recording Forms for the fourpreviously impacted Aboriginal Heritage Sites, AHIMS 52-2-1108, 52-2-1029, 52-2-1030 and 52-2-1031 were prepared on the 22.03.17. These forms weresubmitted to OEH Heritage Branch via email dated 07.04.17. OEH confirmedacceptance via email dated 10.04.17.Based on the submission of these reports more than one month after consent wasgranted this condition has been assessed as an administrative non-compliance.

SSD 6835,C63

The Applicant shall prepare an Emergency Response Plan for the site detailingprocedures to be implemented in the event of a fire on or near the site. TheEmergency Response Plan shall:(a) be prepared by a suitably qualified and experienced expert in consultationwith Council and the NSW Rural Fire Service;(b) be submitted to the Secretary within three months of the date of thisconsent, or an alternative timing as otherwise agreed with the Secretary; and(c) detail emergency access and egress routes, including an alternative accessroute, escape routes, refuge areas, assembly points and evacuationprocedures.


The ERP has been prepared to provide procedures for 23 types of emergencyincidents, including fires on site at the greenwaste/mulch/compost and landfillsurface, underground (in the landfill waste) and fire in received waste loads andfires off-site at adjacent properties.The ERP was prepared initially in 2013 and has been updated most recently inAugust 2017. The ERP was prepared and revised by a number of SUEZ staff.The most recent update was completed by the Site’s Compliance Officer inconsultation with NSW Rural Fire Service.The ERP was provided to the NSW Rural Fire Service on the 14.03.17. The NSWRural Fire Service provided comments on the ERP on the 6.05.17. In particular theNSW Rural Fire Service requested that emergency procedures include triple zeronotification to all fires, irrespective of size. The auditors reviewed the ERP andfound that SUEZ had incorporated these comments into the ERP.The ERP was provided to the SCC in March 2017 for consultation. SCC providedcomments via email dated 2.05.17. The auditors reviewed the comments andfound that some of the comments had been incorporated into the ERP dated21.08.17.b) The ERP was sent to DPE on 23.08.17. The consent was granted on the23.01.17.c) The ERP includes an Evacuation Diagram however this appears to be only ofthe resource centre and not the entire site. For example it does not detailalternative access / egress routes from the landfill or existing GO Facility.This condition has been assessed as an administrative non-compliance as theERP was not submitted to the DPE within three months of the consent beinggranted. It is noted the relevant agencies required approximately two months toprovide comments on the draft ERP.

2018-IEA-OFI09:Update the EvacuationDiagram within the ERPto include the entire siteand detail alternativeaccess / egress routesfrom the landfill andexisting GO facility.



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Reference Condition/Requirement Compliance Status Comment RecommendationsSSD 6835,D1

The Applicant shall prepare a Construction Environmental Management Plan(CEMP) for the Development, to the satisfaction of the Secretary. The Planmust:(a) be prepared in consultation with Council and be approved by the Secretaryprior to construction of the Development;(b) identify the statutory approvals that apply to the site;(c) outline all environmental management practices and procedures to befollowed during construction;(d) describe all activities to be undertaken on the site during construction,including a clear indication of construction stages;(e) detail how the environmental performance of the construction works will bemonitored, and what actions will be taken to address identified adverseenvironmental impacts;(f) describe the roles and responsibilities for all relevant employees involved inconstruction works; and(g) include the management plans under Condition D2 of this consent.

Non-compliant As per the definitions of the consent, construction means:“As described in the EIS, including:

· Landfill re-profiling, stripping back covered areas and landfilling on top ofexisting waste;

· Construction of the GO Facility, earthworks, hardstand, internal accessroad, water and leachate infrastructure, waste receivals and sorting areas,compost bunkers and storage areas;

· Construction of the ARRT Facility, earthworks, hardstand, buildings,biofilters, water infrastructure; and

· Mill Creek re-alignment.”During the audit period the following construction works had commenced:

· Landfill re-profiling, stripping back covered areas and landfilling on top ofexisting waste.

SUEZ reported that as the bulk of construction works had not commenced(construction of the ARRT and GO facility) a separate CEMP for the re-profilingworks had not been prepared. Instead these works were incorporated into theOEMP, required under Condition D2.The OEMP did not make it clear that it was incorporating the requirements of D1for the re-profiling works into the OEMP nor was this communicated to the DPE inits submission of the OEMP via email on the 23.08.17.Approval from DPE for the LHRRP OEMP had not been received at the time of theaudit. On the basis that the OEMP had not been approved prior tocommencement of landfill re-profiling works, this condition is considered non-compliant.

2018-IEA-REC16:Make it clearer within theOEMP that it alsoincorporates therequirements of ConditionD1 for a CEMP for theworks associated with re-profiling, stripping andlandfilling on top ofexisting waste and seekDPE approval of thisapproach.

SSD 6835,D3

The Applicant shall carry out construction of the Development in accordancewith the CEMP approved by the Secretary (and as revised and approved bythe Secretary from time to time), unless otherwise agreed by the Secretary.

Non-compliant SUEZ reported that the CEMP for the dual gas and leachate trench had not beensubmitted to Secretary at the time of the audit.It is recommended that SUEZ seek a staged submission of the CEMP, requiredunder Condition D1 and D2 (as permitted by Condition B14) to allow submission ofthe CEMP for the dual gas and leachate trench separately to the CEMP for theconstruction works.

2018-IEA-REC17:Seek a staged submissionof the CEMP, requiredunder Condition D1 andD2 to allow submission ofthe CEMP for the dualgas and leachate trenchseparately to the CEMPfor the construction works.

SSD 6835,D4

The Applicant shall amend the draft Operational Environmental ManagementPlan (OEMP) for the Landfill, GO and ARRT Facilities, to the satisfaction of theSecretary. The Plans must:(a) be prepared in consultation with Council and be approved by the Secretaryprior to operation of the Development;(b) identify the statutory approvals that apply to the site;(c) outline all environmental management practices and procedures to befollowed during operation;(d) detail how the environmental performance of the Development will bemonitored, and what actions will be taken to address identified adverseenvironmental impacts; and(e) include the management plans under Condition D5 of this consent.


As per the definitions of the consent, operations means:“As described in the EIS, includes receipt, processing and landfilling waste on there-profiled landfill and at the GO and ARRT facilities”Landfilling waste on the re-profiled area began in January 2018.

SUEZ was required to update the Draft LHRRP OEMP prepared as part of the EIS(EIS Appendix S). The LHRRP OEMP, dated 13.10.17 replaced the LandfillEnvironmental Management Plan (LEMP) for the Site and relates to activitiesassociated with landfilling and re-profiling. The Draft OEMPs for the GO Facility orARRT Facility prepared as part of the EIS (Appendices T and U respectively) hadnot been updated at the time of the audit. SUEZ reported that the OEMP would beupdated to cover these activities and the associated management measures whenthe design and construction of the GO Facility and ARRT Facility was underwayand prior to their operation as per this condition. DPE approved this stagedapproach by letter dated 22.02.18.

a) Evidence of consultation with SCC was sighted by the auditors, as a series ofemails dated between the 10.01.17 and 14.03.17.

The OEMP was submitted to the DPE via email on the 23.08.17. Approvalfrom DPE for the LHRRP OEMP had not been received at the time of theaudit.

2018-IEA-OFI10:There is an opportunity forthe OEMP to capture therequirements of the PCYCEPL to ensure therequirements of the EPLare not missed.



47

Reference Condition/Requirement Compliance Status Comment Recommendationsb) The OEMP states that it has been prepared to address the following statutory

requirements:

· SSD 6835;

· EPL 5065;

· ANSTO Lease;

· VPA.

The OEMP identifies that the Site holds other EPLs for the GO Facility andPCYC minibike club but does not incorporate the requirements of theseEPLs. There is an opportunity for the OEMP to capture the requirements ofthe PCYC EPL to ensure the requirements of the EPL are not missed. TheGO Facility has a separate OEMP.

c) The OEMP includes a number of sections on the environmental managementof the Site including surface water, leachate, landfill gas, odour, dust, litter,noise, weeds, traffic and emergency preparedness. It was noted that theOEMP needs to be updated to include the updated requirements of EPL5065, varied on 07.12.17.

d) The OEMP includes a section on the monitoring requirements required underthis consent and EPL 5065. As identified above this plan requires updating toreflect the updated EPL 5065. In addition the monitoring requirements ofPCYC EPL 13114 should be included to capture all the regulatory monitoringrequirements. In addition Appendix C includes a summary of the monitoringreporting requirements for the Site. The OEMP also includes a description of‘rectification measures’; which would be implemented in the event that anenvironmental incident occurs.

e) Refer to Condition D5.Refer to the main report for further discussion of the adequacy of the OEMP.This condition has been assessed as an administrative non-compliance asapproval from the DPE had not been received prior to operations commencing inJanuary 2018.

SSD 6835,D5

As part of the OEMP's for the Development, required under Condition D4 ofthis consent, the Applicant shall include the following:(a) site air quality and odour management plan (Condition C11);(b) ARRT Facility air quality and odour management plan (Condition C17);(c) biofilter and pre-treatment monitoring and maintenance plan (ConditionC18);(d) aquatic habitat monitoring plan (Condition C33);(e) Mill Creek stream rehabilitation, stabilisation and vegetation managementplan (Condition C34);(f) groundwater management plan (Condition C35); and(g) emergency response plan (Condition C63).


The following plans have been attached the OEMP, dated 13.10.17:· Emergency Response Plan, dated 2.03.17

At the time of the audit the AQOMP (Condition C11) and the GMP (Condition C35)were not attached to the OEMP.At the time of the audit the management plans required under Conditions C17,C18, C33 and C34 were not required to be prepared. Therefore the requirement toinclude the plans with the OEMP had not been triggered.The auditors noted that the OEMP document did not include the attachmentswithin the Appendices headings. SUEZ should review the documents contained itthe appendices of the OEMP and revise as required.

2018-IEA-REC18:Review the documentscontained it theappendices of the OEMPand revise as required,including attachment ofthe most recent plansunder this condition,AQOMP and GMP.



48

Reference Condition/Requirement Compliance Status Comment RecommendationsSSD 6835,D15

The Applicant shall make the following information publicly available on itswebsite and keep the information up to date.(a) the EIS, RTS, CEMP and OEMPs;(b) current statutory consents, approvals and licences for the site;(c) approved strategies, plans and programs;(d) a summary of all monitoring data for the site as required under this consent;(e) a complaints register, updated on an annual basis;(f)Annual Reviews, Independent Environmental Audits and the Applicant'sresponse to the recommendations; andg) any other matter required by the Secretary.

Note: This requirement does not require any confidential information to bemade available to the public.

Non-compliant The following information was available on the SUEZ website, when reviewed onthe 27.02.18:· A link to the EPA Register was provided to access EPL 5065 and EPL

12520.· Development Consent (SSD 6835), dated 23.01.17.· The OEMP for the LHRRP, dated March 2017. It is noted that this is not the

most recent version of the OEMP. SUEZ needs to update the website toinclude Version 2, dated 13.10.17. In addition the Appendices to the OEMPhad not been attached the website.

· A link to the DPE Major Projects Assessment website for SSD 6835, whichincludes the EIS and RTS.

The following documents required under this condition were not provided on thewebsite:· EPL 13114· Noise monitoring data from the annual noise monitoring report, required

under Condition C56.· Complaints register· Air quality and odour management plan (Condition C11)· Groundwater management plan (Condition C35), however it is noted that this

was updated on the 31.01.18, therefore would not have been uploaded at thetime of this audit

· Emergency response plan (Condition C63)· CEMP for the dual gas and leachate trench

Part (f) and (g) have not been triggered during the audit period.It is noted that additional monitoring data is provided on the website as requiredunder the EPL.

2018-IEA-REC19:Review the requirementsof this condition andupload the requireddocumentation to theSUEZ website.

EPL 5065,

L1.1

Pollution of waters

Except as may be expressly provided in any other condition of this licence, thelicensee must comply with section 120 of the Protection of the EnvironmentOperations Act 1997.

Non-compliant Refer to SSD 6835, Condition C30.

EPL 5065,

L2.4

Water and/or Land Concentration Limits Non-compliant Point 1 (MC 1)

SUEZ conducted monitoring at Point 1 31 times during the audit period. Theconcentration limits were exceeded for:

· Dissolved oxygen three times (5.2 mg/L, 5.2 mg/L and 5.3 mg/L).

· Total Suspended Solids (TSS) six times. The range of exceedances wasbetween 60 mg/L and 210 mg/L.

Point 20 (DS002), 21 (DS001), 22 (OF001)

SUEZ reported that no discharges occurred from Point 20 during the audit period.

Point 21 (DS001) is the point of discharge from the stormwater plant. SUEZconducted monitoring at Point 21 25 times during the audit period. The samplingwas triggered by wet weather and to establish the freeboard in the main sedimentdam. There were no exceedances of pollutant limits at Point 21 during the auditperiod.

Point 22 (OF001) is the overflow point from sediment dam 5. SUEZ conductedmonitoring at Point 22 five times during the audit period. The TSS concentrationlimit was exceeded five times with a range of 160-410 mg/L.

This condition has been assessed as non-complaint on the basis of theexceedances of the dissolved oxygen limits at Point 1 and the TSS exceedance onthe 25.03.17 which did not appear to be caused by a significant rainfall event.(refer to L2.5 below). Condition L2.5 also discusses what practical measures wereimplemented to minimise and avoid water pollution.

POINT 1

Pollutant Units of Measure 100 percentile concentration limit

Conductivity Microsiemens percentimetre

1500

Dissolved oxygen Milligrams per litre 6

Nitrogen (ammonia) Milligrams per litre 2.5

pH pH 5.5 - 8.5

Phenol milligrams per litre 0.32

TSS milligrams per litre 50

POINT 20,21,22


Nitrogen (ammonia) milligrams per litre 2.5




49

Reference Condition/Requirement Compliance Status Comment RecommendationsEPL 5065,

M1.3

The following records must be kept in respect of any samples required to becollected for the purposes of this licence:

a) the date(s) on which the sample was taken;b) the time(s) at which the sample was collected;c) the point at which the sample was taken; andd) the name of the person who collected the sample.

Administrativenon-compliance

CES Quarterly/Annual Groundwater, Surface water and Leachate monitoring

The field data sheets are included as an attachment to the quarterly CES reports.The auditors reviewed a sample of these data sheets are found the groundwaterdata sheets included the date, time, monitoring point ID and the initials of thepeople who completed the sampling. The surface water data sheets did not alwaysinclude the time of sampling.

Gas monitoring

The surface gas monitoring results provided as excel worksheets and included thedate, time and GPS coordinates of the monitoring point. Two of the four datasheets included the name of the person sampling.

The subsurface monitoring results included the point at which the sample wastaken and the date range for March and June, and the ‘Sampling Date’ forSeptember and December. The time the sample was collected and name of theperson who collected the sample was not included.

Gas accumulation monitoring results are provided as excel worksheets andinclude the date, location and name of person undertaking the sampling. The timeof sample was not recorded.

Wet weather monitoring

SUEZ reported that a field datasheet is not completed during wet weathersampling when undertaken in-house by SUEZ. Some sampling information wasrecorded on the sample bottle and Chain of Custody provided to the laboratory,which is then recorded in the final laboratory reports. Laboratory reports forsampling at MC1 were reviewed by the auditors.

As all of the required information (e.g. time and name of sampler) is not alwaysrecorded, this condition has been assessed as an Administrative non-compliance.

2018-IEA-REC20:

Ensure all of the requiredinformation (e.g. time andname of person whocollected the sample) isrecorded for monitoringrequired by the EPL, inparticular for wet weathersampling undertaken inhouse.

EPL 5065,

M2.3

Water and/or Land Monitoring RequirementsPOINT 1

Pollutant Units of measure Frequency SamplingMethod

Conductivity microsiemens percentimeter

Special Frequency 1 Probe

Dissolved Oxygen milligrams per litre Special Frequency 1 Grab sampleNitrogen(ammonia)

milligrams per litre Special Frequency 1 Grab sample

pH pH Special Frequency 1 Grab samplePotassium milligrams per litre Special Frequency 1 Grab sampleTotal dissolvedsolids


Total organicscarbon


Total Phenolics milligrams per litre Special Frequency 1 Grab sampleTotal SuspendedSolids


POINT 3,40


Alkalinity (as calciumcarbonate)

milligrams per litre Yearly Grab sample

Aluminium milligrams per litre Yearly Grab sampleArsenic milligrams per litre Yearly Grab sample

Non-compliant This condition was varied on 7.12.17 as part of a licence variation. The mainchanges in the variation include:

· Addition of new monitoring points, highlighted in blue text;

· Addition of new ‘pollutants’ to monitor at respective monitoring points,highlighted in blue text;

· Change to monitoring frequency from quarterly to yearly and visa versa; and

· Removing the requirement to monitoring turbidity at Point 1.

Monitoring of surface water, groundwater and leachate was undertaken under therequirements of the previous EPL (dated 17.07.17), therefore this condition hasbeen reviewed against the requirements in EPL 5065 (dated 17.07.17)

Quarterly sampling of surface water, groundwater and leachate during the auditperiod was undertaken in January, April, September and December. A summaryis provided below.

2018-IEA-REC21:

Include failures toundertake monitoring inaccordance with thefrequency specified in theEPL within the AnnualReturn.



50

Reference Condition/Requirement Compliance Status Comment RecommendationsBarium milligrams per litre Yearly Grab sampleBenzene milligrams per litre Yearly Grab sampleBenzo(a)pyrene milligrams per litre Yearly Grab sampleBicarbonate alkalinity milligrams per litre Yearly Grab sampleBOD milligrams per litre Yearly Grab sample

Cadmium milligrams per litre Yearly Grab sampleCalcium milligrams per litre Yearly Grab sampleChemical oxygendemand


Chloride milligrams per litre Yearly Grab sampleChromium(hexavalent) milligrams per litre Yearly Grab sampleChromium (total) milligrams per litre Yearly Grab sampleCobalt milligrams per litre Yearly Grab sampleConductivity microsiemens per

centimeterQuarterly Probe

Copper milligrams per litre Yearly Grab sampleEthyl benzene milligrams per litre Yearly Grab sampleFluoride milligrams per litre Yearly Grab sampleLead milligrams per litre Yearly Grab sampleMagnesium milligrams per litre Yearly Grab sampleManganese milligrams per litre Yearly Grab sampleMecury milligrams per litre Yearly Grab sampleNickel milligrams per litre Yearly Grab sampleNitrate milligrams per litre Yearly Grab sampleNitrite milligrams per litre Yearly Grab sampleNitrogen (ammonia) milligrams per litre Yearly Grab sampleOrganochlorinepesticides


Organophosphatepesticides


pH pH Quarterly ProbePhosphorus milligrams per litre Yearly Grab samplePolycyclic aromatichydrocarbons


Potassium milligrams per litre Yearly Grab sampleSodium milligrams per litre Yearly Grab sampleSulfate milligrams per litre Yearly Grab sampleToluene milligrams per litre Yearly Grab sampleTotal dissolved solids milligrams per litre Yearly Grab sampleTotal organic carbon milligrams per litre Yearly Grab sampleTotal petroleumhydrocarbons


Total Phenolics milligrams per litre Yearly Grab sampleTotal suspended solids milligrams per litre Yearly Grab sampleXylene milligrams per litre Yearly Grab sampleZinc milligrams per litre Yearly Grab sample

POINT 4,7,8,16,17,18,19,24,25,26,27,44,45,46,47,48,49,50



milligrams perlitre

Quarterly Grab sample

Aluminium milligrams perlitre

Yearly Grab sample

Arsenic milligrams perlitre

Yearly Grab sample

EPAPoint

Type &location

Frequency Parameters Comments

Groundwater quality

4, 7,8, 16,17,18,19,24,25,26,27

MB008,MB032,MB034,MB305,MB306,MB033,MB035,MB038,MB039,MB040,MB041

Quarterly Alkalinity,Benzo(a)pyrene,calcium, chloride,magnesium,ammonia, pH,PAH, potassium,sodium, standingwater level, sulfate,TDS, total organiccarbon, TPH

Conducted by CES.

Review of CESquarterly monitoringreports (Mar, Jun,Sept and Dec)indicated thismonitoring wasundertaken.

Annually Various otherparameters

EPAPoint

Type &location


Leachate

3 Leachatequalityfromleachatedam –LD001

Quarterly Benzo(a)pyrene,conductivity,Polycyclicaromatichydrocarbons,TPH

Conducted by CES.

Review of CES quarterlymonitoring reports (Mar,Jun, Sept and Dec)indicated this monitoringwas undertaken.


40 Leachatequalityfromleachatedam LH1- LD002


Review of CES quarterlymonitoring reports (Mar,Jun, Sept and Dec)shows:

- quarterly sampling ofBenzo(a)pyrene, TPHwas not undertaken.

- yearly sampling of 18analytes was notundertaken (reportedas Not Tested in thesampling results).




51

Reference Condition/Requirement Compliance Status Comment RecommendationsBarium milligrams per

litreYearly Grab sample

Benzene milligrams perlitre

Yearly Grab sample

Benzo(a)pyrene milligrams perlitre

Yearly Grab sample

Bicarbonate alkalinity milligrams perlitre


Cadmium milligrams perlitre

Yearly Grab sample

Calcium milligrams perlitre


Chloride milligrams perlitre


Chromium(hexavalent) milligrams perlitre

Yearly Grab sample

Chromium (total) milligrams perlitre

Yearly Grab sample

Cobalt milligrams perlitre

Yearly Grab sample

Copper milligrams perlitre

Yearly Grab sample

Ethyl benzene milligrams perlitre

Yearly Grab sample

Fluoride milligrams perlitre

Yearly Grab sample

Lead milligrams perlitre

Yearly Grab sample

Magnesium milligrams perlitre


Manganese milligrams perlitre

Yearly Grab sample

Mecury milligrams perlitre

Yearly Grab sample

Nickel milligrams perlitre

Yearly Grab sample

Nitrate milligrams perlitre


Nitrite milligrams perlitre


Nitrogen (ammonia) milligrams perlitre


Organochlorinepesticides

milligrams perlitre

Yearly Grab sample


milligrams perlitre

Yearly Grab sample

PCBs milligrams perlitre

Yearly Grab sample

pH pH Quarterly ProbePhosphorus milligrams per

litreQuarterly Grab sample

Polycyclic aromatichydrocarbons

milligrams perlitre

Yearly Grab sample

Potassium milligrams perlitre


Redox potential Millivolts Quarterly Grab sampleSelenium milligrams per

litreYearly Grab sample

EPAPoint

Type &location


Surface water

1 Dischargeto watersoverflowqualitymonitoring– MC1

Within 24hours ofdischarge

Conductivity,DO,Ammonia,pH, Phenol,TSS,Turbidity

SUEZ conduct wetweather monitoring.Monitoring wasundertaken on 31occasions during theaudit period*. On 10 ofthese occasionsturbidity was nottested.

20 PumpeddischargefromSedimentDam 5 –DS002

Weeklyduringdischarge

Ammonia,TSS

SUEZ reported nodischarges during theaudit period.

21 Pumpeddischargefromstormwatertreatmentplant –DS001


Ammonia,TSS

Review of Eurofinslaboratory reports (25sampling event reports)indicated this monitoringwas undertaken.

22 OverflowfromSedimentDam 5 –OF001


Ammonia,TSS

Review of Eurofinslaboratory reports (fivesampling event reports)indicated this monitoringwas undertaken.

23 SedimentDam 5 –SD005

Quarterly Ammonia,TSS

Conducted by CES.Review of CES quarterlymonitoring reports (Mar,Jun, Sept and Dec)indicated this monitoringwas undertaken.

*As discussed under SSD6835 Condition C30, based on correspondence with theEPA it is noted that monitoring of Point 1 was not undertaken on the 4.03.17(Saturday) and 5.03.17 (Sunday) during an overflow event at Sediment Dam 5 asrequired by this condition. This was not reported as a non-compliance with EPL5065 in the Annual Return.

This condition has been assessed as not-compliant based on the following:

· Monitoring not being undertaken at Point 1 during discharge from SedimentDam 5 on 4.03.17 and 5.03.17.

· Turbidity was not measured on 10 occasions for Point 1. It is noted thatturbidity monitoring is no longer required.

· Quarterly sampling of Benzo(a)pyrene and TPH was not undertaken at Point40. It is noted that monitoring of Benzo(a)pyrene and TPH is now requiredyearly.

· Yearly sampling of 18 analytes was not undertaken at Point 40.



52

Reference Condition/Requirement Compliance Status Comment RecommendationsSodium milligrams per


Standing Water Level metres Quarterly In situSulfate milligrams per


Temperature Degrees Celsius Quarterly ProbeTetrachloroethane(tetrachloroethylene)

milligrams perlitre

Yearly Grab sample

Toluene milligrams perlitre

Yearly Grab sample

Total dissolved solids milligrams perlitre


Total organic carbon milligrams perlitre


Total petroleumhydrocarbons

milligrams perlitre

Yearly Grab sample

Total Phenolics milligrams perlitre

Yearly Grab sample

Trichloroethylene milligrams perlitre

Yearly Grab sample

Xylene milligrams perlitre

Yearly Grab sample

Zinc milligrams perlitre

Yearly Grab sample

POINT 20,21


Nitrogen(ammonia) milligrams per litre SpecialFrequency 2

Grab sample

Total suspendedsolids

milligrams per litre SpecialFrequency 2

Grab sample

POINT 22



Grab sample



Grab sample

POINT 23


Nitrogen(ammonia) milligrams per litre Quarterly Grab sample


milligrams per litre Quarterly Grab sample



53

Reference Condition/Requirement Compliance Status Comment RecommendationsEPL 5065,

M8.1

Requirement to Monitor Landfill Gas

The licensee must undertake quarterly surface landfill gas monitoring inaccordance with the document titled “Landfill Surface Gas MonitoringProgramme, Lucas Heights Waste and Recycling Centre” prepared by WSNEnvironmental Solutions and dated February 2006.

If the results of the monitoring indicate the presence of methane in excess of500 ppm on the surface of the capped areas, the licensee must:

a) notify the EPA within 24 hours; andb) submit to the EPA a proposed program to control these emissions.The above quarterly surface landfill gas monitoring must be submitted to theEPA annually, accompanying the Annual Return.

Non-compliant The auditors reviewed the surface gas monitoring results provided by SUEZ asexcel files. The results identified the following:

· 21.04.17 - A total of 100 samples were taken and the maximum methanelevel recorded was 251.2 ppm


· 12.09.17 - A total of 309 samples were taken and the maximum methanelevel recorded was 454.7.4 ppm


No exceedances of the 500 ppm for methane were noted. The timing of monitoringhas not been completed every three months, but instead four times within thecalendar year. Monitoring data for September was not published on the website atthe time of the audit.As per the 2015 IEA (2015-IEA-REC24) it was noted that the quarterly surfacelandfill gas monitoring was not attached the Annual Return for EPL 5065.This condition has been assessed at not compliant as monitoring is not beingundertaken quarterly and surface landfill gas monitoring was not attached to theAnnual Return 5065.

2018-IEA-REC23:

Submit quarterly surfaceand gas accumulationmonitoring reports as anattachment to eachAnnual Return.

2018-IEA-REC24:

Conduct surface gasmonitoring every 3months.

2018-IEA-OPI16:

Publish all monitoringdata required to beundertaken under EPL5065 on the LucasHeights LHRRP websitewithin 14 days ofreceiving the results.

EPL 5065,

M8.2

The licensee must undertake quarterly landfill gas accumulation monitoring inaccordance with the document titled “Proposed Landfill Subsurface Gas andAccumulation Monitoring Program, Lucas Heights Waste and RecyclingCentre” prepared by WSN Environmental Solutions and dated March 2006.

If the results of the monitoring indicate the presence of methane in excess of 1% (v/v), the licensee must:

a) notify the EPA within 24 hours; andb) submit to the EPA a proposed program to control these emissions.The above quarterly landfill gas accumulation monitoring must be submitted tothe EPA annually, accompanying the Annual Return.

Non-compliant This condition was revised on 7.12.17 as part of the licence variation. Prior to therevision the condition stated that “if the results of monitoring indicate the presenceof methane in excess of 1.25% (v/)…”. Therefore this condition has beenassessed in the following way:

· 23.01.17 – 6.12.17 – 1.25% (v/v)

· 7.12.17 to 23.01.18 – 1% (v/v)

Monitoring completed between the 23.1.17 to 6.12.17

Sub-Surface Gas Monitoring

Four exceedances of the methane presence of 1.25% (v/v) were recorded atmonitoring point 29 (MB037) during the audit period:

· 14/15 March 2017 – 14.5% (reported in the Annual Return)

· 7 June 2017 – 10.5% (reported in the Annual Return)

· 20 and 25 September 2017 – 5.3%

· 6 December 2017 – 9.7%

The Annual Return states that two additional bores were installed on the 14 May2017 and Gasglams were installed on continuous monitoring on MB036 andMB037.

SUEZ notified the EPA in a letter dated 13.03.17 of the March 2017 monitoringresults at EPL Point 29 (MB037) which recorded initial methane concentration of3.3% v/v and 14.5% v/v after the well was put under vacuum. The letter does notidentify the date sampling was recorded, or a proposed plan to control emissions.

SUEZ reported that the EPA was not notified of the exceedances of methaneconcentrations in June, September and December 2017.

Gas Accumulation Monitoring

Gas accumulation monitoring results were reviewed for the 21.04.17, 16.08.17 and21.11.17. No exceedances of the 1.25% (v/) were identified. It is noted thatsampling was not undertaken quarterly as required by this condition.

As per condition M8.1

2018-IEA-REC25:

Ensure all exceedancesof methane levels arereported to the EPA withthe required information.

2018-IEA-OFI17:

Include exceedances ofEPL limits in the incidentsregister, for example sub-surface gas methanelevels to ensure that theEPA is notified and theappropriate actions aretaken to control theexceedance.



54

Reference Condition/Requirement Compliance Status Comment Recommendations7.12.17 to 23.01.18

No subsurface gas or accumulation monitoring was undertaken between 7.12.17to 23.01.18.

The auditors noted that the Proposed Landfill Subsurface Gas and AccumulationMonitoring Program was last updated in July 2015, therefore had not beenupdated with the new trigger level on 1% (v/v) as per this condition. It is noted thatCondition M8.3 and M8.4 require the Site to prepare and submit to the EPA a DraftLandfill Sub-Surface Gas Monitoring Programme for the premises by 31 March2018.

As per the 2015 IEA (2015-IEA-REC24) it was noted that the quarterly landfill gasaccumulation monitoring was not attached to the Annual Return for EPL 5065.

This condition has been assessed as not compliant for the following reasons:

· SUEZ did not report the exceedance of methane concentrations in June,September and December 2017 to the EPA;

· Quarterly landfill gas accumulation monitoring was not attached the AnnualReturn for EPL 5065.

· Gas accumulation monitoring was not undertaken quarterly.

EPL 5065,

R1.5

The Annual Return for the reporting period must be supplied to the EPA viaeConnect EPA or by registered post not later than 60 days after the end ofeach reporting period or in the case of a transferring licence not later than 60days after the date the transfer was granted (the 'due date').


The Annual Return (21.08.16-20.08.17) was required to be submitted to the EPAbefore 20.10.17.

The auditors reviewed the EPA POEO Public Register which identified that theannual return was submitted on the 20.10.17.

This condition was found to be an administrative non-compliance as the annualreturn was submitted 61 days following the reporting period.

EPL 5065,

R2.2

The licensee must provide written details of the notification to the EPA within 7days of the date on which the incident occurred.

Note: The licensee or its employees must notify all relevant authorities ofincidents causing or threatening material harm to the environment immediatelyafter the person becomes aware of the incident in accordance with therequirements of Part 5.7 of the Act.


The LHRRP reported two fires to the EPA in accordance with this condition.As identified in Condition R4.1 written notification of the small fire on the 5.5.17was provided to the EPA in an email dated 15.05.17, which is 10 days after thedate of the incident, therefore this condition has been assessed as anadministrative non-compliance.

EPL12520,A1.1

This licence authorises the carrying out of the scheduled activities listed belowat the premises specified in A2. The activities are listed according to theirscheduled activity classification, fee-based activity classification and the scaleof the operation.

Unless otherwise further restricted by a condition of this licence, the scale atwhich the activity is carried out must not exceed the maximum scale specifiedin this condition.

Scheduled Activity Fee Based Activity Scale

Composting Composting >500 - 50000 T annualcapacity to receiveorganics


Non-thermal treatment ofgeneral waste

Any annual processingcapacity

Non-compliant SUEZ provided a Mandalay report from the Site’s weighbridge for the period from01.01.17 to 31.12.17. The weighbridge report showed that 54,350.29 tonnes ofgreen waste was received at the Site.

SUEZ reported in the 2016/17 Annual Return a non-compliance with conditionA1.1. Where the Site exceeded the maximum of 50,000 tonnes of green wastereceived at site per reporting year by 8,053 tonnes. SUEZ reported in the AnnualReturn that additional tonnes were a result of fulfilling existing council contracts forgreenwaste collection and that no new contracts had been taken on.



55

Reference Condition/Requirement Compliance Status Comment RecommendationsEPL12520,L2.1

Waste

The licensee must not cause, permit or allow any waste to be received at thepremises, except the wastes expressly referred to in the column titled “Waste”and meeting the definition, if any, in the column titled “Description” in the tablebelow. Any waste received at the premises must only be used for the activitiesreferred to in relation to that waste in the column titled “Activity” in the tablebelow. Any waste received at the premises is subject to those limits orconditions, if any, referred to in relation to that waste contained in the columntitled “Other Limits” in the table below. This condition does not limit any otherconditions in this licence.

Code Waste Description Activity Other Limits

NA Excavatednaturalmaterial

Waste that meetsall the conditionsof the excavatednatural materialorder 2014

Wasteprocessing(non-thermaltreatment)

Only excavated natural materialthat meets the excavated naturalmaterial order 2014 can beblended with pastuerised gardenorganics that meets thepasteurised garden organicsorder 2016

NA Woodwaste

As defined inSchedule 1 ofthe POEO Act,as in force fromtime to time

Composting The maximum quantity of woodwaste and garden wastecombined, for storage,processing or recovery at thepremises must not exceed125,000 m3 or 50,000 tonnes(based on a density rate of 0.4)onsite / year. The maximumquantity of garden waste andwood waste combined, whetherprocessed or unprocessed, mustnot exceed 45,000 cubic metresor 18,000 tonnes (based on adensity rate of 0.4) onsite at anyone time.

NA Gardenwaste


Composting The maximum quantity of woodwaste and garden wastecombined, for storage,processing or recovery at thepremises must not exceed125,000 m3 or 50,000 tonnes(based on a density rate of 0.4)onsite / year. The maximumquantity of garden waste andwood waste combined, whetherprocessed or unprocessed, mustnot exceed 45,000 m3 or 18,000tonnes (based on a density rateof 0.4) onsite at any one time.

NA Virginexcavatednaturalmaterial

As defined inSchedule 1 ofthe POEO Act,as in force fromtime to time.

Composting NA

NA Manure Composting NA

NA Fly ash Composting NA

Non-compliant SUEZ provided the Auditors with a data extract from the Mandalay system (whichrecords weighbridge data). The report was run from the 01.01.17 to 31.12.17.

Based on this report the Site received the following through the weighbridge:

· 54,350.29 tonnes of green waste.

· 510.22 tonnes of manure

· 84.50 tonnes of ash

· 629.34 tonnes of unpasteurised blending material (horse manure)

· 38,493.19 tonnes of inorganic blending material (sand)

As per condition L1.1, this condition has been assessed as not compliant as morethan 50,000 tonnes of green waste was accepted on site.

SUEZ provided the auditors with a ‘Resource Recovery Characterisation’certificate, prepared by DLA Environmental Services, dated 24.03.17 (expiry24.04.17) classifying approximately 27,000 tonnes of sand material as VEMN.

To monitor the quantity of wood and garden waste stored on site at any one timethe SUEZ quality assurance personnel conduct monthly stocktakes using a GPSsystem. SUEZ provided the auditors with a sample of monthly stocktake reportsfor the ‘bottom’ and ‘top’ stockpile pads.

Based on a review of the three months of stocktake reports the volume ofprocessed and unprocessed wood and garden waste did not exceeded the limit inthis condition, as shown below:

· February – 43,510 m2

· June – 44,024 m2

· December – 32,446 m2

This condition has been assessed as non-compliant as the volume of gardenwaste received on site exceeded the 50,000 tonnes on site per year limit.

Refer to EPL 12520Condition A1.1



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Reference Condition/Requirement Compliance Status Comment RecommendationsEPL12520,M1.3

The following records must be kept in respect of any samples required to becollected for the purposes of this licence:



The surface gas monitoring excel data sheets were provided to the auditors.These excel records included the date, time and sample point number (with GPSreference coordinates. The person who undertook the sampling was not includedin the April and August sampling records. The November Sampling record layoutshould be used by SUEZ for future monitoring rounds to ensure compliance withthis condition.

2018-IEA-REC26:

Include the name of theperson who conductedthe surface gasmonitoring in the exceldata sheets.

EPL12520,M2.1/M2.2

Requirement to monitor concentration of pollutants discharged

For each monitoring/discharge point or utilisation area specified below (by apoint number), the licensee must monitor (by sampling and obtaining results byanalysis) the concentration of each pollutant specified in Column 1. Thelicensee must use the sampling method, units of measure, and sample at thefrequency, specified opposite in the other columns:

Air Monitoring RequirementsPOINT 1

Pollutant Units of measure Frequency Sampling method

Methane parts per million Quarterly Special Method 1

Non-compliant During the audit period monitoring of methane at surface gas monitoring pointswas undertaken on the 21.04.17, 16.08.17 and 21.11.17.

Monitoring was not undertaken quarterly therefore this condition has beenassessed as not compliant.

It was noted that ‘Special Method 1’ is not defined in the EPL. EPL 5065 definesSpecial Method 1 for methane monitoring as in accordance with the methodsoutlined in Chapter 5.3 Landfill gas sub-surface monitoring of EnvironmentalGuidelines: Solid Waste Landfills (NSW EPA, Second Edition, September 2016)and it is assumed it would have the same meaning for EPL 12520.

SUEZ should seek to have Special Method 1 defined in the next licence variation.

2018-IEA-OFI18:

Include the definition of‘Special Method in thenext licence variation ofEPL 12520.

EPL13114,M2.1/ M2.2


For each monitoring/discharge point or utilisation area specified below (by apoint number), the licensee must monitor (by sampling and obtaining results byanalysis) the concentration of each pollutant specified in Column 1. Thelicensee must use the sampling method, units of measure, and sample at thefrequency, specified opposite in the other columns:

Water and/ or Land Monitoring Requirements

POINT 1

Pollutant Units of measure Frequency Sampling Method

Ammonia milligrams perlitre

Every 6 months Grab sample

pH pH Every 6 months Probe


milligrams perlitre

Every 6 months Grab sample

Non-compliant SUEZ published monitoring data for Point 1 on the Lucas Heights website. SUEZprovided the laboratory reports for monitoring of Point 1 (PCYC Dam) undertakenon the 12.01.17 and 30.08.17. The monitoring recorded the following results:

· pH was between 7 and 7.7 pH which is in the normal range for surface water.

· Ammonia ranged from <0.01 to 0.75 mg/L.

· Suspended solids ranged from 7.6 to 21 mg/L.

EPL 13114 Annual Return (09.06.16 to 08.06.17) identifies that 14 samples weretaken over the annual return reporting period.

SUEZ also undertook monthly field sampling of Point 1 for water level,temperature, conductivity, pH, dissolved oxygen and turbidity..

This condition has been assessed as not compliant as sampling has not beenundertaken within a six month period for the analytes required under this condition

2018-IEA-REC28:

Conduct surface watermonitoring at Point 1every 6 months foranalytes required underEPL 13114, conditionM2.2.



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8.3 Summary of opportunities for improvementThe following table has been reproduced from this report and Appendix A. For details on therequirement, and for further discussion of the issue, please refer directly to the tables in Appendix A.Many recommendations are based around continuous improvement opportunities identified during theaudit and do not necessarily represent immediate potential non-compliance issues.Table 8-3 Recommendations for Conditions considered compliant for improved compliance or continuous

improvement

Reference # Opportunity for Improvement

Air Quality and OdourManagement Plan

2018-IEA-OFI01 Update Section 11 to include a reference to SSD 6835,Condition D8 which includes a number of triggers forupdating the strategies, plans and programs requiredunder SSD 6835.

GroundwaterManagement Plan

2018-IEA-OFI02 1. Where the requirement to prepare the GMP isprovided (Section 1.1) include reference to where inthe GMP each requirement has been addressed.

2. Include reference to the SSD 6835, Condition D8which includes a number of triggers for updating thestrategies, plans and programs required under SSD6835.

SSD 6835, C5 2018-IEA-OFI03 Add the requirement to maintain 300 mm cover to theLandfill Daily Checklist. Add confirmation box to recordthat it has been done. Include an electronic signature onchecklists completed in soft-copy.

SSD 6835, C8 2018-IEA-OFI04 Consider changing the daily odour audit procedure to beundertaken at different times throughout the day

SSD 6835, C23 2018-IEA-OFI05 Include a revision table within the CEMP to identify whoprepared the CEMP and that the EPA has reviewed andapproved the plan.

SSD 6835, C31 2018-IEA-OFI06 Update the GO OEMP to include discussion of thedischarge or disposal of greenwaste liquor from thegreenwaste dam and the requirement that it betransported off-site and disposed of lawfully or dischargedto sewer in accordance with a Trade Waste Agreement.

SSD 6835, C37 2018-IEA-OFI07 Management of chemicals, fuels and oils at the workshopis not currently detailed in the OEMP. SUEZ shouldupdate the OEMP to include a description of theworkshop area, Select Civils role and responsibilities andoverview of works undertaken and controls implemented.

SSD 6835, C57 2018-IEA-OFI08 Check that the weekly checklist includes inspecting theTPA for litter and stormwater infrastructure and update ifrequired.

SSD 6835, C63 2018-IEA-OFI09 Update the Evacuation Diagram within the ERP to includethe entire site and detail alternative access / egressroutes from the landfill and existing GO facility.

SSD 6835, D4 2018-IEA-OFI10 There is an opportunity for the OEMP to capture therequirements of the PCYC EPL to ensure therequirements of the EPL are not missed.

SSD 6835, D14 2018-IEA-OFI11 Ensure the Appendices to the Meeting Minutes (whichincludes the environmental update) are uploaded to theSUEZ website.



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Reference # Opportunity for Improvement

EPL 5065, P1.1 2018-IEA-OFI12 Update the OEMP to include the most recent variation toEPL 5065.

EPL 5065, O5.3 2018-IEA-OFI13 Encourage whenever possible for the public to separaterecyclables from the general waste stream and dispose ofrecyclable materials in the appropriate area at the publicdrop-off.

EPL 5065, O5.7 2018-IEA-OFI14 Revise the OEMP to specifically refer to the application ofVENM as daily and intermediate cover

EPL 5065, O5.13 2018-IEA-OFI15 Consult with the EPA on the relevance of this Conditionand potentially remove or amend to refer to a more recentSUEZ document.

EPL 5065, M8.1 2018-IEA-OFI16 Publish all monitoring data required to be undertakenunder EPL 5065 on the Lucas Heights LHRRP websitewithin 14 days of receiving the results.

EPL 5065, M8.2 2018-IEA-OFI17 Include exceedances of EPL limits in the incidentsregister, for example sub-surface gas methane levels toensure that the EPA is notified and the appropriateactions are taken to control the exceedance.

EPL 12520, M2.1 /M2.2

2018-IEA-OFI18 Include the definition of ‘Special Method in the nextlicence variation of EPL 12520.

EPL 12520, E1.1 2018-IEA-OFI19 Update the GO EMP to include fire prevention measuresand fire-fighting procedures as required by the EPAEnvironmental Guidelines: Composting and RelatedOrganics Processing Facilities Guidelines (July 2004) andalso to reference the requirements of the PasteurisedGarden Organics Order 2016.

EPL 13114, O3.1 2018-IEA-OFI20 Include measures to minimise the emission of dust fromthe PCYC minibike club in the OEMP

Appendix B 2015 IEA 2018-IEA-OFI21 Incorporate noise monitoring requirements in EPL 13114within the annual noise monitoring completed under SSD6835.



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9.0 LimitationsAECOM Australia Pty Limited (AECOM) has prepared this report in accordance with the usual careand thoroughness of the consulting profession for the use of SUEZ Recycling and Recovery Pty Ltdand only those third parties who have been authorised in writing by AECOM to rely on this Report.

It is based on generally accepted practices and standards at the time it was prepared. No otherwarranty, expressed or implied, is made as to the professional advice included in this Report.

It is prepared in accordance with the scope of work outlined in our proposal dated 10 October 2017.

Where this Report indicates that information has been provided to AECOM by third parties, AECOMhas made no independent verification of this information except as expressly stated in the Report.AECOM assumes no liability for any inaccuracies in or omissions to that information.

This Report was prepared between January 2018 and April 2018 and is based on the conditionsencountered and information reviewed at the time of preparation. AECOM disclaims responsibility forany changes that may have occurred after this time.

This Report should be read in full. No responsibility is accepted for use of any part of this report in anyother context or for any other purpose or by third parties. This Report does not purport to give legaladvice. Legal advice can only be given by qualified legal practitioners.

Except as required by law, no third party may use or rely on this Report unless otherwise agreed byAECOM in writing. Where such agreement is provided, AECOM will provide a letter of reliance to theagreed third party in the form required by AECOM.

To the extent permitted by law, AECOM expressly disclaims and excludes liability for any loss,damage, cost or expenses suffered by any third party relating to or resulting from the use of, orreliance on, any information contained in this Report. AECOM does not admit that any action, liabilityor claim may exist or be available to any third party.

Except as specifically stated in this section, AECOM does not authorise the use of this Report by anythird party.

It is the responsibility of third parties to independently make inquiries or seek advice in relation to theirparticular requirements and proposed use of the site.

Any estimates of potential costs which have been provided are presented as estimates only as at thedate of the Report. Any cost estimates that have been provided may therefore vary from actual costsat the time of expenditure.



A

Appendix A Compliance Tables

Appendix A - Audit Checklist/Protocol-Lucas Heights Resource Recovery ParkRevision Final 20 April 2018

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Appendix A - Audit Checklist/Protocol-Lucas Heights Resource Recovery Park

1.1 SSD 6835Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsOBLIGATION TO MINIMISE HARM TO THE ENVIRONMENTB1 In addition to meeting the specific performance criteria established under this

consent, the Applicant shall implement all reasonable and feasible measures toprevent and/or minimise any harm to the environment that may result from theDevelopment.

Compliant Other than where issues have been identified, in general SUEZ appeared tobe compliant with its obligation to minimise harm to the environment.

Environmental management plans and procedures have been establishedand generally implemented to identify, plan for and manage environmentalaspects and impacts related to the LHRRP.

No incidents with the potential to cause harm to the environment (other thana number of small fires – discussed under the EPLs) were recorded duringthe audit period.

TERMS OF CONSENTB2 The Applicant shall carry out the Development in accordance with the:

(a) EIS and RTS;(b) Development plans and drawings in the EIS and RTS (see Appendix A);(c) the Management and Mitigation Measures (see Appendix B); and(d) the draft Landfill, GO, ARRT and Post Closure Environmental ManagementPlans included in the EIS.

Compliant (a) A detailed assessment of compliance with the EIS and RTS was notundertaken. Based on a high level review, the following are noted:· The new GO facility and ARRT described in the EIS were yet to be

constructed at the time of the audit and as such the environmentalbenefits from these facilities were not being realised. SUEZ reportedthat it was still in the design stage for these works.

· Re-profiling of the landfilling in Area D had commenced (Phase 2 inEIS staging plan) and appeared to be carried out generally inaccordance with the EIS.

· SUEZ reported that it was in the process of designing a new 5 MLsediment dam to capture sediment from the Stage 5-3 area. Thissediment dam was not specifically described in the EIS however wasdiscussed more broadly in Section 13.4 of the EIS as a managementand mitigation measure to “design and operate sediment dams andtraps to promote sedimentation”

(b) The phasing plan from the EIS was provided to the landfill contractor,Select Civil, to develop the more detailed fill platform drawings (inconsultation with SUEZ). Whilst the sequencing has changed from thatproposed in the EIS for operational reasons relating to managing gas,leachate and surface water, the overall footprint remains the same.

(c) The Management and Mitigation Measures included in Appendix B havebeen included in the appropriate management plans. A review of themanagement plans and their implementation is provided under thespecific conditions relating to the plans

(d) As discussed the GO and ARRT were yet to be constructed.B3 If there is any inconsistency between the plans and documentation referred to in

Condition B2 above, the most recent document shall prevail to the extent of theinconsistency. However, the conditions of this consent shall prevail to the extentof any inconsistency.

Not triggered Not triggered

B4 The Applicant shall comply with any reasonable requirement(s) of the Secretaryarising from the Department's assessment of:(a) any reports, plans or correspondences that are submitted in accordance withthis consent; and(b) the implementation of any actions or measures contained in thesedocuments.

Noted The preparation, including consultation with DPE required for eachenvironmental management plan and implementation is discussed againstthe relevant consent condition.

LIMITS OF CONSENTB5 This consent lapses five years after the date from which it operates, unless the

Development has physically commenced on the land to which the consentapplies before the date on which the consent would otherwise lapse underSection 95 of the EP&A Act.

Compliant Noted.SUEZ commenced re-profiling in January 2018. No work has commenced forthe construction of the GO and ARRT facilities.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsB6 The Applicant shall not receive more than:

(a) 850,000 tonnes of general solid waste (putrescible and non-putrescible) andasbestos waste per year on site for landfill disposal;(b) 10,000 tonnes of general solid waste (non-putrescible) and batteries per yearon site at the Resource Recovery Centre and waste collection point;(c) 80,000 tonnes of garden and wood waste per year and 2,000 tonnes ofmanure at the GO Facility;(d) 200,000 tonnes of general solid waste (putrescible and non-putrescible) peryear including 10,000 tonnes of biosolids at the ARRT Facility; and(e) the quantity of waste required to meet the final landform profile described inthe EIS.

Compliant SUEZ provided the auditors with a report for the date range 1.01.17 to31.12.17, extracted from the Mandalay reporting system which is used torecord waste into and out of the LHRRP through the weighbridge.a) In 2017 the LHRRP received and landfilled 631,721.06 tonnes of

general solid waste (putrescible and non-putrescible) and asbestoswaste.

b) The Mandalay Weighbridge report for the 2017 calendar year showedthat less than 10,000 tonnes of general solid waste, including mixedwaste, recyclables and green waste) was accepted by “small vehicles”.SUEZ reported that batteries are captured under the “mixed recyclingsmall vehicles” weighbridge category.

c) Not triggered. The GO Facility to which this condition relates had notbeen constructed during the audit period. The existing GO facility isallowed to receive up to 50,000 tonnes of organics under EPL 12520,refer to EPL 12520, Condition A1.1 for further detail.

d) Not triggered during the audit period. The ARRT facility to which thiscondition relates had not been constructed during the audit period.

e) Not triggered during the audit period.B7 The receipt, processing and disposal of waste at the landfill, GO and ARRT

facilities shall cease at the end of 2037.Not triggered Not triggered.

OTHER CONSENT AND APPROVALSB8 Within 6 months of the date of this consent, the Applicant shall modify DA 11-01-

99 to remove the conditions of that consent that relate to the LHRRP. Themodification shall be in accordance with the Environmental Planning andAssessment Regulation, 2000. The modification is required to ensure allactivities undertaken at the LHRRP are covered by this consent only.


An Application to Modify DA 11-01-99 was submitted to the DPE on the13.09.17. As part of the process, SUEZ conducted a review of all of theconditions of consent for DA 11-01-99 and identified those conditions thatshould be removed or modified.As Sutherland Shire Council (SSC) was a co-applicant for DA-11-01-99 itsstaff were involved in the review.A letter was sighted from the EPA to the DPE (dated 11.10.17) stating thatthe EPA had no comments or objections to the modification.A letter was sighted from RMS dated 9.10.17 stating that RMS had noobjections.At the time of the audit, the Modification was yet to be approved by the DPEas SUEZ was yet to receive land owner consent from ANSTO.The application was not submitted within 6 months of the date of the consentand on this basis, has been assessed as an administrative non-compliance.

STATUTORY REQUIREMENTSB9 The Applicant shall ensure that all licences, permits and approval/consents are

obtained as required by law and maintained as required throughout the life of theDevelopment. No condition of this consent removes the obligation for theApplicant to obtain, renew or comply with such licences, permits orapproval/consents.

Compliant The Site has the following licences, permits and approvals/consents:· Development Consent SSD 6835· EPL 5065 - covers operations at LHRRP - varied on 7.12.17 to enable

re-profiling (overtopping, subject to the requirements of licenceconditions L3.4, E7.1, O5.8, O5.11, O5.12, O5.18, O6.6, O6.7 and O6.8.

· EPL 12520 – covers operation of the existing GO facility.· EPL 13114 – covers the operation of the PCYC minibike club.· Trade Waste Agreement with Sydney Water which is renewed every 12

months, the agreement was sighted by the auditors, dated 8.06.17.· Voluntary Planning Agreement (VPA) with Sutherland Shire Council,

dated 17.03.17. Requirements of the VPA were not reviewed as part ofthis audit.

· The ANSTO Agreement under which SUEZ lease land owned byANSTO

No other approvals were reportedly required during the audit period.STRUCTURAL ADEQUACYB10 The Applicant shall ensure that all new buildings and structures, and any

alterations or additions to existing buildings and structures are constructed inaccordance with the relevant requirements of the BCA.Notes: • Under Part 4A of the EP&A Act, the Applicant is required to obtain constructionand occupation certificates for the proposed building works; and• Part 8 of the EP&A Regulation sets out the requirements for the certification of theDevelopment.

Not triggered No new building or structures were constructed during audit period.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsOPERATION OF PLANT AND EQUIPMENTB11 The Applicant shall ensure that all plant and equipment used for the

Development are:(a) maintained in a proper and efficient condition; and(b) operated in a proper and efficient manner.

Non-compliant a) A number of procedures were in place to maintain plant and equipment ina proper and efficient condition, these included:

LandfillSelect Civil was responsible for maintaining plant and equipment used on thelandfill. Select Civil used a number of tools including:· Pre-start checklists.· The Plant Assessor database which tracks required regular

maintenance requirements and issues noted in pre-start checklists.· On-site maintenance workshop for non-major repairs. For major repairs

plant and equipment is sent off-site to Select Civils workshop.· Calibration/Inspection and Testing of Equipment Register.

During the site inspection the auditors observed that the liner of the mainleachate pond was lifted (referred to as ‘whaling’ in the geomembrane). The2015 IEA identified the same issue and made the following recommendation(2015-IEA-REC34):· ‘Repair the liner which had lifted in the main leachate dam.’

The lift of the liner is caused by a build-up of gas below the membrane whichcannot escape. Whaling can lead to significant failures of the liner- at worstcase it can burst. It can also compromise the capacity of the leachate dam.SUEZ reported that due to the rain in 2016 and 2017, it was not able to emptythe pond and do the repair however, it will be in a better position to empty thepond after the completion of the leachate treatment plant extension (on LH1)scheduled in 2018. The extension works will commence subject to theapproval of the Development Application.

The emergency pond and leachate storage tanks are used to export leachatefrom site. The main leachate pond has pumps to allow transfer of leachate toeither of these locations. This allows for a reduced volume of leachate to bestored in the main pond and reduce head pressure on the existing liner untilfurther investigation into the liner integrity can be carried out.

SUEZ commissioned a structural adequacy review of the five concreteleachate tanks on 15.09.16. The inspection noted that four of the tanks,although they have significant cracking are considered structurally adequate.The report recommends that these tanks are inspected every two years. Thefifth tank was not considered structurally adequate for use and should beemptied of any water and not used. During the audit inspection the five tankswere reportedly not in use. SUEZ reported that Tank 5 had beendecommissioned and is no longer in use.

GO FacilitySUEZ was responsible for maintaining the GO Facility plant and equipment. .SUEZ used a number of tools including:· Pre-start checklists.· The MAINPAC system which tracks required regular maintenance and

issues noted in pre-start checklists.

Water treatment plant and leachate treatment plantThe water treatment plant was being maintained by JPG Engineering. JPGused a number of tools including:· A Maintenance Leachate Inventory and Operations Checklist completed

on a daily basis.· Monitoring through SCADA which sends low flow, high level alarm alerts

to JPG Engineering. JPG view the SCADA system online and receiveemergency updates for example high-level alarms.

· JPG provide SUEZ with the records of maintenance. Auditors sightedthe daily records from JPG on the LH1 Leachate Treatment Plant.

2018-IEA-REC07:SUEZ should investigate ifthe integrity of the mainleachate pond liner hasbeen impacted by thewhaling of the liner andrepair it as required.


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Condition No Summary of Condition/Requirement Compliance Status Comment Recommendations· JPG Engineering provided a Monthly Operation and Plant Condition

Report to SUEZ. The report includes the weekly inspections for thewheel wash, stormwater treatment plant, leachate and ammoniatreatment plant (LH1), leachate transfer pumps, Stage 5/3 leachate riserpump facility, grass drain stormwater recirculation pump, excavationwater transfer pump, PCYC dust suppression transfer pump.

Landfill GasEDL provide a monthly report to SUEZ which shows methane concentration,flow and gas volumes, broken monitoring points, which wells are notproducing gas (due to malfunction or low gas volume). EDL operates under aseparate EPL. The auditors were provided with the December 2017 monthlyreport.

WeighbridgeThe Weighbridges are calibrated annually. The auditors sighted theweighbridge Repair and Verification Reports, issued by Standard Scales andServices Pty Ltd for In-bridge 1 (dated 10.11.17), In-bridge 2 (dated 30.05.17)and the Out-bridge (dated 28.07.17).

b) Each contractor on-site is contractually responsible for employing suitablytrained and competent staff.Select Civil reported that it completes a monthly forum which includestraining on SUEZ Standard Operating Procedures (SOPs). Trainingrecords were sighted by the auditors for Dust Control (SC-SOP-024),dated 25.09.17, and Leachate Management (SC-SOP-018), dated27.07.17. It was noted that training on the SUEZ OEMP and theconditions of consent in SSD 6835 had not been provided during the auditperiod but is reportedly planned.Training records for SUEZ staff were being maintained in SIMs. The‘Landfill – Competency Skill Matrix’ is a register which maintains SUEZstaff training needs and records.Operational meetings were held monthly with SUEZ, Select Civil, EDLand JPG to track project progress including training.

SUEZ implements a number of controls to maintain and operate plant andequipment in an efficient manner. However, this condition has been assessedas non-compliant as no actions were taken to assess the integrity or repairthe main leachate pond liner.

PROTECTION OF PUBLIC INFRASTRUCTUREB12 Prior to the commencement of construction, the Applicant shall:

(a) prepare a dilapidation report of the public infrastructure in the vicinity of thesite (including roads, kerbs, footpaths, nature trip, street trees and furniture); and(b) submit a copy of this report to the Secretary and Council.


A dilapidation report was prepared by AECOM dated 20.04.17. A copy wassubmitted to the Secretary on the 07.07.17. A response from DPE, dated10.07.17 was sighted by the Auditors which confirmed it was received with nofurther comments.SUEZ was not able to find evidence of submission to SCC prior toconstruction commencing in January 2018. Internal SUEZ emails werereviewed by the auditors which indicated that they were going to send thereport to Council, dated 8.05.17. SUEZ emailed a copy of the dilapidationreport to SCC on 2.03.18 (email sighted by auditors).On the basis that the dilapidation report was not submitted to Council prior tothe commencement of construction, this requirement has been assessed asan administrative non-compliance.

B13 The Applicant shall:(a) repair, or pay the full costs associated with repairing, any public infrastructurethat is damaged as a result of the Development; and(b) relocate, or pay the full costs associated with relocating, any publicinfrastructure that needs to be relocated as a result of the Development.

Not triggered SUEZ reported that this condition was not triggered during the audit period.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsSTAGED SUBMISSION OF PLANS OR PROGRAMSB14 With the approval of the Secretary, the Applicant may:

(a) submit any strategy, plan or program for the landfill re-profiling, GO Facilityand ARRT Facility construction and operation, required by this consent, on aprogressive basis; and/or(b) combine any strategy, plan or program required by this consent.

Compliant SUEZ requested via email dated 14.12.17, staged submission of the AirQuality and Odour Management Plan (AQOMP) and the GroundwaterManagement Plan (GMP) to cover the re-profiling stage of SSD 6835 andthat the plans would then be updated following the construction of the GOFacility and ARRT Facility.DPE requested further information on the 18.12.17 to clarify why the stagedsubmission was required, to which SUEZ responded on the 19.12.17.SUEZ received approval for the staged submission of the following plans in aletter from the DPE dated 22.02.18:· Air Quality and Odour Management Plan (C11)· Groundwater Management Plan (C35)· Emergency Response Plan (C63)· Operational Environmental Management Plan (Condition D4).

DPE note that the approval is for the submission of the above plans in twostages. The first stage would cover the re-profiling of the landfill and thesecond stage would cover construction and operation of the new GO Facilityand ARRT Facility.Compliance with submission of required management plans has beenassessed under the respective conditions of consent below.

DISPUTE RESOLUTIONB15 In the event that a dispute arises between the Applicant and either Council or a

public authority, in relation to an applicable requirement in this consent orrelevant matter relating to the Development, either party may refer the matter tothe Secretary for resolution. The Secretary's determination of any such disputeshall be final and binding on the parties.Note: This condition does not relate to disputes raised regarding matters in the VoluntaryPlanning Agreement required under Condition 8 19.

Not triggered Not triggered during the audit period.

COMPLIANCEB16 The Applicant shall ensure that employees, contractors and sub-contractors are

aware of, and comply with, the conditions of this consent relevant to theirrespective activities.

Compliant SUEZ reported that SUEZ employees and contractors would be made awareof the conditions of consent through training (OEMP training) and toolboxtalks. Training on the OEMP had not been completed at the time of the audit.SUEZ provides contractors with a copy of the consent for their records. Theconsent, EIS and EPL is also provided as part of the Select Civil contract(Tender Documents) as sighted by the auditors (annexure B(2)).The environmental management plans required under this consent areimplemented by SUEZ and provided to contractors e.g. Select Civil.

2018-IEA-REC08:Undertake training in theOEMP for all sitepersonnel.

B17 The Applicant shall be responsible for environmental impacts resulting from theactions of all persons that it invites onto the site, including contractors, sub-contractors and visitors.

Noted SUEZ reported that it requires visitors, site personnel and contractors tocomplete an on-line induction, site induction and permits to work for confinedspaces, breaking ground etc. Visitors are accompanied on-site.

EVIDENCE OF CONSULTATIONB18 Where consultation with any public authority or community group is required by

the conditions of this consent, the Applicant shall:(a) consult with the relevant public authority or community group prior tosubmitting the required documentation to the Secretary for approval, whererequired;(b) submit evidence of this consultation as part of the relevant documentationrequired by the conditions of this consent; and(c) include the details of any outstanding issues raised by the relevant publicauthority or community group and an explanation of or agreement between anypublic authority or community group and the Applicant or any person acting onthis Development consent.

Non-compliant Consultation with public authorities and/or community groups has beendiscussed against the specific conditions below. The AQOMP and GMPinclude records of consultation with the relevant agencies as appendices,however not all plans / reports requiring consultation include these details, forexample, the OEMP (D4), Emergency Response Plan (C63) and odour audit(Condition C12). On this basis, this condition has been assessed as notcompliant.

2018-IEA-REC09:Ensure evidence ofconsultation is submittedto the DPE as part of therelevant documentationrequired by the conditionsof consent. This shouldinclude details of anyoutstanding issues raisedduring the consultationand an explanation of theagreement reached.


A6 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsPLANNING AGREEMENTB19 Prior to the commencement of construction and prior to receiving increased

tonnes of waste in accordance with Condition B6(a), the Applicant shall enterinto the Voluntary Planning Agreement with Council in accordance with theLetter of Offer dated 15 December 2016.

Compliant A Voluntary Planning Agreement (VPA) was entered into by SUEZ and SSCon the 17.03.17.A copy was submitted to the Secretary on the 07.07,17. The Site commencedre-profiling in January 2018. During the audit period the Site had not receivedmore tonnages of waste than previously approved. Re-pro-filing began inJanuary 2018 following approval of the EPL variation in December 2017.

WASTEReceipt, Storage and Handling of WasteC1 The Applicant shall only receive waste on site that is authorised for receipt by an

EPL.Compliant The Landfill is authorised to receive general solid waste (putrescible and non-

putrescible), asbestos waste, tyres, leachate and other waste below licensingthresholds by EPL 5065. Refer to Condition L3.1 of EPL 5065 for anassessment of compliance with this requirement.The existing GO Facility is authorised to receive excavated natural material,wood waste, garden waste, VENM, manure and fly ash by EPL 12520. Referto Condition L2.1 of EPL 12520 for an assessment of compliance with thisrequirement.The PCYC minibike club area is authorised to receive general solid waste(non-putrescible), general or specific exempt waste and other waste belowlicensing thresholds by EPL 13114. Refer to Condition L2.1 of EPL 13114 foran assessment of compliance with this requirement.

C2 The Applicant shall ensure any waste generated on the site during constructionis classified in accordance with the EPA's Waste Classification Guidelines, 2014or its latest version, and disposed of to a facility that may lawfully accept thewaste.

Compliant Construction activities were limited to re-profiling of the landfill during theaudit period (removal of intermediate cover). Construction of ARRT and GOhad not commenced.

C3 The Applicant shall:(a) implement auditable procedures to:i) ensure the site does not accept wastes that are prohibited;ii) screen incoming waste loads; and(b) ensure that:i) all waste types that are controlled under a tracking system have theappropriate documentation prior to acceptance at the site; andii) staff receive adequate training in order to be able to recognise and handle anyhazardous or other prohibited waste.

Compliant SUEZ has developed SOP40 – ‘Waste Acceptance and Receipt’ to ensurewaste is received that is compatible with site design and regulatoryrequirements. SUEZ explained that the following measures are implemented:· Weighbridge staff and staff at the public drop off are trained in SOP40

and other relevant SOPs including SOP030.3 –Radioactive Waste andWork Instruction 063.6 – Asbestos Waste Management.

· Incoming loads are visually screened by the weighbridge operatorwhere possible and any waste that is not licensed to be received at thesite is rejected.

· Waste brought to site by the public are sent to the public waste drop-offwhere SUEZ staff monitor waste disposed of at the respective drop-offpoint e.g. general waste, green waste, mattresses and e-waste.

· Asbestos must be bagged appropriately to be disposed of on-site,otherwise the load is rejected.

· A Rejected Load Form is completed for all rejected loads and they arerecorded in a rejected load register.

· The rejected load register maintained at the weighbridge was sightedduring the audit. The register included the date, docket number,registration of the vehicle, product (waste type), the reason for nottipping and was signed by the weighbridge attendant.

Lucas Heights Landfill does not accept any trackable waste other thanasbestos.From 30.09.17 LHRRP, as a waste receiving facility, is required under theProtection of the Environment Operations (Waste) Regulation 2014, clause79, to track asbestos waste weighing more than 100 kilograms, or consistingof more than 10 square metres of asbestos sheets in one load using theEPA’s online system called WasteLocate.SUEZ reported that there is a WasteLocate QR code installed at theweighbridge. Customers with asbestos scan the code upon arrival to fulfil theonline reporting requirement. For those who don’t scan the code, SUEZ put aremark on the transaction. At the end of each month, SUEZ provides a list toEPA which includes all transactions that have not been able to scan the code.


A7 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsMonitoringC4 The Applicant shall provide details of the quantity, type and source of wastes

received on the site and provide these details to the EPA and the Secretarywhen requested.

Compliant Section 88 Return provided to the EPA monthly. Mandalay reporting systemmanages waste in and out of site.SUEZ reported that DPE has not requested records be provided during theaudit period.

Landfill OperationsC5 To minimise the potential for odour generation, the Applicant shall, unless

otherwise agreed in writing by the EPA:(a) ensure a maximum of 1 hectare of existing intermediate cover or 2 hectaresof existing final capped cover may be stripped in advance of landfilling to formthe prepared surface. The prepared surface must have a minimum depth of 300millimetres;(b) at any one time a maximum of 2,500 metres squared of the prepared surfacemay be stripped back to expose previously landfilled waste to form the active tipface; and(c) the landfill gas field infrastructure must be retained and operating at all times,with the exception of the stripped back prepared surface.

Compliant SUEZ captures these requirements in Section 7.4.5 of the OEMP. In additionthe Landfill Daily Checklist includes strip back operational requirements asspecified in part (a) and (b) of this condition. Checklist from 19.01.18 sightedby the auditors. The requirement that the prepared surface must have aminimum depth of 300 mm was not included.During the site inspection the auditors sighted the extension of landfill gasinfrastructure on the stripped back prepared surface. SUEZ noted that thesewells are disconnected during filling but will be recommissioned followingcompletion of the lift in that area. This process will be repeated until the finallandform is reached and final capping is complete. The remaining gasinfrastructure within the landfill remains operational, less those which areoffline for maintenance reasons. This information is recorded in the EDLmonthly report. Refer to EPL 5065 condition O5.18 for a further discussion ofthe extension of landfill gas infrastructure.

2018-IEA-OFI03:Add the requirement tomaintain 300 mm cover tothe Landfill DailyChecklist. Addconfirmation box to recordthat it has been done.Include an electronicsignature on checklistscompleted in soft-copy.

Imported SoilC6 The Applicant shall:

(a) ensure that only VENM or ENM or other material approved in writing by theEPA is used as fill on the site;(b) keep accurate records of the volume and type of fill to be used; and(c) make these records available to the Secretary upon request.

Compliant a) The clay was imported from Elizabeth Drive, Badgerys Creek and wasclassified as VENM by the following reports:

· Letter Report titled ‘Elizabeth Drive Landfill, VENM classification ofquarried material’ prepared by GHD, dated 18.12.09 which stated thatthe material from this Site was classified as VENM as defined in NSWDECC (2008), “Waste Classification Guideline Part 1: ClassifyingWaste”.

· Stockpile Assessment – Elizabeth Drive Landfill, prepared by GHD,dated June 2012 which stated that “visual observations during the siteinspection of the manner in which site management controls areimplemented, and groundwater and leachate quality demonstrate thatthe stockpiled natural material is suitable to continue to be classified asVENM as defined in NSW DECC (2009), “Waste ClassificationGuidelines Part 1: Classifying Waste” and the Protection of theEnvironment Operations Act 1997”.

SUEZ reported that it has not imported any ENM for use as fill on the site.b) SUEZ use the Mandalay weighbridge system to record materials importedto site. SUEZ also commission a landfill volumetric survey and stockpilesurvey every six months (June 2017 and December 2017) which details thetype and volume of stockpiles (including VENM) and landfill capacity details.This report is submitted to the EPA.c) The Site reported no requests for records were made by the Secretaryduring the audit period.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsC7 During construction, the Applicant shall ensure any material brought on site for

use as fill meets the requirements of the relevant Resource Recovery Order andExemption issued under the Protection of the Environment Operations (Waste)Regulation 2014, to apply that material to land. The Applicant shall retainrecords of all material brought on site for filling purposes and provide the recordsto the EPA and the Secretary when requested.

Not triggered During the audit period SUEZ reported that the following materials have beenbrought onto site for use during cell construction:

· Clay for use as clay liner during cell construction – 8,343.14 tonnesfrom 1.01.17 to 31.12.17 and 2,980 tonnes from 1.1.18 to 23.01.18.

· Drainage gravel aggregate for landfill gas wells.· Drainage gravel for leachate collection system.· Geotextile, HDPE membrane, HDPE pipes and fittings for cell

construction.SUEZ holds Operational Purpose Deduction Certificates, issued by the EPAfor the periods from 01.10.16 – 30.09.17, and 01.10.17-31.04.18. Thesecertificates permit SUEZ to receive specific quantities and types of waste andmaterial at LHRRP for specified works. Each certificate is allocated aDeduction Identification Number for claims in the facility’s WasteContributions Monthly Report.The clay is imported from Elizabeth Drive, Badgerys Creek and was classifiedas VENM by GHD, report Stockpile Assessment, Elizabeth Drive Landfill,June 2012. No material was reportedly brought onto site for use as fill thatwould trigger the requirements of a Resource Recovery Order and Exemption

ODOUR and AIR QUALITYLimits


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsC8 The Applicant shall ensure the Development does not cause or permit the

emission of any offensive odour, as defined in the POEO Act.Compliant SUEZ undertook the following measures to mitigate odour from the LHRRP:

· The tip face has been reduced in size.· Waste is reportedly covered at the end of each day.· An odour unit and odour fence is in place around the GO receivals area

of the GO garden organics.· Portable odour units were being used as required· The leachate and organics dams were reportedly aerated as required. At

the time of the audit the leachate dam was at a very low level due todrought therefore no aeration was taking place.

· Weather conditions were monitored for when possible odorous works areundertaken.

· An odour patrol was undertaken in the mornings in and around the site toidentify possible odour. The Auditors sighted the ‘Odour AssessmentDiary 2017’ which records the date, time and location of odour patrolundertaken at the following two locations:o Cnr New Illawarra Rd and Heathcote Roado Onsite inner perimeter road and carpark (two locations)The Diary includes notes on the assessment (e.g. no odour detected,mild organics odour etc.). The Diary indicated assessments were beingcompleted daily (Monday to Friday) during 2017.

· Ongoing installation of additional landfill gas collection wells.· EDL, the operators of the gas infrastructure undertake inspections and

identify areas that require additional wells or additional clay cover.· A new odour unit and odour fence was installed on the south-eastern

boundary of Area D. It was reported that a second unit and odour fencewas going to be installed on the western side of Area D in early 2018.

In June 2017, 15 odour complaints were received from the communitybetween the 15.06.17 and 29.06.17. Under the SUEZ Complaint Investigationand Rectification Process (Appendix K of the OEMP) when 15 or morecomplaints are received within any calendar month SUEZ undertakes aninternal technical audit to investigate the area of concern. The auditorsreviewed the Internal Compliance Audit (Odour), dated 31.07.17. Two actionswere implemented following this investigation:· Revision of the contractor checklist to include regular inspection of water

traps. SUEZ provided the auditors a copy of the ‘Lucas Heights DailyGas Field Log’ (no date). The log appeared to have the following watertraps listed for daily observations WT35, WT64, WT94, WT61, WT70,WT52, WT91, WT16 and WT26. The auditors were not able to verify thechanges to the daily log had occurred since the internal odour audit.

· Revision of the existing GO Facility checklist to include inspection of theplatform surface. The auditors reviewed the ‘Compost Facilities WeeklyChecklist’ (FORM026.3.1) and were not able to verify that thisrecommendation had been implemented.

The audit identified that the management and mitigation measures outlined inthe OEMP were in place as part of the day to day operations. SUEZ provideda copy of the odour audit to SCC (email dated 31.07.17). SCC responded on1.08.17, stating that “they were happy with the way SUEZ kept Council up todate with what was happening on site. I (SCC) was also impressed with theway the problem was identified and resolved quickly”.This condition has been assessed as compliant as SUEZ has processes inplace to identify and manage odours, including investigating complaints andimplementing continual improvement controls. During the site inspection,odours were not considered to be particularly offensive.

2018-IEA-OFI04:Consider changing thedaily odour auditprocedure to beundertaken at differenttimes throughout the day.

2018-IEA-REC10:When internal technicalaudits are triggered inresponse to complaintsensure that evidence ofthe actions implementedto address the findings ofthe audit is included as anattachment to the report.This will provide greatertransparency that therecommended changeshave occurred.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsC9 The Applicant shall:

(a) operate and maintain all facilities within the site in a condition which controlsthe emission of dust; and(b) carry out all reasonable and feasible measures to minimise dust from thesite.

Compliant The Site implemented the following dust controls, as detailed in the OEMP:· A wheel wash was being used to minimise tracking of dirt onto roads in

wet weather.· Select Civil had one water truck in operation during the audit period.

During the site inspection Select Civil reported that they werepurchasing a second water cart for the site.

· The GO Facility has a water cart.· The Site reportedly has reduced the size of the tip face.

The AQOMP includes requirements for dust management and monitoring.Included in the plan are the following performance criteria:· Monthly dust deposition monitoring is undertaken at 6 gauges on site

and shall not exceed 4 g/m2/month (annual mean). The auditorsreviewed the dust deposition monitoring data for 2017 (‘LH Dust2017.xlxs) and noted all dust gauges had annual averages well belowthe 4 g/m2/month level.

· Total suspended particulates (TSP) are monitored continuously andshall not exceed 90 µg/m3 (annual average). TSP monitoring has beenundertaken at LHRRP since April 2017 using a real-time continuousdust monitor. The annual average for 2017 (28.04.17-31.12.17) was14.69 μg/m3, well below the target value of 90 μg/m3.

The SUEZ complaints register reported that no dust complaints werereceived during the audit period.This condition is considered compliant as SUEZ has a number of dust controlmeasures implemented, monitoring did not exceed the pre-determinedcriteria and no dust complaints were received during the audit period.

Meteorological MonitoringC10 The Applicant shall install, operate and maintain a meteorological weather

station on the site that complies with the requirements of an EPL for the site.Compliant SUEZ operates a meteorological weather station as required by Condition

M4.1 of EPL 5065. The auditors were shown the weather station during thesite inspection. The auditors were also shown the real-time monitoring datadisplayed via a mobile phone app.SUEZ provided the weather data from 01.01.17 to 25.02.18 to the auditors.Refer to EPL 5065, condition M4 for further assessment of the weatherstation.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsSite Air Quality and Odour Management PlanC11 The Applicant shall prepare a Site Air Quality and Odour Management Plan. The

plan shall:(a) be prepared by a suitably qualified and experienced person in consultationwith the EPA and Council;(b) be submitted to the Secretary prior to the commencement of construction;(c) list all emission sources across the LHRRP and key performance indicatorsfor each emission type;(d) describe odour and dust monitoring methods, location, frequency andduration;(e) show the locations of real-time dust monitors on and off-site with appropriatetrigger values;(f) report on the performance of the site against the key performance indicatorsfor each emission type;(g) detail proactive mitigation measures for the control of dust and odourimpacts;(h) detail the contingency measures to be implemented to respond to complaintsor if dust or odour impacts are identified; and(i) include record keeping, a complaints register and compliance reporting.

Compliant SUEZ prepared an AQOMP for the landfill re-profiling works and existing GOFacility.(a) The AQOMP was prepared by the Site’s Compliance Scientist, Brian

Kelly. Brian’s qualifications were not reviewed as part of this audit.A record of consultation with the EPA, Council and DPE is provided inSection 13 of the AQOMP.The AQOMP was submitted to the EPA by email dated 27.10.17. Aletter was received from the EPA dated 21.11.17 stating that the EPAconsiders the AQMP has considered the matters required by ConditionC11 and providing one comment for SUEZ’s consideration (to considerthe impacts from uncapped areas and/or lack of vegetative matter onsurface areas, and the subsequent potential to contribute to sedimentloads in surface waters and windblown dust).The SCC provided feedback on the AQOMP, dated October 2017. TheSCC made a number of comments. SUEZ response to the SCC wasprovided to the auditors, and is included in the OEMP. SUEZ reportedthat SCC did not provide further comments.

(b) Construction, being the stripping back of covered area and landfilling ontop of existing waste, commenced in January 2018. The AQOMP wassubmitted to the DPE on the 11.12.17. The DPE provided comments onthe plan to SUEZ on the 13.12.17. SUEZ revised and re-submitted theAQOMP to the DPE 15.12.17. The DPE requested minor additionalchanges to the AQOMP in an email dated 7.03.18. SUEZ re-submittedthe AQOMP on the 9.02.18.

(c) A high level review of the AQOMP was completed by the auditors and itis considered that the requirements of condition C11 (c)-(i) have beenincluded in the plan.

SUEZ requested approval for a staged submission of the AQOMP (email toDPE dated 14.12.17). SUEZ reportedly intends to update the AQOMPfollowing the construction of the new GO Facility and ARRT Facility. The DPEapproved the staged submission in a letter dated 22.02.18.

LandfillC12 The Applicant shall conduct an odour audit of the landfill to validate the odour

reductions described in the EIS have been achieved at the existing landfill. Theodour audit shall:(a) be prepared by a suitably qualified and experienced person in consultationwith the EPA and Council;(b) be submitted to the EPA, Council and the Secretary at least one month priorto the commencement of landfill re-profiling;(c) include collection and analysis of odour samples in accordance with theEPA's Approved Methods for Sampling and Analysis of Air Pollutants in NSW;and(d) identify mitigation measures with a timeline for implementation, where theodour reductions identified in the EIS are not being achieved.

Non-compliant (a) A LHRRP Landfill Odour Audit was conducted by environmentalconsultants, GHD (report dated October 2017).SUEZ submitted the Odour Audit to SCC for consultation in an emaildated 25.09.17. SCC provided comments in an email dated 6.10.17,and noted the requirement for odour sampling and the relevance of thedaily odour observations, as SUEZ odour observations during June didnot identify any odour issues, however 15 complaints were receivedfrom the community.SUEZ submitted the Odour Audit to the EPA for consultation in an emaildated 25.09.17. A response from the EPA was received in a letterdated 24.10.17. The EPA raised a number of concerns including:- The audit does not discuss the comparative effectiveness in odour

reduction from any specific measurements implemented andappears to draw conclusions based on a general reduction in odourin the sections surveyed.

- The EPA provided a number of factors that may have influencedthe conclusions drawn in the Odour Audit.

- That the audit does not discuss the relationship between the workscompleted and the odour complaints received, which increasedduring the time period of the audit.

A response from SUEZ to SCC and the EPA was not provided to theauditors.

2018-IEA-REC11:Submit the final OdourAudit to SCC and EPA asper C12(b).


A12 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment Recommendations(b) Re-profiling commenced in January 2018. SUEZ submitted the Odour

Audit to the DPE (email dated 26.10.17). SUEZ had not provided a copyof the final Odour Audit to the EPA and Council at the time of the audit.SUEZ reported that it was reviewing the Odour Audit in conjunction withthe Air Quality and Odour Management Plan.

(c) Odour samples were not collected as part of the audit. Section 3.1 of theOdour Audit Report states that “SUEZ advised GHD that it hadpreviously met with the EPA and the EPA agreed that odour samplingwas not needed, should observations made during the audit’s siteinspection indicate that suitable odour reductions have been realised atthe site”. SUEZ reported to the auditors that this correspondence wasverbal during a face to face meeting held on the 11.07.17. Formalwritten evidence of this discussion was not available. In addition, GHDrecommended that “odour sampling is not to be undertaken in the mainareas identified in 2014, as it is considered unlikely that the odouremitted from these areas would be detectably at off-site receptors”.

(d) The Odour Audit found that the odour reductions described in the EIS in2015 have been achieved at the main odour emitting areas of thelandfill. The audit noted the following:- The landfill batters – no landfill gas was notifiable in the

‘rectangular area south of the excavation stockpile’. However nolandfill gas odours were detected on site 150m downwind, whichindicates that odour emissions from this area are limited.

- ‘v section’ – significant odour was not experienced off the newlandfill barriers or from the ‘v section’ as it no longer exists.

The Audit included a number of mitigation measures already identifiedand being implemented by SUEZ and recommended they continue to beimplemented.

On the basis that it could not be demonstrated whether the EPA and SCC’scomments on the Odour Audit report were addressed, and whether a Finalversion of the Odour Audit was provided to the SCC and EPA prior to thecommencement of landfill re-profiling, this condition has been assessed asnon- compliant.

GO FacilityC13 All organic material and waste shall be stored at the GO Facility in accordance

with the requirements of an EPL for the site, including limits on the height ofstockpiles and use of breathable membrane covers on compost bunkers.

Not triggered This Condition relates to the new GO Facility which had not beenconstructed.Organic material and waste at the existing GO Facility was being managed inaccordance with EPL 12520 (refer to assessment with this EPL).

C14 The Applicant shall conduct an odour audit of the GO Facility to validate theodour data used in the EIS. The odour audit shall:(a) be prepared by a suitably qualified and experienced person in consultationwith the EPA and Council;(b) be submitted to the EPA, Council and the Secretary within 6 months ofcommencement of operation of the GO Facility as described in the EIS;(c) include collection and analysis of odour samples in accordance with theEPA's Approved Methods for Sampling and Analysis of Air Pollutants in NSW;(d) validate the efficiencies of the odour controls, specifically the covers used forthe active composting stage;(e) validate the odour data for freshly turned material;(f) demonstrate that the final design achieves an equivalent or betterperformance than stated in the EIS, supported by dispersion modelling inaccordance with EPA's Approved Methods for Sampling and Analysis of AirPollutants in NSW, if required; and(g) identify additional mitigation measures with a timeline for implementation,where odour performance significantly differs from the predictions in the EIS.

Not triggered Design of the new GO Facility had not commenced at the time of the audit.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsARRT FacilityBiofilter and Pre-Treatment SystemC15 The Applicant shall appoint an appropriately qualified and experienced person to

design the ARRT Facility, biofilter and pre-treatment and post-treatmentsystems. The biofilter, pre-treatment and post-treatment systems shall bedesigned and constructed to:(a) achieve the point source discharge parameters detailed in the EIS, as aminimum; and(b) achieve a maximum odour emission concentration of 250 OU/m3 atdischarge. If 250 OU/m3 cannot be achieved, the Applicant shall implement thepre-treatment and post-treatment systems, in accordance with the requirementsof the EPA and in a timeframe approved by the Secretary.

Not triggered Design of the new ARRT Facility had not commenced at the time of the audit.

Pre-OperationC16 Prior to the commencement of operation of the ARRT Facility, the Applicant

shall:(a) provide written evidence to the EPA and the Secretary, from an independentodour expert to verify the final design parameters and actual stack parametersfor the pre-treatment system and biofilter;(b) prepare an odour verification report for the pre-treatment, biofilter and post-treatment system, prepared by an independent odour expert, to verify:a. the systems are fully commissioned prior to operation of the ARRT Facility;andb. approve the odour control system and the odour management plan requiredunder Condition C17.

Not triggered Construction of the new ARRT Facility had not commenced at the time of theaudit.

Air Quality and Odour Management PlanC17 The Applicant shall prepare an Air Quality and Odour Management Plan for the

ARRT Facility. The plan shall:(a) be prepared by an independent odour expert in consultation with the EPAand Council;(b) be submitted to the EPA, Council and the Secretary prior to thecommencement of operation of the ARRT Facility;(c) include an odour management strategy containing:i. objectives and targets;ii. odour risk assessment;iii. biofilter and pre-treatment monitoring and maintenance plan;iv. air quality monitoring plan;v. communications strategy; andvi. system and performance review for continuous improvement.


Biofilter and Pre-Treatment Monitoring and Maintenance PlanC18 The Applicant shall prepare a Biofilter and Pre-Treatment Monitoring and

Maintenance Plan as required under Condition C17. The plan shall:(a) be prepared by an independent odour expert endorsed by the Secretary;(b) be prepared in consultation with the EPA and Council;(c) be submitted to the EPA, Council and the Secretary prior to thecommencement of operation of the ARRT Facility;(d) include a method for monitoring biofilter and pre-treatment performance thatidentifies biofilter and pre-treatment performance indicators that can bemonitored via the process control room computer systems;e) detail all proposed actions to ensure the biofilter and pre-treatment system ismaintained for operation in a proper and efficient manner including, but notlimited to, frequency of replacement/replenishment of filter bed material; and(f) identify mitigation actions to be taken in the event of breakdown and/orservicing of the biofilter and/or pre-treatment system.


Operating ConditionsC19 All waste receivable, processing, storage and dispatch associated with the

ARRT Facility must be completely enclosed within sealed buildings that areoperated under negative pressure.

Not triggered Construction of the new ARRT Facility had not commenced at the time of theaudit


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsC20 The Applicant shall ensure all air captured through the ARRT Facility buildings

are treated through a biofilter and approved pre-treatment system prior todischarge to atmosphere.


Odour AuditC21 The Applicant shall conduct an odour audit of the ARRT Facility to validate the

odour data used in the EIS. The odour audit shall:(a) be prepared by an independent odour expert in consultation with the EPAand Council;(b) be submitted to the EPA, Council and the Secretary within 6 weeks ofcommencement of operation of the ARRT Facility and again after 6 months ofoperation;(c) include collection and analysis of odour samples in accordance with theEPA's Approved Methods for Sampling and Analysis of Air Pollutants in NSW;(d) validate the efficiencies of the odour controls, including the biofilter(s) andpre-treatment system;(e) demonstrate the final design achieves an equivalent or better performancethan stated in the EIS, supported by dispersion modelling in accordance withEPA's Approved Methods for Sampling and Analysis of Air Pollutants in NSW, ifrequired; and(f) identify additional mitigation measures with a timeline for implementation,where odour performance significantly differs from the predictions in the EIS.


GREENHOUSE GASC22 The Applicant shall implement all reasonable and feasible measures to minimise

energy use on site and greenhouse gas emissions produced on site.Compliant SUEZ is required to report its energy use and greenhouse gas emissions

under the National Greenhouse Gas and Energy Reporting Scheme(NGERs). This is done at the corporate level with input from the facilities.For LHRRP, monthly fuel and lubricating oil volumes were received fromSelect Civil and Morris Civil (sighted monthly volumes for 2016-17 reportingperiod). Electricity use is monitored by Corporate.The main method in which SUEZ minimises greenhouse gas emissions isthrough the efficient operation of the gas infrastructure. The gas infrastructureinstalled on site collects landfill gas and converts it to electricity or where thisis not possible the landfill gas is flared. This is managed by EDL. InDecember 2017 46% of the landfill gas was methane used in powergeneration. EDL has an economic incentive to maximise the amount oflandfill gas collected and converted to electricity, reducing greenhouse gasemissions.

LEACHATELandfill – Dual Gas and Leachate TrenchC23 The Applicant shall design and install a dual gas and leachate management

trench near the perimeter of the re-profiled landfill to intercept sidewaysmovement of leachate. The trench shall:(a) be designed in accordance with the requirements of the EPA;(b) be approved by the EPA, prior to construction of the trench and landfill re-profiling;(c) include extraction risers along the length of the trench to allow extraction andtransfer of leachate to the existing ring main; and(d) be installed in accordance with a CEMP, prepared by a suitably qualifiedperson and submitted to the EPA at least one month prior to construction of thetrench.

Compliant SUEZ submitted the:· CEMP, Part 1 – Landfill Related Construction works only, Dual Gas and

Leachate Trench construction works, dated July 2017, and· The Dual Gas and Leachate Trench Concept Design,

to the EPA on the 20.07.17. The EPA provided a letter response, dated10.10.17, which stated that the EPA has approved the installation providedthat installation and construction is undertaken in accordance with the DualGas and Leachate Trench Concept Design provided, and installation andconstruction is undertaken in accordance with the Dual Gas and LeachateTrench CEMP provided.SUEZ reported that construction of the trench is planned for February/March2018.The CEMP did not specify who prepared it, therefore the auditors could notdetermine if the CEMP was prepared by a suitably qualified person.Installation of the dual gas and leachate management trench had not begunat the time of the audit therefore implementation of the CEMP was notreviewed.

2018-IEA-OFI05:Include a revision tablewithin the CEMP toidentify who prepared theCEMP and that the EPAhas reviewed andapproved the plan.


A15 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsLandfill Gas InfrastructureC24 The Applicant shall maintain and operate the landfill gas infrastructure on the

site, at all times. The Applicant shall retain and operate the gas collection systemwithin the prepared surface (stripped back cover) as much as practicable.

Compliant The gas infrastructure within the landfill is operational at all times, less thosewells which are offline for maintenance reasons or decommissioned due tolow or no extraction being achieved. This information is recorded in the EDLmonthly report. Refer to condition C5(c) for a discussion of the operation andextension of the gas collection system within the stripped back preparedsurface.

Operating ConditionsC25 Accumulated sludge and sediment formed during leachate storage at the site

shall be disposed of to a special waste area at the LHRRP, separate from theactive tip face.

Not triggered Leachate storage ponds had not been emptied and de-silted / de-sludgedduring the audit period. Minimal sludge produced by leachate storage.

C26 The Applicant shall manage all water that comes into contact with waste at theGO Facility as leachate. Leachate generated at the GO Facility may only bereused in the composting process on site or disposed to sewer in accordancewith a Trade Waste Agreement or as otherwise agreed in writing with the EPA.

Not triggered This condition is considered applicable to the new GO facility.The existing GO facility collects leachate in a separate leachate pond. This ismanaged under the Garden Organics OEMP. No discharge to trade waste.

C27 All leachate generated at the ARRT Facility must be stored indoors or inenclosed tanks and used in the ARRT composting process or transferred fordisposal to a Facility lawfully permitted to receive it.

Not triggered Construction of the new ARRT facility had not commenced at the time of theaudit.

Leachate MonitoringC28 The Applicant shall routinely monitor leachate volumes from all sources and re-

calibrate the leachate model included in the EIS, to ensure adequate storage,treatment and disposal capacity is maintained at all times. The Applicant shallreport the results of on-going monitoring and model calibration every year in theAnnual Review required under Condition D7.

Not verified Real-time monitoring of leachate volumes is conducted using a SCADAsystem. JPG provides a monthly “Leachate Inventory Status ReportSpreadsheet” to SUEZ. The report includes the leachate volumes for sourcesacross the site, for example Harrington’s Quarry, LH2 Dam to EmergencyDam, LH2 storage dam, LH2 Stage 5/3 etc. Leachate Volumes are reportedto the EPA every 12 months in the Annual Return.The auditor reviewed email correspondence from the GHD technical lead forthe leachate studies undertaken as part of the EIS, which stated that theintent of the mitigation measures proposed in the EIS and Response toSubmissions Report was for ongoing monitoring to facilitate periodicrecalibration of the water balance. SUEZ reported that it would look intoseeking a modification to have this condition to align with the intent of theleachate studies. In the meantime, the Annual Review is required to reporton the leachate model calibration. As the submission of the Annual Reviewfor the 2017 calendar year fell outside of the audit period, this condition couldnot be verified.

2018-IEA-REC12:Ensure the 2017 annualreview includes acalibration of the leachatemodel included in the EISor seek a modification tothis requirement.

C29 The Applicant shall implement any recommended measures identified byleachate model calibrations to maintain adequate storage, treatment anddisposal capacity for the LHRRP at all times.

Not triggered Not triggered.

SURFACE WATER AND GROUNDWATERDischarge LimitsC30 The Development shall comply with Section 120 of the POEO Act, which

prohibits the pollution of waters, except as expressly provided for in an EPL.Non-compliant EPL 5065 includes concentration limits for pollutants discharged to waters

from Points 1, 20, 21 and 22.Surface WaterSUEZ reported the following non-conformance with limits in EPL 5065 in theAnnual Return for the audit period (23.01.17 – 20.08.17):· Six exceedances of suspended solids at EPL Monitoring Point 1 on the

17.03.17, 18.03.17, 19.03.17, 25.03.17, 4.4.17 and 10.06.17· Five exceedances of suspended solids at EPL Monitoring Point 22 on

the 17.03.17, 18.03.17, 19.03.17, 04.04.17 and 10.06.17· Four exceedances of dissolved oxygen levels at EPL Monitoring Point 1

on the 03.03.17, 09.03.17, 18.03.17 and 25.03.17. The auditors notethat the exceedance reported on the 25.03.17 was a concentration of6 mg/L dissolved oxygen. This is not considered a non-compliance as itis not less than 6 mg/L, which is the concentration limit in Condition L2.4of the EPL.


A16 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsSUEZ provided a copy of the laboratory reports for review of sampling datafor EPL Points 1, 21, and 22. No other exceedances of surface watermonitoring were reported by SUEZ.SUEZ received a letter from the EPA (dated 27.06.17), requesting an updateon two areas of stormwater management:1. Stormwater management infrastructure works, undertaken by SUEZ to

improve ammonia levels in stormwater.2. Stormwater discharge management on weekends in response to a

community complaint received identifying potential overflow fromLHRRP stormwater dams on Saturday 4 March 2017 resulting insuspended solids discharging to Mill Creek. No sampling was conductedby SUEZ during this discharge over the weekend.

SUEZ provided a letter response to the EPA (dated 27.07.17) which reportedthat the following works had been undertaken:1. Stormwater management infrastructure works:· Replacement of leachate ring main between LP16 and LP17.· Installation of a new section of HDPE pipe and associated riser pipes.· Reinstatement of the pipeline and backfilling it with clay, forming a

barrier between the edge of the capping and the western dirty waterdrain.

· Removal of the French Water Drain.· Reconstruction of the dirty water drain, including gabion baskets

2.Stormwater discharge management on weekends:· Upgrading the STP control system from a manual system to a visual

touch screen system (including new computer hardware and software).· Installing an ultrasonic level detector in the sediment dam which is

linked to the control system allowing remote monitoring of the sedimentdam.

· Enabling the control system to monitor any sediment dam overflowevents and send notification to nominated site representatives via SMS.

· Revising the stormwater management plan to specify nominatedpersonnel and the required actions to be undertaken outside of normaloperating hours.

· Introducing a maintenance program for the stormwater plant includingchecking and verification by SUEZ/Contractor.

· Installation of a freeboard marker in the sediment dam.A response from the EPA to SUEZ’ letter was not sighted by the auditors.The auditors observed the western ring main and new western dirty waterdrain during the site inspection on the 22.01.17. Photos are provided inSection 6.1 of the main report.The GO Facility EPL (12520) and PCYC Minibike Club EPL (13114) do notinclude concentration limits for pollutants discharged to waters. The AnnualReturns for the GO Facility and PCYC Minibike Club did not report anyincidents of pollution of waters. On the basis of the recorded exceedanceswith EPL 5065 pollutant concentration limits during the audit period thiscondition has been assessed as non-compliant.GroundwaterGroundwater monitoring was undertaken quarterly at 11 locations prior toEPL 5065 variation dated 07.12.17. SUEZ publishes results of the monitoringon the SUEZ website.EPL 5065, condition R4.2 requires that SUEZ reports to the EPA levels ofammonia detected above 1 mg/L at Points 4, 7, 8, 16, 17, 18, 19 (and from07.12.12 Points 24, 25, 26, 27, 44, 45, 46, 47, 48 or 49. A review of thequarterly monitoring results for Mar, Jun, September and December identifiedno instances where ammonia levels greater than 1mg/L were detected. Noother limits on groundwater pollutants are specified in the EPL.


A17 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsGO FacilityC31 The Applicant shall ensure excess water collected in the leachate dams at the

GO Facility during high rainfall periods is transported off-site and disposed oflawfully or discharged to sewer in accordance with a Trade Waste Agreement.

Compliant The GO OEMP discusses the collection of rain water and process water(greenwaste liquor), storage within the greenwaste dam and reuse forcomposting operations. It however does not discuss discharges or disposal ofthe greenwaste liquor from the dam and the requirement that it betransported off-site and disposed of lawfully or discharged to sewer inaccordance with a Trade Waste Agreement.SUEZ reported that if leachate levels in the pond from the existing GO Facilityreaches below the free-board, leachate from the pond is tankered off-site to alicensed facility (Spring Farm). The pond has level makers to indicate whenthe free board volume is reached. SUEZ reported that this has only occurredonce in 2013/14 (outside the audit period).SUEZ identified that it would not currently use the existing waste watertreatment plant at LH1, which discharges to sewer, as the BOD levels may beexceeded from the garden organics leachate.

2018-IEA-OFI06:Update the GO OEMP toinclude discussion of thedischarge or disposal ofgreenwaste liquor fromthe greenwaste dam andthe requirement that it betransported off-site anddisposed of lawfully ordischarged to sewer inaccordance with a TradeWaste Agreement.

C32 The Applicant shall prepare and submit a detailed design for managing surfacewater from roofs and breathable membrane covers at the GO Facility. Thedesign shall:(a) be approved by the EPA prior to the commencement of operation of the GOFacility;(b) demonstrate that surface water runoff from the roof and breathablemembrane covers does not come into contact with waste; and(c) describe a program for on-going monitoring of the water quality dischargedfrom the GO Facility to Mill Creek.

Not triggered The GO Facility was yet to be designed at the time of the audit.

Mill CreekC33 The Applicant shall prepare an Aquatic Habitat Monitoring Plan to monitor the

stream health of Mill Creek within the site. The plan shall:(a) be prepared by a suitably qualified and experienced person in consultationwith DPI Water;(b) be submitted to the Secretary prior to construction of the GO Facility andupdated and re-submitted to the Secretary prior to construction of the ARRTFacility;(c) describe the monitoring locations, frequency and parameters to bemeasured; and(d) detail the measures to be implemented if monitoring indicates the habitatquality of Mill Creek is decreasing as a result of activities on the site.

Not triggered The GO and ARRT facilities were not constructed at the time of the audit.

C34 The Applicant shall prepare a Mill Creek Stream Rehabilitation, Stabilisation andVegetation Management Plan. The plan shall:(a) be prepared by a suitably qualified and experienced person in consultationwith DPI Water;(b) be submitted to the Secretary prior to construction of the GO and ARRTfacilities;(c) be prepared in accordance with DPI Water Guidelines for ControlledActivities on Waterfront Land;d) detail proposed stream realignment works including details of the measures tominimise water quality impacts;(e) detail the proposed rehabilitation and stabilisation of the stream includingmethods and staging of works;(f) detail opportunities to maximise the width of riparian zones, particularly in thefinal landform design, and detail the vegetation types, maintenance, monitoringand performance criteria for the rehabilitation works; and(g) be updated to include any changes to the rehabilitation objectives andstaging approved in the Post Closure Plan for the site, required under ConditionC40.

Not triggered The GO and ARRT facilities were not constructed at the time of the audit.


A18 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsGroundwater Management PlanC35 The Applicant shall prepare a Groundwater Management Plan for the site. The

plan must:(a) be prepared by a suitably qualified and experienced person, in consultationwith the EPA and DPI Water;(b) be submitted to the Secretary, prior to the commencement of construction;(c) detail the groundwater monitoring network including location and frequency ofmonitoring, the parameters for testing, relevant criteria and trigger levels foraction;(d) include a protocol for investigation, notification and mitigation of anyexceedances of the identified trigger levels; and(e) describe the measures that could be implemented to respond to identifiedgroundwater contamination.


SUEZ has prepared a Groundwater Management Plan (GMP), dated31.01.18.

(a) The plan was prepared by Douglas Partners, in consultation with theEPA and DPI. SUEZ met with DPI Water for a consultation meetingon the 28.07.17. Two letters were received from DPI Water on the19.04.17 and 10.08.17 providing a number of recommendations/comments. DPI Water provided a number of comments in regards topreparation of the plan in accordance with the requirements ofCondition C35 (c), (d) and (e).The EPA was provided the GMP for consultation in an email dated6.09.17. The EPA provided a response in a letter dated 10.10.17, inwhich a number of recommendations / comments were made.

(b) The GMP was originally submitted to DPE on the 19.10.17. The DPEprovided comments on the GMP on the 30.10.17.The DPE noted thatnot re-establishing bores, as per Condition C5, requires amodification to SSD 6835 (discussed further in C36).The GMP was updated in January 2018 and re-submitted to DPE viaemailed dated 13.02.18.Construction commenced in January 2018.

Submission of the updated GMP to the EPA and DPI Water and confirmationthat the agencies were satisfied that their comments had been addressedwas not sighted by the auditors. On the basis that the updated planaddressing the EPA and DPI comments was not provided to the DPE prior toconstruction, this condition has been assessed as an administrative non-compliance.The GMP has been prepared to address the re-profiling of the existing landfillonly and does not include the GO Facility or the ARRT Facility. DPE providedapproval (letter dated 22.02.18) under SSD 6835, Condition B14, for theGMP to be submitted in two stages, the re-profiling (Stage 1) and the GOFacility and ARRT Facility (Stage 2).The auditors conducted a high level review of the GMP (dated January 2018)and found that the plan included:

· Monitoring locations including EPL reference number for surfacewater, leachate and groundwater, including figures.

· Monitoring point analytes and frequency of monitoring,· Groundwater investigations trigger levels based on the National

water quality management strategy. Australia and New ZealandGuidelines for Fresh and Marine Water Quality 2000 (ANZECC), EPLLimits and National Health and Medical Research Council (2011)drinking water criteria.

· A procedure for investigation, notification and mitigation.· The measures that would be adopted if sampling of groundwater

monitoring bores indicates any abnormality in the groundwater tests(‘Groundwater Contamination Response Plan’).

2018-IEA-REC13: Submitthe updated GMP to EPA,DPI Water and DPE.


A19 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsGroundwater MonitoringC36 The Applicant shall re-establish historic groundwater monitoring bores (BH24,

BH31, MB021 and MB022) to improve detection of leachate in groundwatersystems to the north of the site. The Applicant shall monitor groundwater fromthese bores in accordance with the requirements of an EPL for the site and thegroundwater management plan required under Condition C35.

Not verified Section 5.1 of the GMP provides an assessment of the requirement to re-install BH24, BH31, MB021 and MB022. Douglas Partners recommends thatBH31, MB021, BH24, MB022 are not re-instated. They have identified a gapin monitoring on the western site boundary, south of points MB305 andMB306, and therefore recommend installation of two bores in this area, priorto the commencement of operations at the GO Facility and ARRT Facility.Correspondence from DPI Water dated 10.08.17 also made the followingrecommendations:· Refurbishment of MB022.· An additional monitoring bore is strongly recommended to be installed

approximately positioned 100 to 120 m north-northwest of bores MB038–MB039. This new monitoring bore site is considered by DPI Water asan alternative to re-establishing the three northern bores (BH31, MB021and BH24) referred to in C36.

· Installation of this new nested monitoring bore site is stronglyrecommended by DPI Water and is proposed to be included as part ofthe ongoing development of the monitoring network and the landfill site.This additional monitoring bore is to be a nested bore, including twoscreens, a shallow screen and a deeper screen of similar depth toMB022.

SUEZ has acknowledged the last two recommendations and undertaken theinstallation of two new monitoring wells in December 2017. The installationreport for these two new monitoring wells is provided in Appendix H of theGMP. The GMP identifies that MB022 will not be reinstated.The four monitoring bores have not been added to the EPL in the DecemberEPL Variation.The auditors have not been able to adequately assess compliance againstthis condition, based on the ongoing consultation with DPI Water on therequirement to install these wells. The updated GMP should be submitted theEPA, DPI Water and DPE. Following their review, if agreed, SUEZ shouldseek a modification to remove/ modify this condition.

2018-IEA-REC14:Submit a modification tohave this conditionremoved if the EPA andDPI Water agree thatthese bores are no longernecessary.


A20 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsBundingC37 The Applicant shall store all chemicals, fuels and oils used on the site in

appropriately bunded areas in accordance with the requirements of all relevantAustralian Standards, and/or the EPA's Storing and Handling of Liquids:Environmental Protection - Participants Handbook.

Compliant The following fuel tanks and chemicals were stored on site at the time of thesite inspection:

· 60,000 L diesel tank used for refuelling collection vehicles in TPA· The 55,000 L diesel tank discussed in the previous audit report was

decommissioned (stored on site at the time of the audit) and replacedwith an aboveground double-skinned self bunded 60,000 L dieseltank (safe fill level 62,300 L). A second above ground double skinnedself bunded diesel 27,000 L tank was on site at the time of the audit.Select Civil reported that this tank would be removed from site.

· Waste oils in two 2,000 L tanks in the maintenance yard in a concretebund.

· Oils and coolants in intermediate bulk containers (IBCs), 205 L drumsand 20 L containers in the maintenance yard stored on single IBCbunded spill pallets.

· In-ground waste oil pit associated with oil water separator in themaintenance yard. Waste oil from the separator is stored in a 20 Lplastic container. Select Civil reported that minimal separated oil isgenerated. Waste oil is collected by Southern Oil Collections for off-site recycling.

· Dangerous Goods (DG) Class 3 (Flammable Liquids) including paintsand thinners, stored in a Flammable Goods cabinet.

Domestic quantities of waste were stored in the hazardous waste receipt areaprior to collection for off-site treatment. Materials include waste oils, wastepaints and batteries. These were stored in an undercover, bunded area.Select Civil is responsible for maintaining the Workshop area. Select Civil hasits own management systems and procedures for the storage of chemicals,fuels and oils including SC-WHS-005 ‘Storage & Handling of HazardousMaterials’.Chemicals, fuels and oils appeared to be stored in appropriately bundedareas.SUEZ had made a number of improvements to hydrocarbon managementsince the 2015 IEA including:

· Construction of a new lined and fenced stormwater pit at themaintenance area. Water from the pit is then manually pumped intothe dirty water drain, as required. The Site reported that they arereviewing the operation of the stormwater pit and may upgrade thewater treatment to include sediment capture.

· Replacement of concrete flooring in the workshop area, identified inthe 2015 IEA as damaged.

The following areas for improvement were noted by the auditors:· Drains and bunds did not appear to be well maintained. Drains and

bunds should be cleaned regularly to ensure capacity in the systemis maintained.

· The concrete bund with hydraulic oil had staining from where thehose is not correctly stored within the bund and product is leakingover the bund wall.

· The auditors observed that the drainage area within the concretebund for waste oil appeared to be blocked. The concrete bund drainsto an underground storage tank. The soil surrounding the tank coverappeared to be stained with oil.

· The workshop should be cleaned and areas for storage of oils, drumsand waste clearly marked and segregated.

Refer to main report, Section 6 for photos and recommendations relating tobund maintenance.

2018-IEA-OFI07:Management ofchemicals, fuels and oilsat the workshop is notcurrently detailed in theOEMP. SUEZ shouldupdate the OEMP toinclude a description ofthe workshop area, SelectCivils role andresponsibilities andoverview of worksundertaken and controlsimplemented.


A21 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsFINAL LANDFORM, REHABILITATION & CLOSUREFinal LandformC38 The Applicant shall rehabilitate the site to achieve the final landform shown in

Appendix C, in accordance with the criteria in the EPA's EnvironmentalGuidelines: Solid Waste Landfills, 2016, or its latest version.

Not triggered To be assessed in future audits.

C39 The Applicant shall ensure the height of the final landform does not exceed179.9 metres Australian Height Datum (AHO) post-settlement of the waste massand final capping, as described in the EIS.


Post-Closure PlanC40 The Applicant shall amend the draft Post-Closure Plan for the site, to the

satisfaction of the Secretary. The plan shall:(a) be prepared by a suitably qualified and experienced person;(b) be submitted to the EPA and the Secretary 12 months prior to the plannedclosure of the landfill, GO and ARRT Facilities on the site;(c) be approved by the EPA, Council, ANSTO and the Secretary, prior tocommencement of the final phase of landfill capping and rehabilitation works;(d) detail the requirements for on-going management of the capped waste mass;(e) describe monitoring and management measures to ensure integrity of thecap;(f) describe on-going leachate and surface water management, odour and dustcontrol;g) detail landfill gas monitoring and maintenance;(h) identify future land uses on the site, developed in consultation with Council,ANSTO, the Cronulla Model Aero Club and local recreational and sportinggroups;

(i) include a rehabilitation management plan, including, but not limited to:i) rehabilitation works as generally depicted in Appendix C;ii) criteria for evaluating the effectiveness of the rehabilitation;iii) a program and schedule to monitor the effectiveness of the rehabilitation;iv) a program and schedule for routine maintenance of the rehabilitation;v) any remedial actions necessary to ensure the success of therehabilitation;vi) a weed management plan; and

j) incorporate the post closure requirements detailed in the VPA.


VISUAL AMENITYC41 The Applicant shall undertake screen planting as shown on the plan in Appendix

D to minimise the visual impacts of the Development. The planting shall becompleted by January 2025, subject to agreement with ANSTO for works onANSTO's land. Evidence of implementation of the planting shall be provided tothe satisfaction of the Secretary, within one month of completing the planting.


C42 The Applicant shall progressively hydro-mulch and grass completed landfillareas to minimise the visual impacts of the Development.

Not triggered At the time of the audit no areas of the landfill had been completed.

BIODIVERSITYConstructionC43 The Applicant shall prepare a Vegetation and Fauna Management Plan to

minimise impacts on biodiversity during construction of the GO and ARRTfacilities, to the satisfaction of the Secretary. The plan shall:(a) be prepared by a suitably qualified and experienced ecologist;(b) be submitted to the Secretary, prior to the commencement of construction ofthe GO and/orARRT Facility, whichever is sooner;(c) include a vegetation clearing protocol and pre-clearance surveys;(d) detail specific procedures for protecting native vegetation, including theCoastal Upland Swamp, and fauna adjacent to construction areas, including theaccess track near the GO Facility, the sediment pond north of the ARRT Facilityand the verge adjacent to Heathcote Road;(e) detail erosion and sediment controls and weed management procedures; and(f) include procedures for seed collection and translocation of key species,including Allocasuarina diminuta subsp. Mimica and Acacia bynoeana.

Not triggered Construction of the new GO and ARRT facilities had not commenced at thetime of the audit.


A22 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsC44 The Applicant shall appoint a qualified and experienced ecologist to be present

on site during native vegetation clearing for construction of the GO and ARRTfacilities and realignment of Mill Creek.


Biodiversity Offset StrategyC45 The Applicant shall purchase and retire the ecosystem and species credits listed

in Table 1, in accordance with OEH's Frameworks for Biodiversity Assessment2014 and the NSW Biodiversity Offsets Policy for Major Projects 2014, to thesatisfaction of the Secretary. The credits shall be purchased and retired prior toconstruction of the relevant facility listed in Table 1.

Table 1: Biodiversity Offset Strategy

Facility No. of Credits Offset TypeGO Facility 185 ecosystem Red Bloodwood –

Scribbly Gum Healthywoodland on sandstoneplateaux

97 species Eastern Pygym-possumARRT Facility 143 ecosystem Red Bloodwood –

Scribbly Gum Healthywoodland on sandstoneplateaux

88 species Eastern Pygym-possum5154 species Allocasuarina diminuta

subsp. Mimica

Note: The areas referred to in Table 1 are shown on the figures in Appendix A.


C46 The Applicant shall not commence construction of a facility listed in Table 1, untilthe Biodiversity Offset Strategy for that facility has been implemented, to thesatisfaction of the Secretary.


C47 The Applicant shall ensure the biodiversity offsets are secured by a conservationmechanism, which protects and manages the land in perpetuity, to thesatisfaction of the Secretary.


TRANSPORT AND ACCESSConstruction Traffic Management PlanC48 The Applicant shall prepare a Construction Traffic Management Plan for

construction of the GO and ARRT facilities. The plan shall:(a) be prepared by a suitably qualified and experienced expert, in consultationwith Council and RMS;(b) be submitted to the Secretary, prior to the commencement of construction ofthe GO and/or ARRT Facility;(c) detail the measures to be implemented to ensure road safety and networkefficiency during construction;(d) detail heavy vehicle routes, access and parking arrangements;(e) include a Driver Code of Conduct to:

• minimise the impacts of construction works on the local and regional roadnetwork;• minimise conflicts with other road users;• ensure truck drivers use specified routes;

(f) include a program to monitor the effectiveness of these measures; and(g) if necessary, detail procedures for notifying residents and the community, ofany potential disruptions to routes.



A23 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsIntersection Safety ReviewC49 The Applicant shall conduct a safety review of the Little Forest Road and New

Illawarra Road intersection in the years 2020 and 2025 to ensure the on-goingsafe and efficient performance of the intersection. The safety reviews shall beprepared to the satisfaction of the Secretary and shall:(a) be prepared by an independent traffic expert;(b) be undertaken in consultation with Council and RMS and in accordance withrelevantguidelines;(c) be approved by the Secretary and RMS, by the end of 2020 and 2025;(d) analyse vehicle movements and delays during peak periods;(e) establish intersection performance and the need for any intersection upgradeworks; and(f) include a program for implementation of intersection upgrade works, ifrequired.


C50 The Applicant shall implement the recommendations of the safety reviews,including any required intersection upgrades, to the satisfaction of the Secretaryand RMS. The timing and payment for implementation of any requiredintersection upgrades shall be agreed with the Secretary and RMS.


Operating ConditionsC51 The Applicant shall ensure:

(a) all staff vehicles, plant and equipment are parked on site and do not park onthe public road network;(b) all loading and unloading of materials is carried out on site;(c) all trucks entering or leaving the site with loads have their loads covered;(d) vehicles do not track dirt onto the public road network; and(e) heavy vehicles use designated routes to minimise impacts on the local andregional road network.

Compliant a) During the site inspection no parked vehicles, plant or equipment wassighted on the public road network.b) the site has a weighbridge which directs vehicles to the appropriate areasfor unloading. No dumped rubbish was sighted by the auditors.c) The auditors did not identify any uncovered loads during the siteinspection.d) the wheel wash was observed to be operational and used by trucks duringthe site inspection. The vehicle wheel wash is open every day. During wetweather conditions all vehicles which access the tip face must use the wheelwash. During dry conditions the wheel wash is optional.e) SUEZ implemented the following measures for heavy vehicles:- Implementation of the Site’s Traffic Management Plan- SUEZ has Heavy Vehicle PBS Authorisation permit for a number of itstrucks (quad-axle mostly used to transport waste from transfer stations) whichspecifies which designated routes they can use.- SUEZ sub-contractor (e.g. Bulkways) tool box drivers on designated routes- SUEZ trucks are fitted with GPS monitoring. If a vehicle deviates from routean alert is sent to the head office.

ParkingC52 The Applicant shall provide sufficient parking facilities for site personnel and

heavy vehicles on the site, to ensure traffic associated with the site does notutilise public and residential streets or public parking facilities.

Compliant Site observations indicated that parking facilities are sufficient for theworkforce and heavy vehicles.


A24 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsNOISEHours of WorkC53 The Applicant shall comply with the hours detailed in Table 2, unless otherwise

agreed in writing by the EPA or the Secretary.Table 2: Hours of WorkFacility Activity Day TimeLandfill Construction Monday - Friday 7 am – 5pm

Saturday - Sunday 8 am – 5pmOperation Monday - Friday 6 am – 5pm

Saturday - Sunday 8 am – 5pmOther operations1 Monday - Sunday Anytime

GO Facility Construction Monday - Friday 7 am – 5pmSaturday - Sunday 8 am – 5pm

Operation Monday - Friday 6 am – 5pmSaturday - Sunday 8 am – 5pm

Other operations2 Monday - Sunday AnytimeARRT Facility Construction Monday - Friday 7 am – 5 pm

Saturday - Sunday 8am -5 pmOperation Monday - Sunday Anytime

Notes:1 Other landfilling operations includes only security guard control, machinerymaintenance and/or repairs, site infrastructure maintenance and/or repairs (landfill gasand leachate), and emergency management activities related to site safety, emergencyrepairs and site infrastructure repairs2 Other GO operations includes only repair works, machinery maintenance and repairs,loading bunkers, final product preparation manufacture (but does not include shredding)and emergency management activities related to site safety, emergency repairs and siteinfrastructure repairs. Unloading bunkers is only permitted between the hours ofoperations listed under 'GO Facility - Operation' in Table 2.

Compliant The Site operated from 6am to 4pm during the audit period from Monday –Friday. The site operated from 8am to 4pm Saturdays and Sundays. SUEZreported that a security guard locks the gates at 4:30pm. The auditorsobserved the security guard was present at the gate at 5:30 pm.SUEZ reported that the garbage trucks leave the TPA at 5 am; however nowaste is accepted before 6 am when the weighbridge opens.SUEZ reported that they are in the process of applying for a modification tothe consent to change the operational hours to between 5 am and 5 pm.The GO Facility and ARRT Facility were not constructed that the time of theaudit.

Operational Noise LimitsC54 The Applicant shall ensure noise from the site does not exceed the noise limits

in Table 3.Table 3: Noise Limits dB(A)No. Location Day Evening Night Night

Leq(15min) Leq(15min) Leq(15min) Leq(1min)R1 Engadine 35 35 35 45R2 Barden Ridge 35 35 35 45

R3 Menai 35 35 35 45

R6 Gandangara 37 37 37 45

R7 Gandangara North 35 35 35 45

Note:· To identify a noise receiver location, refer to the figure in Appendix E.· Noise generated on the site is to be measured in accordance with the relevant

procedures and exemptions (including certain meteorological conditions) of theEPA's NSW Industrial Noise Policy.

Compliant SUEZ commissioned an annual noise assessment as required underCondition C56. The assessment found that Site complied with the noise limitsprovided in Table 3. Refer to condition C56 for further information.


A25 of 74

Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsNoise ManagementC55 The Applicant shall implement the noise management measures described in

the OEMPs for the LHRRP, GO and ARRT facilities to ensure noise from the sitecomplies with the limits in Table 3.

Compliant This condition has been assessed for the LHRRP. The GO Facility and ARRTFacility had not been constructed at the time of the audit.The OEMP for the LHRRP includes a number of preventative, mitigation andrectification measures. These were observed to be generally undertaken atthe site.In addition a number of activities are required under the OEMP. The followingobservations are noted for each:

· The site is inspected for excessive noise levels – daily. The auditorsnoted that the Landfill Daily Checklist includes a check of “noise (onand off-site)”. No further detail is provided on how this assessment isundertaken.

· Maintenance of machinery – as required. Maintenance of plant andequipment is discussed under condition B11.

· Checking machinery for excessive noise – quarterly. SUEZ reportedthat quarterly monitoring began in October 2017. Select Civil conductthe monitoring and record the results in a ‘Noise Monitoring RecordSheet’. SUEZ provided the auditors with a copy of the testsundertaken on the 24.10.17 for a Dozer and 836 Compactor. Bothmachines measured below 85dB.

· Recording noise complaints – on occurrence. No noise complaintswere received during the audit period.

· Recording of noise volumes at strategic points across the site – asrequired. SUEZ provided the auditors with a copy of the noisemonitoring results for monitoring undertaken at the Bike Club,Harrington’s Gate, Workshop, Tip Face and Boundary Fence (LH2Noise May 2012 – Present.xls). Noise monitoring was undertaken bythe SUEZ EQS Officer on the 14.02.17, 02.06.17, 05.10.17 and the02.01.18. Section 8.8.4 of the OEMP includes performance indicatorsfor noise monitoring. The auditors note that the performance criteriawithin the OEMP do not reflect the noise limits provided in ConditionC54. The performance limits include the Site’s previous consent (DA11-01-99). Therefore this monitoring was not able to be interpretedby the auditors against the criteria provided in Table 3.

A detailed assessment of the adequacy of the OEMP has been provided inSection 7 on the report.Based on the observations during the site inspection and no complaints beingreceived related to noise during the audit period this condition is consideredto be compliant.

2018-IEA-REC15:The following updates tothe OEMP arerecommended:· Include a noise

monitoring procedureappropriate formeasuring noise levelsin accordance withCondition C54. Theprocedure shouldinclude the locations,frequency and timing ofmonitoring to beundertaken by the Site.In addition anexplanation of how theresults will be used andwhat actions will betaken to addressexceedances of thecriteria should beprovided.

· Include the requirementto undertake annualnoise monitoring inaccordance withCondition C56.

Noise MonitoringC56 The Applicant shall monitor noise from the site to demonstrate compliance with

the noise limits in Table 3. The monitoring shall be:(a) undertaken annually, or to address genuine noise complaints that are relatedto the site as determined by the EPA or the Secretary;(b) in accordance with the NSW Industrial Noise Policy; and(c) reported to the EPA and the Secretary within one month of completing themonitoring, including details of management actions taken and the effectivenessof the actions to address any exceedances of the limits in Table 3.

Compliant a) During the audit period the annual compliance noise monitoring wasundertaken by Wilkinson Murray Pty Ltd. Monitoring was undertakenat the five receptors listed in Condition C54. The audit found that “nonoise from Site was audible at any time at locations R7, R1, R2 andR3. Noise from Site was audible at times at location R6 however onlywhen the sound power level (SPL) fell to around 32dBA. Theestimated noise from the LHRRP therefore complies with theconditions (C54) at all locations”.

b) Wilkinson Murray state in Section 1 of the report, that theassessment was conducted in accordance with the NSW EPAIndustrial Noise Policy.

c) Noise monitoring was undertaken on the 25.10.17.The Annual Compliance Noise Monitoring report, dated November2017, was submitted to both the DPE and EPA via email dated23.11.17.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsLITTER AND PEST CONTROLC57 The Applicant shall:

(a) ensure all waste loads are covered;(b) inspect and clear the site (and if necessary, surrounding area) of litter arisingfrom the Development on a daily basis; and(c) maintain the site in a clean and tidy state at all times.

Compliant a) The majority of waste trucks are enclosed bodies. The weighbridge hascameras installed to check that loads are covered upon entering andexiting the Site.

b) The Site undertook the following during the audit period:· Landfill Daily Checklist completed by Select Civil. The checklist

includes notes on litter picking completed and whether litter fencing isin place.

· Landfill Weekly Checklist completed by SUEZ. The checklist includesinspection of litter screens, site boundary and identification of litterbeyond the site boundary. Comments included “litter pickers onsite toaddress tip face area” and “Litter cleared from site NE corner”.

· Select Civil, under a requirement of the VPA, reportedly undertookmonthly litter patrols on New Illawarra Road up to the intersection ofHeathcote Road and the conservation area.

c) The Site entrance and landfill areas were observed to generally be cleanand tidy. The auditors observed the following areas for improvement formaintaining the site in a clean and tidy state:· The TPA had litter collected on the fence boundary within the site,

including a number of damaged mobile garbage bins.· The stormwater drains in the TPA appeared be full of sediment and

required cleaning.

2018-IEA-OFI08:Check that the weeklychecklist includesinspecting the TPA forlitter and stormwaterinfrastructure and updateif required.

C58 The Applicant shall:(a) implement measures to manage pests, vermin and declared noxious weedson site; and(b) inspect the site routinely to ensure the measures are effective, and pests,vermin or noxious weeds are not present on site in sufficient numbers to pose anenvironmental hazard, or cause the loss of amenity in the surrounding area.Note: For the purposes of this condition, noxious weeds are those speciessubject to an order declared under the Noxious Weed Act 1993.

Compliant Section 8.9 of the LHRRP OEMP includes a management strategy for weeds,pest and vermin.SUEZ reported that it engaged a weed and vermin contractor (Rentokil) toundertake monthly inspections of the Site, including LH1, between Januaryand December 2017. In October, inspection of LH1 was reportedly reduced toonce every two months. The auditor sighted the Landfill Monthly Checklistsfor the audit period which included the Rentokil inspections.SUEZ participates in a co-operative control program for rabbits, cats, foxes,dogs and deer with SCC. The program is managed by SCC with SUEZcontributing financially and by providing access to the site. The auditorsreviewed an email from SSC, dated 11.04.18, which identified that during2017, 14 pest animal cullings were completed using mobile vehicle basedoperations.SUEZ also participates in an integrated control program for noxious weedswith SCC, Crown Lands, Department of Defence and ANSTO. An annualprogram is prepared identifying the weeds to be targeted, the program outlineand treatment method. The program is administered by SCC with SUEZcontributing financially and allowing access to the site. In 2017, the Councildid not carry out the weed control due to a shortage of staff (email dated11.04.18). SUEZ contacted SCC on 2.08.17 regarding the weed controlprogram and since then SSC has conducted a weed inspection. Select Civilarranged weed spraying during the week ending 3.09.17, for areas on thelandfill with pampas grass and castor oil plants.

HERITAGEUnexpected Finds ProtocolC59 If Aboriginal objects are uncovered during construction, work in the immediate

area must stop and the Regional Operations Group of the OEH, Council and theRegistered Aboriginal Parties are to be consulted.

Not triggered No excavation outside of the landfill footprint has been undertaken during theaudit period.

C60 If any archaeological relics are uncovered during the course of the work, then allworks shall cease immediately in that area and the OEH Heritage Branchcontacted. Depending on the possible significance of the relics, anarchaeological assessment and an excavation permit under the NSW HeritageAct 1977 may be required before further works can continue in that area.

Not triggered No excavation outside of the landfill footprint has been undertaken during theaudit period.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsSite Impact RecordingC61 Within one month of the date of this consent, the Applicant shall submit Site

Impact Recording Forms to OEH for the four previously impacted Aboriginalheritage sites, AHIMS 52-2-1 108, 52-2-1029, 52-2-1030 and 52-2-1031 , asdescribed in the EIS.


Consent was granted on the 23.01.17. Site Impact Recording Forms for thefour previously impacted Aboriginal Heritage Sites, AHIMS 52-2-1108, 52-2-1029, 52-2-1030 and 52-2-1031 were prepared on the 22.03.17. These formswere submitted to OEH Heritage Branch via email dated 07.04.17. OEHconfirmed acceptance via email dated 10.04.17.Based on the submission of these reports more than one month after consentwas granted this condition has been assessed as an administrative non-compliance.

FIRE PREVENTION & MANAGEMENT

C62 The Applicant shall:(a) design and construct the GO and ARRT Facility buildings to meet the firesafety requirements of the SCA; and(b) maintain a 10 metre wide Asset Protection Zone around the northern andwestern sides of the GO and ARRT Facility buildings.


C63 The Applicant shall prepare an Emergency Response Plan for the site detailingprocedures to be implemented in the event of a fire on or near the site. TheEmergency Response Plan shall:(a) be prepared by a suitably qualified and experienced expert in consultationwith Council and the NSW Rural Fire Service;(b) be submitted to the Secretary within three months of the date of this consent,or an alternative timing as otherwise agreed with the Secretary; and(c) detail emergency access and egress routes, including an alternative accessroute, escape routes, refuge areas, assembly points and evacuation procedures.


The ERP has been prepared to provide procedures for 23 types ofemergency incidents, including fires on site at the greenwaste/mulch/compostand landfill surface, underground (in the landfill waste) and fire in receivedwaste loads and fires off-site at adjacent properties.The ERP was prepared initially in 2013 and has been updated most recentlyin August 2017. The ERP was prepared and revised by a number of SUEZstaff. The most recent update was completed by the Site’s ComplianceOfficer in consultation with NSW Rural Fire Service.The ERP was provided to the NSW Rural Fire Service on the 14.03.17. TheNSW Rural Fire Service provided comments on the ERP on the 6.05.17. Inparticular the NSW Rural Fire Service requested that emergency proceduresinclude triple zero notification to all fires, irrespective of size. The auditorsreviewed the ERP and found that SUEZ had incorporated these commentsinto the ERP.The ERP was provided to the SCC in March 2017 for consultation. SCCprovided comments via email dated 2.05.17. The auditors reviewed thecomments and found that some of the comments had been incorporated intothe ERP dated 21.08.17.b) The ERP was sent to DPE on 23.08.17. The consent was granted on the23.01.17.c) The ERP includes an Evacuation Diagram however this appears to be onlyof the resource centre and not the entire site. For example it does not detailalternative access / egress routes from the landfill or existing GO Facility.This condition has been assessed as an administrative non-compliance asthe ERP was not submitted to the DPE within three months of the consentbeing granted. It is noted the relevant agencies required approximately twomonths to provide comments on the draft ERP.

2018-IEA-OFI09:Update the EvacuationDiagram within the ERP toinclude the entire site anddetail alternative access /egress routes from thelandfill and existing GOfacility.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsENVIRONMENTAL MANAGEMENTConstruction Environmental Management PlanD1 The Applicant shall prepare a Construction Environmental Management Plan

(CEMP) for the Development, to the satisfaction of the Secretary. The Planmust:(a) be prepared in consultation with Council and be approved by the Secretaryprior to construction of the Development;(b) identify the statutory approvals that apply to the site;(c) outline all environmental management practices and procedures to befollowed during construction;(d) describe all activities to be undertaken on the site during construction,including a clear indication of construction stages;(e) detail how the environmental performance of the construction works will bemonitored, and what actions will be taken to address identified adverseenvironmental impacts;(f) describe the roles and responsibilities for all relevant employees involved inconstruction works; and(g) include the management plans under Condition D2 of this consent.

Non-compliant As per the definitions of the consent, construction means:“As described in the EIS, including:

· Landfill re-profiling, stripping back covered areas and landfilling ontop of existing waste;

· Construction of the GO Facility, earthworks, hardstand, internalaccess road, water and leachate infrastructure, waste receivals andsorting areas, compost bunkers and storage areas;

· Construction of the ARRT Facility, earthworks, hardstand, buildings,biofilters, water infrastructure; and

· Mill Creek re-alignment.”During the audit period the following construction works had commenced:

· Landfill re-profiling, stripping back covered areas and landfilling ontop of existing waste.

SUEZ reported that as the bulk of construction works had not commenced(construction of the ARRT and GO facility) a separate CEMP for the re-profiling works had not been prepared. Instead these works wereincorporated into the OEMP, required under Condition D2.The OEMP did not make it clear that it was incorporating the requirements ofD1 for the re-profiling works into the OEMP nor was this communicated to theDPE in its submission of the OEMP via email on the 23.08.17.Approval from DPE for the LHRRP OEMP had not been received at the timeof the audit. On the basis that the OEMP had not been approved prior tocommencement of landfill re-profiling works, this condition is considered non-compliant.

2018-IEA-REC16:Make it clearer within theOEMP that it alsoincorporates therequirements of ConditionD1 for a CEMP for theworks associated with re-profiling, stripping andlandfilling on top ofexisting waste and seekDPE approval of thisapproach.

D2 As part of the CEMP for the Development, required under Condition D1 of thisconsent, the Applicant shall include the following:(a) a construction management plan for the dual gas and leachate trenchprepared in consultation with EPA (Condition C23);(b) an erosion and sediment control plan;(c) a vegetation and fauna management plan (Condition C43); and(d) a construction traffic management plan (Condition C48).

Compliant a) A stand-alone CEMP for the dual gas and leachate trench had beenprepared, as discussed in Condition C23. The EPA approved the CEMPin a letter dated 10.10.17.

b) Not triggered during audit periodc) Not triggered during audit periodd) Not triggered during audit period

D3 The Applicant shall carry out construction of the Development in accordancewith the CEMP approved by the Secretary (and as revised and approved by theSecretary from time to time), unless otherwise agreed by the Secretary.

Non-compliant SUEZ reported that the CEMP for the dual gas and leachate trench had notbeen submitted to Secretary at the time of the audit.It is recommended that SUEZ seek a staged submission of the CEMP,required under Condition D1 and D2 (as permitted by Condition B14) to allowsubmission of the CEMP for the dual gas and leachate trench separately tothe CEMP for the construction works.

2018-IEA-REC17:Seek a staged submissionof the CEMP, requiredunder Condition D1 andD2 to allow submission ofthe CEMP for the dual gasand leachate trenchseparately to the CEMPfor the construction works.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsOperational Environmental Management PlanD4 The Applicant shall amend the draft Operational Environmental Management

Plan (OEMP) for the Landfill, GO and ARRT Facilities, to the satisfaction of theSecretary. The Plans must:(a) be prepared in consultation with Council and be approved by the Secretaryprior to operation of the Development;(b) identify the statutory approvals that apply to the site;(c) outline all environmental management practices and procedures to befollowed during operation;(d) detail how the environmental performance of the Development will bemonitored, and what actions will be taken to address identified adverseenvironmental impacts; and(e) include the management plans under Condition D5 of this consent.


As per the definitions of the consent, operations means:“As described in the EIS, includes receipt, processing and landfilling waste onthe re-profiled landfill and at the GO and ARRT facilities”Landfilling waste on the re-profiled area began in January 2018.

SUEZ was required to update the Draft LHRRP OEMP prepared as part ofthe EIS (EIS Appendix S). The LHRRP OEMP, dated 13.10.17 replaced theLandfill Environmental Management Plan (LEMP) for the Site and relates toactivities associated with landfilling and re-profiling. The Draft OEMPs for theGO Facility or ARRT Facility prepared as part of the EIS (Appendices T andU respectively) had not been updated at the time of the audit. SUEZ reportedthat the OEMP would be updated to cover these activities and the associatedmanagement measures when the design and construction of the GO Facilityand ARRT Facility was underway and prior to their operation as per thiscondition. DPE approved this staged approach by letter dated 22.02.18.

a) Evidence of consultation with SCC was sighted by the auditors, as aseries of emails dated between the 10.01.17 and 14.03.17.

The OEMP was submitted to the DPE via email on the 23.08.17.Approval from DPE for the LHRRP OEMP had not been received at thetime of the audit.

b) The OEMP states that it has been prepared to address the followingstatutory requirements:

· SSD 6835;

· EPL 5065;

· ANSTO Lease;

· VPA.

The OEMP identifies that the Site holds other EPLs for the GO Facilityand PCYC minibike club but does not incorporate the requirements ofthese EPLs. There is an opportunity for the OEMP to capture therequirements of the PCYC EPL to ensure the requirements of the EPLare not missed. The GO Facility has a separate OEMP.

c) The OEMP includes a number of sections on the environmentalmanagement of the Site including surface water, leachate, landfill gas,odour, dust, litter, noise, weeds, traffic and emergency preparedness. Itwas noted that the OEMP needs to be updated to include the updatedrequirements of EPL 5065, varied on 07.12.17.

d) The OEMP includes a section on the monitoring requirements requiredunder this consent and EPL 5065. As identified above this plan requiresupdating to reflect the updated EPL 5065. In addition the monitoringrequirements of PCYC EPL 13114 should be included to capture all theregulatory monitoring requirements. In addition Appendix C includes asummary of the monitoring reporting requirements for the Site. TheOEMP also includes a description of ‘rectification measures’; whichwould be implemented in the event that an environmental incidentoccurs.

e) Refer to Condition D5.Refer to the main report for further discussion of the adequacy of the OEMP.This condition has been assessed as an administrative non-compliance asapproval from the DPE had not been received prior to operationscommencing in January 2018.

2018-IEA-OFI10:There is an opportunity forthe OEMP to capture therequirements of the PCYCEPL to ensure therequirements of the EPLare not missed.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsD5 As part of the OEMP's for the Development, required under Condition D4 of this

consent, the Applicant shall include the following:(a) site air quality and odour management plan (Condition C11);(b) ARRT Facility air quality and odour management plan (Condition C17);(c) biofilter and pre-treatment monitoring and maintenance plan (Condition C18);(d) aquatic habitat monitoring plan (Condition C33);(e) Mill Creek stream rehabilitation, stabilisation and vegetation managementplan (Condition C34);(f) groundwater management plan (Condition C35); and(g) emergency response plan (Condition C63).


The following plans have been attached the OEMP, dated 13.10.17:· Emergency Response Plan, dated 2.03.17

At the time of the audit the AQOMP (Condition C11) and the GMP (ConditionC35) were not attached to the OEMP.At the time of the audit the management plans required under ConditionsC17, C18, C33 and C34 were not required to be prepared. Therefore therequirement to include the plans with the OEMP had not been triggered.The auditors noted that the OEMP document did not include the attachmentswithin the Appendices headings. SUEZ should review the documentscontained it the appendices of the OEMP and revise as required.

2018-IEA-REC18:Review the documentscontained it theappendices of the OEMPand revise as required,including attachment ofthe most recent plansunder this condition,AQOMP and GMP.

D6 The Applicant shall operate the Development in accordance with the OEMP'sapproved by the Secretary (and as revised and approved by the Secretary fromtime to time), unless otherwise agreed by the Secretary.

Compliant A detailed assessment of the implementation of the OEMP was notundertaken, however, in general, the site appeared to be operated inaccordance with the OEMP. This includes complaints management, incidentmanagement and reporting, monitoring requirements, reporting requirementsand operational controls.

Management Plan RequirementsD7 The Applicant shall ensure the Management Plans required under this consent

are prepared in accordance with any relevant guidelines, and include:(a) detailed baseline data;(b) a description of:i) the relevant statutory requirements (including any relevant approval, licence orlease conditions);ii) any relevant limits or performance measures/criteria; andiii) the specific performance indicators that are proposed to be used to judge theperformance of, or guide the implementation of, the Development or anymanagement measures;(c) a description of the measures that will be implemented to comply with therelevant statutory requirements, limits, or performance measures/criteria;(d) a program to monitor and report on the:i) impacts and environmental performance of the Development; andii) effectiveness of any management measures (see (c) above);(e) a contingency plan to manage any unpredicted impacts and theirconsequences;(f) a program to investigate and implement ways to improve the environmentalperformance of the Development over time;(g) a protocol for managing and reporting any:i) incidents;ii) complaints;iii) non-compliances with statutory requirements; andiv) exceedances of the impact assessment criteria and/or performance criteria;and(h) a protocol for periodic review of the plan.Note: The Secretary may waive some of these requirements if they areunnecessary or unwarranted for particular management plans.

Compliant The following plans had been prepared at the time of the audit, for reviewunder this condition:

· OEMP· AQMP· GMP

In general the plans appeared to address the requirements of this condition.A more detailed assessment of the adequacy of the management plans isprovided in the main report.

Revisions to Strategies, Plans and ProgramsD8 Within three months of:

(a) an audit submitted under Condition D12;(b) an incident report under Conditions D10 and D11;(c) an annual review under Condition D9; and/or(d) a modification to this consent,the Applicant shall review, and if necessary, revise the strategies, plans, andprograms required under this consent to the satisfaction of the Secretary.Note: This is to ensure the strategies, plans and programs are updated on aregular basis, and incorporate any recommended measures to improve theenvironmental performance of the site.

Not triggered This requirement was yet to be triggered during the audit period.The condition will be triggered following submission of this audit report andsubmission of Annual Review in February.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsREPORTINGAnnual ReviewD9 By the end of December each year, and annually thereafter, the Applicant shall

review the environmental performance of the site, to the satisfaction of theSecretary. This review must:(a) be submitted to the Secretary by the end of February each year;(b) describe the operations that were carried out in the past year;(c) analyse the monitoring results and complaints records of the site over thepast year, including a comparison of these results against the:i) relevant statutory requirements, limits or performance measures/criteria;ii) monitoring results of previous years;iii) predictions in the EIS;(d) identify any non-compliance over the last year, and describe what actionswere (or are being) taken to ensure compliance;(e) identify any trends in the monitoring data;(f) identify any discrepancies between the impacts predicted in the EIS and theactual impacts of the site and analyse the potential cause of any significantdiscrepancies; and(g) describe what measure will be implemented over the next year to improvethe environmental performance of the site.

Not triggered The Annual Review was in the process of being prepared for submission inFebruary 2018.

Incident ReportingD10 Upon detecting an exceedance of the limits/performance criteria in this consent

or the occurrence of an incident that causes (or may cause) material harm to theenvironment, the Applicant shall immediately (or as soon as practical thereafter)notify the Secretary and any other relevant agencies of the exceedance/incident.

Not triggered The Site did not report any exceedances of the noise limits specified in thisconsent during the audit period.SUEZ reported that no environmental incidents occurred during the auditperiod.

D11 Within seven days of the date of the incident, the Applicant shall provide theSecretary and any relevant agencies with a detailed report on the incident, andsuch further reports as may be requested.

Not triggered SUEZ reported that no environmental incidents occurred during the auditperiod.

INDEPENDENT ENVIRONMENTAL AUDITD12 Within one year of the date of this consent, and every three years thereafter,

unless the Secretary directs otherwise, the Applicant shall commission and paythe full cost of an Independent Environmental Audit of the site. The audit must:(a) be carried out by a suitably qualified, experienced and independent auditteam whose appointment has been endorsed by the Secretary;(b) assess the environmental performance of the site, and its effects on thesurrounding environment;(c) determine whether the site is complying with the relevant standards,performance measures and statutory requirements;(d) review the adequacy of the Environmental Management Plans for the site,compliance with this consent, and any other licences and consents; and, ifnecessary;(e) recommend measures or actions to improve the environmental performanceof the site, and/or any plan/program required under this consent.

Compliant This report presents the findings of the first independent environmental audit(site inspections undertaken on the 22 and 23 January 2018).As this audit has been conducted within one year of the consent (dated23.01.17) the timing of the audit is compliant with this condition.a. The audit was conducted by suitably qualified and experienced auditors

from AECOM. Helen Onus (lead auditor), Katherine Dodd (auditor),Chani Lokuge (Technical Reviewer) were approved by the DPE by letterdated 1.11.17.

b. The environmental performance of the site is assessed in Section 5.c. Refer to relevant CoC conditions requiring assessment of relevant

standards, performance measures and statutory requirements.d. Refer to the main report for a review of the adequacy of the EMPs

required under this consent. This report presents the findings of theassessment of compliance with the CoC, EPL 5065, EPL 12520 andEPL 13114.

e. A number of recommendations have been made through this report.These recommendations are summarised in Section 8.

D13 Within three months of commissioning the audit, or as otherwise agreed by theSecretary, the Applicant shall submit a copy of the audit report to the Secretarywith a response to all recommendations contained in the audit report.

Not triggered Not triggered during the audit period. To be assessed in the next audit.


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Condition No Summary of Condition/Requirement Compliance Status Comment RecommendationsCOMMUNITY ENGAGEMENTCommunity Reference GroupD14 The Applicant shall establish and maintain a Community Reference Group

(CRG) to maintain regular communication with the local community regardingactivities on the site, any environmental impacts, monitoring results andmanagement actions. The CRG shall include representatives from the localcommunity, recreational and sporting clubs, ANSTO, Council and the Applicant.The CRG shall meet on a quarterly basis.

Compliant The Community Reference Group (CRG) was operational during the auditperiod. The CRG is chaired by the SUEZ Stakeholder Engagement Managerand includes community members, community groups e.g. Menai WildflowerGroup and SUEZ. Invitees also include ANSTO and the meetings areoccasionally attended by local and state members of parliament. Themeetings are held quarterly (sighted example meeting minutes for 9.03.17,8.06.17, 7.09.17 (draft) and 23.11.7 (draft) and members are invited on a sitetour annually (last conducted on 07.09.17).A review of the meeting minutes noted that the meetings include updates onoperations, environmental matters, developments and LH1 and include asummary of outstanding actions.The Environmental update is an attachment to the minutes. The attachmentswere not provided on the website.

2018-IEA-OFI11:Ensure the Appendices tothe Meeting Minutes(which includes theenvironmental update) areuploaded to the SUEZwebsite.

Access To InformationD15 The Applicant shall make the following information publicly available on its

website and keep the information up to date.(a) the EIS, RTS, CEMP and OEMPs;(b) current statutory consents, approvals and licences for the site;(c) approved strategies, plans and programs;(d) a summary of all monitoring data for the site as required under this consent;(e) a complaints register, updated on an annual basis;(f)Annual Reviews, Independent Environmental Audits and the Applicant'sresponse to the recommendations; andg) any other matter required by the Secretary.

Note: This requirement does not require any confidential information to be madeavailable to the public.

Non-compliant The following information was available on the SUEZ website, when reviewedon the 27.02.18:

· A link to the EPA Register was provided to access EPL 5065 andEPL 12520.

· Development Consent (SSD 6835), dated 23.01.17.· The OEMP for the LHRRP, dated March 2017. It is noted that this is

not the most recent version of the OEMP. SUEZ needs to update thewebsite to include Version 2, dated 13.10.17. In addition theAppendices to the OEMP had not been attached the website.

· A link to the DPE Major Projects Assessment website for SSD 6835,which includes the EIS and RTS.

The following documents required under this condition were not provided onthe website:

· EPL 13114· Noise monitoring data from the annual noise monitoring report,

required under Condition C56.· Complaints register· Air quality and odour management plan (Condition C11)· Groundwater management plan (Condition C35), however it is noted

that this was updated on the 31.01.18, therefore would not have beenuploaded at the time of this audit

· Emergency response plan (Condition C63)· CEMP for the dual gas and leachate trench

Part (f) and (g) have not been triggered during the audit period.It is noted that additional monitoring data is provided on the website asrequired under the EPL.

2018-IEA-REC19:Review the requirementsof this condition andupload the requireddocumentation to theSUEZ website.


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1.2 EPL 5065ConditionNo.

Summary of Condition/Requirement ComplianceStatus

Comment Recommendations

A1.1 This licence authorises the carrying out of the scheduled activities listed below at thepremises specified in A2. The activities are listed according to their scheduledactivity classification, fee-based activity classification and the scale of the operation.

Unless otherwise further restricted by a condition of this licence, the scale at whichthe activity is carried out must not exceed the maximum scale specified in thiscondition.Scheduled Activity Fee Based Activity ScaleWaste processing(non-thermal treatment)

Non-thermal treatment ofliquid waste

Any annualprocessing capacity

Waste disposal(application to land)

Waste disposal by applicationto land

Any capacity

Waste storage Waste storage – other typesof waste

Any other types ofwaste stored

Waste storage Waste storage – waste tyres ˃ tyres stored

Noted Noted.

A2.1 The licence applies to the following premises:

Premises Details

LUCAS HEIGHTS RESOURCE RECOVERY PARK

NEW ILLAWARRA ROAD

LUCAS HEIGHTS

NSW 2234

LOT 1 DP 233333, LOT 2 DP 605077, PART LOT 101 DP 1009354, LOT 3 DP1032102, LOT 111 DP 1050235, LOT 4 DP 1149334, LOT 6 DP 1149334

EXCLUDING AREA DEFINED BY RED BOUNDARY AND LABELLED AS"GARDEN ORGANICS AREA" ON MAP TITLED "PLAN SHOWING THE POSITIONOF THE "GARDEN ORGANICS AREAS" WITHIN LOT 101 IN DP1009354 AT THELUCAS HEIGHTS 2 WASTE PROCESSING FACILITY", REFERENCE 12415ISSUE A, AND DATED 3 MARCH 2011.

EXCLUDING PART LOT 101 DP1009354 SHOWN ON THE MAP RECEIVED BYTHE EPA ON 6 MAY 2009 AND TITLED "PLAN SHOWING AREA LICENSED TOPCYC PART LOT 101 IN DP1009354 LUCAS HEIGHTS", DATED 28 APRIL 2009AND MARKED AS PROPOSED NEW BIKE TRACK AREA. MAP REF: 11925.

Noted Noted

A3.1 This licence applies to all other activities carried on at the premises, including:· Ancillary Activity

o Crushing, grinding or separating

Noted Noted

A4.1 Works and activities must be carried out in accordance with the proposal containedin the licence application, except as expressly provided by a condition of this licence.

In this condition the reference to "the licence application" includes a reference to:

a) the applications for any licences (including former pollution control approvals)which this licence replaces under the Protection of the Environment Operations(Savings and Transitional) Regulation 1998; and

b) the licence information form provided by the licensee to the EPA to assist the EPAin connection with the issuing of this licence.

Noted The application for the EPL and subsequent variations has not beenreviewed as part of this audit.


A34 of 74

ConditionNo.



P1.1 Location of monitoring/discharge points and areas

The following points referred to in the table below are identified in this licence for thepurposes of monitoring and/or the setting of limits for the emission of pollutants tothe air from the point.

Noted During the audit period EPL 5065 was varied on 17.12.17 to include thefollowing additional subsurface gas monitoring points 51, 52, 53 and 54.

At the time of the audit the OEMP, dated 13.10.17, had not been updatedto reflect the EPL variation therefore monitoring points 53 and 54 forsubsurface gas were not included in the OEMP.

2018-IEA-OFI12:

Update the OEMP to includethe most recent variation toEPL 5065.

P1.2 The following utilisation areas referred to in the table below are identified in thislicence for the purposes of the monitoring and/or the setting of limits for anyapplication of solids or liquids to the utilisation area.

Noted

P1.3 The following points referred to in the table are identified in this licence for thepurposes of the monitoring and/or the setting of limits for discharges of pollutants towater from the point.

Noted During the audit period EPL 5065 was varied on 17.12.17 to includeadditional groundwater monitoring points 44, 45, 46, 47, 48, 49, 50.

At the time of the audit the OEMP, dated 13.10.17, had not been updatedto reflect the EPL variation therefore monitoring points 47, 48, 49 and 50for groundwater monitoring were not included in the OEMP.

Quarterly sampling undertaken of surface water, groundwater andleachate points was prior to the EPL licence variation on the 17.12.17.Therefore all analysis was completed using the requirements of EPL5065, dated 17.07.17.

Refer to recommendationprovided in condition P1.1.


A35 of 74

ConditionNo.




A36 of 74

ConditionNo.



L1.1 Pollution of waters


Non-compliant Refer to SSD 6835, Condition C30.


A37 of 74

ConditionNo.



L2.1 Concentration limits

For each monitoring/discharge point or utilisation area specified in the table\s below(by a point number), the concentration of a pollutant discharged at that point, orapplied to that area, must not exceed the concentration limits specified for thatpollutant in the table.

Noted Reviewed under L2.4.

L2.2 Where a pH quality limit is specified in the table, the specified percentage ofsamples must be within the specified ranges.

Noted

L2.3 To avoid any doubt, this condition does not authorise the pollution of waters by anypollutant other than those specified in the table\s.

Noted

L2.4 Water and/or Land Concentration Limits Non-compliant Point 1 (MC 1)

SUEZ conducted monitoring at Point 1 31 times during the audit period.The concentration limits were exceeded for:

· Dissolved oxygen three times (5.2 mg/L, 5.2 mg/L and 5.3 mg/L).

· Total Suspended Solids (TSS) six times. The range of exceedanceswas between 60 mg/L and 210 mg/L.

Point 20 (DS002), 21 (DS001), 22 (OF001)

SUEZ reported that no discharges occurred from Point 20 during theaudit period.

Point 21 (DS001) is the point of discharge from the stormwater plant.SUEZ conducted monitoring at Point 21 25 times during the audit period.The sampling was triggered by wet weather and to establish thefreeboard in the main sediment dam. There were no exceedances ofpollutant limits at Point 21 during the audit period.

Point 22 (OF001) is the overflow point from sediment dam 5. SUEZconducted monitoring at Point 22 five times during the audit period. TheTSS concentration limit was exceeded five times with a range of 160-410mg/L.

This condition has been assessed as non-complaint on the basis of theexceedances of the dissolved oxygen limits at Point 1 and the TSSexceedance on the 25.03.17 which did not appear to be caused by asignificant rainfall event. (refer to L2.5 below). Condition L2.5 alsodiscusses what practical measures were implemented to minimise andavoid water pollution.

POINT 1


Conductivity Microsiemens percentimetre

1500

Dissolved oxygen Milligrams per litre 6

Nitrogen (ammonia) Milligrams per litre 2.5

pH pH 5.5 - 8.5

Phenol milligrams per litre 0.32


*NOTE: The 50 percentile concentration limit, 90 percentile concentration limit and3DGM concentration limit columns included in EPL 5065 have been removed fromthe table above as they had no values provided.

POINT 20,21,22


Nitrogen (ammonia) milligrams per litre 2.5


*NOTE: The 50 percentile concentration limit, 90 percentile concentration limit and3DGM concentration limit columns included in EPL 5065 have been removed fromthe table above as they had no values provided.

L2.5 The licensee is taken not to have breached the licence total suspended solidsconcentration limits for Point 1 and Point 22 if:

a) the overflow is caused by a rainfall event; and

b) the licensee has taken all practical measures to avoid or and minimise waterpollution.

Noted As stated above, TSS limits were exceeded at Point 1 and Point 22during the audit period. In order to assess whether the overflow wascaused by a rainfall event and whether all practical measures were takento avoid and minimise water pollution, the rainfall data (from the on-sitemeteorological station) for the two days prior to the exceedance eventwas reviewed and an assessment made as to whether the sedimentbasin design rainfall depth (34.8mm) was exceeded. The designinformation was obtained from the EIS for the proposed expansion(Appendix H Surface Water Assessment pg. 27, GHD 2015) which statedthat the enlarged Sediment Dam 5 was designed for a 34.8 mm rainfalldepth which is the 90th percentile 2-day depth for Sutherland Shire. The90th percentile was selected based on Blue Book Volume 2b WasteLandfills and the 2 day management period selected based upon thecapacity of the stormwater treatment plant and the size of the settlingzone volume required.

This approach aligns with Condition O6.8 which was added to the EPL onthe 7.12.17.


A38 of 74

ConditionNo.



Table: 2017 surface water quality exceedances and analysis of rainfall data for TSSexceedances

Date EPAPoint

TSS levelrecorded(mg/L)

Rainfallrecorded inprevious 2-day period

Did rainfall eventexceed basindesign criteria?(34.8 mm, 2-day)

17.03.17 1

22

60

160

26.8 No (however25 mm rain alsorecorded on15.03.17)

18.03.17 1

22

140

190

40.8 Yes

19.03.17 1

22

140

260

48 Yes

25.03.17 1 71 6.6 No

4.04.17 1

22

190

410

53.6 Yes

10.06.17 1

22

210

380

41 Yes

Of the six exceedances at Point 1 and the five at Point 22, four were aftera rainfall event which exceeded the basins design capacity and one wasafter a rainfall event that was close to exceeding the capacity and waspre-ceded by another large rainfall event. One of the exceedancesrecorded at Point 1 did not correlate with a significant rainfall event(25.03.17).

A review of the rainfall data also indicated a number of high rainfallevents (greater than 34.8) which did not result in TSS exceedances,suggesting that SUEZ has made improvements to the operation of thesediment basin.

Refer to Condition C30 of the Consent for discussion of theimprovements SUEZ has made to stormwater management andsediment dam 5.


A39 of 74

ConditionNo.



L3.1 Waste

The licensee must not cause, permit or allow any waste to be received at thepremises, except the wastes expressly referred to in the column titled “Waste” andmeeting the definition, if any, in the column titled “Description” in the table below.Any waste received at the premises must only be used for the activities referred to inrelation to that waste in the column titled “Activity” in the table below.

Any waste received at the premises is subject to those limits or conditions, if any,referred to in relation to that waste contained in the column titled “Other Limits” in thetable below.

This condition does not limit any other conditions in this licence.

Compliant SUEZ has developed SOP40 – ‘Waste Acceptance and Receipt’ toensure waste is received that is compatible with site design andregulatory requirements. If a delivery of waste arrives which is notlicensed to be received at the site, it was reported that it would berejected by the weighbridge personnel. A Rejected Load Form iscompleted by SUEZ and recorded in a rejected load register. Therejected load register maintained at the weighbridge was sighted duringthe audit.Rejected waste may include for example asbestos which is notappropriately wrapped, soil without the appropriate paperwork andradioactive waste (picked up by radiation meter at weighbridge).SUEZ provided the auditors with the weighbridge report from Mandalayfor the period from 01.01.17 to 31.12.17. The Mandalay report identifiedthat 0.48 tonnes of waste was rejected from the Site.

The site appears to have processes in place to ensure that only allowablewaste is received at the site.

This condition was varied on 7.12.17 as part of a licence variation. Thetable was updated to allow for leachate to be received from Harrington’sQuarry and LH1 for waste processing at a rate a 1,500 kL/day (previouslythe EPL permitted 1,200 kL/day). SUEZ provided the auditors with anexcel summary of the leachate volumes for 2017 with a breakdown ofmonthly leachate volume from LH1 and Harrington’s Quarry. Theaverage daily volume of leachate from LH1 and Harrington’s Quarry wasbelow 1,200 kL/day.

L3.2 If the licence permits the disposal of asbestos waste, the licensee must comply withPart 7 of the Protection of the Environment Operations (Waste) Regulation 2014.

Not assessed Asbestos was being received at the site. An assessment of compliancewith the requirements of Part 7 of the POEO (Waste) Regulation was notundertaken as part of this audit.


A40 of 74

ConditionNo.



L3.3 The disposal of waste is permitted within Cell 5.3A, Cell 5.3B and Cell 5.3C. Thedisposal of waste is also permitted within Cell 5.1 and Cell 5.2 defined as areas"Stage 5-1" and "Stage 5-2" in the plan prepared for Suez Recycling and RecoveryPty Ltd by Mamdoh Ibrahim of PE Civil and titled "Drawing number LH-160526-1-R0Location of waste cells (stages)" and dated 26 May 2016.

Compliant SUEZ reported that waste filling at Cell 5.1, Cell 5.2 and Cells 5.3 A, B&C was suspended when overtopping commenced in January 2018.

L3.4 The disposal of waste is permitted within the areas marked "Area E", "Area D", "AreaB" and "Area A" on the below plans received by the EPA on 12 October 2017:

· Proposed Reprofiling Development Plan, Drawing Job number 21-23482,Landform marked "Phase 1" (Revision C, 3 July 2015) prepared by GHD,

· Proposed Reprofiling Development Plan, Drawing Job number 21-23482,Landforms marked "Phase 2" and "Phase 3", (Revision C, 3 July 2017),prepared by GHD, and

· Proposed Re-profiling Development Plan, Drawing Job number 21-23482,Landform marked "Phase 4", (Revision C, 3 July 2017), prepared by GHD.

Compliant SUEZ reported that disposal of waste in Area D began in January 2018.

L4.1 No condition of this licence identifies a potentially offensive odour for the purposes ofsection 129 of the Protection of the Environment Operations Act 1997.

Note: Section 129 of the Protection of the Environment Operations Act 1997,provides that the licensee must not cause or permit the emission of any offensiveodour from the premises but provides a defence if the emission is identified in therelevant environment protection licence as a potentially offensive odour and theodour was emitted in accordance with the conditions of a licence directed atminimising odour.

Noted Noted

O1.1 Licensed activities must be carried out in a competent manner.This includes:a) the processing, handling, movement and storage of materials and substancesused to carry out the activity; andb) the treatment, storage, processing, reprocessing, transport and disposal of wastegenerated by the activity.

Compliant SUEZ maintains an overarching training needs matrix which wasdeveloped by SUEZ Corporate to reflect the generic trainingrequirements of SUEZ forms, guides, manuals, plans, registers, SOPs,Work Instructions, procedures required for each position (responsibility).Underneath the training needs matrix, each site has a Site TrainingMatrix (REG004).

The auditors reviewed Landfill Training Matrix (11.04.18). The matrixincluded the training requirements for each SUEZ employee under thefollowing categories; external training, inductions, health and safety,manuals, plans, policies, procedures, registers, standard operatingprocedures, work instructions, and fire warden training. A sample ofTraining Attendance Records were reviewed by the auditors.

Select Civil also has a company-wide Training Matrix. Whilst there wasno specific environmental training, there was a requirement for LandfillOperations Training and this included training on the SUEZ’ SOP’s. Theauditor sighted training records for training conducted on the 25.09.17 onthe Dust Control SOP 024 and on the 27.07.17 on the LeachateManagement SOP 018. It was reported that OEMP training for SelectCivil was planned in the upcoming months

With regards to operating plant, Select Civil has its own operatorcompetency system. This includes three levels of competency:

· SC-COM-001 Plant Operator Preliminary Compliance &Certification Assessment

· SC-COM-002 Plant Operator Final or Refresher Compliance &Certification Assessment

· SC-COM-003 Workshop Operator AssessmentThe on-line system was demonstrated to the auditors during the siteinspection.


A41 of 74

ConditionNo.



O2.1 All plant and equipment installed at the premises or used in connection with thelicensed activity:a) must be maintained in a proper and efficient condition; andb) must be operated in a proper and efficient manner.

Compliant Refer to SSD 6835, Condition B11.

O3.1 All operations and activities occurring at the premises must be carried out in amanner that will minimise the emission of dust from the premises.

Compliant Refer to SSD 6835, Condition C9.

O4.1 The licensee must take all practicable steps to control entry to the premises. Compliant The site operated from 8 am to 4 pm Saturdays and Sundays. SUEZreported that a security guard locks the gates at 4:30pm. The auditorsobserved the security guard was present at the gate at 5:30 pm.All vehicles carrying waste and visitor vehicles are required to passthrough the weighbridge.

O5.1 There must be no incineration or burning of any waste at the premises. Compliant SUEZ reported that no waste was deliberately burnt on site. Fires whichoccurred on the tip face are discussed under EPL 5065 condition M8.7.

O5.2 The licensee must ensure that recycling facilities as much as practicable areprovided for the following materials:a) Glass – clear, brown and green;b) Paper and cardboard;c) Batteries;d) Sump engine oil;e) Aluminium and steel cans; andf) Reusable timber, firewood and green waste.

Compliant During the site inspection the following recycling facilities were observedby the auditors:

· Paper & cardboard· Sump oil· Paint· Vehicle batteries· Mattresses· Computers and peripherals· Television sets· Asbestos· Scrap metal, including steel cans· Greenwaste· Aluminium (photo provided by SUEZ)

SUEZ reported that it does not provide source separation areas for glass,reusable timber or firewood as this is not considered commercially viable.

O5.3 Recycling facilities at the premises must be clearly marked and be available foraccess by the public.

Compliant The recycling areas identified in O5.2 were observed by the auditors tobe clearly labelled and accessible to the public. SUEZ provides employeeattendants within the public waste receivals area to direct the public tothe appropriate drop off zone.

The general waste skip bins were observed to have cardboard (e.g. largeTV boxes) and greenwaste. There is an opportunity to improvesegregation of recyclables out of the landfill waste stream.

2018-IEA-OFI13:

Encourage wheneverpossible for the public toseparate recyclables fromthe general waste streamand dispose of recyclablematerials in the appropriatearea at the public drop-off.

O5.4 Tyre StorageThe licensee must ensure that stockpiles of used, rejected or unwanted tyres(including shredded tyres and tyre pieces) are located in a clearly defined area.

Not triggered SUEZ reported that tyres are not accepted on site. No tyre stockpileswere observed by the auditors.

O5.5 The licensee must ensure that stockpiles of used, rejected or unwanted tyres(including shredded tyres and tyre pieces) are managed so as not to cause or to belikely to cause the spread of disease by vermin.

Not triggered Refer to O5.4.

O5.6 The licensee must ensure that measures are taken to prevent stockpiles of used,rejected or unwanted tyres (including shredded tyres and tyre pieces) from catchingon fire.



A42 of 74

ConditionNo.



O5.7 Covering of Waste

a) Daily cover

Daily cover can be either:

i) virgin excavated natural material (VENM); orii) approved alternative daily cover (ADC) on active tipface only.Note: For the purposes of condition O5.7 (a) (i) the cover material must be applied toa minimum depth of 15 centimetres over all exposed landfilled waste prior to ceasinglandfill operations at the end of each day.

Note: For the purposes of condition O5.7 (a) (ii) the approved ADC is the“Tarpomatic” Automatic Tarping Machine (“ATM”) that achieves the RequiredOutcome specified in Chapter 8 (Covering of Waste) of the EPA's EnvironmentalGuidelines: Solid Waste Landfills (2016).

b) Intermediate cover

Intermediate cover material must be VENM and applied to a depth of 30 centimetresover surfaces of the landfilled waste at the premises which are to be exposed formore than 90 days.

c) Cover material stockpile

At least two weeks of VENM cover material must be available at the premises underall weather conditions. This material may be won on site, or alternatively a coverstockpile must be maintained adjacent to the tip face.

Compliant The OEMP outlines the process for covering waste.

· At the end of each working day a minimum of 150 mm of daily coverwill be applied to all exposed work surfaces. Daily cover willcomprise:· Inert, non-combustible material primarily from onsite

excavation· “Tarpomatic” or an alternative approved by the EPA

· Where a filled area has not reached the final landform level but willremain inactive for greater than 90 days, 300 mm of compacteddaily cover will be applied.

The Landfill Daily Checklist includes comments on daily and intermediatecover including how many loads were used and where it was sourcedfrom (sighted completed example 02.02.18).

The auditors sighted large stockpiles of VENM on site during the siteinspection. SUEZ reported that it maintains several VENM stockpiles onsite, which are recorded in the six monthly survey report provided to theEPA.

2018-IEA-OFI14:

Revise the OEMP tospecifically refer to theapplication of VENM as dailyand intermediate cover.

O5.8 The licensee must progressively final cap completed stages of filling as soon aspracticable.

Not triggered This condition was added on 7.12.17 as part of the licence variation.Therefore this condition has been assessed from 7.12.17 to 23.01.18.

No stages of filling had been completed during the audit period.

O5.9 Disposal of Immobilised Waste

The licensee must cover the immobilised waste on the day of receival.

Not triggered SUEZ reported that no immobilised waste was accepted on Site duringthe audit period.

O5.10 Uncovering of Landfilled Waste

The licensee must not carry out any activity that exposes previously landfilled wasteat the premises, except as expressly permitted by a condition of this licence.

Compliant During the site inspection the auditors observed waste previouslylandfilled in Area D being exposed for re-profiling. This activity isapproved by EPL 5065. No other observations were made.

O5.11 A maximum area of 1 hectare of existing intermediate cover or 2 hectares of existingfinal capped cover may be stripped of cover in advance of landfilling to form the"Prepared Surface". The Prepared Surface must have a minimum depth of 300mm.

Compliant This condition was added on 7.12.17 as part of the licence variation.Therefore this condition has been assessed from 7.12.17 to 23.01.18.

Refer to SSD 6835, Condition C5.

O5.12 Each day, a maximum of 2,500 m2 of the Prepared Surface may be stripped back toexpose previously landfilled waste to form the "Active Tipface".



O5.13 The licensee must carry out works in accordance with the document titled OdourManagement Plan for Landfill Gas Extraction Systems provided with the letterreceived from Waste Service NSW dated 28 June 2002.

Not assessed The Odour Management Plan for Landfill Gas Extraction Systems wasprepared by WSN and has been superseded by SUEZ odourmanagement documents including:

· Odour Management SOP

· Landfill Gas Extraction System plan

Refer to Condition C8 of the Consent for further discussion of odourmanagement on site.

2018-IEA-OFI15:

Consult with the EPA on therelevance of this Conditionand potentially remove oramend to refer to a morerecent SUEZ document.

O5.14 Landfill Leachate

Landfill leachate must not be irrigated except as expressly permitted by a conditionof this licence.

Compliant SUEZ reported that landfill leachate was not used to irrigate during theaudit period. The auditors did not observe any irrigation occurring on Siteduring the site inspection.


A43 of 74

ConditionNo.



O5.15 The licensee must not inject leachate back into the landfill waste. Compliant It was reported that leachate was not re-injected back into the landfillwaste.

Some gas wells are dual purpose and extract leachate from the landfilland pipe to leachate dam.

O5.16 Leachate must be disposed of to sewer or removed by tanker to a premises whichmay lawfully receive the leachate for treatment.

Compliant Leachate is transferred from the main leachate dam via the leachatetransfer line to a holding dam at LH1. From the holding dam the leachategoes through the batch reactor which allows for biological treatment(specifically ammonia removal) prior to pumping to sewer in accordancewith a Trade Waste Agreement with Sydney Water. An assessment ofcompliance with the Trade Waste Agreement was not undertaken as partof this audit.

SUEZ reported that no leachate was tankered off-site during the auditperiod.

O5.17 Landfill Gas

Except in emergency conditions or short periods of shutdowns the licensee mustensure that landfill gas generated by the disposal of waste and collected at thepremises is treated by oxidation to carbon dioxide.

Compliant SUEZ has installed a leachate gas collection system to extract landfillgas and transfer it to two local power stations for conversion into energyfor power generation. Where electricity cannot be generated, the landfillgas is flared to convert the methane into carbon dioxide. EDL isresponsible for the landfill gas extraction, electricity generation andflaring. EDL provides SUEZ with a monthly report which summarises howthe gas field operated during the month. For the month of December2017, EDL reported that 9,389,464 kWh of electricity was generated, theflare was run for 18 hours and there were no station outages.

Un-treated landfill gas could be emitted from the landfill if there areissues with the landfill gas collection system. This elevated landfill gaswould get picked up by the surface gas monitoring undertaken on aquarterly basis. Refer to M8.1 for a discussion of surface gas monitoringresults.

O5.18 With the exception of the Prepared Surface, landfill gas field infrastructure locatedwithin the re-profiling area outlined at E7.1 must be retained and operating at alltimes.



O6.1 Management of Collected Groundwater

The licensee must manage any groundwater extracted from groundwaterdepressurisation works in the same manner as leachate if the ammoniaconcentration in the groundwater is greater than 1 mg/L.

Compliant SUEZ reported that groundwater was extracted from the groundwaterdepressurisation works during the audit period. SUEZ pumps this waterto the leachate pond therefore manage this groundwater in accordancewith the leachate management processes.

O6.2 Household Chemical Collection Program

Chemicals which have been collected in conjunction with a “Household ChemicalCollection Program” must be stored in a secure and bunded location within thepremises pending lawful off site disposal or recycling of these chemicals.

Not triggered SUEZ reported that the Site did not receive chemicals collected throughthe Household Chemical Collection Program during the audit period.

O6.3 Closure PlanThe licensee must prepare and submit to the EPA within twelve months prior to thelast load of waste being landfilled, a closure plan in accordance with section 76 ofthe Protection of the Environment Operations Act 1997.

Not triggered Not triggered during the audit period


A44 of 74

ConditionNo.



O6.4 Preventing Fires

All operations and activities occurring at the premises must be carried out in amanner that will prevent and minimise the risk of fire at the premises.

Compliant As discussed in Section 7.16 of the OEMP, SUEZ reportedly implementthe following measures to prevent fires:

· Incoming wastes which are found during inspection to be hot or onfire prior to disposition will be directed away from the activelandfilling areas where the material can be exhausted without risk ofcausing a fire on site.

· A firebreak, not less than 20 m wide and cleared of all flammablematerial is maintained around the boundaries of the waste disposalareas.

· All new employees receive fire prevention, protection, fire-fightingand emergency procedures training. All employees are given arefresher training course at regular intervals. The auditors sightedthe Training Matrix for Select Civil which includes fire andemergency response and high risk work.

· A ban on smoking around the active landfilling area, with clear signsindicating designated smoking areas. No smoking signs wereobserved during the site audit around refuelling areas and in thepublic drop off area.

· Clear posted signs on display to the public advising that wasteflammable liquids are not permitted on the site.

· Cell construction, compaction and use of cover material should beundertaken in a manner that prevents fire.

· All sealed or contaminated drums should not be accepted unlessthey are delivered as a special waste whose contents are clearlyidentified and suitable for acceptance.

· All fuels or flammable solvents for operational use will be stored inan appropriately ventilated and secure store that complies with theAct covering storage of dangerous goods. The auditors

· Hot Works Permits will be used where appropriate.

O6.5 Management of Surface Waters

Surface waters must be diverted away from any area where waste is being or hasbeen landfilled.

Compliant Surface water within the landfill area is diverted to a series of dirty waterdrains on the eastern and western perimeter of the site. Refer to SSD6835 Condition C30 for further discussion of stormwater management.

O6.6 SUEZ must install and maintain freeboard markers in Sediment Dam 5. Freeboardmarkers must:

a. indicate the 10ML settling zone,

b. indicate 2ML increments,

c. be permanently installed, and

d. be positioned in location/s that allow freeboard verification.


SUEZ provided a letter to the EPA, dated 27.07.17, which included apicture of the freeboard marker.

The auditors saw the freeboard marker during the site inspection,however at the time of the audit Sediment Dam 5 was nearly dry,therefore the marker was on the floor of the dam.

The marker is located at the end of an access pier.

O6.7 Sediment Dam 5 must be maintained at or below the base of the 10ML settling zone,except as specified in Condition O6.8.


At the time of the site inspection Sediment Dam 5 has a very low waterlevel due to extended drought.


A45 of 74

ConditionNo.



O6.8 During 2 day 90th percentile rainfall events of 34.8mm of more, the stormwatertreatment plant must be engaged, as soon as the event is known, to treat sedimentladen water. A 10ML capacity settling zone within Sediment Dam 5 must be re-established within 5 days of the rainfall event occurring.

Not triggered This condition was added on 7.12.17 as part of the licence variation.Therefore this condition has been assessed from 7.12.17 to 23.01.18.This condition was not triggered during that period.

M1.1 Monitoring records

The results of any monitoring required to be conducted by this licence or a loadcalculation protocol must be recorded and retained as set out in this condition.

Noted Noted

M1.2 All records required to be kept by this licence must be:

a) in a legible form, or in a form that can readily be reduced to a legible form;

b) kept for at least 4 years after the monitoring or event to which they relate tookplace; and

c) produced in a legible form to any authorised officer of the EPA who asks to seethem.

Compliant Monitoring data was generally provided in a legible form. SUEZ reportedthat they keep records on file for more than four years.

No information was requested by the EPA during the audit period.

M1.3 The following records must be kept in respect of any samples required to becollected for the purposes of this licence:



CES Quarterly/Annual Groundwater, Surface water and Leachatemonitoring

The field data sheets are included as an attachment to the quarterly CESreports. The auditors reviewed a sample of these data sheets are foundthe groundwater data sheets included the date, time, monitoring point IDand the initials of the people who completed the sampling. The surfacewater data sheets did not always include the time of sampling.

Gas monitoring

The surface gas monitoring results provided as excel worksheets andincluded the date, time and GPS coordinates of the monitoring point. Twoof the four data sheets included the name of the person sampling.

The subsurface monitoring results included the point at which the samplewas taken and the date range for March and June, and the ‘SamplingDate’ for September and December. The time the sample was collectedand name of the person who collected the sample was not included.

Gas accumulation monitoring results are provided as excel worksheetsand include the date, location and name of person undertaking thesampling. The time of sample was not recorded.

Wet weather monitoring

SUEZ reported that a field datasheet is not completed during wet weathersampling when undertaken in-house by SUEZ. Some samplinginformation was recorded on the sample bottle and Chain of Custodyprovided to the laboratory, which is then recorded in the final laboratoryreports. Laboratory reports for sampling at MC1 were reviewed by theauditors.

As all of the required information (e.g. time and name of sampler) is notalways recorded, this condition has been assessed as an Administrativenon-compliance.

2018-IEA-REC20:

Ensure all of the requiredinformation (e.g. time andname of person whocollected the sample) isrecorded for monitoringrequired by the EPL, inparticular for wet weathersampling undertaken inhouse.

M1.4 The licensee must record the date, duration and volume of any leachate dischargeto surface water.

Not triggered No instances where leachate was discharged to surface water wasreported by SUEZ during the audit period.


A46 of 74

ConditionNo.



M2.1 Requirement to monitor concentration of pollutants discharged

For each monitoring/discharge point or utilisation area specified below (by a pointnumber), the licensee must monitor (by sampling and obtaining results by analysis)the concentration of each pollutant specified in Column 1. The licensee must use thesampling method, units of measure, and sample at the frequency, specified oppositein the other columns:

Noted Noted

M2.2 Air Monitoring RequirementsPOINT 28,29,30,31,32,33,51,52,53,54

Pollutant Units of measure Frequency Sampling Method

Carbondioxide

percent by volume Quarterly Special Method 1

Methane percent by volume Quarterly Special Method 1

Compliant This condition was varied on 7.12.17 as part of a licence variation. Aspart of the variation the Monitoring Points 51, 52, 53, and 54 were addedto the condition and the requirement to monitoring carbon dioxide wasadded.

As discussed in Condition M8.2, subsurface gas monitoring for methanewas undertaken quarterly (March, June, September and December).

The requirement to monitor carbon dioxide was not trigger during theaudit period.

Monitoring in accordance with Special Method 1 (the methods outlined inChapter 5.3 Landfill gas sub-surface monitoring of EnvironmentalGuidelines: Solid Waste Landfills (NSW EPA, Second Edition, September2016) has not been assessed in the audit.

M2.3 Water and/or Land Monitoring RequirementsPOINT 1


Conductivity microsiemens percentimeter

Special Frequency 1 Probe

Dissolved Oxygen milligrams per litre Special Frequency 1 Grab sampleNitrogen(ammonia)


pH pH Special Frequency 1 Grab samplePotassium milligrams per litre Special Frequency 1 Grab sampleTotal dissolvedsolids


Total organicscarbon


Total Phenolics milligrams per litre Special Frequency 1 Grab sampleTotal SuspendedSolids


POINT 3,40




Aluminium milligrams per litre Yearly Grab sampleArsenic milligrams per litre Yearly Grab sampleBarium milligrams per litre Yearly Grab sampleBenzene milligrams per litre Yearly Grab sampleBenzo(a)pyrene milligrams per litre Yearly Grab sampleBicarbonatealkalinity


BOD milligrams per litre Yearly Grab sample

Cadmium milligrams per litre Yearly Grab sample

Non-compliant This condition was varied on 7.12.17 as part of a licence variation. Themain changes in the variation include:

· Addition of new monitoring points, highlighted in blue text;· Addition of new ‘pollutants’ to monitor at respective monitoring

points, highlighted in blue text;· Change to monitoring frequency from quarterly to yearly and visa

versa; and· Removing the requirement to monitoring turbidity at Point 1.Monitoring of surface water, groundwater and leachate was undertakenunder the requirements of the previous EPL (dated 17.07.17), thereforethis condition has been reviewed against the requirements in EPL 5065(dated 17.07.17)

Quarterly sampling of surface water, groundwater and leachate duringthe audit period was undertaken in January, April, September andDecember. A summary is provided below.

EPAPoint

Type &location


Groundwater quality

4, 7,8, 16,17,18,19,24,25,26,27

MB008,MB032,MB034,MB305,MB306,MB033,MB035,MB038,MB039,MB040,MB041

Quarterly Alkalinity,Benzo(a)pyrene,calcium, chloride,magnesium,ammonia, pH,PAH, potassium,sodium, standingwater level, sulfate,TDS, total organiccarbon, TPH

Conductedby CES.

Review ofCESquarterlymonitoringreports (Mar,Jun, Septand Dec)indicated thismonitoringwasundertaken.


2018-IEA-REC21:

Include failures to undertakemonitoring in accordancewith the frequency specifiedin the EPL within the AnnualReturn.


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ConditionNo.



Calcium milligrams per litre Yearly Grab sampleChemical oxygendemand


Chloride milligrams per litre Yearly Grab sampleChromium(hexavalent) milligrams per litre Yearly Grab sampleChromium (total) milligrams per litre Yearly Grab sampleCobalt milligrams per litre Yearly Grab sampleConductivity microsiemens per

centimeterQuarterly Probe

Copper milligrams per litre Yearly Grab sampleEthyl benzene milligrams per litre Yearly Grab sampleFluoride milligrams per litre Yearly Grab sampleLead milligrams per litre Yearly Grab sampleMagnesium milligrams per litre Yearly Grab sampleManganese milligrams per litre Yearly Grab sampleMecury milligrams per litre Yearly Grab sampleNickel milligrams per litre Yearly Grab sampleNitrate milligrams per litre Yearly Grab sampleNitrite milligrams per litre Yearly Grab sampleNitrogen (ammonia) milligrams per litre Yearly Grab sampleOrganochlorinepesticides




pH pH Quarterly ProbePhosphorus milligrams per litre Yearly Grab samplePolycyclic aromatichydrocarbons


Potassium milligrams per litre Yearly Grab sampleSodium milligrams per litre Yearly Grab sampleSulfate milligrams per litre Yearly Grab sampleToluene milligrams per litre Yearly Grab sampleTotal dissolved solids milligrams per litre Yearly Grab sampleTotal organic carbon milligrams per litre Yearly Grab sampleTotal petroleumhydrocarbons


Total Phenolics milligrams per litre Yearly Grab sampleTotal suspendedsolids


Xylene milligrams per litre Yearly Grab sampleZinc milligrams per litre Yearly Grab sample

POINT 4,7,8,16,17,18,19,24,25,26,27,44,45,46,47,48,49,50




Aluminium milligrams per litre Yearly Grab sampleArsenic milligrams per litre Yearly Grab sampleBarium milligrams per litre Yearly Grab sampleBenzene milligrams per litre Yearly Grab sampleBenzo(a)pyrene milligrams per litre Yearly Grab sampleBicarbonatealkalinity


Cadmium milligrams per litre Yearly Grab sampleCalcium milligrams per litre Quarterly Grab sample

EPAPoint

Type &location


Leachate

3 Leachatequalityfromleachatedam –LD001


Conducted byCES.

Review of CESquarterlymonitoringreports (Mar, Jun,Sept and Dec)indicated thismonitoring wasundertaken.


40 Leachatequalityfromleachatedam LH1- LD002


Review of CESquarterlymonitoringreports (Mar, Jun,Sept and Dec)shows:

- quarterlysampling ofBenzo(a)pyrene, TPH wasnotundertaken.

- yearlysampling of18 analyteswas notundertaken(reported asNot Tested inthe samplingresults).



A48 of 74

ConditionNo.



Chloride milligrams per litre Quarterly Grab sampleChromium(hexavalent) milligrams per litre Yearly Grab sampleChromium (total) milligrams per litre Yearly Grab sampleCobalt milligrams per litre Yearly Grab sampleCopper milligrams per litre Yearly Grab sampleEthyl benzene milligrams per litre Yearly Grab sampleFluoride milligrams per litre Yearly Grab sampleLead milligrams per litre Yearly Grab sampleMagnesium milligrams per litre Quarterly Grab sampleManganese milligrams per litre Yearly Grab sampleMecury milligrams per litre Yearly Grab sampleNickel milligrams per litre Yearly Grab sample

Nitrate milligrams per litre Quarterly Grab sampleNitrite milligrams per litre Quarterly Grab sampleNitrogen (ammonia) milligrams per litre Quarterly Grab sampleOrganochlorinepesticides




PCBs milligrams per litre Yearly Grab samplepH pH Quarterly ProbePhosphorus milligrams per litre Quarterly Grab samplePolycyclic aromatichydrocarbons


Potassium milligrams per litre Quarterly Grab sampleRedox potential Millivolts Quarterly Grab sampleSelenium milligrams per litre Yearly Grab sample

Sodium milligrams per litre Quarterly Grab sampleStanding Water Level metres Quarterly In situSulfate milligrams per litre Quarterly Grab sampleTemperature Degrees Celsius Quarterly ProbeTetrachloroethane(tetrachloroethylene)


Toluene milligrams per litre Yearly Grab sampleTotal dissolved solids milligrams per litre Quarterly Grab sampleTotal organic carbon milligrams per litre Quarterly Grab sampleTotal petroleumhydrocarbons


Total Phenolics milligrams per litre Yearly Grab sampleTrichloroethylene milligrams per litre Yearly Grab sampleXylene milligrams per litre Yearly Grab sampleZinc milligrams per litre Yearly Grab sample

POINT 20,21



Grab sample



Grab sample

EPAPoint

Type &location


Surface water

1 Dischargeto watersoverflowqualitymonitoring– MC1


Conductivity,DO,Ammonia,pH, Phenol,TSS,Turbidity

SUEZ conductwet weathermonitoring.Monitoring wasundertaken on31 occasionsduring the auditperiod*. On 10of theseoccasionsturbidity wasnot tested.

20 PumpeddischargefromSedimentDam 5 –DS002


Ammonia,TSS

SUEZ reportedno dischargesduring the auditperiod.

21 Pumpeddischargefromstormwatertreatmentplant –DS001


Ammonia,TSS

Review ofEurofinslaboratoryreports (25sampling eventreports)indicated thismonitoring wasundertaken.

22 OverflowfromSedimentDam 5 –OF001


Ammonia,TSS

Review ofEurofinslaboratoryreports (fivesampling eventreports)indicated thismonitoring wasundertaken.

23 SedimentDam 5 –SD005

Quarterly Ammonia,TSS

Conducted byCES. Review ofCES quarterlymonitoringreports (Mar,Jun, Sept andDec) indicatedthis monitoringwasundertaken.

*As discussed under SSD6835 Condition C30, based on correspondencewith the EPA it is noted that monitoring of Point 1 was not undertaken onthe 4.03.17 (Saturday) and 5.03.17 (Sunday) during an overflow event atSediment Dam 5 as required by this condition. This was not reported as anon-compliance with EPL 5065 in the Annual Return.


A49 of 74

ConditionNo.



POINT 22



Grab sample



Grab sample

POINT 23


Nitrogen(ammonia) milligrams per litre Quarterly Grab sample



This condition has been assessed as not-compliant based on thefollowing:

· Monitoring not being undertaken at Point 1 during discharge fromSediment Dam 5 on 4.03.17 and 5.03.17.

· Turbidity was not measured on 10 occasions for Point 1. It is notedthat turbidity monitoring is no longer required.

· Quarterly sampling of Benzo(a)pyrene and TPH was not undertakenat Point 40. It is noted that monitoring of Benzo(a)pyrene and TPH isnow required yearly.

· Yearly sampling of 18 analytes was not undertaken at Point 40.

M2.4 For the purposes of the table(s) above:

a) Special Frequency 1 means, if discharges occur, the collection of samples within24 hours of discharge;b) Special Frequency 2 means, the collection of samples at minimal weekly intervalsduring discharge; andc) Special Method 1 means in accordance with the methods outlined in Chapter 5.3Landfill gas sub-surface monitoring of Environmental Guidelines: Solid WasteLandfills (NSW EPA, Second Edition, September 2016).

Noted Noted

M3.1 M3 Testing methods - concentration limitsMonitoring for the concentration of a pollutant emitted to the air required to beconducted by this licence must be done in accordance with:

a) any methodology which is required by or under the Act to be used for the testingof the concentration of the pollutant; orb) if no such requirement is imposed by or under the Act, any methodology which acondition of this licence requires to be used for that testing; orc) if no such requirement is imposed by or under the Act or by a condition of thislicence, any methodology approved in writing by the EPA for the purposes of thattesting prior to the testing taking place.

Note: The Protection of the Environment Operations (Clean Air) Regulation 2010requires testing for certain purposes to be conducted in accordance with testmethods contained in the publication "Approved Methods for the Sampling andAnalysis of Air Pollutants in NSW".

Not assessed This condition was revised on 7.12.17 as part of the licence variation.Between 23.01.17 and 7.12.17 the only monitoring of a pollutant emittedto air required by EPL 5065 was for methane (% v/v) by Special Method1 (M2.2). Special Method 1 referred to the Benchmark 16 of EPA (1996)Environmental Guidelines: Solid Waste Landfills. An assessment ofmonitoring methodologies was not undertaken as part of this audit.

M3.2 Subject to any express provision to the contrary in this licence, monitoring for theconcentration of a pollutant discharged to waters or applied to a utilisation area mustbe done in accordance with the Approved Methods Publication unless anothermethod has been approved by the EPA in writing before any tests are conducted.

Not assessed CES conducted water monitoring at the Site in accordance with a project-specific Quality Assurance and Quality Control Plan (QA/QC) Plan,prepared in 2016, to meet the requirements of EPL 5065 and EPL 13114.

The auditors have not reviewed the QA/QC plan as part of this audit.


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ConditionNo.



M4.1 Requirement to Monitor Meteorological Parameters

The licensee must monitor (by sampling and obtaining results by analysis) theparameters specified in Column 1. The applicant must use the sampling method,units of measure, averaging period and sample at the frequency, specified oppositein the other columns.

Parameter Units ofmeasure

Frequency AveragingPeriod

SamplingMethod

Rainfall mm Continuous 1 hour AM-4

Wind Speed @10metres

m/s Continuous 15 Minute AM-2 & AM-4

Wind Direction@10 metres

Degrees Continuous 15 Minute AM-2 & AM-4

Temperature DegreesCelsius

Continuous 15 Minute AM-4

Sigma theta @metres

Degrees Continuous 15 Minute AM-2 & AM-4

Solar Radiation W/m2 Continuous 15 Minute AM-4

AdditionalRequirements

-Siting-Measurement

AM-1 & AM-4

AM-2 & AM-4

Compliant Real-time data from the weather station was sighted during the auditindicating the parameters were being monitored as required. A detailedassessment against siting and measurement standards was notundertaken by the auditors. Confirmation was obtained by SUEZ from itsweather station maintenance contractor that the weather station meetsthe requirements specified in the table under Condition M4.1 of the EPLduring the previous IEA in 2015. The location of the weather stationremains unchanged.

M5.1 Recording of pollution complaintsThe licensee must keep a legible record of all complaints made to the licensee orany employee or agent of the licensee in relation to pollution arising from any activityto which this licence applies.

Compliant SUEZ has an Incident Reporting and Corrective Action Procedure(PROC008) which details the process for handling complaints. SUEZhas also developed an Environmental Complaints Management SOP066which provides further details on the process of recording, investigating,managing and reporting environmental complaints.Complaints are logged using an Initial Incident Report and a CorrectiveAction Report (CAR) in SIMS. SIMS was demonstrated to the auditorsduring the audit and a complaints report for the audit period generated.

M5.2 The record must include details of the following:a) the date and time of the complaint;b) the method by which the complaint was made;c) any personal details of the complainant which were provided by the complainantor, if no such details were provided, a note to that effect;d) the nature of the complaint;e) the action taken by the licensee in relation to the complaint, including any follow-up contact with the complainant; andf) if no action was taken by the licensee, the reasons why no action was taken.

Compliant The following information was recorded as demonstrated by a CARprovided to the auditors dated 22.06.17, 23.06.17 and 13.11.17:· Site details (location)· Time and date reported· A copy of original communications from complainant· Complainant details as provided (name, mobile number, address).· Call back request (yes, no),· Nature of complaint (observation)· Actions taken, action required in the SUEZ system.

M5.3 The record of a complaint must be kept for at least 4 years after the complaint wasmade.

Compliant SUEZ reported that the data management systems (SIMS) storesrecords indefinitely.

M5.4 The record must be produced to any authorised officer of the EPA who asks to seethem.

Not triggered During the audit period the Site reported that the EPA did not request arecord therefore this condition has not been triggered.

M6.1 Telephone complaints line

The licensee must operate during its operating hours a telephone complaints line forthe purpose of receiving any complaints from members of the public in relation toactivities conducted at the premises or by the vehicle or mobile plant, unlessotherwise specified in the licence.

Compliant LHRRP has a contact number for feedback one environmental matterswhich was advertised on the SUEZ Lucas Heights website (1800 368737)). In addition the general SUEZ enquiry line is advertised on the signat the entrance to the Site (1300 651 116).


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ConditionNo.



M6.2 The licensee must notify the public of the complaints line telephone number and thefact that it is a complaints line so that the impacted community knows how to make acomplaint.

Compliant LHRRP has a contact number for feedback on environmental matterswhich was advertised on the SUEZ Lucas Heights website and in theCRG meeting minutes published on the website (1800 ENV REP (1800368 737)).

SUEZ has a sign at the entrance of the LHRRP which provides the SUEZinformation phone number (1300 651 116). A SUEZ contact number isprovided on the SUEZ website.

M6.3 The preceding two conditions do not apply until 3 months after: the date of the issueof this licence.

Closed Out Closed Out

M7.1 Requirement to monitor volume or massFor each discharge point or utilisation area specified below, the licensee mustmonitor:a) the volume of liquids discharged to water or applied to the area;b) the mass of solids applied to the area;c) the mass of pollutants emitted to the air;at the frequency and using the method and units of measure, specified below.

POINT 41Frequency Units of measure Sampling MethodSpecial Frequency 3 kilolitres In line instrumentation



Note: Special Frequency 3 sampling requires a continuous inline flow meter withreporting of the total volume of leachate discharged quarterly.

Compliant The leachate flow monitoring was conducted by SUEZ at Point 41, 42and 43 during the audit period. The results of the flow monitoring areprovided on the Lucas Heights Website.

The auditors noted that the unit of measurement reported in themonitoring data uploaded to the SUEZ website is presented as cubicmeters. It is recommended that the unit is reported as kilolitres to beconsistent.

2018-IEA-REC22:

Report the leachate volumesin kilolitres as per the EPLrequirement.

M8.1 Requirement to Monitor Landfill Gas

The licensee must undertake quarterly surface landfill gas monitoring in accordancewith the document titled “Landfill Surface Gas Monitoring Programme, Lucas HeightsWaste and Recycling Centre” prepared by WSN Environmental Solutions and datedFebruary 2006.

If the results of the monitoring indicate the presence of methane in excess of 500ppm on the surface of the capped areas, the licensee must:

a) notify the EPA within 24 hours; andb) submit to the EPA a proposed program to control these emissions.The above quarterly surface landfill gas monitoring must be submitted to the EPAannually, accompanying the Annual Return.

Non-compliant The auditors reviewed the surface gas monitoring results provided bySUEZ as excel files. The results identified the following:

· 21.04.17 - A total of 100 samples were taken and the maximummethane level recorded was 251.2 ppm


· 12.09.17 - A total of 309 samples were taken and the maximummethane level recorded was 454.7.4 ppm


No exceedances of the 500 ppm for methane were noted. The timing ofmonitoring has not been completed every three months, but instead fourtimes within the calendar year. Monitoring data for September was notpublished on the website at the time of the audit.As per the 2015 IEA (2015-IEA-REC24) it was noted that the quarterlysurface landfill gas monitoring was not attached the Annual Return forEPL 5065.This condition has been assessed at not compliant as monitoring is notbeing undertaken quarterly and surface landfill gas monitoring was notattached to the Annual Return 5065.

2018-IEA-REC23:

Submit quarterly surface andgas accumulation monitoringreports as an attachment toeach Annual Return.

2018-IEA-REC24:

Conduct surface gasmonitoring every 3 months.

2018-IEA-OFI16:

Publish all monitoring datarequired to be undertakenunder EPL 5065 on theLucas Heights LHRRPwebsite within 14 days ofreceiving the results.


A52 of 74

ConditionNo.



M8.2 The licensee must undertake quarterly landfill gas accumulation monitoring inaccordance with the document titled “Proposed Landfill Subsurface Gas andAccumulation Monitoring Program, Lucas Heights Waste and Recycling Centre”prepared by WSN Environmental Solutions and dated March 2006.

If the results of the monitoring indicate the presence of methane in excess of 1 %(v/v), the licensee must:

a) notify the EPA within 24 hours; andb) submit to the EPA a proposed program to control these emissions.The above quarterly landfill gas accumulation monitoring must be submitted to theEPA annually, accompanying the Annual Return.

Non-compliant This condition was revised on 7.12.17 as part of the licence variation.Prior to the revision the condition stated that “if the results of monitoringindicate the presence of methane in excess of 1.25% (v/)…”. Thereforethis condition has been assessed in the following way:

· 23.01.17 – 6.12.17 – 1.25% (v/v)

· 7.12.17 to 23.01.18 – 1% (v/v)

Monitoring completed between the 23.1.17 to 6.12.17

Sub-Surface Gas Monitoring

Four exceedances of the methane presence of 1.25% (v/v) wererecorded at monitoring point 29 (MB037) during the audit period:

· 14/15 March 2017 – 14.5% (reported in the Annual Return)

· 7 June 2017 – 10.5% (reported in the Annual Return)

· 20 and 25 September 2017 – 5.3%

· 6 December 2017 – 9.7%

The Annual Return states that two additional bores were installed on the14 May 2017 and Gasglams were installed on continuous monitoring onMB036 and MB037.

SUEZ notified the EPA in a letter dated 13.03.17 of the March 2017monitoring results at EPL Point 29 (MB037) which recorded initialmethane concentration of 3.3% v/v and 14.5% v/v after the well was putunder vacuum. The letter does not identify the date sampling wasrecorded, or a proposed plan to control emissions.

SUEZ reported that the EPA was not notified of the exceedances ofmethane concentrations in June, September and December 2017.

Gas Accumulation Monitoring

Gas accumulation monitoring results were reviewed for the 21.04.17,16.08.17 and 21.11.17. No exceedances of the 1.25% (v/) wereidentified. It is noted that sampling was not undertaken quarterly asrequired by this condition.

7.12.17 to 23.01.18

No subsurface gas or accumulation monitoring was undertaken between7.12.17 to 23.01.18.

The auditors noted that the Proposed Landfill Subsurface Gas andAccumulation Monitoring Program was last updated in July 2015,therefore had not been updated with the new trigger level on 1% (v/v) asper this condition. It is noted that Condition M8.3 and M8.4 require theSite to prepare and submit to the EPA a Draft Landfill Sub-Surface GasMonitoring Programme for the premises by 31 March 2018.

As per the 2015 IEA (2015-IEA-REC24) it was noted that the quarterlylandfill gas accumulation monitoring was not attached to the AnnualReturn for EPL 5065.

This condition has been assessed as not compliant for the followingreasons:

· SUEZ did not report the exceedance of methane concentrations inJune, September and December 2017 to the EPA;

· Quarterly landfill gas accumulation monitoring was not attached theAnnual Return for EPL 5065.

· Gas accumulation monitoring was not undertaken quarterly.

As per condition M8.1

2018-IEA-REC25:

Ensure all exceedances ofmethane levels are reportedto the EPA with the requiredinformation.

2018-IEA-OFI17:

Include exceedances of EPLlimits in the incidentsregister, for example sub-surface gas methane levelsto ensure that the EPA isnotified and the appropriateactions are taken to controlthe exceedance.


A53 of 74

ConditionNo.



M8.3 By 31 March 2018, the licensee must submit to the EPA a Draft Landfill Surface GasMonitoring Programme for the premises. The Landfill Surface Gas MonitoringProgramme must, at a minimum:

1. Be prepared by a suitably qualified and experienced person,

2. Meet the requirements of the EPA's Environmental Guidelines: Solid WasteLandfills, Second edition (September 2016).

3. Consider the recommendations and trends shown on the premises' previoussurface gas monitoring,

4. Consider and plan for future site changes, and

5. Identify trigger points for additional monitoring, investigation, and correctiveactions. Trigger points must include odour-related triggers and the MonitoringProgramme may refer to other operational or monitoring plans.


M8.4 By 31 March 2018, the licensee must submit to the EPA a Draft Landfill Sub-SurfaceGas Monitoring Programme for the premises. The Draft Landfill Sub-Surface GasMonitoring Programme must, at a minimum:

1. Be prepared by a suitably qualified and experienced person,

2. Meet the requirements of the EPA's Environmental Guidelines: Solid WasteLandfills, Second edition (September 2016),

3. Consider the recommendations and trends shown on the premises' previous sub-surface gas monitoring, including the recommendations in GHD's letter to Kim Rossof Suez titled " Lucas Heights 2 landfill site: Landfill Gas Investigation" dated 5 April2017,

4. Consider and plan for future site changes, and

5. Identify trigger points for additional monitoring, investigation, and correctiveactions. Trigger points must include odour-related triggers and the MonitoringProgramme may refer to other operational or monitoring plans.


M8.5 The Draft Landfill Surface Gas Monitoring Programme and Draft Landfill Sub-surfaceGas Monitoring Programme required by M8.3 and M8.4 must be submitted to beEPA via email to [email protected] licensee must consider any comments or recommendations made by the EPA inresponse to the above submission prior to finalising the Monitoring Programmes.Note: The Draft Landfill Surface Gas Monitoring Programme and Draft Landfill Sub-surface Gas Monitoring Programme required by M8.3 and M8.4 may be incorporatedinto a single document, if desired by the licensee.


M8.6 Requirement to Record Leachate Discharge EventsThe licensee must record the date, duration and volume of any leachate dischargeto surface water.

Not triggered Refer to Condition M1.4.

M8.7 Requirement to Record FiresThe licensee must record the following data in relation to all fires occurring at thepremises:(a) time and date when the fire started;(b) whether the fire was authorised by the licensee, and, if not, the circumstanceswhich ignited the fire;(c) the time and date that the fire burnt out or was extinguished;(d) the location of fire (e.g. clean timber stockpile, putrescible garbage cell);(e) prevailing weather conditions at the time of the fire;(f) observations made in regard to smoke direction and dispersion;(g) the amount of waste that was combusted by the fire;(h) action taken to extinguish the fire; and(i) action taken to prevent a reoccurrence.

Compliant The SUEZ incident register recorded two fires during the audit period atLHRRP:

· 05.02.17- Active tip face – the written notification to the EPA wasprovided to the auditors. The information required under thiscondition was included.

· 05.05.17 – Active tip face - the written notification to the EPA wasprovided to the auditors. The information required under thiscondition was included.

These two fires were reported in the Annual Return.

Refer to condition R4.1 for more information on reporting of fires to theEPA.


A54 of 74

ConditionNo.



R1.1 Annual return documents

The licensee must complete and supply to the EPA an Annual Return in theapproved form comprising:

1. a Statement of Compliance,2. a Monitoring and Complaints Summary,3. a Statement of Compliance - Licence Conditions,4. a Statement of Compliance - Load based Fee,5. a Statement of Compliance - Requirement to Prepare Pollution Incident ResponseManagement Plan,6. a Statement of Compliance - Requirement to Publish Pollution Monitoring Data;and7. a Statement of Compliance - Environmental Management Systems and Practices.At the end of each reporting period, the EPA will provide to the licensee a copy ofthe form that must be completed and returned to the EPA.

Compliant During the audit period one Annual Return was submitted to the EPA forthe period from 21.08.16 to 20.08.17.

The Annual Return looked to be in the approved form as per thiscondition.

R1.2 An Annual Return must be prepared in respect of each reporting period, except asprovided below.

Noted Noted

R1.3 Where this licence is transferred from the licensee to a new licensee:

a) the transferring licensee must prepare an Annual Return for the periodcommencing on the first day of the reporting period and ending on the date theapplication for the transfer of the licence to the new licensee is granted; andb) the new licensee must prepare an Annual Return for the period commencing onthe date the application for the transfer of the licence is granted and ending on thelast day of the reporting period.


R1.4 Where this licence is surrendered by the licensee or revoked by the EPA or Minister,the licensee must prepare an Annual Return in respect of the period commencing onthe first day of the reporting period and ending on:

a) in relation to the surrender of a licence - the date when notice in writing ofapproval of the surrender is given; orb) in relation to the revocation of the licence - the date from which notice revokingthe licence operates.


R1.5 The Annual Return for the reporting period must be supplied to the EPA viaeConnect EPA or by registered post not later than 60 days after the end of eachreporting period or in the case of a transferring licence not later than 60 days afterthe date the transfer was granted (the 'due date').


The Annual Return (21.08.16-20.08.17) was required to be submitted tothe EPA before 20.10.17.

The auditors reviewed the EPA POEO Public Register which identifiedthat the annual return was submitted on the 20.10.17.

This condition was found to be an administrative non-compliance as theannual return was submitted 61 days following the reporting period.

R1.6 The licensee must retain a copy of the Annual Return supplied to the EPA for aperiod of at least 4 years after the Annual Return was due to be supplied to the EPA.

Compliant SUEZ reported that Annual Returns are kept on file indefinitely. The sitewas able to provide a copy of the Annual Return for the audit period..

R1.7 Within the Annual Return, the Statements of Compliance must be certified and theMonitoring and Complaints Summary must be signed by:

a) the licence holder; orb) by a person approved in writing by the EPA to sign on behalf of the licence holder.Note: The term "reporting period" is defined in the dictionary at the end of thislicence. Do not complete the Annual Return until after the end of the reportingperiod.Note: An application to transfer a licence must be made in the approved form for thispurpose.

Compliant The Annual Return was signed by the SUEZ Director on the 18.10.17.

R2.1 Notification of environmental harm

Notifications must be made by telephoning the Environment Line service on 131555.

Compliant The LHRRP reported two fires to the EPA in accordance with thiscondition. Refer to Condition R4.1 for further information.SUEZ reported that no other incidents of environmental harm occurred atLHRRP during the audit period.


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ConditionNo.



R2.2 The licensee must provide written details of the notification to the EPA within 7 daysof the date on which the incident occurred.

Note: The licensee or its employees must notify all relevant authorities of incidentscausing or threatening material harm to the environment immediately after theperson becomes aware of the incident in accordance with the requirements of Part5.7 of the Act.


The LHRRP reported two fires to the EPA in accordance with thiscondition.As identified in Condition R4.1 written notification of the small fire on the5.5.17 was provided to the EPA in an email dated 15.05.17, which is 10days after the date of the incident, therefore this condition has beenassessed as an administrative non-compliance.

R3.1 Written report

Where an authorised officer of the EPA suspects on reasonable grounds that:

a) where this licence applies to premises, an event has occurred at the premises; orb) where this licence applies to vehicles or mobile plant, an event has occurred inconnection with the carrying out of the activities authorised by this licence,

and the event has caused, is causing or is likely to cause material harm to theenvironment (whether the harm occurs on or off premises to which the licenceapplies), the authorised officer may request a written report of the event.

Noted During the audit period the EPA issued a letter dated 27.06.17 to SUEZrequesting information be provided on two issues:· stormwater management infrastructure works; and· stormwater discharge management on weekends.

Refer to SSD6835 Condition C30 for a discussion of the request from theEPA.

R3.2 The licensee must make all reasonable inquiries in relation to the event and supplythe report to the EPA within such time as may be specified in the request.

Compliant As per condition R3.1, the EPA requested SUEZ provide an update bythe 28.07.17. A response from SUEZ to the EPA, dated 27.07.17 wassighted by the auditors.

R3.3 The request may require a report which includes any or all of the followinginformation:

a) the cause, time and duration of the event;b) the type, volume and concentration of every pollutant discharged as a result of theevent;c) the name, address and business hours telephone number of employees or agentsof the licensee, or a specified class of them, who witnessed the event;d) the name, address and business hours telephone number of every other person(of whom the licensee is aware) who witnessed the event, unless the licensee hasbeen unable to obtain that information after making reasonable effort;e) action taken by the licensee in relation to the event, including any follow-upcontact with any complainants;f) details of any measure taken or proposed to be taken to prevent or mitigateagainst a recurrence of such an event; andg) any other relevant matters.

Noted Noted

R3.4 The EPA may make a written request for further details in relation to any of theabove matters if it is not satisfied with the report provided by the licensee. Thelicensee must provide such further details to the EPA within the time specified in therequest.

Compliant With regards to R3.2, no written requests from the EPA for further detailswere sighted by the auditors.

R4.1 Notification of Fires

The licensee must notify the details of the occurrence of all fires on the premises tothe EPA in accordance with conditions R2.1, R2.2 and R2 note.

Notifications must include the data recorded under condition M8.7 at the time ofnotification.

Compliant The LHRRP recorded the following fires during the audit period:

· 5.2.17 – Small Fire on the tarpomatic unit near the active tippingface. The EPA was notified via telephone on the 7.2.17 (referencenumber C01736-2017) and provided written notification in a letterdated 10.2.17. The written notification included the informationrequired under condition M8.7.

· 5.5.17 – Small fire on the landfill tipping face. The EPA was notifiedvia telephone on the 5.5.17 (reference number C07219-2017) andprovided written notification via email dated 15.05.17, attachmentincluded a letter dated 12.5.17. The written notification included theinformation required under condition M8.7. An email from the EPA,dated 22.05.17, acknowledged receipt of the letter and request nofurther information.

The two fires above were reported in the Annual Return.


A56 of 74

ConditionNo.



R4.2 Notification of Groundwater Contamination by Leachate and proposedremediation action

In the event that monitoring detects ammonia in groundwater at a concentrationabove 1 mg/L in any of the points 4, 7, 8, 16, 17, 18, 19, 24, 25, 26, 27, 44, 45, 46,47, 48 or 49, the licensee must send written notification to the EPA within 14 days ofthe monitoring results becoming available.

Not triggered This condition was added on 7.12.17 as part of the licence variation.Monitoring points 24, 25, 26, 27, 44, 45, 46, 47, 48, 49, 50 were addedon the EPL on the 7.12.17.

The auditors reviewed the Quarterly Report for Water Monitoring,prepared by CES which included groundwater monitoring data from theMarch, June, September and December sampling rounds. Noexceedances of ammonia levels were recorded.

It was noted that during the June sampling round Point 16 (MB305) andPoint 17 (MB306) were not monitored due to access restrictions.

G1.1 Copy of licence kept at the premises or plantA copy of this licence must be kept at the premises to which the licence applies.

Compliant The licence is maintained in the Site office and electronically on theSUEZ system.

G1.2 The licence must be produced to any authorised officer of the EPA who asks to seeit.


G1.3 The licence must be available for inspection by any employee or agent of thelicensee working at the premises.

Compliant The licence is maintained in the Site office and electronically on theSUEZ system.

E1.1 Requirement To Maintain Financial Assurance

A financial assurance in the form of an unconditional and irrevocable and ondemand guarantee from a bank, building society or credit union operating inAustralia as “Authorised Deposit-taking Institutions” under the Banking Act 1959 ofthe Commonwealth of Australia and supervised by the Australian PrudentialRegulatory Authority (APRA) must be maintained during the operation of the facilityand thereafter until such time as the EPA is satisfied the premises areenvironmentally secure. The financial assurance must be in favour of the EPA in theamount of four million six hundred and forty four thousand dollars ($4,644,000). Thefinancial assurance is required to secure or guarantee funding for works or programsrequired by or under this licence. The financial assurance must contain a term thatprovides that any monies claimed can be paid to the EPA or, at the written directionof the EPA, to any other person.

Compliant The Banker’s Undertaking, dated 16.09.13 (Ref No.130365), was sightedby the auditors, for the maximum aggregate sum of four million sixhundred and forty four thousand Australian dollars.

E1.2 The financial assurance must be replenished by the full amount claimed or realised ifthe EPA has claimed on or realised the financial assurance or any part of it toundertake a work or program required to be carried out by the licence which has notbeen undertaken by the licence holder.


E1.3 The EPA may require an increase in the amount of the financial assurance at anytime as a result of reassessment of the total likely costs and expenses ofrehabilitation of the premises.


E1.4 The licensee must provide to the EPA the original counterpart guarantee within fiveworking days of the issue of:

(a) the financial assurance required by condition E1.1; or(b) the adjusted financial assurance as required by condition E1.2 and E1.3


E2.1 Environmental Obligations of Licensee (Works and Programs)

While the licensee’s premises are being used for the purpose to which the licencerelates, the licensee must:

(a) Clean up any spill, leak or other discharge of any waste(s) or other material(s)as soon as practicable after it becomes known to the licensee or to one of thelicensee’s employees or agents.(b) In the event(s) that any liquid and non-liquid waste(s) is unlawfully deposited onthe premises, such waste(s) must be removed and lawfully disposed of as soon aspracticable or in accordance with any direction given by the EPA.(c) Provide all monitoring data as required by the conditions of this licence or asdirected by the EPA.

Compliant a) SUEZ has a Spill Response procedure (SOP007) for the managementof spills. During the site inspection the auditors did not observe spills ordischarges of waste. Spill kits were available on site as sighted duringthe audit.

b) Refer to SSD 6835, Condition C3 and EPL 5065, Condition L3.1 for adiscussion of rejected waste procedures.

c) Refer to specific conditions within this EPL for assessment of reportingrequirements to the EPA.


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ConditionNo.



E2.2 In the event of an earthquake, storm, fire, flood or any other event where it isreasonable to suspect that a pollution incident has occurred, is occurring or is likelyto occur, the licensee (whether or not the premises continue to be used for thepurposes to which the licence relates) must:

(a) Make all efforts to contain all firewater on the licensee’s premises;(b) Make all efforts to control air pollution from the licensee’s premises;(c) Make all efforts to contain any discharge, spill or run-off from the licensee’spremises;(d) Make all efforts to prevent flood water entering the licensee’s premises;(e) Remediate and rehabilitate any exposed areas of soil and/or waste;(f) Lawfully dispose of all liquid and solid waste(s) stored on the premises that is notalready securely disposed of;(g) At the request of the EPA monitor groundwater beneath the licensee’s premisesand its potential to migrate from the licensee’s premises;(h) At the request of the EPA monitor surface water leaving the licensee’s premises;and(i) Ensure the licensee’s premises is secure.

Not triggered An earthquake, storm, fire, flood or pollution event did not occur duringthe audit period therefore this condition has not been triggered. It wasnoted that the Site has an ERP and PIRMP which would be implementedin the event of an emergency. The Site has firewater tanks and spill kitsavailable.

E2.3 After the licensee’s premises cease to be used for the purpose to which the licencerelates or in the event that the licensee ceases to carry out the activity that is thesubject of this licence, that licensee must

(a) remove and lawfully dispose of all liquid and non-liquid waste stored on thelicensee’s premises;(b) rehabilitate the site, including conducting an assessment of and if requiredremediation of any site contamination.


E3.1 EPA May Claim On a Financial Assurance

The EPA may claim on a financial assurance under s303 of the POEO Act if alicensee fails to carry out any work or program required to comply with the conditionsof this licence.


E4.1 Final Capping LayerThe final capping layer must be installed to the following specification starting withthe seal bearing layer being applied onto the waste mass:- 100mm topsoil- 250mm revegetation layer- 500mm subsoil layer- 600mm low permeability compacted clay- 300mm Seal bearing layer


E5.1 Expansion of Landfill Gas Field InfrastructureThe licensee must expand the existing gas field infrastructure in accordance withLicence Condition O5.10 and the plans and design and installation specificationsattached to the approved operational purpose deduction application received by theEPA on 27 March 2015 and titled:

a. 160mm Leachate Extraction Well Design, drawing number LFGP-DP-079,revision 0, design date 20/02/03, prepared by Energy Developments;

b. 90mm J-Trap Detail (017985), drawing number LFGP-DP-005, revision 6, designdate 7/11/95, prepared by Energy Developments;

c. 110mm Horizontal Well, drawing number LFGP-DP-114, revision A, design date26/02/15, prepared by Energy Developments;

d. Lucas Heights 2 LFG Power Project, Gas Extraction System Design Layout - Area5-2, drawing number 840-AB-192, revision A, design date 05/02/14, prepared byEnergy Developments;

e. Lucas Heights 2 LFG Power Project, Area 5-3 EPA Levy, drawing number 840-AB-193, revision A, design date 26/02/15, prepared by Energy Developments.

Not assessed SUEZ reported that the expansion of the Landfill Gas Field Infrastructurerequired under this condition had been completed. A review of thedocuments referred to in this condition was not undertaken as part of thisaudit.


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ConditionNo.



E5.2 The licensee must expand the existing gas field infrastructure in accordance withLicence Condition O5.10 and the description and plans included in the approvedoperational purpose deduction application received by the EPA on 5 November 2015and titled:

a. Description of Proposed Works - Gas Extraction System Extension (page 2-3 ofapproved operational purpose deduction application);b. Lucas Heights 2 LFG Power Project, Main Header Replacement Area 5-2 – Stage76 Part A, drawing number 840-AB-196, revision A, design date 04/07/15, preparedby Energy Developments;c. Lucas Heights 2 LFG Power Project, Relocation of Main Header in Area 5-1 toArea 5-2 – Stage 76 Part B, drawing number 840-AB-199, revision A, design date22/07/15,prepared by Energy Developments;d. Lucas Heights 2 LFG Power Project, Area 5-2 Shallow Well Installation Stage 76Part D, drawing number 840-AB-200, revision A, design date 22/07/15, prepared byEnergy Developments.

Not assessed SUEZ reported that the expansion of the Landfill Gas Field Infrastructurerequired under this condition had been completed. A review of theoperational deduction application described in this condition was notundertaken as part of this audit.

E6.1 Construction of Landfill - Dual Gas and Leachate Trench

The licensee must construct and install a dual gas and leachate management trenchin accordance with Licence Condition O5.10 and the below plans and designsreceived by the EPA on 20 July 2017 and titled:

· Construction Environmental Management Plan Part 1 - Landfill RelatedConstruction works only Dual Gas and Leachate Trench construction works,Lucas Heights Resource Recovery Park (version no. 0031, July 2017),prepared by Suez,

· Phase 1 to 4 Filling, Proposed dual gas / leachate trench, sections and details,Drawing No. 147-Se-CL-LHRRP-DA-001 (Revision A, Issued for review on13.07.17), prepared by Suez,

· Phase 1 to 4 Filling, Proposed dual gas / leachate trench, sections and details,Drawing No. 147-Se-CL-LHRRP-DA-002 (Revision A, Issued for review on13.07.17), prepared by Suez, and

· Phase 1 to 4 Filling, Proposed dual gas / leachate trench, sections and details,Drawing No. 147-Se-CL-LHRRP-DA-003 (Revision A, Issued for review on13.07.17), prepared by Suez.

Not triggered This condition was added on 7.12.17 as part of a licence variation.

At the time of the audit the construction of the Dual Gas and LeachateTrench had not commenced.

E7.1 Reprofiling (overtopping) worksThe licensee must conduct the re-profiling (stages 1, 2, 3 and 4) works inaccordance with the below plans and designs received by the EPA on 12 October2017 and titled:· Development Consent under Section 89E of the Environmental Planning and

Assessment Act 1979 for Application No SSD 6835 issued to SITA AustraliaPty Ltd and Sutherland Shire Council, dated 23 January 2017 and signed byJoe Woodward PSM, Member of the Commission (Chair),

· Final Landform Phase 1 to 4 Fill Areas, Suez Recycling & Recovery LucasHeights RRP, Drawing Job Number 21-20508 (Revision A), prepared by GHD,and

· Proposed Reprofiling Development Plan, Drawing Job number 21-23482,Landform marked "Phase 1" (Revision C, 3 July 2015) prepared by GHD,

· Proposed Reprofiling Development Plan, Drawing Job number 21-23482,Landforms marked "Phase 2" and "Phase 3", (Revision C, 3 July 2017),prepared by GHD, and

· Proposed Reprofiling Development Plan, Drawing Job number 21-23482,Landform marked "Phase 4", (Revision C, 3 July 2017), prepared by GHD.

Not triggered This condition was added on 7.12.17 as part of a licence variation.

At the time of the audit the re-profiling of Section D had commenced inJanuary 2018. It is noted that SUEZ have begun works in Phase 3 (AreaD) which is not in the sequence provided.

This condition has not been triggered as re-profiling works had only justcommenced at the time of the audit. An assessment of compliance withthe SSD 6835 has been undertaken and is provided above.


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1.3 EPL 12520Condition No. Summary of Condition/Requirement Compliance Status Comment Recommendations

EPL No. 125201 Administration ConditionsA1 What the licence authorises and regulates

A1.1 This licence authorises the carrying out of the scheduled activities listed below at thepremises specified in A2. The activities are listed according to their scheduled activityclassification, fee-based activity classification and the scale of the operation.

Unless otherwise further restricted by a condition of this licence, the scale at which theactivity is carried out must not exceed the maximum scale specified in this condition.


Composting Composting >500 - 50000 T annualcapacity to receiveorganics


Non-thermal treatment ofgeneral waste

Any annual processingcapacity

Non-compliant SUEZ provided a Mandalay report from theSite’s weighbridge for the period from01.01.17 to 31.12.17. The weighbridgereport showed that 54,350.29 tonnes ofgreen waste was received at the Site.

SUEZ reported in the 2016/17 AnnualReturn a non-compliance with conditionA1.1. Where the Site exceeded themaximum of 50,000 tonnes of green wastereceived at site per reporting year by 8,053tonnes. SUEZ reported in the AnnualReturn that additional tonnes were a resultof fulfilling existing council contracts forgreenwaste collection and that no newcontracts had been taken on.

A2 Premises or plant to which this licence applies

A2.1 The licence applies to the following premises:

Premises Details

LUCAS HEIGHTS WASTE AND RECYCLING CENTRE

NEW ILLAWARRA ROAD

LUCAS HEIGHTS

NSW 2234

PART LOT 101 DP 1009354

PART LOT 101 DP1009354 LABELLED AS "GREEN WASTE PROCESSING AREA"ON MAP TITLED "PLAN OF SUBDIVISION OF LOT 10 IN DP 837126 FOR LEASEPURPOSES BEING PART LOT 1 IN DP 804455" DATED 21 DECEMBER 1999 ANDMAP TITLED "PLAN SHOWING POSITION OF GREENWASTE PROCESSING AREAWITHIN LOT 101 IN D.P.1009354 AT LUCAS HEIGHTS NO.2" DATED 28 JULY 2006

Noted Noted

A3 Information supplied to the EPA

A3.1 Works and activities must be carried out in accordance with the proposal contained inthe licence application, except as expressly provided by a condition of this licence


a) the applications for any licences (including former pollution control approvals) whichthis licence replaces under the Protection of the Environment Operations (Savings andTransitional) Regulation 1998; andb) the licence information form provided by the licensee to the EPA to assist the EPAin connection with the issuing of this licence.

Noted The application for the EPL andsubsequent variations has not beenreviewed as part of this audit.


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Condition No. Summary of Condition/Requirement Compliance Status Comment Recommendations

P1.1

P1.2

Location of monitoring/discharge points and areas

The following points referred to in the table below are identified in this licence for thepurposes of monitoring and/or the setting of limits for the emission of pollutants to theair from the point.

The following utilisation areas referred to in the table below are identified in this licencefor the purposes of the monitoring and/or the setting of limits for any application ofsolids or liquids to the utilisation area.

Compliant Concentrations of landfill gas (methaneequivalents were measured 5-10 cm abovethe ground surface at regular intervals(approximately 25 x 25 m grid).SUEZ conducted the following surface gasmonitoring:· 58 monitoring points were measured

on the 21.04.17· 58 monitoring points were measured

on the 16.08.17· 312 monitoring points were measured

on the 21.11.17



Compliant As described in the Greenwaste LiquorManagement Plan stormwater whichcomes into contact with the GO compoundis drained to the greenwaste liquor dam,aerated and reused to irrigate the compost.

SUEZ did not report any incidents ofpollution of waters during the audit period.

The auditors did not observe any practicesduring the audit period that may result inpollution of waters.


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L2.1 Waste

The licensee must not cause, permit or allow any waste to be received at thepremises, except the wastes expressly referred to in the column titled “Waste” andmeeting the definition, if any, in the column titled “Description” in the table below. Anywaste received at the premises must only be used for the activities referred to inrelation to that waste in the column titled “Activity” in the table below. Any wastereceived at the premises is subject to those limits or conditions, if any, referred to inrelation to that waste contained in the column titled “Other Limits” in the table below.This condition does not limit any other conditions in this licence.

Code Waste Description Activity Other Limits

NA Excavatednaturalmaterial

Waste thatmeets all theconditions of theexcavatednatural materialorder 2014

Wasteprocessing(non-thermaltreatment)

Only excavated natural materialthat meets the excavated naturalmaterial order 2014 can beblended with pastuerised gardenorganics that meets thepasteurised garden organicsorder 2016

NA Woodwaste


Composting The maximum quantity of woodwaste and garden wastecombined, for storage, processingor recovery at the premises mustnot exceed 125,000 cubic metresor 50,000 tonnes (based on adensity rate of 0.4) onsite peryear. The maximum quantity ofgarden waste and wood wastecombined, whether processed orunprocessed, must not exceed45,000 cubic metres or 18,000tonnes (based on a density rateof 0.4) onsite at any one time.

NA Gardenwaste


Composting The maximum quantity of woodwaste and garden wastecombined, for storage, processingor recovery at the premises mustnot exceed 125,000 cubic metresor 50,000 tonnes (based on adensity rate of 0.4) onsite peryear. The maximum quantity ofgarden waste and wood wastecombined, whetherprocessed or unprocessed, mustnot exceed 45,000 cubic metresor 18,000 tonnes (based on adensity rate of 0.4) onsite at anyone time.

NA Virginexcavatednaturalmaterial

As defined inSchedule 1 ofthe POEO Act,as in force fromtime to time.

Composting NA

NA Manure Composting NA

NA Fly ash Composting NA

Non-compliant SUEZ provided the Auditors with a dataextract from the Mandalay system (whichrecords weighbridge data). The report wasrun from the 01.01.17 to 31.12.17.

Based on this report the Site received thefollowing through the weighbridge:

· 54,350.29 tonnes of green waste.

· 510.22 tonnes of manure

· 84.50 tonnes of ash

· 629.34 tonnes of unpasteurisedblending material (horse manure)

· 38,493.19 tonnes of inorganicblending material (sand)

As per condition L1.1, this condition hasbeen assessed as not compliant as morethan 50,000 tonnes of green waste wasaccepted on site.

SUEZ provided the auditors with a‘Resource Recovery Characterisation’certificate, prepared by DLA EnvironmentalServices, dated 24.03.17 (expiry 24.04.17)classifying approximately 27,000 tonnes ofsand material as VEMN.

To monitor the quantity of wood andgarden waste stored on site at any onetime the SUEZ quality assurancepersonnel conduct monthly stocktakesusing a GPS system. SUEZ provided theauditors with a sample of monthlystocktake reports for the ‘bottom’ and ‘top’stockpile pads.

Based on a review of the three months ofstocktake reports the volume of processedand unprocessed wood and garden wastedid not exceeded the limit in this condition,as shown below:

· February – 43,510 m2

· June – 44,024 m2

· December – 32,446 m2

This condition has been assessed as non-compliant as the volume of garden wastereceived on site exceeded the 50,000tonnes on site per year limit.

Refer to EPL 12520 Condition A1.1


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L3.1 Potentially offensive odour

No condition of this licence identifies a potentially offensive odour for the purposes ofsection 129 of the Protection of the Environment Operations Act 1997.

Note: Section 129 of the Protection of the Environment Operations Act 1997, providesthat the licensee must not cause or permit the emission of any offensive odour fromthe premises but provides a defence if the emission is identified in the relevantenvironment protection licence as a potentially offensive odour and the odour wasemitted in accordance with the conditions of a licence directed at minimising odour.

Compliant Four odour complaints were received onthe 23.06.17 which were attributed toactivities at the GO Facility.

As discussed under SSD 6835, ConditionC38, this condition has been assessed ascompliant as SUEZ has processes in placeto identify and manage odours, includinginvestigating complaints and implementingcontinual improvement controls.

O1.1 Activities must be carried out in a competent manner

Licensed activities must be carried out in a competent manner.This includes:a) the processing, handling, movement and storage of materials and substances usedto carry out the activity; andb) the treatment, storage, processing, reprocessing, transport and disposal of wastegenerated by the activity.

Compliant SUEZ maintains an overarching trainingneeds matrix which was developed bySUEZ Corporate to reflect the generictraining requirements of SUEZ forms,guides, manuals, plans, registers, SOPs,Work Instructions, procedures required foreach position (responsibility). Underneaththe training needs matrix, each site has aSite Training Matrix (REG004).

SUEZ provided a copy of the Site’sOrganics Training Matrix to the auditors forreview. The register included the trainingrequirements for each SUEZ employeeunder the following categories; externaltraining, inductions, health and safety,manuals, plans, policies, procedures,registers, standard operating procedures,work instructions, and fire warden training.A sample of Training Attendance Recordswas reviewed by the auditors.

O2.1 Maintenance of plant and equipment

All plant and equipment installed at the premises or used in connection with thelicensed activity:

a) must be maintained in a proper and efficient condition; andb) must be operated in a proper and efficient manner.

Compliant The GO Facility plant and equipment werebeing maintained by SUEZ. using anumber of tools including:· Pre-start checklists.· The MAINPAC system which tracks

required regular maintenance andissues noted in pre-start checklists.

O3.1 Dust

The premises must be maintained in a condition which minimises or prevents theemission of dust from the premises.

Compliant Refer to SSD 6835, Condition C9

O4.1 Emergency response

All activities and operations at the premises must be carried out in a manner that willprevent and minimise the risk of fire.

Compliant The GO EMP includes a general statementthat activities will be carried out in amanner that will prevent and minimise fireat the premises but does not includedetails of fire prevention measures.

SUEZ reported one incident of‘smouldering in an oversized stockpile’ onthe 20.02.17.

As discussed under condition E1.1 the GOEMP should be updated with fireprevention measures and a fire fightingprocedure.

Refer to condition E1.1


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O5.1 Waste management

The last licensee must prepare and submit to the EPA within twelve months prior tothe last load of waste being received a closure plan in accordance with section 76 ofthe Protection of the Environment Operations Act 1997.

Not triggered Not triggered during audit period.

O5.2 Waste liquor that has been appropriately aerated may be irrigated over the compostwindrows in accordance with the Lucas Heights 11 Greenwaste Liquor ManagementPlan.

Compliant SUEZ reported that it irrigates thegreenwaste liquor over the compost windrows as per the Greenwaste LiquorManagement Plan, dated January 2016.

The auditors observed that the GreenWaste Liquor dam was being aerated atthe time of the site inspection.

O5.3 Waste liquor irrigation must be conducted in a manner that prevents spray drifts. Compliant Irrigation of waste liquor was not observedby the auditors during the site inspection.The GO EMP and Greenwaste LiquorManagement Plan do not includeinformation on irrigation controls. SUEZdescribed the controls for limiting spraydrifts as:

· No fine mist nozzles are used

· Exclusion zone of 30m

· No spraying if wind speed is morethan 20km/hr

O5.4 Liquid which has come into contact with stockpiled waste, or with composting materialmust not be discharged to waters.

Compliant SUEZ considers liquid which has comeinto contact with stockpiled waste orcomposting material as leachate orgreenwaste liquor and manages itaccordingly. At the existing GO Facility rainwater which falls on the compound andany process water (leaching from thecomposting area) flows to the northeasterncorner of the GO Facility. From here itcollected water (greenwaste liquor) isdirected via pipes to the Green WasteLiquor Dam. The greenwaste liquor isaerated and used to irrigate compostwindrows prior to pasteurisation.



Noted Noted


a) in a legible form, or in a form that can readily be reduced to a legible form;b) kept for at least 4 years after the monitoring or event to which they relate took place;andc) produced in a legible form to any authorised officer of the EPA who asks to seethem.

Compliant a) Monitoring records were provided tothe auditors in a legible form (excelspreadsheets).

b) Monitoring records were available forthe audit period. It was reported thatresults are maintained indefinitely inan electronic format.

c) It was reported that there had beenno instances where an authorisedofficer of the EPA asked to see thedata.


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M1.3 The following records must be kept in respect of any samples required to be collectedfor the purposes of this licence:



The surface gas monitoring excel datasheets were provided to the auditors.These excel records included the date,time and sample point number (with GPSreference coordinates. The person whoundertook the sampling was not includedin the April and August sampling records.The November Sampling record layoutshould be used by SUEZ for futuremonitoring rounds to ensure compliancewith this condition.

2018-IEA-REC26:

Include the name of the person whoconducted the surface gas monitoring inthe excel data sheets.

M2.1/M2.2 Requirement to monitor concentration of pollutants discharged

For each monitoring/discharge point or utilisation area specified below (by a pointnumber), the licensee must monitor (by sampling and obtaining results by analysis) theconcentration of each pollutant specified in Column 1. The licensee must use thesampling method, units of measure, and sample at the frequency, specified opposite inthe other columns:

Air Monitoring RequirementsPOINT 1

Pollutant Units of measure Frequency Samplingmethod

Methane parts per million Quarterly Special Method 1

Non-compliant During the audit period monitoring ofmethane at surface gas monitoring pointswas undertaken on the 21.04.17, 16.08.17and 21.11.17.

Monitoring was not undertaken quarterlytherefore this condition has been assessedas not compliant.

It was noted that ‘Special Method 1’ is notdefined in the EPL. EPL 5065 definesSpecial Method 1 for methane monitoringas in accordance with the methodsoutlined in Chapter 5.3 Landfill gas sub-surface monitoring of EnvironmentalGuidelines: Solid Waste Landfills (NSWEPA, Second Edition, September 2016)and it is assumed it would have the samemeaning for EPL 12520.

SUEZ should seek to have Special Method1 defined in the next licence variation.

2018-IEA-OFI18:Include the definition of ‘Special Method inthe next licence variation of EPL 12520.

M3.1 Testing methods - concentration limits

Monitoring for the concentration of a pollutant emitted to the air required to beconducted by this licence must be done in accordance with:

a) any methodology which is required by or under the Act to be used for the testing ofthe concentration of the pollutant; orb) if no such requirement is imposed by or under the Act, any methodology which acondition of this licence requires to be used for that testing; orc) if no such requirement is imposed by or under the Act or by a condition of thislicence, any methodology approved in writing by the EPA for the purposes of thattesting prior to the testing taking place.Note: The Protection of the Environment Operations (Clean Air) Regulation 2010requires testing for certain purposes to be conducted in accordance with test methodscontained in the publication "Approved Methods for the Sampling and Analysis of AirPollutants in NSW".

Not assessed As discussed in the GO EMP, surface gasmonitoring is conducted internally by theCompliance officer on a quarterly basis inaccordance with the BenchmarkTechniques 17 of the Solid Waste LandfillGuidelines.

The only monitoring of a pollutant emittedto air required by this licence is formethane monitoring (% v/v) by SpecialMethod 1 (M2.). As noted under M2.2above, Special Method 1 is not definedhowever is assumed to be in accordancewith the methods outlined in the Chapter5.3 Landfill gas sub-surface monitoring ofEnvironmental Guidelines: Solid WasteLandfills (NSW EPA, Second Edition,September 2016).

An assessment of monitoringmethodologies was not undertaken as partof this audit.


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M4.1 Recording of pollution complaints

The licensee must keep a legible record of all complaints made to the licensee or anyemployee or agent of the licensee in relation to pollution arising from any activity towhich this licence applies.

Compliant Refer to EPL 5065, Condition M5.1.

M4.2 The record must include details of the following:

a) the date and time of the complaint;b) the method by which the complaint was made;c) any personal details of the complainant which were provided by the complainant or,if no such details were provided, a note to that effect;d) the nature of the complaint;e) the action taken by the licensee in relation to the complaint, including any follow-upcontact with the complainant; andf) if no action was taken by the licensee, the reasons why no action was taken.





Not triggered During the audit period the Site reportedthat the EPA did not request a recordtherefore this condition has not beentriggered.

M5.1 Telephone complaints line

The licensee must operate during its operating hours a telephone complaints line forthe purpose of receiving any complaints from members of the public in relation toactivities conducted at the premises or by the vehicle or mobile plant, unless otherwisespecified in the licence.




M5.3 The preceding two conditions do not apply until 3 months after: the date of the issue ofthis licence.


R1.1 Annual return documents

The licensee must complete and supply to the EPA an Annual Return in the approvedform comprising:

1. a Statement of Compliance,2. a Monitoring and Complaints Summary,3. a Statement of Compliance - Licence Conditions,4. a Statement of Compliance - Load based Fee,5. a Statement of Compliance - Requirement to Prepare Pollution Incident ResponseManagement Plan,6. a Statement of Compliance - Requirement to Publish Pollution Monitoring Data; and7. a Statement of Compliance - Environmental Management Systems and Practices.At the end of each reporting period, the EPA will provide to the licensee a copy of theform that must be completed and returned to the EPA.

Compliant During the audit period one Annual Returnwas submitted to the EPA for the periodfrom 01.04.16 to 31.03.17.

The Annual Return looked to be in theapproved form as per this condition.


Noted Noted

R1.3 Where this licence is transferred from the licensee to a new licensee:

a) the transferring licensee must prepare an Annual Return for the period commencingon the first day of the reporting period and ending on the date the application for thetransfer of the licence to the new licensee is granted; andb) the new licensee must prepare an Annual Return for the period commencing on thedate the application for the transfer of the licence is granted and ending on the last dayof the reporting period.



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R1.4 Where this licence is surrendered by the licensee or revoked by the EPA or Minister,the licensee must prepare an Annual Return in respect of the period commencing onthe first day of the reporting period and ending on:

a) in relation to the surrender of a licence - the date when notice in writing of approvalof the surrender is given; orb) in relation to the revocation of the licence - the date from which notice revoking thelicence operates.


R1.5 The Annual Return for the reporting period must be supplied to the EPA via eConnectEPA or by registered post not later than 60 days after the end of each reporting periodor in the case of a transferring licence not later than 60 days after the date the transferwas granted (the 'due date').

Compliant The Annual Return (01.04.16 to 31.03.17)was required to be submitted to the EPAbefore 31.05.17.

The auditors reviewed the EPA POEOPublic Register which identified that theannual return was submitted on the29.05.17.

R1.6 The licensee must retain a copy of the Annual Return supplied to the EPA for a periodof at least 4 years after the Annual Return was due to be supplied to the EPA.

Compliant The site was able to provide a copy of theAnnual Return for the reporting period.

R1.7 Within the Annual Return, the Statements of Compliance must be certified and theMonitoring and

Complaints Summary must be signed by:

a) the licence holder; orb) by a person approved in writing by the EPA to sign on behalf of the licence holder.Note: The term "reporting period" is defined in the dictionary at the end of this licence.Do not complete the Annual Return until after the end of the reporting period.Note: An application to transfer a licence must be made in the approved formfor this purpose.

Compliant The Annual Return was signed by theSUEZ Director on the 29.05.17.

R2.1 Notification of environmental harm

Notifications must be made by telephoning the Environment Line service on 131 555

Not triggered SUEZ reported that no incidents ofenvironmental harm occurred at the GOFacility during the audit period.

Environmental incidents are discussed isSection 5.1 of the main report.

R2.2 The licensee must provide written details of the notification to the EPA within 7 days ofthe date on which the incident occurred.

Note: The licensee or its employees must notify all relevant authorities of incidentscausing or threatening material harm to the environment immediately after the personbecomes aware of the incident in accordance with the requirements of Part 5.7 of theAct.

Not triggered SUEZ reported that no incidents ofenvironmental harm occurred at the GOFacility during the audit period.

R3.1 Written report

Where an authorised officer of the EPA suspects on reasonable grounds that:

a) where this licence applies to premises, an event has occurred at the premises; orb) where this licence applies to vehicles or mobile plant, an event has occurred inconnection with the carrying out of the activities authorised by this licence,and theevent has caused, is causing or is likely to cause material harm to the environment(whether the harm occurs on or off premises to which the licence applies), theauthorised officer may request a written report of the event.

Not triggered The auditors were not informed of anyinstances where the EPA requested awritten report in respect to an event onsite.

R3.2 The licensee must make all reasonable inquiries in relation to the event and supply thereport to the EPA within such time as may be specified in the request.



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R3.3 The request may require a report which includes any or all of the following information:

a) the cause, time and duration of the event;b) the type, volume and concentration of every pollutant discharged as a result of theevent;c) the name, address and business hours telephone number of employees or agentsof the licensee, or a specified class of them, who witnessed the event;d) the name, address and business hours telephone number of every other person (ofwhom the licensee is aware) who witnessed the event, unless the licensee has beenunable to obtain that information after making reasonable effort;e) action taken by the licensee in relation to the event, including any follow-up contactwith any complainants;f) details of any measure taken or proposed to be taken to prevent or mitigate againsta recurrence of such an event; andg) any other relevant matters.


R3.4 The EPA may make a written request for further details in relation to any of the abovematters if it is not satisfied with the report provided by the licensee. The licensee mustprovide such further details to the EPA within the time specified in the request.


R4.1 Annual Waste Summary Reporting

The licensee must complete and submit to the EPA an Annual Waste SummaryReport each financial year.

Compliant SUEZ provided the auditors with a copy ofthe Annual Waste Report: Lucas HeightsWaste and Recycling Centre – 12520,which was submitted to the EPA for the2016/17 reporting period.

R4.2 The Annual Waste Summary Report must be submitted to the EPA via the Waste andResource Reporting Portal (WARRP) within 60 days of the end of the financial year.

Compliant The Annual Waste Report was due on29.08.17. The Report stated that it wascertified by SUEZ on 24.08.17.

G1.1 Copy of licence kept at the premises or plantA copy of this licence must be kept at the premises to which the licence applies.

Compliant A copy of the EPL is kept at GO FacilitySite office and electronically on the SUEZsystem.

G1.2 The licence must be produced to any authorised officer of the EPA who asks to see it Not triggered Not triggeredG1.3 The licence must be available for inspection by any employee or agent of the licensee

working at the premises.Compliant A copy of the EPL is kept at GO Facility

Site office and electronically on the SUEZsystem.

U1.1 Reduction in amount of garden and wood waste stored at the Premises to below18,000 tonne and 45,000 cubic metre licence limits

The licensee must remove from the premises the following quantities of material(expressed in tonnes and cubic metres) to meet the following schedule:

Schedule Date Total Tonnes of Gardenand Wood Waste

Onsite

Total Cubic Metres ofGarden and Wood

Waste Onsite

31 July 2015 22,501 56,252

30 October 2015 19,001 47,502

30 November 2015 18,000 45,000

Not assessed Given the scheduled dates, it is assumedthis condition has been completed. Thiscondition has not been assessed in thisaudit as it is outside of the audit period.

2018-IEA-REC27:

In the next variation of EPL 12520, seek tohave the completed Pollution Studies andReduction Programs marked as completed.

U1.2 a) The licensee must undertake a volumetric survey of all stockpiles containingprocessed and unprocessed garden and wood waste at the Premises to determinecompliance with the scheduled reduction targets specified in U1.1.

b) The licensee must submit a diagram to the EPA no later than 14 days after eachvolumetric survey has been undertaken. The diagram must include the volume andtonnage (based on an average bulk density rate of 0.4) of each stockpile containingprocessed and unprocessed garden and wood waste stored on the Premises.

Not assessed Given the scheduled dates, it is assumedthis condition has been completed and hasnot been assessed un this audit as it isoutside of the audit period.

As per recommendation in U1.1


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E1.1 Environment Management Plan (EMP)

The licensee must prepare an Environment Management Plan (EMP) to ensurecompliance with the conditions of this licence and relevant Environmental Legislationfor the premises. The EMP must, as a minimum, address the matters listed inAppendix C of the DEC’s Environmental Guidelines: Composting and RelatedOrganics Processing Facilities Guidelines (July 2004).

Compliant The Lucas Heights Organics FacilityEnvironmental Management Plan (GOEMP) was last updated on 25.05.17(Version 5).

The auditors conducted a high level reviewof the GO EMP against the Compostingand Related Organics Processing FacilitiesGuidelines and found the plan wasprepared generally in accordance with theguideline, except that the plan does notinclude a section on fire fighting andprevention other than stating that the GOdam may be used for fire fightingpurposes.

The GO EMP does not reference therequirements of the Pasteurised GardenOrganics Order 2016.

2018-IEA-OFI19:

Update the GO EMP to include fireprevention measures and fire-fightingprocedures as required by the EPAEnvironmental Guidelines: Composting andRelated Organics Processing FacilitiesGuidelines (July 2004) and also toreference the requirements of thePasteurised Garden Organics Order 2016.

E1.2 The licensee must submit the EMP required by condition E1.1 of this licence to theDEC’s Manager Waste Operations by 30 November 2006.

Not assessed It is assumed this condition has beencompleted and has not been assessed unthis audit as it is outside of the auditperiod.

As per recommendation in U1.1

1.4 EPL 13114Condition No. Summary of Condition/Requirement Compliance Status Comment Recommendations

A1.1 What the licence authorises and regulates

This licence authorises the carrying out of the scheduled activities listed below at thepremises specified in A2. The activities are listed according to their scheduled activityclassification, fee-based activity classification and the scale of the operation.

Unless otherwise further restricted by a condition of this licence, the scale at which theactivity is carried out must not exceed the maximum scale specified in this condition.


Waste Storage Waste Storage – othertypes of waste

>0 T stored

No triggered SUEZ reported that no waste was receivedor stored at the PCYC site, to which thislicence applies.

A2.1 Premises or plant to which this licence applies

The licence applies to the following premises:

Premises DetailsLUCAS HEIGHTS PCYC MINIBIKE CLUB AREANEW ILLAWARRA ROADLUCAS HEIGHTSNSW 2234PART LOT 101 DP 1009354AS SHOWN ON THE MAP RECIEVED BY THE EPA 6 MAY 2009, TITTLED "PLANSHOWING AREA LICENSED TO PCYC PART LOT 101 IN DP 1009354 LUCASHEIGHTS" AND DATED 28 APRIL 2009. REF: 11925

Noted Noted


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A3.1 Information supplied to the EPA

Works and activities must be carried out in accordance with the proposal contained inthe licence application, except as expressly provided by a condition of this licence.


a) the applications for any licences (including former pollution control approvals) whichthis licence replaces under the Protection of the Environment Operations (Savings andTransitional) Regulation 1998; andb) the licence information form provided by the licensee to the EPA to assist the EPAin connection with the issuing of this licence.

Noted The application for the EPL andsubsequent variations has not beenreviewed as part of this audit.

P1.1

P1.2

Location of monitoring/discharge points and areas

The following points referred to in the table are identified in this licence for thepurposes of the monitoring and/or the setting of limits for discharges of pollutants towater from the point.

The following utilisation areas referred to in the table below are identified in this licencefor the purposes of the monitoring and/or the setting of limits for any application ofsolids or liquids to the utilisation area.

Compliant SUEZ undertook monitoring of the PCYCDam (Point 1) on the 30.08.17. Refer tocondition M2.2 for a review of monitoring.



Compliant SUEZ did not report any incidents ofpollution of waters during the audit period.


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L2.1 Waste

The licensee must not cause, permit or allow any waste to be received at thepremises, except the wastes expressly referred to in the column titled “Waste” andmeeting the definition, if any, in the column titled “Description” in the table below.

Any waste received at the premises must only be used for the activities referred to inrelation to that waste in the column titled “Activity” in the table below.

Any waste received at the premises is subject to those limits or conditions, if any,referred to in relation to that waste contained in the column titled “Other Limits” in thetable below.This condition does not limit any other conditions in this licence.Code Waste Description Activity Other

LimitsNA General Solid

Waste (non-putrescible)

As defined inSchedule 1 of thePOEO Act, as inforce from time totime

- 50,000 T

NA General orSpecificexempted waste

Waste that meetsall the conditions ofa resource recoveryexemption underClause 51A of theProtection of theEnvironmentOperations (Waste)Regulation 2005

As specified ineach particularresourcerecoveryexemption

10,000 T

NA Waste Any waste receivedon site that is belowlicensing thresholdsin Schedule 1 of thePOEO Act, as inforcefrom time to time

- NA

Not triggered SUEZ reported that VENM had beenaccepted onto the Site historically forconstruction and maintenance of the biketracks.

SUEZ reported that no waste was receivedat the PCYC site during the audit period.

Weighbridge data provided by SUEZ forthe LHRRP did not identify any wastereceived as Site and sent to the PCYC.

L3.1 Noise limits

Noise from the premises must not exceed:a) 56 dB(A) LAeq(15 minute) during the day (7am to 6pm) Monday to Friday and 7am to1pm Saturday; andb) 55 dB(A) LAeq(15 minute) during the evening (6pm to 10pm) Monday to Friday; andc) at all other times 45 dB(A) LAeq (15 minute), except as expressly provided by this licence.Where LAeq means the equivalent continuous noise level – the level of noiseequivalent to the energy-average of noise levels occurring over a measurementperiod.

Compliant The new Consent (SSD 6835) includesnoise limits for the LHRRP that are morestringent than those in the EPL for thePCYC. SUEZ undertakes annualmonitoring to assess compliance withthose noise criteria as required byCondition C56 of the Consent.The annual noise assessment undertakenin October 2018 did not report anyexceedances of the noise limits.

L3.2 To determine compliance with condition(s) L6.1 noise must be measured at, orcomputed for, any affected noise sensitive locations (such as a residence, school orhospital). A modifying factor correction must be applied for tonal, impulsive orintermittent noise in accordance with the "Environmental Noise Management - NSWIndustrial Noise Policy (January 2000)".

Noted It is assumed that this condition refers toassessment of compliance with conditionL3.1.

Refer to L3.1 for a discussion of noisemonitoring.

O1.1 Activities must be carried out in a competent manner

Licensed activities must be carried out in a competent manner.This includes:a) the processing, handling, movement and storage of materials and substances usedto carry out the activity; andb) the treatment, storage, processing, reprocessing, transport and disposal of wastegenerated by the activity.

Compliant SUEZ reported that no waste was receivedon site requiring processing, handling orstorage.


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O2.1 Maintenance of plant and equipment

All plant and equipment installed at the premises or used in connection with thelicensed activity:

a) must be maintained in a proper and efficient condition; andb) must be operated in a proper and efficient manner.

Compliant Gas infrastructure at the PCYC minibikeclub is managed by EDL. EDL provide amonthly report to SUEZ which showsmethane concentration, flow and gasvolumes, broken monitoring points, whichwells are not producing gas (due tomalfunction or low gas volume). Theauditors were provided with the December2017 monthly report. EDL operates undera separate EPL.

No other plant and equipment is installedat the PCYC minibike club area.

O3.1 Dust

All operations and activities occurring at the premises must be carried out in a mannerthat will minimise the emission of dust from the premises.

Compliant SUEZ reported that the following measuresare implemented at the PCYC to minimisedust:

· During events track marshals waterthe track using hoses located atvarious locations around the circuit.Water is supplied by SUEZ fromeither on site stormwater storage orpotable water during dry periods.

· Water storage tanks located at theclub house also collect rain waterfrom the main building and are usedfor supply for dust suppression.

2018-IEA-OFI20:

Include measures to minimise the emissionof dust from the PCYC minibike club in theOEMP

O4.1 Processes and management

The licensee must ensure that any inert and/or solid for storage or transfer or recoveryby way of separating or processing at the premises is assessed and classified inaccordance with the DECC Waste Classification Guidelines as in force from time totime.

Not triggered SUEZ reported that no waste was receivedon site requiring processing, handling orstorage.

O5.1 Waste management

The total quantity of used, rejected or unwanted tyres (including shredded tyres andtyre pieces) stockpiled at the premises must not exceed 50 tonnes.

Not triggered SUEZ reported that tyres are not acceptedon site. No tyre stockpiles were observedby the auditors.

O5.2 The licensee must ensure that stockpiles of used, rejected or unwanted tyres(including shredded tyres and tyre pieces) are located in a clearly defined area.


O5.3 The licensee must ensure that stockpiles of used, rejected or unwanted tyres(including shredded tyres and tyre pieces) are managed so as not to cause or to belikely to cause the spread of disease by vermin.


O5.4 The licensee must ensure that measures are taken to prevent stockpiles of used,rejected or unwanted tyres (including shredded tyres and tyre pieces) from catching onfire.


O5.5 Without limiting 05.1 to 05.4, any area(s) used for the storage of used rejected orunwanted tyres (including shredded tyres and tyre pieces) at the facility must:

a) be surrounded by a fire break of at least six (6) metres width that is kept clear of allcombustible material; andb) be fenced or otherwise secured to prevent any unauthorised access to the tyres andthe fire break.




Noted Noted


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a) in a legible form, or in a form that can readily be reduced to a legible form;b) kept for at least 4 years after the monitoring or event to which they relate took place;andc) produced in a legible form to any authorised officer of the EPA who asks to seethem.

Compliant Monitoring records were available in alegible form.

M1.3 The following records must be kept in respect of any samples required to be collectedfor the purposes of this licence:a) the date(s) on which the sample was taken;b) the time(s) at which the sample was collected;c) the point at which the sample was taken; andd) the name of the person who collected the sample.

Compliant The ‘PCYC test cell annual returnsummary’ Excel workbook was reviewedby the auditors and noted to record all ofthe required information.

M2.1

M2.2


For each monitoring/discharge point or utilisation area specified below (by a pointnumber), the licensee must monitor (by sampling and obtaining results by analysis) theconcentration of each pollutant specified in Column 1. The licensee must use thesampling method, units of measure, and sample at the frequency, specified opposite inthe other columns:

Water and/ or Land Monitoring Requirements

POINT 1


Ammonia milligrams per litre Every 6 months Grab sample

pH pH Every 6 months Probe


milligrams per litre Every 6 months Grab sample

Non-compliant SUEZ published monitoring data forPoint 1 on the Lucas Heights website.SUEZ provided the laboratory reports formonitoring of Point 1 (PCYC Dam)undertaken on the 12.01.17 and 30.08.17.The monitoring recorded the followingresults:

· pH was between 7 and 7.7 pH whichis in the normal range for surfacewater.

· Ammonia ranged from <0.01 to 0.75mg/L.

· Suspended solids ranged from 7.6 to21 mg/L.

EPL 13114 Annual Return (09.06.16 to08.06.17) identifies that 14 samples weretaken over the annual return reportingperiod.

SUEZ also undertook monthly fieldsampling of Point 1 for water level,temperature, conductivity, pH, dissolvedoxygen and turbidity..

This condition has been assessed as notcompliant as sampling has not beenundertaken within a six month period forthe analytes required under this condition

2018-IEA-REC28:

Conduct surface water monitoring atPoint 1 every 6 months for analytesrequired under EPL 13114, condition M2.2.

M3.1 Testing methods - concentration limits

Subject to any express provision to the contrary in this licence, monitoring for theconcentration of a pollutant discharged to waters or applied to a utilisation area mustbe done in accordance with the Approved Methods Publication unless another methodhas been approved by the EPA in writing before any tests are conducted.

Note verified SUEZ did not provided the auditors with acopy of the monitoring records thereforethis could not be verified.

M4.1 Recording of pollution complaints

The licensee must keep a legible record of all complaints made to the licensee or anyemployee or agent of the licensee in relation to pollution arising from any activity towhich this licence applies.

Not triggered The 2016-17 Annual Return reported thatno complaints had been received for thePCYC.

Refer to EPL 5065, Condition M5.1 for theSUEZ process for recording complaints.


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M4.2 The record must include details of the following:a) the date and time of the complaint;b) the method by which the complaint was made;c) any personal details of the complainant which were provided by the complainant or,if no such details were provided, a note to that effect;d) the nature of the complaint;e) the action taken by the licensee in relation to the complaint, including any follow-upcontact with the complainant; andf) if no action was taken by the licensee, the reasons why no action was taken.

Not triggered Refer to EPL 5065, Condition M5.2 for theSUEZ process for recording complaints.


Not triggered Refer to EPL 5065, Condition M5.3 for theSUEZ process for recording complaints.



M5.1 Telephone complaints lineThe licensee must operate during its operating hours a telephone complaints line forthe purpose of receiving any complaints from members of the public in relation toactivities conducted at the premises or by the vehicle or mobile plant, unless otherwisespecified in the licence.




M5.3 The preceding two conditions do not apply until 3 months after:a) the date of the issue of this licence orb) if this licence is a replacement licence within the meaning of the Protection of theEnvironment Operations (Savings and Transitional) Regulation 1998, the date onwhich a copy of the licence was served on the licensee under clause 10 of thatregulation.


R1.1 Annual return documentsThe licensee must complete and supply to the EPA an Annual Return in the approvedform comprising:a) a Statement of Compliance; andb) a Monitoring and Complaints Summary.At the end of each reporting period, the EPA will provide to the licensee a copy of theform that must be completed and returned to the EPA.

Compliant The Annual Return for the period 9.06.16to 8.0617 was reviewed and noted toinclude the Statement of Compliance andMonitoring and Complaints Summary.


Noted Noted

R1.3 Where this licence is transferred from the licensee to a new licensee:a) the transferring licensee must prepare an Annual Return for the period commencingon the first day ofthe reporting period and ending on the date the application for the transfer of thelicence to the new licensee is granted; andb) the new licensee must prepare an Annual Return for the period commencing on thedate the application for the transfer of the licence is granted and ending on the last dayof the reporting period.


R1.4 Where this licence is surrendered by the licensee or revoked by the EPA or Minister,the licensee must prepare an Annual Return in respect of the period commencing onthe first day of the reporting period and ending on:a) in relation to the surrender of a licence - the date when notice in writing of approvalof the surrender is given; orb) in relation to the revocation of the licence - the date from which notice revoking thelicence operates.


R1.5 The Annual Return for the reporting period must be supplied to the EPA by registeredpost not later than 60 days after the end of each reporting period or in the case of atransferring licence not later than 60 days after the date the transfer was granted (the'due date').

Compliant The Annual Return (9.06.16 to 8.0617)was required to be submitted to the EPAbefore 08.08.17.

The auditors reviewed the EPA POEOPublic Register which identified that theannual return was submitted on the01.08.17.


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R1.6 The licensee must retain a copy of the Annual Return supplied to the EPA for a periodof at least 4 years after the Annual Return was due to be supplied to the EPA.

Compliant The site was able to provide a copy of theAnnual Return for the reporting period.

R1.7 Within the Annual Return, the Statement of Compliance must be certified and theMonitoring andComplaints Summary must be signed by:a) the licence holder; orb) by a person approved in writing by the EPA to sign on behalf of the licence holder.

Compliant The Annual Return was signed by theSUEZ Director and Company Secretary.

R1.8 A person who has been given written approval to certify a certificate of complianceunder a licence issued under the Pollution Control Act 1970 is taken to be approvedfor the purpose of this condition until the date of first review of this licence.Note: The term "reporting period" is defined in the dictionary at the end of this licence.Do not complete the Annual Return until after the end of the reporting period.Note: An application to transfer a licence must be made in the approved form for thispurpose.

Noted Noted

R2.1 Notification of environmental harmNotifications must be made by telephoning the Environment Line service on 131 555.

Not triggered No incidents relating to the PCYC Minikearea were reported to the EPA during theaudit period.

R2.2

The licensee must provide written details of the notification to the EPA within 7 days ofthe date on which the incident occurred.Note: The licensee or its employees must notify all relevant authorities of incidentscausing or threatening material harm to the environment immediately after the personbecomes aware of the incident in accordance with the requirements of Part 5.7 of theAct.

Not triggered

R3.1

Written reportWhere an authorised officer of the EPA suspects on reasonable grounds that:a) where this licence applies to premises, an event has occurred at the premises; orb) where this licence applies to vehicles or mobile plant, an event has occurred inconnection with the carrying out of the activities authorised by this licence,and the event has caused, is causing or is likely to cause material harm to theenvironment (whether the harm occurs on or off premises to which the licenceapplies), the authorised officer may request a written report of the event.


R3.2 The licensee must make all reasonable inquiries in relation to the event and supply thereport to the EPA within such time as may be specified in the request.


R3.3

The request may require a report which includes any or all of the following information:a) the cause, time and duration of the event;b) the type, volume and concentration of every pollutant discharged as a result of theevent;c) the name, address and business hours telephone number of employees or agentsof the licensee, or a specified class of them, who witnessed the event;d) the name, address and business hours telephone number of every other person (ofwhom the licensee is aware) who witnessed the event, unless the licensee has beenunable to obtain that information after making reasonable effort;e) action taken by the licensee in relation to the event, including any follow-up contactwith any complainants;f) details of any measure taken or proposed to be taken to prevent or mitigate againsta recurrence of such an event; andg) any other relevant matters.


R3.4The EPA may make a written request for further details in relation to any of the abovematters if it is not satisfied with the report provided by the licensee. The licensee mustprovide such further details to the EPA within the time specified in the request.


G1.1 Copy of licence kept at the premises or plantA copy of this licence must be kept at the premises to which the licence applies

Compliant The licence is maintained in the Site officeand electronically on the SUEZ system.

G1.2 The licence must be produced to any authorised officer of the EPA who asks to see it. Not triggered Not triggered

G1.3 The licence must be available for inspection by any employee or agent of the licenseeworking at the premises.

Compliant The licence is maintained in the Site officeand electronically on the SUEZ system.



B

Appendix B 2015 IEARecommendationsThe table below provides a summary of the recommendation and opportunities for improvementincluded in the 2015 IEA. The audit reviewed the actions taken against these recommendations duringthe audit period.

Ref Recommendation / Opportunity forImprovement Action since 2015 IEA

2015-IEA-REC01

Develop and implement an Action Plan toclose out the recommendations made in thisreport.

Closed OutThe DPE provided SUEZ withcorrespondence dated 2.12.16 seekingrepresentations with regards tooutstanding compliance items fromindependent environmental audits. SUEZresponded by letter dated 12.01.17 whichincluded an attachment with theoutstanding issues and its response.

2015-IEA-REC02

As per 2012 IEA, SUEZ should ensure that ithas an Occupation Certificate on file for theTPA.

Not assessedNot within scope of this audit.

2015-IEA-REC03

Update the LEMP to reflect current activitiesand regulatory requirements. including butnot limited to, landforms, infrastructurelayout, surface water controls, waste figures,groundwater bores, collection systems,targets and monitoring requirements andapproval of the plan obtained from the DPE.

Not applicableThe LEMP had been replaced by theOEMP during the audit period. Anassessment of the OEMP has beenundertaken in Section 7 of the Report.

2015-IEA-REC04

Provide in the LEMP a section that clearlydefines in a concise way all of themanagement actions required for theenvironmental management and monitoringof the site to assist in implementation andauditing of the LEMP. This should includedetailed and specific drawings such as forerosion and sediment controls.


2015-IEA-REC05

Update the LEMP to include the measuresproposed in the Environmental Assessmentand Submissions Report prepared by GHD tosupport MOD 8 and submit to the DPE forapproval.




B


2015-IEA-REC06

Undertake independent noise monitoring atthe nearest sensitive receivers to the PCYCminibike club area on an annual basis todemonstrate compliance with the noise levelsspecified in the EPL. Submit these resultswith the Annual Return for EPL 13114.

OutstandingSUEZ did not provide noise monitoring forthe PCYC minibike club. It was notedhowever that under the new consent SSD6835, Condition C56 annual noisemonitoring is required for LHRRP todemonstrate compliance with noise levelsprovided in Condition C54. These limitsare stricter than the levels in EPL 13114.The annual reporting undertaken againstSSD 6835 did not report any exceedanceof noise limits.2018-IEA-OFI21 – incorporate noisemonitoring requirements in EPL 13114within the annual noise monitoringcompleted under SSD 6835.

2015-IEA-REC07

Update the Air Quality Management Plan toinclude details of the monitoring methodologyand frequency for TSP monitoring and thenimplement.

Not applicableAn updated Air Quality and OdourManagement Plan (AQOMP) had beenprepared by the Site as required underSSD 6835, Condition C11. Anassessment of the AQOMP has beenundertaken in Section 7 of the Report.

2015-IEA-REC08

Ensure that an annual interpretation ofmonitoring results is conducted and includedin the annual reports provided by theindependent consultant.

Not assessedThis condition has not been carried overinto SSD 6835 therefore thisrecommendation has not been assessed.

2015-IEA-REC09

Forward water quality monitoring resultswithin one month of sampling and annualinterpretation to the NOW. Retain records ofsubmission in a designated directory.


2015-IEA-REC10

Ensure that the IEA report is provided to theEPA, NOW and CRG (in addition to the DPEand Council).

Not assessedThis requirement to submit to EPA, NOWand the CRG has not been carried overinto SSD 6835 therefore thisrecommendation has not been assessed.

2015-IEA-REC11

Continue to implement measures to ensurecompliance with the maximum quantities ofgreenwaste received specified by the EPL

Closed outAcceptance of greenwaste has beenassessed under EPL 12520.

2015-IEA-REC12

Line the runoff pit to which the oil / waterseparator discharges in the maintenanceyard as per previous IEA recommendation.

Closed outAs shown in Section 6 of this report, thisrecommendation has been completed.

2015-IEA-REC13

Relocate collection trucks used for spareparts to hardstand area to reduce the risk ofland contamination.

Closed outSite observations indicated thisrecommendation was implemented by theSite.

2015-IEA-REC14

Ensure servicing of trucks only occurs on thehard stand area which drains to the wheelwash area.

Closed outSite observations indicated thisrecommendation was implemented by theSite.



B


2015-IEA-REC15

Undertake a detailed review to determine theroot cause of the exceedances with EPLlimits. This should include a review of theoperation and design of Sediment Dam 5,review of sources of sediment e.g. un-vegetated and exposed areas of the site anda risk assessment to identify risks related towater management.

Closed outRefer to Section 5 of the main report fora review of environmental performance.

2015-IEA-REC16

Update the LEMP to accurately andcompletely reflect the monitoringrequirements of the EPL and to reflect thechanges that have occurred on site since2012. As per the previous IEA the LEMPshould include a section focussing on allmanagement and monitoring requirementswith accountabilities and responsibilitiesadequately defined. The Plan should includedetailed drawings showing the extent andlocation of controls so that it is clearly definedwhat controls exist in what locations and thiscan be audited effectively.


2015-IEA-REC17

Develop a documented procedure for theoperation of Sediment Dam 5 to endure thatthe dam is operated as per its design. Thisshould include details such as maintenanceof freeboard, pumping and dischargerequirements, what to do before and during arainfall event and de-silting regimes.

OutstandingSection 8.2 of the OEMP contains somedetails regarding the operation ofSediment Dam 5 however it is not veryuser friendly and refers to the EIS for re-silting requirements.Refer to Section 7.1 for discussion of theadequacy of the OEMP.

2015-IEA-REC18

Revise EPL to include all groundwatermonitoring bores (MB023, MB044, MB045,MB046 and MB047)

Closed outEPL 5065 was varied to include thefollowing monitoring points:

· Point 44 (MB023)· Point 45 (MB044)· Point 46 (MB045)· Point 47 (MB046)· Point 48 (MB047)· Point 49 (MB048)· Point 50 (MB049)

2015-IEA-REC19

Undertake a gap analysis to check that all therequired approvals for the emergencyleachate dam have been obtained anddocument findings as evidence of review. Inparticular confirm approvals were notrequired under the EP&A Act and the WaterManagement Act.

Closed outAn investigation into the requirement toseek approval under the EP&A Act andthe Water Management Act was notundertaken by SUEZ. However, theemergency leachate dam was included inthe description of existing operations inthe EIS (GHD, October 2015) for theexpansion of the landfill, therefore it isconsidered that the ongoing use of theemergency leachate dam has beenapproved under SSD 6835.



B


2015-IEA-REC20

Review compliance with the Mill CreekStream Works and Rehabilitation Plan (GHD2006) in particular for the works implementedat the northern end of the LHRRP. Shouldthe expansion not proceed ensure the worksin the southern end have also beenimplemented as per the approved Plans.

Not assessedSSD 6835 includes a number of newconditions which relate to themanagement of Mill Creek, including C32,C33, C34 and C44. These conditionshave not been triggered during the auditperiod therefore have not been assessed.

2015-IEA-REC21

As recommended in the previous IEA, reviewrehabilitation strategy of the Mill Creek Cleanwater diversion drain and incorporate areasfor potential rehabilitation on the westernclean water drain banks to create a naturalriparian zone.


2015-IEA-REC22

As recommended in the previous IEA, reviewthe Rehabilitation of Mill Creek – StreamWorks and Vegetation Management Plans(GHD September 2006) and obtainindependent verification of compliance withthe Plan. Experts in creek stabilisationshould be part of this review and suggestadditional recommendations for furtherstabilisation works in Mill Creek.


2015-IEA-REC23

As recommended in the previous IEA, obtainindependent verification that the surfacedrainage outlets to Mill Creek wereconstructed in accordance with therequirements of the NOW endorsed plans.


2015-IEA-REC24

Submit quarterly surface and gasaccumulation monitoring reports as anattachment to each Annual Return.

OutstandingThe auditors reviewed the Annual Return(21 August 2016 to 20 August 2017). Thequarterly surface and gas accumulationmonitoring reports were not attached.Refer to Condition M8.1 of EPL 5065 andassociated recommendation.

2015-IEA-REC25

Update the Landfill Surface Gas MonitoringProgramme and the Proposed LandfillSubsurface Gas and AccumulationMonitoring Program which form Appendicesto the LEMP reflect changes that haveoccurred on site since 2006 (e.g. installationof new wells, variations to EPL and changesin gas monitoring methodology)

Closed OutEPL 5065, varied on 7.012.17, includes arequirement under condition M8.4, toprepare and submit a draft Landfill Sub-Surface Gas Monitoring Programme by31 March 2018. This plan will meet therecommendations of this condition.

2015-IEA-REC26

Undertake independent noise monitoring atthe nearest sensitive receivers to the landfillon an annual basis to demonstratecompliance with the noise levels specified inthis Consent.

Closed outCondition C56 of SSD 6835 requiresannual noise monitoring to demonstratecompliance with noise levels provided inCondition C54.



B


2015-IEA-REC27

Once an approved landscape plan isadopted, ensure independent monitoring /assessment of the progress of rehabilitationagainst rehabilitation objectives is completedon a quarterly basis.

Not assessedThis requirement has been capturedunder SSD 6835, Condition C40. Thiscondition has not been assessed as it isoutside of the audit period.

2015-IEA-REC28

Ensure TPA has been constructed as per theapproved Landscape Plan and Appendix 2 ofthe Development Consent. This may requireextending the concrete within the TPA orseeking a Modification to the DevelopmentConsent to allow for portions of the TPA tonot be concreted.

Closed outDuring the site inspection it was observedthat these works had not been completed.SUEZ reported that the works would beundertaken in the next month andphotographs were provided in April 2018indicating that concreting works werealmost complete.

2015-IEA-REC29

Include the TPA Landscape Plan within theLEMP as the TPA CEMP is now largelyobsolete.

OutstandingThe LEMP has been replaced with theOEMP. A review of the OEMP indicatedthat ongoing maintenance and operationof the truck parking area is not included.Refer to Section 7.1 forrecommendations relating to theadequacy of OEMP.

2015-IEA-REC30

Undertake a detailed Dangerous Goods auditto assess compliance with AS 1940 2004 inparticular of the earthen bund housing dieseltank in maintenance yard.

Closed outDuring the site inspection the auditsobserved that the earthen bund anddiesel tank had been decommissioned.Diesel was stored in an above grounddouble-skinned self bunded 60,000 Ldiesel tank.

2015-IEA-REC31

Repair damaged concrete in maintenanceworkshopRefer also to recommendation under CoC 48

Closed outThe auditors sighted two slabs of newconcrete in the workshop area. Refer tosite observations recorded in Section 6.1.

2015-IEA-REC32

Update the Environmental ComplaintsManagement SOP066 to reflect therequirement to respond to complainantswithin 24 hours rather than 48 hours.


2015-IEA-REC33

Include further details within the CAR of thefollow up action taken to close out thecomplaint with the complainant. If thecomplainant does not request a response thisshould be noted within the CAR.

Closed outThe auditors noted in the two complaintrecords reviewed that one complainantrequested a call back. The CAR includedan action which stated the complainantwas called back 6 days following thecomplaint.Refer to SSD 835, Condition M4.1 for anassessment of SUEZ complaintsprocedure.

2015-IEA-REC34

Repair the liner which had lifted in the mainleachate dam.

OutstandingAt the time of the time of the siteinspection the liner was still raised. Referto site observations recorded in Section6.1 and recommendations made underCondition B11 of SSD 6835.



B


2015-IEA-OFI01

Clarify with the EPA whether quarterlyreporting to the EPA of the volume ofleachate discharged EPL Points 41, 42 and43 to the EPA is required or whether currentreporting as part of Annual Return issufficient.

Closed outThe auditors consider that therequirement to report ‘quarterly totalvolumes (kilolitres)’ with the AnnualReport addresses the requirement of theEPL. The Site can contact the EPA torequest formal confirmation of thisinterpretation. No issue to date has beenraised by the EPA in regards to theAnnual Return.

2015-IEA-OFI02

Ensure that the time at which a sample iscollected is also recorded on monitoringrecords.

OutstandingRefer to discussion of compliance withCondition M1.3 of EPL 5065 andassociated recommendation.

2015-IEA-OFI03

Investigate practical options for reducing therisk of erosion from exposed sections of thestockpile

Closed outSUEZ has committed to implementingadditional erosion and sediment controlsas part of the expansion.

2015-IEA-OFI04

Review the Groundwater Remediation ActionPlan to ensure it reflects the most recentlegislation, guidelines and any requirementsof the EPL.

Closed outThe Groundwater Remediation ActionPlan is no longer required under SSD6835. An updated GroundwaterManagement Plan was prepared duringthe audit period. This plan is discussed inSection 7 of the main report.

2015-IEA-OFI05

Install level markers in Sediment Dam 5 atthe 10 ML mark (the level which the settlingzone needs to be maintained below) toensure adequate freeboard is available forrainfall events and to indicate at the 80% siltlevel.

Closed outThe auditors sighted a letter to the EPA,dated 27 July 2017, which identified that afreeboard marker was installed in thesediment dam. Photos of the freeboardwere attached to the letter.

2015-IEA-OFI06

Investigate adding stormwater managementsystem onto SCADA so that sediment damlevels, pumps and the stormwater treatmentplant can be monitored remotely.

Closed outThe auditors sighted a letter to the EPA,dated 27 July 2017, which identified thatthe stormwater treatment plant (STP)would be upgraded to a SCADA systemin August 2017. Monitors installed includean ultrasonic level detector.

2015-IEA-OFI07

Ensure operational noise measures for theTPA are included within the LEMP (or revisedOEMP).


2015-IEA-OFI08

Undertake independent noise monitoring atthe nearest sensitive receivers to the PCYCminibike club area on an annual basis todemonstrate compliance with the noise levelsspecified in the EPL. Submit these resultswith the Annual Return for EPL 13114.

Closed outCondition L3.1 of EPL 13114 discussesnoise monitoring at the PCYC minibikeclub.



B


2015-IEA-OFI09

Consolidate any requirements within the TPACEMP that are applicable for the ongoingmaintenance and operation of the TPA intothe LEMP.




C

Appendix C DPE Audit Team Approval