Works Approval Application Report - Melbourne Regional Landfill Biogas Facility, 714 Christies Road, Ravenhall VIC Prepared for: Landfill ...
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Works Approval Application Report Melbourne Regional Landfill Biogas Facility, 714 Christies Road, Ravenhall VIC Prepared for: Landfill Operations Pty Ltd Level 4, 441 St Kilda Road Melbourne VIC 3004 6 April 2020
Distribution
Distribution
Works Approval Application Report,
Melbourne Regional Landfill Biogas Facility, 714 Christies Road, Ravenhall VIC
6 April 2020
Copies Recipient Copies Recipient
1 PDF Mr James Moverley 1 PDF EPA Victoria
Project Manager - Infrastructure Development Assessment Unit
Landfill Operations Pty Ltd
Level 4, 441 St Kilda Road
Melbourne VIC 3004
1 PDF Senversa Project File M17755
Disclaimer and Limitations
1 This document is confidential and has been prepared by Senversa for use only by its client and for the specific purpose
described in our proposal which is subject to limitations. No party other than Senversa’s client may rely on this
document without the prior written consent of Senversa, and no responsibility is accepted for any damages suffered by
any third party arising from decisions or actions based on this document. Matters of possible interest to third parties may
not have been specifically addressed for the purposes of preparing this document and the use of professional
judgement for the purposes of Senversa’s work means that matters may have existed that would have been assessed
differently on behalf of third parties.
2 Senversa prepared this document in a manner consistent with the level of care and skill ordinarily exercised by
members of Senversa’s profession practicing in the same locality under similar circumstances at the time the services
were performed.
3 Senversa requires that this document be considered only in its entirety, and reserves the right to amend this report if
further information becomes available.
4 This document is issued subject to the technical principles, limitations and assumptions provided in Section 5.0.
Senversa Pty Ltd
ABN: 89 132 231 380
Level 6, 15 William Street, Melbourne, VIC 3000
tel: + 61 3 9606 0070; fax: + 61 3 9606 0074
www.senversa.com.au
Primary
Author / Technical
Project Peer
Manager Review
Colin Stapleton Suanna Harvey
Senior Associate Principal
M17755_002_RPT_Rev2
ii
Contents
Contents
List of Acronyms ...................................................................................................................................................................... vi
1.0 General Information ...................................................................................................................................................... 1
1.1 Primary Information...................................................................................................................................................... 1
1.1.1 Company Legal Entity ........................................................................................................................................ 1
1.1.2 Project Cost and Works Approval Application Fee .............................................................................................. 1
1.2 Purpose and Objectives ............................................................................................................................................... 1
1.3 Scheduled Activity........................................................................................................................................................ 1
1.4 Relevant EPA Legislation, Policy and Guidelines ...................................................................................................... 2
1.5 Supporting Information ................................................................................................................................................ 2
1.6 Land Use ....................................................................................................................................................................... 4
1.6.1 Planning and Other Approvals ............................................................................................................................ 4
1.6.2 Site Definition ..................................................................................................................................................... 4
1.6.3 Choice of Location for New Premises ................................................................................................................. 5
1.7 Track Record................................................................................................................................................................. 5
1.7.1 The Applicant ..................................................................................................................................................... 5
1.7.2 Community Concerns and Public Feedback ....................................................................................................... 5
1.7.3 Enforcement Actions Received from EPA........................................................................................................... 5
1.7.4 The Steps Taken to Deal with Any Environmental Issues ................................................................................... 5
1.7.5 How the Proposal will Affect Any Existing Issues ................................................................................................ 6
1.7.6 Summary of Relevant Offences under Section 20C of the Environment Protection Act....................................... 6
1.7.7 Has the applicant been found guilty of any relevant offences in the past 10 years .............................................. 6
1.7.8 Indicate the recent track record of any other operations in Victoria or interstate ................................................. 6
1.7.9 Biogas Operations Contractor ............................................................................................................................ 7
1.8 Community Engagement.............................................................................................................................................. 7
1.8.1 Engagement Activities Completed ...................................................................................................................... 7
1.8.2 Continuing Community Engagement .................................................................................................................. 8
1.9 Process and Integrated Environmental Assessment ................................................................................................. 8
1.9.1 Existing Operation .............................................................................................................................................. 8
1.9.2 Description of the Proposal ................................................................................................................................ 9
1.9.3 Process and Technology .................................................................................................................................. 10
1.9.4 Consistency with EPA Victoria Landfill Gas Management Hierarchy................................................................. 10
1.9.5 Consideration of Climate Change ..................................................................................................................... 11
1.9.6 Environmental Compliance Assessment (Current Operation) ........................................................................... 13
2.0 Environmental Information ........................................................................................................................................ 16
2.1 Energy Use and Greenhouse Gas Emissions ........................................................................................................... 16
2.2 Water Use .................................................................................................................................................................... 16
2.3 Air Emissions.............................................................................................................................................................. 16
2.4 Noise Emissions ......................................................................................................................................................... 18
2.5 Waste ........................................................................................................................................................................... 21
2.6 Surface Water Management ....................................................................................................................................... 22
M17755_002_RPT_Rev2
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Contents
2.7 Land and Groundwater............................................................................................................................................... 23
2.8 Environmental Management ...................................................................................................................................... 23
2.8.1 Risk Assessment of Non-Routine Operations ................................................................................................... 23
2.8.2 Health, Safety and Environmental Management ............................................................................................... 27
2.8.3 Emissions Control ............................................................................................................................................ 27
2.8.4 Fire Management, Safety and Incident Response ............................................................................................ 28
2.8.5 Complaints Management and Incident Response ............................................................................................. 29
2.8.6 Construction Environmental Management ........................................................................................................ 29
2.9 Summary of Best Practice.......................................................................................................................................... 30
3.0 Other EPA Approvals ................................................................................................................................................. 32
3.1 Licence Amendment Application............................................................................................................................... 32
4.0 Post Decision Operational Requirements ................................................................................................................. 33
4.1 Financial Assurance ................................................................................................................................................... 33
4.2 Polychlorinated Biphenyls Management................................................................................................................... 33
4.3 Monitoring ................................................................................................................................................................... 33
4.4 Reporting Annual Performance ................................................................................................................................. 33
5.0 Principles and Limitations ......................................................................................................................................... 34
6.0 References .................................................................................................................................................................. 35
Tables
Table 1.1: Supporting Information ........................................................................................................................................... 3
Table 1.2: Land Use .................................................................................................................................................................. 4
Table 1.3: Community Engagement Activities ........................................................................................................................ 7
Table 1.4: GoV Climate-Ready Actions .................................................................................................................................. 13
Table 1.5: APS Licence Compliance Reporting (FY15 to FY19) ........................................................................................... 14
Table 1.6: Air Quality Discharge Reporting (APS Submissions FY15 to FY19)................................................................... 14
Table 1.7: Methane Destruction Efficiency ............................................................................................................................ 15
Table 2.1: Design Level Ground Concentration Criteria (Ektimo, 2020) .............................................................................. 17
Table 2.2: Air Quality Modelling Results (after Ektimo, 2020) .............................................................................................. 18
Table 2.3: Predicted Noise Levels (MDA, 2020) ..................................................................................................................... 21
Table 2.4: Waste Management................................................................................................................................................ 21
Table 2.5: Descriptions of Qualitative Measures of Likelihood and Consequence............................................................. 24
Table 2.6: Risk Ratings ........................................................................................................................................................... 24
Table 2.7: Summary of Medium Initial Risk Scenarios and Current Controls ..................................................................... 26
Table 2.8: Summary of Best Practice ..................................................................................................................................... 30
M17755_002_RPT_Rev2
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Contents
Figures
Figure 1: Site Setting (Senversa)
Figure 2: Power Station 2 Location (Senversa)
Figure 3: Sheet 1 of 6: Power Station 2 Planning Permit Amendment Aerial Showing Power Stations 1 & 2. Date 19 September
2019 (Charter Keck Cramer)
Figure 4: Sheet 2 of 6: Power Station 2 Planning Permit Amendment Aerial Showing Power Stations 1 & 2. Date 19 September
2019 (landfill Cell Layout) (Charter Keck Cramer)
Figure 5: Sheet 3 of 6: Power Station 2 Planning Permit Amendment – Existing Conditions Plan Power Station 1 (Charter Keck
Cramer)
Figure 6: Sheet 4 of 6: Power Station 2 Planning Permit Amendment – Proposed Layout (Charter Keck Cramer)
Figure 7: Sheet 6 of 6: Power Station 2 Planning Permit Amendment – Conceptual Site Elevations (Charter Keck Cramer)
Figure 8: Drawing Number E1437-01-009 Conceptual Site Elevation 4 x CAT3516LE In Acoustic Encloses. Date 31 October
2019 (SDA Engineering)
Figure 9: SDA Engineering Drawing Number E1437-01-003 Site Layout – Option 2 (Enclosures) 4 x 2MW Caterpillar
Generators (discharge points). Date 07 December 2018 (SDA Engineering)
Appendix A: EPA Returnable Information
Company Entity Information
ASIC Company summary (February 2020)
Completed Relevant Offence Declaration Form
Supporting information table (EPA format)
LOPL list of Pollution Abatement Notices and Penalty Infringement Notices
Cleanaway Victoria PAN track record
Copy of Cleanaway national enforcement tool register
Cleanaway enforcement track record
Table of contents (EPA format)
Appendix B: Planning Permit Amendment
Planning Permit PA2016/5386/02 (City of Melton)
Appendix C: Technical Data Sheet
Caterpillar G3516 LE Gas Engine Technical Data Sheet
Appendix D: Community Engagement
Melbourne Regional Landfill Community Reference Group Meeting Minutes 27 November 2019
Melbourne Regional Landfill Community Reference Group Meeting Minutes 27 February 2020
Appendix E: Health Safety and Environment
Risk Assessment Matrix
Run Energy Health, Safety and Environment Manual (April 2019)
Run Energy Health, Safety and Environment Plan (version dated 13 January 2020)
Appendix F: Air Quality Assessment
Air Quality Assessment for Proposed Biogas Expansion Project (Ektimo, February 2020)
Appendix G: Greenhouse Gas Assessment
Cleanaway Melbourne Regional Landfill Greenhouse Gas Assessment (ERM Power, February 2020)
Appendix H: Noise Assessment
Melbourne Regional Landfill – Additional Gas Generator Modules (Marshall Day Acoustics, February 2020)
Appendix I: Surface Water Management
Surface Water Management Plan (Golder, 2019)
M17755_002_RPT_Rev2
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List of Acronyms
List of Acronyms
Acronym Definition
APS Annual Performance Statement
AS Australian Standard
BOM Bureau of Meteorology
BPEM Best Practice Environmental Management Siting, Design, Operation and Rehabilitation of Landfills
CCTV Closed Circuit Television
CEMP Construction Environmental Management Plan
CO Carbon Monoxide
CO2-e Carbon dioxide equivalent
dB Decibel
DELWP Victorian Department of Environment, Land, Water and Planning
EMS Environmental Management System
EPA Environment Protection Authority Victoria
FY Financial Year
GHG Greenhouse Gas
g/min Grams per minute
GWP Global warming potential
HAZOP Hazard and operability
HSE Health, Safety and Environment
JSA Job Safety Analysis
Km Kilometre
kV Kilovolt
kWh Kilo-watt Hours
Leff Effective noise level
LEMP Landfill Environmental Monitoring Plan
LOPL Landfill Operations Pty Ltd
LORA Landfill Operations Risk Assessment
m Metres
m3/hr Metres cubed per hour
MRL Melbourne Regional Landfill
M17755_002_RPT_Rev2
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List of Acronyms
Acronym Definition
MRLCRG Melbourne Regional Landfill Community Reference Group
MSDS Material Safety Data Sheet
MW Mega Watt
MWRRG Metropolitan Waste and Resource Recovery Group
NO2 Nitrogen Dioxide
NPI National Pollutant Inventory
PCB Polychlorinated Biphenyls
PPE Personal Protective Equipment
QMS Quality Management System
SEPP State Environment Protection Policy
SMS Short message service (text message)
SO2 Sulfur Dioxide
SUZ-1 Special Use Zone – Schedule 1
SWMP Surface Water Management Plan
SWMS Safe Work Method Statement
SWRRIP Statewide Waste and Resource Recovery Infrastructure Plan
WA Works Approval
V Volt
µg/m3 Micro-gram per metre cubed
M17755_002_RPT_Rev2
vii
General Information
1.0 General Information
1.1 Primary Information
Senversa Pty Ltd (Senversa) has been engaged by Landfill Operations Pty Ltd (LOPL) to prepare a
Works Approval application to EPA Victoria to increase the capacity of the existing landfill biogas
facility at Melbourne Regional Landfill (MRL) located at 714 Christies Road, Ravenhall VIC 3023 to
enable management of projected landfill gas generation from current and future landfill cells.
A works approval (reference WA 61767) was first issued for the biogas facility in August 2007 enabling
the progressive installation of engines 2 to 8 and the generation of electricity. LOPL currently holds a
licence from EPA (reference 112063 first issued in March 2015) to generate electrical energy from
waste landfill gas at a rated capacity of 8.8 megawatts.
1.1.1 Company Legal Entity
The Works Approval applicant is Landfill Operations Pty Ltd (LOPL) a wholly owned subsidiary of
Cleanaway Waste Management Limited (Cleanaway). The completed Company Legal Entity Form is
provided as Appendix A.
1.1.2 Project Cost and Works Approval Application Fee
The capital cost of the project is expected to be $12 million. The Works Approval fee is $66,645 (4,500
fee units).
1.2 Purpose and Objectives
The purpose of this report is to document the Works Approval application in accordance with EPA
Victoria Works Approval application requirements.
There are two main objectives of this report:
1. Provide a summary of the scheduled activity and technical reports and information prepared to
inform the Works Approval application; and
2. Demonstrate that the proposed activity would meet or exceed EPA Victoria’s requirements for the
scheduled activities to occur at the site.
1.3 Scheduled Activity
LOPL are seeking to increase the capacity of the existing landfill biogas facility by developing a
second power station compound at the landfill premises and are seeking a Works Approval under
Section 19B of the Environment Protection Act 1970 (“the Act”) the enable the works to commence.
The activities proposed at the facility are scheduled activities under Environment Protection
(Scheduled Premises) Regulations 2017 (“the Regulations”). The scheduled activities proposed are
Waste to Energy and Power Stations and are described in the Regulations as:
Waste to Energy (A08) – premises which recover energy from waste at a rated capacity of at least 3
megawatts of thermal capacity or at least 1 megawatt of electrical power; and
Power Stations (K01) – premises which generate electrical power from the consumption of a fuel at a
rated capacity of at least 5 megawatts of electrical power.
Following issue of a Works Approval, both activities require a licence from EPA to operate but a
financial assurance is not required.
M17755_002_RPT_Rev2
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General Information
1.4 Relevant EPA Legislation, Policy and Guidelines
In preparing this Works Approval application, reference is made to the following Victorian legislation,
policy and guidelines:
• Environment Protection Act 1970.
• Planning and Environment Act 1987.
• Climate Change Act 2017.
• Environment Protection (Scheduled Premises) Regulations 2017.
• Sustainability Victoria (2018) Statewide Waste and Resource Recovery Implementation Plan
(SWRRIP).
• Victorian State Environment Protection Policy (Control of Noise from Commerce, Industry and
Trade) No. N-1. 15 June 1989.
• Victorian State Environment Protection Policy (Air Quality Management), December 2001.
• EPA Publication 1659 (2017) Selected Scheduled Premises Prompt Sheets.
• EPA Publication 1658 (2017) Works Approval Application.
• EPA Publication 1517.1 (2017) Demonstrating Best Practice.
• EPA Publication 559 (2017) Energy from Waste Guideline.
• EPA Publication 788.3 (2015) Best Practice Environmental Management Siting, Design, Operation
and Rehabilitation of Landfills.
• EPA Publication 480 (1996) Environmental Guidelines for Major Construction Sites.
• Government of Victoria (2015) Climate Ready Victoria: Greater Melbourne Factsheet.
1.5 Supporting Information
The Works Approval application is this report and the technical studies and information appended to
this report. This application report draws together a summary of the key information about the
application and the environmental impact assessments prepared, however the appended reports and
information should be read in conjunction with the relevant section of this report.
Table 1.1 describes information provided in support of the works approval application.
M17755_002_RPT_Rev2
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General Information
Table 1.1: Supporting Information
Appendix Information type Relevant Section
of this Report
Figures • Figure 1: Senversa Figure 1: Site Setting All sections
• Figure 2: Senversa Figure 2: Power Station 2 Location
• Figure 3: Charter Keck Cramer Sheet 1 of 6: Power Station 2 Planning Permit
Amendment Aerial Showing Power Stations 1 & 2. Date 19 September 2019
• Figure 4: Charter Keck Cramer Sheet 2 of 6: Power Station 2 Planning Permit
Amendment Aerial Showing Power Stations 1 & 2. Date 19 September 2019
(landfill Cell Layout)
• Figure 5: Charter Keck Cramer Sheet 3 of 6: Power Station 2 Planning Permit
Amendment – Existing Conditions Plan Power Station 1
• Figure 6: Charter Keck Cramer Sheet 4 of 6: Power Station 2 Planning Permit
Amendment – Proposed Layout
• Figure 7: Charter Keck Cramer Sheet 6 of 6: Power Station 2 Planning Permit
Amendment – Conceptual Site Elevations
• Figure 8: SDA Engineering Drawing Number E1437-01-009 Conceptual Site
Elevation 4 x CAT3516LE In Acoustic Encloses. Date 31 October 2019.
• Figure 9: SDA Engineering Drawing Number E1437-01-003 Site Layout –
Option 2 (Enclosures) 4 x 2MW Caterpillar Generators (discharge points). Date
07 December 2018.
Appendix A • Company Entity Information Section 1.1
• ASIC Company summary (February 2020) Section 1.6
• Completed Relevant Offence Declaration Form Section 1.7
• Supporting information table (EPA format)
• LOPL list of Pollution Abatement Notices and Penalty Infringement Notices
• PAN track record
• Copy of Cleanaway national enforcement register
• Enforcement track record
• Table of contents (EPA format)
Appendix B • City of Melton Planning Permit PA2016/5385/02 Section 1.5.1
Appendix C • Caterpillar G3516 LE Gas Engine Technical Data Sheet Section 1.8.3
Appendix D • Community Engagement Information – Melbourne Regional Landfill Section 1.7
Community Reference Group Meeting Minutes 27 November 2019
• Community Engagement Information – Melbourne Regional Landfill
Community Reference Group Meeting Minutes 27 February 2020
Appendix E • Risk Assessment Matrix Section 2.9
• Run Energy Health, Safety and Environment Manual (April 2019)
• Run Energy Health, Safety and Environment Plan (version dated 13 January
2020)
Appendix F • Air Quality Assessment (Ektimo, 2020) Section 2.3
Appendix G • Greenhouse Gas Assessment (ERM Power, 2020) Section 2.1
Appendix H • Noise Assessment (MDA, 2020) Section 2.4
Appendix I • Stormwater Management Plan (Golder, 2019) Section 2.6
M17755_002_RPT_Rev2
3General Information
1.6 Land Use
The land where the activity is proposed to occur is in the landfill premises currently used for
maintenance and storage activities associated with the landfill operation. The land is zoned under the
City of Melton planning scheme as Special Use Zone – Schedule 1 (SUZ1) to enable the use of the
premises as a landfill. The existing biogas facility and landfill are located in a larger industrial precinct
that comprises an operating basalt quarry, asphalt plant and pre-cast concrete manufacturing plant.
The site location is shown in Figure 1. The location of the proposed facility is shown in Figure 2 and
the major components of the landfill operation and their proximity to the proposed biogas facility is
shown in Figure 3.
The Land uses surrounding the proposed site location are described in Table 1.2.
Table 1.2: Land Use
Direction Land use
North • Concrete liner manufacturing plant, crushing plant, concrete batching plant and asphalt manufacturing
plant.
• The Ravenhall precinct boundary (Melbourne to Ballarat rail line) is approximately 2.2 km from the Power
Station 2 boundary.
• The nearest sensitive receptor is over 3 km from the proposed biogas facility (house)
South • Landfill leachate ponds followed by the Stage 2 landfill cells.
• The Ravenhall precinct boundary (Middle Road) is proximately 900 m from the Power Station 2
boundary.
• The nearest sensitive receptor is over 2.5 km from the proposed biogas facility (house)
East • Cleanaway operations and maintenance areas including offices and weighbridge.
• The Ravenhall precinct boundary (Christies Road) is approximately 560 m the Power Station 2 boundary.
• The nearest sensitive receptor is approximately 1 km from the biogas facility (Dame Phyllis Frost Centre)
although given potential for future receptors to be established to the east of the landfill, the Noise
Assessment has included the potential for a receptor adjacent to the MRL site boundary.
West • Power Station 1 is 25 m to the west followed by the Stage 3 and Stage 4 landfill cells
• The operating Boral basalt quarry commences approximately 1 km from the Power Station 2 boundary.
• The Ravenhall precinct boundary (Hopkins Road) is approximately 2.5 km from the Power Station 2
boundary.
• The nearest sensitive receptor is approximately 2 km from the proposed biogas facility (house)
1.6.1 Planning and Other Approvals
LOPL holds a planning permit to operate the biogas facility (permit number PA2016/5386) from City of
Melton (Council) under Section 72 of the Planning and Environment Act 1987.
On 6 February 2020 Council granted an amended planning permit (PA2016/5386/2) and endorsed the
plans to include the additional 8 biogas engines.
The amended planning permit and endorsed plans are provided as Appendix B.
1.6.2 Site Definition
The current and proposed landfill biogas facility is located within the premises of the Melbourne
Regional Landfill (MRL). The existing operation, termed “Power Station 1” operates from a landfill
biogas compound comprising 8 biogas engines and 3 landfill gas flares.
This Works Approval application is to develop a second compound for the landfill biogas facility to
operate a further 8 biogas engines. The second compound would be located approximately 25 m to
the east of Power Station 1 and be termed “Power Station 2”. It is intended that one EPA licence
would cover both Power Station compounds.
The location of the proposed Power Station 2 along with the existing Power Station 1 location is
shown on Figure 2.
M17755_002_RPT_Rev2
4General Information
1.6.3 Choice of Location for New Premises
Power Station 2 is designed to utilise the grid connectivity infrastructure from Power Station 1 and so
has been sited 25 m to the east of Power Station 1 to enable the efficient connection of both
compounds to the existing infrastructure.
Power Station 2 is proposed to be sited near the landfill cells and the maintenance and administrative
areas to both limit the distance LOPL need to transfer landfill gas and to facilitate access using the
existing road network. The facility is located on stable ground. It is not located on the landfill cells to
avoid potential settlement of the ground surface.
1.7 Track Record
1.7.1 The Applicant
The applicant is Landfill Operations Pty Ltd (LOPL) a wholly owned subsidiary of Cleanaway Waste
Management Limited (Cleanaway). LOPL is the current licensee for the current Biogas facility and also
MRL, the largest landfill in Victoria. LOPL has operated the MRL Power Station since March 2015.
Since taking over the Power Station LOPL has undertaken operational improvements to ensure
environmental performance in accordance with the regulatory framework and requirements. The most
significant being the installation and commissioning of four new engines in late 2017. This resulted in
doubling power generation capacity from approximately 32,000 MWh per year to 64,000 MWh per
year. It also doubled the conversion of LFG from flaring to power generation from 2,500 m3 per hour
to 5,000 m3 per hour. As a result, in financial year 2018-19 more than 200,000 tonnes per year of
greenhouse gas (GHG) emissions (as CO2 equivalent) avoided entering the atmosphere.
To ensure this track record is continued, if this application is approved and all 16 biogas engines are
operating, more than 400,000 tonnes per year (CO2 equivalent) of GHG emissions will be avoided and
power generation will be doubled. Based on the electricity generated in 2018/19 power generation will
increase from 64,000 MWh per year to 128,000 MWh per year, powering the equivalent of 30,000
homes. The proposed Power Station expansion will ensure MRL electricity generation capacity will
keep up with the forecast increase in available landfill gas.
In respect to EPA licence 112063 operations LOPL has not had any licence non-conformances, fines
or EPA Notices since taking over in March 2015.
1.7.2 Community Concerns and Public Feedback
Since 2015 LOPL has had quarterly meetings with the community. In addition, LOPL has a 24 hr
seven day a week community hot-line, which residents can contact if they have complaints or wish to
raise any concerns or issues. Since 2015 there have been no complaints or issues raised in respect to
the Power Station. At the most recent community meeting the proposal to expand the Power Station
was presented. Refer to Section 1.8 for further details. LOPL did not receive any comments or
concerns about the proposal during or after the meeting.
1.7.3 Enforcement Actions Received from EPA
The question here specifically relates to ‘existing operations at the premises’ over the last 3 years,
however LOPL has responded to it in relation to the licensed premises and the broader site of the
landfill. A list of EPA Notices served on LOPL (last 3 years) is presented in Appendix A. The table
includes the outcomes of each Notice. In all cases the Notices relate to the landfill (licence 12160) and
LOPL has completed the requirements of the Notice to the satisfaction of the EPA or, where work is in
progress, are progressing to the satisfaction of the EPA.
None of the Notices relate to the Power Station operation, which is regulated under a separate EPA
licence 112063 and so technically there have been no enforcement actions regarding existing
operations at the premises as per the specifically requested information.
1.7.4 The Steps Taken to Deal with Any Environmental Issues
Environmental risks have been assessed as part of the Works Application. All environmental risks
identified during this process have been mitigated in the design. In addition, regular monitoring of the
emissions stacks at the Power Station will continue to be undertaken.
M17755_002_RPT_Rev2
5General Information
1.7.5 How the Proposal will Affect Any Existing Issues
The purpose of the Power Station is to intercept GHG and convert this into electricity rather than have
LFG flare or discharge to the environment. Increasing the power capacity of the plant greatly assists
with delivering this key environmental benefit. The proposed Power Station expansion will ensure MRL
electricity generation capacity will keep up with the forecast increase in available landfill gas.
1.7.6 Summary of Relevant Offences under Section 20C of the Environment Protection Act
The works approval application requires the applicant to declare any offences as determined under
Section 20C of the Environment Protection Act. The applicant, LOPL, has not been the subject of any
summary or indictable offences. The completed and signed Relevant offence declaration form for
LOPL is provided in Appendix A.
The directors and persons involved in the management of LOPL of the subsidiaries of Cleanaway
Waste Management Limited have not been found guilty of any relevant offences in the last 10 years.
Cleanaway’s credentials as a fit and proper person are further evidenced by the on-going grants of
new works approvals and licences, and licence renewals for its operations across Australia – including
for example the EPA’s decision to grant Cleanaway a works approval for the extension of its
operations at the Melbourne Regional Landfill.
1.7.7 Has the applicant been found guilty of any relevant offences in the past 10 years
LOPL’s ultimate parent entity Cleanaway Waste Management has many subsidiaries that conduct
waste operations across all Australian jurisdictions in both solid and liquid waste sectors. None of
those entities have, in the last 10 years, had any convictions recorded in relation to offences as
determined under s20 of the Environment Protection Act. In 2018 Cleanaway acquired the Toxfree
group of companies expanding aspects of its operations across Australia, since acquisition by
Cleanaway there have been no convictions recorded against any of the former Toxfree companies.
As required by the request for further information from the EPA, the following is noted regarding
offences in Queensland:
• In 2019 Nationwide Oil Pty Ltd, a related entity of LOPL’s, pleaded guilty to charges regarding
breaches of approval conditions regarding sulphur content in fuel, related emissions and related
late notification of breaches at its plant at Narangba, Queensland. This was a complex matter
where Cleanaway worked openly with the Department to find the root of the emissions issues. No
conviction was recorded and the prosecutor conceded that there was no harm to the environment
nor any potential for harm. A number of charges were dropped and a global penalty of $55,000
was imposed. Magistrate Saggers acknowledged that Nationwide Oil had worked hard to comply
with its environmental obligations, was a good corporate citizen and had excellent antecedents.
Magistrate Saggers also acknowledged the significant expense incurred by Nationwide Oil in
implementing the scrubber solution.
• In 2015 Nationwide Oil Pty Ltd and another related entity Transpacific Industries Pty Ltd (TPI)
pleaded guilty to charges regarding the failure to track waste. The Magistrate accepted the
evidence of Nationwide Oil and TPI that they did not intend to transport trackable waste and that
the defendants did not consider the vessels to be trackable waste. Nationwide Oil was fined
$2,000 and ordered to pay $750 legal costs, and TPI was fined $3,000 and ordered to pay $1,250
legal costs and $4,598 investigation costs. No convictions were recorded against either defendant.
The low level of the fines, the fact that no convictions were recorded, and no environmental harm
found indicate the low level of culpability.
1.7.8 Indicate the recent track record of any other operations in Victoria or interstate
Cleanaway has over 120 operating sites that are licensed by the relevant environmental regulators
across Australia. It has an extremely broad range of operations and overall has a solid track record of
environmental compliance and where non-compliance occurs making sure that solutions are put in
place to avoid any on-going issues.
Set out below is an indication of the recent track record, over the past three years. Note that where
existing operations have been acquired (e.g. via the ToxFree takeover) only matters since under
Cleanaway ownership are considered.
M17755_002_RPT_Rev2
6General Information
Cleanaway considers its track record across the diverse operations in Australia demonstrates that it is
a suitably fit and proper person to obtain the works approval being applied for.
1.7.8.1 Victorian operations
The Applicant’s related entities that conduct a broad range of EPA licensed waste operations across
Victoria have received various notices over the last 3 years.
Attached as part of Appendix A is a list of Victorian notices regarding environmental compliance. It
includes PANs for completeness.
The most recent Annual Performance Statements for all of the Victorian licensed operations are
available to the EPA and indicate a very high level of compliance. Where non-compliances are listed
actions have been taken or are underway to remedy the non-compliances.
1.7.8.2 Operations outside Victoria
Cleanaway’s recent track record outside of Victoria is also testament to it being a fit and proper person
to hold the works approval being applied for.
Attached as part of Appendix A is a list of penalty infringement notices and enforcement action from
environmental regulators outside Victoria over the last 3 years.
Where PINs have been issued, they are generally for isolated incidents, with low or no harm and have
not resulted in further action. The prosecutions in Queensland matters are listed above.
1.7.9 Biogas Operations Contractor
The Biogas facility is operated by Cleanaway’s landfill gas management contractor, currently this is
Run Energy Pty Ltd (Run Energy). Run Energy provide services to Cleanaway at MRL and at several
of their other landfill sites to:
• Install and maintain the landfill gas extraction infrastructure from the landfill cells
• Monitor landfill gas volume and composition
• Balance the well-field across the site
• Operate and maintain the biogas facility.
1.8 Community Engagement
1.8.1 Engagement Activities Completed
Table 1.3 describes the engagement activities that have been completed pursuant to the Works
Approval application.
Table 1.3: Community Engagement Activities
Stakeholder Activity completed and feedback
Melbourne Regional Landfill Community The project was presented initially to the group during the meeting of 27
Reference Group (MRLCRG) November 2019.
Note: Following purchase of MRL, The only action arising from the meeting in regard to the biogas plant was for
Cleanaway re-established this community Cleanaway to confirm what approvals were required for the expansion. The
forum to share information about the landfill minutes note that a planning application was submitted to Council however an
operations with the community members EPA Works Approval is not mentioned.
that represent the interests of the wider An update on the project was provided by Cleanaway at the meeting on 27
community. February 2020. There were no actions arising from the meeting in regard to this
project.
The presentation slides and minutes of each meeting are provided as Appendix
D.
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Stakeholder Activity completed and feedback
EPA Victoria LOPL representatives have been in regular telephone discussions with EPA
Victoria Development Assessment Unit team to discuss the proposed Works
Approval application. EPA provided email correspondence to LOPL on 4
December 2019 confirming that the application is being treated as a Fast Track
application by EPA. The EPA provided guidance on the types of information that
should be included and confirmed that the standard of information provided for a
Fast Track information should not be less than a standard Works Approval
application.
Consideration of the guidance from EPA is included in this Works Approval
application.
Powercor Regular discussions between LOPL and Powercor have taken place since June
2018 pursuant to increasing the power output to the grid, including:
• June 2018: An application was made to Powercor to increase power
output to the grid and initial meeting was held between Cleanaway and
Powercor.
• October 2018: A grid connection feasibility study was sent to Powercor.
• Jan 2019: A “Steady State” network study was sent to Powercor for
review.
• August 2019 – October 2019: Amended “Steady State” network studies
were sent to Powercor for review.
• November 2019: A meeting was held between Cleanaway, Cleanaway’s
engineers and Powercor. The Steady State modelling was approved by
Powercor.
• January 2020: Cleanaway has received the Dynamic Modelling pack from
Powercor and is awaiting the detailed response.
1.8.2 Continuing Community Engagement
The MRLCRG meets quarterly and LOPL representatives intend to provide an update to the project
including this Works Approval application at the next meeting.
1.9 Process and Integrated Environmental Assessment
1.9.1 Existing Operation
1.9.1.1 Landfill Gas Destruction and Utilisation
The existing operation comprises the destruction and utilisation of landfill gas from the MRL landfill
cells for the generation of electrical power from eight 1.115-Megawatt (MW) Caterpillar biogas
engines. Landfill gas has been utilised for electricity generation at MRL since 2006. A Works Approval
was granted in 2007 (WA61767) enabling the progressive installation of engines 2 to 8.
The existing Power Station 1 compound is approximately 0.4 hectares in area and comprises the
landfill flare compound, 8 existing biogas engines, gas conditioning plant and transformers and
ancillary infrastructure such as switch rooms, maintenance shed, oil tanks and water tanks.
Landfill gas is extracted from the landfill cells using a network of over 300 vertical and horizontal
landfill gas extraction bores installed into the waste mass. A series of blowers are used to extract the
landfill gas under pressure and deliver it to the biogas facility using a network of gas header lines.
Moisture is removed from the gas using a series of knockout pots in the header lines before it reaches
the biogas facility.
Gas flow to the biogas facility is regulated to both keep the gas field under negative pressure and to
maintain the rate that gas is delivered to the engines. Prior to combustion, gas conditioning equipment
is used to remove any final moisture or solid contaminants from the gas and adjust the gas
temperature prior to injection into the biogas engine. The landfill gas is combusted in the biogas
engines. Electrical generators known as “GenSets” connected to the biogas engines are used to
generate the electrical power that is exported to the grid. Step-up transformers are then used to
increase voltage from 415 V to 22 kV for supply into the grid network. One transformer is required per
2 biogas engines.
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8General Information
Each biogas engine has the capacity to combust and utilise an average of 625 m3/hr of landfill gas,
providing a total capacity of 5,000 m3/hr from all 8 engines. 3 flares are maintained at the facility to
provide sufficient redundancy in the event that one or more of the biogas engines are not operating.
The 3 flares have the combined capacity to combust 7,000 m3/hr of landfill gas (2 flares have
3,000 m3/hr capacity and 1 flare has 1,000 m3/hr capacity).
Cleanaway has indicated that in the last 12 months a total of 43,708,654 m3 of landfill gas was
directed to the biogas facility and utilised to produce a total of 64,593,198 Kilowatt hours (kWh) of
electricity.
Emissions control is described in Section 2.8.3 and fire management is described in Section 2.8.4.
A plan of the existing conditions is provided as Figure 5.
1.9.1.2 Site Security
The facility is secure and has a 2.5 m high fence surrounding the entire perimeter. The gate is locked
and with access only by Cleanaway authorised personnel. Control rooms and maintenance sheds are
locked.
The facility is not accessible by the public due to its location in the landfill premise. Access to the
landfill is tightly controlled and is only via the main site entrance weighbridge facility which is staffed
during operating hours (24 hours per day 6 days per week) and has CCTV.
1.9.1.3 Vehicle Movements
The biogas facility process does not generate large volumes of traffic. Vehicle movements are
required for operations and maintenance activities only using light vehicles.
1.9.2 Description of the Proposal
It is proposed to develop and operate a second biogas compound, Power Station 2, for the biogas
facility to manage landfill gas generated from MRL. Power Station 2 is a duplication of Power Station 1
and is designed to have capacity for eight 1.115 MW biogas engines configured as a north and south
generator bank. At full capacity the overall biogas facility (i.e. both the existing Power Station 1 and
proposed Power Station 2) would consist of 16 biogas engines capable of combusting and utilising
10,000 m3/hr of landfill gas for electricity generation.
At full capacity, Power Station 2 would comprise:
• Eight 1.115 MW biogas engines.
• 4 high voltage step-up transformers and associated equipment.
• 4 gas conditioning skids.
• Control room and high voltage switch room.
• Fire detection system, fencing and signage.
The compound will be fenced and secured, with access to the compound by Cleanaway authorised
personnel only.
The development of Power Station 2 is primarily to manage landfill gas from the current and future
cells in the current licensed landfill facility boundary. Whether future landfill stages connect to Power
Station 1 and 2 is dependent on the connection logistics (primarily distance) and the available capacity
at the Power Stations at the time. This decision would be taken as part of establishing future landfill
stages.
The modular construction of the engines enables LOPL to scale up and scale down the infrastructure
across the gas generating cycle of the landfill. The project is also staged to manage the flare
redundancy capacity. Initially 4 engines (engines 9 to 12) would be procured and commissioned,
which would provide 7,000 m3/hr of landfill gas utilisation capacity.
There is a 12-month lead for commissioning the facility that includes a 6-month lead time for delivery
of the engines and a 6-month construction and commissioning phase. Assuming the appropriate
approvals are in place by May 2020 the facility could commence operation in May 2021.
The indicative timing for commissioning of engines 13 and 14 is expected to be in 2023, and engines
15 and 16 in 2025.
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9General Information
Flare capacity will be reassessed following the installation of engines 9 to 12. The average availability
of the existing power station is greater than 98%. Most of the down time is due to external factors such
as damage to gas collection infrastructure, network faults or a request to cease generation whilst the
local supply authority conducts switching. It is assumed the new power station will achieve a similar
availability rate. Of the 16 modules, there would normally be one generator off-line for maintenance.
The maintenance is planned well in advance to ensure there is no overlap between the maintenance
periods, where possible.
Cleanaway reports that as the landfill is under vacuum it would take 24 to 48 hours to pressurise to
near atmospheric pressures should there be an unlikely event of all engines flares not operating.
Assuming all flares are operating when all engines are down then then the landfill will be under
vacuum for a much longer period. This means even under worst case conditions there is enough time
to enable repairs. Mobile flares could also be installed at short notice to enable a vacuum to be placed
on the landfill.
Schematic plan and elevation drawings of Power Station 2 are provided as Figure 6 and Figure 7.
The discharge points for the stacks are shown on Figure 8 and Figure 9.
1.9.3 Process and Technology
The proposed process for landfill gas destruction and utilisation is as described in Section 1.8.1. The
major difference between Power Station 2 and Power Station 1 operations is that it is currently not
proposed to locate flares at Power Station 2. This is because a dedicated flare compound has already
been established at Power Station 1.
The biogas engine technology proposed is the Caterpillar G3516 LE landfill gas engine. This is the
same technology as is used currently and is the industry standard for combustion of landfill gas due to
its modular configuration and ability to operate effectively with landfill gas that can often vary in
constituents. The specification and product data sheet for the Caterpillar G3516 LE landfill gas engine
is provided as Appendix C.
1.9.4 Consistency with EPA Victoria Landfill Gas Management Hierarchy
EPA Publication 788.3 Best Practice Environmental Management Siting, Design, Operation and
Rehabilitation of Landfills (EPA, 2015) (often referred to as “the BPEM”) outlines a landfill gas
management hierarchy that describes the management options from least preferred to most preferred.
The options for management depend on the volume of landfill gas produced at the landfill and the
feasibility of implementing the treatment option at the site. The landfill gas management hierarchy is
shown in Figure 1-3. The hierarchy shows that power generation, as currently completed at the site, is
preferred to destruction with a flare without power generation.
Figure 1-1: Landfill Gas Management Hierarchy (EPA, 2015)
The BPEM also specifies a series of relevant objectives for different aspects of landfilling. For
management of landfill gas this is to: “ensure that no safety or environmental impacts are caused by
landfill gas”.
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10General Information
A number of “required outcomes” are provided in the BPEM that need to be implemented in order to
satisfy the relevant objectives and also clause 15 (3) and (4) of the Victoria Waste Management
Policy 1.
The required outcomes of the BPEM that are relevant to the biogas system are:
• Develop and implement an appropriate landfill gas management system.
• The landfill gas management system is updated and is in compliance with the landfill gas
management hierarchy.
The management of landfill gas via combustion is a critical component of the environmental
management and safe operation of the landfill both during operation and post-filling. Landfill gas
needs to be managed from both the active and completed cells at the landfill and the collection and
treatment infrastructure needs to be sized to accommodate the gas generation from the landfill cells.
It is prudent for the operator to predict landfill gas management needs prior to cell construction so that
there is sufficient capacity to manage the gas before that cell becomes operational. Provisioning for
additional landfill gas destruction and utilisation infrastructure is therefore considered best practice.
The proposed upgrades to the landfill gas management infrastructure in this application is a key
component of LOPL’s compliance with the required outcomes of the BPEM and is consistent with
EPAs hierarchy for landfill gas management. Establishing the combustion infrastructure needs to
occur prior to expanding the LFG well field so that the collection efficiency of landfill gas can be
maintained as new cells are connected to the system. This has the effect of reducing the potential for
uncontrolled landfill gas emissions including odours that could occur if there were delays from
connecting to the extraction system.
1.9.5 Consideration of Climate Change
The Victorian Climate Change Act 2017 came into effect on 1 November 2017 and under Section 17
requires EPA to consider climate change in Works Approval decisions.
In considering climate change the proposed expansion of the biogas facility should be considered in
the context of it being a key component of the greenhouse gas management strategy for the landfill
operation as the landfill cells are a much larger potential source of greenhouse gas than the biogas
facility. Landfill gas is created from the anaerobic decomposition of organic matter in the waste. The
principal constituent gases in typical putrescible waste derived landfill gas are methane (typically 60 to
65%) and carbon dioxide (typically 30 to 35%), which are both greenhouse gases. Methane has a
significantly higher global warming potential (GWP) than carbon dioxide, some 56 times higher over
20 years according to the United Nations Framework Convention on Climate Change 2. Therefore, the
net emissions benefit associated with combustion of methane in landfill gas versus the carbon dioxide
emitted from the landfill gas engine stacks supports the proposal for combustion of landfill gas.
The greenhouse gas offset benefit from combustion of methane for energy production is discussed in
Section 2.1.
The 2 main considerations for climate change are therefore considered to be:
• Management of greenhouse gas emissions from the landfill cells
• Utilisation of landfill gas for electricity generation in preference to flaring (i.e. energy recovery)
The BPEM also states that:
“in order to manage landfill gas and minimise greenhouse gas emissions, appropriate landfill gas
containment (for example, landfill cap, basal and side liners) and landfill gas collection systems must
be developed, implemented and monitored”.
As described in Section 1.8.4 the utilisation of landfill gas is preferred by EPA to flaring with no energy
recovery and therefore the proposal to upgrade and continue to combust and utilise landfill gas for
electricity generation is considered to be consistent with EPA best practice to manage landfill gas and
minimise greenhouse gas emissions.
1
Waste Management Policy (Siting, Design and Management of Landfills), No. S264, Gazette 14/12/2004
2
https://unfccc.int/process/transparency-and-reporting/greenhouse-gas-data/greenhouse-gas-data-unfccc/global-warming-
potentials
Note that a GWP value of 25 times higher than carbon dioxide has been used in the Greenhouse Gas Assessment (Section 2.1)
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