APPENDIX 13 Continued: ASD Assessment of EBAC response to S22 Notice 2 EPA issued a request for further information in the form of a Section 22 Notice, dated 8 May 2018, seeking clarification on Technical aspects of the application, specifically the following: Provide justification for the use of strip filter drains in the landfill cells: The use of filter strip drains in not recommended in landfill cells as it does not support on-going maintenance such as inspection and cleaning and has a higher risk of premature failure due to clogging; Provide further justification for the substitution of the drainage layer with a soil protection layer: Please outline the OH&S risks associated with the use of the BPEM compliant aggregate layer. Outline how the build-up of leachate head will be prevented. The build-up of a head of leachate could compromise the integrity of the cell liner leading to failure. It is understood that over many decades the leachate collection systems could fail. Explain how the design requirement for the cell still be able to remove liquid from the CCL surface through natural drainage alone will be met, in the event of failure of the drains. Please provide supporting evidence that demonstrates how the deviations from the best practice design that you have proposed in your application will achieve the objectives of the BPEM and do not increase the environmental risk. A response to the Section 22(1) notice was submitted by GHD 18 May 2018 and forms part of the current review and subsequent ASD advice. ADVICE ASD note the following assumption that has been considered when formulating our advice (as stated in the report titled Brix Australia, Former Morwell Power Station, Phase 2 Environmental Site “Energy Assessment”, dated March 2018 prepared by GHD): landfill will only be receiving solid inert asbestos waste. All other waste material “The [generated during demolition] will be… either recycled or disposed at appropriately … licenced landfill site”. Therefore, ASD assume ALL waste entering the proposed landfill will be handled in accordance with publication 611.2 (EPA Victoria, June 2017), and as described in section 4.12.2 of the GHD report
APPENDIX 13 Continued: ASD Assessment of EBAC response to S22 Notice 2 EPA issued a request for further information in the form of a Section 22 Notice, dated 8 May 2018, seeking clarification on Technical aspects of the application, specifically the following: Provide justification for the use of strip filter drains in the landfill cells: The use of filter strip drains in not recommended in landfill cells as it does not support on-going maintenance such as inspection and cleaning and has a higher risk of premature failure due to clogging; Provide further justification for the substitution of the drainage layer with a soil protection layer: Please outline the OH&S risks associated with the use of the BPEM compliant aggregate layer. Outline how the build-up of leachate head will be prevented. The build-up of a head of leachate could compromise the integrity of the cell liner leading to failure. It is understood that over many decades the leachate collection systems could fail. Explain how the design requirement for the cell still be able to remove liquid from the CCL surface through natural drainage alone will be met, in the event of failure of the drains. Please provide supporting evidence that demonstrates how the deviations from the best practice design that you have proposed in your application will achieve the objectives of the BPEM and do not increase the environmental risk. A response to the Section 22(1) notice was submitted by GHD 18 May 2018 and forms part of the current review and subsequent ASD advice. ADVICE ASD note the following assumption that has been considered when formulating our advice (as stated in the report titled “Energy Brix Australia, Former Morwell Power Station, Phase 2 Environmental Site Assessment”, dated March 2018 prepared by GHD): “The landfill will only be receiving solid inert asbestos waste. All other waste material [generated during demolition] … will be… either recycled or disposed at appropriately licenced landfill site”. Therefore, ASD assume ALL waste entering the proposed landfill will be handled in accordance with publication 611.2 (EPA Victoria, June 2017), and as described in section 4.12.2 of the GHD report