ANNUAL PERFORMANCE STATEMENT

Transcription

1 ENVIRONMENT PROTECTION ACT 1970 SECTION 31 D(5) ANNUAL PERFORMANCE STATEMENT AGL LOY YANG PTY LTD HOLDER OF LICENCE: ACN: REGISTERED ADDRESS: PREMISES ADDRESS: LEVEL GEORGE STREET SYDNEY NSW 2000 BARTONS LANE TRARALGON VIC 3844 STATEMENT SUMMARY Statement Period: 01-Jul-2016 To 30-Jun-2017 Total Number of Conditions on Licence: 24 Number of Conditions - Complied: 21 Number of Conditions - Non-Complied: 3 DECLARATION I, Andrew Vesey declare that the information in this Annual Performance Statement is true and correct I have made all necessary enquiries, and no matters of significance have been withheld from the EPA Name: Position: Managing Director Signed: Date: 25 The most senior Australian-ba ed officer of your organisation for this licence must sign this statement and it must be scanned and upload d along with this completed APS form via the EPA web portal by 02 October In the event this is not possible, the signed statement must be faxed to (03) by 02 October In both instances the statement must also be e-certified on the web portal by 02 October Under Section 310(5) of the Environment Protection Act 1970,it is an offence to provide false or misleading information in an Annual Performance Statement or conceal any relevant information or document from the Authority. Contravention of subsection (5) is an indictable offence that carries a penalty of 2400penalty units or imprisonment for two years, or both.

2 ~~~~~ VICTORIA,,~ ANNUAL PERFORMANCE STATEMENT: 01 July 2016 To 30 June 2017 STATEMENT OF COMPLIANCE Premises Address: BARTONS LANE, TRARALGON VIC 3844 Licensed Activities: This licence applies to a premises where brown coal is mined and electricity is generated in a brown coal fired power station with generating capacity waste to land. Scheduled Categories: A05 Landfills C01 K01 Extractive Industry and Mining Power Stations Analysis of performance against environmental Performance Conditions Condition Condition Condition Description Condition Area Reference Complied with? I You must ensure that waste is not discharged, emitted or General LI_G1 deposited beyond the boundaries of the premises except in No accordance with this licence. General General LI_G2 LI_G3 You must immediately notify EPA of non-compliance with any condition of this licence. By 30 September each year you must submit an annual performance statement to EPA for the previous financial year in accordance with the Annual Performance Statement Guidelines (EPA Publication 1320). Documents and monitoring records used for preparation of the General LI_G4 annual performance statement must be retained at the premises for seven years from the date of each statement. General General General LI_G5 LI_G5.2 LI_G6 You must implement a monitoring program that enables you and EPA to determine compliance with this licence. You must implement a program to assess the effect of your discharges to air on the ability of the Latrobe Valley Air Quality Control Region to comply with Schedule 2 of the State environment protection policy (Ambient Air Quality). You must maintain a financial assurance calculated in accordance with the EPA method. You must ensure that odours offensive to the senses of human Amenity LI_A1 beings are not discharged, emitted or released beyond the boundaries of the premises. You must ensure that there are no emissions of noise and/or vibrations from the premises which are detrimental to either of the following: Amenity LI_A2 a) the environment in the area around the premises; and b) the well-being of persons or property in the area around the premises. You must ensure that nuisance dust and/or nuisance airborne Amenity LI_A3 particles are not discharged or emitted beyond the boundaries of No the premises AGL LOY YANG PTY LTD Page 2 of 24

3 c:t'.~~~ VICTORIA.. i~ ANNUAL PERFORMANCE STATEMENT: 01 July 2016 To 30 June 2017 I Condition Condition Condition Description Condition Area Reference Complied with? You must develop and put into place a monitoring program that accords with Section A of the Landfill Licensing Guidelines, (EPA Publication , released September 2016). The program must evaluate the risks to the environment associated with the operation of the landfill and the steps which can be taken to manage such risks and enable both you and EPA to determine changes in the condition of the environment or impacts to environmental quality as a result of activities at the premises. The monitoring program must be verified by a person who has been appointed as an environmental auditor under the Environment Protection Act 1970 and it must do all of the following: a) contain an assessment of the risks to the environment arising from the waste that has been deposited at the premises and of Landfill L1_L1 the current landfill operation prepared in accordance with the Landfill Licensing Guidelines, (EPA Publication , released September 2016) or another method approved by EPA in writing; b) describe the environmental monitoring of landfill gas, leachate, groundwater, land, air, odour, noise, dust and surface water which will be undertaken to respond to the risks identified in the risk assessment in paragraph a) above; c) contain trigger levels and contingency actions to prevent further pollution when exceeded; d) specify the frequency for completing environmental audits of the landfill operation; and e) be appropriate and adapted to the characteristics of the landfill, including the landfill design, the volume of waste received, the age and planned future lifespan of the landfill and the surrounding environment. Landfill Landfill Air L1_L2 LI L4 L1_DA1 You must engage a person who has been appointed as an environmental auditor under the Environment Protection Act 1970 to conduct and submit to EPA environmental audits of the risk of harm actually or potentially arising from landfill operation under Section 53V of the Act at the frequency specified in the monitoring program. Waters contaminated by leachate must not be discharged beyond the boundaries of the premises. Discharge of waste to air must be in accordance with the 'Discharge to Air' Table. The concentration of particles discharged from discharge points 1 Air L1_DA1.3.3 to 4 must not exceed 0.24 grams per normal cubic metre (based on 3 minute averages at 12% C02) for more than a total of 88 hours each year (aggregate total for all discharge points). The annual frequency distribution of the mass discharge rate of sulfur dioxide from discharge points 1 to 4 must not exceed (a) a Air L1_DA1.5 90th percentile frequency distribution mass rate of grams per minute and (b) a 50th percentile frequency distribution mass rate of grams per minute. Air Water L1_DA2.1 L1_DW1 Visible emissions to air other than steam must not be discharged from the premises, except in accordance with condition L1_DA1. You must ensure that surface water discharged from the premises is not contaminated with waste AGL LOY YANG PTY LTO Page 3 of 24

4 CJ:' VICTORIA ~~~~,,~ ANNUAL PERFORMANCE STATEMENT: 01 July 2016 To 30 June 2017 Condition Condition Condition Description Condition Area Reference Complied with? Water LI_DW2 Discharge of waste to surface waters must be in accordance with the 'Discharge to Water' Table. You must ensure that the activities carried on at the premises do not do either of the following, except as permitted by condition LI_DL 1.1.1: a) cause detriment to any beneficial use which may be made of Land LI_DL1.1 groundwater both within and beyond the boundary of the premises; and b) pollute groundwater both within and beyond the boundary of the premises contrary to section 39 of the Environment Protection Act The levels of the following groundwater quality indicators specified in Table 3 of State Environment Protection Policy Land LI_DL1.1.1 (Groundwaters of Victoria) are not required to be met within the attenuation zone shown in Schedule 1B: sulfate, aluminium, total dissolved solids and chloride. Land Land LI_DL2 LI_DL3.1 Discharge of wastewater to land must not adversely affect the land. Deposit of wastes generated at the premises must be in accordance with Schedule 2. You must ensure that the activities carried on at the premises do not do either of the following: No Land LI_DL5.1 a) cause detriment to any beneficial use which may be made of the land on the premises outside of the boundary of any landfill cells; and b) pollute land on the premises contrary to section 45 of the Environment Protection Act AGL LOY YANG PTY LTD Page 4 of 24

5 $?,ORIA Stote EPA Government NON-COMPLIANCE DETAIL Premises Address: BARTONS LANE, TRARALGON VIC 3844 DETAILS OF NON COMPLIANCE WITH LICENCE CONDITION Condition LI_G1 You must ensure that waste is not discharged, emitted or deposited beyond the boundaries of the premises except in accordance with this licence. a) Date(s) when the non-compliance occurred (If applicable) 111/07/2016 I 101/08/ /11/ / /03/2017 b) Summary of particulars of non-compliance 1. Due to a high rainfall event over a long period in July 2016, two exceedances of water quality limits for suspended solids and one exceedance for turbidity occurred at licensed discharge point L160. On 11/7/2016 reported suspended solids of 69mg/L, exceeded the licence limit of 60mg/L. On 1/ reported suspended solids of 110 mg/l and turbidity of 89 NTU, exceeded the licence limits of 60mg/L and 80 NTU respectively. 2. Three strong wind events gave rise to community complaints about fugitive dust. One complaint was received on 7/11/2016, one complaint was received on 30/1/2017 and two complaints were received on 27/3/2017. These complaints were verified. c) What is your assessment of environmental impact as a result of non-compliance 1. Record rainfall caused the flow in the Traralgon creek to also be elevated at the time of the exceedances on 11/7/16 and There was no material harm to the environment as a result of these exceedances. 2. The verified complaints were regarding nuisance fugitive dust causing an amenity impact AGL LOY YANG PTY LTD Page 5 of 24

6 C"f\ EPA ~~~I,~.~ d) Cause of non-compliance 1. On 11/7/2016 overtopping of the North West Corner Retention Pond resulted in an increase in flowrate through the flocculant dosing station. The manually set flocculant dosing rate was not adjusted in proportion to the increased flowrate. On 1/8/2016 the rate of flow through the treatment system, in excess of the design throughput, reduced the available settling time. The system was designed for short duration, high intensity rain events rather than for long periods of regular rainfall. 2. On 7/11/2016, 30/1/2017 and 27/3/2017 strong winds generated fugitive dust in the Mine, which discharged off-site due to the strength of the winds. e) Action taken or that will be taken to mitigate any adverse effects of the non-compliance 1. There was no material harm to the environment as a result of the elevated levels of suspended solids on 11/7/2016 and the elevated levels of suspended solids and turbidity on 1/8/ The Trigger Action Response Plan (TARP) was implemented for each strong event, and the activation of sprays for wetting down occurred in accordance with the TARP. Each of the complainants had direct contact with a representative from AGL Loy Yang, and the activities being undertaken to manage and mitigate off-site dust were discussed. Water tanks were cleaned and water replaced where required. f) Action taken or that will be taken to prevent reoccurence of the non-compliance 1. Reviewing the treatment system capacity and design, implementing an automated flocculant dosing system and installing an online water quality monitoring system. Upgrades to the treatment system have commenced and are in progress. 2. Actions taken: (i) allocating a second permanent water cart to base of mine activities; (ii) identifying areas in the mine for priority application of paper mulch; (iii) conducting an expert review of the current dust mitigation activities; (iv) conducting series of dust management improvement idea generating sessions with site personnel; and (v) implementing a program to enable remote operation capability of the water spray network AGL LOY YANG PTY LTO Page 6 of 24

7 ~~t~ri~ EPA.. i~vernme Premises Address: BARTONS LANE, TRARALGON VIC 3844 DETAILS OF NON COMPLIANCE WITH LICENCE CONDITION Condition: LI_A3 You must ensure that nuisance dust andlor nuisance airborne particles are not discharged or emitted beyond the boundaries of the premises. a) Date(s) when the non-compliance occurred (If applicable) / / /03/ b) Summary of particulars of non-compliance Three strong wind events gave rise to community complaints about fugitive dust. One complaint was received on 7/11/2016, 30/1/2017 and two complaints were received on 27/3/2017. These complaints were verified. one complaint was received on c) What is your assessment of environmental impact as a result of non-compliance The verified complaints were regarding nuisance fugitive dust causing an amenity impact. d) Cause of non-compliance On 7111/2016, 30/1/2017 and 27/3/2017 strong winds generated fugitive dust in the Mine, which discharged off-site due to the strength of the winds. e) Action taken or that will be taken to mitigate any adverse effects of the non-compliance The Trigger Action Response Plan (TARP) was implemented for each event, and the activation of sprays for wetting down occurred in accordance with the TARP. Each of the complainants had direct contact with a representative from AGL Loy Yang, and the activities being undertaken to manage and mitigate off-site dust were discussed. Water tanks were cleaned and water replaced where required AGL LOY YANG PTY LTD Page 7 of 24

8 ~~ORIA Stob;! EPA GOllcrnmllnt f) Action taken or that will be taken to prevent reoccurence of the non-compliance Actions taken: (i) allocating a second permanent water cart to base of mine activities; (ii) identifying areas in the mine for priority application of paper mulch; (iii) conducting an expert review of the current dust mitigation activities; (iv) conducting series of dust management improvement idea generating sessions with site personnel; and (v) implementing a program to enable remote operation capability of the water spray network AGLLOYYANGPTYLTD Page 8 of 24

9 c:e'?~~!.~ VICTORIA ANNUAL PERFORMANCE STATEMENT: 01 July 2016 To 30 June 2017 Premises Address: BARTONS LANE, TRARALGON VIC 3844 DETAILS OF NON COMPLIANCE WITH LICENCE CONDITION Condition LI_DW2 Discharge of waste to surface waters must be in accordance with the 'Discharge to Water' Table. a) Date(s) when the non-compliance occurred (If applicable) 111/07/ /08/2016 b) Summary of particulars of non-compliance Due to a high rainfall event over a long period in July 2016, two exceedances of water quality limits for suspended solids and one exceedance for turbidity occurred at licensed discharge point L160. On 11/7/2016 reported suspended solids of 69mg/L, exceeded the licence limit of 60mg/L. On 1/ reported suspended solids of 110 mg/l and turbidity of 89 NTU, exceeded the licence limits of 60mg/L and 80 NTU respectively. c) What is your assessment of environmental impact as a result of non-compliance Record rainfall caused the flow in the Traralgon creek to also be elevated at the time of the exceedances on 11/7/16 environment as a result of these exceedances. and There was no material harm to the d) Cause of non-compliance On 11/7/2016 overtopping of the North West Corner Retention Pond resulted in an increase in flowrate through the flocculant dosing station. The manually set flocculant dosing rate was not adjusted in proportion to the increased flowrate. On 1/8/2016 the rate of flow through the treatment system, in excess of the design throughput, reduced the available settling time. The system was designed for short duration, high intensity rain events rather than for long periods of regular rainfall. e) Action taken or that will be taken to mitigate any adverse effects of the non-compliance There was no material harm to the environment as a result of the elevated levels of suspended solids on 1117/2016 turbidity on and the elevated levels of suspended solids and f) Action taken or that will be taken to prevent reoccurence of the non-compliance Reviewing the treatment system capacity and design, implementing an automated flocculant dosing system and installing an online water quality monitoring system. Upgrades to the treatment system have commenced and are in progress AGL LOY YANG PTY LTD Page 9 of 24

10 ~?g,~~~ AIR ADDITIONAL INFORMATION Premises Address: BARTONS LANE, TRARALGON VIC 3844 AIR - MONITORING METHODS Carbon monoxide Continuous 0.01 N/A Chlorine compounds (as Chlorine) Stack test YES Fluorine compounds (as HF) Stack test YES Oxides of nitrogen (as N02) Continuous 0.01 N/A Particles Continuous 2.52 N/A Sulfur dioxide Continuous 0.01 N/A Sulfur trioxide Stack test YES AIR - RECORDED VALUES 1 TO 15 Particles g/min 43,400 = 29, Opacity No Proxy Indicator Used 1 T04 Carbon monoxide g/min 206,000 = No Proxy Indicator Used No Proxy Indicator Used 1 T04 Chlorine compounds (as Chlorine) g/min 33,000 = No Proxy Indicator Used No Proxy Indicator Used 1 T04 Fluorine compounds (as HF) g/min 8,200 = No Proxy Indicator Used No Proxy Indicator Used 1 T04 Oxides of nitrogen (as N02) g/min 114,000 = No Proxy Indicator Used No Proxy Indicator Used 1 T04 Sulfur dioxide g/min 400,000 = No Proxy Indicator Used No Proxy Indicator Used AGL LOY YANG PTY LTO Page 10 of 24

11 ~~g,~i,~ Discharge Point Number Indicator Units Licence Limit Maximum Recorded Value 90th Percentile Value Primary Proxy Indicator Secondary Proxy Indicator 11 T04 Sulfur trioxide g/min I 33,000 I = I INOProxy Indicator Used INo Proxy Indicator Used * Indicates a bubble limit AGL LOY YANG PlY LTO Page 11 of 24

12 $?,ORIA EPA ~~rnmel'lt WATER ADDITIONAL INFORMATION Premises Address: BARTONS LANE, TRARALGON VIC 3844 WATER - RECORDED VALUES L160 Turbidity Required NTU Maximum 80 = L171 Turbidity Required NTU 90th Percentile 40 = L160 Turbidity Required NTU Annual Median 30 = L171 Turbidity Required NTU Annual Median 20 = L160 Total dissolved solids Required mgtl Maximum 700 = L171 Total dissolved solids Required mgtl Maximum 700 = L160 Total dissolved solids Required mgt I Annual Median 500 = L171 Total dissolved solids Required mgtl Annual Median 500 = L160 ph Required ph Minimum 6 = L171 ph Required ph Minimum 6 = L160 ph Required ph Maximum 8.5 = L171 ph Required ph Maximum 8.5 = L171 Colour Required Pt-Co Maximum 70 = L171 Colour Required Pt-Co Annual Median 50 = L160 Suspended solids Required mgtl Maximum 60 = L171 Suspended solids Required mgt I 90th Percentile 40 = L160 Suspended solids Required mgtl Annual Median 40 = L171 Temperature above ambient Required Degree I Above Ambient 8 = AGL LOY YANG PTY LTO Page 12 of 24

13 c:e'?g~!,~ Suspended solids L160 Turbidity Optional No NTU 90th Percentile = L171 Turbidity Optional No NTU Maximum = L160 Turbidity Optional No NTU 90th Percentile = L171 Turbidity Optional No NTU Maximum = L160 Total dissolved solids Optional No mg/l 90th Percentile = L171 Total dissolved solids Optional No mg/l 90th Percentile L160 Total dissolved solids Optional No mg/l 90th Percentile L171 Total dissolved solids Optional No mg/l 90th Percentile I 1= L160 ph Optional No ph Annual Median L171 ph Optional No ph Annual Median 1 1= L160 ph Optional No ph Annual Median 1 1= L171 ph Optional No ph Annual Median L171 Colour Optional No Pt-Co 90th Percentile L171 Colour Optional No Pt-Co 90th Percentile L160 Suspended solids Optional No mg/l 90th Percentile I 1= L171 Suspended solids Optional No mg/l Maximum L160 Suspended solids Optional No mg/l 90th Percentile L171 Temperature above ambient Optional No Degree Annual Median L171 Temperature above ambient Optional No Degree Maximum L171 Temperature above ambient Optional No Degree Minimum I 1= WATER - SAMPLING RECORD AND FLOW Number of Samples AGL LOY YANG PTY LTO Page 13 of 24

14 C"'f'.ORIA. EPA ~~rnmllnt 01 (Jul - Sep) 02 (Oct - Dec) 03 (Jan - Mar) 04 (Apr - Jun) Total. I 13 II 13 II 13 II 13 11~ Discharge (ML) 01 (Jul - Sep) 02 (Oct - Dec) 03 (Jan - Mar) 04 (Apr - Jun) Total I 2, II 1, II 1, II 1, r--6-, , AGL LOY YANG PTY LTD Page 14 of 24

15 Cf'?g,~~,~ LANDFILL ADDITIONAL INFORMATION Premises Address: BARTONS LANE, TRARALGON VIC 3844 MONITORING PROGRAM VERIFICATION Has your monitoring program been verified by an environmental auditor in the past Financial Year? Last date Monitoring Program verified: 127/06/2017 ~========== Environmental Auditor: IRohan Ash 1 Did the environmental auditor set any requirements for your monitoring program? Audit frequency (set by auditor) every year(s) Next scheduled audit completion date: 130/06/ le' le 0 No ONo This is the date of your next audit and it must be within the audit frequency period set by the environmental auditor. AUDIT REQUIREMENTS Has your environmental audit been completed in the past Financial Year? le C No Last audit report date: Environmental Auditor: Audit report CARMS number: 127/06/ [ROhanAsh Did the environmental auditor set any recommendations? Ci CNo I AGL LOY YANG PlY LTD Page 15 of 24

16 $w.or1a EPA.. i:~rnmcnt AUDITOR REQUIREMENTS I RECOMMENDATIONS Flow monitoring and telemetry on the leachate system has been installed and is operational. 2014/ R18 Monitoring Program Low 30/06/2016 Completed 30/06/2017 roundwater potentiometric levels and interpreted flow directions for the SAS and MFAS around the Ash Pond are presented in the FY17 Annual Groundwater Monitoring Report. 2014/ R20 Monitoring Program Low 30/06/2016 Completed 25/08/2017 Action Taken 1 Proposed AGL LOY YANG PTY LTO Page 16 of 24

17 ~?,ORIA Stote EPA Governml)nt Equipotential maps are presented in the FY17 Annual Groundwater Monitoring Report. 2014/ R22 Monitoring Program Low 30106/2016 Completed 25/08/ R30 Monitoring Program Low 30/06/2016 Completed 06/12/2016 Update the ERMP including Landfill Monitoring Program documentation to reflect the outcomes of this audit. Consider the suggested editorial changes in Appendix E. Action Taken 1 Proposed AGL LOY YANG PTY LTD Page 17 of 24

18 $.~~!.~ EPA Action Taken / Proposed n "operational landfill audit" was completed and the audit report issued on 27/6/ / R1 Monitoring Program Low 30/06/2018 Not started 2016/ R4 Monitoring Program Low 30/06/2019 Not started Recommendation AGLLOYYANG PTY LTD Page 18 of 24

19 Cf' VICTORIA?~~!.~ ANNUAL PERFORMANCE STATEMENT: 01 July 2016 To 30 June 2017 audits. Recommendation has been reviewed and accepted. The EMP will be updated to reflect this recommendation. 2016/ R6 Monitoring Program Low 30106/2019 Not started Recommendation has been reviewed and accepted. The EMP will be updated to reflect this recommendation R7 Monitoring Program Low 30106/2018 Completed 04/04/ AGL LOY YANG PlY LTO Page 19 of 24

20 ~~~,~I,~ R10 Monitoring Program Low 30106/2018 In Progress New Bore LY4923 (see Appendix A GHD 2017 Figure 1 Bore Location Plan) is proposed on the western bench of the OB dump. When installed include this in the LMP network. Recommendation has been reviewed and accepted. The EMP will be updated to reflect this recommendation AGL LOY YANG PTY LTO Page 20 of 24

21 c:t'?~~!,~ Recommendation has been reviewed and accepted. The EMP will be updated to reflect 6 monthly water quality monitoring of all ash pond and landfill monitoring bores. 2016/ R13 Monitoring Program Low 30/06/2019 In Progress Recommendation has been reviewed. Consideration will be given to plotting Na/CI ratios as a function of key parameters in the FY18 Annual Groundwater Monitoring Report. 2016/ R15 Monitoring Program Medium 31/12/2017 In Progress AGL LOY YANG PTY LTD Page 21 of 24

22 $~ORIA EPA Stote Government e R16 Monitoring Program Medium 31/12/2017 In Progress Recommendation has been reviewed and accepted. The EMP will be updated to reflect this recommendation R18 Site Audit Low 30106/2019 Not started AGLLOYYANG PTY LTD Page 22 of 24

23 $~t~ri~ EPA.. ~~vcrnme IRecommendation has been reviewed and accepted. An operational landfill audit will be undertaken by an EPA appointed auditor in the APS reporting period AGL LOY YANG PlY LTO Page 23 of 24

24 $~ORIA EPA Stote Government WASTEWATER TO LAND ADDITIONAL INFORMATION Premises Address: BARTONS LANE, TRARALGON VIC 3844 Discharge of Wastewater to Land (ML) Number of irrigation Days Net Irrigation Area (hectares) I ] I 121 I I 115 I AGL LOY YANG PTY LTD Page 24 of 24