Amazon S3 - WORKS APPROVAL APPLICATION EPA ......The Camperdown Compost Company Pty Ltd (Camperdown Compost) has prepared a works approval application for the upgrade of their existing

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WORKS APPROVAL APPLICATION

EPA LICENCE 13415 445 Sandys Lane,

Bookaar, VIC

July 2020

Camperdown Compost Works Approval Application July 2020

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Document Information Prepared for

Project Name

Date

Client Contact

Author(s)

The Camperdown Compost Company

The Camperdown Compost Company Works Approval Application

16 July 2020

Nick Routson

Dr Jacquelle Gorski and Nathan Hines

Distribution List Report Status

Date Issued

Number of Copies

Description of Changes

Environment Protection Authority Final 19/06/2020 1

The Camperdown Compost Company Environment Protection Authority Corangamite Shire Council

Final 14/07/2020 3 Amendment to Appendix C Drawing No: ECP-01

The Camperdown Compost Company Environment Protection Authority Corangamite Shire Council

Final 16/07/2020 3 Amendment to table 6 page 27 to remove reference ‘grease trap waste’

Company Details Registered Name Sustainable Project Management Pty Ltd ABN 91 625 759 275 Author Dr Jacquelle Gorski Address 13 Banksia Close Torquay Vic 3228 Phone 0411 551 833 Email [email protected]

Sustainable Project Management Pty Ltd has produced this document in accordance with instructions from The Camperdown Compost Company for their use only. The concepts and information contained in this document are the copyright of Sustainable Project Management Pty Ltd. Use or copying of this document in whole or in part without written permission of Sustainable Project Management Pty Ltd constitutes an infringement of copyright.

This is a controlled document. Details of the document ownership, location, distribution, status and revision history are listed above. All comments or requests for changes to content should be addressed to the document owner

Sustainable Project Management Pty Ltd does not warrant this document is definitive nor free from error and does not accept liability for any loss caused, or arising from, reliance upon the information provided herein.

© 2018 Sustainable Project Management Pty Ltd

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Executive Summary The Camperdown Compost Company Pty Ltd (Camperdown Compost) has prepared a works approval application for the upgrade of their existing composting facility at 445 Sandys Lane, Bookaar, Victoria.

The facility is proposing two major changes to the onsite waste treatment:

1. Increase in the licence limit for the amount of waste treated onsite from 24,000 tonnes per year to 50,000 tonnes per year (T/yr), to be composed of up to 30,000 t/yr green organics and up to 30,000 t/yr Prescribed Industrial Waste (PIW), subject to not exceeding a starting windrow bulk density of 650kg/m3, and not exceeding a starting windrow moisture content of 65%.

2. Receival of two (2) additional compost wastes specifically: • Municipal food waste from kerbside Food Organics Garden Organics (FOGO) collection,

and • Commercial food waste (e.g. from restaurants, catering operations)

The upgrade to the site will improve the waste processing on site by employing biological drying of the liquid PIW, which will enhance the compost decomposition through forced aeration of the windrows. The forced aeration will remove significantly more water from the compost with the biological heat generated by microbes.

The intent of the upgrade is to ensure the site can efficiently process waste produced in Victoria’s south west region, such as dairy processors and Councils. Over the past few years, several composting operations in the region have closed down, which has reduced the waste processing capacity in the region and placed added pressure on businesses that produce waste by-products, such as dairy industries and Councils.

The proposed upgrade at the Bookaar site is in line with best practice for waste composting as:

• Biological drying will result in better treatment of wastes during the primary stages of composting • Increased aeration and evaporation in compost will minimise any runoff • Contact water (PIW) is segregated from leachate (Maturation runoff) within the site’s catchment,

and • An impervious hardstand, consistent with EPA Publication 1588.1, will ensure risk to groundwater

is minimised.

This proposal is broadly in line with the regional objectives outlined in the 2017-2026 Barwon South West Waste and Resource Recovery Implementation Plan which identifies a need for new or upgraded organics process infrastructure.

The following application for the upgrade of the site has been prepared in accordance with EPA Publication 1588.1, 1658 and Australian Standard 4454 and is being submitted to EPA in parallel with a planning permit application to Corangamite Shire Council.

A number of studies have been completed to inform this application. These include:

• An air quality assessment (GHD, Appendix D) has confirmed the upgrades are likely to improve the air quality including odour and dust emissions


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• A stormwater balance (Foresight Engineering, Appendix F) has confirmed that the proposed contact water dam will adequately manage stormwater and leachate captured within the site

• Groundwater assessment to understand the existing risks to shallow aquifers (SESL, Appendix G) assessment and management plan will provide

Extensive research has been completed to determine the optimal design proposed for the upgrade. The activities proposed on site have been modelled on a successful operation of the Seiringer Umweltservice GmbH composting facility in Weiselberg, Austria.

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Table of Contents Primary Information ............................................................................................................... 10

1.1. Need for Works Approval ................................................................................................ 10

1.2. Works Details ................................................................................................................ 10

1.3. Company Legal Entity .................................................................................................... 10

1.3.1. CEO Contact Details ............................................................................................... 10

1.4. Track Record ................................................................................................................. 11

1.5. Application Fee .............................................................................................................. 11

Legal and Policy Framework .................................................................................................. 12

2.1. Victorian Legislation ....................................................................................................... 12

2.2. Relevant Guidelines ....................................................................................................... 12

2.3. Principles of the EP Act .................................................................................................. 12

Composting in the South West region ...................................................................................... 13

3.1. Barwon South West Waste Resource Recovery ................................................................ 13

3.2. Other Composting Operations in the Region ..................................................................... 13

The Camperdown Compost Site ............................................................................................. 14

4.1. Choice of location .......................................................................................................... 14

4.2. Surrounding area and sensitive receptors ......................................................................... 14

4.3. Topography ................................................................................................................... 16

4.4. Site Geology.................................................................................................................. 16

4.5. Climate Data ................................................................................................................. 16

4.6. Local Waterways ........................................................................................................... 16

4.7. Flooding ........................................................................................................................ 17

LAND USE ........................................................................................................................... 18

5.1. Planning and Other Approvals ......................................................................................... 18

Existing Camperdown Compost Operation ............................................................................... 19

6.1. Existing Operation .......................................................................................................... 19

6.2. Existing Product Quality .................................................................................................. 20

6.3. Reference Site for Upgrade ............................................................................................. 23

6.3.1. Comparison between Reference Site and Camperdown Compost ................................ 25

Proposed Process and Technology Upgrade ........................................................................... 26

7.1. Current Site Deficiencies ................................................................................................ 26

7.2. The Proposed Upgrade .................................................................................................. 26

7.2.1. Site upgrades already commenced ........................................................................... 26

7.3. Hours of Operation ......................................................................................................... 27

7.4. Traffic Management ....................................................................................................... 27

7.5. Source of Raw Materials ................................................................................................. 27


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7.6. Existing and Proposed Input Streams and Rates ............................................................... 28

7.7. Mass Balance and Process Flow ..................................................................................... 31

7.7.1. Design Contingency Scenarios ................................................................................. 33

7.8. Stages of Composting .................................................................................................... 34

7.8.1. Stage 1 - Feedstock Receipt (Pre-Compost Processing) ............................................. 34

7.8.2. Stage 2 - Blending of feedstock with mature compost ................................................. 34

7.8.3. Stage 3 - Composting (Biological Drying) .................................................................. 34

7.8.4. Stage 4 - Composting (Pasteurisation) ...................................................................... 34

7.8.5. Stage 5 - Composting (Maturation) ........................................................................... 34

7.8.6. Stage 6 - Screening ................................................................................................ 34

7.9. The Mechanical Process ................................................................................................. 36

7.9.1. Biological Drying ..................................................................................................... 36

7.9.2. Aerated Concrete Floor ........................................................................................... 36

7.9.3. Self-Powered Windrow Turner .................................................................................. 39

7.9.4. Water Application .................................................................................................... 40

7.9.5. Process water ........................................................................................................ 41

7.9.6. Process Control/Monitoring ...................................................................................... 42

7.9.7. Maintenance .......................................................................................................... 43

7.9.8. Wastes Produced ................................................................................................... 43

7.10. Compost Quality Assurance ........................................................................................ 43

7.11. The Market ................................................................................................................ 44

Air Assessment ..................................................................................................................... 45

8.1. Relevant Legislation ....................................................................................................... 45

8.2. Air quality assessment .................................................................................................... 45

8.2.1. Existing air emission sources ................................................................................... 45

8.2.2. Buffer distances ...................................................................................................... 46

8.2.3. Baseline odour survey ............................................................................................. 46

8.2.4. Qualitative dust and bioaerosol assessment .............................................................. 47

8.3. Conclusion .................................................................................................................... 47

8.4. Air quality best practice management ............................................................................... 48

Energy Use and Greenhouse Gas (GHG) ................................................................................ 51

9.1. Relevant legislation ........................................................................................................ 51

9.2. Greenhouse gas emissions sources ................................................................................. 51

9.3. GHG calculations for Camperdown Compost .................................................................... 51

9.4. Best practice energy and greenhouse gas management .................................................... 54

Water Assessment ............................................................................................................ 55

10.1. Relevant legislation .................................................................................................... 55


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10.2. Surface water management ......................................................................................... 55

10.2.1. Site Water Balance ................................................................................................. 55

10.2.2. Stormwater ............................................................................................................ 56

10.2.3. Leachate and contact water ..................................................................................... 56

10.2.4. Water Management Hierarchy .................................................................................. 57

10.3. Groundwater .............................................................................................................. 58

10.3.1. Regional groundwater ............................................................................................. 58

10.3.2. Groundwater at Camperdown Compost ..................................................................... 58

10.3.3. Groundwater monitoring events ................................................................................ 59

10.3.4. Potential for groundwater impacts ............................................................................ 62

10.4. Best practice water management ................................................................................. 62

Noise Assessment ............................................................................................................. 63

11.1. Noise impact .............................................................................................................. 63

11.2. Best practice noise management ................................................................................. 63

Waste Assessment ............................................................................................................ 65

12.1. Waste handling and treatment ..................................................................................... 65

12.2. Process water management ........................................................................................ 65

12.3. Recycling operation .................................................................................................... 65

12.4. Best practice PIW management ................................................................................... 66

12.5. Financial Assurance ................................................................................................... 66

Biosecurity ........................................................................................................................ 67

13.1. Biosecurity Hazards .................................................................................................... 67

13.1.1. Emergency Animal Diseases .................................................................................... 67

13.1.2. Disease Vectors ..................................................................................................... 68

13.1.3. Restricted Animal Material (RAM) ............................................................................. 68

13.2. Best practice biosecurity management .......................................................................... 69

Climate Change Impacts .................................................................................................... 70

Site Risks ......................................................................................................................... 71

15.1. Emergency Management ............................................................................................. 71

15.2. Fire Risk and Management ........................................................................................... 71

Environmental Management ............................................................................................... 74

Stakeholder Engagement ................................................................................................... 75

17.1. EPA Consultation ....................................................................................................... 75

17.2. Corangamite Shire Council .......................................................................................... 76

17.3. Public Consultation ..................................................................................................... 76

17.4. Industry and Local Government Feedback .................................................................... 77

Environmental Best Practice ............................................................................................... 78


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18.1. Choice of Process and Technology/Integrated Environmental Assessment ....................... 80

18.1.1. Final Choice of Technology ...................................................................................... 81

Post Works Approval ......................................................................................................... 83

19.1. Commissioning Plan ................................................................................................... 83

19.1.1. Cold test (technical commissioning) .......................................................................... 83

19.1.2. Warm test (technological commissioning) .................................................................. 83

19.2. Post works approval – Operation Requirements ............................................................. 83

19.2.1. Financial Assurance ................................................................................................ 83

19.2.2. Monitoring .............................................................................................................. 83

19.3. Licence Amendment Subsequent to WAA ..................................................................... 84

Table index Table 1 South West regional composting .................................................................................. 13 Table 2 Wastes processed at Camperdown Compost ............................................................... 19 Table 3 Product results against AS4454 ................................................................................... 22 Table 4 Waste processing at the Weiselberg Site ...................................................................... 23 Table 5 Comparison of inputs between Camperdown Compost and reference site ........................ 25 Table 6 Typical Feedstocks ..................................................................................................... 27 Table 7 Historic input streams and rates (2015 to 2019) ............................................................. 28 Table 8 Proposed Input Streams and Rates .............................................................................. 29 Table 9 Process flow and mass balance of 50,000 tonnes .......................................................... 31 Table 10 Mass balance calculations for 50,000 tonnes ................................................................ 32 Table 11 Comparison of water demand under each scenario. ....................................................... 33 Table 12 Stages of Composting ................................................................................................. 35 Table 13 Advantages of self-propelled windrow turners over excavators or front-end loaders ........... 39 Table 14 Proposed controls and monitoring ................................................................................ 42 Table 15 Optimal operating parameters ...................................................................................... 42 Table 16 Product Quality Testing Regime ................................................................................... 43 Table 17 Buffer distances for existing and future activities at Camperdown Compost ...................... 49 Table 18 Site specific directional buffers for Camperdown Compost .............................................. 50 Table 19 Annual GHG calculations ............................................................................................ 53 Table 20 Camperdown Compost water hierarchy ........................................................................ 57 Table 21 Summary of groundwater exceedances ........................................................................ 60 Table 22 Key stakeholders ........................................................................................................ 75 Table 23 Concerns Raised in Public Submissions ....................................................................... 76 Table 24 EPA Publication 1517.1 Demonstrating Best Practice ..................................................... 78 Table 25 Best Available Techniques (BAT) Reference Document for Waste Treatment ................... 79 Table 26 Options considered by Camperdown Compost .............................................................. 80 Table 27 Variations to open window aerated concrete pad ........................................................... 82


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Figure index Figure 1 Location of Camperdown Compost in land parcel ........................................................... 14 Figure 2 Residents in proximity to Camperdown Compost ........................................................... 15 Figure 3 Nearest sensitive environmental receptors .................................................................... 16 Figure 4 Land use Farming Zone .............................................................................................. 18 Figure 5 Existing site footprint ................................................................................................... 20 Figure 6 Locality map of the Weiselberg composting site ............................................................. 24 Figure 7 Aerial view of the site showing aerated floor .................................................................. 24 Figure 8 The Chimney Effect .................................................................................................... 37 Figure 9 Aerated floor installed by Compost Systems, Austria ...................................................... 38 Figure 10 Diagram Illustrating aeration under windrows................................................................. 38 Figure 11 Self-Propelled Windrow Turner trialled at Camperdown Compost .................................... 40 Figure 12 A typical irrigation hose reel with impeller ...................................................................... 41 Figure 13 Example of high speed surface aeration of a leachate pond ............................................ 57 Figure 14 Groundwater monitoring wells and groundwater contours 2017 ....................................... 61 Figure 15 Location of groundwater monitoring wells 2020 .............................................................. 61

Appendices Appendix A – ASIC Company Extract

Appendix B – Offence Declaration

Appendix C – Camperdown Compost Site Layout and Design Plans

Appendix D – Air Quality Assessment (GHD, 2020)

Appendix E – Seiringer Umweltservice GmbH Odour Study

Appendix F – Site Water Balance (Foresight Engineering, June 2020)

Appendix G – Groundwater Monitoring Reports – March, 2017, May 2018 and March/May 2020 (SESL)

Appendix H – Groundwater Monitoring Plan (SESL, February 2020)

Appendix I – Site Risk Register

Appendix J – Environmental Management Plan

Appendix K - Emergency Management Plan

Appendix L – Fire Risk Assessment and Management Procedure

Appendix M – Correspondence to surrounding residences

Appendix N – Letters of Support

Appendix O – Financial Assurance Calculation

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Primary Information 1.1. Need for Works Approval

Camperdown Compost has operated at 445 Sandys Lane Bookaar since 2000 and has been licensed by EPA to operate (EPA licence 13415) since 2000. Camperdown Compost is applying to EPA for an amendment to its existing licence to allow an increase in the volume of waste received on site.

A works approval application was submitted by Camperdown Compost in August 2019. This document is a revision to the original works approval application and outlines the proposed upgrades at the site to improve the processing of waste to compost. As part of the upgrades, Camperdown Compost will implement best practice technology for composting and will apply processes successfully operating in Weiselberg Austria. Details in this application provide information to support the request to increase volumes processed at the Bookaar site and minimise environmental impact.

An EPA works approval is triggered by the Environment Protection (Scheduled Premises) Regulations 2017 for the following premises activities:

Scheduled Category A01 – Prescribed Industrial Waste Management

Storage, treatment, reprocessing, containment or disposal facilities handling any prescribed industrial waste not generated at the premises

Schedule Category A07 – Organic waste processing

Premises on which organic waste is processed by aerobic or anaerobic biological conversion and which—

(b) accept more than 70 tonnes or 140 cubic metres of organic waste in any month and produce more than 50 tonnes of pasteurised material, compost or digestate in any month.

1.2. Works Details

Project/Works Name Composting Upgrade – Improvements to Camperdown Compost Company Organic Waste Recycling Facility

Cost of Works $2,500,000

1.3. Company Legal Entity

The Camperdown Compost Company Pty Ltd is a registered company with the Australian Securities and Investment Commission (ASIC). The details are as follows:

Company Name The Camperdown Compost Company Pty Ltd ACN 108 839 363 ABN 59 108 839 363 Registered Address 19 Pike Street CAMPERDOWN VIC 3260 Principal Place of Business 445 Sandys Lane BOOKAAR VIC 3260 Relevant current EPA licence number 13415

A current Company Extract is presented in Appendix A.

1.3.1. CEO Contact Details

Name Nick Routson Phone 0417 148 656 Email [email protected]

mailto:[email protected]


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1.4. Track Record

A relevant Offence Declaration signed by the CEO of Camperdown Compost is presented in Appendix B.

The company was fined in 2018 for exceeding the licence limit of 24,000 tonnes of waste per year. The current proposal and application to increase volumes to reflect what is received will allow the Bookaar site to effectively process the high amount of feedstock demand as well with comply with the EPA licence.

The site has received minimal odour complaints in the nineteen years prior to 2019 with the exception of two complaints in 2014. Several complaints were received from local residents regarding odour between February and April 2019 which was caused by the company trialling a new method of windrow turnings involving a self-propelled turner.

The equipment that created the odour requires a relatively flat and solid surface in order to maintain its track and effectively turn the compost windrows. Due to the undulating nature of the site and saturation of the soils from the current method of liquid waste application to the windrows, the turner was regularly bogged and could not effectively turned the windrows. Camperdown Compost has subsequently returned to the current method of using an excavator, which has ensured more effective turning of the windrows (given current site conditions). The excavator is more effective in boggy conditions that are experienced across the existing surface. The upgraded concrete pad will improve the surface at the site and allow for application of more sophisticated turners to be used after the upgrades are completed

It is important to note that this odour event did not result during normal operating conditions.

1.5. Application Fee

EPA Publication 658 Works Approval Application states that the application fee is either

• 1% of estimated costs; or • 81.83 Fee Units

The estimated cost of works at The Camperdown Compost Company’s Bookaar site is AUD$2,500,000 hence the applicable fee is AUD$25,000.


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Legal and Policy Framework This works approval has been developed in accordance with best practice technology for composting and relevant legislation and guidelines, including:

2.1. Victorian Legislation

• Environment Protection Act 1970 • Planning and Environment Act 1987 • Climate Change Act 2017 • Environment Protection (Scheduled Premises) Regulation 2017 • State Environment Protection Policy (Air Quality Management) • State Environment Protection Policy (Ambient Air Quality) • State Environment Protection Policy (Prevention and Management of • Contamination of Land) • State Environment Protection Policy (Control of Noise from Commerce, Industry and Trade No.

N1) • State Environment Protection Policy (Waters)

2.2. Relevant Guidelines

• EPA Publication 824 (2002) The Protocol for Environmental Management: Greenhouse Gas Emissions and Energy Efficiency in Industry

• Australian Standard 4454: 2012 – Composts, Soil Conditioners and Mulches (AS 4454: 2012) • EPA Publication 1518 (2013) Recommended Separation Distances for Industrial Residual Air

Emissions. • EPA Publication 1517.1 (2017) Demonstrating Best Practice Guideline • EPA Publication 1588.1 (2017) Designing, Construction and Operating Composting Facilities • EPA Publication 1658 (2017) Works Approval Application guideline • EPA Publication 1677.2 (2018) Management and Storage of Combustible Recyclable and Waste

materials – Guideline

2.3. Principles of the EP Act

Camperdown Compost is committed to applying the following principles of the Environmental Protection Act 1970:

• s.1B The Principle of integration of economic, social and environmental considerations • s.1C The Precautionary principle • s.1D The Principle of Intergenerational equity • s.1E The Principle of conservation of biological diversity and ecological integrity • s.1F The Principle of improved valuation, pricing and incentive mechanisms • s.1G The Principle of shared responsibility • s.1H The Principle of product stewardship • s.1I The Principle of the wastes hierarchy • s.1J The Principle of integrated environmental management • s.1K The Principle of enforcement • s.1L The Principle of accountability


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Composting in the South West region 3.1. Barwon South West Waste Resource Recovery

Section 7 of the Barwon South West Waste Resource Recovery Implementation Plan identifies the need for new or upgraded infrastructure capacity for processing organic material due to:

• Current processing at or near capacity • Opportunity to increase recovery from kerbside, and • Increased volumes of Commercial and Industrial (C&I) waste streams particularly from

agricultural sectors.

The Camperdown Compost operation is strategically important for the management of compostable PIW in south west Victoria.

3.2. Other Composting Operations in the Region

The current capacity of large-scale composting in the region is outlined in Table 1.

Table 1 South West regional composting

Facility Location Capacity (t/yr)

Wastes accepted

Comment

Corangamite Regional Landfill Composting

Cobrico 10,000 Municipal green waste

Corangamite landfill is only licenced and equipped to take green waste and Food Organics/Garden Organics (FOGO).

Solid animal wastes Solid domestic food wastes

The Midfield Group (Pomala Pty Ltd)

Woolsthorpe 5,000 Hard green wastes

Site was established primarily to process paunch material from the Midfield Group's abattoir in Warrnambool.

Municipal green waste

14,000 Solid animal wastes

Statewide Recycling Services Pty Ltd

Panmure Closed Site has surrendered its EPA licence

The closure of the Statewide Recycling at Panmure has put considerable pressure on Camperdown Compost as previously these two sites either split loads of PIW or accepted waste on each other’s behalf (in times of high amount of waste production in the area). This allowed for each site to buffer the peaks in feed rates for PIW, thereby allowing more consistent composting to occur.

The closure has also increased the feed rate of PIW to the Bookaar site to the point where loads are now being rejected. As a consequence, waste producers are having to find alternative options for treatment of their PIW and in some cases waste from far south west Victoria is being transported to facilities as far away as Dandenong.


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The Camperdown Compost Site Camperdown Compost has been located at 445 Sandys Lane Bookaar since 2009 in an area of rural properties located approximately 7 km north west of Camperdown, Victoria and 170 km south-south west of the Melbourne CBD. Following the expansion, the site occupied by Camperdown Compost will be a 4.4 hectare parcel of land that extends 369 m along Sandys Lane and 120 m deep.

4.1. Choice of location

The surrounding land use is predominantly agriculture, used for cattle grazing and cropping. The topography of the site and surrounding areas is gently undulating. The site is ideal for composting as:

• The 4.4 hectare parcel is centrally located in a rural farming zone. The 4.4 hectare site is encapsulated in a 1000 hectare farm to the south. The northern side of Sandys Lane encompasses a 2,500 hectare property (Figure 1).

• The site is centrally located for accepting waste from a range of producers in south west Victoria, and

• It is proximal to transport corridors, primarily the Princes Highway

Figure 1 Location of Camperdown Compost in land parcel

4.2. Surrounding area and sensitive receptors

The proposed site is approximately 1200 m from the nearest residential property which is the house on the property at 445 Sandys Lane, Bookaar. EPA Publication 1518 Recommended Separation Distances for Industrial Residual Air Emissions recommends a buffer distance of 500 metres (m) for PIW treatment facilities and 2000 m for open windrow composting facilities.

The area surrounding Camperdown Compost is used for broad acre farming. A road reserve forms the northern site boundary. Beyond this, land to the north is used for broadacre farming. No dwellings are

Camperdown Compost Company 445 Sandys Lane Bookaar


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located due north of the subject site. Similarly, land to the west is also used for broadacre farming and dwellings are absent due west.

Adjoining land and land opposite the site to the east is used for broadacre farming. Six (6) dwellings are located within 2-3 kilometres of the subject site towards the east, south east and north east. To the west there are no houses within 5 kilometres.

Adjoining land to the south is used for broadacre farming and is contained on the same title as the subject site. As depicted in Figure 2, one (1) dwelling (R1) is located approximately 1.2 kilometres of the subject site, which is contained within the same land holding as the subject site.

Figure 2 and Figure 3 indicate the proximity to the site to nearby sensitive receptors.

Figure 2 Residents in proximity to Camperdown Compost


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Figure 3 Nearest sensitive environmental receptors

4.3. Topography

The surrounding region is characterised by gently undulating plains and low rolling hills. The site is predominantly flat, with a very slight slope (<1%) towards Blind Creek to the south west. The site does not lie within any water protection areas.

4.4. Site Geology

Review of the regional geology maps of Victoria (Seamless Geology Victoria, Geoscience Victoria 2014) indicates that the site is located within the Brighton Group, which is characterised by gravel, sand and silt: variably calcareous to ferruginous sandstones and coquinas; marine to non-marine.

The extensive flats and basaltic, undulating plains of the region formed over six million years through volcanic activity. The volcanic plans give rise to fertile reddish-brown to black loams and clays and red friable earths in the north of the region and medium to heavy textured clays in the south (near the site). A review of the Earth Eon groundwater bore logs (June 2015) indicate the site is dominated by clay and sandy clay textured soils.

Freshwater and saltwater lakes are featured throughout the landscape and wetlands, salt marshes and saline and freshwater or brackish ponds support diverse flora and fauna.

4.5. Climate Data

The site is located within the Barwon River-Lake Corangamite river region, within the South East Coast drainage division in Southern Victoria. Data from the Camperdown weather station #090181 (BOM Climate Data Online 2020) shows the mean annual rainfall is 755 mm (range = 576 mm to 997 mm); average annual pan evaporation is 1200 mm and average evapotranspiration is 400 mm. The highest rainfall is received in the during the winter months. Though the winter months April to October are identified as the period in which there is the greatest risk of flooding, the site is outside of the historic flood extent mapped for the area (Corangamite Flood Extent Map (CCMA Flood Portal).

4.6. Local Waterways

Lake Bookaar

Lake Colongulac Blind Creek


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The Site is located approximately 450 metres north east of Blind Creek, which is the closest surface water body. Blind Creek is a tributary of Mt Emu Creek which spans approximately 250 km in length. Mt Emu Creek is known to contain breeding populations of platypus, and is home to native fish species, as well as introduced recreational species such as Redfin. Other significant water storage includes Lake Bookaar, 4.5 km north east of the site, Lake Gnotuk, 4.5 km south east of the site, and Lake Colungolac, 5.5 km east of the site. Average streamflow for the Barwon River-Lake Corangamite river region is estimated at 0 – 100 ML/day (BOM Regional Water Information 2020).

4.7. Flooding

Bookaar is at approximately 100- 200 m above sea level. No flood data is available specifically for the site from the Corangamite Flood Portal; however, significant flooding events have been recorded by the Corangamite Shire Council for regions further north of the site; the most recent in January 2011. The Mt Emu Creek and the Curdies River are key waterways that are prone to flooding.


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LAND USE 5.1. Planning and Other Approvals

Camperdown Compost has an agreement that allows use of the site for the next 20 years. Camperdown Compost has submitted a planning permit application to Corangamite Shire Council for the upgrade of composting operations at 445 Sandys Lane, Bookaar. The application seeks approval to construct and carry out works associated with an upgrade of the site. The upgrade requires a permit under the Corangamite Planning Scheme in accordance with Clause 35.07 Farming Zone to construct and carry out works (Clause 35.07-4) and to expand the existing use of the site (Clause 35.07-1). Figure 4 depicts land leased by Camperdown Compost (yellow) within the larger freehold land parcel (blue dashed line).

Figure 4 Land use Farming Zone

The Camperdown Compost Company 445 Sandys Lane, Bookaar


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Existing Camperdown Compost Operation 6.1. Existing Operation

Camperdown Compost Company currently runs an open windrow composting process at 445 Sandys Lane accepting eight (8) different codes of PIW and two (2) types of organic waste. These are listed in Table 2.

In 2019, the site processed approximately 13,639 T/yr of green waste and 30,596 T/yr of PIW. In 2020, it is forecast that 15,986 tonnes of green waste and 28,175 tonnes of PIW will be processed. Green waste is received on site from local Councils and stockpiled. PIW is received from a variety of industries including dairy processing factories and commercial businesses.

Table 2 Wastes processed at Camperdown Compost

Waste Code Waste Description K100 Animal effluent and residues including abattoir wastes and other wastes

from animal processing K120 Grease interceptor trap effluent K200 Food and beverage processing wastes L100 Car and truck wash waters L150 Industrial wash waters from cleaning, rinsing or washing operations not

otherwise specified N150 Fly ash N190 Filter cake T130 Inert sludges or slurries Green Waste Hard Green wastes

Municipal Green wastes

The current operation involves acceptance and stockpiling of green waste at the site and the addition of liquid and sludge PIW, followed by the formation of windrows. The existing site layout is presented in Appendix C Drawing ECP-10

The process at Camperdown Compost manages the incorporation of liquids into the compost by the formation of chipped green waste bund dams for the soaking up of liquid wastes. Surplus liquid drains to a contact dam and the moist green waste mass is then formed into windrows. Further process waters are added to windrows through the process, ceasing prior to the completion of a final AS4454 compliant pasteurisation sequence to ensure product treatment. The compost is then further matured and dried for screening and sale to farm.

The first stage takes approximately eight weeks. The addition of liquid waste ceases 3 weeks prior to the completion of the pasteurisation sequence to ensure product quality. The compost is then further pasteurised and matured for 6 weeks then dried for screening and sale. Camperdown Compost’s customers are primarily local farms who apply the compost as a soil conditioner.


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Figure 5 Existing site footprint

6.2. Existing Product Quality

Camperdown Compost produces a pasteurised and matured compost material that is suitable for broad acre application. The compost produced by Camperdown Compost is suitable for its intended purpose and is deemed a mature compost. In accordance with AS4454-2012 and EPA Publication 1588.1, mature compost is an organic product that has undergone controlled aerobic and thermophilic biological transformation through the composting process to achieve pasteurisation and exhibits lower levels of phytotoxicity and a higher degree of biological stability.

As highlighted in AS4544-2012, any product supplied or described as ‘composted’ shall-

(a) Comply with Clause 3.2.1; and

(b) Have achieved a specified level of maturity in accordance with the requirements of AS4544-2012 Appendix N.

To maintain a consistent product that meets the quality requirements of customers, Camperdown Compost conducts regular testing of the compost product following maturation. Analysis in accordance with AS4454-2012 and EPA Publication 1588.1 is required to understand concentrations of total nutrients, trace metals, pesticides, chemical residues, plant propagules and pathogens. Table 3 presents the results of analysis of a number of batches collected at Camperdown Compost since 2017.

Analysis of Camperdown Compost product is conducted by SESL which is a NATA accredited laboratory. Since 2017, a few batches have concentrations of analytes that exceed AS4454-2012 criteria for mature compost. The exceedances indicate that there are batches that may not reach full maturity but are generally effectively pasteurised

Electrical conductivity (EC): slightly above the upper threshold indicating a higher salt content and can also be attributed to a higher level of nutrients.

Total organic carbon (TOC): batches have been marginally below the minimum requirement of 20% in AS4454-2012, ranging from 15.9 to 18.8% dry weight.

PIW Acceptance Compost Maturation

Screened Mature Compost (Finished Product)

Contact Water Basins

Blending and Primary Composting


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Nitrogen drawdown index (NDI): a few batches have been below the minimum requirement, which likely indicates immaturity.

Phosphorus: above the AS4454-2012 criteria of <0.1 % dry weigh, indicating compost is unsuitable for phosphorous sensitive plants.

Wettability: likely affected by the low moisture content. Wettability can be managed by increasing the moisture content of the compost.

Sodium: High sodium levels are likely contributing to the elevated electrical conductivity.

Metals: Zinc, and to a lesser extent cadmium and arsenic, have been measured above criteria assumed to be associated with potential contaminants within the feedstock received, ie. FOGO, drilling mud.

AS4454-2012 Section 3.1.2 states the Standard does not attempt to classify products by suitability for any specific end use or application. The producer may adopt industry specific end use guidelines or develop internal guidelines to ensure their products are fit for purpose. Camperdown Compost create a balanced compost that meets key parameters for oxygen, temperature, carbon/nitrogen ratio and pH levels. Results presented for batches analysed since 2017 indicate that the end product is generally complaint with EPA Publication 1588.1 Section 1.1.21 Table 8 Pathogen and plant propagules reduction performance standards, Section 8.1 Table 9 Chemical contaminants limits for unrestricted use and Table 10 Physical contamination limits.

Elevated concentrations particularly of zinc, cadmium, electrical conductivity and phosphorous is a function of the variability in feedstocks received by Camperdown Compost. Feedstocks varying in both content and volume create difficulties in effectively managing input waste streams through composting stages and can impact the final compost produced. Elevated zinc has been routinely measured in batches since 2017. Zinc deficiency is the most widespread micronutrient deficiency problem1. Elevated zinc in compost can reverse zinc deficiency in soils.

The compost produced by Camperdown Compost has a low C:N ratio and sometimes higher nitrogen and phosphorous levels than those specified in AS 4544-2012. AS4454-2012 does allow for higher levels of nutrients to be present in a product “if a product claims to contribute to plant nutrition” or is not “for products that claim to be for phosphorus- sensitive plants”. Camperdown Compost does not claim its compost is beneficial for phosphorous-sensitive plants.

TOC is marginally lower than the AS4454-2012 recommended concentration, most likely as oxygen is insufficiently distributed through to the windrows during processing. Carbon can be lost as CO2 during anaerobic conditions. Similarly, with NDI the current compost is relatively immature as it is difficult to provide sufficient oxygen during the composting process to fully mature the material. At times, NDI fails if the material does not drain in the specified time.

The upgrades should correct the irregularities measured in compost batches, particularly TOC, moisture and NDI. The upgrades proposed at the site will allow for better control of the composting on site and improve management of the stages required to achieve a mature compost.

1 Hafeez B, Khanif YM, Saleem M (2013) Role of Zince in Plant Nutrition – A Review American Journal of Experimental Agriculture 3(2): 374-391


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Table 3 Product results against AS4454


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6.3. Reference Site for Upgrade

Camperdown Compost has been aware that the existing configuration of the site is inefficient at processing the waste streams it receives. Over the past 36 months the company has embarked on a rigorous global search to uncover a proven technology that can be applied at the Bookaar location. A number of site configurations and waste processing and treatment methods have been considered that have been applied at a number of locations worldwide. Further details on the options assessed are provided in section 18.1.1.

Camperdown Compost has chosen its upgrades based on the effectiveness of a composting operation in Weiselberg, Austria, known as Seiringer Umweltservice GmbH. This site is the reference site on which Camperdown Compost’s chosen processes can be directly compared with.

The Seiringer Umweltservice GmbH composting facility is located approximately 750 metres from the nearest residential building (Figure 6). It is within 2 km of the regional towns Weiselberg and Weinzierl which have a combined population of 5,000 residents. The facility is also located within 3 kilometres of two train lines and an Autobahn, including the main train line from Vienna to Munich.

The Weiselberg reference site has been using an aerated floor technology effectively and successfully to compost similar feedstocks to those received at the Bookaar site. The reference site has been operating for 20 years using the same technology proposed at Bookaar (i.e. open windrows with an aerated floor). The reference site processes materials that have a similar risk profile to Camperdown Compost. An aerial photograph of the reference site, including the aerated floor is presented in Figure 7.

The reference site yields 12,979 tonne of product from a total input of 29,454 tonne giving it a mass balance ratio of 44% product. The operation requires approximately 4700 tonne of make-up water per year on top of the waste received. The reference site treats a significant proportion (62%) of Animal By-Products Regulations (ABPR) wastes which are similar to FOGO. These wastes have a higher potential for offsite odour since in the production of green waste in the mixture is considerably reduced during the colder months. The inputs streams are presented in Table 4.

Table 4 Waste processing at the Weiselberg Site

Type of Waste Austrian Waste Code

Tonnes/Year

Inputs Woody material from Trees and Shrubs SN92105 4,840 Green Organics SN 92102 2,680 Animal By-Products Regulations (ABPR) Material SN 92401 15,542 Other Non-hazardous Waste Various 1,692 Total Solid Waste 24,754 Make Up Water 4,700 Total Input Material 29,454 Outputs Oversize Screenings (Sent offsite for Biomass Fuel) 1,006 Commercial Grade Compost 12,979 General Waste Removed 223 Total Outputs 14,208


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Figure 6 Locality map of the Weiselberg composting site

Figure 7 Aerial view of the site showing aerated floor


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Seiringer Umweltservice GmbH operates under the rigorous European Union and Austrian environmental regulations and guidelines primarily:

• State of the Art of Composting 2009 • ÖNORM S2205 Technical Requirements for Composting Plants • ÖWAV working aid 58 Recycling Untreated Waste Wood for the Establishment of

Biomass Processing, and • ÖWAV working aid 44 Production of Compost Soil

The aeration floor has been proven a successful and low risk process that the upgrade to Camperdown Compost has been modelled on.

6.3.1. Comparison between Reference Site and Camperdown Compost

The Camperdown Compost upgrade will adequately allow for the receipt of a combined volume of 42,000 tonnes/year of solid waste and sludge waste, and 8,000 tonnes/year of liquid PIW to equate to a total waste input of 50,000 tonnes/year. Table 5 presents a comparison between volumes received at the reference site and Camperdown Compost.

The Bookaar site will be a scaled-up version of the Weiselberg operation with a number of longer windrows. Given the modular nature of both open windrows and aerated floor composting, Camperdown Compost can be directly scaled up to a larger throughput by maintaining a similar ratio of solids to liquids at the reference site. This will ensure the biological drying process functions effectively and is aligned with the Seiringer Umweltservice GmbH composting facility in Weisleberg, Austria.

Table 5 Comparison of inputs between Camperdown Compost and reference site

Total Inputs Tonnes Dry matter [t] Water content [t]

Reference Site Wieselburg Solid Waste/Sludge 10,654 14,100 Total Tonnes 24,754

Camperdown Solid Waste/Sludge 17,424 24,576

Total Tonnes 42,000 Proportion of totals Reference Site Weiselberg Solid Waste/Sludge 43.04% 56.96% Camperdown Solid Waste/Sludge 41.49% 58.51%


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Proposed Process and Technology Upgrade 7.1. Current Site Deficiencies

Camperdown Compost has been operating at capacity for several years. Camperdown Compost’s existing site arrangement has struggled to cope with increasing volumes of feedstocks generated in south west Victoria, as well as more frequent peak volumes received on site. The closure of several composting operations such as Statewide Recycling’s Panmure facility coupled with an increase in waste produced in the region has put pressure on the site’s ability to adequately treat the waste, particularly PIW.

The current process cannot efficiently treat the liquid PIW which results in a large amount of unprocessed liquid entering the contact water basin, creating anaerobic conditions and odour. Pooling of water in and around the windrows leads to excess mud generated during large machinery use, which compromises the hardstand and increases risk of groundwater contamination.

7.2. The Proposed Upgrade

The proposed upgrade of the facility will enable Camperdown Compost greater control over the composting process. This upgrade seeks to improve the standard of the facility so it can effectively process wastes into a beneficial product, reduce risk to the environment and improve amenity of the local area.

The following upgrades are proposed for the site:

• Construct an impermeable hardstand with a minimum permeability of 1 x 10-9 m/s • Concrete aeration floor approximately 100 metres by 65 metres containing perforated underfloor

aeration tubes • Separated maturation area • Self-propelled windrow turner with spray nozzles to apply process water to the windrows • Contact water basin with a 7.3 megalitre capacity to collect run-off with open drains. • Designated acceptance and sorting area • 187,000 litre acceptance pit for PIW • Solids separation unit • 240,000 litre bunker for temporary storage of liquid PIW • A separate drainage point and storage tank with a combined volume of 312,200 litres to capture

runoff from the maturation area.

The proposed site plans and drawings are presented in Appendix C. The proposed site layout following upgrade is presented in Appendix C Drawing No. GP-01.

Aerated open windrows are the preferred option for managing the variability of feedstock in terms of the heterogeneity of the material and variability of volumes received at the site. Following the upgrade, the composting and pasteurisation of the waste will occur on an aerated concrete floor which will:

• Accelerate the composting process via the increase in air flow through the compost windrows • Ensure even temperature and moisture profile across windrows, significantly reducing the

formation of hot spots or excessive moisture clusters • Ensure effective and even incorporation of liquid PIW into the compost windrows • Significantly reduce the amount of liquid PIW stored onsite,

7.2.1. Site upgrades already commenced


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Camperdown Compost has already begun an upgrade of the existing hard stand underneath the windrows to install 500 mm of compacted clay with a minimum permeability of 1 x 10-9 m/s. The clay is covered with a layer of geotextile and then 420mm of compacted gravel.

An area of 8000 m2 (approximately 40% of the working area of the site) has already been recontoured with clay and crushed rock to enable processing through the 2020 winter.

The installation of three (3) groundwater bores also occurred in February 2020 to enable a better understanding of the groundwater beneath the site.

The earthworks schedule is presented in Appendix C Drawing No. EWS-01. The construction sequence is presented in Appendix C Drawing No. SEQ-01

7.3. Hours of Operation

The normal hours of operation will be 7.30am – 4.30pm Monday-Friday, and 8.00am -12.00pm Saturday. The site will accept waste after hours only if there is an immediate need (e.g. a process upset at one of the waste producers) via the process outlined in standard operating procedures.

7.4. Traffic Management

As part of the Planning Permit Application ESR Transport Planning Pty Ltd was engaged to compile a Transport Impact Assessment for the proposal. The impact assessment concluded the following:

1. The proposed facility expansion is not expected to increase the amount of trucks entering the site following the upgrade. Truck movements will continue to vary day to day with market forces.

2. Additional traffic due to the proposed expansion can be absorbed by the local road network without significant impact to efficient traffic flow.

3. Ample car parking provisions will be provided on-site. 4. The site layout provides ample area for large articulated vehicles to manoeuvre.

7.5. Source of Raw Materials

Camperdown Compost will continue to receive waste from its existing supplier network of local dairy processing facilities including Bega (Koroit), Fonterra (Cobden) and Saputo (Allansford) as well as green waste and potentially FOGO from nearby Councils such as Warrnambool City Council, Colac Otway Shire and City of Greater Geelong.

The typical type of feedstocks expected from each of the main waste producers is presented below in Table 6.

Table 6 Typical Feedstocks

Waste Producer Typical Feedstock Bega DAF Sludge/ Milk, Whey, Wash Waters Fonterra Saputo Warrnambool City Council Green Waste/FOGO Colac Otway Shire City of Greater Geelong Various Paunch, food processing waste


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7.6. Existing and Proposed Input Streams and Rates

The following tables provide information on the historic input streams and rates (Table 7) and the proposed volumes once the upgrades have been completed (Table 8).

Table 7 Historic input streams and rates (2015 to 2019)

Waste Code

Description Tonnes 2015 2016 2017 2018 2019

K100 Animal effluent and residues including abattoir wastes and other wastes from animal processing

954 2,080 3,970 8,680 7,128

K120 Grease interceptor trap effluent

3,007 4,928 7,422 3,239 3,159

K200 Food and beverage processing wastes

2,630 6,429 4,345 4,568 15,181

L100 Car and truck wash waters 1,528 0 0 939 615 L150 Industrial wash waters from

cleaning, rinsing or washing operations not otherwise specified

332 2,209 3,792 1,386 2,321

N150 Fly ash 0 0 0 0 0 N190 Filter cake 0 0 0 0 0 T130 Inert sludges or slurries 7,070 6,625 163 2,483 2,552 Total PIW 15,521 22,271 19,692 21,295 30,956 Organic Waste 7,985 7,229 12,692 9,017 13,639 Total Waste Input 23,506 29,500 32,384 30,312 44,595


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Table 8 Proposed Input Streams and Rates

Waste Code Description Material Input

mass (t)

Dry matter (%)

Density (t/m³)

Volume (m³)

Ratio (m/m%)

Dry matter (t)

Water content (t)

SOLIDS

Organic Waste

Green Organics 20,840 0.50 0.42 49,619 49.6% 10,420 10,420

Food Organics / Green Organics (FOGO) 3,000 0.45 0.47 6,383 7.1% 1,350 1,650

T130 Inert sludges or slurries Drill Cuttings 3,000 0.40 1.60 1,875 7.1% 1,200 1,800

Sum for Solids 26,840 0.48 0.46 57,877 63.9% 12,970 13,870

SLUDGES

K100 Animal effluent and residues including abattoir wastes and other wastes from animal processing

Dried Blood 3,600 0.28 0.95 3,789 8.6% 1,008 2,592

Paunch 4,000 0.26 0.95 4,211 9.5% 1,040 2,960

K200 Food and beverage processing wastes DAF Sludge (Dairy) 2,400 0.15 0.95 2,526 5.7% 360 2,040

AD Sludge (dairy) 3,000 0.25 0.95 3,158 7.1% 750 2,250

Sum for Sludges 13,000 24.3% 0.95 13,684 31.0% 3,158 9,842

Pore filling reduction factor for Sludges for volumes 90% 1,368

Recirculated screen oversize

2,160 0.60 0.42 5,143 5.1% 1,296 864

Mixture for first windrow

42,000 41% 0.65 64,388 100.00% 17,424 24,576

LIQUIDS FOR IRRIGATION

K200 Food and beverage processing wastes Milk, Whey, Wash Waters 8,000 0.10 1.00 8,000 800 7,200

L100 Car and truck wash waters


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Waste Code Description Material Input

mass (t)

Dry matter (%)

Density (t/m³)

Volume (m³)

Ratio (m/m%)

Dry matter (t)

Water content (t)

L150 Industrial wash waters from cleaning, rinsing or washing operations NOS

Solid/Sludge/Mature Compost Mixture for first windrow 42,000 0.41 0.65 64,388 100% 17,208 24,792

TOTALS

Organic Waste 23,840 11,770 12,070

Organic Waste (Oversize) 2,160 1,296 864

Total PIW (Solid/Sludge) 16,000 4,358 11,642

Total PIW (liquid) 8,000 800 7,200

Total Waste Input 50,000 18,224 31,776


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7.7. Mass Balance and Process Flow

The composting process has three distinct phases, biological drying, pasteurisation and maturation. These are described in detail in Table 9. The mass balance shows a total mass loss of 57% through evaporation and degradation. Degradation of dry matter (to CO2) correlates with the input and output figures shown at the Seiringer Umweltservice GmbH composting operation in Weiselberg 56% (based on 2019 report to the Austrian Government).

A mass balance has been completed for Camperdown Compost to understand the outputs of the proposed process as well as to establish the parameters for process efficiency during operation (Table 10).

Table 9 Process flow and mass balance of 50,000 tonnes

PHASE 1 - BIOLOGICAL DRYING The biological drying stage is a four-week intensive phase of composting with aeration and regular turning twice a week. In this stage the windrows are irrigated with liquid PIW, contact water and make-up water (rainwater or mains water).

In this stage the light, high energy material becomes the fuel in the composting process where approximately 20% of dry matter (DM) will degrade and evaporate 67% of the total water throughout the process.

The resultant compost from biological drying has a maximum moisture content of approximately 56%.

Input Biological Drying Dry Matter 17,424 t/a Moisture Content 24,576 t/a Irrigated PIW 8,000 t/a Total 50,000 t/a Output Biological Drying Dry Matter Degraded 3,485 t/a Evaporation Loss 20,909 t/a Dry matter 13,939 t/a Moisture Content 17,741 t/a Total 31,680 t/a Mass loss phase 1 25%

PHASE 2 - PASTEURISATION

Material is composted over fifteen days and turned every three days. A minimum temperature of 55°C is maintained. Irrigation water is supplied by maturation area runoff or make-up water.

Water is only added if moisture content reduces below 40% which will depend on moisture content of input material and rate of environmental evaporation.

The resulting pasteurised compost has a maximum moisture content of approximately 54%.

Output Pasteurisation Dry Matter Degraded 836 t/a Evaporation Loss 5,018 t/a Dry matter 13,103 t/a Moisture Content 15,382 t/a Total 28,484 t/a Mass loss phase 2 10%

PHASE 3 - MATURATION The maturation stage which is a six week process to ensure that the quality of the compost is optimised. As with pasteurisation, irrigation is only conducted with maturation area runoff or make-up water. Turning is also reduced to a minimum of weekly.

The resulting compost from pasteurisation, has a maximum moisture content of approximately 45% to enable screenable material for the finished product.

Output Maturation Dry Matter Degraded 917 t/a Evaporation Loss 5,503 t/a Dry matter 12,186 t/a Moisture Content 9,970 t/a Total 22,156 t/a Mass loss phase 3 22%


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Table 10 Mass balance calculations for 50,000 tonnes

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7.7.1. Design Contingency Scenarios

Two additional mass balance scenarios were assessed to gauge the redundancy in the system with the current proposed input rate of 50,000 tonnes/year. This was contingent on adequate processing of liquid PIW and contact water to ensure only minimal contact water stayed in the contact water dam under normal operations and weather conditions.

The two scenarios where based on the site having an input rate of:

• 59,000 tonnes/year; and • 70,000 tonnes/year.

These scenarios were chosen as they are valuable in explaining that more material can be processed in a given time whilst still maintaining the key parameters of not exceeding a starting density of 650kg/m3 or a starting moisture content of 60%..

The results of the comparisons (Table 11) indicated the upgrade can manage 59,000 tonnes/year (15% more than is currently proposed) without changing the ratio of irrigated liquid PIW irrigated to the total amount of waste accepted for processing.

Table 11 Comparison of water demand under each scenario.

Proposed Input 50,000 Tonne/Yr

Contingency Input 59,000

Tonne/Yr

Contingency Input 70,000 Tonne/Yr

Dry matter (t/a) 41% 17,424 41% 20,900 41% 26,140 Moisture content (t/a) 59% 24,576 59% 29,500 59% 36,860 Irrigated PIW (t/a) 8,000 8,600 7,000 Total (t/a) 50,000 59,000 70,000 Ratio of irrigated PIW to total waste

16% 15% 10%

Water Demand Contact water from Rainfall (m³/y)

5694 5694 5694

Maximum amount for re-irrigation (m³/y)

5,590 5,627 5,940

Contact water to dam (m³/y)

103 67 -246

Collected clean surface water

2435 2435 2435

Reirrigated clean surface water:

2751 1661 2463

Maturation runoff Water to dam

-316 774 -29


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7.8. Stages of Composting

Following the upgrades, the proposed process for composting at Camperdown Compost will consist of five (5) stages:

7.8.1. Stage 1 - Feedstock Receipt (Pre-Compost Processing)

Green Waste/ Food Organics Garden Organics Upon receipt, GO and FOGO will be fed through a CRAMBO slow speed shredder. This will break down large wood and food items, ensuring all parts of the incoming material can compost effectively.

Prescribed Industrial Waste Solid feedstocks imported to site are placed on the receival pad. Liquid PIW are discharged directly to the liquid receival pit. The liquids are screened to enable them to be irrigated via the self propelled turner. The solid component recovered is added to green waste and rowed out.

7.8.2. Stage 2 - Blending of feedstock with mature compost

The green waste, FOGO feedstocks and solid PIW are blended with mature compost (mostly oversize material).

7.8.3. Stage 3 - Composting (Biological Drying)

Duration: Four Weeks The mixed feedstocks are processed on a concrete aerated floor. This enhances the biological degradation and dewaters the liquid PIW by using the energy of the compost windrows to evaporate the clean water to atmosphere.

Windrows are formed on the aerated floor and then undergo primary composting (incorporating biological drying of the liquid PIW). Windrows are turned weekly to maintain an even temperature and moisture profile. At any time, there will be eight (8) windrows on the aerated floor dedicated to biological drying and being irrigated with liquid PIW.

7.8.4. Stage 4 - Composting (Pasteurisation)

Duration: Two Weeks (Fifteen days) Maturation area runoff and freshwater (if necessary) will be applied to the remaining four (4) windrows on the aeration pad to enable effective pasteurisation to occur. The windrows will be turned every three days and kept at a minimum temperature of 55oC to ensure compliance with requirement 3.2.1 of AS4454.

7.8.5. Stage 5 - Composting (Maturation)

Duration: Six Weeks Windrows are formed on the maturation pad and then matured over a period of six (6) weeks, being turned weekly to enable the finished product to meet the requirements for mature compost outlined in Table 3.1(A) of AS4454.

During this stage, the compost is also dried to ensure optimum moisture level in the finished product. Turning will be determined primarily by moisture monitoring as well as periodic oxygen, carbon dioxide and methane monitoring.

7.8.6. Stage 6 - Screening

The compost is transferred to a single pile at the Eastern end of the site and screened to create finished project with a particle size less than fifteen (15) millimetres.

The finished compost is despatched to clients and the oversize compost is transferred back to the receival pad to provide a portion of the green waste component in the blending stage. The finished


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oversize compost has the advantage in that it can readily absorb liquid enabling a quick activation of the compost process.

The process flow table depicting the stages at Camperdown Compost is presented in Table 12. The configuration of the site considering each stage is presented in Appendix C Drawing No. PLAN-001 to PLAN-05.

Table 12 Stages of Composting


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7.9. The Mechanical Process

7.9.1. Biological Drying

The proposed upgrade to Camperdown Compost will enhance biological drying of the PIW in the primary composting stage. Biological drying is the process by which a biodegradable waste is rapidly heated during composting to remove moisture during the aerobic decomposition of the organic material. Biological drying enhances evaporation of surface water as well as water within the PIW sludge.

In this process, the drying rates are increased by biological heat from the composting process and forced aeration. This heat generation assists in reducing the moisture content of the compost without the need for mechanical heating.

Biological drying enhances what is known as the “Chimney Effect” in compost windrows, whereby air evenly enters the windrows near the base and exits out the top edge as displayed in . The addition of this oxygen to the base of the windrow stimulates a chimney effect, which draws oxygen into the outside base of the windrows. The amount drawn in at the base of the windrows exceeds the volume supplied by the air fans which is the standard application for in-vessel composting.

Oxygen is added to the base of the window in pulses of approximately six (6) minutes with a seven (7) minute pause between them. This process of stimulating a natural process is the most energy efficient way of adding oxygen to the windrows.

Optimum Windrow Size The reference site, Compost-Systems GmbH, has researched various sized windrows and has confirmed it becomes difficult to maintain an efficient chimney effect when the windrows are greater than five (5) metres wide x 2.2 metres high. The biological drying floor will be 100 x 65 metres and hold 12 windrows through a 6 week process. Windrows will extend the 100 m in length. This sized windrow is deemed optimum for the Camperdown Compost upgrade.

7.9.2. Aerated Concrete Floor

The primary composting (biological drying) stage of the operation will be conducted on a concrete pad with twelve (12) built in concrete tubes running along the length of them. Each tube will run the full length of the pad and contain perforations at regular intervals to enable air to pass up through the windrows. The air is pumped from a central pumping station, consisting of twelve (12) fans with each aeration tube having a dedicated air-line.

The proposed concrete aerated floor will provide the capacity to ensure a constant supply of air and oxygen to the windrows, ensuring the aeration of the microbiology living in the windrow. This will reduce the risk of odorous anaerobic pockets forming inside the windrows and ensure more even temperature spreads throughout the windrows. The aeration when combined with regular turning, ensures an even distribution of air and moisture minimising the likelihood of dead (i.e. anaerobic), dry or wet areas forming within the windrow.

The runtime and frequency of the fans is determined by the temperature measurements taken in the windrows at three different levels. Generally, the fans are required more in the first two weeks of the windrow processing, when oxygen demand is at its highest. Figure 9display the proposed aeration system.


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Conventional Windrow

With well managed conventional windrows the chimney effect occurs however the air flow is not uniform which can lead to areas of either excess heat or moisture. Both can be detrimental to the composting process.

Forced Aeration Windrow

Pulsed aeration stimulates a greater draw in of air providing a greater rate of oxygenation throughout the windrow leading to even distribution of heat and moisture.

Figure 8 The Chimney Effect

Potential area for excess heat moisture or anaerobic conditions

Aeration Tube


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Figure 9 Aerated floor installed by Compost Systems, Austria

Figure 10 Diagram Illustrating aeration under windrows

Perforations run the length of the tube


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7.9.3. Self-Powered Windrow Turner

The windrows will be turned via a Komptech “Topturn X55” self-propelled windrow turner which drives through the windrow at a slow rate (Figure 11) and has a maximum clearance of 2.2 metres vertically and 5 metres horizontally. The major role of the turner is to homogenise the windrows, ensuring consistent temperature and moisture throughout the mass of the windrow, rather than add oxygen.

Use of a self-propelled windrow turner affords considerable advantage over use of excavators (currently in use at the site). The windrow turner can effectively turn the windrows more evenly whilst keeping them in optimum formation. Self-propelled windrow turners have been effectively utilised in composting operations around the world for over twenty years. The advantages of a self-propelled windrow turner over the current method of excavators are presented in Table 13.

Table 13 Advantages of self-propelled windrow turners over excavators or front-end loaders

Advantage Impact on process Increased windrow turning capacity

The rate of windrow turning is increased from 180 m3/hr (average for front end loader) to 4000 m3/hr. As a result, windrows only require approximately 10% of the mechanical turning compared to front end loaders.

Reduced fuel consumption

Less movement and less equipment will result in a substantial reduction in diesel for the site and in turn reduce greenhouse gas production.

More effective aeration

A consistent and more complete level of oxygen/carbon dioxide exchange is achieved which will stimulate greater microbial activity in the windrow and reduce the formation of methane.

More effective blending

The increased level blending maximises the carbon to nitrogen (C:N) interaction necessary for the decomposition of material.

Even temperature distribution

Reduces hot spots which can kill microorganisms as well as increase the risk of fire; and Reduces cold spots which slow the composting process.

Even distribution of liquid waste/water

By applying the liquid waste/water during the turning stage, an even distribution of water within the windrow is achieved which allows for maximum microbial action and biological evaporation.


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Figure 11 Self-Propelled Windrow Turner trialled at Camperdown Compost

7.9.4. Water Application

The water dispensing system is mounted on the windrow turner to allow for continuous application of liquid waste/water to the windrows. This will ensure an even distribution of water. A 75-millimetre application hose is mounted on the rear of the windrow turner and dispenses liquid waste/water onto a plough disc which disperses the water into the windrow as it is being turned. The compost turner has a remote on/off switch in the cabin, enabling the operator to start and stop the pump as required.

The application hose is fed via a 100-millimetre irrigation hose on an irrigation reel which can extend with the movement of the turner and retract via use of an impeller that works off the water flow within the hose.

The maximum application rate for the water is 25 litres per second, which means that up to 60,000 litres can be applied to a single windrow in the forty minutes it takes to complete turning. This rate can be reduced by either moving faster or reducing pump pressure. The windrow must not be allowed to be watered beyond a moisture content of 60%. This can be calculated by measuring the moisture content before application, and documenting the maximum water allowed to be added.

The application of 60,000 litres per windrow to eight windrows weekly would give a theoretical irrigation capacity of 24,960 tonnes of liquid per year. Water added will comprise around 13,500 tonnes of liquid, comprising 8,000 tonnes of liquid PIW and 5,500 tonnes of contact water.

It is critical to note that liquid will only be added to the point that is needed to assist the composting process. This is dictated by the moisture content within the rows before irrigation.

The process of applying water will be:

PIW Irrigation to Pre-Pasteurisation Area • The irrigation hose is hooked up to the irrigator spray and the turner commences turning the

windrow.


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• Once the turner is approximately five metres into the windrow the pump is switched on and the irrigation of liquid PIW begins.

• When the turner reaches approximately five metres before the end of the windrow, the pump is switched off to stop overspray.

Fresh/Maturation Runoff Irrigation The irrigation line must be completely flushed prior to commencing irrigation of the pasteurisation and maturation area.

• The windrow turner is stopped approximately ten metres before the end of the last windrow being irrigated with PIW.

• A valve is then turned so that fresh water or maturation runoff is drawn from either the mains or the maturation runoff tank.

• The windrow turner is then started again and irrigates the remainder of the PIW windrow with the flushing water.

• The turner can then reposition on either the pasteurisation or maturation areas and commerce irrigating with the appropriate grade of water.

The effectiveness of this process can be verified in the commissioning plan by sampling and analysis of the matured compost for E.coli and Salmonella.

Figure 12 A typical irrigation hose reel with impeller

7.9.5. Process water

Process water will be separated into:

• Contact water from the biological during and pasteurisation area will be directed to a contact water basin which will be aerated to reduce odour; and

• Leachate from the maturation area that will be directed to a sump and stored in a tanka smaller liquid PIW storage bunker

The concrete base laid for the pasteurisation area will capture and drain contact water to the co. This will drain to sealed contact water dams which will hold reserve water for ongoing application to windrows.

The drainage will be split to avoid the current cross contamination of liquid PIW and leachate in the leachate basin under normal operating conditions The runoff from the maturation area will be

Marani Hard Hose


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pumped to a tank and irrigated across the maturation and pasteurisation areas, with an overflow mechanism for high rainfall events.

The drainage and plumbing configuration proposed for the site are presented in Appendix C Drawing No. MEP-01 and MEP-02

7.9.6. Process Control/Monitoring

To ensure that the composting process can run smoothly and offsite impact is reduced, the controls and monitoring outlined in Table 14 will be implemented.

Table 14 Proposed controls and monitoring

Process Stage Controls/Monitoring General All equipment will be operated within the “Safe Operating Limits” (e.g.

travel speed, rate of water addition). Prestart All equipment will be subjected to prestart checks to ensure that the items

are fit for use. Any issues will be communicated to management and/or remedied were possible.

Stage 1 - Feedstock Receipt

All trucks must report to the weighbridge/waste and present either: • For PIW - A valid EPA Waste Transport Certificate; or • For green waste/FOGO – A consignment note or run sheet.

Any waste that is found to be non-conforming with the EPA licence (e.g. green waste containing general waste) is immediately quarantined and removed from site with seven (7) days or 24 Hours for potentially odourous waste. Solids will be removed from the solid separation screen once per day and blended into green waste and all PIW liquid will be drained from the pit and irrigated over the windrows prior to the end of each shift (6pm).

Stage 2 - Blending of solid feedstock with mature compost

The Carbon:Nitrogen (C:N) ratio is maintained between 20:1 and 40:1 in the primary composting stage by ensuring the blending limits are carefully managed.

Stage 3 - Composting (Biological Drying)

The windrow areas will be subject to a turning timetable to ensure that it is continuous. Windrows are maintained at a height of 2.2 metres and width of five (5) metres. Windrows are constantly monitored (Refer to Section 6.3.4.1) Speed of the turner is limited to 4 km/hr and application of liquid PIW is limited to 25 L/s (Stage 3-4 only). Routine monitoring of process parameters (See Below

Stage 4 - Composting (Pasteurisation) Stage 5 - Composting (Maturation)

Stage 6 - Screening All material is screened prior to despatch with oversize being placed in the oversize pile for feeding back into blending process.

Specific Process Monitoring The temperature and moisture will be monitored continuously via the SCADA monitoring system and the levels maintained inside the optimum operating parameters listed in Table 15.

Table 15 Optimal operating parameters

Parameter Measured Requirements

Monitoring Frequency

Operator Response

Temperature >55°c Continuous If > 75°c Turn Oxygen >10% Daily If < 10% Aerate or Turn Carbon Dioxide <8% If > 8% Aerate or Turn Methane <1% If > 1% Aerate or Turn


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7.9.7. Maintenance

Camperdown Compost has an existing preventative maintenance schedule for all equipment and the additional equipment will be incorporated into this schedule based on the manufacturer’s maintenance recommendations. This will include:

• Daily checks and routine planned servicing of mobile plant • Daily checks and routine planned servicing of pumps • Daily checks and routine planned servicing of fans and electrical components, and • Five yearly visual inspection of the aeration tubes by a suitably qualified civil/structural

engineer.

7.9.8. Wastes Produced

The proposal will not directly produce any waste products under normal operating conditions as all feedstocks accepted will be incorporated into the compost.

Waste products from the composting activities will only be produced in the following scenarios:

• Green waste or FOGO is found to be contaminated with general waste • A waste is found to be a non-conforming waste under the EPA licence and is removed from

site after being segregated from process feedstocks (in the receival area), or • Waste is required to be removed due to weather conditions or the need to reduce potentially

odorous feedstocks.

A Waste Management Procedure will be developed prior to commissioning the site upgrades.

7.10. Compost Quality Assurance

To maintain a consistent product that meets the quality requirements of customers, Camperdown Compost currently conducts regular testing of the product following maturation. The recent results are presented in Section 6.2

Following the upgrades, a monitoring program will be implemented to align the compost produced by Camperdown Compost in line with Australian Standard AS4454-2012.

Specific product quality that will are considered essential for compost from Camperdown Compost are presented in Table 16.

Table 16 Product Quality Testing Regime

Pasteurisation - temperature maintained at 55°C or higher for 15 days, windrow turned a minimum of five times.

Wettability Minutes

pH Pathogen indicators

Total CaCO3 equivalent % Particle size

dry matter Chemical contaminants (includes heavy metals),

Electrical conductivity Characteristic and unit of measurement

Sodium Moisture content %

Phosphorus, soluble mg/L in solution Physical contaminants (Glass, metal, plastics)

Phosphorus, total % dry mass Phosphorous

Ammonium-N mg/L in solution Nitrates

Nitrogen, Total Self-Heating


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Organic carbon Plant Growth

Carbon: Nitrogen Ratio (C:N)

7.11. The Market

The main market for the compost will continue to be agricultural farms in the southwest region. This customer base will consume up to 90% of the total product sold.


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Air Assessment 8.1. Relevant Legislation

Two State Environment Protection Policies (SEPP) are relevant to air emissions in the context of the GDC, and they include:

• State Environment Protection Policy (Air Quality Management) No. S240 (SEPP AQM) • State Environment Protection Policy (Ambient Air Quality) No. S19 (SEPP AAQ)

SEPP AQM provides a framework for the management of emissions to the air environment so that the beneficial uses of the air environment are protected, Victoria’s air quality goals and objectives are met and continuous improvement in air quality is achieved. It also requires generators of emissions to model their transport and dispersion, to demonstrate that predicted emissions meet relevant design criteria and that odours do not adversely affect local amenity.

SEPP AAQ sets Victoria’s air quality objectives and goals, based on the requirements of the National Environment Protection Council (Ambient Air Quality) Measure (NEPM). It also Identifies beneficial uses to be protected for the policy and environmental indicators and quality objectives to ensure beneficial uses are protected.

8.2. Air quality assessment

An air quality assessment was undertaken by GHD Pty Ltd (GHD) for the proposed expansion and upgrade of Camperdown Compost and the report is presented in Appendix D. The purpose of this assessment was to understand the current odour generated from the site based on the existing operations that occur at the site, otherwise referred to as baseline. Consideration of the local meteorology, site footprint and activities, sensitive receiver locations and associated EPA buffer requirements were included. The report also considers the potential air emission impacts from the proposed upgrade to Camperdown Compost and opportunities for improved air quality.

8.2.1. Existing air emission sources

Odour and dust are generated from the site during existing site activities and emissions have the potential to impact offsite sensitive uses. The main contributors of odour from the existing operation are the offloading of fresh solid and liquid wastes received, the compost windrows during early pasteurisation and the contact water basins.

There are currently nine (9) windrows in the main composting area each measuring 4m high x 9m wide x 100m. This equates to the total volume of compost in these windrows at 19,440 m³ and available surface area of 8,100 m². The windrows are currently turned manually with excavators to aerate the piles as well as blend the liquid and solid wastes.

There are two basins which were designed to capture leachate however the current method of operation has led to liquid waste entering these. This has created anaerobic conditions and contributed to the site’s offsite odour potential.

Other sources include:

• Windrows static in the curing area • Finished compost windrows in the loadout area • Driving vehicles on unsealed surfaces within the site • Loading finished product onto trucks


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8.2.2. Buffer distances

Default buffer distances Buffers, or separation distances, are addressed in EPA Publication 1518 and EPA Publication 1588. EPA Publication 1518 refers to Publication 1588.1 to determine separation distances for composting facilities. The guideline specifies recommended separation distances, feedstock related risk factors and best practice methods for siting and operation of a composting facility. The guideline also includes management measures to control dust and odour emissions from a compost facility.

Based on Table 3 of EPA Publication 1588.1 the 50,000 tonnes proposed by Camperdown Compost, the suggested separation distance of 2,000 m applies, based on is applicable. GHD noted that a separation distance of 2,000 m is conservative as it applies to a standard composting operation, not accounting for the technology proposed at the upgraded site. Based on the existing operation of 24,000 tonnes, an existing operations buffer of 1,600 m is applicable.

GHD presented Figure 4.1 in their report, displayed as Table 17 in this application that indicates the extent the 1,600 m and 2,000 m. Both buffers encompass sensitive receptors R1 and R1A and abuts R1B which are within the landholders property. The 2,000m buffer encompasses R1B and abuts receptor R3.

Directional buffer distances As specified in EPA Publication 1518, the EPA can allow a site-specific variation to a default buffer distance. A range of criteria can be assessed in order to create a revised default buffer distance for a given industry. In order to vary the default buffer distance, GHD conducted a risk assessment of the potential odour from proposed upgraded operations. This risk assessment of the potential odour from the operations post upgrades considered the following to be riskier factors:

• Time of year - operational peak of summer (high temperature) and meteorological peak in winter (stable atmospheric conditions)

• Time of day – daytime period when onsite activities are greatest, and night-time when atmospheric conditions are more stable and reduced dispersion of odour.

The topographical and meteorological conditions at the site the wind patterns indicate the following risk scenarios for odour generated following the upgrades at Camperdown Compost:

• High emission scenario • Summer daytime, with southerly winds • Winter night-time, with predominant winds from the north. • Medium emission scenario • Summer night-time, with winds from south, south-southwest and south-southeast • Winter daytime, with north, northwest and north northwest • Low emission scenario • Wind directions north and west-northwest

Based on the topographical and meteorological conditions that define the high, low and medium emission scenarios, site specific directional buffers have been determined for the 2,000 m default buffer. The directional buffers (shown in Figure 6.3 of GHD’s report) are displayed below as Table 18.

8.2.3. Baseline odour survey

A baseline odour survey was conducted of the existing onsite operations to identify baseline odour, prior to any upgrades occurring at the site. GHD detected odour during four baseline surveys, conducted on different days. It was found that intensity and characteristics of the odour differed largely based on the activities occurring at the subject site. For example, during liquid waste deliveries, a foul, sour odour was detected, whilst during green deliveries, a grassy, garden odour was detected. When deliveries were not underway, the odour characteristic was typically a sweet compost smell.


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Compost odour was noted a maximum distance of 2 km from Camperdown Compost boundary during the first odour survey. It was noted that the compost odour detected during the surveys was mostly weak and intermittent beyond 1,000 m from the subject site, with a progression to a distinct and constant odour less than this distance from the subject site (when downwind). Odour was described by GHD as ‘green waste’, ‘liquid/green waste’, ‘matured compost, ‘liquid waste (sour, foul odour)’, ‘wastewater odour’, ‘grassy compost’ and ‘sweet smelling’.

8.2.4. Qualitative dust and bioaerosol assessment

Dust Several dust emission sources exist at Camperdown Compost including:

• Waste delivery - creating dust on roads and waste receipt pad • Windrow composting - compost pads generating dust during material movement, formation,

turning • Refinement, storage and dispatch of final product

The Camperdown Compost Environmental Management Plan (EMP) recognises the on-site dust sources and outlines a number of control measures to be implemented to reduce dust. Several additional practices and procedures will also be applied to manage off-site dust:

• Regular cleaning of the concrete and hardstand working areas • Dust suppression on unsealed surfaces and work areas using a water cart or alternative • Minimising traffic movements on exposed areas • Minimising heavy vehicle speed within the site • Dampening of stockpiles

Based on proposed upgrade measures, proposed controls and general moist nature of the operations, GHD concluded that dust from the subject site will remain a low risk and unlikely to affect the nearby receptors.

Bioaerosols Bio-aerosols are defined as airborne material containing biological material from animals, plants, insects or micro-organisms. The release of bio-aerosols generated at composting plants has the potential to impact on the occupational health of workers and the public living near composting facilities.

The following activities can result in the increased potential for bio-aerosols to be released:

• Initial shredding of the organic waste • Filling and emptying of vessels and vehicles • Formation of windrows or static piles • The physical turning of the material in the windrow or static pile during the maturation stage • The screening and bagging of the mature compost

The amount of bio-aerosol in the air reduces the further the distance from the activity due to particle settling and the dilution affect from bulk air movement. Prevailing weather and wind conditions will affect the disbursement and spread of any bio-aerosol.

GHD concluded that Camperdown Compost is reasonably remote, with a separation to the nearest property being 1.3 km, the off-site bio-aerosol impacts are unlikely to be experienced by the general public as a result of operations. Risks will be effectively managed and deemed low if a number of strategies are applied and incorporated into the EMP.

8.3. Conclusion

Following the completion of the Air Quality Assessment, GHD expects that the proposed upgrade measures and proposed controls will result in decreased odour from the upgraded facility in


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comparison with the existing operations. The existing risks of odour amenity impact at the nearby sensitive receptors is low given:

• Only the residences occupied by the landholder of the subject site fall within the buffers for the low, medium and high risk scenarios (plus R3 for the high risk scenario which is occupied by the daughter of an owner of Camperdown Compost).

• The high risk scenario buffer is driven by the predominant light winter night-time northwest winds when the most high risk activities (waste receival and windrow turning) do not occur.

8.4. Air quality best practice management

Odour and dust has the potential to be generated at Camperdown Compost from a number of sources including receipt of fresh liquid and solid wastes, storing raw organics, and the composting process that involves mixing wastes, turning/aeration and screening or moving of feedstock. Following the completion of the Air Quality Assessment, GHD expects that following the proposed upgrade measures and proposed controls, odour from the upgraded facility will decrease in comparison with the existing operations.

EPA Publication 1588.1 identifies the following measures to be applied to compost facilities to meet SEPP (AQM) requirements:

• fit and maintain appropriate air emission controls to onsite equipment • develop and implement an air quality management plan as part of an Environmental

Management Plan (refer to section 16) • create a balanced compost recipe that enables key parameters to be met for oxygen,

temperature, carbon/nitrogen ratio and pH levels • train staff to prepare and process material according to best practice.

The information presented in Sections 6.3 and 7.9 indicate that the method of composting in open windrows with forced aeration floor can be deemed best practice for the type of composting conducted at Camperdown Compost.

The twelve (12) windrows in the main composting area each 2.2m high x 5m wide x 100m will equate to a volume of 11,616 m³ compost with an available surface area of 9,000 m². The increased surface area will allow more effective dispersal of both moisture and CO2 emissions from the windrows.

The solid waste will be blended into the compost on the receival pad prior to formation of the windrows. The windrows will be mixed by a self-propelled windrow turner to aerate as well as blend in the liquid waste. The continuous aeration of windrows using the underfloor system will provide an efficient and reliable pasteurisation process for the compost.

In addition, a case a study of odour reduction conducted in Weiselberg, Austria at the Seiringer Umweltservice GmbH facility is presented in Appendix E. The case study describes the difference in odour (as measured in odour units) over a 30 day period for a sewage blend and biowaste. it indicates a 30% (sewage blend) to 80% (biowaste) reduction in odour at the point of windrow turning compared to straight, open windrows with no aeration.

The contact water dam will be aerated utilising a high-speed surface aeration unit, which is standard practice across industry.

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Table 17 Buffer distances for existing and future activities at Camperdown Compost


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Table 18 Site specific directional buffers for Camperdown Compost


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Energy Use and Greenhouse Gas (GHG) 9.1. Relevant legislation

State Environment Protection Policy (Air Quality Management) (SEPP (AQM)), requires that generators of greenhouse gas emissions avoid and minimise emissions in accordance with the waste hierarchy, pursue continuous improvement and apply best practice to the management of emissions. Applicants for a works approval are required to comply with the more detailed requirements contained in EPA Publication 824, Protocol for Environmental Management – Greenhouse gas emissions and energy efficiency in industry (the PEM).

The PEM is an incorporated document of the SEPP (AQM). It provides guidance for businesses and requirements for the management of greenhouse gas emissions and energy consumption. The protocol specifies the steps that will need to be taken by businesses to demonstrate compliance with the policy principles and provisions of SEPP (AQM) related to energy efficiency and greenhouse gas emissions, and how EPA will assess compliance.

The PEM outlines the following requirements for applicants applying for works approval:

• Describe the proposed works in relation to energy use and greenhouse gas emissions • Include energy consumption and any non-energy related greenhouse gas emissions • Discuss best practice for energy use and greenhouse gas emissions

The following section outlines the assessment of energy use and greenhouse gas emissions from Camperdown Compost.

9.2. Greenhouse gas emissions sources

Greenhouse gas emissions are categorised into direct and indirect emission sources as defined by the National Greenhouse and Energy Reporting (NGER) Act and the Greenhouse Gas Protocol (WRI and WBCSD, 2012). The NGER Scheme and the Greenhouse Gas Protocol classify direct emissions into Scope 1 and indirect emissions into Scope 2 and Scope 3 as follows:

• Scope 1: Direct greenhouse gas emissions • Scope 2: Indirect greenhouse gas emissions from purchased electricity • Scope 3: Other indirect greenhouse gas emissions

Scope 3 emissions were excluded from this assessment as they are not relevant to the site activity.

A review of potential greenhouse gas emission sources at the site associated with the combustion of fossil fuels and consumption of electricity was undertaken. The review identified electricity consumption from the operation of pumps, aerators, diesel generators and other plant equipment, and fuel usage by onsite vehicles as the primary sources of energy use and greenhouse emissions at the site.

The assessment considered relevant legislation and guidelines including the National Greenhouse Energy Reporting Act 2007 and EPA Protocol for Environmental Management- Greenhouse Gas Emissions and EPA Publication 824 Energy Efficiency in Industry.

9.3. GHG calculations for Camperdown Compost

The total energy use and Greenhouse Gas (GHG) emission calculation was based on:

• Yearly electricity consumption • Amount and type of fuel used and


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• Quantity of organic agricultural material generated in the operations area

The net CO2-e benefit generated by the site activities is estimated to be 46,801 tonnes CO2e per year. The calculations are presented in Table 19.


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Table 19 Annual GHG calculations

Camperdown Compost

Landfill diversion benefitGarden &/or Garden & Food Organics 31,500 tonnes 1.4 t co2e 44,100 t co2eSolids from PIW Liquids 25,000 14% 3,500 tonnes 1.9 t co2e 6,650 t co2e

35,000

Soil BenefitOutput tonnes 25,000Less Moisture Content 25%Net Weight 75% 18,750 Dry Tonnes

Soil Conditioner 60% CO2e per dry tonne 11,250 428 Kg CO₂-e 4,815 t co2eMulch 30% CO2e per dry tonne 5,625 332 Kg CO₂-e 1,868 t co2eOversize 10% re-processed

Gross Benefit 57,433 t co2eComposting losses50% of carbonFresh Kerbside Organic Matter % Dry Weight 64% 35,000 tonnes 22,400 40% losses 8,960 t co2e

Production Process Energy total load total operating hours KilogramsPower Kilograms Tonnes

Machine Litres per hour KW Hrs use days use total Hrs GHG ems GHG ems GJWater Pump 1 7.5 6 260 1560 16895 17 327Water Pump 2 7.5 6 260 1560 16895 17 327Water Pump 3 7.5 6 260 1560 16895 17 327Water Pump 4 7.5 6 260 1560 16895 17 327Fan 1 5.5 14.4 365 5256 41743 42 807Fan 2 5.5 14.4 365 5256 41743 42 807Fan 3 5.5 14.4 365 5256 41743 42 807Fan 4 5.5 14.4 365 5256 41743 42 807Fan 5 5.5 14.4 365 5256 41743 42 807Fan 6 5.5 14.4 365 5256 41743 42 807Fan 7 5.5 14.4 365 5256 41743 42 807Fan 8 5.5 14.4 365 5256 41743 42 807Fan 9 5.5 14.4 365 5256 41743 42 807Fan 10 5.5 14.4 365 5256 41743 42 807Fan 11 5.5 14.4 365 5256 41743 42 807Fan 12 5.5 14.4 365 5256 41743 42 807Contingency Allowance 100 12 260 3120 450528 451 8714Light & Power 50 12 260 3120 225264 225 4357Excavator 15 8 260 2080 84240 84 1629Loader 15 8 260 2080 84240 84 1629Loader 15 8 260 2080 84240 84 1629Windrow turner 18 8 260 2080 101088 101 1955Trommel Screen 10 8 260 2080 56160 56 1086Cars 3 8 260 2080 16848 17 326

Total diesel consumed annually litres 158080 t co2e 1671.11 32323 1671 t co2e

Total Use 10,631 t co2e

Net CO2e Benefit 46,801 t co2eNational Greenhouse Accounts Factors July 2017NSW Dept Climate Change & Water: application of their principles and factors MethodsEquations1) Energy realated activies - GHG = Energy consumption (kWh,GJ) x GHG coefficient 2) Individual Plant - GHG = (total actual load {kW} x operating hours) x GHG coefficient http://www.sustainability.vic.gov.au/resources/documents/Module3.pdfPower Feed

GHG Natural Gas burning 1 gigajoule of natural gas is = to 51.7 kg's of Co2

GHG Brown Coal Burning1.444 kg's of Co2 is = to 1 KwH(kilowatt hour)

http://www.sustainability.vic.gov.au/resources/documents/Module3.pdf

Diesel Burn litre of diesel grams of carbon1 2.7

http://www.environment.gov.au/settlements/transport/fuelguide/environment.html


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9.4. Best practice energy and greenhouse gas management

Where the anticipated level of energy use associated with the application is 500 gigajoules per annum or more (or greater than 100 tonnes of energy-related CO2 –equivalent emissions per annum), work approval applicants are required to identify and implement best practice with respect to the activities that are the subject of the application.

Camperdown Compost proposes to implement a number of practices and management systems to reduce the site’s energy consumption as far as practicable onsite including to:

• Design, construct and operate the site in a way that will achieve an acceptable balance of minimising energy and water use and waste generation.

• Design, construct and operate the site to comply with the Protocol for Environmental Management ‘Greenhouse Gas Emissions and Energy Efficiency in Industry’.

• Consider electricity and fuel efficiency and whole of life costs, including electricity and fuel consumption, when purchasing new plant and equipment, in particular pumps and blowers

• Maintain equipment to manufacturer specification • Only using plant and equipment when required with vehicles not left idling • Integrate sustainability in purchasing decisions, e.g., purchase correct size pumps, invest in

energy efficient pump technologies including variable speed drives • Undertake energy audits regularly to identify energy efficiency and conservation opportunities.


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Water Assessment Stormwater and leachate management are the key considerations at Camperdown Compost, which are described further in this section. Groundwater is also of significance and is also discussed.

Discharge to surface water is not relevant as there are no surface water bodies in the direct vicinity of the site. Potable water is also not a consideration for the site as mains water is not available in the area. bipartisan

10.1. Relevant legislation

The State Environment Protection Policy (Waters) (SEPP (Waters)) is the legislative tool of importance to the water management at Camperdown Compost. SEPP (Waters) identifies the beneficial uses to be protected for each segment of the surface water and groundwater environments and the level of environmental quality required to protect beneficial uses and values identified.

This section of the WAA provides an assessment of the considerations to water management at Camperdown Compost and compliance with SEPP (Waters).

10.2. Surface water management

Camperdown Compost has a number of surface water considerations within the site that need to be managed to avoid impact to beneficial uses and environmental values. These include stormwater, leachate and contact water that are relevant across the various stages of composting. Water use is pivotal for the irrigation of compost windrows and the management of moisture content through the pasteurisation and maturation stages.

The nearest water course is Blind Creek, approximately 750 metres to the west of the site and 450 metres to the south west. The risks of contaminated water reaching watercourses is negligible as the site will be upgraded to contain all surface water within the site boundary.

All surfaces will be sloped between 1-3% to drain to the contact water dam and surrounding areas grassed to capture silt in any runoff.

10.2.1. Site Water Balance

A water balance was completed by Foresight Engineering in April 2020. This report is presented in Appendix F. The objective of this assessment was to confirm the relationship between the maximum stormwater captured across the 4.4 hectare site, and the ability to retain water and avoid offsite discharge. The water balance was also completed to confirm the size of the contact water dam.

The analysis consisted of two stages. Stage 1 calculates the volume of rainwater the site collects during a single 1% Annual Exceedance Probability (AEP) storm event (1 in 100 Year event as calculated by the Bureau of Meteorology). Based on a catchment area of 34,902 m2 a single 1% AEP, 168 hour storm event (7 days) would require a detention dam that could store a minimum volume of 5,340 m³.

Based on the likelihood that the contact water dam is already partially filled due to prior storms, Stage 2 of the model analysed the maximum volume of two events that combined and resulted in an AEP of 1% or greater. The Stage 2 scenario was considered to be a worst case for the site. Both analyses only considered storm durations of 168 hours (7 days) as this is the longest duration provided in the BOM data; the longest storms always result in the highest total volume for a given AEP.

The Stage 2 analysis showed that a combined event of a 10% AEP (1 in 10 Year event), 168 hour storm followed by a 50% (1 in 2 Year event), 168 hour storm resulted in the highest total storm


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volume of 6,289 m³: 949 m³ larger than the Stage 1 analysis. This was the maximum volume calculated under all the scenarios that had a probability of greater than 50% over the 100-year period.

Hence, to adequately manage water on site, Camperdown Compost requires a total detention dam volume of at least 6,289 m³ to meet the required 1 in 100 year storm capability whilst also allowing for the low water consumption rate during application during pasteurisation.

A contact water dam with a capacity of 9.2ML is proposed for the upgraded site. Allowing for 600mm freeboard, the capacity drops to 7.3ML. The dam is 38m long and 94 metres wide. It extends only two metres below ground level ensuring no interaction with groundwater. The dam extends two metres above ground level, giving a total depth of four metres. The dam will be constructed with an internal clay layer of at least 500mm thickness, and a quality which is compliant with the permeability requirements in EPA Publication 1588.1.

10.2.2. Stormwater

Stormwater will be captured across the site by a closed contact water drainage system. All surface runoff caught is treated as contaminated by contact with the organic composting process. The two primary sources of potential stormwater contamination are the windows and the liquid waste receival area. Stormwater contaminants include tannins (from composting) and residual liquid/ solid PIW which consist of organic matter from animal products which has a high biological oxygen demand. If allowed to get into waterways, dissolved oxygen will be depleted as the organic matter in the contaminated stormwater decomposes.

The entire site will be surrounded by an earthen bund 300 millimetres high by 2 metres wide to catch and redirect surface runoff. The exception is the entrance to the site which will be concrete rollover bunds. All water captured on site will be channelled into the 7.3 megalitre dam which will be located to the west of the site.

To achieve a higher performing composting process, high rates of liquids are required. An impermeable handstand will be established across the entire site that will also include an additional concrete base in the pasteurisation area. The impermeable hardstand will effectively capture and drain leachate and contact water. The hardstand will be constructed with 500 mm of compacted clay with a minimum permeability of 1 x 10-9 m/s. The clay will be covered with a layer of geotextile and then 420mm of compacted gravel. This will drain surface runoff to the sealed contact water dam which will reserve water for ongoing application to pasteurisation windrows.

10.2.3. Leachate and contact water

There are two streams of process water that will be created at Camperdown Compost. ‘Contact water’ is produced from the primary composting where biological drying and pasteurisation occurs, whereas the ‘leachate’ will be produced in the maturation windrows.

During the biological drying and pasteurisation of compost, water will be supplied to the windrows primarily from the 7.3 megalitre contact water dam. Water will be applied to windrows by a hose attached to the self-propelled windrow turner ensuring thorough mixing of the windrows and consistency in moisture content.

Any runoff from the pasteurisation area will flow back into the contact water dam. The new concrete air floor will improve drainage and process water capture and provide greater efficiencies in biological drying of liquid wastes added to the windrows. It is anticipated the concrete surface which has a gradient of 1% will reduce water tabling at the base of the windrows which will assist with improved convective airflow and the significant reduction, if not elimination of anaerobic zones, at the base of the windrows. Contact water will account for approximately 60% of the water on site.

The contact water dam will be aerated and monitored weekly for pH and dissolved oxygen biochemical oxygen demand, and oil and grease. Figure 13 depicts an example of high-speed aeration of a leachate pond.


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The maturation area requires less watering to maintain moisture content in the windrows. Water will be supplied from a storage tank with a capacity of 275,000 litres. Any runoff from the maturation area will be captured by drains that will direct water to a sump. The sump will pump water back into the storage tank where it will cycle back before application onto the maturation stockpiles. Fresh water from a large rainwater tank will supplement the maturation leachate water tank. In the event excess water is captured, the leachate water will overflow to the contact water dam. The maturation water will compromise 40% of water captured within the site.

Figure 13 Example of high speed surface aeration of a leachate pond

10.2.4. Water Management Hierarchy

Water will be sourced for composting processing from incoming waste and rainwater. Mains water will be connected as a backup as it is anticipated the site will run at a net water deficit due to process consumption. This is likely to be the case under normal operating conditions. Camperdown Compost similarly anticipates that scenarios are likely where significant volumes of water will available onsite, particularly during events described in Stage 2 of the water balance (Appendix F).

To effectively deal with variable availability of water, Camperdown Compost has considered a water management hierarchy. The hierarchy has been split based on the water quality and water sources necessary for the (1) biological drying area and (2) pasteurisation area/ maturation area. The water hierarchy is displayed in Table 20.

Table 20 Camperdown Compost water hierarchy

Scenario Hierarchy of Actions

Biological Drying Area Pasteurisation Area/ Maturation Area

Normal Operation Draw liquid PIW from PIW storage pit and any water from the Contact Water Dam

1. Review moisture levels in maturation windrows to determine if irrigation is necessary

2. Draw water from the maturation runoff/rainwater tank.

3. If depleted import water from farm dam.


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Scenario Hierarchy of Actions

Dry Conditions-Zero Level in Contact Water Dam

1. Draw liquid PIW from PIW storage Pit.

2. If this is depleted import water from farm dam.



3. If this is depleted import water from farm dam.

Wet Conditions - High Level in Contact Water Dam

1. Cease accepting liquid PIW until dam levels are back at acceptable levels.

2. Draw water from the contact water dam.

3. If water is not reduced at a minimum rate 60 m3/day, water will need to be disposed offsite at an EPA licensed facility.



10.3. Groundwater

10.3.1. Regional groundwater

A review of registered groundwater bores in the surrounding areas (Australian Groundwater Explorer, Bureau of Meteorology, 2017) indicate that bores in the vicinity of Camperdown Compost are primarily used for domestic and stock watering. The closest bore (133393) is located 1 km upgradient and north of the site. This 16.76 m deep bore is functional and has a registered use for domestic and stock watering however, it is not being monitored. All other bores appear to be located at least 2 km away.

Schedule 1 of SEPP (Waters) prescribes the segments for groundwater by reference to Total Dissolved Solids (TDS), which is a measure of salinity. Each segment has a defined list of beneficial uses (BU) that afford protection based on the salinity of groundwater within an aquifer. The Groundwater Resource Report (Vic, DELWP) indicates the groundwater in the Hopkins – Corangamite surface aquifer has a TDS of 1001-3500 m/L, which would be indicate groundwater is classified as Segment B in accordance with SEPP (Waters).

The protection of the following beneficial uses are afforded to Segment B:

• Water dependent ecosystems and species • Potable mineral water supply • Agriculture and irrigation (irrigation) • Agriculture and irrigation (stock watering) • Industrial and commercial • Primary contact recreation • Traditional owner cultural values • Cultural and spiritual values • Geothermal properties; and • Buildings and structures.

The beneficial use of potable water does not apply to Segment B.

10.3.2. Groundwater at Camperdown Compost

In 2015, three groundwater monitoring wells were installed at Camperdown Compost and their locations are depicted in Figure 14. Since 2017, SESL Australia has been engaged by Camperdown


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Compost to assess the groundwater below Camperdown Compost. There is no information available prior to 2017.

The groundwater aquifer has been measured at a depth of 3 m below ground level (BGL). Groundwater level measurements indicate that the groundwater generally flows in a westerly direction (Figure 14). Based on the groundwater flow direction, MW3 is located hydraulically up gradient and MW2 and MW1 are hydraulically down-gradient and cross-gradient, respectively.

Groundwater analysis indicates that TDS in groundwater ranged from 4,730 – 9,360 mg/L and exceeds the range of values for Segment B SEPP (Waters) suggested by the Groundwater Resource Report. As such, the appropriate segment for the site groundwater is Segment C which is afforded protection of the following beneficial uses:

• Water dependent ecosystems and species • Potable mineral water supply • Agricultural and irrigation (stock watering) • Industrial and commercial • Water-based recreation (primary contact recreation) • Traditional owner cultural values • Cultural and spiritual values • Geothermal properties, and • Buildings and structures

The beneficial uses of potable water, and agriculture and irrigation (irrigation) do not apply to Segment C.

10.3.3. Groundwater monitoring events

SESL Australia has conducted groundwater monitoring events (GME) in March 2017, May 2018, March 2020 and May 2020 to understand groundwater quality below Camperdown Compost. During each event, wells have been gauged and sampled. In 2017, three wells MW1, MW2 and MW3 were sampled. Prior to the May 2018 sampling event, MW3 had been inadvertently destroyed by site activities and MW1 and MW2 were sampled in May 2018. Following sampling in 2018, SESL recommended that MW3 was decommissioned and reinstalled in an approximate position prior to the next monitoring event.

As a consequence of the proposed upgrades and expansion of the site, Camperdown Compost decommissioned MW1, MW2 and MW3 in February 2020 and installed three new wells. The locations were chosen to be proximal to the original wells and were located upgradient, downgradient and cross-gradient, consistent with the original wells. These wells have been labelled MW4, MW5 and MW6. The locations of the new wells are presented in Figure 15.

The groundwater results and corresponding water quality criteria are presented in Table 21. The results collected across the GME’s can be summarised as followed:

• Hydrocarbons, VOC’s PCB’s OCPs and OPP’s are undetectable. • Legionella sp. and Salmonella spp. are undetectable. • Escherichia coli and faecal coliforms were detected in all wells in March 2020. Further

sampling in May 2020 did not detect E.coli, indicating anomalous results in the March 2020 GME.

• Copper, nickel and zinc were elevated in March 2020, with a trending temporal increase. In May 2020, only copper and zinc were above criteria.

• Chloride and sodium concentrations are generally consistent across all GME. • Ammonia was detected in all wells in March 2020 and again in May 2020. • Nitrate was detected in all wells. Since 2017, concentrations had increased upgradient but

decreased in the cross gradient and downgradient wells.


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Table 21 Summary of groundwater exceedances

Upgradient Cross gradient

Downgradient

Analyte (mg/L) MW3 MW1 MW2 Guideline Exceeded

2017 Copper <0.001 <0.001 0.002 0.0014mg/L 95% FW ANZG1 Nickel 0.009 0.008 0.014 0.011mg/L 95% FW ANZG1 Zinc 0.009 0.011 0.011 0.008mg/L 95% FW ANZG1 E.coli <10 <10 <10 <100mg/L ANZG livestock2 Nitrate 0.08 24.7 44.5 2.4mg/L FW ANZG3

MW3 MW1 MW2 2018 Copper nd 0.022 <0.001 0.0014mg/L 95% FW ANZG1

Nickel nd 0.016 <0.001 0.011mg/L 95% FW ANZG1 Zinc nd 0.036 0.06 0.008mg/L 95% FW ANZG1 E.coli nd 5 <10 <100mg/L ANZG livestock2 Nitrate nd nd nd 2.4mg/L FW ANZG3

MW4 MW5 MW6 March 2020

Copper 0.02 0.014 0.007 0.0014mg/L 95% FW ANZG1 Nickel 0.064 0.015 0.006 0.011mg/L 95% FW ANZG1 Zinc 0.062 0.059 0.03 0.008mg/L 95% FW ANZG1 E.coli 2000 60 10 <100mg/L ANZG livestock2 Nitrate 0.57 3.92 2.19 2.4mg/L FW ANZG3

May 2020

Copper 0.006 0.009 0.003 0.0014mg/L 95% FW ANZG1 Zinc 0.039 0.048 0.018 0.008mg/L 95% FW ANZG1

Nitrate 0.42 9.48 6.89 2.4mg/L 95% FW ANZG3 Concentrations highlighted red are exceedances of the nominated guidelines:

1. ANZG 2018 Australian and New Zealand Guidelines for Fresh and Marine Water Quality. 2. ANZG 2018 “Primary Industries” guidelines for livestock drinking water quality. 3. ANZG 2018 Freshwater Aquatic Ecosystems 95% Grading Value as per Hickey 2013

The SESL groundwater monitoring reports for the 2018 and 2020 GME’s are presented in Appendix G.


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Figure 14 Groundwater monitoring wells and groundwater contours 2017

Figure 15 Location of groundwater monitoring wells 2020


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10.3.4. Potential for groundwater impacts

There is the potential that site activites are impacting the quality of the groundwater. The primary migratory path for the contaminants in process water at the site is through infiltration of contaminated water into groundwater aquifers through permeable soils. The risk pathways include the clay hardstand underlying the composting operations, the diversion drains directing leachate into the onsite dams and site perimeter bunding. These critical built forms may be permeable and failing to eliminate contact between site activities and groundwater below the site.

The shallow standing water level (3 m below ground level) presents an increased risk of groundwater contamination via surface water infiltration and the existing water collection dam, which is located downgradient to the west of the site, is approximately 4.0 to 4.5 m deep. At this depth, based on the measured standing water level of < 3 metres below ground level (bgl) across the site, there is potential for dam water to interact with groundwater.

It has been evident that the hard stand has been failing in numerous locations. Over time, the surface of the compost process area has degraded as a consequence of significant movement of trucks and mobile equipment across the site. The base of the composting site is showing wear and tear. It is possible this surface damage is posing a risk to groundwater below the site.

10.4. Best practice water management

Section 6.1 of EPA Publication 1588.1 requires contact water (stormwater contacted with stockpiles) to be stored and not discharged offsite and designed for up to a one-in-20-year storm event. This section of the EPA Publication 1588.1 suggests best practice to effectively manage surface water, groundwater and land contamination may include the following:

• Sealed surfaces • Wastewater storage tanks or ponds • Bunding and inception drains; and • Liquid mixing pit management

The proposed upgrade will apply best practice technology and processes to protect the surface water and groundwater environments at Camperdown Compost. The biological drying process will significantly reduce the amount of contact water and leachate produced by the process.

Camperdown Compost Company intends to seal all process areas by constructing an impermeable clay layer with a hydraulic conductivity of less than 1x10-9 m/s, strong enough to support the weight of the composting material as well as movement of trucks and mobile equipment. In addition, concrete will be the base for the pasteurisation area.

The process areas will also be overlaid with crushed rock to protect the clay from desiccation and subsequent cracking and from physical damage from composting activities, vehicle movements and removal (scraping) of compost mass during or after processing. significantly improve the hardstand area and create an impermeable clay surface overlaid in areas with the concrete aeration pad.

A new contact dam with a capacity of 9.3ML is proposed. Allowing for 600mm freeboard, the capacity is 7.3ML, almost 1 ML larger than the sizing suggested by modelling of worst case rain events (Section 10.2.1). The new dam will not extend further than 2 metres below ground, avoiding interaction with groundwater. The dam will have a lining of at least 500mm of clay with a permeability of less than 1 x 10-9 as highlighted in EPA Publication 1588.1. In addition, the dam will be aerated with high speed aeration pumps to maintain process water in an aerobic state to minimise odour.

A Groundwater Monitoring Plan has been developed by SESL (Appendix G) and this will be applied to confirm the site upgrades are effectively preventing any impact groundwater below the site.


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Noise Assessment There are two key industrial noise control documents currently used in Victoria, namely:

• State Environment Protection Policy – Control of Noise from Commerce, Industry and Trade No. N-1 (SEPP N-1) (Victorian Government, 1989)

• Noise from Industry in Regional Victoria (NIRV): Recommended maximum noise levels from commerce, industry and trade premises in regional Victoria (EPA publication 1411, 2011)

SEPP N1 provides a framework for the design of any proposed new commercial, industrial or trade premises so that the noise emissions do not exceed the noise limits set out in the policy. It also requires that the effective noise level does not exceed the derived or prescribed noise limit to protect identified beneficial uses. The SEPP N-1 is applicable for sensitive receivers located in a Major Urban Area (MUA), with potential impact from industrial noise. A ‘Major Urban Area’ is defined as:

• The part of Melbourne that is within the SEPP N-1 boundary • The part of Melbourne that extends beyond the SEPP N-1 boundary, but is within the

Melbourne Urban Growth Boundary (UGB); or • Land within the ‘Major Urban Area’ boundary of an Urban Centre with a population greater

than 7000 • Land zoned either Residential Zone, Industrial Zone, Business Zone or Urban Growth Zone

that is transected by the ‘Major Urban Area’ boundary of an Urban Centre with a population greater than 7000, then the whole of that zone shall be considered as part of the MUA.

The NIRV guideline is applicable for sensitive receivers located in a rural area outside of those areas outlined above that may potentially be impacted from industrial noise. A rural area is defined as:

‘A rural area is land that is not within a major urban area. It includes land in cities or towns with population below 7000, and rural locations outside major urban areas’ (EPA Victoria, 2011).

The Camperdown Compost site and nearby sensitive use are located beyond the SEPP N-1 area and the Melbourne Urban Growth boundary (EPA Victoria, 2011). These sensitive receivers were assessed against the NIRV guideline.

11.1. Noise impact

Noise emissions from Camperdown Compost may arise from both mobile and fixed machinery including movements of transport vehicles entering and leaving the site.

The new system is expected to see a reduction in the use of diesel-powered equipment via the aeration floor using 4.5kW electric motors to aerate the windrows which will see a reduction of front -end loader activities. The fans themselves are “DLD4” Industrial fans which operate at approximately 88 LpA which meets the Worksafe maximum levels of working without hearing protection and as such are highly unlikely to cause nuisance noise offsite.

Other fixed plant sources of noise include pumps housed in a shed for noise containment all of which are commonplace in place the surrounding farms.

Due to the separation distances provided, the total noise from the operations will be inaudible at the nearest sensitive use located 1.2 km from the site. The largest noise source will be truck engines and windrow turners. At an estimated 85 LpA, (measured at 1m), the extrapolated noise level at the nearest sensitive use, is 10 dBA, well below background levels in this rural setting.

11.2. Best practice noise management

In accordance with EPA Publication 1588.1 the following measures will be applied at Camperdown Compost to minimise noise:


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• select and maintain appropriate equipment for the facility • fit and maintain appropriate mufflers on mobile equipment • enclose noisy equipment • provide noise attenuation screens if required • develop and implement noise control strategies in the environmental management plan.

Equipment currently used on site is mobile plant, loaders, excavators, screens and turners and the equipment meets the definition of mobile farm machinery and is exempt as defined in EPA Publication 1411 Noise for Industry in Regional Victoria.


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Waste Assessment The site currently receives a variety of liquid and solid waste generated across local municipalities and agricultural businesses. These could be otherwise disposed of as a waste product on a regular basis if not received by Camperdown Compost.

Waste is defined by the Environment Protection Act 1970 as:

any matter, whether solid, liquid or gaseous or radioactive, which is discharges, emitted or deposited in the environment in such a volume, constituency or manner as to cause an alteration of the environment.

It is generally recognised that waste is any material that is of no further use and has been discarded. Camperdown Compost receives a number of waste streams and beneficially recycles them to produce a valued product. The site relies on this waste product to create a saleable compost and soil conditioner for agricultural application, embracing the environmental protection principles of the Act and reversing the waste hierarchy by taking waste material disposed from a number of businesses and treating them to be beneficially reused by others.

12.1. Waste handling and treatment

Camperdown Compost acts as a receiving premise for waste, however, it transforms this waste into beneficial produce and therefore does not ‘dispose' of the waste at the site. The site is therefore not considered a waste handling premises. The provisions for such a facility are therefore not relevant and instead the process of treatment is addressed in AS 4454-2012 and EPA Publication 1588.1.

12.2. Process water management

Process water is liquid released during the composting process. For the purpose of this works approval application, two streams of process water are generated at Camperdown Compost: (1) contact water from the pasteurisation windrows and (2) leachate from the maturation stockpiles. These process waters have the potential to contaminate local groundwater and surface-water supplies if unmanaged.

Water generated as part of Camperdown Compost’s onsite processes is collected and treated as part of water management on site. Pooled water is managed on site, and the topography of the site directs contact water from the pasteurisation area to the contact water dam. Leachate generated from the maturation area is directed to the sump and stored for reuse. There is no discharge off site.

The existing dam has a number of issues that reduce the options to effectively manage water quality. Conditions are often unfavourable and anaerobic conditions are created, often leading to offsite odour. The proposed upgrades will significantly improve the management of process water, including leachate and contact water at the site. This is discussed in detail in section 10.

12.3. Recycling operation

Camperdown Compost recycles organic agricultural material from nearby waste producers and converts it to a beneficially reusable and saleable compost and soil conditioning product. The waste is transported from producers to the site and the raw feedstock is processed on site into a soil conditioner and compost. The activity therefore relies on the wastes being recycled to produce a valuable compost.

Camperdown Compost generates minimal waste from processing feedstocks on site. Following the upgrades, Camperdown Compost will employ a “Hurrifex” sorter at the pre-compost processing stage specifically to screen any contaminants from the solid feedstocks received on site including stones,


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metal, plastic and any oversize material. The screened waste will be sorted and stockpiled before being transported offsite to appropriate waste disposal facilities.

The office and staff amenities generate negligible quantities of waste. There is the potential for waste from machinery, though this is minimal and managed appropriately.

Any waste generated, including litter and operating waste will be collected and disposed of at an approved landfill. Spent oils from machinery will be collected in large drums for recycling.

12.4. Best practice PIW management

Camperdown Compost receives a range of PIW. These are listed in section 0. The process water management is consistent with the requirements of EP Publication 1588.1. The systems outlined in this document demonstrate best practice design and operation at Camperdown Compost including:

• Liquid PIW will only be applied to feedstock during biological drying, avoiding the pasteurisation and maturation areas

• Hoses used to apply liquid PIW to windrows will be flushed with fresh water before water is applied to maturation stockpiles

• The site has been engineered to separate the process water captured from the pasteurisation and maturation areas, avoiding cross contamination and protecting matured compost.

• The hard stand will be constructed with a minimum hydraulic capacity of 1 x 10-9 m/s, protecting groundwater below the site

Refer to section 10 for reference for additional information related to best practice PIW management.

12.5. Financial Assurance

As a facility operating under Schedule A01 “Prescribed Waste Treatment” the site will require a Financial Assurance.

The calculation of the Financial Assurance is presented in Appendix O.


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Biosecurity Biosecurity risks are prevalent in the transport, storage, processing and the use of inadequately pasteurised organic wastes that could contain a range of pathogens.

Australian Standard 4454 and EPA Publication 1588.1 specifically address animal and human health. Possible pathogens of concern are identified as viruses, bacteria, Protozoa and Helminths.

Appropriate pasteurisation of the feedstock aims to eliminate any potentially harmful human, animal and plant pathogens and plant propagules that may be present in the feedstock. Some spores and weed seeds may survive the compost process if the temperature/time relationship is not suitable and if the pasteurisation is not uniform.

13.1. Biosecurity Hazards

The main biosecurity hazards relevant to Camperdown Compost are:

• Emergency Animal Diseases (EAD) • Disease Vectors • Restricted Animal Material (RAM)

These are discussed further.

13.1.1. Emergency Animal Diseases

Emergency animal disease such as Foot and Mouth Disease (FMD), Creutzfeldt-Jakob Disease (CJD) and Bovine Spongiform Encephalopathy (BSE) have the potential to cause a biosecurity risk as Camperdown Compost receives waste from abattoirs. The likelihood of an emergency animal disease

An emergency animal disease may go unnoticed and may be transferred to an abattoir in the normal processing of livestock for processing. Appropriate management within abattoirs is vital to eliminate transfer of diseased animal products. Camperdown Compost is reliant on the biosecurity protocols of its suppliers of animal by-products such as paunch.

Biosecurity risks associated the activities of producing compost containing EAD include:

• Delivering to customers a product that has not been adequately pasteurised • Delivering to customers unpasteurised PIW • Cross contamination of pasteurised material with fresh feed stock • Feed stock not being pasteurised due to low temperature in rows • Ruminant animals coming in direct contact with organic wastes and soil conditioner • Fresh PIW coming in contact with feed stock and pasteurised material

Camperdown Compost will take the following actions to mitigate biosecurity risks for pathogens and RAM:

• Make sure all organic wastes are adequately pasteurised and verify through testing • Not allow pasteurised material to be cross contaminated with fresh feedstock • Manage feedstocks as soon as it enters the site to contain the material and ensure proper

pasteurisation • Maintain regular contact with suppliers of abattoir and animal by-product feedstock


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13.1.2. Disease Vectors

Organic waste storage and processing activities have the potential to attract vermin and other vectors if steps are not taken to address and prevent problems occurring on and off site. The vermin and vectors relevant to Camperdown Compost site include:

• Birds – crows, starlings and eagles • Rodents - rats, mice • Domestic pets - cats and dogs • Insects - flies • Wild animals – Foxes • Weeds • Dust

Vectors and vermin can be attracted to the incoming feedstock and/or the composting process as a potential food source and place to breed. The following measures implemented at Camperdown Compost aim to limit the impact of vectors on and off site:

• Prevent access of vectors to biodegradable material through appropriate storage and handling of incoming feedstock and out going product

• Prevent water from pooling and stagnating across the site where insects can breed • Move rows of organic material regularly so as to prevent vermin from nesting • Move incoming feedstock into the pasteurisation phase quickly to prevent vermin nesting • Cover feedstock with dry organic material to prevent crows from feeding • Keep the site free from any weeds and plant more trees to prevent weeds blowing on site • Exclude all ruminant stock by securing fencing the site • Remove waste contaminants and keep the site and sheds in a generally tidy state • Control dust moving off site through appropriate management practices

13.1.3. Restricted Animal Material (RAM)

Of particular concern to Camperdown Compost is the potential for organic wastes to contain Restricted Animal Material (RAM). The Australian Ruminant Feed Ban National Uniform Guidelines2 (2016) states that “ruminants must not be fed restricted animal material” and “risk of unintended ingestion by ruminants of products containing RAM must be mitigated”.

A product is considered to contain RAM if it is derived from animal protein, spilt stock feed, manures and faeces, blood and bone meal and food wastes or any product that might contain a RAM ingredient.

The compost from Camperdown Compost should be deemed to contain RAM. The site receives animal proteins and paunch as PIW, and also meat, manures and food wastes in the FOGO.

Biosecurity risks associated the activities of producing compost containing RAM can include:

• Delivering to customers a product that has not been adequately pasteurised • Delivering to customers unpasteurised PIW

2 https://www.animalhealthaustralia.com.au/wp-content/uploads/2015/09/ARFB-National-Uniform-Guidelines-2016-17_final.pdf

https://www.animalhealthaustralia.com.au/wp-content/uploads/2015/09/ARFB-National-Uniform-Guidelines-2016-17_final.pdf

https://www.animalhealthaustralia.com.au/wp-content/uploads/2015/09/ARFB-National-Uniform-Guidelines-2016-17_final.pdf


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• Cross contamination of pasteurised material with fresh feed stock • Feed stock not being pasteurised due to low temperature in rows • Ruminant animals coming in direct contact with organic wastes and soil conditioner • Fresh PIW coming in contact with feed stock and pasteurised material

Camperdown Compost will take the following actions to mitigate biosecurity risks for pathogens and RAM:

• Make sure all organic wastes are adequately pasteurised and verify through testing • Not allow pasteurised material to be cross contaminated with fresh feedstock • Do not allow ruminant animals access to organic wastes • Advise customers to restrict ruminant animals access to piles of compost • Advise customers a withholding period of 3 weeks is required for treated paddocks before

grazing.

Camperdown Compost takes seriously the biosecurity risks associated with the transport, processing, storage and distribution of its compost.

13.2. Best practice biosecurity management

Biosecurity measures are integrated within the proposed process with the following specific measures being undertaken:

• Separation of the feedstock and product handling equipment, vehicles and areas • Washing of machinery between use for handling untreated feedstock and pasteurised

compost/finished product • Segregation of contact water from pasteurisation area and leachate from maturation area to

ensure PIW does not come into contact with material either undergoing pasteurisation or pasteurised compost

• Pasteurisation residence time of twenty-one (21) days, well in excess of the minimum fifteen (15) days required by AS4454

• Pathogen reduction procedures will be confirmed by testing batches of compost for pathogens when there is a significant change in feedstock or processing procedures

• Quarantine and removal of any animal carcasses • Implementing site vector management strategies • Incorporation of FOGO and paunch into windrows as soon as the material is received onsite.

Biosecurity is integrated into the Site Risk Register presented in Appendix I. Biosecurity management is included in the Environmental Management Plan (Appendix J)


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Climate Change Impacts The Climate Change Act 2017 came into effect on 1 November 2017 and sets Victoria’s legislative framework for action on climate change. Section 17 of the Climate Change Act 2017 states that “Decision makers must have regard to climate change” and sub sections 17(2), (3) and (4) require decision makers to have regard to greenhouse gas emissions and climate change impacts. This section outlines the considerations of climate change relevant for Camperdown Compost.

Camperdown Compost and its operations have a minimal impact on climate change. Victoria’s agricultural sector contributed an estimated 16.3 Mt CO2-e of GHG emissions in 2016. The average annual emissions from Camperdown Compost are estimated at approximately 0.001 Mt CO2-e or 0.063% of Victoria’s agricultural contribution.

As a Corporation, Camperdown Compost is committed to consider climate change issues that are relevant to its operation, including greenhouse gas emissions during mixing and turning material, use of diesel operated machinery, and on site fire risks. Camperdown Compost will implement an adaptive program of continuous improvement.


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Site Risks 15.1. Emergency Management

Camperdown Compost has an Emergency Management Plan and Site Risk Register for the Camperdown Compost site. The significant risks identified for the site include:

• Accepting and processing a waste that is prohibited at site • Self combustion of compost stockpiles • Grassfire originating offsite spreads towards site • Overfilling and overflow of contact water dam • Contamination of leachate water with PIW • Biosecurity risks of RAM and EAD in feedstock

The current Site Risk Assessment and Emergency Management Plans are included in Appendix J and Appendix L.

15.2. Fire Risk and Management

Waste decomposes through microbial and chemical action and has the potential to generate considerable heat. It can spontaneously combust when the heat generated is higher than that lost to the surrounding environment. Fires at waste processing sites can rapidly escalate and have serious consequences.

EPA Publication 1667 Management and Storage of Combustible Recyclable and Waste Materials3 requires occupiers of facilities to take reasonable steps to manage and store material in a manner that minimises risks of harm to human health and the environment from fire. Publication 1667 identifies Hazard, Risk and Control as the important elements to understand and implement the fire risk management framework.

The hazard of fire at Camperdown Compost can be created by several factors including:

• Spontaneous combustion of compost due to elevated internal temperatures • External fire source (grass fire or windblown embers) • Exhaust and sparks from vehicles and equipment on site • Combustion of stored wood, cardboard, paper and plastic • Lightning strike

Camperdown Compost has a Fire Risk Assessment and Management Procedure (Appendix L) integrated into its site management. Site access and water requirements have been identified as the

3 https://www.epa.vic.gov.au/about-epa/publications/1667-2

https://www.epa.vic.gov.au/about-epa/publications/1667-2


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major risks to the management of fire on site. The requirements of CFA have been considered in documentation created for the site.

The composting of wastes with open air windrows at Camperdown Compost presents the major fire risk. Appropriate management of windrows during biological drying is integral to minimising the in-process fire risks associated with open windrow composting caused by high moisture levels. Windrow fire can create a greater risk in saturated conditions where anaerobic conditions create methane pockets at high temperatures over 70°, triggering rapid self-heating and eventual combustion. Windrow temperatures will continue to be managed and not exceed 70°C. Moisture content will be maintained between 45% and 65%.

Moisture content will also influence spontaneous combustion: low moisture levels will stop biological activity, and high moisture levels will allow for evaporative cooling of the pile. EPA Publication 1667.2 Management and storage of combustible recyclable and waste materials indicates moisture levels should be maintained below 20% or more than 45% to mitigate risk of fire. Moisture levels will be maintained above 50% during the pasteurisation phase. The moisture level will slowly reduce during the maturation phase. As the majority of organics contained in the windrows have been degraded by this stage, the temperature of the windrows are expected to remain below 40C. Regular monitoring will confirm this. Screening of compost will occur at a moisture level of around 45%. The oversize fraction represents an elevated fire risk as it drops below 45% moisture content. This material will not be allow to accumulate in large piles, but will be added back at the start of the composting process, where it’s moisture content will be increased back to a safe level of 65%.

Windrow moisture is critical for fire safety. Windrows will be regularly monitored for temperature and moisture levels. The windrows will be maintained at a height of 2.2 metres and width of 5 metres. EPA Publication 1667.2 identifies separation of 12 meters for piles of organic waste of 50 meters. This applies to all forms of organic waste. The windrow layout at Camperdown Compost will not comply with this guideline. However, the following factors lower the risk of a fire occurring within the windrows:

• To ensure efficient composting, windrows will be maintained with a moisture level of between 50% and 65% during the pasteurisation and pre-pasteurisation stages. This is the time where the temperature of the windrows is most likely to escalate to a dangerous level.

• Temperature levels in the windrows are constantly monitored via remote temperature sensors. This information will allow heating to be identified early. A number of remedial actions can be implemented prior to temperature escalation, including watering the row or turning.

• In the event that access via a fire truck is required, a path can be made through the compost windrows with a loader or excavator in a short period of time. It is not anticipated that this will be required, as a system of hydrants, designed with input from CFA, enables hoses to be run to all parts of the site without moving rows.

The upgrade will significantly improve both the windrow management and fire suppression capability at Camperdown Compost. In the event of a fire, CFA appliances will have access to a 275,000 litre


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dedicated water supply. A series of hydrants, designed with CFA input, allows for water from the tank to be easily distributed over the majority of the site. A second 275,000 litre non dedicated water source will be located towards the rear of the site. Additional water sources and pumps are available in needed.

Any construction on the site will comply with Victorian fire code building standards determined through the building approvals process.

In addition, the Bookaar site will implement an Emergency Information Book (EIB) that will be maintained on site for access by emergency services. The local CFA brigade will be invited to run fire drills to become familiar with the onsite storage and hydrant system. Onsite water storage will be available for local brigades to use for fires in the immediate area.


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Environmental Management The site has an Environmental Management Plan (EMP) (August 2019) that considers how the site will manage all environmental risks.

The EMP document details the potential environmental impacts of Camperdown Compost Company’s composting facilities and the ways in which these impacts may be reduced through management strategies and site practices.

The EMP:

• Provides clear direction on the selection and implementation of appropriate environmental controls and monitoring techniques during the operational life of the current facility, transition during construction and the operation of the new technology facility.

• Uses the principles of Camperdown Compost Company’s environmental policies to provide the basis of operational procedures used to implement the control and management of environmental impacts.

• Reflects the requirements of licence and approval conditions as well as Camperdown Compost Company’s commitments to high standard environmental performance.

In order to ensure that the facility operates with the least environmental impact, the EMP addresses a wide range of issues including:

• Feedstock and Waste Acceptance management • Dust management • Odour management • Water, leachate & contact water management • Hazardous materials management • Finished Product management

The Environmental Management Plan is presented in Appendix J. This document will be updated in line with the conditions of the works approval application and will reflect additional conditions that will be applied in the amended EPA licence 13415.


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Stakeholder Engagement Camperdown Compost has actively engaged with stakeholders for the last 20 years. The business is a significant contributor to the south west region’s economy and provides a valuable service to waste producers. The company’s primary objective is to maintain a positive and open relationship with all stakeholders.

Table 22 present the key stakeholders that are pivotal to the Camperdown Compost business.

Table 22 Key stakeholders

Category Type Description Considerations Community Residents Nearby residential

dwellings • Odour from operations. • Potential for increased traffic movements • Provide information and updates about the

site Business Adjacent and nearby farms • Odour from operations.

• Potential for increased traffic movements. • Biosecurity

Government Regulators EPA Approval of works approval application and manage the discharge licence

Corangamite Shire Council Issue planning permit

Country Fire Authority Fire management

Agriculture Victoria; Biosecurity Other Sustainability Victoria Management of $500,000 grant for upgrade

Barwon South West Waste & Resource Recovery Group (BSWWRRG)

General interest in site development with reference to the Barwon South West Waste Resource Recovery Implementation Plan

Business Peak Bodies

Victorian Waste Management Association (VWMA) Australian Organics Recycling Association (AORA)

General interest in site development

Waste producers

Warrnambool Cheese and Butter Bega Abattoirs Gas plants

The site and the upgrade are fundamental to operation of the waste producers as it provides options for beneficial reuse of waste.

17.1. EPA Consultation

Camperdown Compost has maintained an open and transparent relationship with EPA, particularly EPA South West who manage compliance with EPA licence 13415. EPA officers have been welcomed on site over the years. EPA has been aware of the significant pressure on Camperdown Compost to receive additional waste due to the closure of a number of waste receival sites across south west Victoria. EPA has worked positively with the site to better manage the waste streams generated.


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EPA has issued two notices to Camperdown Compost. In 2018, the company was fined for exceeding the licence limit of 24,000 tonnes of waste per year. In December 2019, EPA issued a Pollution Abatement Notice to direct Camperdown Compost to reinstate groundwater monitoring following damage to an onsite well.

Camperdown Compost has responded promptly to all EPA’s requests.

17.2. Corangamite Shire Council

Camperdown Compost has similarly maintained open and transparent communication with Corangamite Shire Council. A planning permit application is being submitted in parallel with the works approval application.

17.3. Public Consultation

Camperdown Compost is cognisant that in the past there have been activities on site that have impacted residents surrounding the site. In the event of offsite impacts, Camperdown Compost has been responsive to issues raised and is open to improving activities on site to minimise adverse impacts. This was particularly the case during the upset conditions in 2019 described in Section Section Error! Reference source not found..

Prior to the submission of the original works approval application, Camperdown Compost engaged directly with neighbouring residents that are located within 5 km of the facility, to update residents of proposed upgrades and provide opportunity for feedback. In the past 12 months, Camperdown Compost has documented fifty one interactions with thirty seven households that are within the 5km radius of the site.

In August 2019, an information pack was distributed to the thirty seven households in the 5 km radius of site. This information pack provided details about the proposed upgrades and the works approval application and planning permit application.

Following submission of the original works approval application, a public information session was held on 14 October 2019 at the Killara Centre in Camperdown and submissions were received via engage Victoria (https://engage.vic.gov.au/).

The concerns raised in the public submissions are outline in Table 23 below. Five main concerns with Camperdown Compost were raised. These relate to traffic, odour, biosecurity, groundwater and surface water.

Table 23 Concerns Raised in Public Submissions

Concerns Raised Traffic

Management Odour Biosecurity Groundwater Surface Water

Submission 1 1 1 1 1 1 Submission 2

1

Submission 3 1 1 1

Submission 4 1 1 1

Submission 5 1

Submission 6 1

Submission 7 1 1

Total 6 5 3 1 1

https://engage.vic.gov.au/


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Traffic management has been addressed via a Traffic Management Plan (TMP) submitted as part of planning permit application PP2019105 which is currently being assessed by Council.

Concerns raised regarding odour, biosecurity, groundwater and surface water are discussed in detail within sections of this document.

In anticipation of a works approval application Camperdown Compost, sent a letter to residents in June 2020 advising of the submission of the applications to EPA and Corangamite Shire Council. To date, feedback from community members related to the resubmission have not been received. Correspondence sent to residents around the site are included in Appendix M.

17.4. Industry and Local Government Feedback

Camperdown Compost has received letters of support for the proposed upgrade from:

• Barwon South West Waste & Resource Recovery Group (BSWWRRG) • City of Greater Geelong • Colac Otway Shire • Fonterra Co-operative Group, and • Murray Goulburn Co-operative Ltd (now Bega Cheese Limited)

These letters of support are presented in Appendix N.


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Environmental Best Practice When considering the appropriateness of the upgrade at Camperdown Compost Company, it was necessary to refer to EPA’s best practice guidelines and European Commission (EC) standards specific to aerobic biological treatment to identify a benchmark to assess the proposal against.

In Victoria, EPA Publication 1517.1 Demonstrating Best Practice is used as a guideline for proponents to demonstrate that their proposal meets the specific principles of best practice referenced in the Environment Protection Act 1970.

The overall environmental management of composting operations is defined in the European Parliament and Council Industrial Emissions Directive 2010/75/EU (Integrated Pollution Prevention and Control) incorporating the Best Available Techniques (BAT) Reference Document for Waste Treatment.

An analysis of the upgrade the Camperdown Compost Company facility against EPA Publication 1517.1 and 2010/75/EU was conducted to determine the conditions of the upgrade in relation to industry best practice.

Table 24 and Table 25 demonstrate how the proposal meets best practice for this type of composting operation.

Table 24 EPA Publication 1517.1 Demonstrating Best Practice

Requirement Camperdown Compost Upgrade Best practice for site selection and management systems

Site selection - The site is located 1.2 kilometres from the nearest sensitive receptor (the residence at 445 Sandys Lane), and 7 kilometres from Camperdown township. The site is surrounded by rural land, used primary for broad acre farming. The nearest waterbody is Blind Creek 450 metres to the Southwest across open paddocks. The nearest flood prone area is Curdies River approximately 19 kilometres south.

Air – An Air Quality Assessment prepared by GHD found that the directional buffer

results indicate that the risk to odour amenity impact at the nearby sensitive receptors is low (Refer to Section 7.2.4). The design of the upgrade provides for maximum aeration and even application of liquid waste to windrows, ensuring optimal aerobic decomposition.

Water – There will be not offsite surface water discharges. All process water will be

contained and managed on site. Land and Groundwater – The operating windrow areas will be lined with 500 mm of

clay to a minimum 1 x 10-9 m/s and covered with a 200mm thick concrete base. Noise – The proposal will not result in noise audible to the nearest sensitive receptor

1.2 km from the site. The site will continuously apply system improvements to ensure noise emissions do not impact sensitive receptors.

Best practice is preventative

The upgrade will improve the site’s environmental performance by proactively managing the windrows and improving procedural controls to effectively manage the site in the event of offsite odour at nearby sensitive receptors.

Best practice means undertaking all practicable measures

The technology chosen is a result of extensive research over the last twelve (12) years to design an upgrade that is suitable for feedstocks and feed rates of incoming material.


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Requirement Camperdown Compost Upgrade Best practice may be internationally demonstrated and locally available

The proposed system has been effectively implemented at eleven (11) different European sites in Austria, Italy and Germany. The proposed technology is prefabricated in Europe and shipped to Australia. Compost Systems will oversee the construction and commissioning.

Table 25 Best Available Techniques (BAT) Reference Document for Waste Treatment

BAT Conclusion Camperdown Compost Proposal BAT 33: In order to reduce odour emissions and to improve the overall environmental performance, BAT is to select the waste input by carrying out the pre-acceptance, acceptance and sorting of the waste input to ensure the suitability of the waste input for the waste treatment.

• All waste producers are informed of the types of material that are accepted at the site.

• Liquid PIW is accepted via a designated pit with a residence time of one shift (7.30am – 5.00pm Monday-Friday, 8.00am -12.00pm Saturday).

• Solid PIW and FOGO are accepted on the receival pad and immediately incorporated into mature mulch.

• Liquid PIW and leachate drainage will be segregated via separate drainage systems and the contact water dam will be aerated.

BAT 34: In order to reduce channelled emissions to air of dust, organic compounds and odorous compounds, including H2S and NH3, BAT is to use one or a combination of:

• Adsorption • Biofilter • Fabric filter • Thermal oxidation, and/or • Wet scrubbing

This is not applicable to this proposal as it does not involve channelled (i.e. point source) emissions.

BAT 35: In order to reduce the generation of wastewater and to reduce water usage, BAT is to use:

• Segregation of water streams • Water recirculation • Minimisation of the generation

of leachate

• The high liquid content of feedstock negates the need to import water for the process under normal operating conditions.

• The liquid PIW is circulated over the windrows in the composting area, and leachate is drained to the leachate basin from the biological drying/pasteurisation area and sprayed back over the windrows.

• The drainage of the pasteurisation compost area is segregated from the maturation area.

• The active controlled aeration and water spray process in the composting area is designed to maximise absorption of water into the windrows and the aerobic bacteria. This ensures majority of water is either bound up in the finished compost or evaporated.

BAT 36: In order to reduce emissions to air and to improve the overall environmental performance, BAT is to monitor and/or control the key waste and process parameters including:

• The composition of the windrows is designed to ensure the C:N ratio is between 20:1 and 40:1 in Stage 1 by ensuring blending limits are maintained. Air flow throughout the windrows (influenced by particle size) is maintained by the active aeration and weekly turning.


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BAT Conclusion Camperdown Compost Proposal • waste input characteristics (e.g. C to

N ratio, particle size) • temperature and moisture content at

different points in the windrow • aeration of the windrow (e.g. via the

windrow turning frequency, O2 and/or CO2 concentration in the windrow, temperature of air streams in the case of forced aeration)

• windrow porosity, height and width.

• The temperature and moisture are monitored continuously via SCADA monitoring system and levels maintained at optimum operating parameters.

• Aeration of windrows is maintained by controlled active aeration system with daily measurements of CO2, O2 and CH4.

• Windrows are maintained at a height of 2.2 metres and width of 5 metres, and overall porosity is kept high by regular turning of the windrows and forced aeration.

BAT 37: In order to reduce diffuse emissions to air of dust, odour and bioaerosols from open-air treatment steps, BAT is to use one or both of: • Use of semipermeable membrane

covers, and/or • Adaptation of operations to the

meteorological conditions

• The review of appropriate technologies for composting at the Bookaar site (refer 8018.1) indicates that the most appropriate technology involved actively aerated uncovered windrows due to the ability to deal with the variations in type and quantity of feedstock whilst minimising the risk of windrow moisture going over the optimum 65% (upper range).

• The odour assessment conducted deemed that the site may be at risk of offsite odour 7% of the time when the wind is from the north east. Accordingly, the site will be managed to reduce the risk of odour during these conditions by suspending acceptance of potentially of odorous wastes (PIW, and FOGO) and processing out the portion of these wastes onsite at the time.

• Site procedures will include turning windrows only if the wind is in a favourable direction

18.1. Choice of Process and Technology/Integrated Environmental Assessment

Camperdown Compost conducted extensive investigations for over the last two years to determine the appropriate technology for treatment its feedstock at the Bookaar site. Several options for the site upgrades were considered by Camperdown Compost. These are summarised in Table 26.

Table 26 Options considered by Camperdown Compost

Do Nothing – The composting operation continues in its current state

Benefits • No additional expenditure is required. • Current method is processing compost to the

standard required by clients and meets AS4454.

Disadvantages • There is a clear risk of continued odour complaints which will lead to compliance issues with EPA licence.

• The current method has led to significant constraints on the quantity of feedstock the site can accept

• The current process cannot guarantee effective management of biosecurity


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• There is a risk of compliance issues with groundwater protection due to current state of base and depth of basins.

Anaerobic Digestion Benefits • Controlled generation of methane that can then be used for generating electricity.

• Odour emissions can be controlled

Disadvantages • High capital and operating costs • A large quantity of animal-based wastes (e.g. milk

solids, paunch) can lead to process upsets (i.e. Reflux)

• Power price payback of AUD$0.15 kW/h as opposed to AUD$0.70 kW/h in Europe

• The digestors require a steady stream of feedstock meaning that the site would have to store potentially odorous materials onsite until they could be fed into the process, limiting acceptance of material from unplanned shutdowns

• Residual digestate would require management at the end of the process

• A significant quantity of wastewater produced with no appropriate outlet available (i.e. sewer connection, irrigation).

In Vessel Containerised Composting

Benefits Any odour emissions can be mitigated by directing them to a point source such a biofilter.

Disadvantages • In vessel units do not have the flexibility to accept large amounts of liquid wastes at short notice

• Solid animal products such as paunch cannot be effectively processed

• High accumulation of moisture can affect the process, leading to odour issues.

Open Window Aerated Concrete Pad (Preferred Option)

Benefits • Aeration control allows for liquid application to be managed and ensures sufficient energy in windrow for processing.

• Wastes with high liquid contents can be effectively processed due to the high rate of evaporation created by the aerated floor.

• The process can manage the inconsistent feedstock rates supplied by waste producers.

Disadvantages First time method has been employed in Victoria

18.1.1. Final Choice of Technology

Following extensive research, the optimal option for the upgrade to Camperdown Compost was deemed to be the open window aerated concrete pad. This option will be the most effective means of processing the rate and type of feedstocks whilst minimising environmental impact.

A range of variations to the preferred option were also considered, and are highlighted in Table 27.


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Table 27 Variations to open window aerated concrete pad

a) Roof over windrows (operating the aeration under negative pressure)

Benefits Any odour emissions can be mitigated by directing them to a point source such a biofilter.

Disadvantages • Odour can still be created if feedstock is left too long on the receival pad prior to mixing into the windrows

• While biofilters have been shown to be effective in controlling odour the entire process must be effectively sealed upstream to enable all odour sources to be mitigated

• Condensation of water will increase during biological drying producing large quantities of water in the contact water basin

• Considerably more energy is required to pump air through a biofilter

b) Removable Membrane

Benefits Potential odour can be contained whilst windrows are stationary (i.e. not being turned)

Disadvantages • This option offers no mitigation of odour during turning • The air flow though the windrow is restricted, increasing

the potential for hot spots and excessive moisture

c) Windrows Open to atmosphere

Benefits • Aerobic decomposition and biological drying are both maximised by the even and high rate of air flow through the windrows

• The windrows function as a biofilter

Disadvantages This option is in contrast to the preferred compost options in Victoria.

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Post Works Approval 19.1. Commissioning Plan

The commissioning plan will incorporate testing all mechanical components of the system, particularly the aeration floor. Particular focus will be applied to confirm the effectiveness of turning windows with the self-propelled turner and optimising the biological drying process. The system will need to be trialled to to identify the maximum liquid flow while still achieving optimum decomposition of the solid component of the PIW, the green waste and FOGO.

Camperdown Compost will be working closely with engineers from Compost Systems GmbH who will visit the Bookaar site to supervise construction and commissioning of the new plant.

The major requirement for commissioning is completion of works outlined in the “Commissioning order form”. This form contains an itemised list of finished construction works and the installation of all equipment. It also covers the supply of necessary utilities such as water, power, internet, filter media for aeration trenches, as well as fixed and mobile plant.

The commissioning process is split into two main tests: the cold test and warm test.

19.1.1. Cold test (technical commissioning)

This involves an operation and efficiency test of each piece of equipment without feedstock, in particular:

• Check of equipment installation status (optical/physical test) • Check of wiring and connections • Check of power supply • Check of fan rotation direction • Adjusting motor protections • Configuration of software parameters • Check cloud connectivity • Assigning TML temperature probes • Set parameters and check functionality of the Interval-Mode • Set parameters and check functionality of the Temperature-Mode • Check radio signal of temperature probe in area • Emergency buttons test • Check air distribution: pressure test on aeration lines • Pressure test of each fan for aeration efficiency, and • Airspeed/volume test for each aeration line across all points

19.1.2. Warm test (technological commissioning)

This involves testing the system’s ability to process compost by constructing windrows then conducting tests on the material and the physical performance of the system. It will also focus on the system’s ability to produce compost to required standard.

19.2. Post works approval – Operation Requirements

19.2.1. Financial Assurance

The site will require an increase in the amount of Financial Assurance payable due to the increased capacity of PIW storage onsite.

The calculation of the Financial Assurance is presented in Appendix O.

19.2.2. Monitoring


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Camperdown Compost will update the monitoring plan to reflect the revised method of operation to be in accordance with section 7.1 of EPA Publication 1588.1 and EPA publication 1322.9.

Post commissioning the site will conduct a supplementary air quality assessment applying the same methodology completed by GHD (Refer to Section 7.2.4). This will allow for the optimisation of operational requirements and confirm that offsite odour has been reduced due to improved processing.

19.3. Licence Amendment Subsequent to WAA

The existing EPA licence 13415 will require amendment following commission of the new upgrades. The new licence will specify the amended volumes of feedstock to be received on site. It will also detail ongoing monitoring requirements. Camperdown Compost welcomes the opportunity to work with EPA to refine the conditions in the amended licence.


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Disclaimer This report is confidential and has been prepared by Sustainable Project Management Pty Ltd and may only be used and relied on by The Camperdown Compost Company. Sustainable Project Management Pty Ltd disclaims responsibility for any third party reliance of this report other than The Camperdown Compost Company. The report may not contain sufficient information for the purposes of other parties or for other uses. This report shall be presented in full and shall not be used to support any other objectives than those set out in Section 1.1 of this report, without written approval from Sustainable Project Management Pty Ltd.

This report is strictly limited to the matters stated in it and subject to the various assumptions, qualifications and limitations in it and does not apply by implication to other matters.

The report supersedes all previous draft or interim reports, whether written or presented orally, before the date of this report. This report has not and will not be updated for events or transactions occurring after the date of the report or any other matters which might have a material effect on its contents, or which come to light after the date of the report. Sustainable Project Management Pty Ltd is not obliged to inform The Camperdown Compost Company of such events, transaction or matters nor to update the report for anything that occurs, or of which Sustainable Project Management Pty Ltd becomes aware, after the date of this report.

Unless expressly agreed otherwise in writing, Sustainable Project Management Pty Ltd does not accept a duty of care or any other legal responsibility whatsoever in relation to this report, or any related enquiries, advice or other work, to any person other than The Camperdown Compost Company. Any other person who receives a draft or a copy of this report (or any part of it) or discusses it (or any part of it) or any related matter with Sustainable Project Management Pty Ltd, does so on the basis that he or she acknowledges and accepts that he or she may not rely on this report or any related information or advice given by Sustainable Project Management Pty Ltd for any purpose whatsoever.

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Appendix A – ASIC Company Extract


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Appendix B – Offence Declaration


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Appendix C – Camperdown Compost Site Layout and Design Plans


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Appendix D – Air Quality Assessment (GHD, 2020)


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Appendix E – Seiringer Umweltservice GmbH Odour Study


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Appendix F – Site Water Balance (Foresight Engineering, June 2020)


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Appendix G – Groundwater Monitoring Reports – March, 2017, May 2018 and March/May 2020 (SESL)


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Appendix H – Groundwater Monitoring Plan (SESL, February 2020)


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Appendix I – Site Risk Register


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Appendix J – Environmental Management Plan


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Appendix K - Emergency Management Plan


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Appendix L – Fire Risk Assessment and Management Procedure


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Appendix M – Correspondence to surrounding residences


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Appendix N – Letters of Support


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Appendix O – Financial Assurance Calculation

Documents

Amazon S3 - WORKS APPROVAL APPLICATION EPA ......The Camperdown Compost Company Pty Ltd (Camperdown Compost) has prepared a works approval application for the upgrade of their existing