Warrnambool wastewater treatment plant Public submissions€¦ · Treatment is biological and subject to fluctuations in bacterial populations and death of bacteria due to the presence

Warrnambool wastewater

treatment plant Public

submissions

Contribution ID 228070

Date Submitted Jun 02, 2020, 11:33 AM

Postcode 3280

Best practice design issues and

proposed operations

High

Environmental management

and monitoring

Very high

Existing site or Applicant's

performance and compliance

Proposal is not compliant with

principles of the Environment

Protection Act 1970 and/or

State Environmental Planning

Policy

Low

Sustainability High

Waste acceptance / storage /

treatment

Very high

Greenhouse gas emissions Medium

Other issue 1 (please specify in

your own words and then select

rating from the box below)

Concerned at the high level of waste discharged at Thunder Point and the increased

waste effect on the area as it is increasing used for recreational purposes, fishing,

swimming at Shelley Beach

The area is adjacent to the Marine Park.

Other issue 1 rating Very high




Other issue 2 rating

Climate change and greenhouse

gas emissions

Medium

Groundwater resources

Land and soil resources

Dust and particulate emissions

Noise amenity

Odour and air emissions

Surface water resources

Waste Very high

Health risks and/or hazards Very high

Other impact 1 (please specify in



Other impact 1 rating






Key issue 1 Concerned at the high level of waste discharged at Thunder Point and the increased

waste effect on the area as it is increasing used for recreational purposes, fishing,

swimming at Shelley Beach

The area is adjacent to the Marine Park.

Key issue 2 Concerned at the low treatment level of the water discharged as its effects on the

mariene enviroment

Key issue 3

Do you support, support subject

to conditions or not support the

proposal? Please provide an

explanation in the text box

below.

Support subject to conditions the proposal

Explanation

If you would like to submit

additional materials (such as

documents, photographs, tables

or figures) as part of your

submission, please attach them

here or to your email.

‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high

Sustainability Very high


treatment

Very high

Greenhouse gas emissions Very high










gas emissions

Very high

Groundwater resources Very high

Land and soil resources Very high

Dust and particulate emissions Very high

Noise amenity Very high

Odour and air emissions Very high

Surface water resources Very high

Waste Very high

Health risks and/or hazards High










Key issue 1 Phosphorous levels exiting the treatment plant will remain too high under the

current proposal, having a significant impact on the marine ecology and leading to

algal blooms in the surrounding area

Key issue 2 The current plant has been a major source of micro‐plastics and other marine debris

in the area, and the proposed upgrades may lessen the issue but don't address it

fully

Key issue 3 The proposal has no plan for effluent disinfection, which would result in a safer

marine environment





below.

Do not support the proposal

Explanation The proposal doesn't address the major issues to an acceptable standard, and would

fall well short from meeting future environmental standards with already aging

upgrades







‐



submissions


Date Submitted Jun 25, 2020, 08:36 PM

Postcode 3280


proposed operations

Very high


and monitoring

Very high



High





Policy

High



treatment

Very high











gas emissions

High

Groundwater resources High


Dust and particulate emissions High

Noise amenity Medium

Odour and air emissions High


Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

High



Medium





Policy

High



treatment

Very high

Greenhouse gas emissions Low




I understand there is a high salt rate in the effluent received by the plant. I propose

that those organisations dumping millions of litres of salty waste be required by law

to treat their own waste prior to releasing it into the City Council's Treatment Plant.

If it is not possible to require them to do this, then the responsibility MUST go to the

Council to treat the waste in such a way that it can either be reused or released in a

clean state. If it costs more, so be it. Our planet is in a bad way. We CANNOT afford

to continue dumping our waste into the environment. Punish it, and it will inevitably

punish us.







gas emissions

Medium

Groundwater resources Medium

Land and soil resources Low

Dust and particulate emissions Low

Noise amenity Low


Surface water resources Low

Waste Very high






Environmental, ocean and wildlife.

Other impact 1 rating Very high





Key issue 1 According to Clean Ocean Foundation (research based), "All coastal outfalls around

Australia to be upgraded to meet the Tertiary Class A+ standard of recycled water by

2030 as a target for better performance and reduced waste." This upgrade is

nowhere near at this level.

Key issue 2 I consider this area to be part of my "backyard". I walk along the Thunder Point track

to Shelly Beach almost every day. It is a beautiful part of the world. Some days,

however, I can see and smell the ugliness of human impact on the environment

here. I hate to think what it will look and smell like on a daily basis in 10 to 20 years if

the treatment of our community effluent is not improved significantly.

Key issue 3 I understand that money is a significant factor in this issue, but the serious and

lasting cost to our environment is the only factor that should matter. If it costs us

more in the short term to build a state of the art Treatment Plant, then so be it. It is a

small price to pay for the las ng benefits.

Clean Ocean Foundation says, "Estimated for coastal outfall upgrades in Australia.

Generally, the benefits of upgrades were found to exceed the costs of upgrades,

meaning there was a significant positive net benefit from outfall upgrades."





below.


Explanation I'll start by saying that I do support the addition of "fine screening through a series of

tertiary screens (currently Wannon Water is engaged in a project to install a 1 mm

screen automated tertiary effluent screen)". No matter, other than water, should be

released into our oceans.

However, the extension of the Plant without upgrading it to meet the Tertiary Class

A+ standard of recycled water for our future is ludicrous. I do not support the

extension at all.







‐



submissions



Postcode 2549


proposed operations

Very low


and monitoring

Low







Policy

Very low

Sustainability Very low


treatment

Very low





Wetlands should be investigated. Much like those on the Werribee treatment plant.

This could be a huge tourist attraction. We cannot afford to continually throw our

waste away. We must embrace the circular economy principles of use and reuse and

recycle. Look into these wetland and eco forest systems.





Solar pumps can be used for pumping wastewater to receiving land‐based

environments. Mega storage dams can also be used for firefighting, irrigation and

public land use‐golfcourses.



gas emissions

Very high




Noise amenity Low

Odour and air emissions Medium


Waste Very low

Health risks and/or hazards Very low




Impact of the outfall on our marine environment, seagrasses, algae and tourism.






Farmers who are in need of more water will miss out on this opportunity.


Key issue 1 The sheer waste of a valuable resource.

Key issue 2 The future scarcity of water

Key issue 3 The waste of money to throw something away.





below.


Explanation I do not believe an outfall is a solution. We need to look at other STP's. Byron Bay is a

good example. East Gippsland Water uses 100% of its wastewater. The sunshine

coast has the Maleny project which the community fought for. Parkes City council do

not have an ocean and make good use of their wastewater. If you guys were NOT on

the coast, you would have to think of another way to deal with the wastewater

anyway.







SUBMISSION_NOTES.zip



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Medium



treatment

Very high











gas emissions

Low

Groundwater resources Low



Noise amenity Low

Odour and air emissions Low


Waste High

Health risks and/or hazards









Key issue 1 The key issue is that historically, Wannon water have not managed to treat the waste

water sufficiently, leading to huge amounts of plastics, cotton buds, nuts led and fat

balls being sent out to sea. This treatment plant sits alongside a protected marine

park. They need to improve their current treatment of waste water before they are

given license to increase their outfall.

Key issue 2

Key issue 3





below.


Explanation If wannon water can first improve the quality of waste water with improved

methods of screening out plastics and fat ball Outfalls and reducing E. coli levels in

their treatment, only then should they be able to increase the limits.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high











gas emissions

Very high







Waste Very high











Key issue 1 Wannon Water plans to double its treatment capacity while not actually upgrading

*how* it treats its waste, which is already 20 years out of date. Their system often

does not work, leading to effluent discharges at natural treasures such as Thunder

Point. There is no backup system in place for failure (whether it be power or

otherwise). There has also been an issue of plastic contamination arising from the

plant.

WW does not intend to change this for the better, in fact their projections are for an

increased pollutant load. This cannot be allowed to occur.

WW must not be allowed to go ahead with this project without significantly

upgrading how it treats our sewage.

Key issue 2 Risks relevant to this project have not been sufficiently evaluated. WW has

presented their risk register but an Ecological Risk Assessment under EPA policy was

not presented, and should be required before works are undertaken.

Key issue 3





below.


Explanation YES Wannon Water needs upgrades. However, it must ensure that these upgrades

are in best practice for treatment of waste. Right now, that is not the case. This

whole process must be redone to ensure that Warrnambool has a water treatment

plan that is safe for its citizens and best for its natural environment, with discharge

being an A+ standard.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



High





Policy

Very low

Sustainability High


treatment

Very high





Sewage treatment level is too low.





Companies sending waste to the treatment plant should be doing initial treatment

themselves.



gas emissions

Medium


Land and soil resources Medium





Waste Very high





Impact on marine environment.






Impact on marine park and foraged food.


Key issue 1 The level of treatment of waste being released into the sea is to low. Unacceptable

levels of ocean contamination are already happening, and the volume of this effluent

is going to be doubled.

Key issue 2 Victoria has treatment plants in other areas that treat waste to a higher level. This

plant should be upgraded to a similar level.

Key issue 3 Businesses should be responsible for initial treatment of their own effluent, with

only final treatment happening at the publicly owned facility.





below.


Explanation I would only support the increased volume of effluent if the level of treatment was

also increased to current best practice. I cannot support the proposal with current

treatment levels.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

High



Very high





Policy

High

Sustainability High


treatment

Very high





Outdated infrastructure and environmental consideration for a rapidly growing

population





Marine life contamination



gas emissions

Medium



Dust and particulate emissions Medium




Waste Very high











Key issue 1 Impact to local ocean, marine flora and fauna

Key issue 2 Pristine location, used by many recreational fisherman, divers and families in the

dal area (rock pools)

Impact of high level of pollutants!

Key issue 3





below.


Explanation I feel that there are better methods than outfall to manage our waste. The

infrastructure is no doubt outdated and other options need to be explored to

manage a growing population.







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

Very high



Medium





Policy

High



treatment

High





high levels of e.coli, nitrogen and phosphorus in sewage outfall





inadequate screening of plastics, waste and microplastics, which then ends up in the

ocean and on beaches



gas emissions

Medium




Noise amenity Very low



Waste Medium











Key issue 1 The amount of effluent discharged each day will grow from 16 megalitres to 26 mgl a

day, which means more pollutants will also be discharged.

Key issue 2 2. Risks to human health from exposure to the effluent both inside and outside the

mixing zone via fishing, diving, snorkelling and rock pooling.

Key issue 3 There is no deep exploration of ways to reuse/recycle the wastewater or reduce the

energy consumption of the upgraded plant.





below.


Explanation The upgrade to the Warrnambool Wastewater Treatment Plant is absolutely

inadequate, especially in terms of doing all that is possible to protect our

environment and safeguard our future.







‐



submissions



Postcode 3996


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high

Sustainability High


treatment

Medium





Phosphorus effluent levels ‐ See attached document





Trade Waste cost ‐ Processing of trade waste needs to capture the real cost to

properly process waste to a level acceptable with evolving community expectations.

The public purse should not be expected to subsidise private operators nor should

environmental standards be compromised to allow continuation of practices that

damage the beneficial uses of our marine environment.



gas emissions

Medium






Surface water resources Medium

Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation Please see attached document







EPA_Clean_Ocean_Foundation_Warrnambool_wastewater_treatment_plant_upgra

de.pdf



submissions



Postcode 3300


proposed operations

Very low


and monitoring

Very low



Very low





Policy

Very low



treatment

Very low

Greenhouse gas emissions Very low




An appalling idea!

Other issue 1 rating Very low




I swim in this water and the very thought that I could be splashing about in sewage

totally revolts me. Also you have no regard or respect for our wildlife. Shame on you.



gas emissions

Very high







Waste Very high





See comments above






See comments above


Key issue 1 Environmental disaster

Key issue 2 Major health hazard

Key issue 3 There are other ways of treating sewage please use them





below.


Explanation A revolting thing to do to our environment







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



High





Policy

High



treatment

Very high

Greenhouse gas emissions




Significant spend and upgrade using existing technology, when a better alternative

exists and isn't in the scope.





The technology proposed, which is currently in use, discharges into the ocean on a

regular basis. If this technology was implemented and in conjunction with city

growth, the future output into the ocean would be environmentally detrimental.



gas emissions

Very high




Noise amenity



Waste High





Damage to the ocean






Poor ocean water quality and damage to the beaches

Other impact 2 rating High

Key issue 1 Existing technology proposed, when more superior technology exists that will

provide less output into the ocean

Key issue 2 Lack of concern for potential environmental impacts to the ocean and our beaches,

now and in the future

Key issue 3





below.


Explanation The proposal doesn't appear to have adequately considered the environmental

impact and needs redesign







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Warrnambool has the largest volume of treated effluent discharged into the ocean,

it is 16.5 ML per day (16‐17 million litres). This will be increased to 30 million litres a

day once the expansion takes place. All other regional coastal outfalls (outside the

metropolitan area) average 3ML or below per day. This plant needs to be upgraded

to a Class A Tertiary Treatment standard







gas emissions

Medium




Noise amenity



Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation To be upgraded to a Class A tertiay treatment plant, current level of treatment is

unacceptable to protect our beautiful coast line. Pleae view the below video, it's

unacceptable our ocean is being polluted in this manner.

https://www.facebook.com/nurdles3280/videos/1115397815499314/







‐



submissions



Postcode 3281


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Continued ecological damage





Health concerns for community, tourism and industry.



gas emissions

Medium







Waste Very high





Ecological impact






Health and economical impact to community and industries


Key issue 1 Environmental management and monitoring of the new expansion to ensure

minimal environmental impacts.

Key issue 2 Financial impact on local industry and tourism if expansion allows continued

contamination.

Key issue 3 Concern proposal does not meet environmental protection act. This is disturbing key

issue and requires diligent management and review of the proposal in order to

ensure state environmental policy is met.





below.


Explanation This is an extensive project for the current and future capacity of the city of

warrnambool and surrounding towns. It is understood significant management and

consultant reporting has been undertaken by wannon water, this does not mean,

this proposal, is the only option or that it can't be set to best practice. The time is

now to develop and implement best practice for ongoing management of all water

resources. I support the proposal subject to environmental issues listed above are

addressed and effective ongoing management of the all water resource systems is

met.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



High





Policy

High

Sustainability High


treatment

Very high

Greenhouse gas emissions High




Community consultation ‐ the promise to keep the wider community fully informed

of this project including the justification for this option has not been met. From what

I can see, there has not been a single post this year on the Wannon Water Facebook

page about the proposal, or the opportunity to comment on this plan via the EPA,

and the updates on the Wannon Water website are also buried. If Wannon Water

was serious about informing the wider community, it would urge people to comment

via this EPA process. Set pieces in the local paper are not enough.





The erroneous assumption that Warrnambool has a reliable, long‐term supply of

fresh water which therefore negates the need to look at recycling options for this

waste water. In a drying continent that is suffering the affects of climate change,

such an assumption is misguided.



gas emissions

Medium


Land and soil resources High




Surface water resources High

Waste High






Consultation with the local indigenous community ‐ the Eastern Maar is now a

recognised Aboriginal Party and may not have been registered when this proposal

was first developed.

Other impact 1 rating Medium




Loss of yet more coastal land and vegetation around the treatment plant to

accommodate this expansion.


Key issue 1 The proposed upgrade is not an upgrade at all, but an expansion of an existing

system designed to cater for industry. We will have a system for the next 20 years

that is based not on the latest technology, but old technology that already fails, with

these failures often kept from the general public. Plastics will continue to enter the

ocean and the description of the screening system as 'tertiary' treatment is

misleading. Warrnambool deserves to be a leader in sewage treatment, not a poor

second cousin.

Key issue 2 The proposal does not encourage industry to invest in waste water treatment at its

source, but instead accommodates huge amounts of pollutants, particularly

phosphorus, to continue to be poured into our ocean. International companies such

as Saputo (owner of Warrnambool Cheese and Butter) should not be subsidised by

the taxpayer or other Wannon Water customers, but encouraged to invest in their

own on‐site treatment.

Key issue 3 Pollutants: our beautiful ocean will continue to receive waste water that is well short

of the standards being rolled out elsewhere and will continue to present risks to the

environment and human health. These dot points from a more scientific mind than

mind sum it up:

1. Proper trade waste control to minimise the plant expansion required, and to stop

the discharge from being so extremely high in phosphorus.

2. Proper disinfection (or a very long outfall much greater than 800m length) to get

rid of the human health risk.

3. Rectification of the issues in the current secondary treatment process which are

causing its gross failure.

4. Expansion and modification of the existing plant to remove solids and nutrients for

environmental protection. In doing so, measures to achieve better treatment

efficiency should also be considered, along with effluent filtration to capture the

plastics which you have been collecting in the area.

5. Consider options to better utilise the biosolids generated by the process at lower

cost.





below.



Explanation I compiled a list of concerns based on input from scientists and environmentalists

advising the Clean Ocean Foundation and I believe this list sums up at least some of

the reasons why this project should not be supported and why Wannon Water

should lobby for federal funds to incorporate better technologies:

1. Where does the sewage go if the treatment plant fails, or partially fails?

2. Risks to human health from exposure to the effluent both inside and outside the


3. The phosphorus concentrations " largely from Warrnambool Cheese and Butter ‐

are about 10 times higher than for a similar plant. This can lead to algal blooms.

4. Micro‐plastics will still be able to make it through the screening process and into

the sea.

5. There is no plan for effluent disinfection. Physical, or chemical disinfection will

provide a much safer marine environment.

6. The amount of effluent discharged each day will grow from 16 megalitres to 26

mgl a day, which means more pollutants will also be discharged.

7. The upgrade doesn't take into account 'new' pollutants and how these will be

handled, such as micro plastics, organo‐chlorines and pesticides.

8. There is no deep exploration of ways to reuse/recycle the wastewater or reduce

the energy consumption of the upgraded plant.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



High





Policy



treatment

Very high





The phosphorus concentrations " largely from Warrnambool Cheese and Butter ‐ are

about 10 times higher than for a similar plant. This can lead to algal blooms. Surely

industry should be partly funding this proposal so that their outputs can comply with

appropriate standards.





Where does the sewage go if the treatment plant fails, or partially fails? Is there a

'back up' plan so that wastewater that's not fully treated is not released into the

ocean?



gas emissions

High







Waste Very high





Marine Sanctuary. Micro‐plastics will still be able to make it through the screening

process and into the sea. plant. This can lead to algal blooms.






Risks to human health from exposure to the effluent both inside and outside the

mixing zone via fishing, diving, snorkelling and rock pooling. (noted levels tested in

past can come back as within acceptable limits‐ however visible fatty solids and

other waste, brown coloured water in region of outfall‐ are all signs of significant

community concern.


Key issue 1 The upgrade doesn't take into account 'new' pollutants and how these will be

handled, such as micro plastics, organo‐chlorines and pesticides.There must be an

upgrade of technology, not just an expansion of the existing systems.

EPAs role is in environmental protection. Thus it's vital that any new works are set

up for current and future environmental issues. Clearly there are existing issues with

microplastics and sewage solids (fatty substances) being discharged into ocean.

These issues must be rectified. More discharge at existing 'quality' will mean more

contaminants entering the ocean.

Key issue 2 There is no plan for effluent disinfection. There is evidence that physical, or chemical

disinfection will provide a much safer marine environment. Why is this not

included in the plan?

The EPAs role is to ensure the marine environment is not adversely affected by

waste water discharge. There is evidence of existing issues (as above) so it's clear

that further treatment is needed.

Key issue 3 The high phosphorous levels, as above, and industry causing the main issues

regarding salinity of treated water‐ needs to be looked at. Should be preparing for

best practice management and not just proposing to do what works would be

covered by the limited funding attained. Further funding should be sought,

particularly through the industries that cause the most issues.





below.


Explanation IF there are sufficient amendments to allow for best practice wastewater‐ such that

there is an IMPROVEMENT to wastewater quality being discharged, despite the

increased volume‐ then I would support it.







‐



submissions



Postcode 3283


proposed operations

Very high


and monitoring

Very high



Very high





Policy

High



treatment

Very high





I am very concerned about the increasing load of high nutrient discharge into the

ocean at Shelly Beach. I do not believe this has been adequately addressed in the

application by Wannon Water. With the projected increase in Warrnambool's

population and the significant contribution by the three main industries mentioned

in the application being Saputo, Midfield Meats and Warrnambool Sale yards; this

presents an unacceptable risk to the fragile marine environment. This also has a

increased risk of toxic algal blooms. It is imperative that a reduction in the amount

of phosphorus concentration in discharge water and this must be a priority.





Catastrophic failure of treatment plant and emergency contingency. In the event of a

complete failure of the treatment plant, there appears to be no contingency plan to

store a large volume of waste until it can be treated appropriately before discharge.

It is not acceptable to bypass treatment in the event of an emergency. I would like to

see more thorough emergency contingency plans in the event of a failure that do not

put the community and environment at risk.



gas emissions

Very high








Waste Very high










Key issue 1 The 1mm screen is not sufficient to capture micro plastics and other nano particles

that are an increasing risk to the health of our marine environment.

Key issue 2 Although I understand that upgrades and expansion of the Sewerage Treatment

Plant must take into consideration economic sustainability I see this application as

short sighted. It takes the view that there is a never ending supply of ground water

for the Warrnambool area. With the projected increase in Warrnambool's

population and the ever increasing unpredictability of climate change this is not

sustainable. To take us into the future Wannon Water must re consider the

treatment of waste water with a few to a use of recycled water on land.

Key issue 3 Risk to the marine environment. I am concerned that the risk to the fragile marine

environment has not been adequately addressed in the proposal. Once it is gone it is

gone forever. Wannon Water cannot afford to get this wrong. Issues include the

increase in discharge, pollutants and contaminants such as phosphorus, PFAS (Per‐

and poly‐fluoroalkyl substances), organo‐chlorines, micro and nano plastics and

bacteria such as E.coli





below.


Explanation Although I would like to see a upgrade to the current Sewerage Treatment Plant and

believe this is long overdue it must be done with a view to best practice,

sustainability and leading waste water technologies that address my above concerns.







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

Very high



High





Policy

Very high



treatment

Very high





WHERE DOES THE SEWAGE GO WHEN THE PLANT FAILS?

There is no capability for this plant to hold up a significant volume of sewage for

retreatment. Such a withholding system is necessary to be able to handle bacterial

population fluctuations.

Power failures can also lead to treatment failure. Using a bypass system in this case

is risking the health of the local residents and the ecology. A temporary storage

should be considered.





EMERGING POLLUTANTS ARE REAL. The works approval application pays no

attention to emerging pollutants that we are aware of but just not sure about their

impacts. Items such as:

Fluorinated compounds (PFAS)

Organo‐chlorines

Disinfectants / biocides in personal care products

Nano‐particles in personal care products

Pesticides

All of these are worthy of consideration in a treatment system upgrade.



gas emissions

High




Noise amenity High




Waste Very high





There is no plan for effluent disinfection in the works approval from Wannon Water.

Physical, or chemical disinfection will provide a much safer marine environment for

recreational water users and fishers. This should be included in upgrade plans.





Wannon Water is proposing to increase the volume / flow of the effluent to the

outfall from ~ 16 to ~ 26 ML/day. This is presumably to be done with the same limits

on the concentrations of pollutants to be discharged. This means that the ocean will

receive a further 60% load in these pollutants. For instance, the phosphorus load at

30mg/L will increase from 480 kg to 780 kg/day (mean limit). Despite any reference

to mixing zones, this increased pollutant load has to be assimilated by the same

environment.

The planned works should be set to improve the environmental and health

outcomes. This plan can only make outcomes worse.


Key issue 1 RISKS TO RECREATIONAL USERS INSIDE THE 300m MIXING ZONE:

There is substantial recreational use of the waters inside the mixing zone for

snorkelling, diving, fishing and rock pooling, particularly on calm days. On days of

low wave height, the dilution and dispersion of pollutants will be substantially

poorer than considered in the mixing zone assessment.

Signage, which does not even appear in the hierarchy of controls for managing

hazards in a workplace context, has not been effective in the past, and there is no

reason to expect it will be in the future.

Key issue 2 RISKS TO RECREATIONAL USERS OUTSIDE THE 300m MIXING ZONE:

Potential exposure to risky levels of E.Coli and Enterococci. The mixing zone

assessment has been undertaken considering the median wave height of 2.5m. This

analysis does not consider that recreational use of this area with primary contact (eg.

diving, snorkelling) will largely occur during the calmest days of the year.

Further, simple analysis of the information presented indicates that exposure of

recreational water users outside the 300m mixing zone is likely to routinely exceed

the licence limits for E.coli and Enterococci, and the state environment water quality

objectives, on multiple days per year.


Key issue 3 PLASTICS CARRY TOXINS AND BACTERIA

Wannon Water has recognised the risk of plastic pollution. However, they have not

taken sufficient steps to reduce this plastic risk in the effluent. The works approval

plans provide a 1mm screen of the final effluent. This will catch visible plastic pieces,

but not the true micro plastics in the forms of fibre, nano particles, and other fine

plastic forms used in the home.

With the next stage of membrane filtration most of the offending plastics can be

removed. This next step was flagged for 2040, we don't believe we can wait until

then to clean up the marine environment.





below.


Explanation BETTER TREATMENT = BETTER OUTCOMES

The Warrnambool community can enjoy improved health and an improved

environment from the use of more advanced treatment technologies. The best

outcome for wastewater treatment is the ability to reuse this fresh water in a dry

land environment. Membrane filtration can allow wastewater reuse as is practised in

many coastal communities such as Phillip Island.

We believe that the Warrnambool community can benefit from a rethink of the

wastewater treatment plans to truly upgrade the technologies rather than simply

expanding the existing treatment systems.







‐



submissions



Postcode 3282


proposed operations

Very high


and monitoring

Very high



High





Policy

Medium



treatment

Very high





Lack of community consultation





Lack of monitoring outside 300m mixing zone



gas emissions

Medium







Waste Very high











Key issue 1 The proposal will see an increase in phosphorus and harmful bacteria such as ecoli

and enterococcus into our coastline. This is not best practice and is cost cutting

rather than minimising environmental impact.

Key issue 2 Lack of community consulta on.

In Wannon waters submission they note that the impact to traditional owners

cultural values will be unlikely to be impacted and the impact to the local community

will be minimal. I completely disagree with this. What proof or evidence do they

have to make such a claim? I would consider increasing pollution in an area that has

for thousands of years provided food for indigenous Australians as evidenced by

nearby archaeological works to be significant. I would also consider the increase in

pollution particularly phosphorous on environmentally sensitive area next to the

marine park and bordering hooded plover habitat to also be significant. Can Wannon

water guarantee that nearby beaches won't be affected from walkers and

recreational uses through worsening smell or worsening aesthetic impact?

Key issue 3





below.


Explanation Any upgrade needs to use best practice to ensure that no extra environmental

damage above current levels is allowed.







‐



submissions



Postcode 3282


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Currently the Sewerage treatment plant is discharging pollutants into the ocean so

by doubling its output we will see a consequential increase in these pollutants which

are harmful to the marine environment and human health.





Microplastics have entered the ocean via the sewerage treatment plant and there is

no reassurance that this will not continue with this proposed â€œupgradeâ€ .



gas emissions

Very high




Noise amenity Low



Waste Very high





The phosphorous levels entering the ocean from the sewerage treatment plant

(mostly from industrial waste from Warrnambool cheese and butter) are 10 times

higher than in similar plants. This can cause algae blooms and must be addressed.






Where will the waste go if the plant fails, this does not appear to be addressed in the

proposal.


Key issue 1 The issue of marine pollution and poor health is well known and with the knowledge

we have we cannot continue to pump our waste into the ocean unless it has been

cleaned to a pristine level. This proposal calls for more of the same but more

pollution. I find cotton buds from the treatment plant on my beach which is a few

kms west of the plant...this is not acceptable and clearly breaches EPA guidelines.

Key issue 2 Local volunteers have documented the pollution coming from the treatment plant

currently...this is in an area visited by people fishing, exploring rock pools and

swimming...the health impacts of our sewerage entering the ocean via the

treatment plant must be fully investigated before even more sewerage is emptied

into our ocean.

Key issue 3 The alarmingly high phosphorus levels entering the ocean via the sewerage

treatment plant must be addressed. Increasing the output of the plant will be

disastrous for our beautiful marine environment.





below.


Explanation In this day and age and knowing all that we know it is not acceptable to have waste

entering our marine environment. This proposal calls for a doubling of waste

without any consideration for the elimination of microplastics and other pollutants.

We need to have a treatment plant that meets worlds best standards and does not

treat our precious marine environment like a garbage dump.







‐



submissions



Postcode Warrnambool


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high











gas emissions

High




Noise amenity High



Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

High



Very high





Policy

High



treatment

Very high





Waste treatment being pumped into the ocean, unacceptable.





The design should be future proof not a band‐aid.



gas emissions

Very high




Noise amenity



Waste Very high





More potential risks/spills into the ocean.






The ocean is not a dumping ground, nor is it a part of a sustainable way of waste

management.


Key issue 1 Partially treated water should not be pumped into the ocean as a part of a 300m

mixing zone.

Key issue 2 Industrial waste should be processed properly and not find its way into the ocean.

Key issue 3





below.


Explanation This plan is a poorly planned stop gap which effects the environment and will only

cost more in the long run. Do it properly we only have one pristine environment, so

stop dumping on it.







‐



submissions



Postcode 3216


proposed operations

Very high


and monitoring

Very high



Very high





Policy

High



treatment

Very high











gas emissions

High




Noise amenity Low



Waste Very high











Key issue 1 1. WHERE DOES THE SEWAGE GO WHEN THE PLANT FAILS?

Treatment is biological and subject to fluctuations in bacterial populations and death of bacteria due

to the presence of various toxins in the influent. Treatment failure may be partial, leaving the sewage

itself partially treated. There is no capability for this plant to hold up a significant volume of sewage

for retreatment. Such a withholding system is necessary to be able to handle bacterial population

fluctuations.

Power failures can also lead to treatment failure. Using a bypass system in this case is risking the

health of the local residents and the ecology. A temporary storage should be considered.

2. HIGH NUTRIENT DISCHARGE RISKS ALGAL BLOOMS?

Phosphorus concentrations from the Warrnambool plant are about ten times higher than for a similar

plant treating domestic sewage. This is a primary nutrient that will affect the receiving environment

leading to algal blooms that have been observed at the outfall. These algal blooms can be toxic to

aquatic species and have demonstrated the inability of Wannon Water to keep nutrient levels at a

suitably low level.

Wannon Water has stated that they do not meet the State Environmental Protection Policy criterion

for phosphorus outside the mixing zone of the effluent with marine water.

Phosphorus reduction in concentration and annual kg load should be a major focus of any treatment

upgrade plan.

3. PLASTICS CARRY TOXINS AND BACTERIA

Wannon Water has recognised the risk of plastic pollution. However, they have not taken sufficient

steps to reduce this plastic risk in the effluent. The works approval plans provide a 1mm screen of the

final effluent. This will catch visible plastic pieces, but not the true micro plastics in the forms of fibre,

nano particles, and other fine plastic forms used in the home.

With the next stage of membrane filtration most of the offending plastics can be removed. This next

step was flagged for 2040, we don't believe we can wait until then to clean up the marine

environment.

Key issue 2 4. EMERGING POLLUTANTS ARE REAL

The works approval application pays no attention to emerging pollutants that we are aware

of but just not sure about their impacts. Items such as:

‐Fluorinated compounds (PFAS)

‐Organo‐chlorines ‐Disinfectants / biocides in personal care products ‐Nano‐par cles in personal care products

‐Pes cides


5. BACTERIA CAN BE DISINFECTED




6. RISKS NEED TO BE EVALUATED

Wannon Water presented their risk register but a more detailed assessment of the risk of

the outfall to our health and the ecology are required. All discharges to the marine

environment are subject to an Ecological Risk Assessment under EPA policy. An ERA was not

presented for this discharge to the ocean making it difficult to evaluate the risk of greater

discharge volumes as well as the levels of pollutants the discharge may contain


Key issue 3 7. IT'S NOT THE CONCENTRATION IT'S THE LOAD

Wannon Water is proposing to increase the volume / flow of the effluent to the outfall from ~ 16 to ~ 26 ML/day. This

is presumably to be done with the same limits on the concentrations of pollutants to be discharged. This means that

the ocean will receive a further 60% load in these pollutants. For instance, the phosphorus load at 30mg/L will increase

from 480 kg to 780 kg/day (mean limit). Despite any refence to mixing zones, this increased pollutant load has to be

assimilated by the same environment.

The planned works should be set to improve the environmental and health outcomes. This plan can only make

outcomes worse.

8. RISKS TO RECREATIONAL USERS INSIDE THE 300m MIXING ZONE:

There is substantial recreational use of the waters inside the mixing zone for snorkelling, diving, fishing and rock

pooling, particularly on calm days. On days of low wave height, the dilution and dispersion of pollutants will be

substantially poorer than considered in the mixing zone assessment.

Signage, which does not even appear in the hierarchy of controls for managing hazards in a workplace context, has not

been effective in the past, and there is no reason to expect it will be in the future.

9. RISKS TO RECREATIONAL USERS OUTSIDE THE 300m MIXING ZONE:

Potential exposure to risky levels of E.Coli and Enterococci. The mixing zone assessment has been undertaken

considering the median wave height of 2.5m. This analysis does not consider that recreational use of this area with

primary contact (eg. diving, snorkelling) will largely occur during the calmest days of the year.

Further, simple analysis of the information presented indicates that exposure of recreational water users outside the

300m mixing zone is likely to routinely exceed the licence limits for E.coli and Enterococci, and the state environment

water quality objectives, on multiple days per year.

10. BETTER TREATMENT = BETTER OUTCOMES

The Warrnambool community can enjoy improved health and an improved environment from the use of more

advanced treatment technologies. The best outcome for wastewater treatment is the ability to reuse this fresh water

in a dry land environment. Membrane filtration can allow wastewater reuse as is practised in many coastal

communities such as Phillip Island.

We believe that the Warrnambool community can benefit from a rethink of the wastewater treatment plans to truly

upgrade the technologies rather than simply expanding the existing treatment systems.





below.


Explanation The proposed plan is, in my mind, a like for like solution only looking at improving

the handling of increased volumes. I think that more should be done to upgrade the

facility into as close to a world class treatment plant as possible and that

considerations be made for an equitable funding model of the capex changes

required so that the higher producers of waste (such as industry) are required to

help fund the solution as they are creating much of the problem. Pumping effluent

directly into the ocean in the modern world seems very archaic to me. To basically

"band aid" the problem until 2040 is ridiculous!







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





1. Where does the sewage go if the treatment plant fails, or partially fails?

2. Risks to human health from exposure to the effluent both inside and outside the mixing

zone via fishing, diving, snorkelling and rock pooling.

3. The phosphorus concentrations " largely from Warrnambool Cheese and Butter " are

about 10 times higher than for a similar plant. This can lead to algal blooms.

4. Micro‐plastics will still be able to make it through the screening process and into the sea.

5. There is no plan for effluent disinfection. Physical, or chemical disinfection will provide a

much safer marine environment.

6. The amount of effluent discharged each day will grow from 16 megalitres to 26 mgl a day,

which means more pollutants will also be discharged.

7. The upgrade doesn't take into account 'new' pollutants and how these will be handled,

such as micro plastics, organo‐chlorines and pesticides.

8. There is no deep exploration of ways to reuse/recycle the wastewater or reduce the

energy consumption of the upgraded plant.

9. There must be an upgrade of technology, not just an expansion of the existing systems.

10. Industries that create the vast majority of the waste should be paying more toward the

plant upgrade to make it best practice and future proof.







gas emissions

Very high





Noise amenity



Waste Very high










Key issue 1

Key issue 2

Key issue 3





below.


Explanation 1. Where does the sewage go if the treatment plant fails, or par ally fails?

2. Risks to human health from exposure to the effluent both inside and outside the mixing

zone via fishing, diving, snorkelling and rock pooling.

3. The phosphorus concentrations " largely from Warrnambool Cheese and Butter " are

about 10 mes higher than for a similar plant. This can lead to algal blooms.

4. Micro‐plas cs will s ll be able to make it through the screening process and into the sea.

5. There is no plan for effluent disinfection. Physical, or chemical disinfection will provide a

much safer marine environment.

6. The amount of effluent discharged each day will grow from 16 megalitres to 26 mgl a day,

which means more pollutants will also be discharged.

7. The upgrade doesn't take into account 'new' pollutants and how these will be handled,

such as micro plas cs, organo‐chlorines and pes cides.

8. There is no deep exploration of ways to reuse/recycle the wastewater or reduce the

energy consump on of the upgraded plant.

9. There must be an upgrade of technology, not just an expansion of the exis ng systems.

10. Industries that create the vast majority of the waste should be paying more toward the

plant upgrade to make it best practice and future proof.








‐



submissions



Postcode 3284


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high











gas emissions

Very high




Noise amenity



Waste Very high





Impacts on recreational use i.e. diving, snorkelling, surfing and fishing activities






Impacts on the natural environment, particularly Belfast Coastal Reserve and Merri

Marine Sanctuary.


Key issue 1 Increasing the volume of effluent = an increase in the amount of pollutants.

It makes no sense to call this an â€œupgradeâ€ when in fact it is actually just about increasing the capacity of the Treatment Plant to discharge more pollutants into the

environment.

Key issue 2 Increasing the capacity to cater for increased Trade waste at the expense of the local

community. Trade waste companies must take more responsibility for their waste

and be expected to cover the costs of upgrading any treatment systems to cater for

the increased waste they generate.

Key issue 3 Issues of energy costs as a driver of this expansion are ill considered and Wannon

Water should be exploring green energy solu ons to effluent management.

Furthermore, ocean outfall of sewerage and pollutants is an anathema in this day

and age.





below.


Explanation Organisa ons such as Wannon Water cannot con nue to trash our environment.

Instead of increasing the capacity of the treatment plant and hence the quantity of

pollutants entering the environment from the treatment plant, Wannon Water has a

responsibility to improve community health and the environment by utilising more

advanced treatment technologies to enable wastewater reuse and the utilisation of

the biosolids produced.

This should be the primary focus for any upgrading and improvement of treatment

facili es.

Ocean ou all of treated sewerage is no be er than a third world solu on.

Wannon Water needs to bring it's systems and technology up to date and eliminate

the need to discharge treated water to the ocean environment.

Wannon Water has an opportunity and responsibility to show leadership by

employing the highest possible standards to protect our environmental and

ecological values.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Where does sewage end up if the plant fails? Health risks to exposure? Phosphorus

concentration leading to algal blooms? How will Micro‐plastics, organo chlorines and

pesticides be kept out during the screening process ?





Why is there no deep exploration of ways to reuse/recycle the wastewater or reduce

the energy consumption of the proposed upgraded plant. Is this upgrade really the

best that can be done to protect our precious environment?



gas emissions

Very high







Waste Very high





There must be an upgrade of technology, not just an expansion of the already failing

existing system. The amount of rubbish that gets through is alarming.






Phosphorus levels.


Key issue 1 No deep exploration of ways to reduce/recycle wastewater, new pollutants eg

microplastics, organo‐chlorines, pesticides or reduce energy consumption.

Key issue 2 There must be an upgrade of technology, not just an expansion of the existing

systems.

Key issue 3 Risks to human health and the environment will be elevated if their prehistoric

upgrade goes ahead.





below.


Explanation There must be an upgrade of technology not just an expansion of an already

outdated and ineffective system.







‐



submissions



Postcode 3280


proposed operations


and monitoring

Very high







Policy

Very high



treatment











gas emissions




Noise amenity



Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

Very high



High





Policy

High



treatment

Very high





There are better options, more environmentally friendly options. Don't take the

cheapest option, it's the land that feeds us that takes the cost. Not a long term

solution. Extremely extremely upsetting.







gas emissions

Very high




Noise amenity



Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation I do not support.







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

Very high



High





Policy

High



treatment

Very high





Where does sewerage go if there is a failure in the plant? What is the redundancy,

and what is the testing regime of it?





Risk to our health from letting this partially treated effluent flow into a pristine

ocean, used for swimming, surfing and fishing.



gas emissions

High




Noise amenity Low



Waste Very high





The phosphorus concentrations from Saputo.






Micro‐plastics being able to slip through screening process into the ocean and our

food chain.


Key issue 1 No plan for effluent disinfection.

Key issue 2 The growth of discharge from 16 megalitre to 26 mega litres a day, where we should

not be discharging anything. Clean and re‐cycle.

Key issue 3 Industry that creates waste should pay more to future proof and upgrade technology





below.


Explanation There does not appear to be much in this as a plan to improve the treatment of the

effluent, appears more like a holding pattern to cater for higher volumes. In this day

and age we should be looking at recycle and reuse, notâ€ p it in the oceanâ€.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Where does the sewage go if the treatment plant fails, or partially fails?









gas emissions

Very high




Noise amenity Low



Waste Very high





The phosphorus concentrations " largely from Warrnambool Cheese and Butter " are

about 10 times higher than for a similar plant. This can lead to algal blooms.






Micro‐plastics will still be able to make it through the screening process and into the

sea.


Key issue 1 There is no plan for effluent disinfection. Physical, or chemical disinfection will


Key issue 2 The amount of effluent discharged each day will grow from 16 megalitres to 26 mgl a


Key issue 3 The upgrade doesn't take into account 'new' pollutants and how these will be






below.


Explanation There is no deep exploration of ways to reuse/recycle the wastewater or reduce the

energy consump on of the upgraded plant.

There must be an upgrade of technology, not just an expansion of the existing

systems.

Industries that create the vast majority of the waste should be paying more toward

the plant upgrade to make it best practice and future proof.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

High







Policy

Very high

Sustainability Medium


treatment

High





Warrnambool is a tourist town with that industry forming an important economic

driver for the area and a significant employer. We must have absolutely best practice

and clean beaches to present to our visitors.







gas emissions

Very high







Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation At this stage there has not been a significant public interaction by Wannon Water

with the community. In part this has been compounded by the current Covid‐19

concerns. I suggest this proposal be delayed for at least 3 months to allow further

community consultation.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Medium



High





Policy

Medium



treatment

Very high





world's best practise is not to put treated effluent in the oceans. warrnambool has a

horrendous history of adding pollution and treated waste. any improvements must

be world's best...not bandaid.







gas emissions

Very low



Dust and particulate emissions Very low


Odour and air emissions Very low


Waste Very high











Key issue 1 proposal is not world's best practise. it will pollute. monitoring so far has included

deception so any response needs to be transparent and evidence based best

practise

Key issue 2

Key issue 3





below.


Explanation not appropriate safeguards for the ocean







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

High



treatment

Very high





I am concerned about the the resulting levels of depression this plan will cause

myself my family and friends and others knowing that untreated brown effluent will

be being pumped into our lovely shelly beach area and the disappointment in the

powers that be....yet another slap in the face to people who care for the

environment and another pat on the back for those who don't.





The anger I feel over the environment being treated so poorly just because some

don't care



gas emissions

Very high




Noise amenity High



Waste Very high






Sight of brown water in the sea knowing it's from sewage





Nurses and cotton bud sticks and other plastics on beach


Key issue 1 Environmental impact ‐ negative for the beach and sealife

Key issue 2 Human impact‐ negative for community increased depression and despondency due

to not being heard resoected

Key issue 3 Future generations ‐ negative effect on our children grandchildren etc ....handing

over a polluted earth.





below.


Explanation Because it is not looking after the environment ‐ beach marine life sand and

disrespecting humans and wildlife that frequent the area







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

High

Sustainability High


treatment

Very high





Micro‐plastics and fatbergs will still be able to make it through the screening

process.





There is no plan for effluent disinfection. which will provide a safer marine

environment. The plant is currently pumping out brown effluent into a pristine

marine environment. The amount of effluent discharged each day will grow from 16

megalitres to 26 mgl a day. The plant is not properly treating the current discharge,

how will it cope with an increase of 10 megalitres a day?



gas emissions

High




Noise amenity High



Waste Very high






The upgrade doesn't take into account how pollutants such as micro plastics, organo‐

chlorines and pesticides will be handled.






Key issue 1 The risks to human health and marine life from exposure to the effluent.

Key issue 2 There must be an upgrade of technology, not just an expansion of the existing

systems. The plant is not properly treating the current discharge, how will it cope

with an increase of 10 megalitres a day?

Key issue 3 The phosphorus concentrations produced by factories are about 10 times higher

than for a similar plant. Industries that create a high proportion of waste, should

contribute more to the plant upgrade





below.


Explanation The plant is currently emitting brown effluent, micro‐plastics and fatbergs into a

pristine marine environment. The plant is not properly treating the current

discharge, how will it cope with an increase of 10 megalitres a day?







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Beach hygiene

Long term Environmental impacts on aqua c & wildlife

Ongoing regulation concerns





Impac ng on other beaches in the area

Damage caused with no recourse



gas emissions

Very high




Noise amenity



Waste Very high











Key issue 1 Water hygiene

Key issue 2 Animal life

Key issue 3 Impact on Town & tourism





below.


Explanation Reckless impact on environment







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high

Sustainability High


treatment

High











gas emissions

Low




Noise amenity Low



Waste High





Marine water quality and risk to divers, fishers and people accessing the marine

environment in this area





Risk to marine environment from discharged into the area


Key issue 1 Water should be treated to a level where there is no risk to human and

environmental health. Redundancies should be put in place so water can be stored if

there is a breakdown and anything less then class A water is never released

Key issue 2 Industrial sources should foot the bill, encouraging them to improve there processes

to minimise waste.

Key issue 3 Micro plastics and similar making it through the plant and into the environment.





below.


Explanation Wannon water should be planning to stop ocean discharges all together and reusing

water for irrigation or industrial uses.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high

Sustainability Low


treatment

Low











gas emissions

Very high




Noise amenity Low



Waste Very high











Key issue 1 Maintaining a clean environment

Key issue 2 To maintain water quality that is discharged into the sea

Key issue 3





below.


Explanation As long as the end product is environmentally friendly







‐



submissions



Postcode 3280


proposed operations


and monitoring

Very high



Very high





Policy

Very high

Sustainability High


treatment

Very high











gas emissions

Medium







Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation I absolutely do not support the proposal, they want a bigger plant but there are

already so many problems with the current plant that will only be exaggerated if the

proposal is approved; for example, wannon water already is pumping bucket loads of

faeces into our wonderful ocean, an ocean that people SWIM IN, an ocean that I

SWIM IN. In fact I have BACTERIAL ear infections quite often, and I believe that it is

because of this contaminated waters (that SHOULD and WOULD be clear if not for

wannon water) that bacteria gets into my ears.

So yes, maybe, just maybe wannon water will be ready to upgrade and get a bigger

land mass to work with, but most certainly NOT until they resolve their many, many

problems. And keep in mind, I have not even mentioned the rubbish they freely let

enter OUR oceans, I'm sure we've all heard of the nurdles.







‐



submissions



Postcode 3280


proposed operations

High


and monitoring



Very high





Policy

Medium



treatment

Very high





This is a beautiful part of the coast which I regularly walk, I constantly see the water

contaminated





people dont go to shelly beach because of the sewage, it is in the wrong place...

warrnambool is supposed to be a tourist town, shelly beach and levy's point are

beauty spots, and if properly promoted and cared for they would be of great benefit

to the community... the sewage and the abattoir are hangovers from a time when

people didnt understand the benefits of promoting our natural environment, in the

long run the cost of moving them will be overshadowed by the financial benefits of

tourism, opening up that coastal walk.. not to mention no one wants to live near

them...



gas emissions

Medium







Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation I think its damaging to the environment and local economy







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high







Policy

Very high



treatment

Very high





waste water does not belong in the ocean and I do not think Wannon Water are up

to the task of managing it due to previous record and lack of transparency / honesty

with the local community. Wannon. Wannon Water did not take responsibility for

previous waste finding its way into the ocean from their facility. I have no faith in

their ability to manage it correctly.





This is a beautiful ocean and reserve nearby that I fear will be greatly impacted

negatively by the upgrade.



gas emissions

Very high




Noise amenity



Waste Very high











Key issue 1 Pristine coastal marine park that will be adversly affected by a spill. Environmental

damage to a fragile marine environment. It is unacceptable to be discharging any

waste water into the ocean.

Key issue 2 Little faith in Wannon Water to be open to the community and transparent given

past track record. Did not own up or take responsibility to previous spills

Key issue 3





below.


Explanation I do not believe that discharging any waste water into the ocean is acceptable under

any circumstances. This facility is near a marine sanctuary and the risks are too great

for this beautiful area to have this type of facility near it. I do not believe that

Wannon Water is transparent and honest with the community given recent incidents

ie nurdle waste and fat deposits finding there way into the ocean.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Medium



treatment

Very high





A history of misinformation and lack of dedication to best practices towards

environmental and community concerns have lowered trust in the services of

Wannon Water. Promises that the upgrade will be of world best practices are not

met and rather than upgrading to mitigate ongoing environmental issues this seems

to be simply an expansion to met industry development.





Historically plant failures have only been brought to the EPA and broader

communities attention by concerned community members. Numerous times there

have been spills and WW have not actively addressed these. Concern for the health

and safety of community has not been a priority and with the substantial increase in

phosphorus concentrations, the health and safety of community is a concern. WW

can not been trusted to ensure spills will not occur.



gas emissions

High







Waste Very high






There does not seem to be a dedicated focus on raising the bar to meet

environmental issues currently present. Through many community debriefs we were

promised this upgrade would address concerns regarding pollution and there would

be a thorough exploration to achieve best practices. There does not seem to be an

interest in exploring ways to reduce consumption or raise the bar. Micro plastics

continue to be a concern and has not been addressed adequately.





The industry that is responsible for the increase in phosphorus and need for the

expansion should be actively involved in finding solutions for the management of

their waste. Other areas do not have the issues relating to industry as we

experience. It should not be up to community to solve this issue rather those who

are responsible for the pollution to improve their consumption and disposal

practices.


Key issue 1 Trust. Wannon water have not proven they can be trusted to adhere to best

practices and environmental protection as a priority.

Key issue 2 Expansion not and upgrade. This plan seems to be primarily focused on meeting the

requirements of industry and not environmental issues

Key issue 3 Future generations. The plan is not adequate in meeting environmental concerns for

a healthier environment for future generations. Exploration of better methods of

dealing with the polluted effluent, concerns for ongoing spills and better method for

dealing with waste rather than allowing discharge into a fragile environment could

be explored further.





below.


Explanation This proposal is underwhelming. After all the aspirational promises from Wannon

Water following the nurdle spill, the mis truths and attempts to ignore concerns

regarding continual spills and to down play the continued role Wannon Water plays

in allowing pollution to occur, this proposal does nothing to inspire trust that WW

are able to manage our precious resources adequately. This is not worlds best

practice we were promised.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





that if something goes wrong everything goes in the ocean







gas emissions

Very high







Waste Very high











Key issue 1 that wannon will not be held responsible for problems or concerns.

Key issue 2 that if anything were to happen wannon water would not be able to adapt because

they have set in place a permanent plane util 2040 so we need to think about the

future.

Key issue 3 that wannon water is not responsible enough to manage until 2040 with adjustments

made now 20 years prior and that in 10 years from now a plan much the same will be

thought up for 2040.





below.


Explanation i believe that wannon water needs to be moved inland because they are failing to

stop trash and gunk get through there systems and into the ocean they are not doing

their job however if they were moved inland then they would not have to worry

about getting trash and gun in the ocean.







‐



submissions



Postcode 3228


proposed operations

Very high


and monitoring

Very high



Medium





Policy

High



treatment

Medium











gas emissions

Medium




Noise amenity Low



Waste High





The proposal to double the size of the treatment plan, without any technological

upgrades will severely impact the surrounding ecosystem where the outfall is

currently located. This proposed upgrade needs to ensure the decisions made today

don't affect the health of or community tomorrow.







Key issue 1 The technology is already outdated and needs a rigorous upgrade before any

expansions. As there is already approximately 14 million litres of partially treated

water being discharged, this is negatively impacting the ecosystem currently.

Doubling the capacity of the treatment plan without technological upgrades will

further destroy the ecosystems and potentially hinder the health of the community.

Key issue 2

Key issue 3





below.


Explanation I do not support the proposal as the technology is outdated and will negatively

impact the community, the environment and the future of the area.







‐



submissions



Postcode 3280


proposed operations

Very low


and monitoring

Low



Medium





Policy

Medium



treatment

Low





Wannon Water needs worlds best practice applied to the matter of treating their

waste water treatment







gas emissions

High







Waste











Key issue 1 Wannon Water needs the worlds best practice applied to the matter of treating its

wastewater. We should not be pumping our waste into our precious marine

environment.

Key issue 2

Key issue 3





below.


Explanation







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

Very high



Medium





Policy

Very high



treatment

Medium





Waste of a potential resource for nearby golf course.

Other issue 1 rating High






gas emissions

Medium







Waste Medium











Key issue 1

Key issue 2

Key issue 3





below.


Explanation Tertiary treatment required in the 21st century.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Let's not degrade this beautiful area with poorly treated waste water. I am

concerned about environmental impacts, and infection risk to locals.





Pollution from inadequately treated water, including plastic waste



gas emissions

Medium




Noise amenity



Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation I am gravely concerned about the pollution and infection risk to the coastal

environment if the proposed increase in waste water discharge is approved.







‐



submissions



Postcode 3281


proposed operations

Very high


and monitoring

Very high



Very low





Policy

High

Sustainability High


treatment

Very high





It is not acceptable to just use the ocean as a waste dump. The use of the term

"mixing zone" is stating the obvious. Of course it is mixing but that is not getting

away from the fact that it is still just being dumped there. The effects are obvious

now and will only become worse as the output increases.





Inland cities such as Shepparton and Hamilton for example don't have this easy

option of dumping their waste so are forced to deal with it responsibly by treating it

and then recycling the waste water. If it can be done in inland areas it can be done

here.



gas emissions

High




Noise amenity Low



Waste High





The damage that will be caused to the marine life in the discharge area






The damage that will be caused to the nearby Marine Sanctuary


Key issue 1 Environmental damage caused by only partly treated waste water being released

into the oceon.

Key issue 2

Key issue 3





below.


Explanation I support the need for a larger treatment facility to cater for future expansion but it

must be truly is a "treatment" facility and not just something that offers little

improvement of discharged waste, just higher capacity and output.







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

Low



Low





Policy

High



treatment

Very high





I am not comfortable with the disposal of only partially treated waste being

channeled into the sea. I think that disposal should be land‐based and create useable

by‐ products. It is unacceptable that anything other than water is pumped into the

sea.







gas emissions

Low







Waste Very high











Key issue 1

Key issue 2

Key issue 3





below.


Explanation See reasons above







‐



submissions



Postcode 3284


proposed operations

Very high


and monitoring

Very high



Very high





Policy



treatment

Very high





Pollu on of the Marine Environment

Pollution of the marine environment around Warrnambool and across the coastal

region along the Belfast Coastal Reserve, and the related impact on marine animals

and plants, and the quality of the sea water, and associated risks to human health,

both from the pollution itself and from the consumption of marine life which has

been made unsafe or even toxic by the presence of polluting liquids and various

solids in the outfall, and the associated financial risks which will no doubtedly follow

in terms of loss of tourism, health costs, real and reputational risks to the seafood

industry, and a general loss of reputation for Wannon Water and the region as a

clean, green region.





The loss of finding a clean, innova ve solu on.

The failure of Wannon Water to research thoroughly and come up with an innovative

proposal which would both ensure our oceans and waterways are protected, and

kept clean and healthy, and is a viable and sustainable solution which, by utilising

innovative, modern technologies and thinking, can add value and provide positive

outcomes for the community and the environment.



gas emissions





Noise amenity



Waste Very high





Pollu on of the Marine Environment















Key issue 1 Pollu on of the Marine Environment










Key issue 2 Lack of proper research and careful monitoring by Wannon Water.

As noted in my comments below, Wannon Water's monitoring leaves a lot to be

desired, as was brought into clear view by the nurdle pollution of our beaches and

then the 'fat modules' escaping through the ou all.

For such an important decision and investment in waste disposal for the next 20

years, I would expect Wannon Water would have thoroughly researched all options,

including reuse and other innovative methods being used elsewhere, prior to settling

for this easiest and cheapest method.


Key issue 3 Serious lack of leadership in proposing a short‐term band‐aid solution for a current

and long‐term problem.

in dumping Warrnambool's sewage into the sea at Thunder Point, Wannon Water

has been polluting our ocean for far too long, and clearly has little interest in either

properly researching and monitoring the impacts of this activity, nor in finding a long‐

term solution which keeps our ocean and its marine life clean and protected from

the myriad of dirty and toxic pollutants which flow through its outfall.





below.


Explanation Given the sensitivity of our marine environment and the fact that releasing sewerage ... - poses health risk for our communities and visitors who swim and dive in these waters;

- also constitutes health risks and potentially serious economic damage for the businesses which source various forms of seafood from this marine environment to sell on our domestic and international markets;

- is damaging for the marine life which inhabits the surrounding area; and- does not just damage the marine environment around the outfall, but can impact wider areas along the coast and out to sea, depending on currents and weather conditions, with sewage having been witnessed off Killarney

beach at times; Wannon Water (WW) should take a stronger lead on caring for and ensuring the protection and health of our marine environment, and the health of marine life and our communities, visitors and tourism industries, by seeking a safer and more sustainable long-term solution, rather than this outrageous, dirty and damaging stop-

gap solution. Unfotunately, WW has a very poor track record of an apparent lack of concern for our environment. This was startlingly obvious when nurdles were dumped into the system and found all over beaches and in all likelihood caused severe damage and stress to our marine life. Not only did WW not even realise the nurdles had gotten through their system and into the ocean, but they were 'missing in action' in following through with the massive clean-up which was required, in communicating with the community or showing much concern at all, and in instilling any faith in the community that they were seriously concerned to properly investigate who caused the problem, how their systems failed to monitor or mitigate it, or how they would ensure such a catastrophy would never happen again. The people who were most concerned and did the lion's share of cleaning up this mess were local volunteers, and it was not long after this episode that they then found the 'fat gobules' which had also gone through WW's systems and into the ocean. NOT GOOD

ENOUGH! There is little trust left in this organisation for the community to feel that WW has any commitment to identifying an environmentally sound and sustainable solution to Warrnambool's waste issues, and not surprising that they would go to such a lazy short-term band-aid solution, rather than showing good leadership in finding an innovative way to both protect the marine environment, and thus the health of the marine life and the health of our communities, and also to do as many other organisations are doing and that is to find a solution which creates positive value and outcomes, such as some of the advanced treatment and reuse technologies and solutions which are being achieved elsewhere.







Wannon_Water_sewage_plans_consultation.pdf



submissions



Postcode 3283


proposed operations


and monitoring







Policy

Sustainability


treatment











gas emissions




Noise amenity



Waste











Key issue 1

Key issue 2

Key issue 3





below.

Explanation







SUBMISSION_RE_WANNON_WATER_PROPOSED_UPGRADE.docx



submissions



Postcode 3280


proposed operations

Very high


and monitoring

High



Very high





Policy

High



treatment

Very high





Long‐term return on investment







gas emissions

Medium







Waste Very high





Ecological implications







Key issue 1 Ocean discharge is not an environmentally responsible solution for secondary

treated waste water in any developed country.

Key issue 2 More investment in research should be devoted toward tertiary treatment options

as the proposed upgrade does not offer a significant reduction of environmental

impacts and only seeks to maintain increase capacity, rather than improve

environmental impacts.

Key issue 3 Too much emphasis is being placed on handling industrial and trade waste which

could be treated offsite, prior to being received at the treatment plant. The real cost

of treating this industrial and trade waste needs to be acknowledged and passed on

to clients, or supported through government incentives to enable the adoption of

local pre‐treatment solutions, where costs threaten the economic sustainability of

businesses. This will increase costs of living and/or production but it is time for

everyone to acknowledge these true costs and set about investing more in big‐

picture thinking, research and development. The fallback argument that nobody

wants to pay for more expensive (albeit sustainable) outcomes is not satisfactory

and should not be a precursor for substandard solutions. Greater effort should be

put in to articulating how much these extra costs are e.g. how much per week will it

add to one's expenses?





below.


Explanation The plant upgrade does not reflect a system which is compatible with the

environmental standards which should be expected for high‐value receiving

aquatic/marine ecosystems. The current plant has demonstrated significant short‐

comings over at least the past 3 years. The entire system needs a complete overhaul

and significant investment into tertiary treatment options. This may require moving

the plant and associated infrastructure to a more suitable site, with obvious high cost

but, with a vision for the future, will provide a much‐longer lasting solution. Until

these options have been thoroughly explored, the proposed upgrade offers nothing

more than an expensive band aid, short‐term solution. I don't have a problem with

the notion that the plant needs to increase capacity to accomodate growth, but it

should not be promoted that this is anything approaching a world class facility. This

needs to be acknowledged as a short‐term solution and cost‐benefit measured in

this respect.








‐



submissions



Postcode 3280


proposed operations

Low


and monitoring

Low







Policy

Medium



treatment

Very low





There is concern that there is double the flow from the plant without the

corresponding upgrade to the systems which screen materials before they are

released into the environment. as I am not a waste water technologist I am not able

to make the suggestions as to what these might be but it is essential that this is part

of the application process. You cannot expect the current system to be able to

handle double the flow and not have huge implications for the environment. It may

cost more now but surely there are long term benefits that Wannon Water can see

from doing this correctly now.







gas emissions




Noise amenity



Waste Very high











Key issue 1 No consideration for the current systems ability to manage increased flow ‐ this will

have an impact on the Merri Marine Sanctuary, local plants and animals, recreation

(surfing and fishing), cost Wannon Water more in clean up and retrofitting the

system.

Key issue 2

Key issue 3





below.


Explanation there must be an upgrade of the system developed and implemented by an

independent body‐ ie. not Wannon Water monitoring itself.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



High





Policy

High



treatment

Very high





A more detailed risk assessment should take place regarding the outfall focussed on

the community health and the impact on the environment. Ecological Risk

Assessment under EPA policy was not presented. This makes evaluation of greater

discharge volumes and the level of pollutants it may contain difficult.





Phosphorus reduction in concentration and annual kg load should be a major focus

of any treatment upgrade plan. High nutrient discharge leads to algal blooms that

can be toxic to local marine life. Having a serious health impact on the local

community who use these areas for swimming, fishing and other leisure purposes.



gas emissions

High




Noise amenity Low



Waste Very high






RISKS TO RECREATIONAL USERS INSIDE AND OUTSIDE THE 300m MIXING ZONE

Inside the 300m mixing zone, on days of low wave height, the dilution and dispersion

of pollutants will be substantially poorer than considered in the mixing zone

assessment.

The information presented indicates that exposure of recreational water users

outside the 300m mixing zone is likely to routinely exceed the licence limits for E.coli

and Enterococci, and the state environment water quality objectives, on multiple

days per year.





There is no mention of other pollutants and their effect or treatment such as:

Fluorinated compounds (PFAS), Organo‐chlorines, Disinfectants / biocides in

personal care products

Nano‐particles in personal care products, Pesticides


Key issue 1 WHERE DOES THE SEWAGE GO WHEN THE PLANT FAILS?

Treatment failure may be partial, leaving the sewage itself partially treated. There is

no capability for this plant to hold up a significant volume of sewage for retreatment.

Such a withholding system is necessary to be able to handle bacterial population

fluctuations.

Key issue 2 PLASTICS CARRY TOXINS AND BACTERIA

The works approval plans provide a 1mm screen of the final effluent. This will catch

visible plastic pieces, but not the true micro plastics in the forms of fibre, nano

particles, and other fine plastic forms used in the home.

With the next stage of membrane filtration most of the offending plastics can be

removed. This next step was flagged for 2040, I don't believe we can wait until then

to clean up the marine environment.

Key issue 3 Disinfection of bacteria








below.


Explanation The proposal is an expansion not an upgrade to the sewerage treatment plant. There

are no signs of new technologies that are introduced to tackle many of the current

problems that exists, eg. micro plastics, fat balls, nurdles etc. The proposed 1mm

screen will only catch visible plastics but will not filter out fibres and other fine

plastics that are used in households. I have many concerns that this proposal is based

on cost cutting and does not focus on the benefits investment in better technologies

might have for the future of the environment and the people of Warrnambool.

Better waste water treatment would make for better outcomes for our community

and ecology.








‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

High



treatment

Very high





Issue 2 Concern Very High: Environmental management and monitoring. I have no confidence in

Wannon Water(WW) or the EPA. Some of EPA's regulations were downgraded which allowed

Wannon Water to meet compliance regulations on discharging microplastics into the ocean. Even

though, the new plant might meet existing EPA regulations, these regulations are not robust enough.

The fine screen might help with preventing the many plastics that have already been discharged by

WW over the years but will it prevent high loads of nitrogen, phosphorus and synthetic chemicals

being discharged into the ocean? I think we shouldn't be discharging any waste treated or otherwise

into the ocean unless it has been treated to the standard of a Class A water treatment . The marine

park is nearby with important kelp ecosystems which support marine life such as the common

seadragon. It is an environmental crime to be having a short sewage outfall pipe with a marine park

nearby , polluting the ocean. With the nurdle spill in November 2017, WW did not fess up until social

media and the EPA stepped in. Then it was by described by WW as a 'dump' which could be construed

as a dump by an unknown source such as a waste truck. But WW is responsible for what waste enters

the facility and log books, monitoring of incoming loads and checks should be done by any responsible

water treatment plant authority that accepts incoming industrial waste. Then we had thousands of

cotton buds collected off Shelly Beach over three years (23,000, and still counting). Given the

concentrations of cotton buds and other bathroom/toilet items found on a beach adjacent to the

Thunder Point sewage outfall, one would logically deduce that these items could be classified as

sewage related marine debris. But WW was loath to own up to the fact that so much plastic was

coming from their plant. Too many cover ups and a slow response from the EPA is the reason why I

have no confidence in Environmental management and monitoring by both Authorities.






Issue 2 Expansion not an upgrade at all. The WW treatment Plant is far too close to

residential areas. Water quality is impacted in a popular coastal area frequented by

locals and tourists. From a social media post, a dirty decant was filmed on 29 June

2020. Dirty decants in the sewage outfall's mixing zone area are not uncommon and

are of particular concern for bathing, surfing, fishing as a threat to marine diversity

in the region ('filter feeders concentrate pathogens by a factor of 10,000 apparently,

so the potential for infection is very high'). I have observed tourists and families

heading for Shelly Beach (probably attracted by the name, 'Shelly') as well as people

fishing off the rocks near the outfall . When I lived in Fairway Crescent, I would

notice the odour from the plant. I am glad I have since moved away from the stench

of Midfield and WW as I am a person who is odour sensitive. Of course it is not only

the stench that is of concern but the traffic by industrial trucks coming into a built up

area is also of concern for residents living in that area. The plant location might have

been sufficient 50 years ago but with the proposed expansion, a different location

for industrial waste should be considered. If 70 percent of waste processed will be

from industrial waste then a separate treatment plant using a 'user pays system'

should be established at another site, far away from the township and processed on

land, not discharged into the sea. I only hope WW has a crisis management plan in

place if there is ever a waste truck spill accident in town.



gas emissions

Medium




Noise amenity High



Waste Very high





Following unbiased expert opinions advise: "Warrnambool STP currently discharges

the third highest loads of nitrogen and phosphorus into the ocean in Victoria (after

the two Melbourne plants which service more than two million people each). The

proposed expansion will allow these discharges from Warrnambool STP to more

than double current values. This is due to the poor level of treatment proposed,

which will generate poor water quality than the other coastal plants in Victoria (both

larger and smaller), and much poorer quality than is achieved in all inland Victorian

plants and most plants throughout Australia." My concern is what right does WW or

any other sewage treatment facility? Impacts from climate change and rising acidity

affects fragile marine ecosystems yet we still persist in discharging unacceptable

levels of waste into the ocean. Warrnambool has the highest level of phosphorous

discharge at 12.3 mg/l and Nitrogen levels at Portland and Warrnambool plants are

also very high 10.3 and 10.0, respectively compared with other coastal towns in

Victoria.






"Effluent screens are not used in STPs as they are not efficient. Secondary effluent

filtration, by contrast, is commonly implemented. This should be properly

considered here to robustly protect the environment from plastic pollutants, but

additionally, suspended solids." The screens were a band aid solution due to

pressure from social media exposing the amount of microplastics being discharged

by WW, especially after the nurdle spill. The fine screens get blocked by fatballs and

wipes and might explain why dirty decants and a greater amount of sewage related

debris is observed on the beach.


Key issue 1 The technology is not sufficient for the amount of industrial waste being treated to

prevent pollution by chemicals and microplastics. Another new plant treating

industrial waste is required. Separate domestic from industrial and find a more

suitable site. Odour and pollution with the expansion of the existing site will affect

residents.

Key issue 2 Further expansion will have an environmental impact on the Merri marine park.A

report by Deakin University's Associate Professor Daniel Ierodiaconou states that

Warrnambool's giant kelp beds are already threatened by climate change. We

should be doing everything in our power to preserve coastal habitats and marine

diversity. With climate change already having a detrimental impact on marine

ecosystems, having to also cope with large amounts of microplastics, nitrogen and

phosphorous could well be the tipping point for the extinction of some of our local

marine life. From numerous community beach clean ups and uploading collected

items onto the Tangaroa Blue Foundation's Australian Marine Database Initiative, we

already have information on sewage related debris found on Warrnambool beaches.

I would like to know if there has been any recent studies conducted on nitrogen and

phosphorous levels in the adjacent Merri marine park?

Key issue 3 Tourism. My business relies on tourism. If the water quality and beaches are being

impacted by this expansion then this affects the town's tourist industry and it affects

my business. It is a shame that such a lovely walk to Shelly Beach is marred by the

pollution and odour coming from the sewage treatment plant. It seems that big

business is the biggest polluter‐the dairy industry. Dairying is important to this area's

economy but we need a better system than the one proposed by WW to cope with

the amount of waste from this industry. One that does not impact adversely on the

environment and human health. It is a shame we can't have wetlands like the

Melbourne Water Authority. A better use of waste water. would also be welcome,

though WW cited it was too salty to be of any use. Surely this waste water can be

reused elsewhere using membrane filtration technologies similar to what is being

used at the Phillip Island sewage treatment plant.





below.



Explanation Warrnambool needs an upgrade not an expansion. The proposed works are merely

increasing the sewage treatment plant's capacity. No new technologies are being

incorporated to cope with the nitrogen and phosphorous levels, synthetic chemicals

and microplastics. An expansion at this site is unacceptable. Treat industrial waste at

another location, away from the town, and dispose of this waste on land not into the

ocean. Incorporate a user pays system for industry waste treatment at this site.

Warrnambool is in need of Tertiary treatment that turns sewage into Class A

recycled water and not the proposed sub‐standard sewage treatment in WW's

proposal.







comparing‐effluent‐nitrogen‐phosporous‐levels‐Victorian‐coastal‐towns.pdf



submissions



Postcode 3283


proposed operations

High


and monitoring

Very high



Very high





Policy

High



treatment

Very high











Micro‐plastics will still be able to make it through the screening process and into the

sea.



gas emissions

Very high




Noise amenity High



Waste Very high





The amount of effluent discharged each day will grow from 16 megalitres to 26 mgl a








Key issue 1 Industries that create the vast majority of the waste should be paying more toward


Key issue 2 Warrnambool STP currently discharges the third highest loads of nitrogen and

phosphorus into the ocean in Victoria (after the two Melbourne plants which service

more than two million people each). The proposed upgrade will allow these

discharges from Warrnambool STP to more than double current values. This is due

to the poor level of treatment proposed, which will generate poor water quality than

the other coastal plants in Victoria (both larger and smaller), and much poorer

quality than is achieved in all inland Victorian plants and most plants throughout

Australia.

Key issue 3 Human health risk (both from recreational use of the waters, and the consumption

of seafood collected in the area). The consumption of seafood is particularly risky. I

am told that the remaining shoreline outfalls in Sydney are looking to be directed to

deep offshore outfalls (at a cost of $60‐80m) to prevent people collecting seafood

around the outfalls. No amount of signage, monitoring cameras or other protections

will stop the collection, so they need to do this manage their risk. Filter feeders

concentrate pathogens by a factor of 10,000 apparently, so the potential for

infection is very high. There are also issues of exposure to anti‐biotic resistant

organisms.





below.


Explanation Do not support in its current form. There must be an upgrade of technology, not just

an expansion of the existing systems.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

High



Very high





Policy

Medium

Sustainability Medium


treatment

Medium











gas emissions

Low




Noise amenity Low



Waste Very high











Key issue 1 Plant Failure: This application fails to explain how the authority will ensure waste is

not flushed into the ocean upon plant failure. Countless times in the past 5 years, the

authority has failed to ensure the waste effluent being discharged meets their own

criteria, let alone the EPA criteria, and is seemingly unable to confidently guarantee

any further works or how this proposed plan will rectify this issue. I feel that if this

authority intends to discharge the waste into an uncontrolled place (ie. The Ocean)

they must be held to the absolute highest standard of plant design and operational

planning; not replicating what they already have and just making it bigger.

Key issue 2 Ocean Discharge: Why is this plan continuing the ocean discharge model? There are

surely far more water authorities not discharging their waste into the ocean and they

must have better models for managing the water. Why were these not considered or

planned in this upgrade.

Key issue 3 Effluent Disinfection: Why is it not being disinfected? The water isn't being

discharged in a non‐swimming area and is close to commonly swum and activity

spaces. this must be changed or considered to improve the quality of the water if we

must be discharging it into the ocean.





below.


Explanation This is half baked and has no consideration for installing modern, best practice water

treatment processes at the Wannon Water facility. It is a poorly thought out increase

of what we already have (old technology to start with) and it must be revised and

improved for the future of our environment. Our community, the planet and our

future generations deserve the best.







‐



submissions



Postcode 3002


proposed operations

Very high


and monitoring

Very high



High





Policy

Medium



treatment

Very high











gas emissions

Low




Noise amenity Low



Waste Very high











Key issue 1 I am surprised and very concerned to find out that Wannon Water has been

discharging sewage at Thunder Point with a lower standard of treatment than

applied almost anywhere in Victoria. I am even more concerned and perplexed that

Wannon Water is seeking to double the amount discharged.

The reason this is relevant to the EPA's consideration is self evident.

Key issue 2 The effluent includes plastics from the sewer, and these are washing up on Shelly

Beach. In addition, I am aware that the phosphorus concentrations in the effluent do

not meet the Victorian requirements, and this will damage the environment in this

remarkable area.

Again I believe the relevance to the EPA's consideration requires no further

explanation.

Key issue 3 I am aware that the effluent is not disinfected such that that on calm days the sea is

unsafe for swimming, and human consumption of shellfish and crayfish caught

hundreds of metres from the discharge pipe risks catching diseases.

Relevance self evident.





below.


Explanation The proposal does not meet current standards for effluent discharge, is polluting to a

beautiful part of Victoria and a potential health hazard, is completely unnecessary as

gold standard technologies are readily available (and deployed throughout Victoria),

and is not future proof.







Feedback_to_Wannon_Water_and_the_EPA_‐_edited.pdf



submissions



Postcode 3280


proposed operations


and monitoring







Policy

Sustainability


treatment











gas emissions




Noise amenity



Waste











Key issue 1 1. Where does the sewage go if the treatment plant fails, or partially fails?

2. Risks to human health from exposure to the effluent both inside and outside the


3. The phosphorus concentrations " largely from Warrnambool Cheese and Butter ‐

are about 10 times higher than for a similar plant. This can lead to algal blooms.

4. Micro‐plastics will still be able to make it through the screening process and into

the sea.

5. There is no plan for effluent disinfection. Physical, or chemical disinfection will


6. The amount of effluent discharged each day will grow from 16 megalitres to 26

mgl a day, which means more pollutants will also be discharged.

7. The upgrade doesn't take into account 'new' pollutants and how these will be


8. There is no deep exploration of ways to reuse/recycle the wastewater or reduce

the energy consumption of the upgraded plant.

9. There must be an upgrade of technology, not just an expansion of the existing

systems.

10. Industries that create the vast majority of the waste should be paying more

toward the plant upgrade to make it best practice and future proof.

Key issue 2

Key issue 3





below.


Explanation The plant needs to be upgraded to accommodate growing quantities of waste but

this should not be at greater cost to the marine environment or human health.

Really, in this day and age we should not be pumping pollution into the sea as if it

has no impact! It should be treated on land where it can be broken down into

recyclable and true waste products and used/disposed of in a way safe to the

environment.







‐



submissions



Postcode 3277


proposed operations

High


and monitoring

Very high



High





Policy

Medium



treatment

Very high











gas emissions

Medium




Noise amenity



Waste Very high






My primary concerns are the direct environmental impacts of unsatisfactory

treatment processes, both generally and in the case of a malfunction. Both levels of

pollution have occurred continually and repeatedly under Wannon Water's contract

to date, including visually brown, smelly flows directly into the ocean, and the

inability to filter out large pollutants such as plastic cotton buds and toiletries

products' lids.

My secondary concern is the long term flow‐on effects of this pollution on the

economy and quality of life in the region, particularly by discouraging tourism and

diminishing the region's attractiveness as a place to live, through the pollution of

beaches and ocean, and the colossal financial impact that this inevitably has. We

need a truly sustainable solution with the lowest environmental impact possible on

every level, to avoid having to reinvest in just a few years when the system is again

clearly below acceptable standards. At top level, innovative and carbon neutral

solution (and this needs to be truly excellent that it makes more than just the local

news) could add to the perceived and actual value of accommodation, land, lifestyle

etc, and provide a long term economic bolster for the region.





The share of strain on the water treatment infrastructure and system from industry,

particularly the cheese and butter factory, is disproportionate and should be

reassessed. The financial investment of these corporations to facilitate a world class

treatment plant that outputs truly safe water and has backup systems for

emergencies, needs to be required and enforced.


Key issue 1 See other impact 1.

Key issue 2 See other impact 2.

Key issue 3





below.

Explanation







‐



submissions



Postcode 3275


proposed operations

High


and monitoring

High



High





Policy

Medium



treatment

Very high





I don't think this waste should be going into our ocean







gas emissions

Very high




Noise amenity Low



Waste Very high











Key issue 1 Waste water should not go into the ocean unless it is drinkable and even then it

would be better used on paddocks or other areas

Key issue 2

Key issue 3





below.

Explanation







‐



submissions



Postcode 3283


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





I am concerned about where the sewage goes if the treatment plant fails, or

partially fails?





Industries that create the vast majority of the waste should be paying more toward




gas emissions

High




Noise amenity Low



Waste Very high





The upgrade doesn't take into account 'new' pollutants and how these will be







There is no plan for effluent disinfection. Physical, or chemical disinfection will



Key issue 1

Key issue 2

Key issue 3





below.


Explanation I do t feel that Wannon water are really looking long term solutions considering

population growth, possible failures and the risks to the marine environment and

how aiming for best standard not just good enough through the use of new

technologies will enable safe guards and protections for people and the marine

species.







‐



submissions



Postcode 3282


proposed operations

Medium


and monitoring

Very high



High





Policy

Medium



treatment

Medium











gas emissions

High







Waste Medium

Health risks and/or hazards Medium










Key issue 1

Key issue 2

Key issue 3





below.


Explanation







‐



submissions



Postcode 3324


proposed operations

Very high


and monitoring

Very high



High





Policy

Medium



treatment

Very high





There must be an upgrade of technology, not just an expansion of the existing

systems.





The upgrade doesn't take into account 'new' pollutants and how these will be




gas emissions

High




Noise amenity Low



Waste Very high





Where does the sewage go if the treatment plant fails, or partially fails?









Key issue 1 WHERE DOES THE SEWAGE GO WHEN THE PLANT FAILS

Treatment failure may be partial, leaving the sewage itself partially treated. There is

no capability for this plant to hold up a significant volume of sewage for retreatment.

Such a withholding system is necessary to be able to handle bacterial population

fluctuations.

Power failures can also lead to treatment failure. Using a bypass system in this case

is risking the health of the local residents and the ecology. A temporary storage

should be considered.

Key issue 2 There is no plan for effluent disinfection in the works approval from Wannon Water.



Key issue 3 Wannon Water is proposing to increase the volume / flow of the effluent to the



receive a further 60% load in these pollutants. Despite any refence to mixing zones,

this increased pollutant load has to be assimilated by the same environment.







below.


Explanation People who live, work or play in warrnambool can enjoy improved health and an

improved environment from the use of more advanced treatment technologies. The

best outcome for wastewater treatment is the ability to reuse this fresh water in a

dry land environment

People who live, work or play in warrnambool can benefit from a rethink of the


expanding the existing systems







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very low





I think this is a disgrace there should be better ways of getting rid of waste and not

offload it it our ocean





I thing Wannon Water need to go back to the drawing board and come up with a

better solution



gas emissions

Very high







Waste Very high





We want better community consultation






Needs more thought into this


Key issue 1 My concern is there is better alternatives than dumping ing the ocean

Key issue 2 Industry's like Warrnambool Cheese and Butter need to be paying a lot more

towards alleviating this problem

Key issue 3





below.


Explanation As mentioned take this back and work out a better solution than dumping in the

ocean







‐



submissions



Postcode 3280


proposed operations


and monitoring

High



Very high





Policy

Sustainability


treatment

High











gas emissions

High




Noise amenity



Waste High











Key issue 1

Key issue 2

Key issue 3





below.


Explanation







‐



submissions



Postcode 3280


proposed operations

Medium


and monitoring

Very high



Very low





Policy

Medium

Sustainability High


treatment

Very high





Long term environmental impact





Impact on water users (swimmers, surfers, snorkelers, etc.)



gas emissions

Medium







Waste High











Key issue 1 Detail analysis regarding impact on environment and those using the beach

Key issue 2 Minimal Exploration of other options for waste management

Key issue 3 Lack of community consultation





below.


Explanation Can't read the other option, but it seems to me that further impact studies are

needed and community consultation.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Low





Policy

Very low



treatment

Very high





Would like to think that for such a major upgrade that we wouldn't simply expand

the current treatment practices, which result in less than ideal quality water being

pumped to the ocean, and that we would move to world best practice. As stated in

FAQs, It would be more expensive, yes, but even at double the cost would be

worthwhile. Vic govt has committed to borrowing $22b to stimulate the economy

post‐covid, perhaps some of this could be applied for with a visionary submission? I

just think we should be aiming higher. I note that the upgrade will allow better

practices to be adopted in the future but why not do it now? Let's show we can be

leaders in this, and really care for the environment we are given charge of, not just

hang our hats on meeting all regulatory requirements.





It is stated that Warrnambool waste water issues are unique given the volumes that

come from industry. Is industry accountable enough for the waste they produce?

Perhaps a contribution towards the upgrade from industry could be sought, if it

hasn't already. Higher levies for the big polluters to encourage more on site

treatment of their waste.



gas emissions

Medium




Noise amenity Low




Waste Very high





High pollutants being pumped into the ocean, threatening the marine environment.






Key issue 1 High level of pollutants in ocean outfall.

Key issue 2 Not following worlds best practice.

Key issue 3





below.


Explanation I do not wish to be too critical as this is an expensive undertaking and would be even

more expensive if worlds best practices were committed to, I just feel that we have

an opportunity to do the job properly and not just expand current practices. I have

some knowledge of the Wannon Water business and realise the financial pressures

that exist when making decisions like this, however I feel the moment is right to

really make a great choice for the future of our water treatment. Please consider.







‐



submissions



Postcode 3105


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





The upgrade will increase the amount of sewage going out without improving its

quality. $40 million dollars could be better spent on investing in better water

treatment technology and a more effective environmental solution.





The idea of releasing waste water through ocean outfalls is incredibly outdated and

adds to the plastic pollution threatening the health of marine environments across

Australia.

We should be investing in changing the way things are done because plastics impact

on community health and, importantly, local wildlife. Outfalls pumping waste water

out into the ocean is simply unacceptable.



gas emissions

Very high







Waste Very high






Potential impact to wildlife is significant. Plastics in the water can have an impact on

local wildlife including on little penguins, migratory birds that feed along the

coastline, and southern right whales that visit each winter. All of these animals are

being affected by the amount of plastic in our ocean.





Contaminant levels a above acceptable levels for humans. E coli measures will

potentially become even worse.


Key issue 1 Risk to public health


potentially become even worse.

Key issue 2 Risk to wildlife




being affected by the amount of plastic in our ocean.

Key issue 3 Irreparable environmental damage

We must change the way things are done so future generations do not have to swim

in an ocean that's full of plastic. This is already happening elsewhere in the world

and Australia will soon be in a similar situation if we continue to blindly accept

illogical, unsound plans that continue to damage our natural environment.





below.



Explanation I strongly oppose this submission. The idea of releasing waste water through ocean

outfalls is incredibly outdated and adds to the plastic pollution threatening the

health of marine environments across Australia.

We should be investing in changing the way things are done because plastics impact

on community health and, importantly, local wildlife. Outfalls pumping waste water

out into the ocean is simply unacceptable.


poten ally become even worse.




being affected by the amount of plas c in our ocean.

The upgrade will increase the amount of sewage going out without improving its

quality. $40 million dollars could be better spend on investing in better water

treatment technology.

We owe it to future generations to make better choices now. We must change the

way things are done so future generations do not have to swim in an ocean that's full

of plastic. This is already happening elsewhere in the world and Australia will soon

be in a similar situation if we continue to blindly accept illogical, unsound,

environmentally damaging plans that continue to damage our natural environment.







‐



submissions


Date Submitted Jul 01, 2020, 05:56 AM

Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high

Sustainability High


treatment

High





Works Approval Application fails to adequately consider widely used approaches and

processes which would address environmental and public health impacts.





Lack of openness, transparency and honesty in public communications on behalf of

Wannon Water. Not addressing issues such as Dirty Decants and plastic/fatball

pollution events when reported to them by members of the public.



gas emissions

High







Waste High





Emerging pollutants such as microfibres not addressed. Plastic particles






Impacts of the shoreline outfall on primary contact recreational use i.e. rock‐pooling,

diving and fishing activities. Loss of amenities (600m of shoreline). Loss of aesthetic

enjoyment of are due to pollution events. Impacts on public health due to the

beneficial uses of fishing and collecting shellfish. Emerging issues such as, Aquatic

food consumption Health, Microbial hazards (pathogens), Toxicity (chemical

contamination).


Key issue 1 Impacts on the marine environment and ecosystem. High nutrient and phosphorus

concentrations in the wastewater can lead to algal blooms and algae blooms can be

toxic to aquatic species. The levels currently to not meet EPA Standards, how is

doubling capacity going to improve those levels?

Key issue 2 Public Health Risks for primary contact recreational users and health risks associated

with aquatic foods consumption. Loss of aesthetic enjoyment of amenities through

litter pollution, discoloured waters and dirty foam.

Key issue 3 Wannon Water does not seem to be able to manage the loads that come into their

plant or what their industrial trade waste customers are putting into the system. This

mismanagement has led to mixed liquor decants into the ocean which have negative

impacts on the environment and public use.





below.


Explanation See attached 242241 Explanation.doc







Archive.zip



submissions



Postcode 3280


proposed operations

Medium


and monitoring

Very high



Very high





Policy

Very high



treatment

Medium





water quality at ocean outfall has been constantly bad over the last 3 years from my

personal observations during regular activities such as cleaning Shelly beach of

plastic. where observations of grey scum can be seen and smelt. Rock pools contain

scum litter and algae blooms. also there has been golf ball sized fat balls washing up

on the beach. And ricotta cheese like incidents washing onto the beach which

creates a feast for sea gulls, crows and fox's. the beach has a resident family of 3

sooty oyster catchers and occasional hooded Plovers that I worry about with the

extra predators attracted to the beach. When I look at the reef where the outfall

discharges it is often brown murky foamy water which concerns me. The outfall

smells bad, some times I can smell the same smell from my house.







gas emissions

Medium




Noise amenity Low




Waste Low










Key issue 1 plastic debris management.

Key issue 2 water quality/safety for the environment including the Homo sapiens that use the

area.

levels of Ecoli, other bacteria and virus. extra nutrients ,P, put onto an ocean reef and

beach system.

Key issue 3 water authorities continued practise of deceit, lies, personal to my self and my

community . there inability to acknowledge problems with the system which then

leads to no solving of the problems.

EPA's inability to reply to my emails or phone calls 2017 causing me to give up on

them.

EPA's office being so far away from Warrnambool.





below.


Explanation I understand that the expansion needs to go ahead to accommodate the growing

demand.

I have no confidence in the water authority or the EPA.

I want tertiary class A+ water treatment to be added to the waste water treatment

plant and I want the state government to pay for it.

I want Class A+ Standard clean water for my environment , the ocean, the Golf

course , local sports fields, industries , and agriculture.







‐



submissions



Postcode 3280


proposed operations

Low


and monitoring

Low



Low





Policy

Sustainability Low


treatment





Amount of plastics and other contaminants entering the ocean environment is

unacceptable.





Wannon Water should be looking for best practice solutions that incorporate the

newest technologies available.



gas emissions

Medium




Noise amenity High



Waste Very high











Key issue 1 Dumping waste into the ocean that contaminates the environment.

Key issue 2 Not using current technologies to improve waste management.

Key issue 3





below.


Explanation The proposal utilises antiquated technologies that have been proven not to work.

The risk to the environment is not acceptable anymore.







‐



submissions



Postcode 3281


proposed operations

Very high


and monitoring

Very high



High





Policy

Very high



treatment

Very high





My main concerns is that this expansion does not involve a major upgrade to

treatment processes and thus will continue to allow discharge of micro plastics, litter

such as cotton buds and high levels if some pollutants into the ocean.





The potential health impacts of sewage discharge into the ocean close to areas near

high levels of recreational use including swimming and surfing. Particularly during

frequent high volume events when it appears from the colour and smell of discharge

water that treatment of all sewage is not occurring.



gas emissions

Very high




Noise amenity Low



Waste Very high





Impact if discharged micro plastics, litter, fat bergs and pollutants on the marine

environment. I would like to see this better understood, especially close to the

outfall, including the rock pools.






Health impacts on recreational users of this area and the impact of the smell of

sewage on land based recreational users. It is not a nice place to walk during a smelly

discharge event.


Key issue 1 The discharge of micro plastics, litter and polluters into the ocean is no longer

considered ok by the majority of people. I believe the EPA should consider how best

to eliminate these types of discharge into the environment. The EPA should be

working with wannon water towards ending sewage ocean outfalls and towards

recycling all wastewater.

Key issue 2 The security of drinking water supply cited in the fact sheet relies heavily on drawing

water from the Otways. The impact of drawing ever larger amounts of water from

these rivers is bound to be impacting the health of these systems. The EPA should

consider impacts to these water sources when deciding to allow wannon water to

continue to release potentially recyclable water into the ocean Instead if reusing it

and thus reducing reliance on the Otways for water.

Key issue 3 This proposal appears to be an expansion of capacity without a major upgrade if

processes and technology. The EPA should consider the long term outcomes and

require wannon water to increase the treatment standard of water discharged into

the ocean or to work towards no ocean outfall in the future rather than allowing a

simple expansion.





below.


Explanation I believe more needs to be done to improve the quality of water before it is released

to ensure no discharge of micro plastics, litter or pollutants into the ocean. I believe

this is an opportunity to work towards recycling wastewater and eliminating the

ocean outfall. If this opportunity is missed it may be many years if continued

discharge if litter ave micro plastics before another opportunity to rectify these

problems arises.







‐



submissions



Postcode 3280


proposed operations

High


and monitoring

High



High





Policy

High

Sustainability High


treatment

High











gas emissions

Medium







Waste High











Key issue 1 Please see our attached letter

Key issue 2

Key issue 3





below.


Explanation Please see our attached Letter.







EPA_WW_submission.docx



submissions


Date Submitted Jul 01, 2020, 01:08 PM

Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Wannon Water has declined to institute a full tertiary treatment facility (world's best practice) based

on the economic cost of such a facility. From this understanding, I expected a full and open economic

analysis to have been instituted, completed and further, be available for public scrutiny. I have asked

for full documentation regarding the economic analysis, only to find that such analysis has simply not

been done. The response from Wannon Water to me upon request of the said documents was ...

"Wannon Water has not submitted an economic evaluation of a tertiary treatment facility to the EPA.

We investigated potential options for what such a facility may look like and used high level costings

taken from across the water industry to obtain approximate capital construction costs. Information on

the cost of tertiary treatment can be found on the Warrnambool STP Upgrade Project web page. Our

costings align with those contained in the Clean Ocean Foundation report Coastal Outfall System

Upgrades in Australia 2019 which identifies the Warrnambool STP as being one of the worst prospects

in Victoria for an upgrade to tertiary treatment."

Given the nature, scope and time frame of the project, this is totally inadequate and provides

significant justification for a complete review of the entire approach. The prime argument used by

Wannon Water for the lack of use of full tertiary treatment is the economic cost of the facility. It is

thus incumbent on them to complete a full, and frank economic assessment directly related to the

significant local issues, not to use broader comparisons that are likely to not apply in this instance.

Worryingly, the failure to comply with world's best practice based on an unjustified economic

argument is potentially a cost shifting exercise to the community through damage to local fishing

grounds, damage to the significant marine sanctuary and threatening the health of the local

community that widely uses the coastal regions immediately adjacent to the outfall.








gas emissions

Very high




Noise amenity



Waste Very high










Key issue 1

Key issue 2

Key issue 3





below.

Explanation







‐



submissions



Postcode 3282


proposed operations


and monitoring







Policy

Sustainability


treatment











gas emissions




Noise amenity



Waste











Key issue 1

Key issue 2

Key issue 3





below.

Explanation







EPA_‐_WWSTP.pdf



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



High





Policy

Very high



treatment

Very high





Refusal by authorities to adopt technical changes to current systems as

recommended by experts





Refusal by authorities to consider alternatives to current systems as suggested by

experts



gas emissions

High







Waste Very high





Impact on marine animals and birds






Impact on human health


Key issue 1 My first key issue is that the current procedures and technologies whereby

Warrnambool's waste is discharged into the ocean have a serious detrimental effect

on the health of the ocean itself, on human health, on marine animal health, and on

bird health. I believe this is indisputable considering all of the available research. I

believe there should be an extensive and independent study into whether it is

possible to create systems whereby all of Warrnambool's waste, or at least part of it,

is disposed of other than into the ocean. This study should consider whether the cost

should in some measure be borne proportionate to use. If the current system is to

remain, then there should be specific changes to current procedures and

technologies as recommended by the experts.

Key issue 2 My second key issue is the suggestion that the new proposals represent an upgrade.

I believe this is inaccurate, and deliberately so. In fact I believe that the new

proposals are simply an expansion, without any major beneficial changes, thereby

increasing the existing problems rather than reducing them.

Key issue 3 My third key issue is the resistant and obstructive stance being adopted by the

relevant authorities including State Government, Wannon Water and the EPA. I

believe the problems are patently obvious, and that there are solutions that can be

found with the assistance of independent experts. I wish the authorities would

change their attitude in three ways: firstly, by acknowledging that serious problems

exist and that change is necessary; secondly, by agreeing to enlist the assistance of

independent experts to find solutions; and, thirdly, that they have realised that the

interested and informed community want change.





below.


Explanation For reasons given







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





The CEO of Wannon Water always told me after the great nurdle pollution event of

2017 that the upgrade of the plant would be worlds best practice and what is on

offer is just an expansion of the existing failing technology.





All of the community consultations have happened before the great nurdle pollution

event of 2017 so accordingly the proposed works doesn't account for this incredible

class 2 state emergency



gas emissions

Very high







Waste Medium





Why The EPA has allowed such a weak licence to be granted in the first place






Why make it so hard for the public to submit their concerns on such a significant long

term project


Key issue 1 Micro plastics escaping through the screens 1 mm aperture at the ocean outfall

Key issue 2 Why are the local industries allowed to put in trade waste that has such high

concentrations of N and P, why doesn't the EPA force them to treat it on site like

other businesses have to. I'm thinking Saputo as a business that is allowed such a

loose disposal licenced arrangement

Key issue 3 How is it that Wannon Water can self regulate their own adherence to the EPA

licence. How many times has their been an incursion and they haven't reported it to

the EPA? Does the EPA regularly audit the paper work at the waste water treatment

plant and does the EPA let these results be made public. It's always tough having one

govt agency regulating another govt corporation





below.


Explanation Just make the proposal world best practice. Become a leader in the world of waste

water treatment and show how micro plastics can be better managed in the effluent

stream







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Wasted nutrients





Ocean pollution



gas emissions

Very high




Noise amenity Low



Waste Very high





Harm to wildlife







Key issue 1 Effluent should not be pumped out to sea. This is harming our marine environment.

Key issue 2 All nutrients should be retained on land and returned appropriately to the soil. This

would complete the nutrient cycle and minimise waste

Key issue 3 Greenhouse gas emissions need to be minimal. We need to set an example of how

to best manage our sewerage, creating a system we can be proud of.





below.


Explanation I think the existing plant is inappropriate. It is not satisfactory to pollute the marine

environment and waste important nutrients.

I have heard the the Water Factory in Gippsland is a far better model.

I would like to see us come up with a completely new idea for Warrnambool, one

that we can proud of for setting the best example of sewerage management.







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Medium



treatment

Very high





Please see attached letter.







gas emissions

Very high







Waste Very high





Please see attached letter.







Key issue 1 Please see attached letter.

Key issue 2

Key issue 3





below.


Explanation After carefuI consideration I do not support the proposal, as I believe it is not

possible to support it in its current form modified by conditions. As discussed in my

atached letter, the starting premise is incorrect as Wannon Water effectively wants

to double the capacity of the STP using an already out‐dated technology.

I believe the best approach is to start with a model where the STP is updated so that

there is no discharge of any pollutants to the ocean, and to work out how the

increased capital expenditure can be funded on a user pays basis.







EPA_submission_on_Wannon_Waters_STP_1.7.2020.docx



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





Low quality of effluent being discharged.

Effluent discharges are increasing in volume ‐ and although improvements to

screening have been made along with extra holding tanks ‐ effluent is not being

membrane filtrated, disinfected or chemically treated.

Upgrade works do not address SEPP (waters) parameters for phosphate levels.

Microplastics and particles less than 1mm remain a concern.





No Plan B.

Emergency Management Plans do not effectively address effluent that has left the

site ‐ it cannot be contained once discharged.

Human error, equipment failure and unforseen circumstances happen ‐ a discharge

into sea of toxic waste is an environmental and social disaster.



gas emissions

Very high







Waste Very high






Human health risk.

Contact with contaminated waters, air, dust particles, ingestion of seafood.

Unassessed risks to public recreational users and domestic neighbors from contact

with effluent,

including chemicals used in treatment, airborne disease, algae blooms, microplastics,

and potential infections from developing human/animal diseases, increasing

medication levels in waste (prescribed and illegal drugs), antibiotic resistant

organisms, fungal and bacterial infections. The nature of waste is changing, and the

infection control issues remain high risk.





Site Location unsuitable for long term use.

Sewage Treatment Plant site is no longer in an appropriate area for 21 century.

Upgrade will result in 50% increase in footprint in a coastal area of native vegetation,

indigenous significance, archaeological interest, tourism development, expanding

housing development and increasing recreational use.

STP is in an environmental spotlight ‐ on the coast, in an area of outstanding natural

beauty, that joins reserve areas ‐ Belfast Coast Reserve, Merri River wetlands, Merri

River Marine Sanctuary. Include the seasonal wildlife we aim to protect ‐ penguins

and whales. Warrnambool is close to the Bonney upwelling and subject to

seasonally elevated nutrient levels in seawater.

This site was chosen in the 1930's, and has outlived its time.


Key issue 1 Public Safety.

STP too close to public access areas, proximity to residential housing, increased

transport of dry waste through developed residential areas, increased effluent

volume, unknown contaminents in effluent, changing profile of waste, unknown risks

to public health.

Key issue 2 Environmental Impact.

Too many variables effecting effluent discharge and quality (dry flow rates, lack of

reduction of mixing zone, effluent quality, industry growth demands) combined with

a poor recent track record for compliance ( Pollution Abatement Notice via EPA Feb

2020).

Emergency Management Plan ‐ ineffective containment strategies following

incidents, including previous cleanup of coastal sites after episodes of effluent

overflow and screen failures (fatballs, plastics, nurdles)

Ocean discharge is not the best solution for this community ‐ aquaculture, ecological

and biological risks.

+


Key issue 3 Lack of improved treatment technologies.

Expanding existing systems only addresses the short term effectiveness of STP by

increasing capacity. Upgrades of technology are lacking.

What is the point of putting in minor changes to infrastucture without improving

process, to push the area to the limit within another 20years?

Cost issues, trade waste costs, user pays systems etc. could be further discussed with

community if this is the main deciding factor in Wannon Water's application.





below.


Explanation Proposal lacks improvements required to make positive long term change to sewage

treatment for the areas of Warrnambool, Koroit and Allansford.







‐



submissions



Postcode 3280


proposed operations


and monitoring







Policy

Sustainability


treatment











gas emissions

High







Waste High











Key issue 1 1.WHERE DOES THE SEWAGE GO WHEN THE PLANT FAILS

Treatment is biological and subject to fluctuations in bacterial populations and death of bacteria due

to the presence of various toxins in the influent. Treatment failure may be partial leaving the sewage

itself partially treated. There is no capability for this plant to hold up a significant volume of sewage

for retreatment. Such a withholding system is necessary to be able to handle bacterial population

fluctuations.

Power failures can also lead to treatment failure. Using a bypass system in this case is risking the

health of the local residents and the ecology. A temporary storage should be considered.

2.HIGH NUTRIENT DISCHARGE RISKS ALGAL BLOOMS

Phosphorus concentrations from the Warrnambool plant are about ten times higher than for a similar

plant treating domestic sewage. This is a primary nutrient that will affect the receiving environment

leading to algal blooms that have been observed at the outfall. These algal blooms can be toxic to

aquatic species and have demonstrated the inability of Wannon Water to keep nutrient levels at a

suitably low level.

Wannon Water has stated that they do not meet the State Environmental Protection Policy criterion

for phosphorus outside the mixing zone of the effluent with marine water.

Phosphorus reduction in concentration and annual kg load should be a major focus of any treatment

upgrade plan.

3.PLASTICS CARRY TOXINS AND BACTERIA

Wannon Water has recognised the risk of plastic pollution (even though it is not a requirement of

their EPA discharge licence). However, they have not taken sufficient steps to reduce this plastic risk

in the effluent. The works approval plans provide a 1mm screen of the final effluent. This will catch

visible plastic pieces, but not the true micro plastics in the forms of fibre, nano particles, and other

fine plastic forms used in the home.

With the next stage of membrane filtration most of the offending plastics can be removed. This next

step was flagged for 2040, we don't believe we can wait until then to clean up the marine

environment.


Key issue 2 4.EMERGING POLLUTANTS ARE REAL

The works approval application pays no attention to emerging pollutants that we are

aware of but just not sure about their impacts. Items such as:

‐Fluorinated compounds (PFAS)

‐Organo‐chlorines ‐Disinfectants / biocides in personal care products ‐Nano‐par cles in personal care products

‐Pes cides


5.BACTERIA CAN BE DISINFECTED




6.RISKS NEED TO BE EVALUATED

Wannon Water presented their risk register but a more detailed assessment of the

risk of the outfall to our health and the ecology are required. All discharges to the

marine environment are subject to an Ecological Risk Assessment under EPA policy.

An ERA was not presented for this discharge to the ocean making it difficult to

evaluate the risk of greater discharge volumes as well as the levels of pollutants the

discharge ay contain.

Key issue 3 7.IT'S NOT THE CONCENTRATION IT'S THE LOAD

Wannon Water is proposing to increase the volume / flow of the effluent to the



receive a further 60% load in these pollutants. For instance the phosphorus load at

30mg/L will increase from 480 kg to 780 kg/day (mean limit). Despite any refence to

mixing zones this increased pollutant load has to be assimilated by the same

environment.



8.BETTER TREATMENT = BETTER OUTCOMES

The Warrnambool community can enjoy improved health and an improved

environment from the use of more advanced treatment technologies. The best

outcome for wastewater treatment is the ability to reuse this fresh water in a dry

land environment. Membrane filtration can allow wastewater reuse as is practised in

many coastal communities such as Phillip Island.

We believe that the Warrnambool community can benefit from a rethink of the


expanding the existing treatment systems.





below.



Explanation Wannon Water has submitted plans for its sewage treatment plant upgrade for

works approval by the EPA. We believe that these plans are insufficient to:

‐Protect the health of local residents who use the seaside for recrea on and fishing,

‐Maintain a healthy ecosystem at and near the ou all.

The works approval application uses high energy and high cost arguments to rule out

various treatment options that we believe are miss‐founded. The cost to us and the

environment of poor‐quality effluent leading to health and ecological degradation

are well beyond the costs in monetary terms. Energy should not be an argument in

that a conscientious organisation should be using renewable energy sources now to

avoid Greenhouse implications of energy use..







‐



submissions



Postcode 3280


proposed operations

Very high


and monitoring

Very high



Very high





Policy

Very high



treatment

Very high





I am wanting assurance that the treatment plant upgrade will focus on world's best

practice for water treatment. I don't want to see an upgrade that's used on the same

practises as is currently used and inadequate. I have observed time and time again

that the water around the outflow is discoloured, foamy brown and smelly. Our

beautiful marine sanctuary is slow close to the outflow and it is unacceptable that

contaminates could place this ecosystem as well as human health at risk. Why can

we not strive toward technologies that minimise disposing waste water into the

ocean? We need a system that can manage adequately if the system fails or gets

overloaded by a weather event. I am very concerned that the amount of effluent

discharged into the ocean with increase significantly over time with potentially even

more pollutants released. I am concerned about the phosphorus concentrations of

the waste water going into our ocean.





The industries that create the vast majority of the waste should be paying more

toward the plant upgrade so that the upgrade achieves world best practice and

future proof.



gas emissions

Low




Noise amenity Low




Waste Very high





I am concerned about the risk to human health from exposure to the effluent both

inside and outside the mixing zone for recreational users of this area via fishing,

diving, snorkelling and rock pooling.






Key issue 1 See explanation above.

Key issue 2 See explanation above

Key issue 3 See explanation above





below.


Explanation







‐

Documents

Warrnambool wastewater treatment plant Public submissions€¦ · Treatment is biological and subject to fluctuations in bacterial populations and death of bacteria due to the presence