Submissions

The Environment Protection Authority (EPA) draft revised Excavated Natural Material Resource Recovery Exemption (ENM Exemption) is attached.  The draft contains a number of welcomed amendments to the ENM exemption including:

  • Reduced sampling frequency for smaller volume materials
  • Removal of chlorinated hydrocarbons
  • Changes to metals and pH levels
  • Introduction of individual BTEX concentrations
  • Use of hot spot separations for in-situ sites

ASBG has prepared a submission which asks for faster and lower cost assessment of ENM materials at smaller quantities, i.e. < 500t. Recommended approaches include

  • On-the-spot testing by human senses and field testing equipment
  • Use of a reduced set of chemical testing where history can demonstrate certain tests are not required
  • Use of third parties to undertake on-the-spot testing for smaller ENM quantities
  • Use of maps to identify areas where certain testing must be undertaken and others where less testing is needed
  • A scientific testing criteria for asbestos

ASBG has lodged its submission on the Review of the Waste and Environment Levy, which is being led by KPMG.  With the demise of the levy in Queensland, there will soon be a such a price difference between Sydney and South East Queensland's landfills in a few years it will become economic to ship waste there.  This is one example of how the waste levy distorts the waste market and can create perverse environmental outcomes. ASBG also goes to some lengths to discuss the adverse impact on certain recycling such as steel and paper mills.  A 3 step process is presented which can address the negative impacts the levy is having on affected recyclers.  Waste infrastructure and illegal dumping are also discussed in this submission.

ASBG responded to the EPA's Environmental Guidelines: Publication of Monitoring Data which was legislated under the Protection of the Environment Legislation Amendment Act 2011. Under this legislation  Environment Protection Licence (EPL) holders with websites must publish their monitoring data or provide data to the public on request.

The Guidelines provide details of what is required in terms of presentation of monitoring data.  A key concern is the need for all the underlying data from an EPL  holding site.  Provision of such details, the explanation of why 'limits' can be legally exceeded due to measurement and other reasons will cause considerable confusion for the public and the media.  This will make the EPA's job of protecting the environment from a scientific basis more difficult.  ASBG considers exception reports should be sufficient to identify the issues the vast bulk of the public wishes to know. 

ASBG has responded to the EPA's Pollution Incident Response Management Plans (PIRMP): Proposed Amendments Under the POEO (General) Regulation 2009.Key issues addressed include:

  • Poor consultation and the by-passing of the RIS process for this regulation
  • Requirement to publicise PIRMPs on company websites is opposed for security, privacy and commercial in confidence reasons.
  • Testing requirements for PIRMPs needs to be clarified and permit simulations and desktop studies where appropriate.

PIRMPs are only one of a number of new changes attached to the POE Amendment Legislation Act 2011.  Website lodgement of monitoring data is the next issue for public consultation.

ASBG responded to the NSW EPA's Draft Landfarming: Technical Practice Notes citing the disproportionate emphasis on VOC emissions from such a miniscule source.

ASBG accepts that some landfarming practices may not well run and some controls may be required.  However, the landfarming notes require treatability tests to be undertaken for apparently all landfarms.  Where VOC emissions are considered by the EPA to be excessive they will need to be controlled using tents, greenhouse enclosures or covers.  ASBG is concerned the testing and performance requirements are not specified and acceptance is at the consideration of the regulator.

ASBG calls for a more holistic approach where the notes consider the material to be treated - bio-degradable hydrocarbons - and assess each available and economically viable option.  Clamping down on too hard landfarming is expected to simply transfer the problem to landfill or result in abandonment of remediation.  Ideally the outcome should be to maximise environmental outcomes than to focus on one treatment type.

 

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