annotated sbcs april 132013/04/17 · statutory process. nor did it engage to any great extent...

SBCS Sou thern Beaches

Conservation Society Inc.

- Tasmania

A Better Waste Management

Future for Tasmania

A Summary of research and information in

response to the proposed Copping C-Cell

Compiled by Southern Beaches Conservation Society Incorporated.

December 2012

For further information please visit: www.crcsbcs.blogspot.com or

email: [email protected]

Cover photo courtesy of Sea Urchin Design, Park Beach Tasmania

NOTE: Comments which are too long to display on the right hand side of the

page can be viewed in full at the end of this document.

Comment [cb1]: For facts visit

swstas.com.au

Table of Contents

Preface ............................................................................................................... 5

1.0 Government Policy and Regulation of Waste Management ............................... 7

1.1 Commonwealth Government .................................................................... 7

1.2 Tasmanian State Government .................................................................. 9

1.3 Landfill Sustainability Guide 2004 ............................................................10

1.4 Municipal Government Authorities ............................................................11

1.5 Other Local Government Authorities .........................................................11

2.0 The Approval Process ................................................................................12

2.1 Community consultation .........................................................................12

3.0 Environmental Impacts ..............................................................................15

3.1 Gas Emissions and airborne contaminants .................................................15

3.2 Surface and groundwater pollution ...........................................................16

3.3 The Carlton River Catchment...................................................................17

3.4 Flora & Fauna........................................................................................17

3.5 Geology & Hydrogeology.........................................................................19

a. Subsurface and surface characteristics .........................................................19

b. Sandstone Terrain .....................................................................................20

c. Slipping Substrate .....................................................................................20

d. High permeability soils/substrata.................................................................21

e. Buffer distance .........................................................................................21

f. Wetlands ..................................................................................................21

g. Flooding...................................................................................................21

3.6 Environmental Impact - Summary ...........................................................22

4.0 Community Impacts ..................................................................................24

4.1 Environmental Discrimination ..................................................................24

4.2 Copping waste disposal site location .........................................................26

4.3 Long term management, remediation and liability ......................................27

5.0 Economic Impacts .....................................................................................28

5.1 Economic Liabilities ................................................................................28

5.2 Economic benefits..................................................................................29

6.0 Science and Engineering ............................................................................30

6.1 EPA Risk Matrix .....................................................................................30

6.2 High & Low Density Poly Ethylene (HDPE /LDPE) ........................................31

6.3 Clay Liner .............................................................................................32

6.4 Further information about liners ..............................................................33 A Better Waste Management Future for Tasmania 3

6.5 Leachate collection and storage ponds ..................................................... 34

6.6 Alternative Waste Treatment Methods...................................................... 34

6.7 Science and Engineering - Summary ....................................................... 35

7.0 Antarctic Waste........................................................................................ 37

8.0 Waste Management Governance in Tasmania - The Way Forward .................. 39

8.1 Commonwealth Government .................................................................. 39

8.2 Tasmanian State Government................................................................. 39

8.3 Local Government ................................................................................. 40

8.4 Waste Levy .......................................................................................... 40

8.5 Landfill Bans ........................................................................................ 41

8.6 Waste Management Governance - Summary............................................. 42

9.0 Recommendations .................................................................................... 43

Version Control .................................................................................................. 45

4

Preface

The purpose of this document is to provide the reader with a summary of the

research undertaken by the Southern Beaches Conservation Society Incorporated

(SBCS), in response to the proposed Category C hazardous waste cell at Copping,

South East Tasmania.

On 19 June 2012 Sorell Council granted development approval for a proposed

Category C hazardous waste disposal facility next to the site of an existing Category B

facility, near the southern Tasmanian town of Copping.

The surrounding area is predominantly rural and the proposed site lies a short

distance from the Carlton River which discharges into Frederick Henry Bay, adjacent to

some of Southern Tasmania’s most popular recreation beaches and sensitive coastal

environs.

The site is immediately adjacent to the Arthur Highway, by which residents and

tourists travel to the Tasman Peninsular – one of the state’s main tourism

destinations, featuring World Heritage listed Port Arthur Historic Site, nature based

tourism, centred on the Three Capes Track and access waterways such as Frederick

Henry and Norfolk Bays.

The C-cells’ proponent Southern Waste Solutions (SWS), is a Joint Authority of four

southern Tasmanian local Councils – Clarence, Sorell, Tasman and Kingborough.

The public was generally unaware of the development application and its subsequent

approval until late August 2012. Once the public became aware of the proposed

development a swell of opposition arose, resulting in a petition of some 1700 local

residents being presented to Sorell Council.

Opposition to the proposal is multi-facetted and ranges from:

• concern over the development approval process;

• lack of public consultation during the approval process;

• concerns over the suitability of the site;,

• questions regarding the science behind the design of the C Cell;

• questions as to appropriateness of landfill as a method of dealing with

hazardous waste;

• the impact of the transportation of hazardous waste on the community and

infrastructure; and • risks to both population and environment as a result of a possible failure of

the C cell.

This high level of community concern resulted in the formation of the SBCS and

undertaking of the research and collation of the reference material contained in this

document.

Members of the SBCS undertook their own research to better understand the nature of

the proposed C-cell. Reference information has been exchanged between members,

posted to the SBCS BlogSpot and shared electronically, establishing a comprehensive

shared knowledge base.

The research covers how the C-Cell came to be sited where it is proposed; analyses

the questionable science on which the design of the C-Cell is based and explores

alternatives that will provide better economic, health, social and environmental

outcomes.

A Better Waste Management Future for Tasmania 5

Comment [cb2]: The public was

disinterested and did not respond to

offers of briefings despite efforts

beginning one week before the

statutory process. Nor did it engage to

any great extent during the statutory

period. Comment [cb3]: The local paper

printed a story full of inaccuracies. It

listed 10 items on the front page and

displayed logos indicating 2 others.

None of the 12 will be accepted in the

C cell. Comment [cb4]: The process

satisfied all statutory requirements. Comment [cb5]: Consultation was

in excess of that required by statute. Comment [cb6]: Concerns raised by

members of the community have all

been answered. They are generally

based on a lack of knowledge of the

science underlying the development.

It would be difficult if not impossible

to find a more suitable location in

terms of geology, geography etc. Comment [cb7]: The proposal has

been developed and independently

assessed by professionally qualified

and experienced scientists and

engineers, not by Google and

Wikipedia. Comment [cb8]: Landfill is

recognized as a last resort. There is

currently no economic means of

extracting further value from the

material destined for the C cell.

Technology will change and resources

will become more scarce, at which

time the material can be extracted

from the cell and re processed. Comment [cb9]: An average of 5

additional trucks per day or 10 traffic

movements on a highway with an

average of 3,300 – ie 0.3%. Comment [cb10]: There is more

risk from the regular transport of

liquid material including petrol and

gas. A road traffic accident with full

fuel tanks poses more risk to the ... [1]Comment [cb11]: This comment is

not based on fact. The material that

will be accepted by the C cell is

currently largely not contained and in

many cases lying on our river banks. ... [2]Comment [cb12]: The science

underpinning the C cell is not

questionable. The conclusions of

amateurs not professionally qualified

in relevant fields is what is ... [3]

Our research supports the view that the Copping C-cell is flawed on many levels

including:

• it is poorly sited for reasons of geology, hydrology and proximity to sensitive

environments;

• that ‘world’s best practise’ waste management strategies unanimously view

landfill as the least preferred method of waste management and one that

should only be considered after alternative strategies have been explored and

exhausted; and

• placing hazardous waste in landfill directly undermines the National Waste

Policy which informs each Australian State Government policy including the

Tasmanian Waste & Resource Management Strategy.

In approving the development application for the proposed C-cell development,

Sorell Council has committed its constituents to a long term, high risk proposition,

with responsibility for all Tasmania’s category C hazardous waste as well as waste

from Australian and Foreign territories in Antarctica.

The proposed Copping C-cell will condemn Tasmania to continue its’ inadequate and

embarrassing past record of waste management.

It is a project that is likely to have poor environmental outcomes into the future and

one that undermines the economics of alternate waste stream pathways which lead to

better outcomes such as reuse, recycling and reprocessing.

It will create a cheap means of disposal of hazardous industrial waste which will

ultimately become the responsibility of local ratepayers as the business is a local

Government joint authority, and not the responsibility of the waste producers.

SBCS remains steadfast in its opposition to the proposed Copping C-Cell and believes

that the arguments against the C-cell proceeding are compelling. We encourage all

individuals and organisations to inform themselves and to assert whatever influence

they have to ensure that the current proposal is halted until further exploration of

alternative strategies have been thoroughly and independently explored.

SBCS also calls on the Tasmanian Government to develop and adopt a state-wide

hazardous waste strategy for Tasmania, building on the recommendations included in

the ‘Current and Future Controlled Waste Practices in Tasmania Draft Report’,

produced for the Government in 2008 by Sustainable Infrastructure Australia.

A full list of reference materials used in this document can be freely accessed at

www.crcsbcs.blogspot.com

6

Comment [cb13]: A geologist with

more than 100 hours of work on the

specific site concludes that the site is

eminently suitable. This conclusions

includes hydrology. Comment [cb14]: The C cell is 1.75

km from the Carlton River. The

recommended (Landfill Sustainability

Guide) buffer distance between a C

cell and a permanent watercourse is

100 m. It is approximately 750 m from

a normally dry unnamed tributary. It is

more than 2 km from the nearest

residence. The recommended buffer

distance is 500 m. A similar cell has

been operating in suburban

Melbourne for some years. It is

approximately 500m from a

residential suburb. Comment [cb15]: This is actually

correct. The material destined for the

C cell does not have any other ... [4]Comment [cb16]: In fact this

project is in conformance with the

policy. It places a price on this ... [5]Comment [cb17]: The risk is low.

The cell is engineered to ensure this. Comment [cb18]: There is no such

thing. Waste is classified as level 1,

level 2, level 3 or level 4. The C cell will ... [6]Comment [cb19]: The reverse is

the case. Tasmania is the only state

without one of these facilities and our ... [7]Comment [cb20]: This comment

fails to acknowledge that the main

purpose of the C cell is to clean up ... [8]Comment [cb21]: The cell and its

operation are designed to allow

extraction and re processing as ... [9]Comment [cb22]: Gate fees will be

commercial and recover the full

lifecycle cost of storing and looking ... [10]Comment [cb23]: The gate fee will

include a component for a trust fund

to monitor and manage the site ... [11]Comment [cb24]: SWS has offered

to show the site to members of the

community to help to allay their ... [12]Comment [cb25]: SWS encourages

this also. Facts are available at

swstas.com.au Comment [cb26]: This report

recommends construction of a C cell.

The Government has established a ... [13]

1.0 Government Policy and Regulation of Waste Management

All levels of Government play an important role in the regulation and oversight of

waste management.

The Commonwealth has created a policy framework that underpins effective waste

management and informs good practice.

The State Government provides the legislative framework for waste management and

local government actively involves itself in residential waste collection, transfer and

disposal.

Following on with this, all levels of Government are guided in principle by the waste

management hierarchy, yet the Tasmanian State Government and especially Local

Governments are often poorly placed to provide waste recovery, reprocessing and

recycling infrastructure that effectively diverts waste from landfill, as is dictated by

any genuine adherence to the waste management hierarchy.

A new paradigm in waste management requires that waste itself is seen as a

resource and not something that has no economic value.

Under such a perspective, discarding waste to landfill should be avoided until all

other options have been explored and exhausted.

1.1 Commonwealth Government

The Commonwealth government released the first incarnation of a national waste

policy in 2009, titled National Waste Policy: Less Waste, More Resources.1 This

policy represents a significant milestone in waste management in Australia.

The policy established an Australian waste framework over the next 10 years with

the following aims:

• To avoid the generation of waste, reduce the amount of waste (including

hazardous waste) for disposal, manage waste as a resource and ensure that

waste treatment, disposal, recovery and reuse is undertaken in a safe,

scientific and environmentally sound manner

• To contribute to the reduction in greenhouse gas emissions, energy

conservation and production, water efficiency and the productivity of the

land.

The key central plank in the policy that informs much of the stated strategies is the

Waste Management Hierarchy.

1 National Waste Policy, Department of Sustainability, Environment, Water, Population and Communities:

http://www.environment.gov.au/wastepolicy/index.html


Comment [cb27]: Putting a price

on the appropriate disposal of level 3

material will ensure that the user

pays, and encourage producers of this

material to look at better processing

options to reduce the amount of level

3 material that they produce. Comment [cb28]: This is why the C

cell is designed and will operate to

facilitate the extraction and

reprocessing of material as technology

changes and as resources become

more scarce. Comment [cb29]: The C cell is

primarily a temporary storage facility

rather than an end solution. Comment [cb30]: As stated above

the C cell allows for future re

processing of the material stored

within it. Comment [cb31]: The C cell is in

line with this policy. In fact it would be

difficult for Tasmania to comply with

the policy without a C cell. Comment [cb32]: As stated

previously the C cell is necessary to

achieve these aims. It ensures that

producers of level 3 waste (and

consumers of the related products)

pay a commercial price to

appropriately store and look after the

material. This provides an incentive to

change future production methods to

reduce the amount of level 3 material

produced. Comment [cb33]: The material to

be stored in the C cell will not produce

greenhouse gas emissions. Comment [cb34]: Access to a

Tasmanian C cell conserves energy

and reduces use of fossil fuels (used in

transport) by significantly reducing the

transport distance.

The diagram following illustrates the underpinning management goals of the Waste

Management Hierarchy.

Established in 2001, prior to the 2009 National Waste Policy, the Environment

Protection and Heritage Council (EPHC) of Australia and New Zealand was tasked

with addressing national policy issues relating to environmental protection.

The EPHC utilised National Environmental Protection Measures (NEPMs) which

outline agreed national objectives for protecting the environment.

Specifically, there exist two NEPMs in relation to waste management, namely:

a) Movement of controlled waste between states and territories; and

b) Used Packaging materials

Of particular interest to a), the National Waste Policy 2009 states:

‘Agreed national principles, guidelines and standards to remove impediments for effective markets for potential wastes, is necessary to deliver on the policy’s overall

aims.’2

It is clear from this that the National Waste Policy 2009 supports the trans-boundary

movement of waste where economies of scale permit management of waste according

to best practice under the waste management hierarchy.

2 Implementation Report 2011 – National Waste Policy: Less Waste More Resources, Department of

Sustainability, Environment, Water, Population and Communities, 2011

8

Comment [cb35]: The impediments

to which this refers primarily included

matters such as waste carriers not

being recognized in multiple

jurisdictions, causing problems in

transporting across state borders. Comment [cb36]: The NEPM does

not encourage trans-boundary

movements. It regulates them. SWS

understands that the majority of

interstate jurisdictions (other than

Queensland) are preparing to close

their C cells to material from other

states.

1.2 Tasmanian State Government

The main statutory instrument for environmental protection, including issues arising

over waste management, in Tasmania is the Environmental Management & Pollution

Control Act 1994 (EMPCA)3.

In 2008 the Environmental Protection Authority (EPA) was established to take statutory

responsibility of the EMPCA in conjunction with the Environment Division of the

Department of Primary Industry, Parks, Water and Environment.

In June 2009, the State Government introduced the Tasmanian Waste & Resource

Management Strategy 20094. The strategy established a framework of objectives for

solid waste management and resource recovery.

The strategy’s guiding principles were heavily influenced and informed by the

National Waste Policy 2009 and include:

• managing waste in line with the Waste Management Hierarchy;

• environmental stewardship to reduce adverse impacts;

• the Precautionary Principle;

• Life Cycle assessment; and

• Polluter Pays / User Pays Principle.

A further outcome of the introduction of the Tasmanian Waste & Resource

Management Strategy 2009 was the concurrent establishment of the Waste Advisory

Council (WAC). Industry and Government representatives sit on the board of this

entity.

The role of WAC is to oversee implementation of the strategy, report on progress

and achievements of the strategy and provide relevant recommendations to the

state government. WAC reports to the EPA.

In order to provide statutory control, monitoring and enforcement of general and

controlled waste in Tasmania, an amended version of the Environmental

Management and Pollution Control (Waste Management) Regulations, passed into

legislation in 2010.

Accompanying these waste management regulations, Environmental Management

and Pollution Control (Controlled Waste Tracking) Regulations also passed into

legislation in 2010. They are designed to monitor movement of hazardous waste

from point of generation to final location of waste management.

The State Government first foreshadowed these regulations in 2004. They were

drafted in 2007, passed through parliament into legislation in 2010. These

regulations were to be supported by the establishment of a Controlled Waste

Tracking System, administered by the EPA. This program has been subsequently

been exempted and has not come into force due to budgetary restraints within the

EPA, leaving proper auditing and tracking of controlled waste in Tasmania poorly

monitored.

3 Environmental Management and Pollution Control Act 1994 (EMPCA), Department of Primary Industries,

Parks, Water and Environment: http://epa.tas.gov.au/policy/empca 4 Tasmanian Waste & Resource Management Strategy, 2009, Department of Primary Industries,

Parks, Water and Environment:

http://epa.tas.gov.au/Documents/Tasmanian_Waste_and_Resource_Management_Strategy.pdf


Comment [cb37]: Environment

Protection Authority. Comment [cb38]: It is actually the

EPA division. Comment [cb39]: 2009? Comment [cb40]: None of these

can be put in to effect without a C cell.

Refer to comments below. Comment [cb41]: The C cell

facilitates this. Comment [cb42]: The C cell also

facilitates this. It is designed to

appropriately store legacy waste that

is currently not appropriately

contained, often on our river banks. It

will also ensure appropriate and

indefinite management and

monitoring of material in the cell by

establishing a trust fund. Comment [cb43]: All material must

first be tested by an independent

NATA accredited laboratory against 32

potential contaminants (and be below

pre-determined levels for each) and

be approved by the EPA prior to

delivery to the C cell. Comment [cb44]: The C cell will

ensure that producers factor in an

appropriate component for managing

its by products in to the future. Comment [cb45]: The C cell

facilitates achievement of this by

putting a price on level 3 material,

ensuring that users of related

products will pay and that producers

will look at ways to minimise the

amount of this material that they

produce. Comment [cb46]: It is a Committee

not a Council. Comment [cb47]: It is a Committee

not a Board and it also includes

representatives from the community

and local government. Comment [cb48]: The WAC is fully

aware of the C cell and supports it.

In 2008, the Department of Economic Development released a draft report on

Controlled (Hazardous) Waste in Tasmania5 prepared by Sustainable Infrastructure Australia (SIA).

The report assessed the current status of controlled waste management and

discussed a business case and feasibility study for controlled waste management

facilities in Tasmania.

The report made a number of recommendations in relation to specific hazardous

waste management facilities and technologies that would divert waste from landfill in

line with the waste management hierarchy.

The State Government has never formally responded to the report or implemented

any of the recommendations contained in the report.

1.3 Landfill Sustainability Guide 2004

In 2004 the Tasmanian Government introduced the Landfill Sustainability Guide6

which superseded the draft Tasmanian Landfill Code of Practice.

The aim of the Sustainability Guide is to provide a consistent and effective

framework for minimising environmental impacts arising from the siting, design,

operation and rehabilitation of landfills in Tasmania.

The objectives of the Sustainability Guide are to:

• help developers establish and manage land-filling activities in compliance

with environmental legislation and policies;

• promote consistency in the regulation of landfills in Tasmania;

• clearly identify the issues that need to be managed and options for their

management;

• inform industry and the community of acceptable standards for landfills;

and

• encourage high level land-filling standards based on the most effective,

affordable and innovative mix of mechanisms available

The Sustainability Guide is designed to help landfill operators achieve good

environmental performance.

While the Sustainability Guide itself is not a legally enforceable document, permit

conditions (which are legally enforceable) are likely to be derived from the

acceptable standards and recommendations described within the Sustainability

Guide.

5 DRAFT REPORT: Current and Future Controlled Waste Practices in Tasmania, Sustainable Infrastructure

Australia, 2008

6 Landfill Sustainability Guide 2004, Department of Primary Industries, Parks, Water and Environment:

http://epa.tas.gov.au/Documents/Landfill_Sustainability_Guide_2004.pdf

10

Comment [cb49]: This report found

that Tasmania does not have landfills

‘that are fully compliant with modern

best practice for ‘secure’ landfills. Lack

of adequate facilities may result in

significant costs to Tasmanian

businesses and may impede economic

expansion for the State.’ The C cell is

such a facility. Comment [cb50]: The C cell is one

of the recommendations and it is

being implemented.

1.4 Municipal Government Authorities

Historically, solid waste, both residential and commercial, has been a responsibility of

Local Government.

The responsibility in relation to the commercial and industrial sector diminished a

number of decades ago, leaving residential municipal solid waste (MSW) as Local

Governments’ primary concern.

As is typical in Tasmania, three regional Local Government authorities have been

established to facilitate integrated regional strategic planning and implementation of

waste management strategies. These are:

Southern Waste Strategy Authority (SWSA) SWSA was established in 2001. It is comprised of 12 member councils from the

Southern region. SWSA states publicly that its waste management strategy is

underpinned by the Waste Management Hierarchy.

Northern Tasmania Waste Management Group (NTWMG)

NTWMG was formed in 2008. It represents 8 member councils from the Northern

region. The NTWMG is currently guided by a 5 year strategy (2009 – 2013) which

includes the aim of reducing Commercial and Industrial (C&I) and Construction and

Development (C&D) waste to landfill.

Cradle Coast Waste Management Group (CCWMG)

CCWMG was established in 2004 and represents the 9 member councils of the

region. The CCWMG is also currently guided by a 5 year strategy (2009 – 2013)

which includes the aim of reducing C&I and C&D waste to landfill.

1.5 Other Local Government Authorities

Copping Refuse Disposal Site Joint Authority

Trading as Southern Waste Solutions (SWS), the Copping Refuse Disposal Site Joint

Authority is a Local Government Authority established in partnership by Tasman,

Sorell and Clarence Councils in 2001. Kingborough Council joined the business

enterprise in 2009 however the three original councils remain the owners of the

Copping landfill site.

The rules of the Authority commit the participating councils to use the Copping landfill

as their principle waste management facility. Total lifespan of the landfill site is

thought to be around 200 years.

SWS also operate a clinical waste treatment plant at Lutana in greater Hobart. The

waste treated here (by shredding and the addition of lime) is then transported to

Copping for disposal at the pre-existing class B-cell landfill.

SWS are the sole proponent for the proposed Category C-cell at the Copping site.

The initial facility is set to accept up to 300 000 tonnes of ‘spade-able’ category 3

hazardous waste, much of it heavy metal laden. Preliminary approval for an

equivalently sized second cell adjacent to the first has been granted. SWS have a

financial interest in maximising revenue by maximising waste disposed to landfill.

This is in opposition to the waste minimisation and waste management hierarchy

espoused by the National Waste Policy and the Tasmanian Waste & Resource

Management Strategy.

Dulverton Waste Management


Comment [cb51]: It still is the legal

responsibility of local government. Comment [cb52]: There is private

sector involvement in collection but

disposal remains the responsibility of

local government. Comment [cb53]: Each of these

Authorities supports the Copping C

cell. Comment [cb54]: The C cell

facilitates this by putting a price on

level 3 material, encouraging

producers to look at reducing the

amount that they generate. It is also a

temporary storage facility – material

will be removed and reprocessed as

technology changes and as resources

become more scarce. Comment [cb55]: Clarence City

Council. Comment [cb56]: It is unclear who

thinks this. The original landfill

Development Proposal and

Environmental Management plan

(DPEMP) envisaged a life of around

100 years if it accepted waste from

the southern region. Changing permit

requirements may see this figure

reduce considerably. Comment [cb57]: It is actually

cubic metres, not tons. Comment [cb58]: Concentrations

as defined for level 3 waste (EPA

Bulletin 105) are actually relatively

low, which is why it is not currently

economical to extract more metal

from it. Comment [cb59]: This is not true.

Such approval has neither been

sought nor granted. Any additional C

cell would be subject to the full

statutory evaluation and approval

process. Comment [cb60]: SWS is not

creating waste to fill its C cell. The

waste is already on the ground.

Putting a commercial gate fee on such

waste will encourage minimization in

future.

Dulverton Waste Management is a local government authority established by the

Central Coast, Devonport, Kentish and Latrobe councils. A landfill and organics

processing facility at Railton is operated by the authority.

2.0 The Approval Process

The Category C-Cell was approved by both the EPA and Sorell Council within one

month.

• Public submissions to Sorell Council regarding the development application

closed on 20 May 2012

• Council granted final approval for the development on 19 June 2012

• The EPA granted approval for the development of a Category C-Cell at

Copping landfill site in just three days: the EPA received the Development

Application and Environmental Management Plan (DPEMP) from Sorell

Council for approval on 5 June 2012 and subsequently granted the

development approval on 8 June 2012

This is an extraordinarily short turnaround for a development approval, given the

complex, highly technical and high risk nature of the proposal; and also for the simple

fact that this is the first development of its kind in Tasmania. The timeframe could not

possibly have allowed due time for careful and detailed consideration of all aspects of

the application, by both the EPA and Councillors!

Furthermore, thorough community consultation and engagement regarding the project

was almost non-existent, as can be evidenced by the verified account7 of Mr Paul Reardon who was one of the original formal objectors to the proposed development.

Importantly, the Landfill Sustainability Guide 2004 notes that Community liaison should be conducted throughout the life of all landfills, commencing during site

selection to ensure local communities are informed and aware of the proposal. Community liaison should be conducted in an open and timely fashion, and allow

local knowledge to be obtained.’8

Two members of the public submitted formal objections to the development. Neither

of these people was notified by Sorell Council of the date when the development

application for the C-cell was to go before a full Sorell Council meeting for approval.

One of the two objectors had conversations with both the EPA and SWS on 19 June

2012 and specifically asked when the development was to go before Council for

approval. Both organisations indicated that it would be some weeks before the

development application would go to Council for approval.

The development application for the Category C-Cell at Copping Landfill Site went

before Sorell Council’s meeting that very evening and was approved.

2.1 Community consultation

Community engagement activities from the proponent and the planning authority

(and part owner) for this development consisted of:

7 Sequence of Events, Paul Reardon’, 2012

8 Landfill Sustainability Guide 2004, Department of Primary Industries, Parks, Water and Environment, Pg 4

12

Comment [cb61]: SWS had the

option of applying for assessment of

the C cell proposal as a Project of

Regional Significance. It actively

considered this option but rejected it

because it would not allow members

of the public to have any input. Comment [cb62]: This is not true.

The proposal was developed over a

period of approximately 4 years. An

Application for Development was first

submitted to the Sorell Council in

December 2012. Due to delays in

completing the DPEMP this document

was withdrawn and re submitted on

10 April 2012. Comment [cb63]: This is not true.

The closing date was 7 May. Comment [cb64]: Not only is this

not true, but the promulgators of this

document were advised that this was

not the case at a meeting with

representatives of the EPA and a State

politician some time last year. A

Notice of Intent was submitted by

SWS to the EPA in January 2012.

Following their review of this

document, and consultation with

interstate jurisdictions, the EPA issued

project specific guidelines in February

2012 detailing what matters it ... [14]Comment [cb65]: This erroneous

statement demonstrates a lack of

knowledge of the planning process.

The EPA provided its report to the ... [15]Comment [cb66]: The timeframe

was not short and all statutory timings

were adhered to. Comment [cb67]: In addition to the

minimum statutory consultation SWS

wrote to adjoining land owners a

week before the start of the statutory ... [16]Comment [cb68]: Mr Reardon was

one of the landowners written to by

SWS. He did not request any

information about the project. In ... [17]Comment [cb69]: SWS tried to

engage with the community early in

the process but no one was

interested. It is interesting to note ... [18]Comment [cb70]: This is untrue.

There were no objections. Comment [cb71]: This is also

untrue. Comment [cb72]: Authority

agendas including

development of a C cell, are mailed

to adjoining landowners. This item ... [19]

• a letter from SWS to landowners immediately adjacent to the Copping

Landfill Site on 13 April 2012 claiming the “need” for a Category C-Cell;

• a letter from Sorell Council to landowners immediately adjacent to the Copping

Landfill Site on 20 April 2012 stating that a development application had been

received by Council;

• an advertisement in the Mercury Public Notices on 21 April 2012;and

• a display of the proposed development in Sorell Council Chambers.

In essence, although plans for Tasmania’s first Category C hazardous waste cell

have presumably been underway for some years:

• if you weren’t an immediate neighbouring land owner (of which we understand

there are approximately 5) you would not have been made aware by the

proponent or the planning authority;

• if you don’t make a habit of reading the Public Notices in the Mercury or if

you didn’t happen to wander into the Sorell Council chambers and see the

display you would have been completely unaware of the development

application - this was the, case for the vast majority of the community.

There are many simple and cost effective measures to have informed the

public of these developments, the Councils own monthly newsletter being

just one example.

As mentioned, Sorell Council received two formal objections to the development -

there is no doubt the number of objections would have been immeasurably higher

had the community been made adequately aware of the proposed development in

the very early stage of planning – perhaps this was the reason not to do anything

‘extra’.

On 24 August 2012, The Mercury newspaper ran a frontpage story ‘Toxic Dump

Planned’ in which news of this proposed (and now approved) development was

broken to the wider Copping and Sorell Communities. In this article, the Chief

Executive Officer (CEO) of SWS was quoted:

‘SWS had been hesitant to publicly acknowledge the project until it was certain it

would go ahead.’9

Although the proponents met their minimal statutory regulations regarding notifying of the proposed development, it is clear from the widespread, united and vocal community backlash, that the level of community consultation was completely

unacceptable.10

Sorell council's approval of the C-cell at Copping undermines its own draft

Community Engagement Strategy11, subsequently adopted post approval (November

2012).12

9 ‘Toxic Dump planned’, The Mercury, 24 August 2012:

http://www.themercury.com.au/article/2012/08/24/355881_tasmania-news.html

11 Sorell Council Community Engagement Strategy, Sorell Council, November 2012:

http://www.sorell.tas.gov.au/component/docman/doc_download/236-sorell-council-community-


Comment [cb73]: The letter also

offered a personal briefing on the

proposal. Nobody was interested.

Comment [cb74]: SWS printed and

issued brochures outlining the

development. Comment [cb75]: Not presumably.

The project had been literally on the

(public) agendas since 2008. Comment [cb76]: 6 separate

owners.

Comment [cb77]: There were no

formal objections. Comment [cb78]: Extra was done. Comment [cb79]: The headline was

actually ‘Toxic Dump’. The

sensationalized and significantly

incorrect front page listed 10 items,

and had logos implying another 2,

NONE of which will be accepted in to

the C cell. The story also said that

council discussions about the project

were held ‘behind closed doors.’ It

was discussed in an open, public

meeting of council. Comment [cb80]: This was not

said. It is demonstrably untrue given

that the project had been on agendas

sent to land owners over a number of

years, all adjoining landowners were

written to by both SWS and the Sorell

Council, politicians from all parties had

been briefed, the project was

advertise in public notices, brochures

had been printed and the project was

considered in an open meeting of

council. Comment [cb81]: This is incorrect.

It is not the proponent’s responsibility

to undertake statutory consultation.

That is the role of the regulators. SWS

undertook its own consultation.

The way in which the DPEMP for the C-Cell was approved by Sorell Council is

entirely at odds with and completely undermines the Guiding Principles outlined in

their strategy including:

• relationship building

• participation and involvement

• effective communication

• transparency

• considering the results

• feedback

• evaluation and review

Since news of the proposed C-Cell development at Copping was made public, the

community has been united in its objection to both the development and the way in

which it was perceived to have been approved ‘behind closed doors’.

The proposed development has generated widespread community outcry and angst,

with extensive media exposure in print, radio and online channels. Several community

crisis meetings have been held and attended by hundreds of locals and concerned

Tasmanians. This has ultimately lead to the establishment of Dump the Toxic

Dump, a campaign of SBCS.

Members of SBCS have met and/or corresponded with numerous politicians and key

stakeholders13 regarding the proposed development including:

• Local Government, in particular the joint owners of SWS - Sorell, Clarence,

Kingborough and Tasman Councils; • SWS – the proponent

• Federal Politicians

• State Politicians including Labour, Greens and Liberal representatives

• Members of the Tasmanian Legislative Council

• Nyrstar;

• EPA;

• Australian Antarctic Division and

• Various industry experts, including regarding soil remediation

12 Letter to Sorell Council re Sorell Council Community Engagement Strategy, Paul Reardon, September 2012 13 SBCS Copies of correspondence from politicians and key stakeholders, August - December 2012

14

Comment [cb82]: Perceptions are

just that. The process was open and

transparent. The C cell protest group

tried to turn the recent Sorell

elections in to a referendum on the C

cell. If the election was a referendum

then the community gave the

proposal a resounding tick. Comment [cb83]: It is the group’s

persistent and willful promulgation of

untruths, and irresponsible

scaremongering that has

unnecessarily frightened some

members of the community.

3.0 Environmental Impacts

The potential for landfill waste to harm both the immediately surrounding

environment and the greater environment and to impact on public health is well

documented.

There are a number of common pathways by which waste landfill sites affect the

environment including, but not limited to:

• Gas emissions and airborne contaminants;

• Surface and groundwater pollution;

• Flora & fauna; and

• Geology and hydrogeology;*

Environmental hazards associated with landfill have been a driving force in the

worldwide move away from landfill as a preferred waste management option.

In October 2012, SBCS commissioned Mr Sam Player (Geomorphologist) to conduct a Desktop Geological and Geomorphological Assessment of the Landfill Controlled Waste

Cell Site at Copping14.

Mr Players’ assessment provided SBSC with a review of all available documents

relating to the proposed C-cell at Copping. His report has been used to inform much

of the geological and hydro-geological detail within the Environmental Impact section

of this document.

Mr Players’ report has been provided to Sorell Council for consideration.

3.1 Gas Emissions and airborne contaminants

Landfill gas consists of naturally occurring methane and carbon dioxide which forms

inside the landfill as the waste decomposes. As the gases form, pressure builds up

inside a landfill, forcing the gases to move. Some of the gases escape into the

surrounding soil or simply move upward into the atmosphere. Hazardous waste

landfills and solid waste landfills appear to be similar in their ability to produce toxic

gases.

Typically landfill gases that escape from a landfill will carry toxic chemicals such as

paint thinner, solvents, pesticides and other hazardous Volatile Organic Compounds

(VOCs) - many of them chlorinated.

A study15 in California tested for VOCs escaping from 25 landfills and reported

finding dry-cleaning fluid (tetrachloroethylene, or PERC), trichloroethylene (TCE),

* Hydrogeology is the area of geology that deals with the distribution and movement of groundwater

in the soil and rocks of the Earths crust, commonly called aquifers

14 Desktop Geological and Geomorphological Assessment of the Landfill Controlled Waste Cell Site at

Copping, Sam Player, October 2012

15 The Landfill Testing Program: Data Analysis and Evaluation Guidelines, .Baker. L, Capouya. R, Cenci. C,

Crooks R, & Hwang. R, California Air resources Board, 1990


Comment [cb84]: This is why both

the B cells and the C cell are properly

and scientifically engineered,

constructed, operated and monitored. Comment [cb85]: As stated in the

DPEMP the material to be stored in

the C cell will not generate gases. Comment [cb86]: As stated in the

DPEMP the cell is designed with

multiple redundancies to ensure that

this does not happen. Comment [cb87]: Material

deposited in the C cell will not be

attractive to fauna (soil and timber),

and will be covered at least daily.

There will be no emissions harmful to

the environment. Comment [cb88]: Found to be

extremely suitable by an professional

after significant research of the

specific site. Comment [cb89]: A relative of a

member of the group. Comment [cb90]: This is a pity

because the report is what it says – a

mere desk top study. Its conclusions

demonstrate that the author has not

visited the sits and has no detailed

knowledge of its geology. More than

100 hours of on site, site specific

research including technical

geophysical work proves that the site

is highly suitable. It is located entirely

on dolerite, one of the most

impermeable natural substances.

Current indications are that this

dolerite extends to a depth of around

15 m below the cell. Comment [cb91]: This does not

apply to the C cell. The waste it

receives will not produce any gases,

toxic or otherwise. This is clearly

articulated in the DPEMP. Comment [cb92]: Refer above. No

material capable of producing gases

will be accepted in to the C cell. Comment [cb93]: The Copping

landfill (both B cells and C cell) is

designed and engineered to today’s

standards, not those that applied

nearly a quarter of a century ago.

toluene, 1,1,1-trichloroethane, benzene, vinyl chloride, xylene, ethyl benzene,

methylene chloride, 1,2-dichloroethene and chloroform in the escaping gases. In many

cases, but not all, toxic gases escaping from these landfills could be measured at the

property line, the legal boundary of the landfill.

Methane at concentrations greater than the regulatory limit of 5% was found to be

migrating offsite, underground at approximately 20% of these landfills. Methane is a

naturally occurring gas, created by the decay of organic matter inside a landfill. As

methane is formed it builds up pressure and then begins to move through the soil,

following the path of least resistance - often it moves sideways for a time before

breaking through to the surface.

Carbon emissions, primarily through methane and carbon dioxide gases emitted

from landfill, account for 4% of Tasmania’s overall Carbon emission footprint16.

The Commonwealth Department of Sustainability, Environment, Water, Population & Communities estimates that the damage cost of greenhouse gas emissions from landfill ranges from $20 per tonne with gas capture technology to $60 per tonne in the

absence of gas capture technology17.

SWS are yet to advise exactly what systems will be in place for monitoring and

reporting air-borne contaminated dust & toxic gas emissions and whether these

continue into the future after the C-cell is capped.

3.2 Surface and groundwater pollution

Precipitation and ground water seeping through landfill waste produces leachate.

Leachate is defined as water contaminated from the various organic and inorganic

substances with which it comes in contact as it migrates through the waste.

Leachate seeping from a landfill contaminates the ground water beneath the landfill.

This contaminated ground water is known as a plume. The normal movement of

ground water causes the leachate plume to extend away from a landfill, in some cases

for many hundreds of metres. The United States (US) Geologic Survey states:

‘…regulations require that most landfills use liners and leachate collection systems to

minimize the seepage of leachate to ground water. Although liners and leachate

collection systems minimize leakage, liners can fail and leachate collection systems

may not collect all the leachate that escapes from a landfill. Leachate collection

systems require maintenance of pipes, and pipes can fail because they crack, collapse,

or fill with sediment. The USEPA has concluded that all landfills eventually will leak

into the environment. Thus, the fate and transport of leachate in the environment,

from both old and modern landfills, is a potentially serious

environmental problem.’ 18

‘The Case against the South Cardup Landfill Extension’ report which was prepared on

behalf of the Serpentine-Jarrahdale Ratepayers Association in Western Australia

provides details of researchers at Texas A&M University who have compared leachate

from 58 municipal landfills with leachate from hazardous waste landfills (Love Canal)

and they report:

16 Annual Greenhouse gas emissions, State of the Environment Tasmania, Resource, Planning and

Development Commission: http://soer.justice.tas.gov.au/2003/indicator/152/index.php

17 The full cost of landfill disposal in Australia, Department of Environment Water, Heritage and the

Arts, July 2009: http://www.environment.gov.au/settlements/waste/publications/pubs/landfill-cost.doc

18 United States Geologic Survey, US Environmental Protection Agency, 1988

16

Comment [cb94]: No gases will be

produced by the material deposited in

the C cell. Refer to the DPEMP. The B

cells have a gas collection system in

place. Landfill gas is collected and

flared. In future it will be used to

generate electricity. Comment [cb95]: Immaterial.

Copping flares its landfill gas to

significantly reduce its emissions. This

is one of the advantages of a well-run

modern landfill – it can minimise its

carbon footprint. The C cell will also

help minimise the state’s carbon

footprint by significantly reducing the

transport distance for level 3 waste. Comment [cb96]: This is not true.

Although we are not required to

monitor air borne contamination

including gases (because there won’t

be any leaving the site) we publicly

announced on 5 November 2012 that

we had agreed to implement a

voluntary depositional air quality

monitoring program as a response to

community feedback. The DPEMP

makes it clear that monitoring of the C

cell is to continue indefinitely. This is

one reason for the establishment of a

trust fund. Comment [cb97]: Our standards

are clearly higher than those that

applied in the US a quarter of a

century ago. The Copping B cells have

more than one impermeable layer,

and testing consistently shows that

groundwater is cleaner when it leaves

the site than when it enters it. The C

cell has four impermeable layers (as

well as other layers for drainage,

cushioning etc). It has a witness sump

that will be inspected on a weekly

basis. This sump is between the

second and third impermeable layers.

In the extremely unlikely event that

leachate was found in the sump,

material would be removed from the

cell, the liner repaired and the

material replaced. The HDPE liners

have lives of several hundreds of

years, and the bottom clay liner has a

life of several thousands of years,

giving ample time for repairs. In

addition the material accepted in the

cell will be substantially dry and

covered, so leachate production wil be

minimised.

1. There is ample evidence that the municipal waste landfill leachates contain toxic

chemicals in sufficient concentration to be potentially as harmful as leachate from

industrial waste landfills.

2. 113 different toxic chemicals in leachate from municipal landfills and 72 toxic

chemicals in leachate from hazardous waste landfills.

3. In industrial landfill leachate, 32 chemicals cause cancer; 10 cause birth defects, and 21 cause genetic damage; in municipal landfill leachate, 32 chemicals cause

cancer, 13 cause birth defects, and 22 cause genetic damage.’ 19

To find information about landfill liners click here

3.3 The Carlton River Catchment

The Southeast Tasmania Groundwater Map indicates that deep aquifers exist in close

proximity to the proposed C-cell site.20 If the C-Cell fails these aquifers are at risk of

being contaminated by leachate.

Any contamination of the groundwater from leaks in the C-Cell will inevitably end up in

the Carlton River - an unnamed tributary of the Carlton River is within 750 metres of

the C-cell site.

The minimum height between groundwater level and the proposed C-cell liner is less

than the recommended 5 metres as per the acceptable standard in the Landfill

Sustainability Guide, and clearly evidenced in the DPEMP.

In the event that ground water levels rise (due to large rainfall events), the

proponent proposes pumping out the groundwater to keep it below the base of the

C-cell.

Groundwater pumping will have to be maintained during periods when groundwater

levels reach the landfill confining layers, even after the landfill is closed. If this does

not occur the groundwater will be hydraulic head (i.e. pressure) pushing it to infiltrate

into the landfill.

3.4 Flora & Fauna

The EPA risk assessment of the proposed C-cell development contains NO aquatic

fauna survey of the Carlton River or its watershed into Frederick Henry Bay.

The EPA risk matrix recognises that a minor failure of the cell would represent a high

environmental risk while a moderate to catastrophic failure would represent an

extreme environmental risk, due primarily to groundwater drainage as described

above.

It is a gross oversight under this risk matrix to have neglected to undertake an

aquatic fauna survey, particularly given that:

19 The Case against the South Cardup Landfill Extension, Lee Bell, page 3

20 Southeast Tasmania Groundwater Map, Department of Infrastructure, Energy and Resources


Comment [cb98]: Copping is

regularly monitored by a professional

independent scientist. Reports are

sent direct to the EPA. Reports are

also sent to adjoining land owners.

There is no evidence of any leachate

leaving the site. It is a closed loop

system. This will also be the case with

the C cell. In any event landfill (B cell)

leachate is generally able to be

irrigated over non-food crops without

prior treatment. Comment [cb99]: No leachate

leaves the site and it is not sufficiently

contaminated, nor is there enough of

it, to cause any of these outcomes. Comment [cb100]: The C cell is

designed to not fail. It will not

discharge leachate to groundwater. Comment [cb101]: The Landfill

Sustainability Guide recommended

buffer distance is 100 m between a C

cell and a permanent watercourse.

The C cell is approximately 1,750 m or

17.5 times the recommended

distance, from the Carlton River. The

unnamed tributary is generally dry

and in any event still well in excess of

the recommended distance. Comment [cb102]: This is not true. The DPEMP says no such thing. It actually states (page 27) that ‘[t]he C-cell will be located on a hillside and its base will be excavated down to approximately 58 m AHD, which is 16 m above that water level. While the water table is expected to follow the hill slope to some extent, it is unlikely to parallel it exactly and the 16 m difference suggests that ... [20]Comment [cb103]: Refer to the

previous comment. Also the C cell is at

an altitude of approximately 48 m – it

will not be subject to flooding. Comment [cb104]: This statement is misleading. A botanical and zoological assessment was included in the DPEMP for the existing landfill. It was concluded that “[t]here are no zoological reasons why this project should not ... [21]Comment [cb105]: This is because

the development does not pose any

risk to fauna – aquatic or otherwise. Comment [cb106]: This is also

untrue and demonstrates a lack of

understanding of risk management.

The risk matrix was not prepared by

the EPA. The risk levels cited here are

the gross risk prior to considering the ... [22]

• the benthic* environment adjacent to Carlton Bluff is the site of the last

known breeding colony of the Red Handfish listed as critically endangered

under the Environment Protection and Biodiversity Conservation (EPBC) Act

1999. 21

The presence of the Red Handfish alone, within the watershed of Carlton River,

places a statutory obligation upon the proponents to refer the proposal to the

Commonwealth Government for assessment under the EPBC Act 1999. This has

not been done!

• the environment at the mouth of the river (Carlton Bluff) is home to Weedy

Sea Dragons, a near threatened species listed on the International Union for

Conservation of Nature (IUCN) Red List;**

• the river contains endemic Ostrea Angasi oysters*** amongst other estuarine

species;

• the wetland and sand belt at the mouth of the river is a gazetted bird

sanctuary;

• the river is visited by seals and dolphins; whales migrate through the area

immediately beyond the mouth of the river.

The EPA previously conducted a terrestrial fauna and flora survey of the area

surrounding the existing Copping Landfill site and found a number of listed fauna

species may occur in the area including:

• the Swift parrot listed as endangered under the Threatened Species

Protection Act 1995 (TSPA 1995),22 EPBC Act 1999 and on the IUCN Red list

• Chaostola skipper butterfly, listed as endangered under the and TSPA 1995;

and

• the Tasmanian Devil listed as vulnerable on both TSPA 1995 and EPBC 1999

Acts and listed as endangered on the ICUN Red list.

* The benthic zone is the ecological region at the lowest level of a body of water such as an ocean or

a lake, including the sediment surface and some sub-surface layers.

21 SPRAT profile- Red Handfish, Department of Sustainability, Environment, Water, Population and

Communities: http://www.environment.gov.au/cgi-bin/sprat/public/publicspecies.pl?taxon_id=83756

and

Environment Protection and Biodiversity Conservation Act, Department of Sustainability,

Environment, Water, Population and Communities: http://www.environment.gov.au/epbc/index.html

** The International Union for Conservation of Nature (IUCN) is the world's main authority on the

conservation status of species. The IUCN Red List of Threatened Species (also known as the IUCN Red

List) founded in 1963, is the world's most comprehensive inventory of the global conservation status

of biological species.

*** The southern mud oyster or native flat oyster, Ostrea Angasi, is endemic to southern Australia,

ranging from Western Australia to southeast New South Wales and around Tasmania. Flat oysters, like

all other oyster species are filter feeders, feeding on, and taking in anything small enough to be filtered

in their gills. This may include plankton, micro-algae or inorganic material.

22 Threatened species Publications, forms & related documents, Department of Primary Industries,

Parks, Water and Environment Tasmania: http://www.dpiw.tas.gov.au/inter.nsf/WebPages/LJEM-

76C7B7?open

18

Comment [cb107]: Refer above re

the EPA’s consideration of fauna.

The threat to the Tasmanian Devil is highlighted with the ‘Save the Devil’

program, an initiation of the Tasmanian Department of Primary Industries,

Parks Water and the Environment (DPIPWE). It has been recorded that

sixteen Tasmanian Devils in the broader area of the Copping Landfill site

have likely been affected by the current B-cell at Copping since 2009.

Any potential impact on Tasmanian Devil populations requires referral to the

Commonwealth Government for assessment under the EPBC Act 1999. 3.5 Geology & Hydrogeology

The 2004 Landfill Sustainability Guide23 sets a framework around the location and

construction of landfill facilities to minimise their impact on the Environment.

In this section we look at how the proposed C-cell location in Copping does not meet

the Guidelines specifically in geological and hyrdrogeological terms, including:

a. subsurface and surface characteristics;

b. sandstone terrain;

c. slipping substrate;

d. high permeability soils/substrata;

e. buffer distance

f. wetlands; and

g. flooding

In looking at this, we also find that the currently active Copping B-cell does not

meet Guidelines set out in the Landfill Sustainability Guide 2004. a. Subsurface and surface characteristics

Under the Guidelines, appropriate subsurface characteristics for a landfill site

include:

• low hydraulic conductivity - the rock type should have zero to very few

interior pores and zero to very few connections between those pores to

inhibit the flow of liquid;

• structural integrity – the geological substrate should not be fractured or

within a fault zone. Fractures provide a conduit for liquid flow and active

faults cause fractures to develop in the future; and

• a homogenous lithology* - where the hydraulic conductivity and isotropy**

of a lithology is known, the speed and direction of leachate flow can be

* A material that is homogenous is uniform in composition or character. The lithology of a rock is a

description of its physical characteristics visible at outcrop, in hand or core sample i.e. its colour,

texture, grain size etc.

** Isotropy is uniformity in all directions

23 Landfill Sustainability Guide 2004, Department of Primary Industries, Parks, Water and Environment:

http://epa.tas.gov.au/Documents/Landfill_Sustainability_Guide_2004.pdf


Comment [cb108]: Refer to an

earlier comment. There is no threat to

fauna in general or to the Tasmanian

Devil in particular arising from the C

cell project. Comment [cb109]: The C cell more

than meets all requirements in the

Guide.

Comment [cb110]: The current B

cell is designed and constructed in

accordance with the landfill permit,

and after specific approval by the EPA.

Comment [cb111]: The C cell will

be constructed on dolerite which

more than satisfies this requirement. Comment [cb112]: The C cell (and

the B cells) are not on fractures

substrate nor are they near any ‘major

tertiary (first order) fault lines that

present risk associated with seismic

activity’. Comment [cb113]: This is not true.

There is no reference in the guide to

‘homogenous lithology’.

predicted. Geological variability complicates such predictions and reduces

the certainty of the outcome of cell failure.

Also under the guidelines, appropriate surface characteristics for a landfill include:

• long distances to stream channels. A landfill should be situated as far

from a stream channel as possible to minimise its’ potential to transport

leachate into the channel. Once entering a channel, leachate will spread

rapidly downstream; and

• a shallow surface gradient. Low topographic gradients reduce the velocity

of overland water flow and slow the movement of leachate into drainage

lines.

b. Sandstone Terrain

The Landfill Sustainability Guide 2004 states that landfills will not be able to be

located in sandstone terrains.24

Contrary to the Guide, the existing Category B-cell landfill at Copping is clearly

located on sandstone lithology as shown by the geological map of the region. The

proposed C-cell is also within the sandstone footprint.

c. Slipping Substrate

The Landfill Sustainability Guide 2004 states that landfills will not be able to be

located in slipping substrates.25

A major east-west fault located to the north of the Copping landfill has reportedly

experienced up to 300 m of vertical displacement. A fracture system is also

identified directly beneath the currently active B-Cell landfill.

The only evidence presented to show that fault and fracture systems in the area are

dormant, is the statement that ‘[a]s far as is known there has been no movement

on any of the structural features in this area within historic times.’ 26

It should be noted here that the risk assessment of the C-cell design report regards

the displacement of underlying strata by faulting as high risk.27 The dolerite that

forms the quarry to be used for the C-cell is also noted to be fractured28. Strikingly, the current DPEMP warns that the fractured dolerite could be highly problematic for leachate contaminants reaching Carlton River, deferring to engineering strategies as

the appropriate solution.29

24 Landfill Sustainability Guide 2004, Department of Primary Industries, Water and Environment , p.17

25 Landfill Sustainability Guide 2004, Department of Primary Industries, Water and Environment, p.17

26 Copping landfill category c cell design report, Pitt & Sherry, 2012 pg 3

27 Copping landfill category c cell design report, Pitt & Sherry, 2012, Appendix B

28 Copping Landfill Controlled Waste Cell, Development Proposal and Environmental Management Plan

(DPEMP), Southern Waste Solutions, 2012, p.21



20

Comment [cb114]: This is not true.

There is no such reference. Comment [cb115]: The Guide

requires a buffer distance of 100 m

between a C cell and a permanent

watercourse. The Copping C cell

distance is 17.5 times greater –

approximately 1.75 km. The Guide

also allows for smaller distances. Comment [cb116]: The C cell is

situated entirely on dolerite. Comment [cb117]: Sandstone

underlain by shale. Comment [cb118]: This is not true.

The C cell is entirely on dolerite. Comment [cb119]: It should be

noted that the C cell is in one of the

most geologically stable parts of

Tasmania. Tasmania is one of the

most geologically stable areas in the

world. In any event the C cell will not

be damaged by an earthquake of the

same magnitude as Christchurch, and

can withstand a tremor of 10,000

times greater than any ever recorded

in the region. Comment [cb120]: This is

misleading. The displacement was

caused by intrusion of dolerite in the

Jurassic period (at least 6,000,000

years ago). It is extremely stable. The

displacement was not the result of

any seismic activity. Comment [cb121]: This is not true.

The C cell is located entirely on

dolerite with a thickness of

approximately 10 -15 m. Comment [cb122]: This is a

misleading, incorrect and selective

quotation. There is no reference to

‘historic times’ within the DPEMP. The

DPEMP states that ‘Southeast

Tasmania, including the Copping area,

is geologically very stable. No

earthquakes greater than magnitude 4.0

have been recorded in southeast ... [23]Comment [cb123]: Again

demonstrates a lack of understanding

of risk assessment. This is the gross

risk with a likelihood ranking of “Rare’ ... [24]Comment [cb124]: A qualified

geologist with more than 100 hours

work on the actual Copping site has

determined that the dolerite is not ... [25]Comment [cb125]: The DPEMP

refers to this as a potential risk that is

dealt with by having a properly

designed and constructed liner.

A Better Waste Management Future for Tasmania

d. High permeability soils/substrata

The landfill is within an area of high permeability sub-strata, contrary to the Landfill

Sustainability Guide 2004, due to its construction upon fractured dolerite and the

proximity of sandstone lithology. e. Buffer distance

The Landfill Sustainability Guide 2004, states that a buffer distance of at least 5

metres must exist between the base of the waste and the water table.

The C-cell DPEMP states that the water table will be deeper than 2-3 meters30 and

gives no guarantee that the 5 metre minimum distance will be adhered to.

Given the potentially extensive life of wastes to be deposited in the C-cell, the

solution seems inherently unsustainable compared to a location that naturally

provides the required buffer distance. f. Wetlands

The Landfill Sustainability Guide 2004 states that landfills are unlikely to be

acceptable in wetlands31

A marsh, currently dry due to surface water diversions, is clearly reported to have

existed to the north of the landfill site32

It has been identified that surface waters and shallow ground waters discharge into

the tributary of the Carlton River. Consequently any leachate escaping to the ground

surface from any part of the landfill site will inevitably flow towards the marsh and into

the tributary of the Carlton River.

The existence of the marsh within the landfill zone, ephemeral or otherwise, is

contrary to current landfill sustainability guidelines.

g. Flooding

The Landfill Sustainability Guide states that landfills are unlikely to be acceptable in

one in one hundred (1 in 100) year floodplains.33

30Copping Landfill Controlled Waste Cell, Development Proposal and Environmental Management Plan


31 Landfill Sustainability Guide 2004, Department of Primary Industries, Water and Environment (DPIWE),

2004, p.21 * The Holocene is a geological epoch which began at around 12,000 to 11,500 years ago and continues

to the present

32 Development Proposal and Environmental Management Plan for Sub- regional Refuse Disposal Facility at Copping, Tasmania, Woodward-Clyde, Prepared for Sorell Council, 1998 and

Copping Landfill Controlled Waste Cell, Development Proposal and Environmental Management Plan (DPEMP), Southern Waste Solutions, 2012, p.23 and

Copping landfill category c cell design report, Pitt & Sherry, 2012, Appendix B


2004, p.21


Comment [cb126]: The C cell is

entirely on non-fractured dolerite. Comment [cb127]: This is not true.

The Guide recommends a buffer of 5

metres but refers to other measures if

this is not achieved. In any event

subsequent geophysical work

indicates a distance of around 15 m. Comment [cb128]: The DPEMP

included measures to counter the

POSSIBILITY of insufficient clearance

to groundwater. The EPA was satisfied

with these measures. In any event

they are not required as there is

ample clearance above groundwater. Comment [cb129]: Yes. To the

north of the B cells. The B cells are

between the C cell and the dry marsh.

The C cell is around the 48 m contour

– well away from any marsh. Comment [cb130]: The cell is 17.5

times further away from a permanent

watercourse than is recommended in

the Guide. It is at the 48 m level. It is

designed so that leachate will not

escape. Comment [cb131]: This is not true

and the writer knows this as the

statement that he/she made above is

that the dry marsh is to the north of

the landfill. The landfill is not on or in

any marsh. It is around the 48m

contour. Comment [cb132]: The cell is not in

any floodplain. It is located at around

the 48 m contour.

The original DPEMP for the existing B-cell landfill finds that the tributary of the

Carlton River, north of the landfill site, should be able to contain the flow of a 1 in

100 year flood apart from some backwater effects.34

The operators have indeed experienced localised flooding during the life of the

current B-cell landfill.35 Certainly the existence of Holocene* age alluvial sediments,

mapped below the active B-cell and continuing over the ground surface to the Carlton

River, suggests that the area is an active hydrological zone subject to flooding.

Basic hydrological modelling applied in this review shows the current landfill to be

directly in a drainage path, which flows towards the Carlton River and its tributary.

While justification for the C-cell is claimed due to its elevation being above the 1 in

100 year

flood level, the critical consequence is that any leachate that escapes from the C-cell

will ultimately find its way to the Carlton River.

Furthermore, the DPEMP studied groundwater levels during below average rainfall

years during 2003 – 2007. Subsequently the region has been subject to a series of

above average rainfall years under the influence of a La Niña climate pattern.

During the period 2008 to 2012, the river has flooded the river valley proximal to

the landfill site on three separate occasions. The DPEMP predicted such flooding as a

1 in 50 year phenomenon, demonstrating that its underlying premise on regional

hydrology and rainfall is flawed. 3.6 Environmental Impact - Summary

The information presented in the existing B-cell landfill DPEMP for Copping clearly

shows it to be an unsuitable location for a landfill development as per current

Landfill Sustainability Guidelines.

The B-cell DPEMP has been used to inform risk assessments for the current C-cell

DPEMP application. Had the original B-cell landfill approval been sought after 2004, it

would likely have been rejected based on the factors in this section.

Indeed, because of the implementation of new guidelines, the previous DPEMP used for

the original landfill is inappropriate for use pertaining to the C-cell and any risk assessments carried over becomes invalid. So, the assertion that ‘The same features

of the site that favoured it as a Category B landfill support it as a location for a

Category C-Cell’ 36 is flatly rejected as incorrect!

The mitigation of geological and hydrogeological concerns for the C-cell is solely

addressed via the application of engineering solutions37 rather than the obvious

alternative of finding a more appropriate geological setting.

34 Development Proposal and Environmental Management Plan for Sub- regional Refuse Disposal Facility at Copping, Tasmania, Woodward-Clyde, Prepared for Sorell Council, 1998.



\\


(DPEMP), Southern Waste Solutions, 2012, pg 8

37 Development Proposal and Environmental Management Plan for Sub- regional Refuse Disposal

Facility at Copping, Tasmania, Woodward-Clyde, Prepared for Sorell Council, 1998: Pg 5-9

22

Comment [cb133]: This is not true.

The marsh, the river, the unnamed

tributary have never flooded the site,

or even come close to doing so. In any

event the C cell is 48 m above sea

level. Comment [cb134]: This is almost

meaningless in the context of the life

of the C cell which is only about 10

years, after which it will be

permanently capped and impervious

to the effects of rainfall, runoff etc. Comment [cb135]: It is impossible

for a 1 in 100 year flood to reach the

elevation of the C cell at 48 m. There

is no critical consequence. Comment [cb136]: The DPEMP

considered the effect of a number of

factors including global warming and

the potential effect on rainfall. Given

the short life span of the cell global

warming’s effect is irrelevant. Comment [cb137]: This is untrue.

The reverse is the case. Comment [cb138]: This is also

untrue. Comment [cb139]: This is untrue. Comment [cb140]: This is untrue.

Indeed there is no comparative discussion within the C-cell DPEMP of the particular

characteristics of Copping that make it the most appropriate site, despite the Landfill

Sustainability Guide 2004 clearly stating that:

‘… prior to site selection, proponents should identify several potential sites and

conduct a preliminary assessment of each to determine their appropriateness for use as a landfill... By addressing the above criteria in a comprehensive and

consistent manner, the most appropriate landfill site should recommend itself for

selection.’ 38

The Copping site has clearly been selected based on the fact that the infrastructure is

already in place, rather than as for best environmental outcomes.

For further information on site selection click here

In Geological and hydrogeological terms, the Copping landfill site is regarded as a

profoundly unsuitable location for a hazardous waste category C-cell due to the

following environmental concerns:

• it is located within a sandstone terrain footprint;

• fault zones are identified to the north of the site, but also beneath the

currently active B-cell landfill;

• the geological substrate is fractured, including the dolerite proposed for the

C-cell, and the adjacent sandstone;

• the presence of a former marsh impinged by the northern portion of the

currently active landfill;

• an unnecessarily close proximity to a tributary of the Carlton River;

• the immediate vicinity of the current landfill being subject to flooding;

• a lack of real evidence to demonstrate that the liner system of the cell will

have longevity in securing the groundwater of the region from leachate in

perpetuity;

• complete negligence in the lack of an aquatic fauna survey for the Carlton

River and its watershed into Frederick Henry Bay, which is the site of at least

one critically endangered species; and

• acknowledgement by the EPA that failure of the C-cell in this particular

location will have high to extreme environmental consequences due to the

relevant hydrogeology of the site and its proximity to the Carlton River.

Furthermore, failure to report potential impacts on all listed species (such as the Red

Handfish), with a subsequent disappearance/decline in that species population from

the relevant locations, post commencement of construction and operation of the C-

cell, opens up the proponent to potential liability and is environmental negligence!

38

Landfill Sustainability Guide 2004, Department of Primary Industries, Water and Environment (DPIWE),

2004, pg 25


Comment [cb141]: A Greenfield

study (refer swstas.com.au) was

conducted in 1993 and after

investigating a number of potential

sites Copping was determined to be

the most suitable for a C cell.

NIMBYism was identified as a

potential problem. The actual site

selected in 1993 was only a few

hundred (less than 1 km) metres from

the current landfill. Comment [cb142]: Or better still

refer to swstas.com.au Comment [cb143]: Not true. The

reverse is the case after more than

100 hours of detailed work at the

Copping facility. Comment [cb144]: Not true. The C

cell is located entirely on non-

fractured dolerite with a depth of 10 -

15 metres. Comment [cb145]: Not true. There

is a displacement caused by intrusion

of dolerite in the Jurassic, not by

seismic activity. Comment [cb146]: Not true. The

cell is underlain by non-fractured

dolerite. Comment [cb147]: This is not true.

As stated it is a former marsh and the

B cells do not impinge on it. The C cell

is nowhere near it. Comment [cb148]: The Guide

requires a buffer between a C cell and

a permanent water course of 100 m.

The C cell is approximately 1.75 KM or

17.5 times that distance away from

the closest permanent watercourse. It ... [26]Comment [cb149]: This is not true.

The landfill is not subject to flooding

and the C cell will certainly not be as it

is located at around the 4 m contour. Comment [cb150]: There is

considerable evidence. Refer Rowe

2005. In relation to the HDPE ... [27]Comment [cb151]: This is insulting

and not true. A more detailed

comment has been provided earlier in

this paper. Comment [cb152]: Again showing

complete lack of understanding of risk

assessment. The EPA made no such

acknowledgement. This is a gross risk ... [28]Comment [cb153]: This is untrue.

Consideration was given to fauna and

in any event the cell will not release

leachate to the environment let alone ... [29]

4.0 Community Impacts

4.1 Environmental Discrimination

Landfill sites and in particular, hazardous waste sites, are often seen as being

undesirable developments. Therefore, it is usually difficult to find suitable locations

to accommodate such developments, not only because of the potential

environmental impacts, but also because of the widely recognised negative social

impacts that such developments attract.

Where possible, such developments are located away from population centres, and

where this isn’t possible, they are often located in low socio-economic or

disadvantaged areas, where the likelihood of objections from the community is much

lower.

This is known as environmental discrimination.

The following is an extract39 taken from a ‘The Case against the South Cardup

Landfill Extension’, which was prepared on behalf of the Serpentine-Jarrahdale

Ratepayers Association in Western Australia:

• ‘In the US, landfills and waste disposal sites are known as LULUs (Local

Undesirable Land Uses)

• Due to the difficulty in siting LULU’s, there is a tendency to cluster such

facilities where communities are politically and financially weak, low in

density or made up of minority groups

• These areas become known as ‘sacrifice zones’ and the discrimination is

justified by claiming that pollution in these areas is already high and

therefore it is better to create another landfill/waste dump in the sacrifice

zone rather than contaminate a new area.

• As more LULUs congregate stigma takes hold, property values fall, social

conflict rises and money leaves town. The name Serpentine-Jarrahdale will

become synonymous with waste disposal not sustainable development.’

An example environmental discrimination in relation to the proposed Copping C-cell

development was clearly demonstrated during an ABC radio interview on 10

September 2012, with SWS Chief Executive Officer (CEO) Ms Christine Bell and SWS

Technical Expert and Director, Mr John Brennan.

When asked by a caller why the Category C-cell was to be located so close to the

Carlton River, Mr Brennan proceeded to explain that the Carlton River Catchment ’is

not a key ecological site in the Derwent-South East region’ and that the ‘Carlton River

is a hotspot for poor water quality due to land use, septic systems, and storm water

damage’. Below is an extract40 of the ABC radio interview transcript:

John Brennan:“Now what I want to raise here is that every person in

that catchment and there are about 2000 households in that

39 The Case against the South Cardup Landfill Extension, Lee Bell, pg 3

40 Transcript of interview, ABC Radio 93.6am Hobart, Sarah Gillman, 10t September 2012

24

Comment [cb154]: Until this group

commenced its activities the general

public was not aware of the exact

location of the landfill. This was a

deliberate situation resulting from the

original landfill planning process, to

satisfy community requirements. Comment [cb155]: A similar C cell

operates successfully in suburban

Melbourne, with a residential suburb

only about 500 m away. Comment [cb156]: What is the

evidence for this statement? Comment [cb157]: Copping is not

in the US.

Comment [cb158]: The landfill

does not pollute. The C cell will not

pollute. Comment [cb159]: The group is

responsible for identifying the exact

site of the landfill. It was a condition

of the original permit that it not be

identifiable. Until recently the

majority of the community did not

know it was there. Comment [cb160]: This is a

statement of fact. Catchment reports

proving this fact are available on our

web site swstas.com.au

catchment. There are 1800 of them that probably have septic tanks and

grey water sullage. Every morning when they have a shower; when they

do a No 1 and No 2, and at lunchtime and at the end of the day they’re

flushing it into the groundwater. My calculations lead me to… three and

half million litres of contaminated water sits in the Carlton Catchment area

in the very place [the caller] is calling from. And it’s seeping into the

environment now. Now if that’s not controlled… people ahhhm people will

suffer the consequences of having polluted beaches. Surfers can be

concerned about the fact that there might be E. coli counts and virus. So

let’s contextualise this – septic tanks in the ground 3,500,000 litres – a

couple of Olympic pools worth of human excrement….”

ABC radio host: “Are you suggesting that this is a place where, it’s OK if a

bit of whatever you’re proposing to store at Copping flows into the Carlton

River?”

John Brennan: “No, no… not at all. I’m contextualising that this is an uncontrolled

form of pollution already occurring that the very opponents are contributing [to]”

• On 12 September 2012, The Mercury newspaper published an article ‘A waste of a

protest’ which read as follows:

‘Proponents of the Copping waste dump say protesters have "zero" chance of stopping

the controversial project going ahead… Residents in the area have expressed concern

that the hazardous waste dump will decrease property values but Ms Bell said the $10

million C-cell could actually increase values in the area. “Because currently, the

Carlton River area is contaminated and the cell will help to clean up their own back

yard, literally," she said.’

• On 10 September 2012, The Mercury ran an editorial titled ‘When the mob

hijacks debate’ written by Mr Greg Barnes, ex-director of a company which

provided advisory services on waste strategies in southern Tasmania in 2008.

The inflammatory article ran with lines like:

‘If there were ever a case of ignoring the science and the economics of a proposal

by a mob of rowdy individuals then this is it.’

‘The Copping Category C Cell development is one that Tasmanians should welcome if

they ignore rhetoric and emotion and focus on the science and the economics of the

project.’

‘But just as is the case with the super trawler issue, once again Tasmania is telling

the world that science and economics do not matter.’

And lastly, to further highlight the environmental discrimination being bandied in the

media against the Copping community (and Tasmanians in general), the author wrote:

‘That the community believes scare campaigns and ignores the facts. That the angry

shrieking mob rules… Tasmania's poor education system is partly to blame - people

who are not well educated can be easily seduced by fear.’

• There has been a 25% increase in population for the Southern Beaches region of

South East Tasmania (which sits within the Sorell Municipality, including

Copping, footprint, in the last ten years according to the Australian Bureau of

Statistics.


Comment [cb161]: These are

statements of fact. The community

faces a real environmental risk but is

not taking action to minimise it.

Comment [cb162]: This is a

statement of fact, but the printed

quote is not correct.

Comment [cb163]: This is true

from the viewpoint that the science

underpinning the C cell is sound.

Comment [cb164]: Mr Barnes is

entitled to his opinion. Comment [cb165]: This

demonstrates that the landfill has not

had any negative impacts on the area.

The landfill has been operating for

more than 10 years.

A high proportion of the working population is represented by trades,

professional and managerial workers (45.4%).41

This clearly shows that the Southern Beaches is a sought after and vibrant

location in which to live and not populated by uneducated, rowdy mobs. It is

NOT an area for a LULU site. 4.2 Copping waste disposal site location

The current Copping site was selected 20 years ago for its suitability for a B-cell, not

for a C-cell. The EPA Environmental Assessment Report, Copping Landfill June 2012

states in relation to possible alternative sites:

‘...There would be the potential to find alternative site throughout Tasmania.

However this would need to be a long term strategy. Currently there is an

opportunity to develop the Category C-Cell at Copping up to 300,000 tonnes.

Further investigation of alternative sites can be completed whilst the proposed

Cat-C-Cell is being filled.’42

The primary reason for location the C-cell in Copping is due to the existing B-cell.

This convenient short term solution was arrived at without thorough assessment of

alternative sites for a new C-cell in Tasmania. The selection of a site should have

been part of a State-wide integrated waste management strategy.

Since that selection for a B-cell took place 20 years ago, policies such as the Landfill

Sustainability Guide have been introduced clearly defining the selection criteria for landfill sites. Independent research clearly shows that the current site is NOT suitable

for a Category C-cell based on the Landfill sustainability Guide.43

Sorell Council, in assessing the development Application for the C-Cell stated ‘As the proposal was for an existing landfill site which is EPA endorsed, there were no planning

or environmental grounds on which to refuse the permit.’ 44

The land on which the C-cell is to be built is zoned Rural45 and is in close proximity to significant agricultural land (as defined in the Southern Tasmanian Regional Land Use

Strategy46). Some critical questions need to be asked of Sorell Council as the planning authority, who approved the SWS development application, including:

1. When assessing the development application did council define the

‘appropriate use’ category as “Utility Services – Major”, which would include a

refuse disposal site; or did they define it as a ‘discretionary use’ as

“Toxic/dangerous Goods Store” – a prohibited use in the Rural Zone?

41 3218.0 - Regional Population Growth, Australian Bureau of Statistics, 2011

42 Environmental Assessment Report, Copping Landfill, EPA TASMANIA, June 2012, pg 8

43 Desktop Geological and Geomorphological Assessment of the Landfill Controlled Waste Cell Site at

Copping, Sam Player, October 2012

44 Copping Landfill Information Sheet published by Sorell Council, September 2012

45 Sorell Planning Scheme 1993, Sorell Council:

http://www.sorell.tas.gov.au/component/docman/doc_view/305-sorell-planning-scheme-1993-incl-

modified-planning-directive-no-4

46 Southern Tasmania regional land use strategy, Southern Tasmanian Councils Authority:

http://stca.tas.gov.au/rpp/southern-tasmania-regional-land-use-strategy/

26

Comment [cb166]: This is a landfill

not a LULU and the fact that it has not

had an adverse impact on the number

or type of people moving in to the

area speaks for itself. Comment [cb167]: Investigation of

potential B cell sites began in 1995. 15

sites were investigated at that time. Comment [cb168]: Copping was in

fact selected as a suitable site for a C

cell before it was selected as a site for

a B cell. Although not the exact

location, a site only a few metres

away was identified as a result of a

Greenfield study in 1993. This report

is available at swstas.com.au Comment [cb169]: This is not

correct. It was identified as being

suitable for a C cell as a result of a

Greenfield study in 1993. Comment [cb170]: Expert research

plus the landfill’s record prove the

contrary. Comment [cb171]: A planning

authority is restricted in what factors

it can consider when assessing

development applications. Comment [cb172]: And so the use

fits perfectly with the zoning. Refuse

disposal is a land use specified as one

of the objectives of a rural zoned area. Comment [cb173]: Refer to

previous comment. Refuse disposal is

specifically mentioned as an objective

of land use in rural areas, so naturally

this was a factor in Council’s

deliberations.

2. Why is the C-cell placed next to significant agricultural land, subjecting it to

possible contamination when such land is identified as worthy of protection

under the Southern Tasmanian Regional Land Use Strategy?

3. Is council aware that the proposal contravenes the Southern Tasmanian

Regional Land Use Strategy, MRH 4 in relation to protection of land and

groundwater from contamination?

4.3 Long term management, remediation and liability

There are many examples of where landfill sites have failed around the world and in

many examples the community (i.e. local ratepayers) are left to ultimately pay the

price for failed C-cells, years after the cells’ discontinuation.

By this stage, the original landfill developers or proponents are often no longer in

existence and therefore unable to take any liability or responsibility for the

developments’ failure and resulting consequences.

’… experience has shown that when Government officials allow a “landfill” to be built

and then filled with thousands of tons of waste and then find it is polluting the

groundwater, it is too late to force the "landfill" owner to do any meaningful clean up.’ 47

Although the C-cell will be capped off with a low density polyethelene liner when

filled, the leachate in the landfill will continue to migrate downward with time. Any

additional infiltration from rainfall or surface waters will exacerbate this.

The C-cell will contain a number of hazardous materials, as listed in the permit, and

many are that were previously liquids will return to their natural liquid state and thus

slowly percolate out as leachate. Loss of this leachate into the environment will

require remediation, which is generally a very expensive process.

Typically, remediation requires processes such as excavation and incineration of

soils in the entire contaminant plume area, with subsequent land filling of these

hazardous substances or injection and pumping of water to remove contaminants

from soils. In either case these processes could be very costly.

The proponents design so far does not provide specifics of how remediation will be

done in the event of a failure of leachate containment, nor who the responsible

parties will be, nor how the costs will be covered.

Again, given that the Sorell Council is a joint owner of the facility and land which sit

within the Sorell Municipality footprint, and SWS have stated that they will set up a

trust fund with Sorell Council to maintain the site, it is clear that the responsibility for

remediation will eventually fall to that Council and consequently, another burden upon

local rate payers.

Specific and careful long term financial planning and prudence, to take into

consideration insurance and extra remediation costs, will be requisite for Sorell

Council from when the C-cell becomes operational, continuing indefinitely. It is not

something that can be just left up to a ‘trust fund’ with indefinite terms.

47 Sanjour Landfill Leak Report, U.S. 1982 (Statement from William Sanjour, Chief Hazardous

Waste Implementation Branch, US Environmental Protection Agency before the Subcommittee on

Natural Resources, Agriculture Research and Environment Committee on Science and Technology

House of

Representatives) November 1982


Comment [cb174]: This is all

incorrect and ignores the fact that the

C cell will primarily accept legacy

waste that is currently inappropriately

contained, often on our river banks.

So the C cell enhances the protection

of groundwater. Comment [cb175]: Tasmanian

landfills are properly regulated and

monitored; and technology and

regulations have changed significantly

in recent years. Comment [cb176]: This is one of

the reasons why a trust fund will be

established. The cost of the trust fund

will be factored in to the gate fee. Comment [cb177]: It is interesting

that the writer of this document

thinks that a paper dating from 1982

is relevant to this ‘debate’. Comment [cb178]: This is untrue.

The cap will have 2 impermeable

layers – one of which is 1000 mm

compacted clay, as well as a drainage

layer and topsoil. Comment [cb179]: This is also

untrue. The cell cap prevents moisture

entering and no leachate will be

generated after capping. Leachate

does not take years to migrate

through a landfill which is what this

comment implies. Comment [cb180]: The permit

does not list any hazardous materials

that will be accepted in to the C cell. Comment [cb181]: This is not true. Comment [cb182]: This is not true. Comment [cb183]: This is all not

true. The point of the C cell is to

contain material including leachate.

No remediation will be required other

than capping the cell. Comment [cb184]: This will not

happen. The statement is false. The

potential loss of leachate is dealt with

in the DPEMP risk assessment. Comment [cb185]: This is not true.

That is the whole purpose of the trust

fund. It is also not true that the fund

will be ‘set up’ with Sorell Council. Comment [cb186]: No it won’t. It is

the responsibility of SWS.

5.0 Economic Impacts 5.1 Economic Liabilities

The development of a Category C-Cell at Copping Landfill Site poses very serious risks

to the economy within the local region and the broader Tasmanian community.

Examples include:

• Oysters Tasmania and the Tasmanian Shellfish Executive Council have both

clearly and publicly stated that they:

‘… are opposed to the development of the proposed C-Cell being built and

situated where leakage is likely to contaminate the nearby estuary and water

ways – waterways on which our members rely for the production of pristine

Tasmanian seafood. The Carlton River, into which any leakage would drain,

feeds 3 major oyster farming areas which have a large employee base and

produce spat – baby oysters – for about half of Australia’s Pacific oyster

farming sector.’ 48

A good example of just how vulnerable our marine industries are to changes in

water quality, and the major impacts this can have can have on the economy

as well as public health, was the recent recall of Spring Bay Mussels from

Tasmania’s East Coast due to naturally occurring algal blooms. Affected

businesses will be feeling the effects of that recall for months - if not years - to

come.

Linked to this same algae bloom, Scallop fishermen in Tasmania will lose an

estimated 1 million dollars in income following a decision to abandon the

scallop season on the east coast. Scallop fishing came to a halt early in

November after a naturally occurring toxic algal bloom affected waters in the

east coast fishing grounds.49

One can only imagine just how economically damaging any contamination from

a Category C-Cell at Copping would be to local marine and aquaculture

industries, with flow on affects for the whole of Tasmania; industrial (heavy

metals for example) contamination is a great deal harder to control with than a

naturally occurring algae bloom.

• Despite reassurances given by the proponents regarding the integrity of the

development, a negative public perception about the development already

exists – this perception alone is enough to have tangible impacts on real

estate values in the immediate area and also in the areas most likely to be

affected should there be a failure at any time in the future (i.e. the Southern

Beaches region, given its location in regards to the mouth of the Carlton

River).

Anecdotally, local real estate professionals acknowledge that potential buyers in

the region have expressed serious concerns about the prospect of a category C-

cell being developed in the region and have shied away from potential real

estate purchases accordingly. As previously stated, the Southern Beaches is a

popular and expanding residential location.

48 Letter from Oysters Tasmania to Southern Waste Solutions, October 2012

49 ‘Scallop season abandoned but mussels back flexing’, The Mercury, 11 December 2012:

http://www.abc.net.au/rural/tas/content/2012/12/s3651208.htm?site=northtas

28

Comment [cb187]: The reverse is

the case. A report prepared by

Sustainable Infrastructure Australia

available on our web site

swstas.com.au concluded that the lack

of infrastructure such as a C cell may

result in significant costs to Tasmanian

businesses and may impede economic

expansion of the State. Comment [cb188]: Unfortunately

these comments were made without a

full understanding of the

development. There is no likelihood of

contamination of any waterway or

estuary. In fact the C cell allows them

to be cleaned up. An oyster grower in

the catchment telephoned to express

strong support for the development

based on environmental grounds. Comment [cb189]: This was totally

unrelated to the existing Copping

landfill or to the proposed C cell. Comment [cb190]: This is

unfortunate but bears no relationship

to the Copping landfill or the C cell. Comment [cb191]: And that sums

up this document. Imagination with

no basis in fact or science. Comment [cb192]: THE FIRST

EDITION OF THIS DOCUMENT

CLAIMED THAT THE TASMANIAN

FARMERS AND GRAZIERS

ASSOCIATION HAD WRITTEN TO THE

EPA EXPRESSING SERIOUS CONCERNS

ABOUT THE EXISTING B CELLS AT

COPPING. IT WENT ON TO DRAW

INFERENCES ABOUT THE OPERATION

OF THE C CELL. THE TFGA HAS NO

SUCH CONCERNS AND NEITHER DOES ... [30]Comment [cb193]: Solely due to

the activities of this group. Comment [cb194]: This personal

opinion is in direct conflict with

previous claims of population growth

in the area surrounding the landfill.

The protesters are potentially ... [31]Comment [cb195]: The C cell is

located approximately 17.5 times the

recommended distance from a

watercourse. Comment [cb196]: But the writer

previously claimed that the population

was on the rise, which will underpin

property increases. Any ‘anecdotes’

such as this one should be placed in ... [32]Comment [cb197]: If it is

expanding then demand is high and

values will increase. This is in direct

conflict with the previous assertion.

• Residents and other concerned community members have raised serious

concerns about the impact the development will have on public amenity in

the area, given risks to public health (though the risk of air borne

contamination); and through increased traffic and the impact this will have

on an already significantly degraded Arthur highway and bridges.

The proponent’s DPEMP estimates that five extra trucks a day will access the

site, but this again cannot be guaranteed and could be immeasurably higher

depending on demand for the cell if and when it is operational.

• There are unanswered questions around the impact the development will

have on neighbouring property owners’ ability to become certified as ‘Organic

producers’, given the high risk nature of the C-cell adjacent to their land. The

development has the potential to render neighbouring property owners

ineligible to tap into the highly lucrative and growing niche organic market,

thereby compromising their livelihoods and their potential businesses.

• Finally, it is important to consider our intergenerational environmental

responsibility. No one can guarantee the future of this proposed C-cell and

therefore we must acknowledge the real possibility of creating a toxic legacy

for our future generations to inherit. 5.2 Economic benefits

There has been no statement of likely economic benefits to the community or

Tasmania that might flow from the development of the C-Cell.

Anecdotal statements have been made by the proponent saying, 'this will be an

economic boon to the region,' but details on this, and a business case for the

operation of the facility seem to be non-existent – at lease not publicly available!

The proposed remediation of the Hobart Rail yards at Macquarie Point - a 50 million

dollar project funded by the Federal Government, currently appears to underpin the

barely existent SWS business case for the Copping C-cell. At the time of writing this

document, no official authority has confirmed that the to be cleaned up rail yard soil

will be placed in the Copping C-cell

How will business profits be distributed and will they in any way benefit the

community that will ultimately be responsible for future liability? This is yet to be

answered by the proponent or owner Councils.

Alternative strategies such as onsite remediation of contaminated sites, including

the Hobart Rail yards should be thoroughly and openly explored. A fraction of the 50

million dollars set aside for the Rail yards would go a long way towards a properly

resourced, waste recovery industry in Tasmania.


Comment [cb198]: The community

has raised unfounded concerns. And

because concerns have been raised

SWS has publicly stated that it will

voluntarily undertake depositional

monitoring to prove that no air borne

contaminants leave the site. The

results of this monitoring will be

publically available, as are results of

monitoring of the existing landfill. Comment [cb199]: The average

increase in traffic is 5 per day, or 10

movements per day, compared with

current movements of 3,300 per day.

That is only 0.3%.

Comment [cb200]: If anything the

presence of the C cell gives the

community more leverage in their

request for upgrades. SWS is more

than happy to actively engage in

lobbying for upgrades to the highway ... [33]Comment [cb201]: If there are

more than 5 trucks per day at any

time, then the law of averages

dictates that there will be fewer than ... [34]Comment [cb202]: SWS’

discussions with certifiers of organic

status indicate that the C cell should

not impact on certification if no ... [35]Comment [cb203]: This is a highly

unlikely scenario. Comment [cb204]: Again the writer

is ignoring the fact that the C cell will

primarily accept legacy material that is

currently inappropriately contained, ... [36]Comment [cb205]: Refer to previous comments. A report prepared by Sustainable Infrastructure Australia (SIA), ... [37]Comment [cb206]: Refer to the SAI

report available on our web site

swstas.com.au Comment [cb207]: The business

case is not barely existent. It has been

presented in draft form to a number

of entities. Comment [cb208]: It is up to the

Authority how any profits are

distributed. The community will not

‘be responsible for future liability’. ... [38]Comment [cb209]: Other options

have been explored and will continue

to be explored. Comment [cb210]: This may well

be the case but this was not the

purpose for which the funds were

allocated.

6.0 Science and Engineering

Many questions have been put to SWS regarding the design and engineering of the

proposed C-cell at Copping. The proponents’ responses have been general in nature

and many questions put to SWS about such issues, remain unanswered.

SWS claim that the Copping C-Cell will be ‘world’s best practise’. In reality, it is

more a case of ‘world’s best guess.’

‘… These quasi-engineered pits are no more than in-situ repository experiments,

backed up by neither defensible scientific proof of adequate on site performance nor

component by component laboratory testing. …The costs of repairing the inevitable

cap failures and mitigating the probable migration plumes for each landfill will be

million dollar propositions. Since these difficulties will occur years or perhaps decades

after closure, the likelihood is low that the facility developer or even

adequate funds in trust for the job will be available.’ 50

6.1 EPA Risk Matrix

The EPA risk assessment outlined in the current DPEMP for the proposed C-cell at

Copping openly acknowledges an alarmingly large number of moderate, high or

extreme risks associated with this development and the subsequent operation of the

C-cell.

Furthermore, many of these risks will only increase over time as the facility ages,

the pressure on the cell increases and ongoing monitoring and maintenance

reduces.

Although the consequences for most of these risks are accurately reported, SBCS

strongly believe the DPEMP dramatically understates the likelihood of these risks

occurring, which in turn skews the overall risk assessment to the point that it is

misleading, as further explained below.

• The Copping site is adjacent to a known 300 metre vertical fault in an area

that has displayed significant seismic activity in the form of seismic clusters

(known as swarms). Swarms are a phenomenon notable for their heralding

of larger seismic events. This seismic activity has not been taken into

account in the risk assessment in the risk assessment of the DPEMP.

• Modelling for the site has relied on hydrological studies undertaken from

2003 – 2007, all years with significantly below average rainfall. Since this

time, the Carlton River has seen annual flood events in the years 2009, 2010

and 2011. All above average rainfall modelling within the DPEMP are

projections without any real data. Omitting this data from the modelling raises

serious concerns regarding the risk assessment outcomes and likelihood of

failure.

• The EPA risk matrix identifies a minor failure as having a high environmental

risk, while a moderate to catastrophic failure represents an extreme

environmental risk. The likelihood ratio for failure is set to increase over time

as the High Density Polyethylene (HDPE) barrier liners degrade. In situ studies

from around the world have demonstrated that these barrier liners can

commence to perish in as little as 20 years under hazardous waste cell

conditions. Further information regarding the cell liners is below.

50 Sanjour Landfill Leak Report, U.S. 1982 (Statement from William Sanjour, Chief Hazardous Waste Implementation Branch, US Environmental Protection Agency before the Subcommittee on Natural Resources, Agriculture Research and Environment Committee on Science and Technology House of Representatives) November 30, 1982, pg 3

30

Comment [cb211]: And they have

all been answered. Comment [cb212]: Again it is

interesting to note the writer’s

selection of outdated and in this case

highly emotive and prejudiced

comments. Times, technology and

regulation have changed a lot in the

past 30 years. Comment [cb213]: This is not true.

Cap failures are not inevitable. The C

ell cap will be maintained in to the

future with the backing of the trust

fund. Comment [cb214]: Again, an

outdated opinion. Times have

changed. Comment [cb215]: There is no such

thing. Comment [cb216]: The risk

assessment is included in the DPEMP.

It was not prepared by the EPA. Comment [cb217]: These

unfounded statements again

demonstrate a lack of knowledge of

risk assessment. Potential risks are

identified and rated prior to

establishing the likelihood of the

event occurring and ways to mitigate

the risk. The end result is what counts

and that is an assessment of risks as

being low other than some transport

risks which by definition cease after ... [39]Comment [cb218]: The group is

entitled to its amateur opinion. SWS

and the regulators rely on qualified

and experienced scientists and ... [40]Comment [cb219]: The fault is not

related to seismic activity. As

commented earlier it is the result of

the intrusion of dolerite during the ... [41]Comment [cb220]: This is all

untrue. Modelling, including the

potential effects of climate change,

was performed by appropriately ... [42]Comment [cb221]: Again, it is not

the EPA’s risk matrix. These comments

demonstrate a lack of knowledge of

the planning and assessment ... [43]Comment [cb222]: As commented

previously the writer continues to

demonstrate a lack of understanding

of risk assessment principles and ... [44]Comment [cb223]: This is untrue.

In relation to the HDPE membranes,

the service life is determined by (page

659 of Rowe): ... [45]

6.2 High & Low Density Poly Ethylene (HDPE /LDPE)

HDPE is a geo-membrane liner (flexible membrane liner) and is the preferred liner

for landfills. It is what is planned to be used in the proposed C-Cell at Copping.

Recent scientific studies have confirmed once again why modern ’dry tomb’ landfill

technology will always fail and should always be expected to poison groundwater.

The ‘dry tomb’ land-filling approach is basically an open dump where compacted soil

(clay) and plastic sheeting (flexible membrane liners) are used to try to isolate the

untreated MSW [Municipal Solid Waste] from moisture. This containment system is

also designed to try to collect and manage leachate generated within the dry tomb.

Other countries and geographical areas in parts of Canada and Western Europe have

chosen not to adopt he dry tomb method of land-filling, typically because of the

likelihood of the ultimate failure of the dry tomb containment (liner) system.51

A 2011 geomembrane study by the US Geosynthetic Institute52 concludes that the

maximum in-situ landfill lifespan for a HDPE liner at 2.5mm thickness is 446 years

with the minimum being just 69 years.

The proposed liners for the C-Cell at Copping are 2mm53 thick!

The same paper suggests a lifespan of just 36 years maximum for the LDPE liner

that is to form the cap of the proposed C-Cell.

A 1990 examination54 of the best available landfill liners concluded that brand-new

state-of-the-art liners of high density polyethylene (HDPE) can be expected to leak

at the rate of about 20 gallons per acre per day (200 litres per hectare per day)

even if they are installed with the very best and most expensive quality-control

procedures. This rate of leakage is caused by pinholes during manufacture, and by

holes created when the seams are welded together during landfill construction.

(Landfill liners are rolled out like huge carpets and then are melded together, side by

side, to create a continuous field of plastic). New examination of actual landfill liners

reveals that even the best seams contain some holes. In addition to leakage caused

by pinholes and failed seams, new scientific evidence indicates that HDPE allows

some chemicals to pass through it quite readily.

A 1991 report55 from the University of Wisconsin details that dilute solutions of

common solvents such as xylene, toluene, trichloroethylene (TCE), and methylene

chloride, penetrate HDPE in one to thirteen days. Even a HDPE sheet 2.5mm thick

51 Municipal solid waste management in lined, "dry tomb" landfills: a technologically flawed approach

for protection of groundwater quality, Fred G Lee & Anne Jones-Lee, 1992:

http://www.calwater.ca.gov/Admin_Record/C-036205.pdf

52 Geomembrane Lifetime Prediction: Unexposed & Exposed Conditions. GRI White Paper #6, Koerner

R.M., Hsuan Grace Y. & Koerner G.R. 2011



54 Field Behaviour of Double-Liner Systems (editor), WASTE CONTAINMENT SYSTEMS:

CONSTRUCTION, REGULATION, AND PERFORMANCE [Geotechnical Special Publication No. 26],

Bonaparte R. & Gross B. A. 1990, pgs. 52-83.

55 Toxic Gases emitted from landfills, (Rachel’s Hazardous Waste News #226), Peter Montague,

Environment Research Foundation, 1991: http://www.ejnet.org/rachel/rhwn226.htm


Comment [cb224]: One of the

liners. There are three types and four

liners (excluding the cap). Two HDPE,

one geosynthetic clay and one natural

clay. Comment [cb225]: This is untrue. Comment [cb226]: Copping is a

scientifically engineered and

constructed landfill not a dump. Comment [cb227]: Municipal solid

waste will not be deposited in the C

cell. Comment [cb228]: Once again the

writer is citing outdated sources.

Technology and regulation have both

improved significantly in the past 20

years. Comment [cb229]: This is untrue.

Liner longevity depends on the liner

and its environment, and the way it is

handled. Refer to prior detailed

comments. Comment [cb230]: A quarter of a

century ago. Comment [cb231]: Leaving aside

the outdated nature of this

‘examination’ these comments ignore

the fact that the C cell has four

impermeable layers. There are two

HDPE liners, one geosynthetic clay and

one natural compacted clay. Comment [cb232]: This is why we

have four impermeable layers and a

witness sump. Comment [cb233]: Almost a

quarter of a century out of date. Comment [cb234]: These items will

not be in the C cell.

(the thickness used in the most expensive landfills) is penetrated by solvents in less

than two weeks.

Another problem that has recently become apparent with HDPE liners is ‘stress

cracking’ or ‘brittle fracture’. For reasons that are not well understood, polyethylene,

including HDPE, can become brittle and develop cracks.

A 1990 paper56 published by the American Society for Testing Materials revealed

that HDPE liners have failed from stress cracks in only two years of use.

Polyethylene pipe, intended to give 50 years of service, has failed in two years.

’…While the long-term stability of geo-membranes (flexible membrane liners) in

landfills cannot be defined, there is no doubt that they will eventually fail to function

as an impermeable barrier to leachate transport from a landfill to groundwater.

Further, and most importantly at this time, there are no test methods, having

demonstrated reliability, with which to evaluate long-term performance of flexible

membrane liners.’57

6.3 Clay Liner

The proposed development for the Copping C-Cell is that an HDPE liner will be

complimented by a compacted clay liner.

If a naturally occurring clay soil is compacted to high density, thereby producing a

material with very low hydraulic conductivity, and if it is maintained within the same

ranges of temperature, pressure, and chemical and biological environment, it would

be expected to function well as a seepage barrier indefinitely.

In waste containment applications, however, conditions do not remain the same. The permeation [penetration] of a compacted clay liner by chemicals of many types is inevitable, since no compacted clay or any other type of liner material is either totally

impervious or immune to chemical interactions of various types. 58

Some other worthy points to note on clay liners:

• SWS claim that the proposed one metre thick clay base liner will last for

thousands of years, without citing the specific reference to which they are

referring and using this single anecdotal reference to dispute sound scientific

evidence.

Studies have found that chemicals such as chlorides and volatile organic

compounds can be the transported through clays (Ficks laws of diffusion). For liners of a typical approximate 1m thickness, simple diffusion can cause

breakthrough of mobile contaminants in approximately 5 years; the diffusive flux

of contaminants out of such liners can be large. 59

There is concern that the clay liner for the proposed C-cell will be affected by the

salinity of groundwater in the immediate area. The introduction of saline water,

56 ASTM International: http://www.astm.org/Standards/F2136.htm




58 Geomembrane Lifetime Prediction: Geosynthetic Institute Organization – Issue Paper 6, update Feb. 8,

2011

59 Flawed Technology of Subtitle D Landfilling of Municipal Solid Waste, G. Fred Lee & Associates, CA,

October 2012, page 21

32

Comment [cb235]: The reasons are

relatively well understood and this is

why the liners of the C cell will be

properly installed and handled to

prevent such events. Once again it

needs to be remembered that there

are multiple impermeable layers, and

three different types of liner. Comment [cb236]: Almost a

quarter of a century out of date again.

In relation to HDPE membranes, the

service life is determined by (page 659

of Rowe):

• Physical puncturing

• Tensile strains

• Antioxidant depletion rates

• Exposure to leachate

• Temperature.

The C cell conceptual liner design

deals with all these issues.

For example:

... [46]Comment [cb237]: And a

geosynthetic clay liner. Comment [cb238]: Correct. And

the writer has in this case accurately

described the conditions within the C

cell. Comment [cb239]: In the C cell

they will remain substantially the

same. Waste is dry and separated so

there will not be chemical reactions

within the cell. And it will be capped ... [47]Comment [cb240]: There are three

impermeable layers between the level

3 material and the compacted clay

liner. Not to mention the fact that

there will not be any chemicals ... [48]Comment [cb241]: There will not

be chemical interactions within the

cell. Different material types are

segregated within the cell and the

material is dry. Comment [cb242]: There is no

sound scientific evidence to the

contrary.

... [49]Comment [cb243]: The Copping C

cell does not have liners this thin. It

also has multiple liners. Comment [cb244]: There may be

concern expressed by poorly informed

amateurs. Professional scientists and

engineers have no such concerns. It

should also be remembers that ... [50]

acid water, or water rich in ammonium, divalent and trivalent cations will cause swelling clay domains to excessively coagulate to the particle-size equivalent of silt or fine sand. This can cause natural clay liners or imported bentonite liners to

leak.60 The ground water quality in proximity to Copping tip site is shown to a high

level of salinity 3000-7000 Milligrams / Litre.61

• In addition research shows that compacted clay liners may also suffer from

Desiccation Cracking and Cation Exchange-Related Failures62.

o Desiccation cracking of clay liners arises from the fact that in order to achieve

the design permeability it is necessary to add water to the clay to achieve

slightly wetter than optimum moisture density. In time, however, due to

unsaturated transport of the water added to the clay, the clay can dry out,

leading to shrinkage and desiccation cracks. This situation is readily observed

in some soils, where during periods of low precipitation, soils will crack.

o Cation Exchange-Related Failure - Some types of clays used in landfill liners,

with an expandable lattice structure, exhibit strong shrink/swell properties

dependent on the type of cation on the clay’s ion exchange sites. With sodium

at the exchange site, the clay is in a swollen state. However, in contact with

water with high calcium/magnesium compared to sodium concentrations, the

calcium and magnesium will replace the sodium on the clay, and the clay will

shrink, leading to higher permeability and possible failure through cracking.

6.4 Further information about liners

• The proposed C-Cell will contain 300,000 cu meters of ’spade-able’ waste

material. However, ’spade-able’ implies intermixed solid material i.e. absorbing

clay or sand mixed with liquids (for example, spilled lubricants, fuels, industrial

effluent by-products) which that will separate over time. Any measures such as

the proposed liners, dealing with leachate should bear in mind that the volume

of leachate may be thousands to tens of thousands of cubic metres. Moreover,

it will take months to years for the liquid to drain down from the top where the

new material is introduced to the bottom where the leachate is collected.

• Another interesting point,63 that ’…the intermixing of inorganic and organic

wastes, wastes of high and low pH, and wastes having different physical

properties in a common disposal area, may lead to influences on the

environment not anticipated from any single waste material.’

This is important because landfill liners are selected to be compatible with

the wastes that will be placed into a landfill. However, as this statement

suggests, the mixing of wastes in a landfill may produce unanticipated

chemical combinations with unpredictable results therefore, a landfill liner

selected to withstand attack from chemicals X, Y and Z may not withstand

attack from chemicals X and Z in combination, or Y and Z in combination.

60 ‘Hazardous Materials Management’, Department of Resource Energy and Tourism, Oct. 2009, page 13

61 Southeast Tasmania Groundwater Map, Department of Infrastructure, Energy and Resources




Comment [cb245]: Again the writer

ignores the fact of multiple liners of

differing composition. Comment [cb246]: The compacted

clay liner under the C cell will not have

an evaporative surface so will not dry

out or desiccate. It is a physical

impossibility. Comment [cb247]: This is untrue.

The C cell liner will not be exposed to

the air and so has no evaporative

surface to facilitate desiccation. Comment [cb248]: This does not

apply to conditions pertaining in the C

cell. Comment [cb249]: It implies

nothing. It means material such as soil

and timber. Comment [cb250]: Leachate will

take months not years to leave the

cell. The leachate collection and

evaporation system is designed to

appropriately evaporate the volume

of leachate that will be produced. Comment [cb251]: Different types

of material will be separately stored

within the cell. There will be no

intermixing. Comment [cb252]: The only type of

organic waste that will be accepted in

to the C cell is timber and it will be

separately stored within the cell. Comment [cb253]: And this is why

the three different types of liner have

been selected for the C cell. Comment [cb254]: Different types

of material will not be mixed. They will

be separately stored within the cell.

The more chemicals involved, the greater the number of possible

combinations, the more complex the interactions will be, and the less

predictable the results become!

The study goes on to say ’…the wastes that are deposited continue to

weather and leach for years.’

The chemical interactions within a landfill do not cease when the dumping

stops. In the case of inorganic materials (such as arsenic, lead and chromium)

the duration of the hazard is essentially infinite - toxic metals will never

change into anything besides toxic metals.

6.5 Leachate collection and storage ponds

It is proposed that leachate from the C-cell will be evaporated off and then

reintroduced into the C-cell. This will mean that it will likely take many years before all

of the liquid in the C-cell has migrated to the bottom of the landfill, been pumped into

the evaporation pond, had its water removed and then be put back into the landfill.

This process will last well after the cell has been capped, and it will be hard to

estimate how long after closure it will need to continue in order to achieve reduction of

the liquid in the landfill.

There are concerns that surface stormwater run-off in the event of flood or high

rainfall will enter the leachate ponds and contaminated overflow will spill into the

environment. The proponent has not provided design detail on how this risk will be

fully mitigated.

Furthermore, there is potential for inadequate elevation of the leachate ponds above

groundwater levels during periods of high rainfall.

Design of the lining of the leachate ponds and leakage monitoring systems for the

ponds was not included in the approved DPEMP and is still subject to detailed design

by the proponent.

At this point it remains unclear to the public as to how surplus leachate will be dealt

with during low evaporation periods, even though this question has been asked of the

proponent.

6.6 Alternative Waste Treatment Methods

As discussed, Australia has a National Waste Policy, which has informed State

Government policy throughout Australia including the Tasmanian Waste & Resource

Management Strategy.

These policies define approaches to waste management in terms of a Waste

Management Hierarchy - an inverted pyramid where landfill is the last option after

all other strategies have been applied.

‘

Such policies and strategies align with progressive international waste management

strategies64 that promote the 4 R’s – Reclaim energy from waste that cannot be otherwise Reduce, Reuse or Recycle.

Current national and international best practise standards recommend landfill as the

last option after all other possibilities have been explored and exhausted.

64 Reference from the 6t International Conference on Waste Management and the Environment 4 - 6 July 2011, New Forest, UK: http://www.wessex.ac.uk/12-conferences/waste-management-2012.html

34

Comment [cb255]: This does not

apply to the C cell as it will be capped

after approximately 10 years and no

more leachate will be produced. Comment [cb256]: There will be no

chemical reactions within the C cell as

different types of material will be

separately stored, and the material

will be essentially dry. Comment [cb257]: Untrue when a

cell has been capped with two

impermeable layers, not to mention

the four underlying impermeable

layers. Comment [cb258]: This is untrue.

The material is essentially dry, it will

be regularly covered to prevent rain

water entering and the cell will be

finally capped after approximately 10

years. Comment [cb259]: None held by

qualified and professional scientists

and engineers. Comment [cb260]: The cell is at

around 48 m above sea level. It will

not flood. Comment [cb261]: The design

detail will be approved by the

independent regulator prior to

construction. Comment [cb262]: Leachate ponds

will be at least 15 m above

groundwater. Comment [cb263]: This is not

totally correct. The detailed design will

be approved by the independent

regulator prior to construction. The

DPEMP contains considerable

information (pp 47 – 54) Comment [cb264]: Please read the

DPEMP which is a public document.

Pages 47 -54 are relevant.

The first key Principal in the Tasmanian Landfill Sustainability Guide 2004 (1.2.165)

advises … waste management performs a critical role in public health and safety and

amenity. Effective waste management also provides an opportunity to conserve

resources through effective avoidance and diversion of waste.

This is effectively expressed through a hierarchy of waste management options,

which are listed below in order of preference: a) avoidance; b) reuse; c) recycling;

d) energy recovery and e) disposal.

This hierarchy recognises that waste is best reduced or avoided at the point of

production or generation, and that there is a need for strategies for re-using and

recycling those wastes that are generated. Inevitably, some residual wastes will need

to be disposed of to landfill, but this should only occur when options further up the

hierarchy are not practicable’

Such consideration of alternative treatment processes has not taken place by the

proponents of the Category C-Cell at Copping Landfill Site.

When asked what alternative waste management options have been considered for this proposed development, ‘Southern Waste board director John Brennan said

“alternatives were too costly and the organisation was a landfill business only”66

6.7 Science and Engineering - Summary

Municipal solid waste management in lined, "dry tomb" landfills: a technologically

flawed approach for protection of groundwater quality67

The above statement in a report by Fred Lee and Anne Jones-Lee, reviews recent

evidence (much of it produced by government-funded research) that:

• landfill liners leak for a variety of reasons;

• leachate collection systems clog up and thus fail to prevent landfill leakage;

• landfill leachate will remain a danger to groundwater for thousands of years;

• even low-rainfall areas are not safe for landfill placement;

• gravel pits and canyons are particularly dangerous locations for landfills;

• maintaining a single landfill's ‘cap’ for the duration of the hazard will cost

hundreds of billions, or even trillions, of dollars;

• groundwater monitoring cannot be expected to detect landfill leakage;

• groundwater, once it is contaminated, cannot be cleaned up and must be

considered permanently destroyed; and


2004, pg 4

66 Toxic Truth out in dump row, The Mercury, 13 September 2012





Comment [cb265]: It is interesting

that the writer admits this to be the

case. Comment [cb266]: SWS operates a

landfill and it is not its responsibility to

consider alternatives. However

reducing waste to landfill reduces

SWS’ costs and extends the life of its

assets. Putting a commercial price on

disposal of level 3 waste passes costs

on to consumers and encourages

producers of this material to reduce

its production. The absence of a C cell

does not send these environmentally

responsible messages, and does not ... [51]Comment [cb267]: It is up to

industry to consider alternatives. They

have no incentive to do so in the

absence of a C cell and associated ... [52]Comment [cb268]: Technology has

changed considerably in the

intervening period – almost a quarter

of a century. Comment [cb269]: Fred and Anne

must have special powers to be able

to review recent evidence in a paper

dated almost a quarter of a century ... [53]Comment [cb270]: Which is why

the C cell will be properly managed to

ensure that these reasons do not

occur. Comment [cb271]: The C cell

system is designed to prevent ‘clog

up’. Comment [cb272]: This is untrue.

The cell will be capped after

approximately 10 years and leachate

will cease to be produced. Comment [cb273]: The writer

acknowledges that landfills are

necessary. If not in low rainfall areas

then where? Comment [cb274]: Neither the

existing landfill cells nor the C cell are

located in such positions. Comment [cb275]: This is another

unsubstantiated outlandish

statement. The cost consists of

gardening. There is no real hazard. ... [54]Comment [cb276]: If groundwater

is not affected then there is unlikely to

be a leak. In any event it is not only

groundwater that is independently ... [55]Comment [cb277]: Which is why

the C cell has multiple impermeable

layers (of three different types), a

witness sump, a significant clearance ... [56]

• groundwater is a limited and diminishing resource which modern societies

grow more dependent on as time passes

Such a large volume of data showing clear flaws in the liners (HDPE, LDPE and Clay)

is a major cause for concern especially considering a failure of a C-cell in the

Copping location will result in ground and surface water contamination, further

resulting in major, irreversible damage.

All landfills lined or not, will eventually contaminate groundwater. Lined landfills will

contaminate groundwater more slowly than unlined landfills, but the long-term effects

will be the same - someone's groundwater will become contaminated whenever

municipal solid waste or industrial waste or legally hazardous wastes are placed in the

ground. When anyone proposes a new landfill and says that liners are being selected

to prevent contamination of the environment, you should ask:

(a) How can they possibly predict all the possible combinations of chemicals that will

be created inside the landfill, producing new combinations of chemicals that will attack

the liners?

And

(b) What is the expected duration of the hazard inside the landfill vs. the expected

duration of the liners that have been selected?

There is no such thing as a secure landfill for perpetuity!

36

Comment [cb278]: A lot of it

outdated and the remainder

selectively quoted. Comment [cb279]: A sweeping

statement with no evidence to back it

up. Regular monitoring at Copping

shows that groundwater is cleaner

leaving the site than it is entering the

site. Comment [cb280]: Different types

of materials will be separately stored

within the cell. There will be no

combinations of chemicals. In addition

the material will not be liquid. Comment [cb281]: Using Rowe’s

antioxidant depletion figures (his

Table 5), this means the service life of

the membranes will be 100 to 300

years. This is longer than the

operational life of the cell. By the

time the membranes ‘failed’, the cell

would be dry entombed, with no

leachate being generated. So, any

‘failure’ of the membranes would be

irrelevant.

Τhe cell liner design is not wholly

dependent on the HDPE membranes –

it has a geosynthetic clay liner and

also a compacted clay liner – both of

these have service lives of many

centuries (provided they don’t

dehydrate). So, even if the HDPE

membranes ‘failed’ while the cell was

operating, the clay liners on their own

will be more than adequate.

7.0 Antarctic Waste

Under both the Basel Convention and the Madrid Protocols, Antarctic Treaty

members are required to repatriate or remediate their waste from Antarctic

territories to their own sovereign territory. The Australian Antarctic Division

(AAD) estimates it has approximately 10 000 tonnes of waste to repatriate from

Australian operation in Antarctica.

Technically and historically, Antarctic waste has been deemed Quarantine waste. The

last significant quantity of waste removal from AAD operations was directed to

Fremantle, Western Australia by Commonwealth Quarantine services as that port has

quarantine facilities that Hobart lacks. Despite this, small volumes of Antarctic waste

have returned to Hobart to be primarily disposed of at the McRobies Gully landfill

site.

Quarantine waste is any waste that has been transported to Australia from other

territories via shipping or aircraft. This includes waste that may be repatriated from

Antarctica. It is thought that the quarantine waste in Australian Antarctica Territories

is likely to be controlled waste in the form of contaminated soils (primarily low levels

of lead), oils and hydrocarbons.

Legislation (Quarantine Act 1908) relating to quarantine waste is administered by the

Australian Quarantine & Inspection Service (AQIS) and Biosecurity Australia at a

Commonwealth level. In Tasmania, the agency Quarantine Tasmania is responsible for

ensuring appropriate services and facilities meeting Commonwealth

requirements are met.

Tasmania currently has two facilities that can accept quarantine waste at a port.

Both are incinerators, one located at Bell Bay, the other at Burnie. This is

problematic for waste being repatriated from Antarctica as the obvious port for

shipping is Hobart and Bell Bay has recently ceased international shipping. There are

significant costs in handling and transporting quarantine waste that require strict

adherence to handling and transport requirements.

SWS has flagged Antarctic waste as a significant contributor to help underpin the

business case of its proposed hazardous waste dump at Copping. This is very

problematic in the absence of a quarantine waste facility in Hobart. An autoclave

facility based at the port of Hobart would be required to satisfy quarantine

requirements. SWS have publicly stated that they are courting both French and

Chinese Antarctic waste and are open to waste from other treaty members with an

Antarctic waste footprint

In relation to quarantine waste being disposed of at landfill, the 2008 Sustainable

Infrastructure Australia (SIA) report states the following; ‘In view of the long life

(often years) of some bacterial and viral infectious substances, and the viability of

many seeds and bacterial/ fungal spores in the soil environment (and the potential for

these to be wind and water-born), the practice of burial of quarantine waste at a

landfill can be inadequate, even potentially hazardous.’


Comment [brennanen282]: This is

not true. For Australia it would not

require any Basel convention approval

for its own waste to return to

Australia. For another country

returning Antarctic waste to Australia

a permit would only be required for

waste deemed by the Basel

Convention and Australian hazardous

waste legislation as hazardous. Some

materials for recycling and reuse can

be returned to Australia from other

Antarctic nations without any Basel

Convention requirements to apply

It is not true that waste generated by

an Antarctic nation has to be returned

to the sovereign territory. In the

Madrid Protocol, Annex III, article 1

part 4 states 4. Wastes removed from ... [57]Comment [brennanen283]: This is

not true. The port in WA just off

loaded the material and it went for

deep burial at a landfill in WA. Hobart ... [58]Comment [brennanen284]: This is

untrue. For at least 5 years all

quarantine waste arriving at Hobart

through shipping and air has been ... [59]Comment [brennanen285]: There

are two different waste streams

generated by Antarctic activities.

Waste inc,using recyclables generated ... [60]Comment [brennanen286]: Not

true Comment [brennanen287]: Quara

ntine Waste is deep buried in Tas. No

incineration occurs. Comment [brennanen288]: While

cost may be higher than general waste

it is not significant to the degree

expressed Comment [brennanen289]: C Cell Comment [brennanen290]: They

have no understanding of the process.

A facility does not need to be at the

port if the landfill is AQIS approved ... [61]Comment [brennanen291]: No

this is not true. Case in point current

quarantine waste lands at port now or

comes in via hbt airport. We have no ... [62]Comment [brennanen292]: I do

not believe that SWS has said this at

all. Comment [cb293]: It is highly

unlikely that waste materials from

legacy hazardous waste from

Antarctica would present a bio ... [63]

The same report further identifies transport of quarantine waste away from ports

and through regional agricultural land as being highly undesirable and imparting

additional quarantine requirements. The Tasmanian agricultural sector is highly

sensitive to quarantine and biosecurity threats.

While it is desirable to repatriate waste where required from Antarctica, land-filling

waste is the least desirable waste outcome under both the Commonwealth 2009

National Waste Policy and the 2009 Tasmanian Waste & Resource Management

Strategy. As the bulk of Antarctic waste from AAD operations is in the form of low level

contaminated soils, a preferred outcome would be to remediate those soils in-situ or in

a development that requires the same such as the proposed Macquarie Point Railyard

development in Hobart. Such remediation of soil involves primarily ‘cooking’ the soil at

over 4000 C and chemically immobilising heavy metal contaminants.

38

Comment [brennanen294]: AQIS

Canberra are able to assess the

appropriateness of rural corridors.

Copping and the Arthur Hwy are not

considered highly sensitive we may

want to say this another way Comment [cb295]: That is why

business has developed means to

assist Antarctic nations to recycle

materials returned to Tasmania. Land

filling or disposal of quarantine waste

will always be required as it presents a

bio security risk. Comment [brennanen296]: They

do not distinguish between current

waste and legacy waste here so

confusing he issue. Comment [cb297]: These

technologies exist but are not

necessarily always able to be used and

able to process materials in a timely

fashion to suit the needs of the site.

8.0 Waste Management Governance in Tasmania - The Way Forward

8.1 Commonwealth Government

The 2009 National Waste Policy (NWP) encompasses much of what is considered

necessary in waste management, guided by the Waste Management Hierarchy.

The main policy and legislative omissions, which would lead to far better outcome in

line with best practice outcomes are as follows:

• the Environment Protection and Heritage Council (EPHC) establish a mechanism

under the NWP that will develop uniform minimum standards and definitions

(or best practice guidelines) for legislation, that will promote a nationally

consistent approach to laws to support resource recovery;

• the Commonwealth Government develop a comprehensive and systematic

approach to the collection, collation, storage and dissemination of waste

management and resource recovery data;

• waste levies, charges, fees etc. collected by State Governments be

reinvested to support resource recovery activities;

• the EPHC introduce Product Stewardship for the most problematic wastes

namely: gas bottles, all types of tyres, lead acid batteries, mercury bearing

lamps and sharps. (States and territories should also take regulatory action

to prohibit the disposal of these items in the waste stream (ban disposal to

bin));

• urgently take action to extend the national carbon offset standard to include

diversion of waste from landfill and develop a plan to recognise recycling as

an energy efficient activity;

• foster the recovery of energy from waste but only when it has been pre-

sorted and is undertaken in full accordance with the WMMA ‘energy from

waste sustainability guide’;

• the EPHC take action to support the development of markets for recycled

organic products, recognising the carbon value for agricultural soils; and

• develop a stimulus package to attract infrastructure investment in the

resource recovery sector; including accelerated depreciation (@ 50%),

development of a Green bonds facility and an AusIndustry innovation

program.

8.2 Tasmanian State Government

In 2009 the Tasmanian State Government released its Waste & Resource

Management strategy. As noted earlier in this paper, this strategy broadly mirrors

the National Waste Policy and it seems to be primarily informed by it.

Unfortunately it would seem that almost no subsequent decisions by the State

Government in relation to waste management including, its stated position on the

SWS proposal, is informed by its own waste management strategy.


Comment [cb298]: Properly

qualified and experienced experts are

working in this area. The following is

not worth detailed comment.

Comment [cb299]: The C cell is

very much in line with these

documents.

The subsequent development of a Waste Advisory Council seems to have had little

impact on waste management practices in Tasmania.

Furthermore the EPA’s role in overseeing and enforcing legislation in relation to

hazardous waste has had little additional support from government as evidenced by

the exemption of the Control Waste Tracking System due to budgetary constraints.

8.3 Local Government

Local Government should play a role in planning for waste and recovery facilities at a

regional level. However, it should not conduct the core business itself. It is therefore

important that Local Government is seen as independent by proponents in the

waste/recovery industry.

Private enterprise proposing waste management developments will be deterred from

engagement in Tasmania if Local Government is seen to be competing in their core

area of business. Private sector business being undermined by Local Government

operations will likely lead to private sector disengagement from waste management

and subsequent devolvement to Local Government of construction and industry waste

and hazardous waste material management with reduced opportunities for material

recovery, higher commodity risks for recovered materials and higher costs.

Furthermore, if Local Government revenue is partly reliant on operating a waste

disposal facility, such as a landfill that does not deliver on core waste minimisation

principles, then its ability to engage its Community in waste minimisation programs

would be significantly undermined.

All of the above principles applying to Local Government involvement in the business

of waste management is amplified in the case of hazardous material waste

management where the additional issue of potential liabilities are poorly accounted for

by Local Government, whom a largely fiscally restrained and under constant financial

pressure.

Rate payers and taxpayers alike would ultimately be underwriting financial liabilities

for these projects, when the hazardous material is predominantly produced by

industry. 8.4 Waste Levy

A waste levy is a market financial instrument that acts as a price signal to the

market with the aim of altering market practice. In Australia waste levies are

applied to waste disposed of to landfill.

As of 2012 five Australian jurisdictions have mandatory waste levies applied at

varying rates, not including Tasmania. In Tasmania there is a nominal voluntary fee of

$2 per tonne of waste to landfill, however it is not universally applied.

Funds raised by waste levies can be reinvested into the waste management sector

to drive change and innovation in pursuit of waste management alternatives to

disposal at landfill.

A good example is the South Australian model, which sees funds directed as follows;

• 50% to Zero Waste SA – Waste to Resources Fund

• 45% to EPA operational expenditure and environmental projects

• 5% to other government environmental projects

40

Comment [cb300]: It is a

committee not a council and it is very

active.

Comment [cb301]: And it does, in

particular through its regional bodies. Comment [cb302]: This is a

ridiculous statement. Waste disposal

is the responsibility of local

government.

Comment [cb303]: This statement

supports the Copping arrangement.

Owner councils pay a commercial fee

for waste disposal and so have a good

incentive to minimise waste to landfill. Comment [cb304]: This is untrue.

Comment [cb305]: A waste levy is

not relevant to the C cell or to the

Authority. It is an issue for

government. SWS supports the

introduction of a levy.

The table below outlines the varying waste levies across Australian jurisdictions68

STATE AREA / Waste Stream $ / tonne Recycling Rate NSW Sydney Metro

Hunter, Illawarra Blue Mountains, NE Coast

$70.30

$65.30 $20.40

52%

QLD SE Qld & Major Regions • C&I, C&D • Regulated Waste: Low

Hazard • Regulated waste: High

Hazard

$35.00 $50.00 $150.00

47%

SA Adelaide Metro SA Rural Areas

$26.00 $13.00

66%

VIC Melbourne Metro & Provincial cities • Rural regions – MSW

• Rural regions – C&I Controlled Industrial waste

• Category B (High Hazard) • Category C (Low Hazard) • Asbestos

$30.00 $15.00

$25.00

$250.00 $70.00 $30.00

62%

WA Perth Metro • Organic/putrescible landfill • Inert landfill

$28.00 $12/m3

33%

Details within this table shows that some jurisdictions have seen fit to differentiate

the waste to landfill and apply differing rates of levy. Typically under such a model

Construction and Demolition, Commercial and Industrial and Hazardous waste is

charged at a premium to Municipal Solid Waste.

In the case of landfill which is owned by Council (effectively by ratepayers) this is

seen as a moral imperative where by-product waste streams generated by

commerce, industry and private enterprise, from which income and profit is

generated, is effectively transferred as a liability to the public. This remains one of

the philosophical areas of contention underlying the SWS proposal for a hazardous

waste landfill.

8.5 Landfill Bans

Legislated landfill bans exist in multiple jurisdictions around the world.

Motivated by the poor environmental record of landfill and the intrinsically wasteful

practice of discarding material that can be reused, recycled or reprocessed, landfill

bans recognise the importance that targeted regulation by Government can have on

modifying poor waste management practice; usually utilising both a combination of

disincentive and incentive based regulation.

Without going into any depth some examples of Landfill Bans and their outcome on

diversion from landfill are as follows:

68 Waste and Recycling in Australia, Department of Sustainability, Environment, Water, Population and

Communities: http://www.environment.gov.au/settlements/waste/publications/pubs/waste-

recycling2009.doc


Comment [cb306]: The writer must

disagree with this approach given an

earlier statement concerning the need

to have landfills. Comment [cb307]: This does not

apply to modern, properly

engineered, constructed and

monitored landfills such as Coping. Comment [cb308]: Financial

incentives such as those that will be

provided by the Copping C cell and its

commercial gate fee are more

effective and ensure that users pay.

Jurisdiction % Waste Diversion

Prior to Landfill

Ban

% Waste Diversion

after Landfill Ban Timeframe in years

Austria 71 96 7 Belgium 75 97 10 Germany 73 99 6 Netherlands 65 90 11 Sweden 77 96 6 Massachusetts 75 78 2

Note: All jurisdictions had already achieved admirable landfill diversion rates prior to

Landfill ban Regulation relative to Tasmania.

Landfill bans in most jurisdictions that entertain them, are accompanied by, or have

had instituted prior to their implementation, waste levies on waste to landfill to send a

significant price signal to the market and shift the economics of waste management

away from discarding waste to landfill.

8.6 Waste Management Governance - Summary

The Commonwealth, State and Local Governments all state that their approach to

waste management practice and regulation is underpinned by the central plank of

the Waste Management Hierarchy.

Unfortunately, in Tasmania, it would appear little more than lip service is paid to the

guiding principles of the Waste Management Hierarchy.

Tasmania continues to have the worst diversion to landfill rates in the nation, some

40% behind the national average of approximately 65% at around 25%. This figure is

in line with figures commonly experienced in developing nations and nothing short of

embarrassing compared to near 100% diversion rates experienced in other

jurisdictions around the developed world.

The recent permit to allow a council joint authority to further develop a landfill for

hazardous waste material at Copping is condemning Tasmania to continue its poor

record of waste management.

It is a project that is likely to have poor environmental outcomes into the distant

future and one that undermines the economics of alternate waste stream pathways to

better outcomes such as reuse, recycling and reprocessing, by creating a cheaper

means of disposal of industrial waste to ultimately become a responsibility of local

ratepayers.

The Tasmanian State Government has the responsibility of lifting Tasmania’s waste

management practices from a distant last in the nation to at least matching the rest

of our Nation, by implementing strong and decisive policy and regulation that shifts

waste into a resource and creates an end to landfill disposal.

42

Comment [cb309]: Levies are a

matter for government. SWS supports

the introduction of a levy.

Comment [cb310]: This is correct,

and Tasmania is the only state without

a C cell. Such a facility is essential to

put a price on the production of level

3 waste and thereby encourage

alternatives to be explored. Comment [cb311]: The C cell will

help to remedy this perception. Comment [cb312]: This is

misleading. The composition of

statistics and data gathering have a

significant impact here. Comment [cb313]: The reverse is

the case. The C cell is designed to

accept legacy waste currently

inappropriately stored in many

locations, often on the banks of our

rivers. It is designed to allow Tasmania

to clean up its act. Comment [cb314]: Refer above.

The reverse is the case. Comment [cb315]: This includes

ensuring that we can appropriately

store our own level 3 material rather

than having to ship it interstate at a

significantly increased cost to our

businesses and the environment.

9.0 Recommendations

The State Government needs to act urgently to address the worst waste

management practices in the Nation.

The following policies and legislation require immediate Government attention:

1. A waste levy for waste to landfill disposal to be introduced forthwith to

send a price signal to the market and deter disposal to landfill. Waste

levies, charges, fees etc. collected by the state government should be

reinvested to support resource recovery activities;

2. State Government must introduce its own regulatory framework that

helps underpin the National Product Stewardship regulations;

3. State Government must develop a comprehensive and systematic

approach to the collection, collation, storage and dissemination of waste

management and resource recovery data;

4. State Government must ensure the EPA is funded appropriately to be able

to conduct its full functions in relation to hazardous waste management and

enforcement regulations;

5. State government must develop a regulatory framework around the

Waste and Resource Management Strategy and formalise it in policy*;

6. State Government must consider regulation that supports a landfill ban on

any future landfill development and a moratorium on all currently

proposed landfill developments including the Copping ‘C’ Cell until all the

above recommendations are met.

7. Local Government continue to manage Municipal Solid Waste (MSW) within

Government regulatory frameworks and guided by Commonwealth and

State waste management policy and strategy;

8. Local Government must not be permitted to own and operate large

regional MSW and Hazardous waste landfill or other significant waste

management facilities;

* To develop and adopt a regulatory framework for a State-wide Hazardous waste strategy for Tasmania, the State Government needs to build on the recommendations included in the ‘Current and Future Controlled Waste Practices in Tasmania Draft Report’, produced for the Tasmanian State Government in 2008 by Sustainable Infrastructure Australia (SIA).

The SIA report includes a draft hazardous waste strategy for Tasmania, but this has never been endorsed or acted upon by the State Government.

The SIA report makes detailed recommendations on hazardous waste management which should be used as the basis of a State Government endorsed strategy. The report recommends a number of alternatives to dumping hazardous waste into landfill, which may also be financially viable, such as incineration, high temperature sterilization, rendering, composting, neutralization and chemical decomposition through heating.



qualified and experienced people are

guiding the state’s waste management

practices and policies. Comment [cb317]: This is untrue.

The lack of a C cell inhibits our

performance but we have waste

management practices that are better

than some other states.

Comment [cb318]: This is neither

sensible nor logical. Local government

is responsible for waste management

and disposal.

In addition, Southern Beaches Conservation Society Incorporated:

1. requests that the proposed Copping hazardous waste C-cell be re-assessed

against an overarching state-wide policy which uses as a base guide, the

framework of the National Waste Policy 2009, the Tasmanian Waste &

Resource Management Strategy 2009 and the draft Sustainable

Infrastructure Australia; Controlled Waste Report 2008;

2. requests a comparative Tasmanian state-wide study is undertaken before

committing to the location of a category C-cell landfill at the existing Copping

landfill site.

3. want to see Tasmania move towards an approach to waste management that

will generate far greater levels of investment and employment through the

implementation of methods and technologies, such as:

o Better recycling practices - Currently Tasmania only diverts 20%-30%

of waste from landfill compared to a national average of 60% and increasing;

o Extended producer responsibility and product stewardship

strategies;69

o New technologies such as waste to energy incineration70 - Currently

100% of Tasmania’s and Antarctica’s hazardous waste is deposited to

landfill and in complete contrast to best practice and trends

throughout the rest of Australia and the developed World.

o Treatment before Disposal - Soil remediation processes called

‘thermal desorption’ are used in Australia as an alternative to sending

contaminated soil to landfill. In 2009, the then Victorian Minister for Environment and Climate Change, Gavin Jennings, called this a viable,

safe and cost-effective method for treating polluted soil.71

69 Waste Management Productivity Commission Inquiry, Report No.38 2006

70 Review of small scale waste to energy conversion systems, CSIRO Energy Technology Australia, March, 2004 http://www.det.csiro.au

71 Media Release from the Minister for Environment and Climate Change, Parliament Victoria, Thursday,

5th March 2009

44


qualified experts are better placed to

make appropriate requests in this field

after taking in to account facts,

science and the public health benefits

of the broader community while

ensuring that the safety and wellbeing

of the local community is safeguarded. Comment [cb320]: The

development satisfies all

requirements and would only be re

approved.

Comment [cb321]: Again, these

statistics are misleading. Definitions

and data vary. Comment [cb322]: The C cell will

assist here by placing a commercial

fee on the acceptance of level 3

material. This will ensure that users of

relevant products pay, and that

producers look for ways to minimise

the level 3 waste production. There

are currently no such incentives. Comment [cb323]: Such

technologies are becoming more

affordable and SWS is exploring

options in this regard. Comment [cb324]: This process is

not suitable for the type of material

that will be accepted by the C cell.

Version Control

Version

Revision History

0.1 First draft

0.2 Revision

0.4 Edit

0.5 Final Draft

1.0 Endorsed by SBCS Executive


[1] Comment [cb10] christine bell 11/04/2013 10:56:00 AM There is more risk from the regular transport of liquid material including petrol and gas. A

road traffic accident with full fuel tanks poses more risk to the environment than an

enclosed truck carrying soil. Page 4: [2] Comment [cb11] christine bell 11/04/2013 10:56:00 AM This comment is not based on fact. The material that will be accepted by the C cell is

currently largely not contained and in many cases lying on our river banks. The C cell has

multiple redundancies and is designed to not fail. Page 4: [3] Comment [cb12] christine bell 11/04/2013 10:56:00 AM The science underpinning the C cell is not questionable. The conclusions of amateurs not

professionally qualified in relevant fields is what is questionable. Page 5: [4] Comment [cb15] christine bell 11/04/2013 10:56:00 AM This is actually correct. The material destined for the C cell does not have any other

commercial use at this stage. It can be extracted and re processed as technology changes

and as resources become more scarce. Page 5: [5] Comment [cb16] christine bell 11/04/2013 10:56:00 AM In fact this project is in conformance with the policy. It places a price on this material

thereby encouraging producers to look at alternative methods and makes users pay; it

ensures ‘adequate disposal facilities exist for environmentally sound management of

wastes’. Page 5: [6] Comment [cb18] christine bell 11/04/2013 10:56:00 AM There is no such thing. Waste is classified as level 1, level 2, level 3 or level 4. The C cell will

accept waste only up to level 3 and only after testing by an independent NATA accredited

laboratory, and after approval from the EPA. Page 5: [7] Comment [cb19] christine bell 11/04/2013 10:56:00 AM The reverse is the case. Tasmania is the only state without one of these facilities and our

only current option is to ship material interstate. Page 5: [8] Comment [cb20] christine bell 11/04/2013 10:56:00 AM This comment fails to acknowledge that the main purpose of the C cell is to clean up legacy

waste currently not appropriately contained and in some cases lying on the banks of our

rivers. Page 5: [9] Comment [cb21] christine bell 11/04/2013 10:56:00 AM The cell and its operation are designed to allow extraction and re processing as technology

changes and as resources become more scarce. Different types of material will be stored

separately within the cell and their locations will be recorded. Page 5: [10] Comment [cb22] christine bell 11/04/2013 10:56:00 AM Gate fees will be commercial and recover the full lifecycle cost of storing and looking after

the material concerned. Currently ‘disposal’ is often free as the material has nowhere to go

and is stored in the back yards of business, and on our river banks.

[11] Comment [cb23] christine bell 11/04/2013 10:56:00 AM The gate fee will include a component for a trust fund to monitor and manage the site

indefinitely. Page 5: [12] Comment [cb24] christine bell 11/04/2013 10:56:00 AM SWS has offered to show the site to members of the community to help to allay their

concerns. In response to some comments made by the community we have also made some

voluntary changes to how we will operate. This comment by the protest group

demonstrates that the group is not interested in negotiating on behalf of the community. Page 5: [13] Comment [cb26] christine bell 11/04/2013 10:56:00 AM This report recommends construction of a C cell. The Government has established a Waste

Advisory Committee to oversee policy. Page 11: [14] Comment [cb64] christine bell 11/04/2013 10:56:00 AM Not only is this not true, but the promulgators of this document were advised that this was

not the case at a meeting with representatives of the EPA and a State politician some time

last year. A Notice of Intent was submitted by SWS to the EPA in January 2012. Following

their review of this document, and consultation with interstate jurisdictions, the EPA issued

project specific guidelines in February 2012 detailing what matters it required to be

addressed by the project DPEMP. The final DPEMP was submitted to the EPA in April 2012. Page 11: [15] Comment [cb65] christine bell 11/04/2013 10:56:00 AM This erroneous statement demonstrates a lack of knowledge of the planning process. The

EPA provided its report to the Sorell Council for its consideration. The Council then gave

final approval to the project. Page 11: [16] Comment [cb67] christine bell 11/04/2013 10:56:00 AM In addition to the minimum statutory consultation SWS wrote to adjoining land owners a

week before the start of the statutory process, offering personal briefings. None were

interested, SWS also briefed representatives of all political parties and printed 500 leaflets

for distribution. SWS also sends scopies of agendas to adjoining land owners prior to each

Authority meeting. A C cell has been on these agendas for a number of years. Page 11: [17] Comment [cb68] christine bell 11/04/2013 10:56:00 AM Mr Reardon was one of the landowners written to by SWS. He did not request any

information about the project. In addition it is not true to say that Mr Reardon was an

objector. There were NO objections to the proposal. Two representations were received

during the period for public comment. SWS responded to the representations in writing and

met with both representors. Mr Reardon negotiated some minor changes to the

commitments surrounding the project, and then advised that he no longer intended to

object to the project. He did not object. Page 11: [18] Comment [cb69] christine bell 11/04/2013 10:56:00 AM SWS tried to engage with the community early in the process but no one was interested. It

is interesting to note that although invited, no members of the group opposing the C cell

(the promulgators of this document) have expressed an interest in being involved in ongoing

community consultation via our Community Reference Group. Page 11: [19] Comment [cb72] christine bell 16/04/2013 5:20:00 PM Authority agendas including

development of a C cell, are mailed to adjoining landowners. This item has been on the agendas for several years. Page 16: [20] Comment [cb102] christine bell 11/04/2013 10:56:00 AM This is not true. The DPEMP says no such thing. It actually states (page 27) that ‘[t]he C-cell will be located on a hillside and its base will be excavated down to approximately 58 m AHD, which is 16 m above that water level. While the water table is expected to follow the hill slope to some extent, it is unlikely to parallel it exactly and the 16 m difference suggests that groundwater under the base of the C-cell will be deeper than 2 to 3 m below the base, perhaps substantially so. Nevertheless, it is possible that the groundwater under the C-cell might approach closer than the 5 m minimum separation between it and waste specified by the Landfill Sustainability Guide for Category C cells. A groundwater relief system will therefore be installed as part of the C-cell design.’ Subsequent detailed surveying indicates that the original estimate of a 16 m clearance is most likely. This will be verified beyond doubt as part of the final design process. Page 16: [21] Comment [cb104] christine bell 11/04/2013 10:56:00 AM This statement is misleading. A botanical and zoological assessment was included in the DPEMP for the existing landfill. It was concluded that “[t]here are no zoological reasons why this project should not proceed." The Policy and Conservation Branch advised the EPA in relation to the category C cell development. Their advice (included in the EPA’s Environmental Assessment Report) was that ‘[a] number of listed fauna species may occur in the area. These include chaostola skipper (Antipoda chaostola) listed as endangered under the TSPA, the Tasmanian devil (Sarcophilus harrisii) and the swift parrot (Lathamus discolour) listed as endangered under the TSPA and the Environment Protection and Biodiversity Conservation Act 1999 (EPBCA). Given that the development is within a highly disturbed environment, it is unlikely to impact these threatened species.”’ Combined with the facts that the cell will not discharge leachate to groundwater or to the Carlton River or its tributaries, that the waste that will be accepted in the cell is not attractive to wildlife and will not be ingested, that the waste is not toxic, and that waste will be covered every day; there is no risk to fauna.

Page 16: [22] Comment [cb106] christine bell 11/04/2013 10:56:00 AM This is also untrue and demonstrates a lack of understanding of risk management. The risk

matrix was not prepared by the EPA. The risk levels cited here are the gross risk prior to

considering the specific project in question. The net risk ratings of these potential events are

low.

[23] Comment [cb122] christine bell 11/04/2013 10:56:00 AM This is a misleading, incorrect and selective quotation. There is no reference to ‘historic times’

within the DPEMP. The DPEMP states that ‘Southeast Tasmania, including the Copping area, is geologically

very stable. No earthquakes greater than magnitude 4.0 have been recorded in southeast Tasmania since records

began in 1841. Fault movements at the Copping site are therefore highly unlikely. The only foreseeable

potential movements of rock under the proposed C-cell would be very localised adjustments following

excavation and even these would be well buffered by the compacted clay liner upon

which the synthetic liners will sit.’ Page 19: [24] Comment [cb123] christine bell 11/04/2013 10:56:00 AM Again demonstrates a lack of understanding of risk assessment. This is the gross risk with a

likelihood ranking of “Rare’ and a net risk of “Low”. Page 19: [25] Comment [cb124] christine bell 11/04/2013 10:56:00 AM A qualified geologist with more than 100 hours work on the actual Copping site has

determined that the dolerite is not fractured and is several metres thick. Page 22: [26] Comment [cb148] christine bell 11/04/2013 10:56:00 AM The Guide requires a buffer between a C cell and a permanent water course of 100 m. The

C cell is approximately 1.75 KM or 17.5 times that distance away from the closest

permanent watercourse. It is also approximately 750 m or 7.5 times the recommended

distance from an ephemeral unnamed tributary. There is no buffer requirement for a

normally dry watercourse. Page 22: [27] Comment [cb150] christine bell 11/04/2013 10:56:00 AM There is considerable evidence. Refer Rowe 2005. In relation to the HDPE membranes,

the service life is determined by (page 659 of Rowe):


• Tensile strains



• Temperature.

The conceptual liner design deals with all these issues.

For example:

• Puncturing risk is addressed by there being a cushion geotextile

between the overlying aggregate and the top HDPE membrane

• Tensile strains will be addressed by careful shaping of the cell

geometry and careful liner deployment with QA/QC inspections

• Antioxidant depletion rates are a function of exposure to

leachate and temperature. In the C-cell, there will be no

putrescible wastes to be rotting and generating heat. Wastes will

be stored separately and any reactions that may occur would only

happen in the leachate once it had collected in the pipes, where it

would have very short resident times. The aggregate cover will

protect the top HDPE membrane from direct sunlight, so the

membranes are unlikely to reach temperatures much higher than

ambient, say 10 – 20 degrees. Using Rowe’s antioxidant

depletion figures (his Table 5), this means the service life of the

membranes will be 100 to 300 years. This is longer than the

operational life of the cell. By the time the membranes ‘failed’,

the cell would be dry entombed, with no leachate being

generated. So, any ‘failure’ of the membranes would be

irrelevant.

• Of course, the cell liner design is not wholly dependent on the

HDPE membranes – it has a geosynthetic clay liner and also a

compacted clay liner – both of these have service lives of many

centuries (provided they don’t dehydrate). So, even if the HDPE

membranes ‘failed’ while the cell was operating, the clay liners on

their own will be more than adequate.

Page 22: [28] Comment [cb152] christine bell 11/04/2013 10:56:00 AM Again showing complete lack of understanding of risk assessment. The EPA made no such

acknowledgement. This is a gross risk assessment included in the DPEMP. The net risk is

assessed as low. Page 22: [29] Comment [cb153] christine bell 11/04/2013 10:56:00 AM This is untrue. Consideration was given to fauna and in any event the cell will not release

leachate to the environment let alone 1.75 km away in the river. Page 27: [30] Comment [cb192] christine bell 16/04/2013 5:45:00 PM THE FIRST EDITION OF THIS DOCUMENT CLAIMED THAT THE TASMANIAN FARMERS AND

GRAZIERS ASSOCIATION HAD WRITTEN TO THE EPA EXPRESSING SERIOUS CONCERNS

ABOUT THE EXISTING B CELLS AT COPPING. IT WENT ON TO DRAW INFERENCES ABOUT

THE OPERATION OF THE C CELL. THE TFGA HAS NO SUCH CONCERNS AND NEITHER DOES

THE EPA. THEREFORE THE INFERENCE IS THAT THE C CELL WILL ALSO BE EXTREMELY WELL

OPERATED. THE GROUP WERE TOLD BY THE TFGA TO REMOVE REFERENCES TO THEM

FROM THEIR DOCUMENT BECAUSE THEY ARE UNTRUE. Page 27: [31] Comment [cb194] christine bell 16/04/2013 5:48:00 PM This personal opinion is in direct conflict with previous claims of population growth in the

area surrounding the landfill. The protesters are potentially damaging real estate values in

the area by their ongoing misleading campaign. Page 27: [32] Comment [cb196] christine bell 11/04/2013 10:56:00 AM But the writer previously claimed that the population was on the rise, which will underpin

property increases. Any ‘anecdotes’ such as this one should be placed in the context of a

generally soft real estate market. Page 28: [33] Comment [cb200] christine bell 16/04/2013 5:55:00 PM If anything the presence of the C cell gives the community more leverage in their request for

upgrades. SWS is more than happy to actively engage in lobbying for upgrades to the

highway and related infrastructure. Page 28: [34] Comment [cb201] christine bell 11/04/2013 10:56:00 AM If there are more than 5 trucks per day at any time, then the law of averages dictates that

there will be fewer than 5 per day at other times. Page 28: [35] Comment [cb202] christine bell 11/04/2013 10:56:00 AM SWS’ discussions with certifiers of organic status indicate that the C cell should not impact

on certification if no contaminants leave the site. Each case will be assessed on its merits

and SWS will be more than happy to make any data available to the certifier. Page 28: [36] Comment [cb204] christine bell 11/04/2013 10:56:00 AM Again the writer is ignoring the fact that the C cell will primarily accept legacy material that

is currently inappropriately contained, often on our waterways. The C cell allows our

environment to be rehabilitated. Page 28: [37] Comment [cb205] christine bell 11/04/2013 10:56:00 AM Refer to previous comments. A report prepared by Sustainable Infrastructure Australia (SIA),

available at swstas.com.au, concludes that the lack of infrastructure such as a C-cell may result in significant costs to Tasmanian businesses and may impede economic

expansion for the State Page 28: [38] Comment [cb208] christine bell 11/04/2013 10:56:00 AM It is up to the Authority how any profits are distributed. The community will not ‘be

responsible for future liability’. This is one of the reasons for establishing a trust fund. Page 29: [39] Comment [cb217] christine bell 11/04/2013 10:56:00 AM These unfounded statements again demonstrate a lack of knowledge of risk assessment.

Potential risks are identified and rated prior to establishing the likelihood of the event

occurring and ways to mitigate the risk. The end result is what counts and that is an

assessment of risks as being low other than some transport risks which by definition cease

after the cell is closed. Page 29: [40] Comment [cb218] christine bell 11/04/2013 10:56:00 AM The group is entitled to its amateur opinion. SWS and the regulators rely on qualified and

experienced scientists and engineers. Page 29: [41] Comment [cb219] christine bell 11/04/2013 10:56:00 AM The fault is not related to seismic activity. As commented earlier it is the result of the

intrusion of dolerite during the Jurassic period more than 600,000 years ago. It is not the

result of seismic activity. The Copping area is one of the most seismically stable in Tasmania

and Tasmania is one of the most seismically stable areas in the world. The C cell is designed

to withstand a tremor as large as the one that struck Christchurch and 10,000 timed greater

than ever ecorded in the region. The swarm referred to had an average reading on the

Richter scale of approximately 1 which is defined as ' not felt'. A reading of between 2 and

3.9 is defined as generally not felt but recorded. So the swarm is insignificant. Page 29: [42] Comment [cb220] christine bell 11/04/2013 10:56:00 AM This is all untrue. Modelling, including the potential effects of climate change, was

performed by appropriately qualified scientists and considered as part of the evaluation of

the project. Page 29: [43] Comment [cb221] christine bell 11/04/2013 10:56:00 AM Again, it is not the EPA’s risk matrix. These comments demonstrate a lack of knowledge of

the planning and assessment processes. Page 29: [44] Comment [cb222] christine bell 16/04/2013 5:58:00 PM As commented previously the writer continues to demonstrate a lack of understanding of

risk assessment principles and practices. These cited risks ratings are gross ratings before

taking in to account likelihood and mitigations. The net assessment is low.

Page 29: [45] Comment [cb223] christine bell 11/04/2013 10:56:00 AM This is untrue. In relation to the HDPE membranes, the service life is

determined by (page 659 of Rowe):


• Tensile strains



• Temperature.

The conceptual liner design deals with all these issues.

For example:







putrescible wastes to be rotting and generating heat. Chemical

reactions will be minimal because the wastes will be stored

separately and any reactions that may occur would only happen

in the leachate once it had collected in the pipes, where it would

have very short resident times. The aggregate cover will protect

the top HDPE membrane from direct sunlight, so the membranes

are unlikely to reach temperatures much higher than ambient,

say 10 – 20 degrees. Using Rowe’s antioxidant depletion figures

(his Table 5), this means the service life of the membranes will be

100 to 300 years. This is longer than the operational life of the

cell. By the time the membranes ‘failed’, the cell would be dry

entombed, with no leachate being generated. So, any ‘failure’ of

the membranes would be irrelevant.

• Of course, the cell liner design is not wholly dependent on the HDPE

membranes – it has a geosynthetic clay liner and also a compacted clay

liner – both of these have service lives of many centuries (provided they

don’t dehydrate). So, even if the HDPE membranes ‘failed’ while the cell

was operating, the clay liners on their own will be more than adequate. Page 31: [46] Comment [cb236] christine bell 11/04/2013 10:56:00 AM Almost a quarter of a century out of date again. In relation to HDPE membranes, the

service life is determined by (page 659 of Rowe):


• Tensile strains



• Temperature.

The C cell conceptual liner design deals with all these issues.

For example:







putrescible wastes to be rotting and generating heat. Incidental

chemical reactions will be minimal because the wastes will be

stored separately and any reactions that may occur would only

happen in the leachate once it had collected in the pipes, where it

would have very short resident times. The aggregate cover will

protect the top HDPE membrane from direct sunlight, so the

membranes are unlikely to reach temperatures much higher than

ambient, say 10 – 20 degrees. Using Rowe’s antioxidant

depletion figures (his Table 5), this means the service life of the

membranes will be 100 to 300 years. This is longer than the

operational life of the cell. By the time the membranes ‘failed’,

the cell would be dry entombed, with no leachate being

generated. So, any ‘failure’ of the membranes would be

irrelevant.

• Of course, the cell liner design is not wholly dependent on the HDPE

membranes – it has a geosynthetic clay liner and also a compacted clay

liner – both of these have service lives of many centuries (provided they

don’t dehydrate). So, even if the HDPE membranes ‘failed’ while the cell

was operating, the clay liners on their own will be more than adequate. Page 31: [47] Comment [cb239] christine bell 11/04/2013 10:56:00 AM In the C cell they will remain substantially the same. Waste is dry and separated so there will

not be chemical reactions within the cell. And it will be capped and well insulated, as well as

excluding rain, after approximately 10 years. Page 31: [48] Comment [cb240] christine bell 11/04/2013 10:56:00 AM There are three impermeable layers between the level 3 material and the compacted clay

liner. Not to mention the fact that there will not be any chemicals present in a form that will

allow this to happen. Page 31: [49] Comment [cb242] christine bell 11/04/2013 10:56:00 AM There is no sound scientific evidence to the contrary.

US National Research Council Committee (2007) Assessment of the

Performance of Engineered Barriers National Academy of Sciences

Here’s a link to the e-version of that book:

http://www.nap.edu/openbook.php?record_id=11930&page=R1

Here’s a direct link to the page on HDPE durability:

http://www.nap.edu/openbook.php?record_id=11930&page=46

The above durability figures are derived from Rowe, R.K. (2005) "Long-

Term Performance of Contaminant Barrier Systems", 45th Rankine

Lecture, Geotechnique, 55 (9): 631-678, which to my knowledge is the

most comprehensive technical paper of liner durability.

Here’s a link to that paper:

http://www.geoeng.ca/Directory/kerry%20Pub/Geotechnique%20Rankin

e%20V55%20N9%20631-678%20Rowe%202005.pdf

Table 6 of that paper (page 664) shows that an HDPE liner has an

expected service life of between 200 and 1700 years if liner temperatures

are kept below 30 deg C.

For a compacted clay liner the paper says (page 665): “Provided that a

CCL has been properly designed and constructed, and provided that

appropriate account has been taken of the potential for an increase in

hydraulic conductivity due to clay–leachate interaction, the CCL can be

expected to have a hydraulic conductivity below the specified design

value for thousands of years provided that it is not allowed to desiccate

after placement.”

For a geosynthetic clay liner the paper says (page 665): “A GCL used as

part of a composite base liner system may also be expected to have a

service life of thousands of years provided that”…[and then it lists a

number of design, construction and maintenance requirements].

So, the Rowe paper supports the conclusion that the multiple liner

system at Copping should have a design life of many centuries, if the

liners are properly designed, constructed and maintained. Page 31: [50] Comment [cb244] christine bell 16/04/2013 6:02:00 PM There may be concern expressed by poorly informed amateurs. Professional scientists and

engineers have no such concerns. It should also be remembers that additional technical and

professional research indicates at least 10 m clearance to groundwater – compared to a

recommended 5 m. This will be verified beyond doubt as part of the final design.

Page 34: [51] Comment [cb266] christine bell 11/04/2013 10:56:00 AM SWS operates a landfill and it is not its responsibility to consider alternatives. However

reducing waste to landfill reduces SWS’ costs and extends the life of its assets. Putting a

commercial price on disposal of level 3 waste passes costs on to consumers and encourages

producers of this material to reduce its production. The absence of a C cell does not send

these environmentally responsible messages, and does not allow for the clean-up of legacy

waste currently inappropriately stored, often on our river banks. Page 34: [52] Comment [cb267] christine bell 11/04/2013 10:56:00 AM It is up to industry to consider alternatives. They have no incentive to do so in the absence

of a C cell and associated commercial gate fee on the level 3 material that they produce. Page 34: [53] Comment [cb269] christine bell 16/04/2013 6:05:00 PM Fred and Anne must have special powers to be able to review recent evidence in a paper

dated almost a quarter of a century ago. Assuming the reference is correct which may not

be the case. Page 34: [54] Comment [cb275] christine bell 11/04/2013 10:56:00 AM This is another unsubstantiated outlandish statement. The cost consists of gardening. There

is no real hazard. There will be a trust fund. Page 34: [55] Comment [cb276] christine bell 16/04/2013 6:08:00 PM If groundwater is not affected then there is unlikely to be a leak. In any event it is not only

groundwater that is independently monitored and reported. Page 34: [56] Comment [cb277] christine bell 16/04/2013 6:10:00 PM Which is why the C cell has multiple impermeable layers (of three different types), a witness sump, a

significant clearance above groundwater and regular inspection and monitoring.christine bell�

27/2/13 10:10 Page 36: [57] Comment [brennanen282] [email protected] 11/04/2013 10:56:00 AM This is not true. For Australia it would not require any Basel convention approval for its own

waste to return to Australia. For another country returning Antarctic waste to Australia a

permit would only be required for waste deemed by the Basel Convention and Australian

hazardous waste legislation as hazardous. Some materials for recycling and reuse can be

returned to Australia from other Antarctic nations without any Basel Convention

requirements to apply

It is not true that waste generated by an Antarctic nation has to be returned to the

sovereign territory. In the Madrid Protocol, Annex III, article 1 part 4 states 4. Wastes

removed from the Antarctic Treaty area shall, to the maximum extent practicable, be

returned to the country from which the activities generating the waste were organized or to

any other country in which arrangements have been made for the disposal of such wastes in

accordance with relevant international agreements. Page 36: [58] Comment [brennanen283] [email protected] 11/04/2013 10:56:00 AM This is not true. The port in WA just off loaded the material and it went for deep burial at a

landfill in WA. Hobart has extensive quarantine experience and the working port is capable

of off loading and processing quarantine materials including waste. Page 36: [59] Comment [brennanen284] [email protected] 11/04/2013 10:56:00 AM This is untrue. For at least 5 years all quarantine waste arriving at Hobart through shipping

and air has been disposed to Glenochy Jackson st landfill for deep burial as approved by

AQIS Page 36: [60] Comment [brennanen285] [email protected] 11/04/2013 10:56:00 AM There are two different waste streams generated by Antarctic activities. Waste inc,using

recyclables generated from current station operations. The second includes old or legacy

waste that may comprise of hazardous and non hazardous waste. The antis have just

focussed on the haz waste. Page 36: [61] Comment [brennanen290] [email protected] 11/04/2013 10:56:00 AM They have no understanding of the process. A facility does not need to be at the port if the

landfill is AQIS approved and AQIS approve the transport route and mechanism this can

apply Page 36: [62] Comment [brennanen291] [email protected] 11/04/2013 10:56:00 AM No this is not true. Case in point current quarantine waste lands at port now or comes in via

hbt airport. We have no autoclave but AQIS allow it to go for deep burial at Glenochy. Page 36: [63] Comment [cb293] christine bell 16/04/2013 6:13:00 PM It is highly unlikely that waste materials from legacy hazardous waste from Antarctica would

present a bio security risk in the context of what these people are saying