melton south class a recycled water scheme · water scheme, as endorsed by epa and department of...

28B Albert Street P.O. Box 571 Warragul Vic 3820

www.landsafe.com.au

Office Tel: 03 5623 4788 Fax : 03 5623 4596

Email: [email protected]

A Division of Ag-Challenge Consulting Pty Ltd ABN 39 109 503 835

Melton South Class A Recycled Water Scheme - Statutory Audit (s.53V) 2013

Final Report 31 August 2014 For:

Western Water 6 Macedon Street

Sunbury, Victoria 3429

EPA CARMS Ref: 67653-2

EPA service order number: 8004160

Auditor Account number: 75654


Ag-Challenge Consulting Pty Ltd

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Document control

Prepared By: Rohan Ash Environmental Auditor (Industrial Facilities) Appointed pursuant to the Environment Protection Act 1970

[email protected] PO Box 163 Chelsea VIC 3196 0407 349 172

Endorsed by:

Glenn Marriot Director Landsafe (Ag-Challenge Consulting Pty Ltd)

[email protected] 28B Albert Rd Warragul VIC 3820 03 5623 4788

Status: Final Version: 1 Date: 31 August 2014

Document copyright and limitations The contents of this report are commercial-in-confidence and are protected by copyright law. The

methodologies, opinions and other material contained within the report remain intellectual property and

copyright jointly residing with Rohan Ash and Land Safe (Ag-Challenge Consulting Pty Ltd).

This report was prepared in accordance with the scope of audit described in the Land Safe Proposal to

Western Water dated 7 October 2013. This report and it findings are based on information and data supplied

by the client and stakeholders consulted by the auditor, conditions encountered during inspections on the dates outlined in this report, and subsequently reviewed during preparation of this report. The auditor does

not accept any responsibility for any changes that may have occurred after this time, nor for any incorrect

information or data supplied to the auditor during the audit.

This report is provided to EPA and Western Water in both printed and electronic format. The printed version

signed by the auditor is the controlled version. All other electronic (scanned Adobe pdf or Microsoft Word)

versions are regarded as uncontrolled versions and provided only for the convenience of EPA and Western Water. The auditor has also kept an original signed hard copy of this report, which can be provided for

inspection upon request.

Land Safe and the author do not accept any liability for any unauthorised use of the contents of this report, including any use of uncontrolled copies or extracts of the report.

This report should only be read or otherwise use as a full document. The auditor does not accept any

responsibility for use (including copying and quoting) of any part of this report in any other context or for any other purpose or by third parties. This report does not include any legal advice, which can only be given by

the legal profession.



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Table of Contents

Document control ................................................................................................................................................... i

Table of Contents................................................................................................................................................... ii

List of Figures and Tables ....................................................................................................................................... v

Glossary and Abbreviations .................................................................................................................................... vi

Executive Summary................................................................................................................................................ 1

E.1 Summary of 53V audit Information ......................................................................................................... 1

1 Introduction ................................................................................................................................................... 1

1.1 Background of Melton South Class A Recycled Water Scheme ................................................................. 1

1.2 EPA Guidelines ....................................................................................................................................... 3

1.3 Audit Purpose ......................................................................................................................................... 4

1.4 This Report ............................................................................................................................................. 4

2 Audit Objectives and Scope ............................................................................................................................ 5

2.1 Audit Objectives ..................................................................................................................................... 5

2.2 Scope ..................................................................................................................................................... 5

2.1.1 Activities subject of this audit .......................................................................................................... 5

2.1.2 Segments of the Environment ......................................................................................................... 6

2.1.3 Beneficial Uses ................................................................................................................................ 6

2.1.4 Risk Assessment .............................................................................................................................. 9

2.1.5 Audit Compliance Period Considered ............................................................................................... 9

2.1.6 Audit Exclusions and Limitations...................................................................................................... 9

2.1.7 Audit Criteria .................................................................................................................................. 9

2.3 EPA Victoria Environmental Auditing Guidance ..................................................................................... 10

2.4 EPA Notification of Audit ...................................................................................................................... 11

3 Methodology ............................................................................................................................................... 12

3.1 Audit Team ........................................................................................................................................... 12

3.2 Audit Program ...................................................................................................................................... 12



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3.2.1 Inception Meeting ......................................................................................................................... 12

3.2.2 Field Audit and Interviews ............................................................................................................. 12

3.2.3 Information and Data Review ........................................................................................................ 13

3.2.4 Audit Checklists ............................................................................................................................. 14

3.3 Compliance Assessment ....................................................................................................................... 14

3.3.1 Non-Conformance Classification .................................................................................................... 14

3.3.2 System improvement (SI) .............................................................................................................. 15

3.4 Risk Assessment ................................................................................................................................... 15

3.4.1 Risk of Harm ................................................................................................................................. 16

3.4.2 Risk Assessment Outcomes ........................................................................................................... 17

3.5 Reporting ............................................................................................................................................. 17

4 Melton South Class A Recycled Water Scheme - Overview of Performance .................................................. 18

4.1 Location ............................................................................................................................................... 18

4.2 Land Uses ............................................................................................................................................. 18

4.2.1 Melton RWP.................................................................................................................................. 18

4.2.2 Class A Recycled Water Supply areas ............................................................................................. 18

4.3 Local Surface Waters ............................................................................................................................ 19

4.3.1 Werribee River Catchment ............................................................................................................ 19

4.3.2 Constructed waterways within Class A Supply Region – Urban Developed Areas ............................ 19

4.4 Land Capability and Climate Review ...................................................................................................... 20

4.4.1 Topography................................................................................................................................... 20

4.4.2 Geology and Soils .......................................................................................................................... 20

4.4.3 Groundwater ................................................................................................................................ 20

4.4.4 Rainfall and Evaporation ............................................................................................................... 20

4.4.5 Plant water irrigation (evapotranspiration) requirement ............................................................... 21

4.5 Melton (Surbiton Park) RWP – Treatment Processes ............................................................................. 21

4.5.1 EPA Amalgamated Licence 74268 .................................................................................................. 21



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4.5.2 Sewerage Catchment .................................................................................................................... 22

4.5.3 Class C Treatment Process ............................................................................................................. 23

4.5.4 Class A Treatment Process............................................................................................................. 25

4.5.5 Class A Treatment Plant Performance – 2012-13 ........................................................................... 27

4.5.6 Class A Recycled Water Quality Incidents and Emergencies ........................................................... 29

4.6 Class A Customer Performance ............................................................................................................. 29

4.6.1 Number of Class A Customers Supplied ......................................................................................... 29

4.6.2 Recycled Water Bulk Supply Volumes ............................................................................................ 29

4.6.3 Reconciliation of Bulk Supply and System Losses ........................................................................... 30

4.6.4 Residential Customer Usage .......................................................................................................... 31

4.6.5 Non-Residential Customer Usage .................................................................................................. 33

4.6.6 Nutrient Loads from Recycled Water – Non-Residential Customers ............................................... 34

4.6.7 Non-Residential Customer CSMP Compliance Review .................................................................... 35

4.6.8 Customer Incidents and non-compliances ..................................................................................... 36

5 Summary of Findings .................................................................................................................................... 37

5.1 General Findings ................................................................................................................................... 37

5.2 Risk of Harm to the Environment .......................................................................................................... 37

5.3 System Improvements .......................................................................................................................... 39

6 Conclusions and Recommendations.............................................................................................................. 43

6.1 Conclusions .......................................................................................................................................... 43

6.2 Recommendations ................................................................................................................................ 43

Appendix A: Masterplans for Eynesbury, Atherstone, Waterford & Toolern Waters Appendix B: Audit Program Schedule Appendix C: Documents Reviewed Appendix D: Water Demand Calculations Appendix E: Class A Non-Residential Customers, CSMP and ERMP Review Appendix F: Audit Checklist and Compliance Assessment Record



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List of Figures and Tables

Figures

Figure 1-1 Location of Melton RWP and Class A Recycled Water Scheme Supply Area ...................................... 2

Figure 1-2 Melton Class A Recycled Water Scheme – HEMP Framework (source: HEMP 2012) .......................... 3

Figure 4-1 Melton RWP Site Plan (source: EPA Licence 74268) ....................................................................... 21

Figure 4-2 Melton RWP Class C and Class A Treatment Plant areas (source: EPA Licence 74268) ..................... 22

Figure 4-3 Melton RWP Class C Treatment Process Flow Diagram (source: Western Water HRMP 2012) ........ 23

Figure 4-4 Melton RWP Class C Treatment Process Flow Diagram (HRMP) ...................................................... 24

Figure 4-5 Melton RWP Class A Treatment Process Flow Diagram (HRMP 2012) ............................................. 25

Figure 4-6 Melton RWP Class A Plant CCPs and QCP (RWQMP 2009) .............................................................. 27

Figure 4-7 Eynesbury – Residential Customer Usage 2012-13 ......................................................................... 32

Tables

Table E-1 Summary of 53V Audit Information ..................................................................................................... 1

Table E-2 Physical Site Information......................................................................................................................... 4

Table 3-1: Western Water Likelihood and Consequence scoring matrix used in the hazard analysis ..................... 16

Table 4-1 Rainfall (mm) – Melton Reservoir (Bureau of Meteorology Station No. 87040) .................................. 20

Table 4-2 Evaporation (mm) – Mean of Melton & Merrimu Reservoir (stations 87040 and 87161) 1 .................. 20

Table 4-3 Melton RWP Class C Plant Performance (2013-14)............................................................................. 24

Table 4-4 Class A Recycled Water Quality Monitoring Data (July 2012 to June 2013) ........................................ 28

Table 4-5 Class A Recycled Water Bulk Supply and Accounted Usage (1 May 2012 to 30 April 2013) ................. 30

Table 4-6 Class A Residential Customer Recycled Water Usage (July 2012 - June 2013) .................................... 31

Table 4-7 Class A Residential Customer Recycled Water Usage (July 2012 - June 2013) .................................... 33

Table 4-8 Class A Recycled Water Irrigation Nutrient Loads – Non-Residential Customers ................................ 35

Table 5-1 Assessment of Risk of Harm to the Environment from the Melton Class A Recycled Water Scheme... 38



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Glossary and Abbreviations

Reference/Abbreviation Description

ACS Annual Compliance Statement

ASCS Annual Summary and Compliance Statement

Dual Pipe Guidelines Guidelines for Environmental Management: Dual Pipe Water Recycling Schemes - Health and Environmental Risk Management (EPA Publication 1015, October 2005).

CA Corrective Action

CCP Critical Control Point

CFA Country Fire Authority

CT Chlorine contact Time

DHS Department of Health Services (now DHV)

DHV Department of Health Victoria (formerly DHS)

DIT Direct Integrity Test

EIP Environment Improvement Plan

EMP Environment Management Plan

EPA, EPA Victoria Environment Protection Authority Victoria

FRC Free Residual Chlorine

HACCP Hazard analysis and critical control points

HEMP Health and Environment Management Plan

MFESB Metropolitan Fire and Emergency Services Board

PDR Pressure Decay Rate

PIW Prescribed Industrial Waste

PLC Programmable logic controller

POS Public open space

QCP Quality Control Point

RWA Recycled Water Agreement

RWP Recycled Water Plant

RWQMP Recycled Water Quality Management Plan

SCADA Supervisory control and data acquisition

SEPP State Environment Protection Policy

SI System Improvements

STP Sewage Treatment Plant

Temp Temperature

TMP Trans Membrane Pressure

UV Ultraviolet

UVT Ultraviolet Transmittance

WW Western Water



E.1

Executive Summary

E.1 Summary of 53V audit Information Summary of audit information for this audit (in accordance with Appendix A (Tables 1 and 2) of EPA Pub No. 1147) is provided below in Tables E-1 and E-2.

Table E-1 Summary of 53V Audit Information

EPA file reference (CARMS No.) 67653-2

EPA service order number: 8004160 Auditor Rohan Ash

Auditor Account number: 75654 Auditor term of appointment 26 May 2014 to 25 May 2019

Name of person requesting audit Anna May

Relationship to premises/location

Manager Renewable Resources Team, Western Water

Date of request 14 October 2013

Date EPA notified of audit 22 October 2013

Completion date of the audit 28 August 2014

Reason for audit Audit required every 3 years by the Health and Environmental Management Plan (HEMP) May 2012 for the Melton Class A Recycled Water Scheme, as endorsed by EPA and Department of Health. The last statutory audit of the Scheme was reported in September 2010.

Description of activity Class A Recycled Water Supply from Western Water’s Melton (Surbiton Park) Recycled Water Plant (RWP) to: • dual pipe residential customers within Eynesbury Township, and the

Toolern Precinct (comprising early stages of Waterford, Atherstone and Toolern Waters developments) in Melton South

• non-residential customers: - Eynesbury golf course, Eynesbury POS and Waterford POS

irrigation, - Tabcorp Park (Harness Racing Facility) dual pipe uses, lawn and

garden irrigation and dust control on the trotting track - Fire service operational activities (fire fighting, training), and - Melton RWP standpipe customers.

EPA region Metro Region



E.2

Dominant — Lot on plan Melton (Surbiton Park) Recycled Water Plant, multiple allotments cnr Butlers Rd and Greigs Rd, Mount Cottrell 3024

Additional - Lot on plan(s) Melton Class A Recycled Water Scheme Supply Area comprises many properties and allotments at the following addresses and postcodes: • Eynesbury Township residential development, golf course and public

open space (POS) watering areas, Eynesbury Rd, Eynesbury 3338 • Toolern Precinct comprising early stages of Waterford (Exford Rd),

Atherstone (Bridge Rd) and Toolern Waters (Rees Rd) residential developments and POS, Melton South 3338

• Tabcorp Park, 2-26 Ferris Rd, Melton South 3338

Site/premises name Melton (Surbiton Park) Recycled Water Plant

• Street Name Cnr Butlers Rd and Greigs Rd

• Suburb Mount Cottrell

• Postcode 3024

Site/premises name Eynesbury Township (Class A recycled water scheme for residential dual pipe uses, golf course and public open space irrigation)

• Street Name Eynesbury Road

• Suburb Eynesbury

• Postcode 3338

Site/premises name Toolern Precinct Residential Developments (Class A recycled water residential dual pipe uses and public open space irrigation) as follows: • Waterford • Atherstone • Toolern Waters (no connections at time of audit)

• Street Name • Waterford – west of Exford Road • Atherstone – north and south of Bridge Road • Toolern Waters – west of Rees Rd

• Suburb Melton South

• Postcode 3338

Site/premises name Tabcorp Park (Harness Racing Victoria)

• Street Name 2-26 Ferris Rd

• Suburb Melton South

• Postcode 3338



E.3

GIS coordinates of site centroid: Latitude (GDA94) Longitude (GDA94)

Melton RWP 37.757485 S 144.584474 E

Eynesbury Township: 37.792475 S 144.559494 E

Waterford Development 37.731024 S 144.571920 E

Atherstone Development 37.715477 S 144.590415 E Toolern Waters Development 37.717633 S 144.559026 E

Tabcorp Park 37.698448 S 144.599045 E

Site area (hectares) Melton RWP: total property area 692 Ha, containing the Class A treatment and storage tank compounds (~1 Ha in size).

Class A recycled water scheme serves supply areas within Eynesbury, Mt Cottrell and Melton South containing the following sub-areas (as at December 2013):

• Eynesbury township precinct about 1250 Ha in total containing: § about 626 residential and 7 non-residential connections with

dual pipe supply (toilet flushing, garden watering, car washing, and trial laundry uses)

§ ~82 Ha of golf course, with ~35 Ha under irrigation (1.5 Ha of greens, 1.5Ha of tees and 22 Ha of fairways)

§ ~4-5 Ha public open space under irrigation (ultimately 8 Ha proposed)

• Waterford Development: ~30 Ha (initial stages), containing about 127 residential dual pipe connections, and 1 POS area (approximately 1 Ha under irrigation)

• Atherstone Development: ~ 20 Ha (initial stages), containing about 51 residential dual pipe connections

• Toolern Waters: residences under construction but none connected to recycled water supply at time of audit

• Tabcorp Park 20 Ha total property area, ~1.8Ha of irrigated gardens and lawns, and ~ 0.65Ha of trotting track area (no longer irrigated).

Members and categories of support team utilised

Tony Pitt (EIA Land for soil and groundwater, Sampling and Interpretation of Analytical Data for soils and groundwater)

Outcome of the audit Based on the operational data and information assessed over the period considered for this audit (1 July 2012 to 30 June 2013), and subject to the system improvements identified in this report: - The Melton South Class A Recycled Water Scheme is being operated

and managed by Western Water generally in accordance with the commitments made in the HEMP, Recycled Water Quality Management Plan (RWQMP) and other documents (Health Risk Management Plan, Environment Risk Management Plan) incorporated into the HEMP framework, and as currently endorsed by EPA and



E.4

Department of Health. - The Recycled Water Scheme is being operated generally in accordance

with the objectives and suggested measures of EPA’s dual pipe guidelines.

- The audit did not identify any non-conformances with the HEMP, RWQMP or other incorporated documents.

- The auditor did not identify any non-conformances with relevant environmental legislation or relevant SEPPs (Waters of Victoria, Groundwaters of Victoria, Contamination of Land)

- The Class A scheme does not pose any obvious risk of harm to the environment or public health.

The Auditor has suggested a number of “System Improvements” (SI) for consideration by Western Water, which are mainly administrative in nature including: • Suggested concurrent reviews the HEMP, RWQMP, HRMP, ERMP, • Reviews of customer site management plans, • Reviews of WW procedures and other key documentation, • Review of monitoring requirements for non-residential customers, • Review of customer engagement and staff training and awareness

programs • Validation of bulk water and customer usage data for water

accounting purposes (potential losses) and reporting purposes • Review of internal auditing programs including for residential

customer cross connection checks, and non-residential customer site soil sampling audits, and

• other system improvements that do not represent risk to the environment.

Suggested SI’s in this audit report are designed to address or clarify certain administrative commitments made by Western Water in the HEMP and/or incorporated documents (RWQMP, ERMP, HRMP). SI’s are provided throughout the main report and also in the Appendices (includes the Audit checklist and record of compliance assessment). Refer to section 5.3 for a consolidated list of SI’s identified in this audit.

Further work or requirements Western Water should consider the Auditor’s suggested system improvements identified in this audit as part of the next review of the HEMP, RWQMP, HRMP, ERMP and other incorporated documents and business management systems.

Refer also to further Conclusions and Recommendations in Section 6.

Table E-2 Physical Site Information

Groundwater Segments The surface aquifer in the region containing the Melton RWP and Eynesbury Township is predominantly Segment C.

The transition to Segment B appears to occur north of the township.



E.5

The surface aquifer in the Toolern Precinct including the Waterford Development and Tabcorp Park (Melton South) is predominantly Segment B. The transition to Segment C appears to occur south of the junction of Toolern Creek and Werribee River (ie. south of Parwan-Exford Rd and Greigs Rd).

Surrounding Land Uses Melton RWP is zoned PUZ1 (Public Use Zone - Service And Utility) within Melton Shire. The RWP (ie. Surbiton Park property) is surrounded by:

• North and West: GWZ (Green Wedge Zone), rural residential properties to the north, dryland rural to the west

• South: RCZ (Rural Conservation Zone), dryland rural lands • East: GWZ and SUZ1 (Special Use Zone – Schedule 1), dryland

rural properties

Eynesbury Township: • Current extent of the township is within Melton Shire. Future

township growth to the south will extend into City of Wyndham. • The township is zoned MUZ (Mixed Use Zone), contains occupied

residential estates, public open spaces, Eynesbury golf course and clubhouse at the historic Eynesbury Homestead.

• The Green Wedge Zone (GWZ) and Grey Box Forest Rural Conservation Zone (RCZ) and native bushland reserve borders the town to the north.

• Dryland rural land (zoned GWZ and RCZ) borders the west and south boundaries of the township

• Dryland rural lands and the Werribee River escarpment borders the township boundary to the east

Waterford Park and Atherstone Developments (Melton Shire): • These developments are within the Urban Growth Zone (UGZ3),

and contain the initial stages of occupied residential development, display village and public open spaces.

• North, South and East: Urban Growth Zone (UGZ3), currently undeveloped

• West of Waterford Park is Melton Reservoir, zoned PUZ1 (Public Use).

Tabcorp Park - Melton Harness Racing Track (Melton Shire) • Site is within a Special Use Zone (SUZ1) • North: Western Freeway (Road Zone - RDZ1) and Industrial (IN1Z) • West, East and South: Urban Growth Zone (UGZ3).



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1 Introduction

1.1 Background of Melton South Class A Recycled Water Scheme Melton Recycled Water Treatment Plant (WTP) is located on Greigs Road, about 6km south of Melton, approximately 33km east of the Melbourne CBD in the Shire of Melton. The RWP produces Class C recycled water from conventional activated sludge processes and maturation lagoons. The Class A plant treats Class C feedwater by microfiltration, UV and chloramination processes for supply to the Melton South Class A Recycled Water Scheme.

A map showing the location of the Melton RWP and Melton Class A Recycled Water Scheme supply areas is provided in Figure 1-1. The Melton Class A RWP became fully operational in October 2008, with the first Eynesbury residential properties connected to Class A recycled water supply in January 2009.

At the time of this audit, the Melton Class A Recycled Water Scheme was connected to about 630 dual pipe residential and non-residential customers within Eynesbury Township and about 178 residential customers in the the Toolern Precinct (Melton South). There are three residential developments under construction within the Toolern Precinct – (i) the Waterford (about 127 connected residences at time of this audit), (ii) Atherstone (about 51 connected residences), and (iii) Toolern Waters (residences under construction but not yet connected or using).

The supply of Class A recycled water allows for residential non-potable uses including toilet flushing, garden watering and car washing, with trials for domestic laundry usage currently underway. The Melton Class A Recycled Water Scheme supplies several non-residential customers including irrigation of public open space areas within the new Eynesbury and Toolern precinct residential areas, irrigation of Eynesbury Golf Course, and irrigation and track watering at Tabcorp Park. The Class A scheme also supplies numerous water carters from the Class A standpipe at Melton RWP, and can also be used for CFA/MFESB fire service operational activities (ie. use of Class A water from fire hydrants for fire fighting training and actual fire fighting purposes).

The supply of Class A recycled water to these dual pipe areas is subject to a Health and Environmental Management Plan (HEMP) and incorporated documents comprising the Recycled Water Quality Management Plan (RWQMP) for the Class A Plant, Health Risk Management Plan (HRMP) and Environmental Risk Management Plan (ERMP) developed and implemented by Western Water. The HEMP framework is shown in Figure 1-2.

This HEMP framework has EPA Victoria approval (most recent documents approved 1 November 2012, original approval in May 2008). The RWQMP (Revision 7) issued to Department of Health Victoria on 26 October 2009 is endorsed by DHV. The recycled water pipelines into the Toolern Precinct including to Tabcorp Park were completed in May 2009. Residential development began in Waterford within the Toolern Precinct in late 2011/early 2012.

The HEMP specifies that a statutory audit shall be conducted every 3 years after the initial HEMP audit. The first audit of the HEMP was carried out by Dr. Ian Wallis of Consulting Environmental Engineers (CEE) between March and September 2010, roughly 12 months after the commencement of Class A recycled water supply to dual pipe residential customers within Eynesbury township.



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Figure 1-1 Location of Melton RWP and Class A Recycled Water Scheme Supply Area

(Source of base map: Western Water 2013)

Waterford

Toolern Waters

Tabcorp Park

Atherstone

Melton Reservoir (Werribee River)

Recycled Water Supply mains

Werribee River

Toolern Creek



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Figure 1-2 Melton Class A Recycled Water Scheme – HEMP Framework (source: HEMP 2012)

Rohan Ash (EPA Appointed Auditor – Industrial Facilities) was engaged by Western Water on 14 October 2013 to undertake a 53V audit of the implementation of the HEMP for the Melton Class A Recycled Water Scheme. The EPA was notified on 22 October 2013 using the form ‘Notification of request to conduct an environmental audit of an activity’ in accordance with EPA Publication 952.4 (April 2013). EPA’s Environmental Audit Coordinator acknowledged the audit notification on the same day and advising of service order number 8004160, and CARM's number 67653-2.

1.2 EPA Guidelines

The primary EPA guidelines relevant to the Melton Class A recycled water scheme are:

• Guidelines for Environmental Management: Dual Pipe Water Recycling Schemes - Health and Environmental Risk Management (EPA Publication 1015, October 2005). Referred to in this report as the “Dual Pipe Guidelines”.

• Guidelines for Environmental Management: Use of Reclaimed Water (EPA Publication 464.2, June 2003). Referred to as the “Reclaimed Water Guidelines”.

This audit primarily focuses on the performance of the Class A Plant and recycled water supply system to the existing residential customer base within Eynesbury and Toolern Precinct developments, for conformance with Western Water’s HEMP framework and EPA’s dual pipe guidelines.

This audit has also broadly assessed Western Water’s non-residential customer management system in terms of general compliance with the intent of the HEMP framework and EPA guidelines. A detailed compliance assessment of the non-residential uses against EPA’s Reclaimed Water Guidelines was not in the scope of this audit.



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1.3 Audit Purpose The May 2012 Health and Environmental Management Plan (HEMP) for the Melton Class A Recycled Water Scheme requires a statutory (“risk to the environment”) audit to be undertaken every 3 years, by an EPA appointed auditor in accordance with section 53V of the Environment Protection Act 1970, and the audit requirements of EPA’s Dual Pipe Guidelines. The last statutory audit was reported to Western Water by Ian Wallis of Consulting Environmental Engineers (CEE) in September 2010.

Class A recycled water supply to Eynesbury Township commenced in early 2009, with about 626 houses connected to the dual pipe reticulation system at the time of this audit. The Toolern Precinct was connected in early 2012, with about 178 houses connected to Class A dual pipe supply at time of this audit. This Audit is the 2nd statutory audit of the Melton Class A Recycled Water Scheme.

Western Water’s Melton Class A Recycled Water Scheme HEMP framework is shown in Figure 1-2. The HEMP framework incorporates the Recycled Water Quality Management Plan (RWQMP) (October 2009), Health Risk Management Plan (HRMP) (May 2012) and Environmental Risk Management Plan (ERMP) (May 2012) to ensure full conformance with the documentation requirements of EPA’s dual pipe guidelines (publication 1015).

The HEMP, RWQMP, HRMP and ERMP were the focus of this Audit. The other integrated business systems and procedures of the framework as shown in Figure 1-2, were subject to broad review only.

1.4 This Report This report describes the audit scope, methods, findings of compliance and assessments on risk of harm to the environment, conclusions and recommendations for corrective actions and opportunities for improvement for the Melton Class A recycled water scheme and HEMP framework.

This report has been prepared to meet the requirements of EPA’s guidelines for 53V audit reporting (publication 952.4, April 2013), intended for submission to Western Water and EPA.



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2 Audit Objectives and Scope

2.1 Audit Objectives

The scope and approach to the audit was outlined in the letter proposal from Land Safe (Ag-Challenge Pty Ltd) to Western Water dated 7 October 2013. The audit scope was prepared to be consistent with the following EPA guidelines: • EPA statutory auditing requirements for dual pipe recycling schemes as described in EPA’s Dual Pipe Water

Guidelines (Publication no. 1015) and • EPA’s auditing guidelines “Preparation of environmental audit reports on risk to the environment” (Publication

952.4).

The overall objective of this audit is to assess compliance with the Melton Class A Recycled Water Scheme HEMP framework and EPA’s dual pipe guidelines, by evaluating the performance of the scheme against the commitments made by Western Water in the HEMP framework.

2.2 Scope

The audit scope responds to the auditing requirements specified in the HEMP, and with that described in Chapter 13 of EPA’s Dual Pipe Guidelines, to assess: • That the provisions within the HEMP are implemented; • That any issues identified in system monitoring or system review as potentially impacting on compliance with

the guideline performance objectives are being appropriately addressed; • That any changes in the system management that could impact on compliance with the guideline performance

objectives are identified and are being appropriately addressed; • That preventative risk management systems are in place and that it appropriately address risk identification,

assessment and management.

To address the above, the audit program included the following compliance and risk assessments:

• review the adequacy of the documented HEMP, including incorporated documents, in particular the RWQMP, HRMP and ERMP Plan;

• review the implementation of the HEMP and incorporated documents to establish if Western Water is meeting its commitments and conforming with EPA’s dual pipe guidelines; and

• assess whether the Melton Class A supply scheme to dual pipe residential developments are operating in a manner that protects human health and does not pose an unacceptable risk of harm to the environment.

The scope of audit focussed on assessment of performance over the period 1 July 2012 to 30 June 2013. Recycled Water usage data since last audit and into the 2013-14 year and were also reviewed for trend analyses.

2.1.1 Activities subject of this audit The Melton RWP is located on Western Water owned property (also called Surbiton Park) at Mt Cottrel, Victoria within the Shire of Melton. The RWP supplies Class A Recycled Water by pipeline to residential and non-residential customers located in Eyensbury and Melton South all currently within the Shire of Melton. Future Eynesbury township growth to the south will ultimately extend into the City of Wyndham.

The study area for this audit is defined as the Melton Class A RWP, existing Class A recycled water storages and supply pipelines, and existing customers in the supply areas shown in Figure 1-1. Masterplans showing existing



6

and future residential areas for Eynesbury, Waterford and Atherstone developments are shown in Appendix A (Figures A-1 to A-4). Note Toolern Waters was under construction but no houses yet occupied during the 2012-13 year (period of assessment for this audit).

The activity and components, which are the subject of this audit comprise: • Class A Recycled Water Supply system from Western Water’s Melton (Surbiton Park) Recycled Water Plant

(RWP) for use within Eynesbury Township and Toolern Precinct by residential customers for dual pipe uses, and • Non-residential Class A customers for irrigation of public open space, fire fighting and standpipe customers.

2.1.2 Segments of the Environment Given the early stages of the dual pipe developments, it is anticipated that the risks to the environment would be low. Therefore, the environmental segments considered in this audit were limited to the following receiving environments and receptors associated with activities located within the Audit study area:

Segment Receptor

• Land: — soil and plants within the dual pipe residential developments, golf course and POS irrigation areas (modified landscape environment with unrestricted access)

• Surface waters: — Stormwater and potential recycled water (runoff, spills, leaks, flushing/scouring, overflows from golf course storage dam and ornamental dams) discharge into man-made Water Sensitive Urban Design (WSUD) urban drainage systems, ultimately discharging to receiving waters of Melton Reservoir, Toolern Ck, and the unnamed drainage system through and downstream of Eynesbury Township (Werribee River Catchment);

• Groundwater: (Category B & C)

— RWP, Class A recycled water storage, pipelines and Class A filling station (potential seepage from spills, leaks, flushing)

— Residential, POS irrigated areas (irrigation pipe spills, leaks and irrigation area leaching, seepage from golf course storage dam and ornamental dams).

Segments of the environment above considered in this audit are those contained the land covering the Melton RWP and Melton Class A Recycled Water Scheme supply area delineated and highlighted in Figure 1-1.

Other elements including the air environment and noise emissions are excluded from the scope because there is negligible associated risk posed by the Class A Recycled Water Scheme.

2.1.3 Beneficial Uses The beneficial uses to be considered in this audit are contained in the following SEPPs, but only those considered relevant to the Melton Class A recycled water scheme:

1. State Environment Protection Policy (Waters of Victoria)

The Melton Class A RWP and supply areas are contained within the “Cleared Hills and Coastal Plains”

segment. Beneficial uses considered relevant to this audit comprise: • Slightly to moderately modified ecosystems • Primary and secondary contact recreation • Aesthetic enjoyment • Agriculture and irrigation • Industrial and commercial use



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• Human consumption after appropriate treatment • Fish, crustacae and molluscs for human consumption.

2. State Environment Protection Policy (Groundwaters of Victoria)

The Melton RWP and Class A supply area is located within a region containing Category B and C groundwater quality (source: Victorian Government Beneficial Use mapping: http://www.water.vic.gov.au/__data/assets/pdf_file/0010/53794/Melbourne-Groundwater-Map-LowRes.pdf). Beneficial use mapping indicates groundwater salinities (TDS) ranging as follows:

• 1000 – 3500 mg/L in the Melton South (Toolern Precinct) area corresponding to Segment B as defined in the SEPP; and

• 3501 - 7000 mg/L across the Melton RWP premises and in Eynesbury Township, corresponding to Segment C in the SEPP.

Therefore Segments B and C were chosen for establishing the relevant beneficial uses for this audit. Beneficial uses of groundwater to be protected within Segments B and C as declared in the SEPP are:

Groundwater Beneficial Uses Segment B Segment C

Maintenance of ecosystems ✓ ✓ Potable Water Supply

Potable Mineral Supply ✓

Agriculture, parks and gardens (e.g. irrigation) ✓ Stock watering ✓ ✓ Industrial water use ✓ ✓ Primary contact recreation (e.g. bathing, swimming) ✓ ✓ Buildings and structures ✓ ✓

3. State Environment Protection Policy (Prevention and Management of Contaminated Land).

SEPP Prevention and Management of Contamination of Land (as amended 26 September 2013) defines beneficial uses of various land uses. The potential land uses considered in this audit adjacent to or within the Melton RWP, Toolern Precinct and Eynsebury Township are:

• Parks and Reserves (ie. Grey Box Forest north of Eynsebury, Toolern Creek Park) • Agricultural (rural areas involved in agricultural and horticultural practices) • Sensitive uses including land used for residential and associated uses • Recreation/open space, and • Commercial and Industrial.

The above land uses relate to the land within and immediately adjacent to the residential developments, public open space and sports ovals currently receiving Class A recycled water in the study area, as well as Western Water owned land containing the RWP and Class A Filling station.

• Beneficial uses to be protected for these lands uses are potentially as follows: • Maintenance of Ecosystems: modified ecosystems, highly modified ecosystems; Human Health; • Buildings and structures; • Aesthetics; and • Production of food, flora and fibre.



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The SEPP does not specify objectives for the main soil parameters (salinity, sodicity, cation balance, structure, texture, dispersion, nutrients, pH, etc.) of concern associated with potential production of food, flora and fibre in home gardens of residential developments. The SEPP focusses on contaminants and triggers (e.g. Ecological and Health Investigation Levels or EILs HILs), which are found in NEPM for heavy metals, pesticides, organic chemicals and other contaminants of industrial origin. Given that SEPP does not specify objectives for normal agronomic parameters, this audit will consider reputable publications containing criteria and guidance on salinity, sodicity, nutrient and pH such as: • Guidelines for Environmental Management - Use of Reclaimed water (EPA Pub. No. 464.2, 2003); • Guidelines for Wastewater Irrigation (EPA Victoria, Pub No. 168, April 1991); and • National Water Quality Management Strategy, Australian Guidelines for Water Recycling: Managing

Health and Environmental Risks (Phase1). Environment Protection and Heritage Council, Natural Resource Management Ministerial Council, Australian Health Ministers Conference, EPHC, November 2006. Specifically relevant criteria contained in: § Appendix 4 Detailed risk assessment for key environmental hazards and § Appendix 5 Reference tables for environmental risk assessment;

• Other reputable publications to be clearly referenced in the audit report.

SEPPs excluded from Audit

The above SEPPs are considered relevant to the environmental segments considered in this audit. Other SEPPs were excluded from the scope of this audit including SEPP (Air Quality Management) and SEPP (Control of Noise from Commerce, Industry and Trade No. N1). The reason for exclusion is that they were largely not applicable to the audited activities (i.e. negligible or no risk of harm to the environment) - as explained below.

SEPP - Air Quality Management

Under the Air SEPP, the following beneficial uses are protected throughout the State of Victoria: a) life, health and well-being of humans;

b) life, health and well-being of other forms of life, including the protection of ecosystems and biodiversity;

c) local amenity and aesthetic enjoyment;

d) visibility;

e) the useful life and aesthetic appearance of buildings, structures, property and materials; and

f) climate systems that are consistent with human development, the life, health and well-being of humans, and the protection of ecosystems and biodiversity.

Spray drift can occur during spray irrigation, which can produce a chlorine type odour from the chlorine residual usually maintained in reticulated Class A recycled water supply. This odour is usually barely detectable to humans and of negligible health or environmental risk.

SEPP (Air Quality Management) was therefore excluded from the scope of this audit given that Class A recycled water is allowed by EPA guidelines to be used without restriction for non-drinking purposes such as toilet flushing, residential garden watering, day-time irrigation of sports reserves and public open spaces.



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SEPP – Control of Noise from Commerce, Industry and Trade No. N1 SEPP – N1 was excluded from the scope of this audit given that the Class A recycled water treatment, supply and reuse activities considered in this audit do not have any potential for excessive or “unwanted noise”. There is potential for noise from irrigation pumps but this is normally barely detectable at sensitive receptors and negligible risk of complaint. The assessment of noise from the Class C treatment activities at the RWP was therefore not part of the scope of this audit.

2.1.4 Risk Assessment A high-level qualitative risk assessment was undertaken to assess and prioritise any non-conformances identified during the audit, in context of risk of harm to the environment. The risk assessment approach is consistent with AS/NZS ISO 31000:2009 Risk Management – Principles and Guidelines. Refer to Section 3.4 for further details of risk assessment methodology.

2.1.5 Audit Compliance Period Considered The period of time for which the scope of this audit applies is the 2012/13 financial year. Note that this audit also reviewed the overall performance of Melton Class A Recycled Water scheme since the previous audit by CEE for the purposes of assessing Western Water’s response to CEE’s audit recommendations, but with focus of assessment based on representative sample of data for the 2012-13 period.

2.1.6 Audit Exclusions and Limitations

Actual or potential environmental impacts were expected to be insignificant in these early years of the Melton Class A recycled water scheme. The assessment of soil and groundwater monitoring results for land within the residential developments of the study area (none available), irrigated plants, natural flora and fauna, aquatic systems, animal health, noise and air emissions (including spray drift and odour) were excluded from evaluation in this audit. These elements however were broadly considered by the auditor and general commentary may be provided where obvious or significant risk issues were identified during the audit program.

Other than the review of Melton RWP Class C recycled water quality as feed water for the Class A plant, the environmental impacts of Class C facility operations were excluded from the scope of audit.

The auditor did not undertake independent sampling of recycled water, soils, groundwaters, stormwater or surface waters. This audit relies on the available monitoring data as provided by Western Water and the non-residential customers interviewed during the audit program.

Other specific audit exclusions are mentioned throughout this report.

2.1.7 Audit Criteria The audit criteria are the requirements against which the audited activities and Western Water (the auditee) are assessed against, if found to be relevant during the audit. The following regulatory and guideline list from the HEMP guidelines formed the basis for developing the Audit criteria for this report:

• Environment Protection Act 1970 (Victoria); • Environment Protection (Scheduled Premises and Exemptions) Regulations 2007 (Vic); • SEPP (Waters of Victoria); • SEPP (Groundwaters of Victoria); • SEPP (Prevention and Management of Contamination of Land); • Health Act 1958 (Vic); • Building Act 1993 (Vic);



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• Water Act 1989 (Vic); • Occupational Health and Safety Act 1985 (Vic); • Guidelines for environmental management: Dual pipe water recycling schemes – health and environmental

risk management (EPA Pub. 1015, 2005); • Guidelines for environmental management: Use of reclaimed water (EPA Pub. 464.2, 2003); • Addendum to Class A Information in EPA Publication 464.2 (2003) (EPA 2006); • Guidelines for wastewater irrigation (EPA Pub. 168, 1991); • Guidelines for environmental management: Disinfection of treated wastewater (EPA Pub. 730, 2002); • Sampling and Analysis of Waters, Wastewaters, Soils and Wastes Industrial Waste Resource Guidelines (EPA

Pub. IWRG701 2009); • Groundwater Sampling Guidelines (EPA Pub. 669, 2000); • Guide for the completion of a Recycled Water Quality Management Plan for Class A water recycling schemes

(DHS Victoria 2008); • Guidelines for validating treatment processes for pathogen reduction. Supporting Class A water recycling

schemes in Victoria (DHV, February 2013); • Recycled Water Plumbing Guide (Recycled Water Plumbing Guide, Dual Pipe Plumbing Systems) (Plumbing

Industry Commission & Water Authorities 2005); • Grey or Recycled Water (Non-Drinking Water) – Performance and compliance check Level 1 and Level 2 Faults

(Plumbing Industry Commission July 2012) • Australian and New Zealand Guidelines for Fresh and Marine Water quality (National Water Quality

Management Strategy Paper No. 4) (ANZECC 2000) • Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase1). Environment

Protection and Heritage Council, Natural Resource Management Ministerial Council, Australian Health Ministers Conference (EPHC 2006).

The criteria for this audit were based on the structure of WW’s HEMP framework and corresponding guideline criteria within EPA’s Publication 1015 (“dual pipe guidelines”). Conformance to the dual pipe guidelines is considered as best industry practice and the key measure of compliance with the other legislative and guidelines criteria mentioned above. Where non-conformance with the HEMP or dual pipe guidelines is identified, the auditor has assessed the risk of harm to the environment in terms of potential adverse impacts on relevant beneficial uses as defined in SEPP.

2.3 EPA Victoria Environmental Auditing Guidance This audit was conducted in accordance with the most up to date editions of the following EPA Victoria guidelines for conducting environmental audits and preparing reports on risk to the environment:

• Environmental Auditor Guidelines, Provision of Environmental Audit Reports, certificates and statements (EPA Pub. 1147.1, January 2013)

• Environmental Auditor Guidelines for Conducting Environmental Audits (EPA Pub. 953.2, October 2007)

• Environmental Auditor Guidelines for the Preparation of Environmental Audit Reports on Risk to the Environment (EPA Pub. 952.4, April 2013).

The audit program and methods adopted were also consistent with AS/NZS ISO 19011: 2003 Guidelines for Quality and/or Environmental Management Systems Auditing.



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2.4 EPA Notification of Audit EPA was formally advised on 22 October 2013 of the appointment of Rohan Ash (EPA Appointed Auditor Industrial Facilities) for this audit. EPA’s Environmental Audit Co-Ordinator (Environmental Audit Unit) acknowledged (by return email) the audit notification on the same day. The auditor advised the Environment Audit Unit of audit program date extensions that occurred during the engagement.

EPA advised that this audit is identified by “service order number” 8004160 and CARM's number 67653-2. Either number can be used to identify this audit in future correspondence and matters regarding this audit.



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3 Methodology

3.1 Audit Team The Audit team was fully sourced from Land Safe (Ag-Challenge Consulting Pty Ltd), as follows:

Audit Team Role

Rohan Ash Lead Auditor - EPA Appointed Auditor Industrial Facilities

Glenn Marriott Agricultural & Environmental Scientist and Audit Support

Tony Pitt Principal Consultant, Expert Support (soils, groundwater) and Peer Reviewer

3.2 Audit Program

3.2.1 Inception Meeting An inception meeting was conducted with Western Water on 1 November 2013 at Melton RWP to:

• Obtain an overview of the Western Water organisational structure and business systems in relation to the Melton (Surbiton Park) RWP and Class A recycled water operations

• Obtain and overview of status of the recycled water scheme and level of compliance with the HEMP; • Introduce key Western Water contacts for the audit program; • Confirm the audit scope, timelines, information and data requirements; and • Make preliminary arrangements for scheduling and resourcing the detailed audit program.

Immediately following the kick-off meeting, the auditor carried out an initial inspection of the RWP and recycled water supply areas:

• Melton RWP including Class C and Class A treatment plant, Class A storage, pump station and pipeline, and Class A Standpipe onsite;

• Location of residential Class A dual pipe recycled water supply areas including: — Eynesbury Township; and — Waterford, Toolern Waters, Atherstone developments with the Toolern Precinct (Melton South)

• Location of non-residential customer sites: — Public open space reserves in the above residential estates; — Eynesbury Golf Course; — Tabcorp Park (Harness Racing Victoria) at Melton South.

3.2.2 Field Audit and Interviews The field audit program was carried out between 9 and 12 December 2013. The field audit program for 9, 10 and 12 December 2013 is provided in Appendix B. A winter follow up inspection of urban stormwater systems for the Eynesbury and Atherstone developments was undertaken on 3 July 2014.

The audit team interviewed key Western Water staff responsible for operation and administration of the Melton Class A recycled water scheme and also responsible for monitoring and compliance with the HEMP.



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The audit team carried out inspections of the Melton RWP Class A treatment process train (from Class C feedwater to Class A storage tank, and associated pumping and pipeline infrastructure where readily and safely accessible. At the time of inspection of the RWP, no Class A recycled water was being produced due to low demand at the time.

The recycled water dual pipe supply areas within Eynesbury township and Toolern Precinct were also inspected including residential areas containing occupied residential properties. No onsite (“intrusive”) inspections of any residential properties were undertaken.

All inspections were from a public viewpoint outside front of property. These inspections of selected properties enabled the audit team to verify a representative sample of the following recycled water infrastructure relevant to compliance with the HEMP and EPA’s dual pipe guidelines:

• Western Water’s bulk recycled water supply infrastructure, i.e. visible above ground works in publically accessible areas including bulk meters, isolation valves, hydrants and recycled water signage for different stages of the developments where Class A recycled water is delivered and used,

• Western Water infrastructure interface points for dual pipe plumbing systems at front of property, including completed recycled water meter and dual check valve assemblies and partly completed assemblies for houses in various stages of completion;

• completed open space parkland/reserve areas including the irrigated areas using Class A recycled water; • stormwater systems serving the residential areas, including stormwater ponds and final outlets to receiving

drains and surface waters (Werribee River catchment).

Inspections were also carried out of a representative selection of non-residential customer sites including irrigated Public Open Space areas of Eynesbury and Waterford Development, Eynesbury golf course and Tabcorp Park. The customer site manager or nominated representatives were also interviewed where available.

These inspections enable the audit team to observe Class RWP facilities, recycled water storage and distribution systems, and end-use sites (residential and non-residential) to assist the auditor with assessment of compliance with the HEMP and identify any potential environmental risks.

During the audit program, the audit team carried out inspection and review of documentation, data, records, reports and computer based management systems and databases maintained at Western Water offices relevant to the Melton Class A Recycled Water Scheme and HEMP compliance.

The Auditor appreciates the assistance, patience and co-operation of all Western Water staff for the prompt responses to the requests for information and data clarifications. The auditor also wishes to thank Western Water staff and its customers for making time for interviews and to accompany the Auditor on the site visits.

The audit schedule and a list of personnel interviewed during the audit are included in Appendix B.

3.2.3 Information and Data Review The audit team conducted a review of a large amount of documentation that forms the key components of the Melton Class A recycled water scheme and HEMP framework. This included the primary controlling documents - the HEMP, RWQMP, HRMP and ERMP, as well as other Western Water environmental and business management systems, operating procedures, hard copy and electronic datasets (including SCADA records), training records, customer site management plans and recycled water agreements, annual reports, internal audit reports and other documents. The purpose of the review was to assist the auditor to evaluate performance of the scheme and Western Water as supplier and scheme manager.



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A complete list of the documentation reviewed during the audit is provided in Appendix C.

3.2.4 Audit Checklists A check-list was used to record the evidence collected and track responses, during the audit program. The check-list was based on the 12 chapters of the HEMP and also in accord with chapter structure of EPA’s dual pipe guidelines, generally as follows:

1. Regulatory framework 7. Communicating management controls

2. Roles and responsibilities 8. Incidents and emergencies

3. Recycled water system assessment 9. Employee awareness and training

4. Managing human health risks 10. Research and development

5. Managing the supply system 11. Documentation and reporting

6. Managing environmental risks 12. Auditing, review and improvement programs

The HEMP checklist served both as a compliance assessment for the commitments made by Western Water in the HEMP, and also for assessment of conformance with EPA’s dual pipe guidelines.

The checklist used for compliance assessment, together with responses and other notes made during the audit are provided in Appendix F.

3.3 Compliance Assessment The audit team carried out compliance assessments against the commitments made in the HEMP, RWQMP, HRMP and ERMP and other key supporting documentation, as well as against relevant EPA and DHV guidelines. The assessment was based on documents reviewed and responses made at site inspections and interviews. The purpose of the compliance assessment was to identify if there were any non-conformances and recommend corrective actions and/or improvement opportunities that would ensure compliance with the HEMP and EPA and DHV guidelines. The assessment also evaluated the impact on non-conformances in terms of risk of harm to the environment or public health by assessing conformance with environmental objectives and potential impacts on beneficial uses as declared in the relevant SEPPs.

The compliance assessments also identify any key data gaps, or other areas where further investigation or amendment to the HEMP or supporting documentation may be suggested as opportunities for improvement (OFI).

Key areas of non-conformance and improvement opportunity are summarised by exception in this report, and prioritised based on qualitative risk assessment of risk of environmental harm, providing a ranking consistent with Western Water’s risk (likelihood and consequence) matrix as described in the HRMP (see Table 3-1).

3.3.1 Non-Conformance Classification A three-tiered nomenclature for classifying non-compliances with the HEMP of EPA guidelines has been adopted for this audit report are defined as follows:

Critical Non-conformance (CNC)

A non-conformance with one or more of the auditable elements or risk management activities where a serious or imminent risk to public health or the environment is identified. That is, if the practice, the process or situation is allowed to continue (or conversely is not implemented) it is very likely to compromise the health of consumers.



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Major Non-conformance (MaNC)

A non-conformance with one or more of the auditable elements, or risk management activities, where there is a high potential for a risk situation and that risk situation is likely to compromise public health or the environment if the non-conformance is not rectified.

Minor Non-conformance (MiNC)

A non-conformance with one or more of the auditable elements, or risk management activities, where the potential impact of the non-conformance is not likely to be a serious or imminent risk to public health or the environment.

These Non-Conformance Classifications were used by the Auditor to classify the non-conformances identified in this audit and any associated potential risk of environmental harm.

3.3.2 System improvement (SI)

Other minor issues that are not regarded as non-conformances or a significant environmental/public health risk were assigned as “System Improvements (SI). These are pro-active suggestions by the auditor designed to address minor management system gaps as identified in the audit. A SI could be administrative in nature such as suggested editorial changes to the HEMP, RWQMP, HRMP, ERMP, customer site management plans, other key documentation or procedures, additional monitoring, awareness training, improved data validation for reporting purposes or other system improvements.

Suggested timelines for addressing non-conformances and any corresponding recommendations and/or system improvements are provided in this report.

The record of the compliance assessment based on the audit teams notes of responses and observations made during the audit are provided in Appendix D.

3.4 Risk Assessment

The purpose of risk assessment in statutory audits is to identify the risk of any possible harm or detriment to segments of the environment caused by any industrial process or activity, as specified by Section 53V of the Environment Protection Act 1970 and EPA auditor guidelines.

Class A recycled water has been supplied to residential properties and non-residential customers within Eynesbury township since early 2009, and within the Toolern Precinct since early 2012. In these early years of the dual pipe scheme, low recycled water volumes have been supplied. There were also been low demands due to higher than average rainfall across the 2009/10-2010/11 period.

In view of the above, a high level qualitative risk assessment was carried out and, focusing on the risk of harm (or “negative” impact) to public health or to the environment from any obvious non-conformances relating to:

1. Class A recycled water product quality; 2. Recycled water supply and distribution systems (both Western Water assets and private residential plumbing

systems) to residential (dual pipe scheme) and non-residential customers; and 3. Recycled water use by non-residential customers – ie. public open space and golf course irrigation.

The risk assessment was essentially based on the audit inspections and desktop review of available data supplied by Western Water and readily available (published) data from other reputable sources, where needed.



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Note that the audit scope did not include assessment of the impact of construction activities currently underway at the various residential developments. Current exposure and disturbance of large areas of dispersive basaltic clay soils represents a significant risk of erosion and potential sediment pollution of local waterways under high intensity rainfall and overland flow events. It is considered that the construction activities currently pose greater risk to receiving surface waters than the current low volumes of Class A recycled water use for dual pipe supply and irrigation of the golf course and POS. However, the risk assessment of the recycled water scheme has considered the potential impact of the construction activities as part of establishing the context of root cause of other potential land and local water quality impacts.

3.4.1 Risk of Harm

Risks identified in this audit were qualitatively estimated and ranked according to the matrix given in Table 3-1. This qualitative risk assessment matrix is consistent with the methods outlined in:

• “Australian Guidelines for Water Recycling: Managing Health and Environmental Risks (Phase 1) NRMMC 2006), • AS/NZS ISO 31000:2009 Risk management - Principles and guidelines.

Table 3-1: Western Water Likelihood and Consequence scoring matrix used in the hazard analysis

Description Likelihood of Failure

Consequence of Failure

D Insignificant

C Minor

B Moderate

A Major

AAA Catastrophic

Failure has already occurred

6 - Already Failed M H E E E

Is expected to occur in most circumstances

5 - Certain L M H E E

Will probably occur in many circumstances

4 - Likely L L M H E

Could occur at some time 3- Moderate N L M H H

Not expected to occur 2 - Unlikely N L L M M

May occur only in exceptional circumstances

1 - Rare N N L L L

E = EXTREME RISK Immediate action

required

H = HIGH RISK High priority action

required

M = MODERATE RISK Develop procedures to

manage risks

L = LOW RISK Risk monitoring

required L1 Check failure cause L2 Contingency plans

N = NEGLIGIBLE RISK

No action required

Given the scheme has only been supplying to the dual pipe scheme for about 5 years, the “Likelihood” bands were also applied to a 5 year period as a sensible means of assessment of risk of harm to public health or the environment for the purposes of this audit.

This qualitative risk assessment methodology is consistent with Western Waters matrix used in its HRMP. The ERMP was noted as not having a risk matrix, instead relying on different approaches used in the various land



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capability assessments for Eynesbury and Toolern Precinct. The auditor will later in this report provide comment on the risk assessment methods used in these LCA’s.

The risk assessment was then used to assign an appropriate level risk to potential non-conformances with the HEMP or EPA dual pipe guidelines.

3.4.2 Risk Assessment Outcomes The outcomes of the compliance assessments including any non-conformances and significant environmental impacts identified were subject to the qualitative risk assessment, consistent with the existing Western Water risk identification and management framework as endorsed by EPA and DHS for the Melton South Class A Scheme.

The risk assessment enabled the auditor to prioritise any non-conformances and associated potential risks, and any subsequent recommendations for corrective action or improvement opportunity. Risk rankings were re-evaluated if mitigating measures were recommended by the Auditor to be implemented by WW.

3.5 Reporting This report was prepared in compliance with EPA Victoria’s Auditor Guidelines listed in section 2.3.

The Chapters to follow provide (based on review of information and data for the 2012-13 financial year):

• summary description and performance of the Melton South Class A Recycled Water Scheme • findings of the Compliance Assessment and summary of any non-conformances • Risk Assessment to evaluate non-conformances in regard to risk of harm to the environment • Conclusions and Recommendations to address non-conformances, and/or system improvements.



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4 Melton South Class A Recycled Water Scheme - Overview of Performance

4.1 Location Melton RWP including the Class A treatment facilities is located on Western Water’s Surbiton Park property (692 Ha) at Mount Cottrell on the east side of the Werribee River as shown in Figure 1-1. The Class A treatment plant and storage tank compound occupies an areas of about 1 Ha, west of the main Class C treatment plant works.

4.2 Land Uses

4.2.1 Melton RWP Melton recycled water treatment plant is zoned PUZ1 (Public Use Zone - Service And Utility) within Melton Shire. Site is surrounded by the following land uses:

• North and West: GWZ (Green Wedge Zone), rural residential to the north, dryland rural to the west

• South: RCZ (Rural Conservation Zone), dryland rural lands

• East: GWZ and SUZ1 (Special Use Zone – Schedule 1), dryland rural properties

4.2.2 Class A Recycled Water Supply areas Eynesbury Township:

• Current extent of the township is within Melton Shire. Future township growth to the south will extend into City of Wyndham.

• The township is zoned MUZ (Mixed Use Zone), contains occupied residential estates, public open spaces, Eynesbury golf course and clubhouse at the historic Eynesbury Homestead.

• The Green Wedge Zone (GWZ) and Grey Box Forest Rural Conservation Zone (RCZ) and native bushland reserve borders the town to the north.

• Dryland rural land (zoned GWZ and RCZ) borders the west and south boundaries of the township

• Dryland rural lands and the Werribee River escarpment borders the township boundary to the east

Waterford Park, Atherstone and Toolern Waters Developments (Melton Shire):

• These developments are within the Urban Growth Zone (UGZ3), and contain the initial stages of occupied residential development, display village and public open spaces. Note: Toolern Waters development did not have any residential or public open spaces connected to recycled water at time of this audit. Some water however may have been used for construction purposes

• North, South and East: Urban Growth Zone (UGZ3), currently undeveloped

• West of Waterford Park is Melton Reservoir, zoned PUZ1 (Public Use).

Tabcorp Park - Melton Harness Racing Track (Melton Shire)

• This non-residential irrigation customer site is within a Special Use Zone (SUZ1)



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• North: Western Freeway (Road Zone - RDZ1) and Industrial (IN1Z)

• West, East and South: Urban Growth Zone (UGZ3).

4.3 Local Surface Waters

4.3.1 Werribee River Catchment The Melton RWP and Class A recycled water scheme supply area is located within the basaltic plains of the lower Werribee River catchment. Melton Reservoir is adjacent to the west of the Waterford and Toolern Waters developments. Toolern Creek (an ephemeral waterway) also runs through the supply area and would ultimately receive urban drainage (via constructed wetlands) from the Waterford and Atherstone developments, as shown in Figure 1-1.

From the Class A supply area, Werribee River flows south through rural drylands, then into the urban areas of Werribee, then to the west of the Werribee Irrigation District, and ultimately to Port Phillip Bay approximately 25km from the Melton RWP. The flow regime and water quality of Werribee River is impacted by urban and rural land-uses, as well as Melton Reservoir and the regulated stream flows for SRW supply to the Werribee and Bacchus March Irrigation Districts.

Melbourne Water monitors the quality of Werribee River at Cobbledicks Ford Rd, Mount Cottrell about 2-3km downstream of Eynesbury township. Published data for this monitoring site on the “Cleaner Yarra and Bay webpage” (http://www.cleaneryarrabay.vic.gov.au/report-card/werribee/wewer1337) indicates that the river at this location is of fair to poor water quality in terms of nutrients, turbidity and heavy metals based on the website’s water quality index for comparison with relevant environmental quality objectives in State environment protection policy (SEPP Waters of Victoria). SEPP (Waters of Victoria) regards this segment of the Werribee River (“Cleared Hills and Coastal Plains”) to have ecosystem beneficial uses that are “Slightly to moderately modified”.

Note that the Melton RWP and Class A scheme does not discharge recycled water to Werribee River or its tributaries. However, emergency discharges to the river can occur during very wet periods subject to an emergency discharge approval issued by EPA. There is potential for some runoff to occur from Class A recycled water irrigation areas (eg. golf course, public open space and residential) to the urban stormwater systems.

Current water quality conditions in this part of the Werribee River catchment are consistent with the wide range of flow and catchment land use modifications, point and diffuse pollution source influences.

4.3.2 Constructed waterways within Class A Supply Region – Urban Developed Areas All urban areas within the Class A recycled water supply area (Eynesbury, Waterford, Atherstone and Toolern Waters) have incorporated water sensitive urban design (WSUD) features to attenuate possible nutrient loads from unplanned leakage/spills of recycled water and potential irrigation runoff. These WSUD features were designed in response to original land capability assessments for Eynesbury (Coomes Consulting 2005) and the Environmental Risk Assessment for the Melton South/Toolern Precinct (Atura 2011), and subsequently endorsed by EPA as part of its approval of the Class A recycled water scheme.

Western Water’s Water Plan 2013-18 outlines a preliminary business case for the Toolern Stormwater Harvesting project. This project aims to ultimately collect an average of 2780 ML/Yr from the Toolern Precinct’s urban wetlands and divert these flows from Toolern and Kororoit Ck catchments to Melton Reservoir (or other new regional water supply networks when available). Stage 1 of this project (Stormwater harvesting basin in Toolern) commenced in 2013, and will be progressively established as the precinct further develops.



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4.4 Land Capability and Climate Review

4.4.1 Topography The land in the Melton Class A supply area is generally flat to undulating basaltic plains. Local drainage is to Werribee River, Toolern Ck and various unnamed ephemeral drains and depressions.

4.4.2 Geology and Soils The geology of the area is dominated by the basalt plains of the Quaternary Newer Volcanics (Atura 2011 LCA).

Soils range widely across the supply area, but in Eynesbury and other residential developments the soil profile is typically described as loams overlying medium to heavy red brown clays (gradational soils). Shallow weathered basalt rock (floaters) is common in many areas. Sandy/loam topsoils have been imported to some areas of the new residential developments to improve surface conditions such as on the golf course, public open spaces, and residential lawns and gardens.

4.4.3 Groundwater The “Melbourne Groundwater Map” (refer to section 2.1.3) indicates that the surface aquifer across the supply area is expected to be at least 10-20m below surface.

The surface aquifer in the region containing the Melton RWP and Eynesbury Township is predominantly brackish (salinity >3500 mg/L or Segment C), which is not considered suitable for irrigation but is potentially suitable for livestock watering and industrial uses.

The surface aquifer may be fresher (1000 – 3500 mg/l, or Segment B) in the Melton South area around Melton Reservoir including the Toolern Precinct containing the Waterford, Atherstone and Toolern Waters developments as well as Tabcorp Park. This groundwater has additional potential beneficial uses including irrigation uses.

The transition to Segment C groundwater appears to occur south of where Toolern Creek meets Werribee River (ie. south of Melton Reservoir and Parwan -Exford Rd and Greigs Rd).

4.4.4 Rainfall and Evaporation Rainfall and evaporation from Bureau of Meteorology data is summarised in Table 4-1 and Table 4-2 respectively.

Table 4-1 Rainfall (mm) – Melton Reservoir (Bureau of Meteorology Station No. 87040)

Rainfall Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

Mean 37 41 31 38 38 34 35 41 45 53 50 43 488

2012 5 55 39 24 91 76 42 61 41 27 45 22 527

2013 7 94 34 14 22 85 42 36 66 53 54 28 535

Table 4-2 Evaporation (mm) – Mean of Melton & Merrimu Reservoir (stations 87040 and 87161) 1

Evaporation Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

Mean 1 183 151 124 78 51 37 42 61 81 111 133 165 1221

Note to Table 4-2: 1. Evaporation averages from 1990 up to end of 2010 based on averages of data from Melton Reservoir (1972 – 1999) and Merrimu Reservoir (1988 – 2014) weather stations.



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4.4.5 Plant water irrigation (evapotranspiration) requirement Based on Table 4-1 and Table 4-2 and EPA Victoria’s water budget calculation method, the annual turf grass water requirement (i.e. irrigation demand) would typically be 4.6 Ml/Ha/Yr in an average year. For the 2012 - 2013 financial year, the annual turf irrigation demand was about 5 ML/Ha/Yr (note drier than average summer rainfall). Refer to the water budget calculations provided in Appendix D to this report. These annual irrigation demand estimate is used later in this audit report to assess recycled water usage over the 2012-13 audit period by Eynesbury and Melton South Class A recycled water irrigation customers.

4.5 Melton (Surbiton Park) RWP – Treatment Processes

4.5.1 EPA Amalgamated Licence 74268 Melton Class C and A RWP wastewater treatment facilities including onsite Class C storage dams and recycled water irrigation operations are subject to amalgamated EPA licence 74268, which was issued 1 May 2008 and last amended 3 December 2013. The Melton RWP is identified on the licence as “Premises reference number” 70316. The premises plan attached to the licence is shown in Figure 4-1.

Figure 4-1 Melton RWP Site Plan (source: EPA Licence 74268)

The Class C and A treatment plant areas are located in the north-west part of the premises. The layout and footprint of the Class C and A treatment facilities is shown in Figure 4-2.



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Figure 4-2 Melton RWP Class C and Class A Treatment Plant areas (source: EPA Licence 74268)

4.5.2 Sewerage Catchment The Melton RWP treats sewage from Melton, Melton South, Toolern Precinct, Eynesbury, Rockbank and surrounding urban areas.

During the 2012-13 period the Melton RWP treated 3641 ML of raw wastewater, or an average of about 10ML/day.

The wastewater treated is predominantly domestic origin (around 50,000 population), but also contains a minor proportion of industrial and commercial trade waste. The main trade waste sources in the Melton sewerage catchment are ABMT Textiles plant and Saizeriya Australia (ready made food products). The main commercial customers are food service and motor vehicle service and repair industries.

Western Water reported in its 2012-13 Annual Report that its main Melton trade waste customer ABMT, has achieved 20% reduction in water usage per kilogram of product since 2009/10. ABMT has largely achieved this by recycling its trade waste via an onsite reverse osmosis plant.

In Western Water’s 2013-18 Water Plan, it proposes to upgrade to the Melton RWP to cater for increased wastewater flows arising from growth in the region, and also to increase capacity of recycled water supply to the region. In 2015/16 the Class A plant is proposed to be upgraded from 5 ML/day to 7.5 ML/day capacity to meet forecast demands. This is to be achieved through the modular addition of UV filtration and MF membranes.



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4.5.3 Class C Treatment Process An overview of Melton RWP treatment processes is shown schematically in Figure 4-3. The Class C treatment plant (STP) treats raw municipal sewage from the Melton sewerage catchment, and in turn provides feed water for the Class A treatment plant.

Figure 4-3 Melton RWP Class C Treatment Process Flow Diagram (source: Western Water HRMP 2012)

The process flow diagram for the STP is shown in Figure 4-4 (source: HRMP 2012). The sewage treatment process includes an influent pump station, inlet screening, primary sedimentation, biological treatment utilising aeration tanks (activated sludge process), secondary sedimentation, and maturation in storage lagoons.

The STP processes are designed to reduce organic matter, suspended solids, ammonia, total nitrogen, phosphorus and pathogens to levels suitable for discharge to land for Class C reuse schemes onsite and offsite, and also as feed water for the Class A plant.

The EPA licence does not specify any wastewater discharge limits for the Melton RWP, given all of the Class C and A recycled water is discharged to land in accordance with EPA guidelines. EPA’s Reclaimed Water Guidelines (Publication 464.2) specifies Class C recycled water quality objectives, to which WW aim’s to comply.

Performance data for 2012 – 2013 for effluent from the Class C plant are given in Table 4-3. The Class C plant complied with relevant EPA criteria during the reporting period. This data is consistent with that reported for the Class C plant in Western Water’s Recycled Water Report 2012/13. There were no Class C feed water quality issues that impacted on Class A recycled water treatment or compliance with Class A supply water quality objectives.

Western Water Class A Recycled Water Scheme – Overview

EynesburyDomestic & CommercialWastewaterReticulation

EynesburyDomestic & CommercialWastewaterReticulation

Melton ClassC RWP

(See separate flowdiagram)

Melton ClassC RWP


5 ML Tank Class A Storage

5 ML Tank Class A Storage

Public Open Space Irrigation

Public Open Space IrrigationFire HydrantsFire HydrantsHousehold UseHousehold Use

Pump Station &Rising Main

Pump Station &Rising Main

Class A ReticulationClass A Reticulation

Domestic Septic Effluent

Tanker Deliveries

Domestic Septic Effluent

Tanker Deliveries

Key

StorageStep

Transport Step

Continuous Process

Intermittent Process

Operational Step

Non-residential Customers

Melton,Toolern, &Rockbank,

Domestic, Commercial& Industrial

Wastewater

Melton,Toolern, &Rockbank,

Domestic, Commercial& Industrial

Wastewater

Pump StationPump Station

Trunk Pipelinesto Class A Scheme


DevelopmentHeader Tank

Storage

DevelopmentHeader Tank

Storage

Melton ClassA RWP


Melton ClassA RWP


Melton RWPOn-site usageMelton RWPOn-site usage

Air gap, tank & small pump; uses are landscape watering, process uses and amenity

Class AStandpipe

Class AStandpipe

Industrial &

CommercialUses

Industrial &

CommercialUses

Residential Customers

Potable BackupPotable Backup

V7.0 20-2-12



24

Figure 4-4 Melton RWP Class C Treatment Process Flow Diagram (HRMP)

Western Water Class A Recycled Water Scheme – Class C RWP

Screens50 mm3 mm

Screens50 mm3 mm

StorageLagoon No. 2

(13 days)

StorageLagoon No. 2

(13 days)

PrimarySedimentation

(mechanical)

PrimarySedimentation

(mechanical)

Aeration Tanks (open)

Aeration Tanks (open)

Secondary Sedimentation(mechanical)

Secondary Sedimentation(mechanical)

Rotary ScreenThickener

Rotary ScreenThickener

DigesterDigester

Biosolids

Domestic, commercial &

industrial sewage, tanker septage

Domestic, commercial &

industrial sewage, tanker septage

Melton ClassA RWP


Melton ClassA RWP


Biosolids

StorageLagoon No.1

(1 day)

StorageLagoon No.1

(1 day)

Process water

Key

StorageStep

Transport Step

Continuous Process


Operational Step

Class A Customers (See separate flow

diagram)

Class A Customers (See separate flow

diagram)

150 L/sFlow Control Valve

P.S.TPit

P.S.TPit

EmergencyRelief

Structure3.6 ML

EmergencyRelief

Structure3.6 ML

Non-conforming recycled water and

backwash water

Filtrate

Irrigationdrainage fromfarm sections

A, B, C, & D

Irrigationdrainage fromfarm sections

A, B, C, & D

Leachate

Optional Process

Irrigationdrainage from

FP2

Irrigationdrainage from

FP2

V7.0 20-2-12

Table 4-3 Melton RWP Class C Plant Performance (2013-14)

Waste discharge parameter

Unit 2012-13 Performance Class C Objectives (EPA Pub. No. 464.2)

Annual Medians

Maximum Annual median

Microbiological Notification levels

Biochemical oxygen demand (BOD)

mg/l 3 6 20 NA

Suspended Solids mg/l 4 10 30 NA Total Phosphorus mg/l 9.0 9.8 NS NA Total Nitrogen mg/l 13 19 NS NA E.Coli orgs/100ml 575 2600 1000 >4000 pH 7.5 8.1 6 – 9 NA Note to above Table: “NS” – not specified. “NA” not applicable

In addition to the Class C water quality monitoring program, the HRMP (2012) contains a number of key operational monitoring activities to address moderate risks (in the HEMP risk register) for ensuring Class C water quality. These include: monitoring sewage inflows and emergency relief structure for hydraulic overloading, sludge levels in activated sludge plant, blue-green inspection/testing, fencing to exclude livestock from lagoons used for Class C feed to the Class A plant, and pesticide monitoring (from use on Surbiton Park farmlands).



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4.5.4 Class A Treatment Process The Class A plant employs a microfiltration followed by UV and chloramination disinfection processes. The plant has a current operating capacity of up to 5Ml/day, which is also the basis for the DHS and EPA approved RWQMP (Rev. 7, October 2009). The process flow diagram for the Class A plant is illustrated in Figure 4-5.

Figure 4-5 Melton RWP Class A Treatment Process Flow Diagram (HRMP 2012)

The key unit treatment steps (multiple barriers for pathogen removal) and Critical Control Points (CCP) as identified in the RWQMP are summarised as follows:

4.5.4.1 Pre-conditioning - Ferric chloride dosing (Coagulation and Flocculation) and micro-straining The Class C effluent from the STP is dosed with ferric chloride, corrected for pH (using caustic soda or HCl as required), then transferred to the Class A feedwater holding tank (containing a fixed speed slow mixer) and membrane feed tank, then passing through microstrainers (with 400-micron screen) before pumping to the MF unit. The feed water can also be subject to pre-chloramination (using hypochlorite).

There are three CCPs associated with the Coagulation step as follows:

1. CCP1a – Coagulant (Ferric Chloride) Dosage Rate (continuously monitored). Critical limit <15 mg/l. 2. CCP1b – Feed Water Tank Mixer (Fixed Speed) is turned on. Critical limit = “mixer off” 3. CCP1c – Minimum floc size. Critical limit >2-3 in Feed Water Tank (determined by onsite lab tests).

Western Water Class A Recycled Water Scheme – Class A RWP

CoagulantDosing &

pH Correction

CoagulantDosing &

pH Correction

Melton Class C RWP

(See separate

flowdiagram)

Melton Class C RWP

(See separate

flowdiagram)

UV DisinfectionFirst Bank

UV DisinfectionFirst Bank

Class A Customers(See separate flow

diagram)

Class A Customers(See separate flow

diagram)

ChloraminationChloramination

Balancing Tank5 ML

Balancing Tank5 MLPumpPump

Back-wash with

ChemicalDosing

Back-wash with

ChemicalDosing

To primary sedimentation

UV DisinfectionSecond Bank

UV DisinfectionSecond Bank

Key

StorageStep

Transport Step

Continuous Process


Operational Step



Pre-Filter Screen

Pre-Filter Screen

Microfilter(0.1 µm)

Microfilter(0.1 µm)

Non-conforming recycled water and

backwash water

Ammonia dosing

Ammonia dosing

Class AStandpipe

Class AStandpipe

Air gap, tank & small pump; uses are landscape watering, process uses and amenity

Potable BackupPotable Backup

Melton RWP

On-site usage

Melton RWP

On-site usage

V7.0 20-2-12



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4.5.4.2 Microfiltration The pre-conditioned water is then pumped through a micro-filtration (MF) membrane unit rated to remove fine suspended solids and particulate matter greater than 0.1 micron in size, including viruses and micro-organisms. There a two PALL Microza microfiltration racks operating in parallel, using hollow fibre technology operating in outside-in mode when in filtration phase. The system has automatic backwashing, cleaning-in-place, membrane integrity testing and monitoring processes – managed by Western Water’s SCADA system.

There are two CCPs associated with the Microfiltration step as follows:

1. CCP2a – Turbidity (continuously monitored). Quality control trigger initiates a DIT at >0.10 NTU (for >15min). Plant shut down Critical limit >0.15 NTU (for > 15 minutes),

2. CCP2b – Daily DIT undertaken. Operator warning for PDR > 0.2kPa.min. Critical limit: PDR > 0.6kPa/min.

4.5.4.3 Ultraviolet (UV) Disinfection The MF filtered water then passes through two UV units operating in series unit where it is disinfected with UV light at a UVI dose of at least 75mJ/cm2.

There are three CCPs associated with the UV disinfection step as follows:

1. CCP3a – UVI (continuously monitored). Individual lamps also alarmed and monitored. Operator warning at UVI <75. Critical limit UVI <73.

2. CCP3b – UVT of filtered water (continuously monitored). Alert level UVT<52%. Critical limit UVT<48%. 3. CCP3c – Filtrate flow (continuously monitored). Critical limit >66.5 l/s (for >5min) to Class A Tank.

Equivalent to > 69 l/sec exiting the MF racks (flows diverted to Membrane RF tanks).

4.5.4.4 Chloramination After the UV unit, hypochlorite solution is dosed for chloramination prior to transfer to the Class A storage tank.

There are two CCPs associated with the chloramination step as follows:

1. CCP4a – Total Chlorine level at tank outlet (continuously monitored). Critical limits calculated according to algorithm in Western Water standard operating procedure (SPRWP-SOP-506). Set points are MF feed temperature dependent, including at ranges >15oC and between 12-15oC.

2. CCP4b – MF Feed temperature (continuously monitored). Plant shuts down at <12oC. Plant operator can restart at lower flow rate (eg. 50% capacity), and keep Cl dosage rates higher for 5 days to ensure conservative approach.

4.5.4.5 Quality control Point QCP1. The RQWMP also specifies a QCP for microbiological monitoring of recycled water quality downstream of the Class A Storage Tank. Monitoring requirements (as approved by DHS) are:

Microbiological Indicator Testing Frequency Standards • E.Coli • weekly • < 1 org/100 mL • FRNA coliphage • fortnightly • < 1 pfu/100mL • Cryptosporidium • quarterly • < 1 oocyst/10 L

Western Water carries out monitoring for a wide range of other parameters as listed in the Recycled Water Quality Monitoring Table in Appendix 3 of the HEMP (May 2012, Version 2.0).



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The point of application of the critical control points (CCP) and monitoring QCP are illustrated in Figure 4-6.

Figure 4-6 Melton RWP Class A Plant CCPs and QCP (RWQMP 2009)

4.5.5 Class A Treatment Plant Performance – 2012-13 The required pathogen reduction rates or log reduction values (LRV) across the combined microfiltration, UV and Chloramination disinfection steps have been validated by WW and subsequently endorsed by DHV and EPA as meeting the microbiological criteria and LRV from raw sewage to recycled water supplied to customer specified in EPA’s Dual Pipe guidelines (publication 1015) as follows:

Pathogen Group Median Lower (Critical) Limit • Bacteria < 10 E.coli / 100 mL • Viruses 7-log reduction 6-log reduction • Protozoa 6-log reduction 5-log reduction

The current Class A treatment train achieves these LRV’s through the original design as specified in the October 2009 RWQMP and as approved by DHS and EPA. The original design and validation was a conservative approach, given that Western Water has not claimed any pathogen reductions through its Class C treatment plant or lagoons.

There have not been any significant design changes to the Class A treatment plant since it commenced operation. Minor changes to process controls have been approved by DHV eg. relocation of temperature sensor closer to chlorine dosing point (May 2013).

Western Water took handover of the operation of the Class A treatment plant from Pentair (Water infrastructure Group) in March 2013. Western Water is proposing some key enhancements to the Class A Plant in the near future including new UV and Cl disinfection systems, partly in response to the February 2013 release of the DHV “Guidelines for validating treatment processes for pathogen reduction (supporting Class A recycled water schemes in Victoria)”. Western Water is in the process of reviewing the 2009 RWQMP in view of planned upgrades.



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4.5.5.1 WW Annual Reported Results Performance data for 2012 – 2013 for Class A recycled water as sampled at the Class A Storage tank onsite at Melton RW is given in Table 4-4. This data is consistent with that reported for the Class A plant in Western Water’s Recycled Water Report 2012/13. The Class A plant complied with relevant EPA and DHS criteria during the reporting period.

Table 4-4 Class A Recycled Water Quality Monitoring Data (July 2012 to June 2013)

Parameter Unit Class A Water Quality Data 2012 – 13 EPA Guideline

Class A Objectives DHS Guideline

Objectives Median Min Max Turbidity NTU 0.2 0.1 0.9 <5 pH 7.5 6.9 8.3 6 – 9 E.Coli MPN/100ml 0 0 0 <10 <1 1 FRNA bacteriophage Pfu/100ml <1 No detection Cryptosporidium oocysts/100ml No detection Total Chlorine mg/l 2.8 0.5 7.4 Free Chlorine mg/l 0.2 0.0

1 3.6

EC µS/cm 770 640 1100 NS TDS mg/l 400 380 430 NS Ammonia mg/l 2.1 0.7 6.4 NS Total Nitrogen mg/l 16.6 9.5 23.6 NS Total Phosphorus mg/l 6.2 4.5 9.8 NS

Notes to above Table: 1. E.coli, FRNA and Cryptosporidium objectives are specified in DHS “Guidelines for validating treatment processes for pathogen reduction – Supporting Class A recycled water schemes in Victoria” (February 2013).

4.5.5.2 RWP SCADA Data Review The Class A Plant is controlled by SCADA, accessible from both Melton RWP depot and also remotely including from Sunbury offices.

Whilst at the site inspections, the Auditor viewed the Melton RWP SCADA system in the company of the Class A Plant senior coordinator treatment teams and the Melton RWP team leader. The plant was not producing recycled water at the time of inspection. The onsite review involved viewing the online SCADA displays on computers connected to the system. The auditor verified all set points for CCPs were consistent with the HEMP and RWQMP. At the same time, the auditor also sighted selected samples of recorded SCADA data for all CCPs for previous Class A water generated during 2012-13 (and also early 2014).

The auditor originally proposed to obtain SCADA records for comparison with Class A monitoring data (Table 4-3 and Table 4-4). However, the SCADA does not easily display data for 2012-13 discharge periods specifically corresponding to Class A supply event times. Given the Auditor’s verification of CCP set points, no shut down events corresponding to Class A supply during 2012-13, and also that Table 4-4 data complies with Class A criteria, the Auditor decided that additional SCADA data review would not be necessary for this audit.

In summary, the Auditor is satisfied that during 2012-13 Melton RWP consistently produced Class A compliant recycled water, when actual supply to Eynesbury and Melton South (Toolern Precinct) customers actually took place. Only a relatively small volume (306 Ml) of Class A recycled water was produced in 2012-13. Given the stop start nature of the plant, the SCADA often indicated variability and spikes (eg. for turbidity, Chlorine levels) during startup modes, membrane cleaning and DIT cycles. At these times the supply to the Class A tank automatically shuts down and the plant operates in recycle mode (ie. diverting product water back to the Class C plant), ensuring potentially non-compliant recycled water is not supplied to customers.



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4.5.6 Class A Recycled Water Quality Incidents and Emergencies There were no Class A water quality supply breaches or incidents during the 2012-13 reporting period. There was one temporary recycled water supply outage affecting Eynesbury in February 2013, but this was not due to water quality (due to a valve being used).

There were also no Class A recycled water storage or distribution system incidents or emergencies (leaks or bursts) reported during the 2012-13 period.

4.6 Class A Customer Performance

4.6.1 Number of Class A Customers Supplied Western Water’s Corporate Report 2013 states that “Residential recycled water customer numbers now total close to 800”. However, according to the Recycled Water Report 2012/13, the number of Class A customers within Eynesbury and Melton South were reported as 612 in number by end of the reporting period. Previous annual recycled water reports indicate there were 491 Class A customers at end of 2011/12, and 254 at end of 2010/11.

At the commencement of the audit (December 2013), there were about 626 Class A residential customers supplied at Eynesbury, 127 at Waterford and 51 in the Atherstone development. The Melton South/Toolern precinct growth plans are forecasting about 20,000 new residential properties by year 2030.

The Class A customer billing registers supplied by Western Water for this audit, indicate that there were around 749 residential customers by end of 2012/13 distributed over the three new urban developments (see Table 4-6 later in this report). Therefore, it appears that Western Water’s Annual Recycled Water Report for 2012/13 may have under-reported the number of Class A customers connected across the whole of the Eynesbury and Toolern Precinct. It is possible that only the number of Eynesbury customers were reported in the 2012/13 annual recycled water report, with Waterford and Atherstone customers inadvertently omitted.

System improvement: SI-1: Western Water should improve internal annual review and reporting processes to ensure data reported in

annual reports is validated against relevant databases. For instance, Class A residential customers supplied by Western Water may currently be under-reported in Annual Recycled Water reports.

4.6.2 Recycled Water Bulk Supply Volumes Western Water’s Recycled Water Report 2012/13 indicates 306 ML of Class A recycled water was produced, with 100% of this reused by supply to Eynesbury, Melton South and Toolern Precinct for:

• residential dual pipe uses (garden watering and toilet flushing), • non-residential customer uses (open space watering, golf course, fire fighting, licensed water carters), and

A proportion of Class A water was also used/consumed for Western Water’s internal operational uses including process recycling through the RWP, tank maintenance/scouring, commissioning of the new Green Hill Class A Tank, other standpipe uses, etc. These uses are discussed later in this report.

A total of 3641 ML of Class C recycled water was generated at the Melton RWP, about 8.4% of which was supplied as feed water to the Class A plant. The balance of Class C water which was supplied to a range of non-residential irrigation customers, which are separate from Class A customers and not subject to this audit.



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4.6.3 Reconciliation of Bulk Supply and System Losses Western Water provided broad analyses of Class A recycled water bulk supply volumes and potential system losses from bulk meters and customer billing data for the 12 month period start May 2012 to end April 2013 (ie. close to the 2012-13 period considered in this Audit). This is provided in Table 4-5. This analyses was undertaken in response to the auditor’s query about quantifying Class A system losses.

Table 4-5 Class A Recycled Water Bulk Supply and Accounted Usage (1 May 2012 to 30 April 2013)

Accounted Usage (kL) Billing Periods Total for

Cycles 1 -3 Cycle 1

May-Aug Cycle 2

Sep-Dec Cycle 3 Jan-Apr

Class A Eynesbury Residential 230 22,120 28,520 50,870 Class A Eynesbury Non-Residential 4,296 60,829 51,014 116,139 Class A Melton Non-Residential - TabCorp Park) 3,521 7,415 7,000 17,936 Class A Melton Sth Residential 43 718 3,411 4,172 Class A Melton Sth Non-Residential 1 1 Class A Dist 91 (Carters) 2,801 9,406 12,233 24,440 Class A internal Use 2,920 4,905 7,690 15,515 Tank Maintenance (scour) – discharged to sewer 8,000 8,000 Commission Green Hill Tank 5,500 5,500 Other – Internal Standpipe Usage 256 256 Customer meter inaccuracy (2% of usage) 276 2,108 2,197 4,581 Theft (0.1% of production) 28 106 154 288 Total Accounted Usage 14,116 107,607 125,975 247,699 Class A production 28,019 106,368 153,725 288,112 Class A Losses (production minus usage) 13,903 -1,239 27,750 40,413 % of Class A Losses (losses divided by usage) 50% -1% 18% 14%

Western Water advised that for Table 4-5, Class A production was aligned with customer billing data as closely as possible, however there are some meter lag issues when viewed in individual cycles ie. there are issues with the cycle of billing not aligning with the financial year (eg. as for plant data) and un-billed construction activities.

Overall losses across the 12 month period assessed (three billing cycles) were estimated at 14% of production. Western Water considers these discrepancies and potential losses to be quite high for a new reticulated system, and beyond what would be expected for a distribution system of this size. However, Western Water has suggested to the auditor that these are not actual losses and considers it may need to look at improved water accounting procedures to be able to more closely match bulk production data with customer data.

Western Water also advised the auditor that monthly review and aggregation of meter reading data is undertaking by the Renewable Resources team for internal and external reporting (eg. balance report card to the Executive). However, the above analysis to match Class A production with customer billing periods (Table 4-5) has not been done before in previous years.

System improvement: SI-2: Western Water should improve internal recycled water metering and accounting procedures to more

closely reconcile Class A production (bulk meter) data with customer usage (metered) data to ensure potential Class A system losses can be tracked and more accurately reported (internally and externally). Reconciliation of Class A water supply and usage will become more important as Class A demand increases.



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4.6.4 Residential Customer Usage Table 4-6 summarises the Class A residential customer numbers and metered usage for 2012-13, from recycled water customer billing data (spreadsheet records) supplied by Western Water.

Table 4-6 Class A Residential Customer Recycled Water Usage (July 2012 - June 2013)

Supply Area Number of Customers 1

Total Volume (ML/yr)

Average use per House (kL/Yr)

Predicted Usage per House (kL/yr) 2

Sites exceeding predicted usage (%)

Eynesbury 612 49.9 81.6

75

~45% Waterford 106 3.6 34.1 ~8% Atherstone 31 0.2 5.0 0 Totals 749 53.7 71.2

Notes to above table:

1. Number of customers house connections as at end of 2012-13 financial year (source Western Water customer register). 2. Auditor’s predicted recycled water usage over a full year for an established residence, based on sum of the following:

• Average house internal toilet usage of the order 18.6 kL/Yr: 5 l/flush, 3 flushes per day per person and average 3.4 persons per house (source: ATURA 2011). Auditor has assumed that washing machine recycled water usage during 2012-13 (in trial stages only) was low in comparison to toilet flushing.

• Average external usage of the order 56.6 kL/Yr: for average sized residential irrigated garden area 112m2 (ATURA 2011), and 2012-13 grass water demand as estimated in section 4.4.5 of this report (based on EPA water budget calculation method, see Appendix D).

As expected, lower overall recycled water usage is associated with newer the residential developments. Many customers were reported with zero usage (23 customers in Eynesbury, 12 in Waterford and 16 in Atherstone), likely due to only just being completed and not yet occupied despite being officially registered by Western Water as connected. There are many more that have very low levels of usage due to only being connected or occupied for a short time (less than the 12 month reporting period). In additional many properties made not have had all meter readings from field sheets yet recorded in Western Water’s billings database. It is the experience of this Auditor that these types of customer usage data limitations are common for new recycled water schemes.

At the other end of the scale, the Auditor has identified high levels of usage by many residential customers as recorded in Western Water’s billing data for the 2012/13 period. The auditor found about 44% of the Eynesbury residential customers and about 8% of the Waterford customers exceeded the predicted average household annual recycled water usage rate of 75 kL/Yr for combined toilet flushing and garden watering as indicated (and explained in the table notes) in Table 4-6.

In Eynesbury, there are a large number of customers greatly exceeding this nominal predicted usage – refer to Figure 4-7. There were 89 Eynesbury customers exceeding 150 kL/Yr, and 9 exceeding 300 kL/Yr usage for 2012-13. The highest recorded annual usage in Eynesbury was 1372 kL/Yr for a residence in Rushworth Avenue. The 2nd highest usage of 574 Kl/Yr was in Castlemaine Dve, and the 3rd highest of 408 kL/Yr was in Heathcote Drive.

In the Waterford development there are 9 customers exceeding the 75 kL/Yr auditor predicted usage trigger. The three highest recorded usage values for Waterford are all located in Avenmore Way (Melton South), with values of 656 Kl/Yr, 354 kL/Yr and 297 kL/Yr. Given these high usage values are all for adjacent houses in Waterford, a possible “common theme” is a data entry error (eg. decimal place in wrong position).

According to 2013-14 water use data, these apparent high use customers in Eynesbury and Waterford do not all continue to record high usage.



32

Figure 4-7 Eynesbury – Residential Customer Usage 2012-13

The data error entry theory is also a plausible reason for the high usage data at Eynesbury, given the significant proportion of high usage customers greatly exceeding the predicted combined usage for irrigation and toilet flushing given the expected occupancy rates and moderate to small garden sizes in these new estates.

Other than meter error and data entry error, there are other potential causes of high recorded usage (i.e. downstream of customer meters) such as:

• construction and pipe flushing and commissioning uses • illegal uses or connections (theft) from unsecured properties • uncontrolled flows from uncapped pipe ends; and • undetected leaks, bursts, break in customer pipes.

Note that none of these potential causes were verified in this audit, given no intrusive inspections or customer interviews were included in the commissioned audit scope.

Western Water’s HEMP and incorporated documents do not clearly identify a residential customer predicted usage trigger number for making metered usage comparisons. In this report, the Auditor has provided “a potential method” for establishing an annual trigger number for residential customers, based on information provided in the ATURA 2011 Environmental Risk Assessment, and use of EPA water balance calculations.

System improvements: SI-3: Western Water should consider establishing residential customer usage triggers and appropriate response

actions based on good science on internal household water usage and relevant EPA guidance (or other reputable methods) for calculating garden irrigation demands.

SI-4: There are a number of residential customers in Eynesbury and Waterford development that have very high recycled water usage recorded for 2012-13, which significantly exceeding that expected for typical garden sizes and occupancy rates in these new estates. Western Water should review residential customer data to identify the reason(s) for this high usage (including possible meter error). Appropriate responses such as education of customers should be undertaken to address the high usage.

Maximum usage site 1372 kL/Yr exceeds scale shown



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4.6.5 Non-Residential Customer Usage There were 9 non-residential properties supplied with Class A recycled water during 2012/13 - see list in Table 4-7. Western Water has three non-residential customers to manage for day-to-day Customer Site Management Plan compliance:

1. The golf course and all public open spaces (POS) in Eynesbury are operated by McMahons under a maintenance contract with the respective property owners. McMahons maintains about 4-5 Ha of irrigated area on POS around Eynesbury, in addition to about 35Ha of golf course under irrigation.

2. POS (estimated by the auditor as about 0.5Ha at present) at the Waterford development is by the developer’s garden maintenance contractor.

3. HRV manages its own garden irrigation operations (around 1.8Ha). It has recently suspended track dust suppression due to problems with track stability when watered with recycled water (discussed further later in this report).

Table 4-7 Class A Residential Customer Recycled Water Usage (July 2012 - June 2013)

Customer Name Operator Property Address Uses kL/Yr Eynesbury Golf P/L

McMahons Eynesbury Rd Eynesbury 18 hole golf course (35 Ha) and Estate lawn (3.5Ha) irrigation, & homestead toilets

113,349

Eynesbury Golf P/L

McMahons Eynesbury Rd Eynesbury Discovery Centre Toilets and Gardens

340

Eynesbury Golf P/L

McMahons Golf Course Maintenance Depot Eynesbury Rd

Golf Course Depot Toilets 53

Eynesbury Development JV

McMahons Reserve 43/54 Lancefield Circuit Eynesbury

POS Irrigation (~50m diameter oval, 0.2Ha)

2,743

OC2 Plan 543210 McMahons 1-3 Benalla Avenue Eynesbury

POS Irrigation (~0.5Ha) 3,823

Melton City Council

McMahons Reserve 37 St Arnaud Rd Eynesbury

POS Irrigation (area not known, future sports precinct ovals under construction?)

1,516

Melton City Council

McMahons 479-481 Eynesbury Rd Eynesbury

Tennis and netball courts toilets and garden beds

135

Harness Racing Victoria

HRV 2-26 Ferris Rd Melton Gardens (1.8Ha), track watering 17,505

608 Property Group

Waterford Developer

Reserve 1/2 Castletown Blvd Waterford (Melton Sth)

POS Irrigation (~0.5 Ha) 990

Total non-residential usage (kL/Yr) 140,454

Water usage trends are also provided in Table 4-7, from Western Water’s customer billing data. Water use data is also provided in Customer Annual Compliance Statements (ACS) required to be submitted in July each year by the customer in accordance with the CSMP. Data contained in Western Water’s billing database is property based and is not always consistent with the ACS customer reports where submitted.

Key findings of the annual water usage by non-residential customers is summarised below:

• Eynesbury Golf Course: acceptable overall usage on golf course (3.2 ML/Ha/Yr over 35Ha under irrigation) and fairways (2.3 ML/Ha/Yr). However, high usage on tees (>15ML/Ha) and greens (>10ML/Ha) reported by McMahons in 2012-13 ACS



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• Eynesbury POS: usage appears to be very high and potentially exceeding the predicted average demand (5 ML/Ha/Yr as per Appendix D). McMahon’s ACS reports 22 ML/Yr usage on “Area 4 Estate Lawns” (3.5Ha), which is equivalent to about 6.3 ML/Ha/Yr. Water usage from WW’s billing data (Table 4-7) indicates individual Eynesbury reserves used 7.5 to 10ML/Ha/Yr, which is also higher than plant needs. High usage often occurs in the first year of recreational turf established, but most of these reserves have existed for more than 12 months. Possible other (non-irrigation) uses adding to usage should be investigated.

• HRV: high usage on track (~10ML/Yr over 1.8Ha) reported by HRV ACS). This could generate runoff into the onsite stormwater dam (overflow risk if not recycled). Acceptable irrigation area usage (~7ML/Yr over 1.8Ha). Toilet flushing reported as ~1ML/Yr.

• Waterford Castletown Boulevard reserve: acceptable usage (~2ML/Ha/Yr) during these initial establishment of this new reserve.

There were also 16 Class A water carters licensed by Western Water, supplied from the Class A Standpipe at Melton RWP. These customers used a total of 24.3 ML in 2012-13 for non-residential purposes (irrigation, construction, dust suppression, etc).

The CFA and MFESB can also utilise Class A recycled water for fire fighting and operational activities including training subject to its “Class A Recycled Water Management Plan” (Version 1, September 2007). No recycled water use for fire fighting purposes was reported by CFA/MFESB nor Western Water for the 2012-13 period. The Class A Recycled Water Management Plan requires reporting the when usage actually occurs.

System improvements: SI-5: Ensure all non-residential customers in Eynesbury and Toolern Precinct submit ACS by due dates, including

all required monitoring data. Ensure all of these ACS reports contain water usage data for individual sites (rather than an aggregation of sites) that correspond with the non-residential customer property addresses contained in the Western Water Billings database. This will enable improved comparisons to be made for future internal and external auditing of non-residential customer recycled water use.

SI-6: Verify and accurately map all Class A recycled water POS areas including roadside irrigation areas to ensure they comply with an up-to-date CSMP and are identifiable by property address in the customer register and billing’s database. The auditor was not able to identify all irrigated POS sites in Western Water’s water usage databases. This includes the roadside drip irrigation area on either side of Eynesbury Rd north of the Grey Box forest up to Exford Rd.

SI-7: There are a number of customers in Eynesbury and Waterford development that have very high recycled water usage recorded for 2012-13, which significantly exceeding that expected for recreational turf irrigation. Western Water should review non-residential customer data to identify the reason(s) for high annual usage (including possible meter error) on individual Eynesbury POS irrigation sites. Appropriate responses such as education of customers should be undertaken to address the high usage.

4.6.6 Nutrient Loads from Recycled Water – Non-Residential Customers Predicted nutrient loads based on nutrient levels in Class A recycled water (Table 4-4) and expected annual grass irrigation demand for 2012-13 (section 4.4.5 and Appendix D) are estimated in Table 4-8. Turf requirements for N and P as given in Table 8 of Western Water’s current ERMP (May 2012) are provided in the table. These turf nutrient requirements are consistent with the indicative nutrient uptake rates for typical grass species as described in EPA’s reclaimed water use guidelines (Publication No. 464.2, 2003).



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Table 4-8 Class A Recycled Water Irrigation Nutrient Loads – Non-Residential Customers

Nutrient Concentrations 2012-13 Turf Water Demand Nutrient Loads Total Nitrogen 16.6 mg/L 5 ML/Ha/Yr 83 kg N/Ha/Yr Total Phosphorus 6.2 mg/L 31 kg P/Ha/Yr Plant nutrient requirements from Table 8 of ERMP (May 2012) Total Nitrogen 171 kg N/Ha/Yr Total Phosphorus 30 kg P/Ha/Yr

If annual irrigation usage is up to 5 ML/Ha/Yr, Nitrogen loads in recycled water applied would represent about half the turf nutrient requirements, whilst phosphorus in recycled water would theoretically closely match turf P requirements. However, based on review of non—residential customer usage discussed earlier in this section, nutrient loads may have been higher on some sites (eg. Eynesbury POS reserves, golf course greens and tees), which suggests phosphorus loads might have exceeded typical annual turf nutrient requirements for 2012-13. Soils in the Eynesbury area are high in clay and have very high absorptive capacity ensuring minimal migration to surface waters of groundwater.

The high usage rates on some customer sites may pose some risk to soil condition and structure. Review of soil salinity/sodicity issues, risks and outcomes of soil monitoring programs on non-residential customer sites is provided in Appendix E.

4.6.7 Non-Residential Customer CSMP Compliance Review CSMP’s and Annual Compliance Statements (ACS) submitted for non-residential customer sites were reviewed and key sites inspected by the Audit team, where identified in the Western Water billings database.

Site inspections and customer interviews for Eynesbury Golf Course and Eynesbury POS site, as well as HRV at Melton South were carried out by the Auditor’s representative (Glen Marriott). The Auditor also inspected (on separate occasions) a selection of Eynesbury and Waterford POS areas, and the Golf Course.

Note that the operator for the Waterford POS reserve at 1/2 Castletown Boulevard (Melton South) was not contactable at time of audit. The auditor inspected this reserve and briefly discussed POS management with a Waterford display home salesperson.

A summary of the non-residential customer CSMP compliance review for 2012-13 is provided in Appendix E. The key findings and site-specific suggested system improvements are as follows:

System improvements: SI-8: Eynesbury Golf Course and POS: It appears that POS soil monitoring required b the CSMP is not being

undertaken. It also appears that the golf course water quality monitoring (also required by the CSMP) is also not being undertaken. Review and update the CSMP’s including soil and golf course water quality monitoring programs, and ACS reporting requirements.

SI-9: Harness Racing Victoria: It appears that soil monitoring, whilst being undertaken on two occasions since commencing use in 2009, it is not being undertaken annually and in accordance with the full suite specified in the CSMP. Review and update the CSMP including soil monitoring programs, and ACS reporting requirements. It is suggested to include inspections of the HRV runoff evaporation dam for recording potential overflow events to local waterways, and to sample the dam is overflow occurs.



36

SI-10: A research and development opportunity exists to further investigate the cause of HRV trotting track instability when watered with recycled water. Appropriate cost effective preventative remedial actions should be identified to ensure similar problems can be avoided in the future at HRV and other similar racing tracks. At present the reported loss of surface integrity effectively precludes the use of recycled water for dust suppression on trotting tracks at HRV therefore reducing Class A recycled water use.

SI-11: Review the ERMP and all CSMP’s to ensure close linkages and consistency between these documents in particular the trigger points and corrective actions specified in the ERMP.

Si-12: Consider adding to the ERMP the following recycled water usage performance objectives, trigger points and corrective actions - as a suggested new sub-section and trigger table in Chapter 4 of the ERMP:

(i) Water use soil monitoring trigger level of: 1.5 ML/Ha/Yr for annual soil monitoring requirement (otherwise every 3 years if trigger not exceeded).

(ii) Annual water use trigger level of: >30% of predicted annual irrigation requirements based on EPA water balance calculations (or the method underlying Table 3 of the ERMP) using actual rainfall and evaporation data and turf crop factors.

SI-13: Western Water should review all ACS soil and other monitoring data against ERMP triggers (subject to ERMP review) to determine if there are any required corrective actions.

4.6.8 Customer Incidents and non-compliances There were no incidents reported by Western Water at customer sites for the 2012/13 period. There were no incidents or non-compliances reported by non-residential customers in 2012-13 ACS reports submitted.

There have been no major leakages (eg. none reported to Western Water), but many minor leakages, particularly on nature strips, where access covers have been driven over in Eynesbury township. The strategic placement of bollards and signage, and education of local residents to protect these irrigated nature strips should be considered.

In addition, recycled water has ceased to be used on the HRV trotting track due to track surface stability and bogging problems. It is believed this may be due to sodicity or other chemicals in the recycled water reacting with the silty fines within the granitic sand surface or in underlying clay soils. HRV has not reported this as a non-compliance. It is noted that the last checklist item on the “Statement of Compliance” in Appendix 2 of the HRV CSMP states: “No Visual Land Degradation (eg. salting, plant growth damage)”, which is more specifically designed for irrigation areas rather than track watering. Despite this, this track stability problem due to recycled water should have been reported to Western Water in the ACS for the year it occurred.

System improvements: SI-14: The strategic placement of permanent bollards and warning signage for irrigated nature strips, and

education of local residents should be considered to protect sprinkler systems and other irrigation infrastructure on nature strips from vehicle damage.

SI-15: Review and customize the HRV Annual Summary and Compliance Statement forms contained in the CSMP to ensure any future track stability issues associated with recycled water usage are reported in the future. This applies if track watering is to recommence at HRV.



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5 Summary of Findings

5.1 General Findings Based on the operational data and information assessed over the period considered for this audit (1 July 2012 to 30 June 2013), and subject to the system improvements identified in this report: • The Melton South Class A Recycled Water Scheme is being operated and managed by Western Water

generally in accordance with the commitments made in the HEMP, Recycled Water Quality Management Plan (RWQMP) and other documents (Health Risk Management Plan, Environment Risk Management Plan) incorporated into the HEMP framework, and as currently endorsed by EPA and Department of Health.

• The Recycled Water Scheme is being operated generally in accordance with the objectives and suggested measures of EPA’s dual pipe guidelines.

• The audit did not identify any non-conformances with the HEMP, RWQMP or other incorporated documents. • The auditor did not identify any non-conformances with relevant environmental legislation or relevant SEPPs

(Waters of Victoria, Groundwaters of Victoria, Contamination of Land) • The Class A scheme does not pose any obvious risk of harm to the environment or public health.

The Auditor has suggested a number of “System Improvements” (SI) for consideration by Western Water, which are mainly administrative in nature including: • Suggested concurrent reviews the HEMP, RWQMP, HRMP, ERMP, • Reviews of customer site management plans, • Reviews of WW procedures and other key documentation, • Review of monitoring requirements for non-residential customers, • Review of customer engagement and staff training and awareness programs • Validation of bulk water and customer usage data for water accounting purposes (potential losses) and

reporting purposes • Review of internal auditing programs including for residential customer cross connection checks, and non-

residential customer site soil sampling audits, and • other system improvements that do not represent risk to the environment.

Suggested SI’s in this audit report are designed to address or clarify certain administrative commitments made by Western Water in the HEMP and/or incorporated documents (RWQMP, ERMP, HRMP).

SI’s are provided throughout the main report and also in the Appendices (includes the Audit checklist and record of compliance assessment). Refer to section 5.3 for a consolidated list of SI’s identified in this audit.

5.2 Risk of Harm to the Environment This audit did not identify any non-conformances with the HEMP or EPA guidelines that potentially represent unacceptable risk to the environment posed by the Melton Class A Recycled Water Scheme. All System Improvements identified in this report are mainly of an administrative nature and have a negligible risk ranking.

A summary assessment of the key risk areas (risk of harm to the environment) is summarised in Table 5-1.



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Table 5-1 Assessment of Risk of Harm to the Environment from the Melton Class A Recycled Water Scheme

Element Key Management Controls and Performance in 2012-13 Risk Ranking Recycled Water Production

• WW did not report any Class A Water Quality or CCP Breaches during 2012-13.

• The Class A RWP control systems have conservative alert levels set points for all CCPs to ensure plant shuts down before critical levels reached.

• Low volumes of recycled water were generated during 2012-13, due to lower residential growth than original forecasts

• Sewerage catchment is predominantly of domestic origin and the main trade waste customer (ABMT) and raw sewage is continuously monitored by WW for a range of contaminants that could impact on the Class A RWP

• The plant is DHV endorsed and has been operating for nearly 5 years with a good track record of Class A quality compliance

Low

Storage/Distribution Integrity and Recycled Water losses

• No recycled water overflows, spills or leak incidents were reported during the 2012-13 period from pipelines or tanks

• The reticulation system is fairly new and designed and built to high construction standards of the Water industry

• WW has proactive asset management plans in place including programmed inspection and maintenance programs (civil, mechanical, electrical), including tank integrity tests

• Potable water and Class A reticulation systems and storage tanks are regularly tested for cross contamination

• Intermittent small leaks of recycled water have been reported to occur (eg. due to vehicles driving over nature strip sprinklers) but these are expected to be attenuated within the constructed wetlands with negligible impact in downstream natural waterways (Werribee River, Toolern Ck)

Very Low

Stormwater

• Eynesbury and Melton South developments have WSUD stormwater systems are constructed prior to commencement of housing construction providing water quality protection of natural waterways during these construction periods

• Risk of stormwater contamination is greater from sediment pollution and erosion from exposed surfaces on construction sites (ie. compared with potential recycled water irrigation runoff of spills/leaks)

• Stormwater quality in Eynesbury has been tested once in June 2011, indicating good water quality in terms of nutrients, pathogens and chemical contamination. Other than Suspended solids quality of this stormwater was better than expected for developing urban areas.

• Any recycled water losses in irrigation runoff and reticulation system leaks or spills are expected to be attenuated within the constructed wetlands with negligible impact in downstream natural waterways (Werribee River, Toolern Ck

• Further routine monitoring of stormwater and “harvesting” of sediment buildup and vegetation from urban wetlands is suggested in this audit.

Very low



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Element Key Management Controls and Performance in 2012-13 Risk Ranking Land • Recycled water is very low in terms of chemical contamination and

poses vey little risk of adversely affecting the land or soil of production of turf and produce in potential home gardens

• Nutrient loads in recycled water are expected to be equivalent to plant water needs for phosphorus and about half the nutrient needs in terms of nitrogen. In most cases customers will not need to provide supplementary fertilisers.

• Salinity and sodicity are longer term issues which are addressed though routine soil monitoring and potential treatment of soils with gypsum or other calcium supplements

• Low recycled water usage rates are expected on the predominantly recreational turf and garden irrigation areas. This audit has recommended review of customer usage data to identify any customers with continuing high usage.

• Improved management of irrigated soils is recommended in this audit – refer to review of non-residential customers in section 4.6.7 and Appendix E

Low

Groundwater

• The volcanic basaltic soils in the supply region are typically silty-clay topsoils overlying heavy clays with high attenuation capacity for phosphorus and potential chemical contaminants.

• Groundwater is typically confined below the clay surface soils, and is at a depth of around 20-30m, and is also typically brackish

• Migration of recycled water leaching from irrigation areas and spilling into stormwater systems is expected to be minimal

• If stormwater systems are excavated into the basalt rock layer, there is some risk of additional leakage. The stormwater drains, detention basins and wetlands are lined with local clay to minimise leakage.

Very low

This audit did not identify any non-conformances, therefore a more detailed risk assessment using the method outlined in section 3.4 was not considered necessary.

5.3 System Improvements A consolidated list of the largely administrative System Improvements identified in this audit report, together with indicative priorities are provided below. The prioritisation code (A,B, C) is the suggested timing for the SI to be considered and addressed as appropriate:

• A: within 3 months • B: within 12 months • C: within 3 years or prior to next Statutory Audit, which ever comes first

No. Description Priority SI-1 Western Water should improve internal annual review and reporting processes to ensure data

reported in annual reports is validated against relevant databases. For instance, Class A residential customers supplied by Western Water may currently be under-reported in Annual Recycled Water reports.

B



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No. Description Priority SI-2 Western Water should improve internal recycled water metering and accounting procedures to

more closely reconcile Class A production (bulk meter) data with customer usage (metered) data to ensure potential Class A system losses can be tracked and more accurately reported (internally and externally). Reconciliation of Class A water supply and usage will become more important as Class A demand increases.

B

SI-3 Western Water should consider establishing residential customer usage triggers and appropriate response actions based on good science on internal household water usage and relevant EPA guidance (or other reputable methods) for calculating garden irrigation demands.

B

SI-4 There are a number of residential customers in Eynesbury and Waterford development that have very high recycled water usage recorded for 2012-13, which significantly exceeding that expected for typical garden sizes and occupancy rates in these new estates. Western Water should review residential customer data to identify the reason(s) for this high usage (including possible meter error). Appropriate responses such as education of customers should be undertaken to address the high usage.

B

SI-5 Ensure all non-residential customers in Eynesbury and Toolern Precinct submit ACS by due dates, including all required monitoring data. Ensure all of these ACS reports contain water usage data for individual sites (rather than an aggregation of sites) that correspond with the non-residential customer property addresses contained in the Western Water Billings database. This will enable improved comparisons to be made for future internal and external auditing of non-residential customer recycled water use.

B

SI-6 Verify and accurately map all Class A recycled water POS areas including roadside irrigation areas to ensure they comply with an up-to-date CSMP and are identifiable by property address in the customer register and billing’s database. The auditor was not able to identify all irrigated POS sites in Western Water’s water usage databases. This includes the roadside drip irrigation area on either side of Eynesbury Rd north of the Grey Box forest up to Exford Rd.

B

SI-7 There are a number of customers in Eynesbury and Waterford development that have very high recycled water usage recorded for 2012-13, which significantly exceeding that expected for recreational turf irrigation. Western Water should review non-residential customer data to identify the reason(s) for high annual usage (including possible meter error) on individual Eynesbury POS irrigation sites. Appropriate responses such as education of customers should be undertaken to address the high usage.

B

SI-8 Eynesbury Golf Course and POS: It appears that POS soil monitoring required b the CSMP is not being undertaken. It also appears that the golf course water quality monitoring (also required by the CSMP) is also not being undertaken. Review and update the CSMP’s including soil and golf course water quality monitoring programs, and ACS reporting requirements.

B

SI-9 Harness Racing Victoria: It appears that soil monitoring, whilst being undertaken on two occasions since commencing use in 2009, it is not being undertaken annually and in accordance with the full suite specified in the CSMP. Review and update the CSMP including soil monitoring programs, and ACS reporting requirements. It is suggested to include inspections of the HRV runoff evaporation dam for recording potential overflow events to local waterways, and to sample the dam is overflow occurs.

B

SI-10 A research and development opportunity exists to further investigate the cause of HRV trotting track instability when watered with recycled water. Appropriate cost effective preventative remedial actions should be identified to ensure similar problems can be avoided in the future at HRV and other similar racing tracks. At present the reported loss of surface integrity effectively precludes the use of recycled water for dust suppression on trotting tracks at HRV therefore reducing Class A recycled water use.

C

SI-11 Review the ERMP and all CSMP’s to ensure close linkages and consistency between these documents in particular the trigger points and corrective actions specified in the ERMP.

B



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No. Description Priority SI-12 Consider adding to the ERMP the following recycled water usage performance objectives,

trigger points and corrective actions - as a suggested new sub-section and trigger table in Chapter 4 of the ERMP:

(i) Water use soil monitoring trigger level of: 1.5 ML/Ha/Yr for annual soil monitoring requirement (otherwise every 3 years if trigger not exceeded).

(ii) Annual water use trigger level of: >30% of predicted annual irrigation requirements based on EPA water balance calculations (or the method underlying Table 3 of the ERMP) using actual rainfall and evaporation data and turf crop factors.

B

SI-13 Western Water should review all ACS soil and other monitoring data against ERMP triggers (subject to ERMP review) to determine if there are any required corrective actions.

B

SI-14 The strategic placement of permanent bollards and warning signage for irrigated nature strips, and education of local residents should be considered to protect sprinkler systems and other irrigation infrastructure on nature strips from vehicle damage.

B

SI-15 Review and customize the HRV Annual Summary and Compliance Statement forms contained in the CSMP to ensure any future track stability issues associated with recycled water usage are reported in the future. This applies if track watering is to recommence at HRV.

B

SI-16 EPA Publication 464.2 should also be added as a key guidance document to HEMP Table 7, and also referenced in the ERMP.

B

SI-17 Ensure the Table of Responsibilities in Appendix 1 of the HEMP is consistent with Section 3.1 and Table 3-1 of the HEMP. Cross-reference Appendix 1 in Chapter 3 of the HEMP, and vice versa.

A

SI-18 Update Section 3-1 of the HEMP to reflect handover of the Class A plant to WW from WIG (Pentair) in March 2013.

A

SI-19 Update Appendix 1 of the HEMP to include: • Executive level responsibilities for management commitment and sign-off of HEMP

and incorporated documents. • roles and responsibilities for ongoing compliance with the RWQMP (Manager – Water

Systems and Solutions), HRMP (Manager Renewable Resources) and ERMP (Manager Renewable Resources

A

SI-20 Ensure controlled (read only access) versions of the WW authorised HEMP and incorporated documents are securely stored together with the relevant and most up-to-date EPA and DHS endorsements. Ensure document control information is up-to-date in the controlled version of the HEMP and all other incorporated documents.

A

SI-21 Update Section 3.1.4 of the HEMP to clarify the form of agreement that applies to non-residential Class A customers. Also provide the purpose, scope, and compliance roles and responsibilities for CSMPs for non-residential Class A customers.

B

SI-22 Clarify if the Customer Service Charter is intended to also apply to Class A non-residential customers. Update next version of Charter if required to include reference to Class A non-residential customers (including the form of agreements and CSMPs).

B

SI-23 Due to the growth in the region, the environmental risks need to be reviewed to ensure risk adequately covers the whole of the Class A supply region and all customers (residential and non residential). An updated environmental risk register should be integrated with the health risk register - it is suggested to use the format used in the HRMP.

B

SI-24 Consider developing a Class A specific newsletter separate from Class B and C newsletters to ensure no confusion between permitted uses of these different recycled water classes.

B

SI-25 Ensure all CCP’s described in SOPs are consistent with process limits specified in the RWQMP HACCP plan and set points in SCADA. For example SOP0603 for CCP2b (DIT) indicates PDR alert levels 50% higher (more conservative) than the set point on SCADA.

A

SI-26 Ensure the review of the RWQMP is completed prior to the next statutory audit. Maintain a document that provides details of the changes made to the 2009 RWQMP.

C



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No. Description Priority SI-27 Implement annual cross connection checks for a representative proportion of connected

customers in response to Table 4-1 of the HRMP. Update the HRMP with a definitive cross connection audit target. It is suggested that around 5% of all customers be checked each year.

A

SI-28 HEMP and HRMP document would benefit from inclusion of a list of key operating, maintenance and inspection procedures for recycled water storage and reticulation system assets.

B

SI-29 Consider seasonal stormwater quality monitoring of all developments for a range of recycled water quality indicators to assess nutrient and other water quality trends. Update monitoring programs and triggers in HEMP framework documents to enable interpretation of stormwater monitoring results.

B

SI-30 Encourage Class A non-residential customers to participate in recycled water training sessions, customer user group and reference group meetings (currently non attending). This will increase customer awareness of CSMP monitoring, reporting and other compliance areas, and help to address the CSMP system improvements identified in this audit.

B

SI-31 Add to the HEMP (Section 8) and relevant ERP incident escalation procedures/manual the following as a “potential incident”: - Verified cross connection (unplanned, illegal) in potable water reticulation or storage systems, or within an occupied residence.

B

SI-32 Ensure all relevant staff are entering their recycled water and environmental training records into HRIS. Records are incomplete for key staff with responsibilities under the HEMP, RWQMP, HRMP and ERMP.

B

SI-33 In Section 11.4, Table 11 of the HEMP Indicate the target due date for submission of annual recycled water report to EPA.

B

SI-34 Review Balance scorecard reporting format to enable Class A scheme performance including usage, and reticulation system efficiency (eg. potential losses) to be clearly distinguished from Class B and C schemes.

B

SI-35 The HEMP, RWQMP , HRMP and ERMP should concurrently reviewed as soon as practicable. This should include:

• Consistency and improved links between the HEMP, RWQMP HRMP and ERMP and also CSMP’s where relevant

• consistency check and gap analysis for non-residential customer compliance programs against the Reclaimed Water Guidelines 464.2

• QA checks when reviews are complete including consistency, editorial and cross-referencing checks.

• Specify the frequency of review of all documents in the Hemp framework.

B

SI-36 Maintain consolidated records of residential customer self-checks of cross connections. Engage customers to encourage participation in self checks and reporting of results to WW.

B

SI-37 Review Table 12 of HEMP to clarify the audit scope, frequency, proportion of target customers to be audited (residential or non-residential), timelines

B

SI-38 Develop audit templates for all HEMP framework documents to provide clear scope for internal and external audit programs.

B



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6 Conclusions and Recommendations

6.1 Conclusions The overall conclusion of this audit is that Western Water has generally met its obligations and commitments as described in the HEMP, RWQMP, HRMP and ERMP, and through this HEMP framework has also ensured compliance with EPA’s Dual Pipe Guidelines (Publication No. 1015, 2005). This audit did not identify any non-conformances with the HEMP or EPA guidelines that potentially represents an unacceptable risk to the environment posed by the Melton Class A Recycled Water Scheme. The Auditor has suggested a number of “System Improvements” (SI), to address mainly administrative non-conformances with certain commitments made by Western Water in the HEMP and/or incorporated documents (RWQMP, ERMP, HRMP). SI’s are provided throughout the main report and in Appendices E and F. A consolidated list of SI’s is provided in section 5.3.

6.2 Recommendations Western Water should consider the Auditor’s suggested System Improvements identified in this audit as part of the next review of the HEMP, RWQMP, HRMP, ERMP and other incorporated documents and business management systems.