Woodlawn Bioreactor - Modification 7

I remain concerned with the likelihood of contamination of pasture and water ways and the resultant pasture growth producing contaminated fodder and contaminated meat products and fibre.
If this incinerator is not polluting, then it should be sited near the source of where the waste is generated.

Objection to the proposed irrigation area outlined in the Woodlawn Modification #7 Report

I accept that it has been challenging at Woodlawn with above average rainfall and limited evaporation opportunities, and the site requires alternative management measures. However, the irrigation area proposed is situated directly on the boundary of my family’s property, Willeroo, which drains through our farm into the closed basin of Lake George.
I have contacted the proponent directly to express my concerns.
Our family was not consulted by Veolia about this specific water management strategy throughout the environmental assessment process. Chapter 5.3 of the modification report discusses the community consultation that has taken place: "Potentially affected community stakeholders were consulted during the environmental assessment process to identify any requirements for consideration in the modification report." As a direct downstream neighbour, I would think we should have qualified as a potentially affected community stakeholder.

Reading the documentation, we have many areas of concern we would like to identify and requirements for consideration.
Key concerns about the project and suggested amendments.

I am aware, through my previous employment at the site, that a previous consideration by Veolia was to explore reverse osmosis as a leachate treatment strategy, incorporating irrigation. The EPA advised Veolia then that an irrigation strategy was not preferred due to ongoing concerns about emerging contaminants. Hence, the current LTP MBR and onsite evaporation strategies were developed. I would be interested to know if the NSW EPA has changed their opinion on what is acceptable in terms of off-site discharge.

The downstream buffer that exists at the irrigation site is really non-existent, and an impact would immediately affect our property. I cannot see any documented process or project precedent, or any detail around how the contaminants are monitored. Specifically, the current known contaminants that are topical in the current regulatory environment.

Are there any precedents or case studies provided on treating and irrigating permeate from landfill leachate?

The process and controls: what quality controls are being put in place prior to irrigation?

Woodlawn’s EPL 11436 outlines a substantial list of 38 pollutants requiring assessment on an annual basis. However, the sustainable irrigation management plan only lists 14 pollutants assessed. I suggest the investigation should include commentary and ROP performance on all known pollutants.

Salt accumulation: the modification document discusses contributing an additional 2% of the total salt yield of the Lake George basin when the application is actually in a concentrated area. It is my understanding that, in reality, the irrigation process is going to directly add 27.3 tonnes of salt to around 34 ha per year, with runoff. With Woodlawn's life expectancy expected to be another 30+ years, adding these elements year on year, what impact will this have on the quality of the soil, groundwater, and surface water over time. This has not been explained.

The design considers processing 8l/sec, however the irrigation impact assessment and water balance only considers 2 l/sec irrigation. How will the sensitive receivers know that Veolia plans to increase the throughput and what cumulative impacts will result from that increase? For example, if irrigation increases from 2-8l sec, presumably salt and other particulates would increase by four times? Over 100 tonnes of salt per year being added to such a small area and run off directly to the ecosystem downstream?

Why has this site been selected? I can think of other sites that would be more suitable at Woodlawn, as they have large buffer zones, several kilometres from the nearest downstream receptor or neighbour. I would have thought that managing risks and mitigating them when there is a significant buffer zone (owned by Veolia) downstream would be preferable. If this is due to potential Sydney Water catchment restrictions (clearly identified in the consultation process with NSW Water), then this is disappointing from a regulatory and engagement perspective.

I have noted the concerned commentary by NSW Water on another reverse osmosis plant that is operating and is discharging permeate that is slightly saline into the Sydney Water Drinking Catchment. When it has been made clear in the modification documentation that the water released from Woodlawn will also be saline, this also leads us to be concerned for both Veolia's land and our land downstream.

If this is irrigated quality water, then would application of this water to arable land to grow profitable pastures, crops, hay, etc. add value and drought-proof the Pylara farm and be a better outcome? Isn't this more aligned with Veolia's ethos and "Green Up" plan?. There are several zones suitable for pasture improvements/cultivation on the Crisps Creek catchment that would be obvious to utilise instead of the location proposed.

The runoff from this irrigation will certainly make its way into the main creek that runs through our property. Our livestock drink from these creeks. The proposed irrigation sprays are projected to be directly adjacent to our boundary, making soil exposure over the fence a reality. We would absolutely like to understand exactly what is in this water post-treatment.

A quantitative or qualitative assessment is stated as insignificant. The site is going from a zero discharge site to a discharge site, a significant change.

What testing procedures will be put in place prior to discharge? After reading the documentation, I have not found this clear, so as a sensitive receiver, this needs to be identified. Do you test at Woodlawn, or neighbouring properties, and what other background testing is ongoing?

Lastly, I know there is a focus on reducing extraction rates from groundwater sources. Instead of the capital investment of a large irrigation system, is Veolia considering using this ROP water for onsite dust suppression, other operational use, or engaging with the Woodlawn Mine operator and their water usage requirements?

Regardless, if irrigation is the necessary and approved solution, I would request that Veolia move the irrigation zone to another suitable block of land that is not directly upstream of our family property.

Regards

Henry Gundry
Willeroo Pty Ltd

Communities Against the Tarago Incinerator Inc. strongly objects to this project by Veolia.
We have detailed our objections in the attached document.

I object to Veolia's most recent modification application for their Woodlawn facility.
I note that this is modification 7. We have had to respond to another six before this. There seems to be a never ending stream of these modification requests. The last one that the community was expected to comment on was only three months ago. The cumulative impact of the community having to continuously respond to these documents is beyond ridiculous. Unlike the DPHI this is not my job, however I am expected to read, research, identify the apparently endless mistakes in their application and respond to the modification all in the space of two weeks. What a joke.
Veolia has done NO community consultation with regards to this reverse osmosis unit. I have had to interpret their intent from their their mistake ridden, lack lustre document. Where is the information about green house gas production? Where is the information about how they intend to power the unit? Where is the information about active real time monitoring? Where is the information about how this plan fits with their toxic waste incinerator plans? Where is the detailed and accurate odour monitoring report?
Veolia has been allowed to keep lobbing these bombs at the community. And we are expected to respond each time without an over all plan for the facility. Veolia and DPHI should be required to appropriately consult with the community laying out all future plans for the site and explaining how each of these modifications fits the big picture. Until this has occurred all future modification applications for the Woodlawn facility should be refused before they even reach public submission stage.
then continuing to add to the cumulative impact on the community of having to address each of these in isolation is completely inappropriate.

I wish to submit an object to this project on the following grounds:

1 - Lack of Community Consultation
The SEARS cover letter clearly stated "A comprehensive open and transparent community consultation engagement process must be undertaken during the Modification Report. This process must ensure that the community is provided with a good understanding of what is proposed (including a description of any potential impacts) and they are actively engaged in issues of concern to them.
Section 5.3 of the Modification report clearly shows that Veolia did not deliver on the above. They claim to have held CLC meetings in November 23 and February 24 to discuss this modification, however the claims that the committee was supportive, or the matter was even discussed are not backed up by the published Minutes of either meeting. In fact attendees have advised me it was not discussed in any detail, with only a cursory mention. Beyond this, Veolia have only have made mention of it "in principle" in one Tarago Times article 8 months ago. This does not constitute open and transparent engagement with the community, in fact it appears Veolia has deliberately limited its engagement with the community so as to have this modification sneak through. Nobody in Tarago knows this is being proposed. This modification must be rejected and Veolia advised to conduct genuine community engagement beyond making vague mention of this in one article in a small local newspaper of limited readership and reach.

2 - Need for more transparent reporting
This modification must be rejected until more comprehensive and transparent reporting arrangements are implemented by Veolia to ensure the community is provided real-time updates on the amount of leachate being treated using the reverse osmosis plant, the quality of the water once treated, and detailed testing of the soil upon which the treated water will be dispersed. This is the only way to hold Veolia to account and provide the surrounding community comfort that Veolia are not further polluting our environment through this activity, noting their persistent licence breaches and failure to deliver on promises while operating the Woodlawn facility over the last 20 years.

3 - Need more details on the power and green house gases this new plant will generate
This modification must be rejected until Veolia are able to provide full details of how much power will be required to run this reverse osmosis plant and how they will source this power. Then clear details of the green house impact of this power is required. They must also then make changes to their Incinerator proposal to incorporate this detail.

My objection is attached.

I object with details in the attached file

I object to the proposal due to concerns regarding biodiversity impact & air quality including dust & odour.

As nearby residents, we have noticed an increase in odour over the past 12 to 18 months & worry that this will continue to get worse with the modification now proposed.

We are also concerned regarding the negative impact the smell has on our personal comfort & property value & request that less waste be received for land filling at the Woodlawn Bioreactor.

Please see the attached document in relation to issues with the proposed ROP. While the ROP is needed, Veolia are neither capable or competent in their current operations at Woodlawn. Veolia's continual insistence that odour is not a problem in Tarago is delusional and symptomatic of a dysfunctional organisation.

I object to the proposal due to concerns regarding biodiversity impact & air quality including dust & odour.

As nearby residents, we have noticed an increase in odour over the past 12 to 18 months & worry that this will continue to get worse with the modification now proposed.

We are also concerned regarding the negative impact the smell has on our personal comfort & property value & request that less waste be received for land filling at the Woodlawn Bioreactor.

I object with details in the attached file

My objection is attached.

I wish to submit an object to this project on the following grounds:

1 - Lack of Community Consultation
The SEARS cover letter clearly stated "A comprehensive open and transparent community consultation engagement process must be undertaken during the Modification Report. This process must ensure that the community is provided with a good understanding of what is proposed (including a description of any potential impacts) and they are actively engaged in issues of concern to them.
Section 5.3 of the Modification report clearly shows that Veolia did not deliver on the above. They claim to have held CLC meetings in November 23 and February 24 to discuss this modification, however the claims that the committee was supportive, or the matter was even discussed are not backed up by the published Minutes of either meeting. In fact attendees have advised me it was not discussed in any detail, with only a cursory mention. Beyond this, Veolia have only have made mention of it "in principle" in one Tarago Times article 8 months ago. This does not constitute open and transparent engagement with the community, in fact it appears Veolia has deliberately limited its engagement with the community so as to have this modification sneak through. Nobody in Tarago knows this is being proposed. This modification must be rejected and Veolia advised to conduct genuine community engagement beyond making vague mention of this in one article in a small local newspaper of limited readership and reach.

2 - Need for more transparent reporting
This modification must be rejected until more comprehensive and transparent reporting arrangements are implemented by Veolia to ensure the community is provided real-time updates on the amount of leachate being treated using the reverse osmosis plant, the quality of the water once treated, and detailed testing of the soil upon which the treated water will be dispersed. This is the only way to hold Veolia to account and provide the surrounding community comfort that Veolia are not further polluting our environment through this activity, noting their persistent licence breaches and failure to deliver on promises while operating the Woodlawn facility over the last 20 years.

3 - Need more details on the power and green house gases this new plant will generate
This modification must be rejected until Veolia are able to provide full details of how much power will be required to run this reverse osmosis plant and how they will source this power. Then clear details of the green house impact of this power is required. They must also then make changes to their Incinerator proposal to incorporate this detail.

I object to Veolia's most recent modification application for their Woodlawn facility.
I note that this is modification 7. We have had to respond to another six before this. There seems to be a never ending stream of these modification requests. The last one that the community was expected to comment on was only three months ago. The cumulative impact of the community having to continuously respond to these documents is beyond ridiculous. Unlike the DPHI this is not my job, however I am expected to read, research, identify the apparently endless mistakes in their application and respond to the modification all in the space of two weeks. What a joke.
Veolia has done NO community consultation with regards to this reverse osmosis unit. I have had to interpret their intent from their their mistake ridden, lack lustre document. Where is the information about green house gas production? Where is the information about how they intend to power the unit? Where is the information about active real time monitoring? Where is the information about how this plan fits with their toxic waste incinerator plans? Where is the detailed and accurate odour monitoring report?
Veolia has been allowed to keep lobbing these bombs at the community. And we are expected to respond each time without an over all plan for the facility. Veolia and DPHI should be required to appropriately consult with the community laying out all future plans for the site and explaining how each of these modifications fits the big picture. Until this has occurred all future modification applications for the Woodlawn facility should be refused before they even reach public submission stage.
then continuing to add to the cumulative impact on the community of having to address each of these in isolation is completely inappropriate.

Communities Against the Tarago Incinerator Inc. strongly objects to this project by Veolia.
We have detailed our objections in the attached document.

Objection to the proposed irrigation area outlined in the Woodlawn Modification #7 Report

I accept that it has been challenging at Woodlawn with above average rainfall and limited evaporation opportunities, and the site requires alternative management measures. However, the irrigation area proposed is situated directly on the boundary of my family’s property, Willeroo, which drains through our farm into the closed basin of Lake George.
I have contacted the proponent directly to express my concerns.
Our family was not consulted by Veolia about this specific water management strategy throughout the environmental assessment process. Chapter 5.3 of the modification report discusses the community consultation that has taken place: "Potentially affected community stakeholders were consulted during the environmental assessment process to identify any requirements for consideration in the modification report." As a direct downstream neighbour, I would think we should have qualified as a potentially affected community stakeholder.

Reading the documentation, we have many areas of concern we would like to identify and requirements for consideration.
Key concerns about the project and suggested amendments.

I am aware, through my previous employment at the site, that a previous consideration by Veolia was to explore reverse osmosis as a leachate treatment strategy, incorporating irrigation. The EPA advised Veolia then that an irrigation strategy was not preferred due to ongoing concerns about emerging contaminants. Hence, the current LTP MBR and onsite evaporation strategies were developed. I would be interested to know if the NSW EPA has changed their opinion on what is acceptable in terms of off-site discharge.

The downstream buffer that exists at the irrigation site is really non-existent, and an impact would immediately affect our property. I cannot see any documented process or project precedent, or any detail around how the contaminants are monitored. Specifically, the current known contaminants that are topical in the current regulatory environment.

Are there any precedents or case studies provided on treating and irrigating permeate from landfill leachate?

The process and controls: what quality controls are being put in place prior to irrigation?

Woodlawn’s EPL 11436 outlines a substantial list of 38 pollutants requiring assessment on an annual basis. However, the sustainable irrigation management plan only lists 14 pollutants assessed. I suggest the investigation should include commentary and ROP performance on all known pollutants.

Salt accumulation: the modification document discusses contributing an additional 2% of the total salt yield of the Lake George basin when the application is actually in a concentrated area. It is my understanding that, in reality, the irrigation process is going to directly add 27.3 tonnes of salt to around 34 ha per year, with runoff. With Woodlawn's life expectancy expected to be another 30+ years, adding these elements year on year, what impact will this have on the quality of the soil, groundwater, and surface water over time. This has not been explained.

The design considers processing 8l/sec, however the irrigation impact assessment and water balance only considers 2 l/sec irrigation. How will the sensitive receivers know that Veolia plans to increase the throughput and what cumulative impacts will result from that increase? For example, if irrigation increases from 2-8l sec, presumably salt and other particulates would increase by four times? Over 100 tonnes of salt per year being added to such a small area and run off directly to the ecosystem downstream?

Why has this site been selected? I can think of other sites that would be more suitable at Woodlawn, as they have large buffer zones, several kilometres from the nearest downstream receptor or neighbour. I would have thought that managing risks and mitigating them when there is a significant buffer zone (owned by Veolia) downstream would be preferable. If this is due to potential Sydney Water catchment restrictions (clearly identified in the consultation process with NSW Water), then this is disappointing from a regulatory and engagement perspective.

I have noted the concerned commentary by NSW Water on another reverse osmosis plant that is operating and is discharging permeate that is slightly saline into the Sydney Water Drinking Catchment. When it has been made clear in the modification documentation that the water released from Woodlawn will also be saline, this also leads us to be concerned for both Veolia's land and our land downstream.

If this is irrigated quality water, then would application of this water to arable land to grow profitable pastures, crops, hay, etc. add value and drought-proof the Pylara farm and be a better outcome? Isn't this more aligned with Veolia's ethos and "Green Up" plan?. There are several zones suitable for pasture improvements/cultivation on the Crisps Creek catchment that would be obvious to utilise instead of the location proposed.

The runoff from this irrigation will certainly make its way into the main creek that runs through our property. Our livestock drink from these creeks. The proposed irrigation sprays are projected to be directly adjacent to our boundary, making soil exposure over the fence a reality. We would absolutely like to understand exactly what is in this water post-treatment.

A quantitative or qualitative assessment is stated as insignificant. The site is going from a zero discharge site to a discharge site, a significant change.

What testing procedures will be put in place prior to discharge? After reading the documentation, I have not found this clear, so as a sensitive receiver, this needs to be identified. Do you test at Woodlawn, or neighbouring properties, and what other background testing is ongoing?

Lastly, I know there is a focus on reducing extraction rates from groundwater sources. Instead of the capital investment of a large irrigation system, is Veolia considering using this ROP water for onsite dust suppression, other operational use, or engaging with the Woodlawn Mine operator and their water usage requirements?

Regardless, if irrigation is the necessary and approved solution, I would request that Veolia move the irrigation zone to another suitable block of land that is not directly upstream of our family property.

Regards

Henry Gundry
Willeroo Pty Ltd

I remain concerned with the likelihood of contamination of pasture and water ways and the resultant pasture growth producing contaminated fodder and contaminated meat products and fibre.
If this incinerator is not polluting, then it should be sited near the source of where the waste is generated.

Please see the attached document in relation to issues with the proposed ROP. While the ROP is needed, Veolia are neither capable or competent in their current operations at Woodlawn. Veolia's continual insistence that odour is not a problem in Tarago is delusional and symptomatic of a dysfunctional organisation.