Guidelines for satisfying environmental objectives
Facility environmental management revolves around the facility occupier finding answers to six fundamental questions:
- What are the key environmental issues associated with the facility?
- What is the required level of environmental performance for these issues?
- What environmental management techniques are proposed to address these issues to the required level of environmental performance?
- How will the environmental management techniques be assessed to determine whether compliance with the objective has been achieved?
- How can the environmental management techniques be monitored to determine whether the required level of environmental performance has been achieved?
- What remedial action is proposed should the monitoring show the controls not to be meeting the required level of environmental performance?
In relation to question 1, 13 key environmental issues have been identified for composting and related organics processing facilities and are described in this section. Composting and related organics processing facilities (for definitions see Table 1) should work to satisfy the objectives for each issue. Environment protection licences issued under the POEO Act will require these issues to be managed effectively.
Each environmental issue addressed in this section has up to 4 parts:
- an objective, which describes the desired environmental outcome
- design requirements, which describe minimum requirements and/or refer to the more detailed Minimum Design Requirements for the protection of waters specified in Section 5, which must be addressed by facility designers. Design requirements may also list and/or refer to acceptable environmental management techniques to be considered by facility planners.
For facilities that are required to be licensed under the POEO Act, design requirements may be placed into 'general terms of approval' during the development assessment process.
For facilities that are already licensed under the POEO Act, the design requirements would need to be addressed by facility operators and designers where changes are needed to prevent emissions and discharges from the premises.
- performance requirements, which describe what is necessary to satisfy the objective. These requirements generally refer to thresholds of performance that must be achieved during operation of the facility (i.e. after the commissioning of the facility).
- performance measurements, which state how performance will be assessed to determine whether the objective is being achieved. Methods to measure and monitor performance are described in Section 6.
Please note that these requirements would need to complement the development assessment process outlined in Section 3, which would take account of the most contentious issues, such as odour generation, odour controls and proximity to boundaries.
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The choice of environmental management techniques (question 3) is not mandated in the guidelines, but is left up to the occupier to determine on the basis of the specific circumstances of the facility. Appendix B contains examples of techniques that have been shown to be effective in dealing with the environmental issues. The Minimum Design Requirements for protection of waters in Section 5 identify goals for the design of environmental management techniques and specify the minimum requirements relating to question 3. The performance requirements address question 2 above, and the performance measurements address question 4 and in some circumstances question 5. Section 6 addresses questions 5 and 6.
Occupiers could refer to Appendixes A and B as a starting point to help them in selecting environmental controls. Other sources (such as the References and Bibliography in these guidelines, scientific journals, environmental consultants and industry representatives) may also be consulted when selecting environmental controls.
You may also contact the Waste Management Section of the EPA on 131 555 for further information.
Issue 1: Odour
No emissions of offensive odours outside the boundaries of the premises.
Details of the likely incremental increase in odour impacts must be given in an impact assessment report for odour. This report must be prepared in accordance with the Approved Methods and Guidance for the Modelling and Assessment of Air Pollutants in NSW (EPA 2001a).
The Draft Policy: Assessment and Management of Odour from Stationary Sources (EPA 2001b) contains a three-level system of odour impact assessment for point and diffuse odour sources:
- Level 1 is a simple screening exercise to identify the potentially affected zone and site suitability for a proposed facility or expansion of an existing facility.
- Level 2 is a simple dispersion modelling procedure that would be undertaken by the proponent or operator.
- Level 3 is a refined dispersion modelling procedure that would be undertaken by the proponent or operator.
Note: The Draft Policy: Assessment and Management of Odour from Stationary Sources is accompanied by a separate booklet, Technical Notes: Assessment and Management of Odour from Stationary Sources in NSW (EPA 2001c).
The odour impact assessment report must at least consider the likely incremental increases relating to the following:
- all phases of processing (e.g. pre-treatment, decomposition, aeration and maturation)
- raw organics and organic products managed at the premises, including impacts during receipt and storage (i.e. including stockpiling of organics)
- movement of raw organics and organic products at and to/from the premises
- management of biogas at the premises (e.g. biogas flaring).
The design of the facility, coupled with the proposed operating procedures, must ensure that the facility does not cause offensive odours outside the premises. Facilities must be designed to meet the odour performance criteria specified in the Approved Methods and Guidance for Modelling and Assessment of Air Pollutants in New South Wales (EPA 2001a).
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All plant used for processing (e.g. pre-treatment, decomposition, aeration and maturation) and the storage and or movement of raw organics and products must always be maintained and operated in an efficient manner to prevent air pollution from the premises.
The absence of confirmed complaints about odour emissions shown to be caused by the facility, and demonstrated compliance with any limit conditions imposed on the licence.
Section 6 (see odour) describes methods to measure and monitor performance.
Issue 2: Particulate matter
Minimise particulate matter emissions from the facility.
Details of the likely incremental increase in PM10, deposited matter and total suspended particulate matter (TSP) due to processing as well as raw organics and product handling at the premises must be given in an impact assessment report for air quality. This report must be prepared in accordance with the Approved Methods and Guidance for the Modelling and Assessment of Air Pollutants in NSW (EPA 2001a) (see note below regarding PM2.5).
The design of the facility, coupled with the proposed operating procedures, must ensure that the predicted incremental increase in particulate matter from the above modelling will satisfy the impact assessment criteria specified in the Approved Methods and Guidance for the Modelling and Assessment of Air Pollutants in NSW and will comply with the requirements specified in the Clean Air (Plant and Equipment) Regulation 1997.
The processing facility must be operated in such a manner and raw organics and products must be always managed in such a manner that the assumptions made in the impact assessment modelling are continuously maintained and emissions comply with requirements specified in the Clean Air (Plant and Equipment) Regulation 1997.
The absence of complaints about particulate matter emissions shown to be caused by the facility.
Emissions comply with the requirements specified in the Clean Air (Plant and Equipment) Regulation 1997.
Section 6 (see particulate matter) describes methods to measure and monitor performance.
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Biological particulate matter
These guidelines specify neither performance requirements nor performance measurements for biological particulate matter, because standardised sampling methodology was lacking at the time of publication of the guidelines. In addition, there is also a lack of consensus on the many types of sampling methods, equipment and assay methods available for biological particulate matter (Swan et al. 2002; Environment Agency 2003). Measures that mitigate emissions of non-biological particulate matter (such as PM10, deposited matter and TSP matter) are also likely to mitigate emissions of biological particulate matter (Pillai & Ricke 2002).
Particulate matter in the size range up to 2.5 µm (PM2.5)
PM2.5 is primarily a human health issue, because PM2.5 are small enough to penetrate into the lungs and are associated with a range of respiratory symptoms (Gilbert 1998; Swan et al. 2002). Information regarding the impact of emissions of PM2.5 is available from the NSW Health Department and/or WorkCover NSW.
The EPA recommends that PM2.5 be controlled by environmental management techniques that address PM10 (see Appendix B), because methods that measure and monitor PM10 include particles smaller than 10 µm (i.e. particles of the size range up to 2.5µm) (see Section 6).
Issue 3: Methane gas management
Minimise emissions of methane to air and diffusion through soil strata such that the risk to humans in confined spaces (such as explosions and suffocation) is minimal.
The design of aerobic composting and related organics processing facilities coupled with proposed operating procedures must ensure that the generation of methane is minimised.
The design of anaerobic composting and related organics processing facilities must ensure that environmental controls are in place for the containment, extraction and treatment of any biogas generated and must comply with Australian Standard AS 2865-1986 Safe Working in a Confined Space, the NSW Occupational Health and Safety (Confined Spaces) Regulation 1990 and the NSW Occupational Health and Safety Act 2000.
Biogas extraction and treatment equipment must be designed to ensure that as much biogas as is commercially practicable will be collected and treated or beneficially reused.
For further information regarding the design requirements and performance requirements relating to occupational health and safety at composting and related organics processing facilities, consult WorkCover NSW.
Note: Facilities that incorporate both anaerobic and aerobic processing stages must demonstrate compliance with both of the above design requirements.
Aerobic composting and related organics processes must be operated, managed and maintained in such a manner that (where relevant) anaerobic conditions are mitigated.
Anaerobic composting and related organics processes must be operated, managed and maintained to contain, extract and treat all biogas generated. Occupiers of such facilities must implement and maintain procedures in accordance with the requirements of the occupational health and safety standards specified in the design requirement above.
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Absence of complaints about odours that are shown to be caused by anaerobic processes at the premises.
Where biogas is produced, it is extracted and utilised to the highest commercially practicable level.
Establishment of procedures and training of staff to meet the requirements of the occupational health and safety standards specified in the design requirement above.
Section 6 describes methods of measuring and monitoring performance.
Issue 4: Emissions of nitrogen oxides, sulfur oxides and non-methane organic compounds
Minimise emissions of nitrogen oxides (NO2 and NO), sulfuric acid mist (H2SO4), sulfur oxides (SO3 and SO2) and non-methane volatile organic compounds (NMVOC) whenever using gas flare or electricity-generating equipment.
An impact assessment report for air quality must be prepared in accordance with the Approved Methods and Guidance for the Modelling and Assessment of Air Pollutants in New South Wales. The report must demonstrate that the facility is designed to comply with the following requirements:
- impact assessment criteria for any air pollutant likely to be emitted (e.g. NO2 and SO2), as specified in the Approved Methods and Guidance for the Modelling and Assessment of Air Pollutants in New South Wales
- provisions specified in the Clean Air (Plant and Equipment) Regulation 1997.
Emissions from the biogas engine exhaust must not exceed the concentration limits specified for the following pollutants:
- nitrogen oxides (NO2 and NO) concentration of 450 mg/m3 (dry) at 273 K, 101.3 kPa and 7% O2
- sulfuric acid mist (H2SO4) and/or sulfur trioxide concentration (as SO3) of 100 mg/m3 (dry) at 273K and 101.3 kPa.
The electricity-generating equipment must be designed to ensure a volatile organic compound (VOC) destruction efficiency of at least 98%.
The biogas flare must be located at ground level, shrouded, provided with automatic combustion air control, an automatic shut-off gas valve and an automatic restart system. It must also be designed so that as much biogas as is practicable will be collected and treated or beneficially reused.
The biogas flare must be designed to meet or exceed the following combustion parameters:
- instantaneous residence time of 0.6 seconds
- instantaneous temperature of 760°C.
Any liquid condensed from the biogas must not pollute groundwater or surface water and must not have an impact on amenity (such as odour problems).
Any biogas flare or electricity-generating equipment must be operated and maintained in a proper and efficient manner and must comply with any licence conditions for air pollutants.
Emissions must comply with requirements specified in the Clean Air (Plant and Equipment) Regulation 1997 and the emission concentration limits specified above.
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Any biogas flare or electricity-generating equipment at the premises must conform to the design requirements, including the provisions of the Clean Air (Plant and Equipment) Regulation 1997 and the emission concentration limits specified above.
Section 6 describes methods of measuring and monitoring performance.
Issue 5: Water pollution
Prevent water pollution. Surface or underground discharges of leachate and water from the facility must not pollute groundwater or surface waters.
(Note: Specific Minimum Design Requirements for the protection of waters are provided in Section 5.)
The working surfaces, including the incoming organics and product storage areas, the active composting pad (for windrow composting) and access roads must meet the minimum requirements specified in Section 5, '1: Working surfaces'.
The design requirements for a leachate barrier system depend on the head of liquid (leachate) acting upon it and must at least conform to the leachate barrier systems listed in Section 5, '2: Leachate barrier system'.
It is possible that the working surfaces of the site or building, together with the leachate drainage and collection system, will act as a leachate barrier to prevent pollution of the subsoil, groundwater and surface water bodies, so a separate leachate barrier may not be required. In such situations, the reasons for not fitting a separate leachate barrier system must be clearly documented.
Unless the reasons for not fitting a separate leachate barrier are justified and approved by the EPA, a specially designed leachate barrier system to prevent pollution of the subsoil, groundwater and surface water bodies must be installed for all composting and related organics processing facilities that:
- process Category 2 or 3 organics
- are operated in trough, trenches or pits that are below ground level
- are set up on a terrain of highly permeable soil, or
- are set up over, or near, vulnerable groundwater or surface resources(s) requiring protection. Where the Department of Infrastructure, Planning and Natural Resources (formerly the Department of Land and Water Conservation) has prepared groundwater vulnerability maps, the areas of concern are those mapped as 'high' or 'very high' vulnerability.
If the preliminary water assessment of the site (see Appendix A) finds that the groundwater underneath and adjacent to the facility is vulnerable and that systems to prevent groundwater pollution are required, then a groundwater and subsoil monitoring network must be established. The design of the groundwater and subsoil monitoring network must at least meet the minimum requirements specified in Section 5, '6: Groundwater and subsoil monitoring network'.
The leachate collection system must be designed to prevent water pollution and odour problems. Section 5, '3: Leachate collection system', lists acceptable techniques.
The design of the leachate storage system must at least comply with the minimum requirements and the acceptable characteristics specified in Section 5, '4: Leachate storage system'.
The design of surface water controls must at least meet the minimum requirements specified in Section 5, '5: Surface water controls'.
Any leachate and surface water management systems (such as storage and barrier systems) must be maintained in such a way that they always conform to the design requirements.
Any leachate and surface water management systems (such as storage and barrier systems) on the premises must conform to the design requirements.
Section 6 (see water pollution) describes methods of measuring and monitoring performance.
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Issue 6: Suitability of incoming organics
Ensure that incoming organics do not have negative environmental impacts (such as air quality impacts) or amenity impacts (such as odour).
Occupiers must design and put in place an incoming material-screening system that ensures that they receive only those categories of organics (see Section 3, Table 3: Categorisation of organics) that are suitable for both the processing techniques and the environmental controls installed at the facility.
Specifically, occupiers must not receive the following categories of organics at composting and related organics processing facilities:
- organics other than those permitted in their licences (see Section 3, Table 3)
- organics seized or subject to controls issued by the Australian Quarantine Inspection Service (AQIS) or NSW Agriculture or another agricultural agency, unless the facility receives and complies with any additional requirements that AQIS or the agricultural agency may impose to ensure destruction or inactivation of the contaminants or pathogens of concern
- organics that are contaminated by chemicals and/or pathogens that will not be rendered harmless by the process or that may constitute a health or environmental risk, including clinical waste and other related wastes of clinical origin, and diseased carcasses
- organics containing contaminants classified as hazardous wastes or industrial wastes in any statutory instruments (see: Protection of the Environment Operations Act 1997 and Environmental Guidelines: Assessment, Classification and Management of Liquid and Non-Liquid Wastes (EPA 1999a)).
The occupier must design and implement methods and operating practices to screen incoming organics to ensure that only those organics permitted to be received at the facility are received (for examples, see Appendix B).
The quantity of organics received for processing and the finished products transported from the premises must be measured or estimated as precisely as possible (see Section 6).
The processing facility must not receive any of the organics listed above and must not receive any category or type of organics other than those permitted to be received at the premises, as specified in the environment protection licence or any other terms of consent.
The quantity of organics permitted to be received at the premises as specified in the environment protection licence (e.g. as specified by the fee threshold) or any other terms of consent must not be exceeded.
Operating practices to screen incoming organics must be employed for all organics received at the facility.
Compliance with the objective will be determined by assessment of the following:
- implementation of procedures to screen incoming organics
- documented evidence of the category or type and quantity of organics received at the facility
- the presence in the storage, preparation and processing areas, within the bounds of due diligence, of only those categories of organics that belong to the categories of organics (see Table 3) specified on the facility's environment protection licence.
Section 6 describes methods for measuring and recording the category or type and quantity of organics received at the facility.
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Issue 7: Safe storage and disposal of process residuals and contaminated organics
Prevent water pollution and amenity impacts (such as odour and dust).
The design of the facility must include infrastructure to securely store all organics, contaminated products, wastes, and process residues that cannot be beneficially processed at the facility, until they can be lawfully disposed of at the facility or transferred to another facility.
The working surfaces used to store all incoming organics, contaminated products, wastes and process residues must meet the minimum requirements specified in Section 5, '1: Working surfaces' and '5: Surface water controls'.
Any organics, contaminated products, wastes, and process residues are stored according to the design requirements.
Any wastes generated at the premises must be disposed of lawfully: for example, in accordance with the POEO Act and the Protection of the Environment (Waste) Regulation 1996, the occupier must comply with the following:
- Before dispatching any waste from the premises the occupier must classify or assess waste in accordance with the Waste Guidelines.
- The occupier must ensure that any waste dispatched from the premises is sent to a waste facility that is licensed to receive it or to premises that may otherwise lawfully receive it.
- For wastes classified or assessed as hazardous waste, industrial waste or Group A waste, the facility occupier must comply with the waste-tracking requirements specified in the environment protection licence and/or Protection of the Environment Operations (Waste) Regulation 1996.
Compliance with the objective is measured using the following:
- There are no contaminated organics, materials, wastes or residues outside the secure storage areas provided for them at the facility.
- There is documented evidence (e.g. waste tracking data) that demonstrates that the occupier has lawfully disposed of contaminated products, wastes or residues that it has generated at the facility.
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Issue 8: Stockpiling of incoming and processed organics
To minimise stockpiling of unprocessed and processed organic materials above that required for processing or to meet market requirements.
The occupier must demonstrate during the planning stage that potential markets for processed organics have been identified, including the projected quantities of processed organics that each type of market will absorb.
The projected maximum quantities of incoming and processed organics stored at the premises at any one time, and the management procedures to control odour, leachate and heat generation must be identified in the planning stage. (Appendix B contains suggested stockpile targets and management procedures.)
Any incoming and processed organics must be stored and managed in quantities not exceeding the design requirements.
The quantities of incoming and processed organics (identified during the planning stage) stored at the premises are not exceeded.
Issue 9: Noise
Minimise noise emissions.
The assessment of noise impacts must be conducted in accordance with the NSW Industrial Noise Policy (EPA 2000b), which includes the following basic steps:
- determining existing background and ambient noise levels, using the method commensurate with the expected level of impact and as specified in the NSW Industrial Noise Policy (EPA 2000b)
- using the procedure specified in the NSW Industrial Noise Policy as the basis for deriving project specified noise levels
- predicting the noise levels produced by the proposed facility, having regard to meteorological effects (such as wind and temperature inversions)
- comparing the predicted noise levels with the project-specific noise levels produced by the proposed facility, to establish any impact.
The design of the facility coupled with the proposed operating procedures must satisfy the requirements of the NSW Industrial Noise Policy (EPA 2000b); consideration must be given to the mitigation strategies for noise control identified in Section 7 of the Policy.
The site-specific noise level determined for a particular facility will be determined/negotiated in accordance with the objectives of the NSW Industrial Noise Policy and thus will include consideration of the receiver's land-use type, the existing background and ambient noise levels, and the nature, level and characteristics of the source noise.
In some instances the site-specific performance requirement for noise emissions, under typical meteorological conditions relevant to the site, may be specified in environment protection licences.
The absence of complaints about noise emissions shown to be caused by the facility that exceed the relevant criteria when sampled and analysed in accordance with the methods prescribed in the NSW Industrial Noise Policy.
Issue 10: Litter
The local amenity must not be degraded by litter emanating from the composting and related organics processing facility.
The design of the facility coupled with proposed operating procedures must control litter and site materials to ensure that the local amenity is not degraded by litter or site materials emanating from the premises. For example, design and operating procedures must prevent vehicles leaving the facility from distributing mud, sediment, litter, or site materials beyond the boundary of the premises, and must ensure that regular inspections are carried out and any litter found is cleaned up immediately.
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The processing facility must be operated and maintained in such a manner that litter and site material do not emanate beyond the boundary of the premises.
Compliance is measured by:
- absence of mud and other types of dirt, organics, wastes and litter being carried by vehicles from the facility that could be deposited on roads outside the facility and on nearby streets
- inspection of the facility and nearby areas to confirm that effective steps are being taken to keep the facility free of litter, as shown by the absence of wind-blown litter and site materials within one working day after windy weather (see Appendix B).
Issue 11: Security of the premises
Ensure that the premises are secure.
The occupier must put into place provisions for denying unauthorised access to the following areas:
- areas used for receiving, storing and processing of organics, process residuals and contaminated materials
- all areas used to store flammable materials.
The occupier must prevent unauthorised entry to the areas of the facility used for receiving, storing and processing of organics, process residuals and contaminated materials and all areas used to store flammable materials.
Compliance with the performance requirement is determined by assessing whether the occupier has established and implemented procedures for preventing vehicles or persons from being on the premises without their presence being recorded in a permanent way.
Issue 12: Fire management
To ensure that the facility is not a fire risk and that the facility is adequately prepared in the event of fire.
The occupier must prepare a fire management strategy that must identify at least the following:
- the potential causes of fire at the composting facility
- the procedure to follow, persons responsible, and equipment to be used in the event of a fire. This will include on-site resources and external resources (such as the Bush Fire Brigade), and details of how the procedure will operate on a 24-hour-a-day basis
- the maintenance schedules for all fire-fighting equipment and facilities. At a minimum, all equipment and facilities should be visually checked for damage on a weekly basis, and test-operated on a quarterly basis
- details of all the fire-fighting equipment that will be installed at the flammable store and at site buildings
- how all fire-fighting equipment will be clearly signposted and how access to it will be ensured at all times
- details of the firebreaks to be constructed and maintained around all filled areas, stockpiles of combustibles, gas extraction equipment and site buildings
- training of facility staff in fire-fighting techniques.
The fire management strategy must be maintained and available to relevant staff trained in the procedures and techniques outlined in the fire management strategy.
Compliance with the performance requirement is determined by assessing whether the occupier has:
- equipment and associated signage installed and maintained as specified in the fire management strategy
- trained staff in the maintenance procedures and fire-fighting techniques outlined in the fire management strategy.
Issue 13: Closure of the facility
To ensure that, after closure, the composting and related organics processing facility does not cause environmental harm.
Before closure of the facility the occupier must prepare a closure plan for approval by the EPA.
The minimum requirements for site remediation when the facility closes are as follows:
- products, feedstock, amendments, contaminated products, process residues or chemicals must not remain on the premises
- all equipment (including appliances, bins and process areas) must be emptied, cleaned and disinfected
- all equipment must be removed from the premises, unless it can be demonstrated that the equipment that remains will not have the potential to cause environmental impacts and is needed for subsequent uses of the site
- the facility must be revegetated or otherwise made stable and suitable for the proposed future land use of the site. The revegetation of any exposed working areas must be started within 30 days of cessation of composting and related organics processing (weather permitting), and the final revegetation layer must be of a depth and type sufficient to support the revegetation scheme proposed.
- the final surfaces prepared on the site must control surface erosion and protect local amenity
- groundwater monitoring and monitoring of surface water bodies must be continued until it demonstrates the absence of any pollution that would pose a threat to the quality of groundwater, surface waters or surface water bodies.
Compliance with the performance requirement will be assessed against the following:
- the minimum requirements specified above
- compliance with the POEO Act, particularly those provisions relating to facility closure (see Section 3), water and air pollution, and the emission of odour.
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Page last updated: 12 July 2012