The company Southern Waste Solutions (SWS) has recently received permits from the Tasmanian Environment Protection Authority (EPA) and Sorell Council to construct and operate a ‘C-cell’, or high-level hazardous waste disposal facility at a site between Copping and Carlton River in south-east Tasmania.
The local community is strongly opposed to the proposal and demands that the permits for the Copping C-cell be revoked. The TCT supports this stand and the reasons for it.
Southern Waste Solutions is the trading name for the Copping Refuse Disposal Site Joint Authority, which operates the existing waste disposal site at Copping. It is a company entirely owned by Sorell, Tasman, Clarence and Kingborough Councils and is therefore owned by the ratepayers and should be operated in their interests. It is normally highly controversial and difficult to seek to revoke approvals for developments. But this project involves the disposal into landfill of our most dangerous waste materials. It is entirely reasonable for the community, as shareholders, to insist that the permits be revoked by the proponent, (SMS).
The TCT is opposed to the Copping C-cell for these reasons:
- lack of consultation with the community
- the risk of hazardous waste escaping into the environment
- the EPA’s failure to have other potential sites properly investigated
- lack of a hazardous waste strategy.
1. Lack of consultation with the local and Tasmanian communities
Does Tasmania need a C-cell?
The Copping proposal is the first C-cell proposed for Tasmania. It is unacceptable that the state government and the proponent proceeded on the arrogant assumption that a C-cell is needed and the community did not have to be consulted or convinced of its need. While the proponent claims that a C-cell is essential, to help clean up hazardous waste that is stored inappropriately across Tasmania, it has provided no evidence that this is the case.
Lack of consultation over the location
Hardly anyone in the local community knew about the Copping C-cell until after it was approved by the EPA and the Sorell Council. Most people were alerted to the project by an article in the Mercury newspaper in August 2012. It appears that both the Sorell Council and the EPA did the bare minimum legally required by advertising the development in newspapers and on their websites and by notifying immediately adjacent landowners. This is the first high-level hazardous waste facility ever proposed for Tasmania and everyone in the local municipality and perhaps across Tasmania should have been made aware of it.
2. Serious concerns regarding risk of hazardous waste escaping into the environment
The TCT fears that there is a high risk of many toxic materials escaping and causing serious damage to human health, the natural environment and local industries, in particular tourism, aquaculture and farming.
Most materials likely to be dumped will never break down or become less hazardous, remaining dangerous well beyond the 100-year lifespan of the dump.
The proposed Copping C-cell has the potential to receive ‘level three’ or high-level non-liquid hazardous waste, including many substances that are toxic to humans and highly damaging to the natural environment, such as (with the approval of the EPA Director) arsenic, cyanide, lead, zinc, cadmium, PCBs and pesticides. The only prohibited hazardous wastes are nuclear materials, those with level-four contamination levels and liquids.
SWS’, claim that many level-three materials will not be accepted into the C-cell, including oil, pesticides and acids, is misleading in the extreme; it is simply a statement by SWS of its current intent, has no legal authority and could change at any time.
Our primary concerns relate to the risk of toxic materials escaping into the groundwater or streams and ending up in the nearby Carlton River and Fredrick Henry Bay.
It seems almost certain that some dust will escape from the dump in strong winds, especially during off-loading and while the active dump face is exposed. Trucks carrying waste to the dump site could also have accidents and release toxic materials anywhere en route.
The Development Proposal and Environmental Management Plan (DPEMP) that was approved by the EPA was extraordinary because of lack, or partial provision, of crucial information related to human and environmental safety. Some of the safety measures proposed are unconvincing, compromised by financial constraints and fail to consider all possible risks. Should a safety measure fail, there is no back-up plan.
The C-cell design provided in the DPEMP is described as ‘conceptual’. The paln states that the final detailed design will be provided later to the EPA Director for approval, but the public is not even offered copies of these documents, let alone an opportunity to comment on them with the possibility of changes being made.
Such arrangements may be legal and normal but this is not a normal development and the EPA and the proponent should have taken into account the interest the public would have in such a project.
Risk of hazardous materials escaping prior to concealment
While the TCT understands that the proponent is not responsible for the cartage of materials by other operators, the state government and the EPA must surely be responsible for ensuring the safe transport of waste to the facility. Regulations on transporting hazardous material, and a licensing system, are in place, but there is no hazardous waste strategy, or other guidance for operators, for example:
- measures to limit accidents and spillage of hazardous waste while in transit, and to deal with such waste should an accident occur
- how vehicles should be covered and materials sealed during transit.
In relation to the handling of waste at the proposed site, the DPEMP does not adequately consider:
- the possibility of heavy machinery damaging the C-cell leachate barriers during unloading;
- measures to ensure that hazardous material is not blown from the tip face by the wind. The plan does not give enough detail about how the options – spraying the exposed landfill tip face with liquid leachate or covering it with soil or a geotextile layer – will work in practice.
Rather than this ad hoc and reactive approach we would have expected the proponent to submit a detailed pre-concealment waste control plan identifying every likely step in the process of being loading, transporting, unloading and containing waste materials prior to permanent concealment at the C-cell. This plan would identify measures to avoid and respond to an escape of waste materials.
Risk of hazardous materials escaping into groundwater or streams
SWS and the EPA have accepted that the clay components of the leachate barriers will crack after some time and that the high-density polyethylene (HDPE) layers have a limited life span and will develop flaws that can let moisture through (although the time periods are disputed by SWS). It is assumed that only very small amounts of moisture will escape as the barrier system has multiple layers and it is highly unlikely that significant gaps will develop in all layers and be aligned. This appears to be an very untested assumption (certainly within the DPEMP process).
The upper layers of the barrier are expected to leak and the plan has provisions to collect, monitor and contain it through a leachate collection pipe network and collection sump. Portals would enable the pipelines to be inspected and cleaned. The material from this collection system is to be diverted to a leachate treatment plant, with evaporation ponds and an active evaporation unit, to ensure excess water is contained and removed and sludge returned to the C-cell.
These are critical safety precautions but few details are provided so it is hard to test claims that they will prevent significant levels of leachate escaping. The type of leachate treatment plant has not been determined.
In the DPEMP it is admitted that, due to financial constraints, PVC will be used instead of the preferred materials, high-density polyethylene, for the collection pipelines. While it is suggested that the pipelines can be cleaned, there is no assessment of how difficult this has proved elsewhere and what occurs if blockages cannot be removed or if cleaning causes further damage.
On page 51 of the DPEMP, leachate evaporation ponds are proposed, but without any details about securing them against one-in-one-hundred-years flood events. The ponds, will be inadequately lined with compacted clay and one 2.5mm layer of HPDE. This is totally unacceptable.
The risk of surface water flooding onto the top of the C-cell is to be averted solely by use of surface-water cut-off drains. The plan gives no details about how the proponent will ensure that the drains never become blocked. A groundwater relief system is proposed, to prevent pressure which could damage the C-cell liner. There areno details about how system will be maintained and staffed/monitored so that it is ready for operation every day.
Although very unlikely, there is a possibility of catastrophic failure of the leachate barrier through a major breach caused by the water table rising, seismic activity, an accident involving heavy machinery or explosives. This possibility was never considered in the assessment process and consequently the project was approved without any contingency plans for catastrophic failure.
If another C-cell is proposed, a detailed design should be submitted along with the development application and be subjected to scrutiny by the general public and independent experts. Every element of the leachate barrier system must be detailed, every possible risk involved with its operation considered, and safety measures proposed, with back-up plans.
3. The failure to have other potential sites properly investigated
It is clear that the Copping site was not chosen in a rigorous selection process but simply by virtue of the applicant owning and operating the existing landfill facility demonstrating that other existing landfill sites in southern Tasmania were not acceptable. No study was done to compare Copping with other landfill sites statewide or undeveloped sites.
The 1993 HMCA Regional Greenfield Landfill Study was used by SWS to justify the selection of Copping as a level three landfill site. A new assessment should have been done to benefit from scientific advancements in the past twenty years and specifically aimed at assessing sites for a level three facility.
SWS has claimed there are potential benefits to the community through cleaning up dangerous and inappropriately stored waste, and that many industries support and require the services of a C-cell. These claims are not in any way verified through any rigorous studies and no attempt is made to identify possible negative impacts on other industries such as aquaculture, farming and tourism and the social impacts on surrounding communities.
4. Lack of a hazardous waste strategy
The public uproar over the proposed Copping C-cell has brought to light the embarrassing fact that Tasmania does not have a specific hazardous waste strategy. The TCT does not rule out that a C-cell may be a necessary but unfortunate last resort when dealing with some hazardous waste. But it is vital that a statewide strategy is in place to ensure that all possible environmentally sound alternatives are considered and encouraged before hazardous waste is put into landfill and becomes the first option, removing the incentive to develop more environmentally sound options.
Apart from having legislation to ensure hazardous waste is handled and transported safely, the state government does little to ensure that our most dangerous waste is dealt with in the most environmentally sound way. It must develop a strategy to assist and possibly compel producers to reduce production of hazardous waste and to reuse, recycle or treat it. It should assess whether government incentives are needed to assist industries to develop cleaner production processes or to research re-treatment methods.
The TCT has written to the Tasmanian government urging it to develop a state-wide hazardous waste strategy, along the lines recommended in the ‘Current and Future Controlled Waste Practices in Tasmania Draft Report’, written for the government in 2008 by Sustainable Infrastructure Australia. It recommends a number of alternatives to dumping hazardous waste into landfill, which may also be financially viable, such as incineration, high temperature sterilization, rendering, composting, neutralization and chemical decomposition through heating.
Peter McGlone
Director
Tasmanian Conservation Trust