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Environment Management Plans (EMPs)

The Environment Protection (Management of tunnel boring machine spoil) Regulations 2020 outline what an Environment Management Plan (EMP) must include before EPA can consider it.

An EMP must include:

  • a description, map and details of the location of the premises and the processing site receiving the tunnel boring machine (TBM) spoil
  • an assessment of the risk of adverse impacts from the receipt, storage, treatment and containment of the spoil
  • management arrangements and operating conditions designed to minimise the risk of any adverse impacts from these activities
  • ongoing environmental auditor requirements.

Approved EMPs

EPA has received Environment Management Plans (EMPs) from three businesses: Hi-Quality, Maddingley Brown Coal and Cleanaway. The EMPs were part of their applications to receive TBM spoil from the West Gate Tunnel Project.

EPA is not responsible for the ultimate decision on where TBM spoil from the project will be taken.

EPA will strictly monitor compliance with any approved EMP and hold any site receiving spoil from the West Gate Tunnel Project to account.

We are satisfied that these EMPs, together with the Regulations, adequately protect human health and the environment from pollution and waste.

Commercially sensitive information in an EMP

The Regulations require that commercially sensitive information contained in an Environment Management Plan is not published. EPA respects the rights of applicants to keep commercial sensitive information private, including information relevant to the tender process underway. 

As such some information from the documents available on this webpage has been redacted. EPA will seek consent to publish this material at the conclusion of the competitive process to select a site.

Hi-Quality’s EMP for the West Gate Tunnel Project

Read EPA's summary (PDF; 429KB)

Read EPA’s assessment of Hi-Quality’s EMP (publication 1902)

Read EPA’s approval letter to Hi-Quality (PDF; 198KB)

Read Hi-Quality’s EMP (PDF; 17.9MB)

Maddingley Brown Coal’s EMP for the West Gate Tunnel Project

Read EPA's summary (PDF; 493KB)

Read EPA’s assessment of Maddingley Brown Coal’s EMP (publication 1903)

Read Maddingley Brown Coal’s EMP (PDF; 4.2MB)

Read EPA’s approval letter to Maddingley Brown Coal (PDF; 155KB)

Read EPA's EMP amendment assessment report – Maddingley Brown Coal (publication 1917)

Read EPA's Amendment Approval Letter - Maddingley Brown Coal (PDF; 164KB)

Cleanaway's EMP for the West Gate Tunnel Project

Read EPA's summary (PDF; 425KB)

Read EPA’s assessment of Cleanaway’s EMP (publication 1914)

Read Cleanaway's EMP (PDF; 2.05MB)

Read EPA’s approval letter to Cleanaway (PDF; 153KB)

Classification

EPA classifies waste materials and specifies how they should be managed and transported. We have issued a Classification to enable the transport and management of per-and poly-fluoroalkyl substances (PFAS) contaminated tunnel boring machine spoil from the site. Spoil includes soil, rock, sludge and water.

Under the Environment Protection (Management of Tunnel Boring Machine Spoil) Regulations 2020 a site must have a number of controls in place to receive tunnel boring machine spoil, including:

  • an EPA-approved Environment Management Plan (EMP)
  • a containment system designed in accordance with the approved EMP and not used to contain any other material other than TBM spoil
  • that the material be received on an impervious surface and secured to not allow for public access
  • leachate testing and management in line with the EPA-approved EMP.

Read the Classification (PDF; 442KB)

Questions and answers

  • Why do we need new Regulations?

    The Regulations were introduced in response to current and anticipated future use of tunnel boring machines (TBMs) by Victorian infrastructure projects, including the West Gate Tunnel project. While some landfills are licensed to receive this spoil, generation can exceed the rate of waste acceptance of Victoria’s existing landfills and significantly reduce their future capacity.  

    The Regulations were introduced to establish an appropriate framework so spoil tunnel boring machine spoil, which is produced continuously and in large volumes, can be safely used or contained. The spoil must be removed, transported, tested and deposited in a manner that minimises any risks to human health and the environment. 

  • How will the community be protected?

    Each site approved for West Gate Tunnel spoil has been rigorously assessed to ensure all environmental risks are addressed. This includes groundwater and surface water quality, air quality, and noise.  

    Each facility has been designed to specifically address risks associated with low levels of PFAS in tunnel boring spoil. This will make them the first facilities in Australia to be specifically designed to accept and deposit low level PFAS containing soils. This approach ensures the design focuses specifically on the known characteristics and risks of PFAS.

    EPA’s scientists and engineers have rigorously reviewed each proposal from the perspective of public health and environmental protection. Each proposal was reviewed by an EPA appointed auditor prior to review by EPA experts. Each proposal is supported by an extensive Human Health and Environmental Risk Assessment that focuses on the unique characteristics of individual sites.

  • How much spoil will the West Gate Tunnel Project generate?

    The West Gate Tunnel Project alone is due to create 3 million tonnes (1.5 million m3) of waste soils from the tunnel alignment over an 18-month period.

    Landfills in Victoria cannot absorb an additional 3 million tonnes of waste soils within an 18-month period, without exhausting existing capacity in the market. In addition, the tunnel soil will be wet and requires a large area to spread out to aid dewatering prior to deposit in a cell - the space and infrastructure is not available at most landfills. Most landfill cells have relatively small operating ‘tipping faces’ where wastes are placed.

    The rate at which tunnel spoil will be produced at peak (11,000 tonnes per day) will exceed the rate at which landfills can accept waste through its existing weighbridges (estimated 6,000 to 7,000 tonnes/day). 

  • Why can’t tunnel boring spoil be disposed of at existing landfills?

    Tunnel boring activity rapidly and continuously generates large quantities of waste material (spoil) in the form of rock, soil and groundwater, mixed together in a paste or slurry. The spoil must be removed, transported, tested and deposited in a manner that minimises any risks to human health and the environment.

    While some landfills are licensed to receive this spoil, generation can exceed the rate of waste acceptance of Victoria’s existing landfills and significantly reduce the future capacity of these landfills.

  • How much waste does Victoria send to landfill annually?

    Landfills in Victoria currently accept between 4 and 5 million tonnes of total waste per year.
  • How much soil currently goes to landfill in Victoria?

    Landfills in metropolitan Melbourne currently accept approximately 650,000 tonnes of waste soils annually, the majority to Hi-Quality and Cleanaway Ravenhall. 
  • Has contaminated soil on the project been classified for removal by EPA?

    EPA has processed multiple applications for soil disposal from various stages of the project, in particular for works at the portals. These applications cover a wide range of contaminants including PFAS. These permissions have authorised disposal at suitably licensed facilities. 
  • What are the risks of tunnel boring machine (TBM) spoil?

    Tunnel boring machine (TBM) spoil can contain contaminants, including per- and polyfluoroalkyl substances (PFAS). However, TBM spoil comes from depths around 20 to 40 metres below ground level, where contamination levels tend to be low. 

    Requiring duty holders to comply with an EPA approved Environment Management Plan (EMP) and strict conditions set out in the new Regulations reduces the already low risk to the health of the community and the environment.

  • What is PFAS?

    PFAS (per-and polyfluorinated alkyl substances) are a group of manufactured chemicals used in many industrial and household products. There are low background levels of PFAS in the environment across Victoria and around Australia.

    Most of us are exposed to very low levels of PFAS in everyday life from common items including some non-stick cooking equipment, furniture and carpets treated for stain resistance, clothing and fast food or packaged food containers.

    The Environmental Health Standing Committee’s (enHealth) guidance outlines there is some evidence that PFAS exposure has been associated with mildly elevated levels of cholesterol, kidney function and some hormones, PFAS has not been shown to cause disease. In line with enHealth advice, EPA takes a precautionary approach to PFAS which means reducing exposure whenever possible.

     
  • Should the community be concerned about PFAS in the spoil?

    Media coverage of PFAS contaminated sites around Australia has caused community concern about PFAS.  These high levels of contamination were caused by extensive use of firefighting foams.  EPA has extensive data on pollution levels at these sites and the levels are typically thousands of times higher than the contamination found in the West Gate Tunnel alignment.

    EPA has also undertaken research to show that there are low levels of PFAS present across most populated or industrialised areas. This is because PFAS is present in common household and industrial products (textiles, plastics, etc) and given it doesn’t break down easily, it can be detected at very low levels over a long time.  

    EPA will continue to monitor the presence and impacts of all emerging chemicals in our environment and continue to be a part of international scientific developments.

  • What controls will be in place to manage those risks?

    The site receiving this spoil must comply with an EPA-approved Environment Management Plan (EMP). The TBM Regulations require the duty holder to comply with strict conditions designed to protect human health and the environment, including that the processing area for the spoil is on an impervious surface.
  • How will leachate be prevented from entering waterways, wetlands and ground water?

    Each approved site has been designed specifically to manage the risks of low level PFAS containing soils.  The design includes features to enable any PFAS containing groundwater to be collected and treated prior to the soil being deposited in a specially designed containment cell.  Cell design features include multiple layers of liner to ensure any residual water can be collected and removed rather than permeating the rock beneath the cell.
  • How noisy will the transportation trucks be on our roads? Will the trucks work into the night?

    EPA has required the waste generator to transport the soil in trucks fitted with equipment that ensures no leakage or dust.  All truck movements will be reconciled to ensure all waste goes to the correct location. The planning restrictions on the project set out truck routes and other requirements outside of the approved facilities.
  • What are the effects of PFAS on wildlife? Does EPA monitor this?

    The main characteristics of PFAS are that it is persistent (doesn’t break down for a long time), it bioaccumulates and it is soluble.  This means that the key risk is to sensitive aquatic ecosystems.  Should PFAS enter sensitive aquatic ecosystems above accepted levels, it can build up in the food chain.  In waterways near highly polluted sites, authorities in Victoria and other States have issued advice to limit the consumption of fish or other affected animals.  The contamination levels expected to be received at approved sites are many orders of magnitude lower than sites where advisories have been put in place.
  • How are these design elements different to a normal landfill?

    There are several landfill types in Victoria including municipal waste landfills and landfills for solid inert waste such as soils.  

    EPA sets out generic engineering requirements for each type.  Each landfill cell is designed to meet the best practice environment management requirements and an EPA appointed auditor approves the design.  

    With the sites approved to take TBM spoil, generic designs are not used because we require the design to protect the environment from PFAS specifically.  The designs are engineered, modelled and auditor approved based on everything that is known about PFAS, making them unique in Australia. 

  • Why have the threshold levels of PFAS been set where they are and are they appropriate for the site?

    The threshold acceptance criteria for each site has been set based on extensive risk assessment, modelling and calculations, having consideration of unique factors including leachate collection and cell design.  Based on these factors, each site proposed a maximum threshold which is well above what is expected from the TBM spoil.  The threshold level is driven by the design characteristics, more so than the expected levels.  This is a good thing, because it means the facilities are ‘over engineered’ and provide a significant safety margin.  The maximum concentrations in the alignment are expected to be up to 0.7 micrograms per litre based on the groundwater testing undertaken. 
  • What level of PFAS has been approved for each site?

    The maximum acceptance criteria for PFAS at each site is reviewed by EPA and includes a rigorous assessment of each design and an understanding of each site.  The maximums are dictated by the site-specific ground conditions and engineering designs provided by each applicant.  Based on the proposed designs, all three sites  are engineered to accept a maximum of 7 micrograms per litre, which is ten times the highest level in groundwater in the tunnel alignment.

  • If the levels of PFAS are expected to be so low, why can’t this spoil be classified as cleanfill?

    EPA has published a ‘cleanfill’ criteria of 4 micrograms per kilogram in soil. The project has been unable to demonstrate that the spoil will meet this level, so it must be taken to an approved site and dewatered to determine the final contamination level.
  • Are these levels of PFAS consistent with national standards?

    EPA Victoria uses authoritative sources to inform its decision making.  These sources are documented in the National Environment Management Plan for PFAS (the PFAS NEMP).  

    Multiple standards are covered including drinking water, recreational water and soil criteria such as ‘open space’ or ‘residential’.  Using these guideline values, it is clear that the contamination levels in the West Gate Tunnel alignment are expected to be very low - well below the Recreational Water Quality value set by the Australian Government Department of Health, meaning they are suitable for recreational activities such as swimming.   

     
  • Will the disposal sites for the tunnel boring machine spoil be subject to the landfill levy?

    No. Sites approved under the Regulations to receive this type of spoil are not areas engineered and licensed for landfilling of the various types of industrial and municipal waste, so spoil received and contained at these sites will not be subject to landfill levy. 

    The sites will appropriately treat, manage, segregate and contain the material so that it may be reused in future if a suitable use can be established.  

  • Who determines the national standards?

    National guidance levels are set by various authoritative bodies depending on their expertise.  For example, guidance levels for daily consumption of PFAS are set by Food Standards Australia and New Zealand (FASANZ), whereas drinking water levels are set by the Department of Health.  These values have been used by the Heads of EPAs to develop broader guidance values such as landfill acceptance criteria.
  • What’s the ongoing testing regime; will there be one?

    The testing regime required is very extensive and will continue beyond the life of the approved facility.  As testing reveals more information about actual pollution levels and risks, it can be adjusted with agreement from EPA. The testing regime is set out in the EMP and is a legal requirement.
  • Will testing results be made available to the public?

    The project will own the sampling results, however EPA will seek to ensure they are available to the public.
  • How will EPA ensure ongoing compliance at the site?

    The EMP and other requirements of the TBM Regulations must be complied with and are enforceable with severe penalties.  EPA officers can visit the sites at any time without notice.  Complaints can be made to the EPA Pollution Watch line.

    Each site that has tendered to take the spoil has other EPA licensed activities ongoing at those sites.  This means EPA inspectors visit the sites regularly, annual reporting is required and auditing is ongoing.

     
  • Will EPA also continue to monitor the transportation of the waste so that it doesn’t create a hazardous spill on our roads?

    EPA has required the waste generator to transport the soil in trucks fitted with equipment that ensures no leakage or dust.  Truck movements will be reconciled to ensure waste goes to the correct location.

    In the unexpected event of a crash leading to the loss of containment of some spoil, standard practices will be employed to prevent waste soils entering the stormwater system.  At the levels expected, there is no risk to human health and the material can be safely handled by personnel.

  • What happens after the spoil comes out of the tunnel?

    The spoil will emerge from the TBMs on a conveyer belt into a large shed at the site in Yarraville. The spoil will then be transported to the disposal sites.

    At the disposal site it will be laid out in bays and dewatered while test results come through. Once the test results are known it will be deposited into the containment cell. Testing of the leachate will determine whether treatment is needed. Each containment cell and leachate collection pond will be the subject of an ongoing testing and reporting regime set out in the EMP.

  • How is the Parwan creek being protected?

    Parwan creek is an ephemeral creek that runs through the MBC site.  The design of the containment cell, dewatering bays and leachate collection system is designed to ensure there is no risk of PFAS from the facility impacting on the creek.  Highly conservative factors have been modelled to ensure risks to waterways are resolved.  Such highly conservative assumptions are needed because of the ability of PFAS to remain present in the environment for such a long time.  The leachate risks to groundwater and surface water have been the key considerations of the design and assessment.
  • Bacchus Marsh Grammar is so close to Maddingley Brown site, are the students safe?

    At the levels known to be in the tunnel alignment there is no risk to human health.  The levels are below the recreational water quality guidelines.  The school is more than 800m from the facility and the combination of very low levels, moisture content of the spoil, lack of odour and the distance means that there can be no risk to student safety from the spoil.  

    EPA understands truck movements and road dust can be an inconvenience to residents and potentially students.

     
  • What measures are in place to prevent dust from the sites blowing onto surrounding areas?

    The soil received from the tunnel will initially be wet, however dust suppression will be put in place to ensure any dust generation from the haul roads and stockpiles is kept to a minimum. Air quality monitoring will also be undertaken to assess that dust control methods are working and are effective.
  • Why has MBC submitted an amendment to its EMP? Why did EPA approve the original EMP?

    The original EMP submitted by Maddingley Brown Coal (MBC) was rigorously reviewed and was approved on the basis it met strict conditions designed to protect human health and the environment.

    MBC voluntarily submitted an amendment to their EMP which included updated designs for its containment cell and a change to their acceptance criteria. The updated designs include enhancements that go beyond the strict requirements outlined by the Regulations.

  • What engagement occurred on the Regulations?

    The Department of Environment, Land, Water and Planning (DELWP) consulted EPA and other parts of government to ensure potential impacts to human health, planning and transport were considered. The Regulations did not require public consultation because no sectors of the community were identified on which significant impacts would be imposed by the Regulations.

    For transparency the Regulations require an approved EMP to be published on the EPA website. EPA is committed to being transparent about its role under the Regulations and may only approve an EMP if satisfied that the plan, together with the Regulations, adequately protects human health and the environment from pollution and waste.

     
  • Why have the EMPs been uploaded to the website redacted?

    The Regulations require that commercially sensitive information contained in an Environment Management Plan is not published. EPA respects the rights of applicants to keep commercial sensitive information private, including information relevant to the tender process underway.
    As such some information from the documents available on this webpage has been redacted. EPA will seek consent to publish this material at the conclusion of the competitive process to select a site.
  • What are the next steps?

    EPA has received and approved  three proposals. The approvals set strict requirements to protect the environment and the health of the community that Maddingley Brown Coal, Cleanaway and Hi-Quality would have to meet if they are selected through the tender.

    Extensive testing shows the levels of PFAS in the spoil from the tunnel boring are expected to be low and at safe levels for the community and the environment with appropriate controls as established by EPA.

    Issuing approvals for the three Environment Management Plans (EMP) is one step in a stringent process to select a site to take the soil from the West Gate Tunnel Project.

    There is still a tender process underway to choose a site, EPA is not involved in the tender process.

Find out more about the West Gate Tunnel Project

You can contact the West Gate Tunnel Project with questions or feedback about their works: 

You can contact EPA to make a report about noise, dust or other environmental impacts. 

Read next

West Gate Tunnel Project

West Gate Tunnel Project: EPA’s role

West Gate Tunnel Project and the environment

About PFAS

Reviewed 8 October 2020