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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.
EPA has approved three EMPs – one from Hi-Quality, another from Western Soil Treatment (WST), and a third from Cleanaway Operations Pty Ltd. The proposed location of the WST facility is the Maddingley Brown Coal (MBC) site. The proposed location of Cleanaway’s Spoil Management and Reuse Facility is adjacent to Melbourne Regional Landfill in Ravenhall. EMPs are part of 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 the approved 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 assessment of Hi-Quality’s EMP (publication 1942)
Read EPA’s approval letter to Hi-Quality (PDF 411KB)
Read Hi-Quality’s EMP (PDF 11.5MB)
Western Soil Treatment’s (WST) EMP for the West Gate Tunnel Project
Read EPA’s assessment of WST’s EMP (publication 1962)
Read EPA’s approval letter to WST (PDF 408KB)
Read WST’s EMP (PDF 12.4MB)
Cleanaway Operations Pty Ltd’s (Cleanaway) EMP for the West Gate Tunnel Project
Read EPA’s assessment of Cleanaway’s EMP (publication 1970)
Read EPA’s approval letter to Cleanaway (PDF 273KB)
Read Cleanaway’s EMP (PDF 8.4MB)
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 443KB)
Questions and answers
The EMPs approved last year were assessed by EPA and made with some requirements for further technical information to be provided before the sites could receive spoil from the West Gate Tunnel Project.
The newly approved EMPs now contain all required information in one complete document.
EPA is confident the administrative error in the earlier EMPs has been addressed.
The Regulations were introduced by Government 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, the amount of waste generated can exceed the rate Victoria’s existing landfills can accept. This may also significantly reduce their future capacity.
The regulations were introduced to establish an appropriate framework for spoil from tunnel boring machines, produced continuously and in large volumes, to 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.
The sites have 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 per-and polyfluoroalkyl substances (PFAS) in tunnel boring spoil. 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. The proposals were also reviewed by an independent 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.
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.
The rate at which tunnel spoil will be produced at peak periods (11,000 tonnes per day) will exceed the rate at which landfills can accept waste through existing weighbridges (estimated 6,000 to 7,000 tonnes/day).
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.
Sampling and testing of the spoil take several days to complete. The results of testing are required to determine whether the spoil can be reused, contained onsite, or needs to be disposed of at a licensed landfill. In addition, the tunnel spoil will be wet and requires a large area to spread out to aid dewatering prior to reuse, permanent containment, or disposal to a licensed landfill; the space and infrastructure is not available at most landfills. Most landfill cells have relatively small operating ‘tipping faces’ where wastes are placed.
While some landfills are already licensed to receive this spoil, the amount of waste generated can exceed the rate Victoria’s existing landfills can accept. This may also significantly reduce the future capacity of these landfills. 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.
Landfills in Victoria currently accept between 4 and 5 million tonnes of total waste per year.
Landfills in metropolitan Melbourne currently accept approximately 650,000 tonnes of waste soils annually, the majority to Hi-Quality and Cleanaway Ravenhall.
EPA has processed multiple applications for soil disposal from various stages of the project. These applications cover a wide range of contaminants including PFAS. The permissions granted under the Regulations have authorised disposal at suitably licensed facilities.
Tunnel boring machine (TBM) spoil can contain contaminants, including 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.
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 a site with an EPA approved EMP.
Spoil will be laid out in bays and dewatered at an EPA approved EMP site while test results are processed. Depending on the test results, the spoil will either be available for reuse, deposited into the containment cell, or disposed to a licensed facility. Testing of the leachate (i.e., liquid formed by decomposed waste) will determine whether treatment of the water component is needed.
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, fast food packaging 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.
Why is there strong community concerns regarding PFAS in this spoil, despite EPA advising the levels of toxicity and contamination are low?
EPA understands that the community is concerned about PFAS because of coverage of PFAS contaminated sites around Australia. Other sites around Australia have high levels of contamination caused by extensive use of chemicals such as firefighting foams. Some of these sites have accessible groundwater used for agriculture etc., where there may be a risk if not managed. EPA has extensive data on pollution levels at these sites and the levels are typically thousands of times higher than the expected contamination levels in the West Gate Tunnel alignment.
EPA has also undertaken research which shows 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). As 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.
Sites receiving spoil must comply with an EPA-approved Environment Management Plan (EMP). The plan itself requires 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.
Each approved site has been designed specifically to manage the risks of low level PFAS containing soils. The design includes features to enable any water containing PFAS 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.
PFAS is persistent, meaning it doesn’t break down for a long time). PFAS also bioaccumulates and 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 in the spoil are expected to be a small fraction of the levels at sites where advisories have been put in place.
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.
The maximum acceptance criteria for PFAS at each site is reviewed by EPA and includes a rigorous assessment of the design and an understanding of the site. The maximums are dictated by the site-specific ground conditions and engineering designs provided by the applicant. Based on the proposed designs the sites are engineered to accept a maximum of 7 micrograms per litre. This should accommodate ten times more than the level of expected TBM spoil.
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 have been set based on extensive risk assessment, modelling and calculations, having consideration of unique factors including leachate collection and cell design. 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.
Final contamination levels can only be determined once spoil is taken to an approved site, dewatered and further samples are analysed. The spoil may be classified as clean fill material depending on the sampling results.
EPA uses authoritative sources to inform its decision making. These sources are documented in the National Environment Management Plan for PFAS (the PFAS NEMP).
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.
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 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.
No. Under regulations , landfill levy only applies to industrial and municipal waste received at a landfill site. Spoil received and contained at these sites will not be subject to landfill levy.
The site will appropriately treat, manage, segregate and (where not suitable for immediate re-use) contain the material so that it may be reused in future if a suitable use can be established.
The testing regime required is very extensive and will continue beyond the operational life of the approved facility. As testing reveals more information about actual PFAS levels, it can be adjusted with agreement from EPA. The testing regime is set out in the EMP and is a legal requirement. Results will be provided to EPA and an independent auditor for oversight.
Results will be the commercial property of the project partners. They must be provided to EPA periodically and at any time on request and EPA will maintain regulatory oversight of all results. EPA is not able to provide copies of results directly to community but will encourage the project partners to. Note that any results would need some degree of technical expertise to properly interpret.
The EMP and other requirements of the TBM Regulations must be complied with by law. They are enforceable with severe penalties and EPA can issue remedial directions for any non-compliances. EPA officers can visit the site at any time without notice. Community members can lodge a pollution report with the EPA Pollution Watch line on 1300 372 842 (1300 EPA VIC).
Each site has other EPA licensed activities ongoing meaning annual reporting is required and auditing is ongoing.
How will transport be managed? 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. All truck movements will be recorded and records reconciled to ensure all 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.
Truck routes and operating hours are a matter for planning controls and EPA does not regulate which roads will be used.
The spoil 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 is kept to a minimum. Air quality monitoring will also be undertaken to assess that dust control methods are working and are effective.
Parwan creek is an ephemeral creek that runs through the WST 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.
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.
Why was the licence for Maddingley Brown Coal amended just before the EMP for Western Soil Treatment was approved?The proposed spoil processing and containment area was excised from MBC’s licence to ensure that the existing licensed landfill operations can be regulated separately. It was also amended to enable discharge of treated leachate to existing dams in accordance with specific conditions.
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.
For transparency the regulations require an approved EMP to be published on EPA's website. EPA is committed to being transparent about its role under the Regulations and will only approve an EMP if satisfied that the plan, together with the Regulations, adequately protects human health and the environment from pollution and waste.
The design behind the application is complex and designers consider their proposed solutions to containing PFAS to be their own intellectual property. This is particularly important during a competitive tender process where applicants may wish to gain a commercial advantage with better designs. EPA is required by law to ensure it does not publish information that is commercially sensitive.
Issuing approvals for the 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 and does not make the ultimate decision on where spoil will go.
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.
- Call us on 1300 372 842. We’re here 24 hours.
- Report pollution online. Register and report pollution through the EPA Interaction Portal.
Reviewed 13 May 2021