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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 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

  • Regulation

    What is an Environmental Management Plan (EMP)?

    An EMP is a document that details the environmental risks and presents the controls and monitoring that will undertaken to minimise these risks to ensure human health and the environment is protected. It is also the document that EPA will use to regulate the construction and operation of the Bulla Spoil Facility.

    Will the proposals present any risks to the community?

    The Bulla Spoil Facility has been rigorously assessed by EPA’s scientists and engineers to ensure all environmental and human health risks are addressed. This includes groundwater and surface water quality, air quality, and noise.

    The 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.

    The site has been engineered to accommodate a PFAS concentration that is 10 times greater that the amount expected in the spoil from the tunnel boring machine. 

    How will EPA ensure ongoing compliance at the site?

    The EMP and other requirements of the Tunnel Boring Machine 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.

    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 facility provides 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. To put this in perspective, drinking water has a allowable PFOS concentration of 0.07 micrograms per litre and it is safe to swim in water with a PFOS concentration of 2 micrograms per litre.

    How will the EPA check that the soil sampling plan is being carried out?

    Regulation of the site will be done through onsite inspections, observations and monitoring by authorised officers and EPA scientists, as well as assessing reports provided to by the accredited Environmental Auditor engaged at the Bulla Spoil Facility.

    What are the repercussions for a failure to comply with the EMP?

    The repercussion will depend on the situation but can range up to prosecution. If a breach is identified, EPA would also issue remedial notices to ensure the breach does not occur again.

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

    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.

    Are these levels of PFAS consistent with national standards? Who determines national standards?

    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.

    How often will the EPA be checking for dust monitoring?

    Everytime an officer attends the site they will check compliance with dust requirements for the EMP. The officers will also be reviewing the data that will be submitted as part of the Environmental Auditor oversight of the operation. EPA officers will also be responding to any community reports of dust from the operation as well.

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

    No. Under regulations, landfill levy only applies to industrial and municipal waste received at a landfill site. Spoil received and contained at Bulla Spoil Facility will not be subject to landfill levy.

  • Testing

    What level of PFAS has been approved for the site?

    The maximum acceptance criteria for PFAS at Bulla Spoil Facility was reviewed by EPA and included a rigorous assessment of the design and an understanding of the site. The maximum concentrations are dictated by the site-specific ground conditions and engineering designs.  Based on the proposed designs a maximum concentration of 7 micrograms per litre was determined. This should accommodate ten times more than the level of expected TBM spoil.

    Will the soil testing results be released to the community and how long it will take for that data to be published?

    Yes. We will provide sampling data on a regular basis as it comes in from the project. Publishing of testing results will occur once we have arranged  them in a logical, understandable way. We aim to publish them as quickly as we can. We need to take into consideration how we  present this data in a meaningful way.

    Will the soil sampling plan be made available to the community?

    EPA is working with the project management team to make this information publicly available.

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 3 March 2022