Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 372
Title: Pollution Reduction Program: Implementation of Odour Reduction Measures
Start date: 01 Apr 2023
 
Licence Condition
The objective of this Pollution Reduction Program (PRP) is to implement measures to minimise or prevent offensive odour emissions from the premises to achieve compliance with section 129 of the Act. The EPA may utilise the information provided under this PRP to include additional conditions in this EPL. This PRP refers to documents titled U11-8 Odour Risk Reduction Options Study Georges River Plants – Summary Report (Sydney Water, May 2022) and U11-7 Odour Risk Reduction Study Georges River Plants (Sydney Water, December 2021) as well as the appendices attached to these reports (the ‘Odour Study Reports’). The ‘Study Area’ is demarcated in the Project Plan required by Condition U11.2 (as then).
The licensee must review the best practice recommendations detailed in the document titled Pollution Study: Odour Risk Reduction Study at Liverpool, Glenfield and Fairfield STPs and surrounding sewer network Best Practice Paper (Stantec, October 2021) and by no later than 30 June 2023, the licensee must submit a report outlining the outcome of the review, including a revised list of best practice recommendations and an implementation timeframe. Any recommendation that licensee identifies cannot be implement must be clearly and adequately justified why it cannot be reasonably and feasibly implemented either currently or in the future The licensee must report to the EPA the progress made towards implementation of the best practice recommendations as per the implementation timeframe on a 6 monthly basis.
The licensee must complete the odour mitigation actions outlined below (1-7) by 30 June 2025*. The licensee must update the EPA on the progress of all actions no later than every 6 months from the commencement date of the PRP until the completion of the work required under this condition. The licensee must advise the EPA within 3 months of completing all actions, outline any odour performance outcomes or further actions required to prevent or minimise odour from the identified source(s), including their estimated timeframes. The licensee must install adequate automated water cannons in the Glenfield storm tanks so that sludge can be effectively removed as soon as possible after wet weather events that utilise the storm tanks. The licensee must install an automated feed flushing arrangement for the Glenfield storm tanks that avoids sludge exposure by retaining and circulating liquid during tank draining. To ensure peak dry weather flow from the primary effluent pump station does not flow to the oxidation pond at Liverpool STP, the licensee must install either adequate pumping capacity with redundancy or manage these high peak flows through the secondary process.  The licensee must repair and optimise ductwork and covers on primary sedimentation tanks at Liverpool STP. The licensee must develop wet and dry weather flow management options for the oxidation pond at Liverpool STP and network. The licensee must complete commissioning and installation of a permanent odour control unit at SP0213 and SP0419 and validate performance of odour control units as meeting or exceeding the minimum standards specified in the Sydney Water’s most up to date technical specifications for odour control units. The licensee must complete flow control optimisation of the Georges River Effluent Diversion Scheme (GREDS) including changes to the Integrated Instrumentation, Control, Automation and Telemetry System (IICATS) and Supervisory Control and Data Acquisition (SCADA) and automation of critical control valves. *With the exception of the odour control unit at SP0419 which must be completed by 31 May 2028.
Implementation of Best Practice Recommendations
Implementation of odour mitigation infrastructure and actions
Implementation of plant assessments and studies
The licensee must complete the assessments or studies outlined below (1 – 5) by no later than 31 December 2023. The licensee must provide the EPA with a report of the outcomes of all actions in this condition within 3.5 months of completion and include recommendations for further works required to minimise odour from the identified source(s). The licensee must complete a performance and capacity assessment for the Glenfield STP and Liverpool STP wet scrubbers. The scrubber assessments must be completed by an appropriately qualified expert and must determine the required scrubber air flow rate, size and efficiency for each STP to meet current and future needs. Should the assessment determine the scrubber performance and capacity is not adequate, the licensee must consider and recommend options to meet this air flow rate, size and efficiency and propose a timeframe to implement the recommendations. The licensee must complete a trial of sodium hypochlorite dosing into the Liverpool STP oxidation pond during wet weather. This trial must cover a range of wet weather operational conditions and where possible, a minimum of 4 wet weather events. The licensee must assess the feasibility of either converting induct/educt vents to induct only vents or installing passive odour control units at a minimum of 3 Discharge Maintenance Holes vent shafts within each Study Area of Glenfield, Fairfield and Liverpool. The licensee must complete a detailed options study for covering, extracting and treating odours at the Fairfield inlet works. This must be completed by an appropriately qualified expert. The licensee must complete a detailed options study to reduce the odours from the PSTs following wet weather events and during emptying and cleaning of the PSTs.  
Evaluation program
The licensee must implement an Odour evaluation program for the purpose of evaluating the effectiveness of the Odour Reduction Measures implemented under this PRP. This must include but is not limited to: Providing a monitoring and evaluation program plan to the EPA by no later than 30 June 2023 designed to enable Sydney Water to provide a report under conditions U3.6, and incorporation of any feedback provided by the EPA. Monitoring of changes in odour emissions related to odour reduction measures implemented under this PRP, in accordance with plan developed under U3.5.1. Evaluation of odour complaints and reports received in accordance with the Odour Complaints Analysis methodology used in U11-8 Odour Risk Reduction Options Study Georges River Plants – Summary Report (Sydney Water, May 2022), including determination of any relationships between odour complaints and odour reduction works completed under this Pollution Reduction Program. Undertake regular proactive community engagement in the Study area with a frequency determined by community feedback but yearly as a minimum. Engagement must provide opportunity for community feedback and report on community concerns regarding odour management in each respective STP Study Area.
By no later than 31 December 2026, the licensee must provide a report on the evaluation program under U3.5 (the Evaluation Report). This report must determine, for the Liverpool STP, Glenfield STP, and Fairfield STP the effectiveness of the measures implemented under this PRP in minimising or preventing odour emissions and offsite odour impacts at each STP and associated study area . The evaluation should consider the level of compliance risk, including any areas of uncertainty and the basis used to make this determination.
Long term odour mitigation options
The licensee must identify and scope out all odour mitigation measures not considered or implemented as part of this PRP for odour reduction within the Malabar Sewage Treatment System for the purpose of compliance with s129 of the Act. This must include an assessment of potential reduction in odour impact as well as the practical steps required to implement each option. The licensee must provide the EPA with a long-term odour mitigation report by no later than 30 March 2025. The licensee must give consideration to, but is not limited to the following options: Permanent ventilation with odour control for the Belmont Rd Carrier and Glenfield Campbelltown Submain Construction of new inlet works at Glenfield and upgrade of secondary processes including reconfiguration of the operation of the storm tanks to minimise odour generation For the Glenfield storm tanks: covering the tanks, removal of the tanks, and conversion to a covered storage system, and optimization of flow management to avoid odour generation For the Liverpool oxidation pond: covering the pond, removal of the pond, and conversion to a covered storage system, and optimization of flow management to avoid odour generation Ensure the draining of the low spot in the rising main from SP0419 is monitored and controlled.  Upgrade capacity in the system (treatment or network) in response to growth that also assists to mitigate odour issues  Wastewater recycling and reuse options.
The purpose of this condition is to identify the full range of long-term options. Options should not be excluded at this stage on a feasibility or funding basis. Assessment of the feasibility and reasonableness of implementing long-term options will only be required depending on ongoing compliance with s129 and the risks indicated by the Evaluation Report under U3.6.