Licence conditions for pollution studies and reduction program


  

Licence conditions for pollution studies and reduction programs

Summary
 
Licence number: 837
Title: PRP U26: Monitoring Program for the Ampol Wharf Drain
Start date: 27 May 2022
 
Licence Condition
EPA has received community complaints regarding the stormwater drain adjacent to the Ampol wharf on Silver Beach (Wharf Drain) for an extended period of time.  The complaints often reference a sheen, a dark colour, and a hydrocarbon odour. Recent EPA water sampling results are variable and have periodically identified the presence of low levels of hydrocarbons and BTEX which indicate the presence of small amounts of fuel in the drain.  The drain catchment captures the Ampol premises (part), a residential area, and the national park.   This PRP requires a period of routine monitoring of pollutant discharges from the Wharf drain (and other significant drains in the catchment) to identify any fuel related pollutants from the Ampol premises entering, and ultimately discharging from the drain.  Following the collation of a monitoring dataset, possible PRP outcomes may include additional monitoring, further investigations, stormwater treatment, or licence changes.
Unless otherwise agreed in writing by the EPA: 1. By 13 June 2022, the licensee must propose a suitably qualified independent expert(s) to the EPA for approval (approved expert). The proposal must include a CV and an explanation of the qualifications of why this person(s) or company has the qualifications to undertake the required work. 2. By 4 July 2022, the licensee must submit a proposed Pollutant Discharge Monitoring Program (Program) to the EPA for Approval. The program must be developed by the approved expert. 3. The licensee must revise the proposed Program by addressing any written comments provided by the EPA. 4. The proposed Program must include: a) A clear delineation of the catchment basin and drainage network that feeds into the Wharf Drain using maps, plans and / or diagrams. b) A proposed assessment of drain / pipeline integrity using CCTV and other methods to assess the condition of the stormwater management network on site. c) A proposed review of any existing information, including monitoring data and previous reports. d) Proposed water sampling and analysis: i) Monitored analytes must include, but may not be limited to, TRH, BTEX, and other appropriate compounds present in fuel products.. ii) Sampling of discharges at the Wharf drain as well as the separators located within the Right of Way on the southern side of Prince Charles Parade, separators located within Ampol premises near Gate 5, and at any other significant points of inflow to the drain. iii) Specific equipment and / or methodology to undertake routine or continuous sampling over a 3 month period to capture a range of operating and natural scenarios. That is, varied operations as well as tides and rainfall events where practicable, that would materially impact discharge water quality. iv) Sampling and analysis for each analyte in accordance with the ‘Approved Methods for the Sampling and Analysis of Water Pollutants in NSW’ (2004). v) The level of reporting for pollutant concentrations must be sensitive enough to detect pollutants at levels related to their environmental risk and the ANZG 2018 toxicant guideline value (where available) while having regard to the best available analytical practical quantification limits using available technology. e) Incorporate proposed routine air monitoring of Volatile Organic Compounds into the program of water sampling such that sampling of air and water are concurrent. Assessment of odours will be achieved through the interpretation of the air sampling results.  f) The expert undertaking the air sampling will make a qualitative assessment of the odours at times of sampling. The qualitative assessment must be undertaken and recorded by an olfactory trained person. g) Propose stakeholder consultation with Sutherland Shire Council in development of the monitoring program. 5. The licensee is to submit a final report on the approved program to the EPA 6 weeks after completion of the sampling component of the program. The report must include the items covered at 4 above and the following matters: h) a presentation and discussion of results as well as recommendations for next steps in the program. i) details of stakeholder consultation with Sutherland Shire Council in development and implementation of the program. j) details of the consideration of any community complaints, observations, or relevant data provided to Ampol. 6. Upon submission of the final report, the licensee must provide the EPA with its plans to update the Kurnell community on program outcomes and next steps. Note: The EPA intends to impose further conditions to this licence / PRP requiring implementation of next steps.
d)   Proposed water sampling and analysis: i)             Monitored analytes must include, but may not be limited to, TRH, BTEX, and other appropriate compounds present in fuel products.. ii)            Sampling of discharges at the Wharf drain as well as the separators located within the Right of Way on the southern side of Prince Charles Parade, separators located within Ampol premises near Gate 5, and at any other significant points of inflow to the drain. iii)          Specific equipment and / or methodology to undertake routine or continuous sampling over a 3 month period to capture a range of operating and natural scenarios.  That is, varied operations as well as tides and rainfall events where practicable, that would materially impact discharge water quality. iv)          Sampling and analysis for each analyte in accordance with the ‘Approved Methods for the Sampling and Analysis of Water Pollutants in NSW’ (2004). v)           The level of reporting for pollutant concentrations must be sensitive enough to detect pollutants at levels related to their environmental risk and the ANZG 2018 toxicant guideline value (where available)while having regard to the best available analytical practical quantification limits using available technology.   e)   Incorporate routine air monitoring of Volatile Organic Compounds into the program of water sampling such that sampling of air and water are concurrent. Assessment of odours will be achieved through the interpretation of the air sampling results. The expert undertaking the air sampling will make a qualitative assessment of the odours at times of sampling. f) Consider any complaints, observations, or relevant data provided by the community as part of the sampling data assessment. g)    Stakeholder consultation with Sutherland Shire Council in development of the monitoring program as well as consultation or updates to the Kurnell community, and other relevant stakeholders during the monitoring program. h)   Six weeks after completion of the sampling program propose a: i) final report incorporating all of the above monitoring which includes the presentation and discussion of results as well as recommendations for next steps in the program. ii) update to the Kurnell community on program outcomes and next steps. Due Date: 18 June 2022