Background
The waste facility’s proximity to residential areas, conservation wetlands, and the Brunswick and Wellesley Rivers means that contemporary and appropriate waste management practices are essential to protect the environment and human health.;
The Stanley Road waste management facility (WMF) provides waste management services to the City of Bunbury, the Shire of Harvey and commercial waste operators. Other activities include the recycling of construction and demolition waste, a community drop off waste and recycling facility and a refund point for the container deposit scheme.
Landfilling at the site commenced in 1990. The landfill cells at the facility are unlined and over time, the waste which has been disposed of at the facility has decomposed. Some of the components of this decomposed waste have seeped in liquid (known as leachate) from the landfill into the groundwater beneath the unlined cells and subsequently migrated into the surrounding areas.
Licensing activities
Show moreLandfilling in Western Australia has an extensive history. Contemporary controls on landfilling operations are quite different to practices in the 1980’s and 90’s. By their nature, unlined landfill cells have the potential to leach contaminants into the environment.
DWER has worked proactively with the Bunbury Harvey Regional Council to address the current leachate management situation, culminating in a licence amendment process in May 2018. At that time, Bunbury Harvey Regional Council requested approval to create a third unlined cell at the landfill to fill a valley between the two existing unlined cells that would create a physical platform on which the proposed new contemporary landfill cells will be placed.
DWER determined that due to Bunbury Harvey Regional Council’s increased recovery rates, the residual waste was less likely to decompose easily, and therefore the leachate that would be generated by the additional cell would not worsen the existing groundwater contamination.
To further minimise the impacts on groundwater, the licence that was granted when approving the new landfill cell required the unlined cells to be ‘capped’ by 30 June 2022. Capping of the remaining cells is the primary and best control available to minimise the emission of leachate from the cells. The licence was granted on the basis that it would allow a new cell, with contemporary controls to be constructed on top of the existing cells which would be capped in an appropriate timeframe.
In December 2019, DWER granted approval for the construction of the new contemporary landfill cells at the site. To ensure future landfilling would not impact groundwater, DWER required these new landfill cells to be provided with engineered liners and a leachate capture and management system.
Bunbury Harvey Regional Council advised at the time of the application that the lined cells would be constructed and operational by January 2021.
As part of the 2018 decision, DWER recognised the ongoing risk that the unlined cells posed to the area surrounding the landfill and imposed a requirement for all landfilling in the unlined cells to cease by 30 June 2021.
Groundwater contamination
Show moreThe lots occupied by the Stanley Road WMF are currently classified under the Contaminated Sites Act 2003 (CS Act) as ‘contaminated – remediation required’.
The landfill site has an extended history under the CS Act, however the site’s classification was most recently updated on 15 September 2021. The classification is based on information submitted to the department up to August 2021.
On 10 August 2021, DWER received a mandatory auditor’s report confirming that the Stanley Road WMF is a source of per-and-polyfluoroalkyl substances (PFAS) in groundwater, which has migrated off-site to the west of the landfill to affect adjacent land. Parcels of land to the west of the landfill, including the neighbouring sand mine and adjacent road reserves, are being regulated under the CS Act as ‘affected sites’. Under the CS Act the party responsible for remediation of a source site is also responsible for remediation of any affected sites.
The concentrations of PFAS identified to the west of the landfill do not pose an immediate risk to the public as DWER understands that there are no public or private bores in the immediate vicinity of the landfill site that are used for the purposes of drinking water. Other water bores in the vicinity are used for irrigation and are generally not suitable for drinking water purposes. In September 2021, DWER requested that Bunbury Harvey Regional Council engage with residents of nearby properties to the west of the site to determine whether private irrigation bores may be impacted with PFAS.
Bunbury Harvey Regional Council completed a doorknock bore survey of approximately 200 residential properties to the west of the landfill to identify private bores and their use, and to offer to test bore water quality. A total of 196 houses were visited and 75 bore water samples were collected.
PFAS (specifically PFOS + PFHxS) was detected in 12 residential bores at concentrations below the drinking water criteria. A PFAS concentration above the drinking water criteria was detected in one bore. The bore is not used as a drinking water source. The concentrations detected in all residential bores were below criteria for non-potable uses such as garden irrigation.
The findings of residential testing indicated that while there are detectable levels of chemicals in groundwater sampled from within the residential area, the groundwater is safe for garden irrigation use.
If you are concerned about the levels of PFAS that are present in the water you use on your garden, it is recommended that a conservative approach be taken, with bore water not to be used for stock or vegetable garden watering.
As a requirement of the site’s classification under the CS Act, Bunbury Harvey Regional Council’s environmental consultants are continuing to investigate and monitor the impacts of PFAS, and other contaminants associated with landfill leachate, in the vicinity of the Stanley Road WMF.
Environmental Protection Notice
Show moreOn 5 July 2021, an Environmental Protection Notice (EPN) was given to Bunbury Harvey Regional Council to require it to control or abate emissions of leachate from the unlined landfill cells into groundwater.
The effect of the EPN is to prioritise the closure and capping of the unlined cells at the Stanley Road WMF, while allowing the acceptance of kerbside bins from the local area. Had DWER not issued the EPN to override licence conditions, there would have been a serious risk of kerbside bins not being collected from community residents.
The EPN allows only certain types of inert and low risk waste to continue to be accepted into the unlined landfill. DWER has taken this approach in order to minimise the risk to the environment.
At present, DWER understands that Bunbury Harvey Regional Council has not progressed past phase two of five capping stages. DWER will be prioritising the capping of the remaining cells as this is the primary and best control available to minimise the emission of leachate from the cells.
On 3 September 2021, DWER Compliance Officers conducted an inspection at the Stanley Road WMF to assess compliance with the EPN and licence conditions. Several potential non-compliances with the EPN and the licence conditions were identified. A number of follow-up site visits have taken place and DWER is continuing to engage with the Bunbury Harvey Regional Council to address outstanding compliance matters.
What is happening now?
Show moreDWER understands from the City of Bunbury and the Shire of Harvey that waste will continue to be collected as normal from residential premises within the Shire of Harvey and the City of Bunbury.
DWER acknowledges that the EPN has imposed restrictions to wastes that can be accepted at the WMF, and that this has impacted local commercial waste operators. Typically, commercial putrescibles waste is likely to generate larger volumes of leachate than residual source segregated municipal waste.
Commercial waste operators may wish to search DWER’s website for alternative solutions for landfill disposal.
DWER has required that the Bunbury Harvey Regional Council provide DWER a clear plan to address the closure and capping of landfill cells.
In considering any potential amendment to the EPN, DWER will have consideration of the ongoing impacts of leachate, the structural stability requirements for the new cells and for compliance with the relevant regulatory instruments.
The EPN does not impact recycling activities that are taking place at the premises or the approval to build the new contemporary landfill cells. These activities can continue to be undertaken in accordance with the conditions of the existing licence.
DWER recognises that sensitive receptors and pathways can change over the time that a licence is in force and DWER’s responsibility is to ensure that the assessment of potential impacts on the environment and public health remains current and that licence conditions remain effective at mitigating risk.
On 27 June 2022 DWER determined to partially renew Licence L8949/2016/2. Category 62 (solid waste depot) and Category 13 (crushing of building material) activities were renewed with only minor amendment to the previous licence conditions. Conditions allowing the disposal of waste within the putrescible landfill at the premises were removed from the licence. The removal of these conditions was due to capacity of the unlined landfill cell being exhausted. The risk assessment determined that the risk to human and environmental health, from continued emission of leachate from the unlined cells, was unacceptable. Category 64 activities remain on the licence to allow for the construction of the new lined landfill cells only.
The renewed licence is advertised on DWER’s website and is available for public appeal. The renewed licence and decision report can be accessed at https://www.der.wa.gov.au/our-work/licences-and-works-approvals/lwa-available-for-public-appeal. Or by searching for the licence number on the DWER’s Licence and Works Approvals page at https://www.der.wa.gov.au/our-work/licences-and-works-approvals/current…
Under the site’s CS Act classification, Bunbury Harvey Regional Council will undertake further investigations to determine the extent of off-site groundwater contamination. The full delineation of PFAS impacts will be determined and appropriately managed.
DWER is currently investigating potential non-compliance with the EPN and licence conditions and DWER Compliance Officers is working with BHRC to address ongoing compliance matters.
More information
Show moreDWER will update this page as new information comes to hand.
If you have any questions related to the Stanley Road Landfill, please email info@dwer.wa.gov.au and quote Stanley Road Waste Management Facility.
Should you have concerns around the site’s operation, please contact DWER’s Pollution Watch hotline on 1300 784 782.
If you have concerns regarding the status of the groundwater and or its uses, please contact the Contaminated Sites Hotline on 1300 762 982.
The Bunbury Harvey Regional Council’s Licence, including the previous decision is available on DWER’s website. The Environmental Protection Notice given to the site is available.