Introduction
Community Environmental Monitoring have been evaluating the monitoring test results from the Alexandria Landfill which is licensed by the EPA as the St Peters Interchange since the
Westconnex construction project started. A few months ago the groundwater monitoring results were the focus of that assessment (See previous report). This evaluation focuses on the reported leachate monitoring test results from Transport for NSW environmental reporting page.
What is leachate?
Leachate is the liquid formed when rain water or ground water filters through wastes placed in a landfill. When this liquid comes in contact with buried wastes, it leaches, or draws out, chemicals or constituents from those wastes. Because leachate will contaminate other groundwater it must be treated and monitored.
Transport for NSW has a Leachate Treatment facility at the St Peters interchange that includes nitrification to convert ammonia to nitrate before discharging it as a trade waste to Sydney Water’s sewer collection system. NSW Environment Protection Authority (EPA)
requires Transport for NSW to monitor this material from a leachate sump located within the landfill. There are both quarterly and annual testing requirements for leachate. The annual testing
requirements are for more serious contaminants, like heavy metals, pesticides and volatile organic
carcinogens.
No evidence that Transport for NSW has been meeting monitoring requirements
Transport for NSW is required to publish monitoring results. Here is the page where these are supposed to be published.
As stated in the previous report, there is still no evidence that Transport for NSW has ever tested or reported any of the annual testing requirements since it took control of the Alexandria Landfill. Both the NSW EPA and Transport for NSW environmental team were informed in writing (by the author) that the annual monitoring test results were missing from the reporting page. The EPA did not issue a notice of violation with a fine for this oversight. Additionally, Transport for NSW did not start reporting these missing results when
notified.
Data analysis
This evaluation focuses on the leachate reported results from samples taken from 12 May 2022 to 22 June 2023 which are the most recent available results.
Table: Transport of NSW Leachate Test Results
| 1Total Phosphorus is spelt as shown here. Phosphorous only refers to the trivalent species. | ||
| 2Transport NSW reported the exact same field parameters in December as in March which is not possible. | ||
| 3Total Nitrogen not required to be reported in their POEO Licence. | ||
| * Sample reportedly lost before given to the laboratory | ||
Errors Identified
In addition to not reporting any of the annual testing requirements for pollution, the first mistake found is that there was no quarterly reporting for the 3 rd quarter of 2022. Sampling for this quarter
should have taken place in August or September. This constitutes a serious violation which would warrant a fine if the environmental regulator was aware of this error.
The next blunder made by Transport for NSW’s environmental consultants was losing the fourth quarter sample before giving it to an accredited laboratory for analysis. Normally when an environmental regulator is made aware of a licensed operator’s failure to submit quarterly monitoring results, they require the licensed operator to resample and reanalyse to ensure that the licence requirements are fully compliant.
It is necessary for environmental consultants to take some measurements in the field because these can change before a sample is delivered to a laboratory. Conductivity, pH, Redox Potential and
temperature are examples of testing parameters that must be measured in the field. Transport for NSW reported the exact same test results for these field-testing parameters in December 2022 and
March 2023. It is not possible to have the exact same leachate field test results from a hot and cooler environment. This is an obvious mistake in which Transport for NSW reported December’s field-testing results in March 2023.
The names applied to pollutants is important to ensure that the correct measurement is being made. Transport for NSW reported Total Phosphorus as Total Phosphorous. There is no such measurement
as total phosphorous. Phosphorous refers is a UK spelling referring to the trivalent phosphate species.
Interestingly, Transport for NSW started reporting Total Nitrogen in March 2023. Total nitrogen is not required to be reported on Transport for NSW’s POEO Licence Number 4647. It seems that Transport for NSW does not monitor required pollutants but adds other pollutants not required when conducting its mandatory environmental testing requirements.
Because water and leachate are ionically neutral, there are a few simple quality control tests that environmental chemists can use to assess whether the data is accurate or not. These procedures are
summarised in in Standard Methods for the Examination of Water and Wastewater. 24th ed. Washington DC: APHA Press (2023) and include ionic balance and Total Dissolved Solids (TDS) agreement with electrical conductivity. Standard Methods established an ionic balance ± 5 % as the target for ionic balance and TDS/EC ratio between 0.55 to 0.7 as the quality data objectives in these measurements. The May 2022 and June 2023 leachate samples failed the ionic balance data quality objectives and all of the TDS/EC ratios failed. In fact, the field conductivity measurement for May 2022 was about 1/10 th of what it should have been.
Conclusions
This analysis of Transport for NSW’s failures in reporting simple leachate monitoring requirements raises serious questions about the competency of both the Department and its contractors.
To summarise:
- Failed to report annual testing requirements;
- Missed reporting the 3 rd quarter results for 2022;
- Lost the samples for the December 2022 POEO Licence mandated monitoring before sending them to the laboratory;
- Reported the exact same field test parameters for December 2022 and March 2023 ( marked in red on table);
- Reported analytes that are not required to be tested;
- Renamed pollutants that are required to be tested;
- Failed simple quality data objectives for ionic balance and TDS-Conductivity agreement.
The NSW EPA is responsible for ensuring that the conditions of the POEO Licence it issues to polluters are followed. It is clear to see that the EPA has either not evaluated these license violations or is choosing not to enforce obvious POEO violations. Either the NSW EPA is incompetent or it is deliberately choosing not to follow legislated regulatory requirements.
The public needs to be aware of these failings and an explanation provided by the NSW government.
Charlie Pierce, Research coordinator
Read more about the situation at the St Peters’ Interchange and earlier reports of high methane levels in Wendy Bacon’s report at City Hub and in the SMH here. and here. There is still no completion date for the St Peters park. This park like the one at Rozelle was supposed to serve as part compensation for the damage done to communities during construction. So far, the community as been left with more costs and potential impacts.