A glossary of common abbreviations and scientific terms, and a bibliography, are ... actual courses of non-compliance or
Stratford District Council Landfills Monitoring Programme Annual Report 2015-2016 Technical Report 2016-71
ISSN: 1178-1467 (Online) Document: 1759499 (Word) Document: 1762307 (Pdf)
Taranaki Regional Council Private Bag 713 STRATFORD November 2016
Executive summary The Stratford District Council (SDC) maintains a closed landfill located on Victoria Road at Stratford, in the Patea catchment. The landfill was closed to the public on 11 March 2002 and to commercial disposers on 23 March 2002. The site has more recently been used to dewater and dispose of oxidation pond sludge from the adjacent municipal waste water treatment plant but this activity ceased in early 2006, and the landfill was recapped and reinstated. The only external material now accepted at the landfill is soil from a local sawmill site remediation project. This activity is covered by separate consent1 held by a third party. SDC also maintains closed landfills at Douglas Road, Huiroa, and Wingrove Road, Pukengahu, in the Patea catchment. Both the Huiroa and Pukengahu landfills have been closed since 1991, but are still monitored with regards to maintenance and leachate discharge on a triennial basis. Monitoring of these sites was not undertaken during the 2015-2016 year, with monitoring next scheduled in the 2017-2018 year. This report for the period July 2015 to June 2016 describes the monitoring programme implemented by the Taranaki Regional Council (the Council) to assess SDC’s environmental performance of these closed landfills during the period under review, and the results and environmental effects of SDC’s activities. SDC holds three resource consents, which include a total of 19 special conditions setting out the requirements that SDC must satisfy. The consents for the Huiroa and Pukengahu landfills were renewed during the period under review. During the monitoring period, SDC demonstrated an overall high level of environmental performance and compliance with resource consent conditions. The Council’s monitoring programme for the closed landfill at Stratford included two inspections, two receiving water and six ground water samples collected for physicochemical analysis, and one biomonitoring survey of receiving waters. There were no incidents recorded by the Council in regards to SDC’s landfill sites during the period under review and the monitoring showed that there were only minor effects on the environment due to the discharges at the closed Stratford landfill site. During the year, SDC demonstrated a high level of environmental performance and good level of administrative performance with the Stratford landfill resource consent. As with the 2014-2015 year, there was some minor ponding occurring on the site and some re-contouring is needed to ensure that all areas of the cap remain free draining For reference, in the 2015-2016 year, 71% of consent holders in Taranaki monitored through tailored compliance monitoring programmes achieved a high level of environmental performance and compliance with their consents, while another 24% demonstrated a good level of environmental performance and compliance with their consents.
1
Consent 7645-1 Alby M Limited
In terms of overall environmental and compliance performance by the consent holder over the last several years, this report shows that the consent holder’s performance remains at a high level in the year under review. This report includes recommendations for the 2016-2017 year.
i
Table of contents Page 1.
Introduction 1.1
2.
3.
1
Compliance monitoring programme reports and the Resource Management Act 1991 Introduction 1.1.1 1.1.2 Structure of this report 1.1.3 The Resource Management Act (1991) and monitoring 1.1.4 Investigations, interventions, and incidents 1.1.5 Evaluation of environmental performance
1 1 1 2 2 3
1.2
Resource consents Water discharge permits 1.2.1
5 5
1.3
Monitoring programme Introduction 1.3.1 1.3.2 Programme liaison and management 1.3.3 Site inspections 1.3.4 Chemical sampling 1.3.5 Biomonitoring surveys
6 6 7 7 7 7
Stratford landfill at Victoria Road
8
2.1
Process description
8
2.2
Resource consent 2.2.1 Water discharge permit
9 9
2.3
Results 2.3.1 2.3.2 2.3.3 2.3.4 2.3.5
Inspections Groundwater Surface waters Biomonitoring Investigations, interventions, and incidents
9 9 10 13 15 16
2.4
Discussion Discussion of site performance 2.4.1 2.4.2 Environmental effects of exercise of consents 2.4.3 Evaluation of performance 2.4.4 Recommendation from the 2014-2015 Annual Report 2.4.5 Alterations to monitoring programmes for 2016-2017
16 16 16 16 17 17
2.5
Recommendation
18
Huiroa landfill
19
3.1
Process description
19
3.2
Resource consent 3.2.1 Water discharge permit Results Investigations, interventions, and incidents 3.3.1
20 20 20 20
Discussion Evaluation of performance 3.4.1 3.4.2 Recommendation from the 2014-2015 Annual Report
21 21 22
3.3 3.4
ii
3.4.3 3.5 4.
Recommendation
22 22
Pukengahu landfill
23
4.1
Process description
23
4.2
Resource consent 4.2.1 Water discharge permit Results Investigations, interventions, and incidents 4.3.1
23 23 24 24
4.4
Discussion Evaluation of performance 4.4.1 4.4.2 Recommendation from the 2014-2015 Annual Report 4.4.3 Alterations to monitoring programmes for 2016-2017
24 24 25 26
4.5
Recommendation
26
4.3
5.
Alterations to monitoring programmes for 2016-2017
Summary of recommendations
27
Glossary of common terms and abbreviations
28
Bibliography and references
30
Appendix I Resource consents held by Stratford District Council Appendix II Biomonitoring report
List of tables Table 1 Table 2 Table 3 Table 4 Table 5 Table 6 Table 7 Table 8 Table 9
Stratford District Council landfill consents Results of the Stratford landfill groundwater quality survey 28 August 2015 Results of the Stratford landfill groundwater quality survey, 31 May 2016 Results of the Stratford landfill water quality survey Summary of performance for Consent 3889-3 (Stratford landfill) Summary of performance for Consent 3890-2 (Huiroa) Summary of performance for Consent 3890-3 (Huiroa) Summary of performance for Consent 3891-2 (Pukengahu) Summary of performance for Consent 3890-2 (Pukengahu)
5 11 11 14 17 21 21 25 25
List of figures Figure 1 Figure 2 Figure 3
Regional map showing SDC landfill sites Stratford landfill (shaded in yellow) and sampling locations Graph showing chloride levels in groundwater at the Stratford landfill
6 8 12
iii
Figure 4 Figure 5 Figure 6
Figure 7 Figure 8
Graph showing ammoniacal nitrogen levels in groundwater at the Stratford landfill Graph showing zinc levels in groundwater at the Stratford landfill Graph showing ammoniacal nitrogen levels in the Patea Stream up and downstream of the landfill (where comparative data is available). Huiroa landfill and approximate sampling locations Pukengahu landfill and approximate sampling locations
12 13
15 19 23
1
1.
Introduction
1.1
Compliance monitoring programme reports and the Resource Management Act 1991
1.1.1 Introduction This report is for the period July 2015-June 2016 by the Taranaki Regional Council (the Council) on the monitoring programme associated with resource consents held by Stratford District Council (SDC). SDC maintains closed landfills on Victoria Road, Stratford, on Douglas Road, Huiroa, and on Wingrove Road, Pukengahu. This report includes the results and findings of the monitoring programmes implemented by the Council in respect of the consents held by SDC that relate to discharges of leachate and stormwater to water from the three closed landfills within the Patea catchment, in the Stratford district. During the year under review monitoring was only undertaken at the Stratford landfill site, as the Huiroa and Pukengahu monitoring programmes are triennial and are next scheduled for the 2017-2018 year One of the intents of the Resource Management Act 1991 (RMA) is that environmental management should be integrated across all media, so that a consent holder's use of water, air, and land should be considered from a single comprehensive environmental perspective. Accordingly, the Council generally implements integrated environmental monitoring programmes and reports the results of the programmes jointly. This report discusses the environmental effects of SDC’s use of water, land, and air, and is the 23rd report by the Council for the landfills managed by the consent holder.
1.1.2 Structure of this report Section 1 of this report is a background section. It sets out general information about: consent compliance monitoring under the RMA and the Council’s obligations; the Council’s approach to monitoring sites though annual programmes; a summary of the resource consents held by SDC; and the nature of the monitoring programme in place for the period under review. Each of the closed landfills is then discussed in a separate section (Sections 2 to 4). In each subsection 1 (e.g. Section 2.1) there is a general description of the landfilled site and its discharges, an aerial photograph or map showing the location of the former landfill, and an outline of the matters covered by the water discharge permit. Subsection 2 presents the results of monitoring of the SDC’s activities at each of the sites during the period under review, including scientific and technical data. Subsection 3 discusses the results, their interpretation, and their significance for the environment in the immediate vicinity of the site under discussion.
2
Subsection 4 presents recommendations to be implemented in the 2015-2016 monitoring year. Section 5 contains a summary of recommendations for the 2016-2017 year. A glossary of common abbreviations and scientific terms, and a bibliography, are presented at the end of the report.
1.1.3 The Resource Management Act (1991) and monitoring The RMA primarily addresses environmental ‘effects’ which are defined as positive or adverse, temporary or permanent, past, present or future, or cumulative. Effects may arise in relation to: (a) the neighbourhood or the wider community around an activity, and may include cultural and social-economic effects; (b) physical effects on the locality, including landscape, amenity and visual effects; (c) ecosystems, including effects on plants, animals, or habitats, whether aquatic or terrestrial; (d) natural and physical resources having special significance (for example recreational, cultural, or aesthetic); and (e) risks to the neighbourhood or environment. In drafting and reviewing conditions on discharge permits, and in implementing monitoring programmes, the Council is recognising the comprehensive meaning of ‘effects’ inasmuch as is appropriate for each activity. Monitoring programmes are not only based on existing permit conditions, but also on the obligations of the RMA to assess the effects of the exercise of consents. In accordance with Section 35 of the RMA, the Council undertakes compliance monitoring for consents and rules in regional plans, and maintains an overview of the performance of resource users and consent holders. Compliance monitoring, including both activity and impact monitoring, enables the Council to continually re-evaluate its approach and that of consent holders to resource management and, ultimately, through the refinement of methods and considered responsible resource utilisation, to move closer to achieving sustainable development of the region’s resources.
1.1.4 Investigations, interventions, and incidents The monitoring programme for the year was based on what was considered to be an appropriate level of monitoring, review of data, and liaison with the consent holder. During the year matters may arise which require additional activity by the Council, for example provision of advice and information, or investigation of potential or actual courses of non-compliance or failure to maintain good practices. A pro-active approach that, in the first instance, avoids issues occurring is favoured. The Council operates and maintains a register of all complaints or reported and discovered excursions from acceptable limits and practices, including noncompliance with consents, which may damage the environment. The incident register includes events where the consent holder concerned has itself notified the Council. The register contains details of any investigation and corrective action taken.
3
Complaints may be alleged to be associated with a particular site. If there is potentially an issue of legal liability, the Council must be able to prove by investigation that the identified company is indeed the source of the incident (or that the allegation cannot be proven). Any investigations, interventions, and incidents for each site are discussed in subsection 3.
1.1.5 Evaluation of environmental performance Besides discussing the various details of the performance and extent of compliance by SDC during the period under review, this report also assigns a rating as to their environmental and administrative performance during the period under review. Environmental performance is concerned with actual or likely effects on the receiving environment from the activities during the monitoring year. Administrative performance is concerned with the consent holders approach to demonstrating consent compliance in site operations and management including the timely provision of information to Council (such as contingency plans or water take data) in accordance with consent conditions. Events that were beyond the control of the consent holder and unforeseeable (that is a defence under the provisions of the RMA can be established) may be excluded with regard to the performance rating applied. For example loss of data due to a flood destroying deployed field equipment. The categories used by the Council for this monitoring period, and their interpretations, are as follows: Environmental Performance
High: No or inconsequential (short-term duration, less than minor in severity) breaches of consent or regional plan parameters resulting from the activity; no adverse effects of significance noted or likely in the receiving environment. The Council did not record any verified unauthorised incidents involving significant environmental impacts and was not obliged to issue any abatement notices or infringement notices in relation to such impacts.
Good: Likely or actual adverse effects of activities on the receiving environment were negligible or minor at most. There were some such issues noted during monitoring, from self reports, or in response to unauthorised incident reports, but these items were not critical, and follow-up inspections showed they have been dealt with. These minor issues were resolved positively, co-operatively, and quickly. The Council was not obliged to issue any abatement notices or infringement notices in relation to the minor noncompliant effects; however abatement notices may have been issued to mitigate an identified potential for an environmental effect to occur.
4
For example: -
-
High suspended solid values recorded in discharge samples, however the discharge was to land or to receiving waters that were in high flow at the time; Strong odour beyond boundary but no residential properties or other recipient nearby.
Improvement required: Likely or actual adverse effects of activities on the receiving environment were more than minor, but not substantial. There were some issues noted during monitoring, from self reports, or in response to unauthorised incident reports. Cumulative adverse effects of a persistent minor non-compliant activity could elevate a minor issue to this level. Abatement notices and infringement notices may have been issued in respect of effects.
Poor: Likely or actual adverse effects of activities on the receiving environment were significant. There were some items noted during monitoring, from self reports, or in response to unauthorised incident reports. Cumulative adverse effects of a persistent moderate non-compliant activity could elevate an ‘improvement required’ issue to this level. Typically there were grounds for either a prosecution or an infringement notice in respect of effects.
Administrative performance
High: The administrative requirements of the resource consents were met, or any failures to do this had trivial consequences and were addressed promptly and co-operatively.
Good: Perhaps some administrative requirements of the resource consents were not met at a particular time, however this was addressed without repeated interventions from the Council staff. Alternatively adequate reason was provided for matters such as the no or late provision of information, interpretation of ‘best practical option’ for avoiding potential effects, etc.
Improvement required: Repeated interventions to meet the administrative requirements of the resource consents were made by Council staff. These matters took some time to resolve, or remained unresolved at the end of the period under review. The Council may have issued an abatement notice to attain compliance.
Poor: Material failings to meet the administrative requirements of the resource consents. Significant intervention by the Council was required. Typically there were grounds for an infringement notice.
For reference, in the 2015-2016 year, 71% of consent holders in Taranaki monitored through tailored compliance monitoring programmes achieved a high level of environmental performance and compliance with their consents, while another 24% demonstrated a good level of environmental performance and compliance with their consents.
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1.2
Resource consents
1.2.1 Water discharge permits Section 15(1)(a) of the RMA stipulates that no person may discharge any contaminant into water, unless the activity is expressly allowed for by a resource consent or a rule in a regional plan, or by national regulations. SDC holds water discharge permits 3889-3, 3890-3 and 3891-3 issued by the Council. The purposes and approximate locations of the consents are provided in Table 1 and Figure 1, and they are each discussed further in the sections of this report covering the individual landfills. Table 1
Stratford District Council landfill consents
Consent Location number
Next review date
Expiry date
To discharge leachate into land and into groundwater adjacent to the Patea River
June 2016
1 June 2028
To discharge up to 230 cubic metres/day [20 litres/second] of stormwater and leachate from a former landfill site onto and into land in the vicinity of an unnamed tributary of the Makuri Stream in the Patea Catchment
-
1 June 2016
3890-3
To discharge stormwater and leachate from the former Huiroa landfill onto and into land in the vicinity of an unnamed tributary of the Makuri Stream [Renewed consent granted 16 June 2016]
June 2022
1 June 2034
3891-2
To discharge up to 910 cubic metres/day [84 litres/second] of stormwater and leachate from the former Pukengahu landfill into an unnamed tributary of the Waihapa Stream in the Patea Catchment
-
1 June 2016
To discharge stormwater and leachate from the former Pukengahu landfill into an unnamed tributary of the Waihapa Stream [Renewed consent granted 16 June 2016]
June 2022
1 June 2034
3889-3
Stratford
3890-2 Huiroa
Pukengahu 3891-3
Purpose
6
Figure 1
1.3
Regional map showing SDC landfill sites
Monitoring programme
1.3.1 Introduction Section 35 of the RMA sets out obligations upon the Council to gather information, monitor, and conduct research on the exercise of resource consents within the Taranaki region. The Council is also required to assess the effects arising from the exercising of these consents and report upon them. The Council may therefore make and record measurements of physical and chemical parameters, take samples for analysis, carry out surveys and inspections, conduct investigations, and seek information from consent holders. The Stratford landfill closed in 2006 and monitoring is conducted annually. Both the Huiroa and Pukengahu landfills have been closed since 1991 but are still monitored with regards to leachate discharge and site maintenance on a three yearly basis. Monitoring was undertaken in the 2014-2015 period, and is scheduled to take place again in 2017-2018 as per the triennial programme.
7
The monitoring programmes for the SDC landfills consist of four primary components as outlined below.
1.3.2 Programme liaison and management There is generally a significant investment of time and resources by the Council in:
ongoing liaison with resource consent holders over consent conditions and their interpretation and application; in discussion over monitoring requirements; preparation for any reviews; renewals; new consents; advice on the Council's environmental management strategies and content of regional plans; and consultation on associated matters.
1.3.3 Site inspections The Stratford municipal landfill site was visited on two occasions during the monitoring period. The landfill inspections focused on the stability, integrity, and drainage of the caps, any potential or actual discharges to receiving watercourses, including potential for leachate discharges, and visual assessment of the receiving water quality.
1.3.4 Chemical sampling The Patea River in the vicinity of the Stratford landfill was sampled on one occasion, and the sample analysed for black disc transparency, biochemical oxygen demand, cadmium, chloride, conductivity, chromium, dissolved oxygen, dissolved reactive phosphorus, faecal coliforms, ammoniacal nitrogen, nitrate/nitrite nitrogen, dissolved oxygen saturation, pH, suspended solids, temperature, turbidity, and zinc. The Council also undertook sampling of the groundwater at the Stratford landfill. Groundwater was sampled on two occasions, and the sample analysed for alkalinity, bicarbonate, chloride, conductivity, dissolved reactive phosphorus, faecal coliforms, ammoniacal nitrogen, nitrate, pH, temperature, water level and zinc.
1.3.5 Biomonitoring surveys A biological survey was performed on one occasion in the Patea River to determine whether or not the Stratford landfill has had a detrimental effect upon the macroinvertebrate communities of the river.
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2.
Stratford landfill at Victoria Road
2.1
Process description The Stratford District Council (SDC) operated a landfill located on Victoria Road at Stratford, in the Patea catchment. The landfill was closed to the public on 11 March 2002 and to commercial disposers on 23 March 2002. All contaminated surface water from the landfill is pumped to the adjacent oxidation ponds for treatment. In March 2004 SDC cleared a site on top of the landfill and created a bunded area for the purpose of oxidation pond sludge dewatering. This dewatering process continued through to early 2006 and the sludge was then covered and capped and the site reinstated. There has been no discharge of refuse to the landfill since 2006. A third party currently holds a consent to discharge chromated copper arsenate (CCA) contaminated soil from the old Fazackerly timber treatment plant site as base fill to the landfill for re-contouring purposes2 (under the supervision of SDC). This consent has been exercised. However, due to an excess of clean overburden, further re-contouring is required.
PAT000330
GND1015
2
GND1014
PAT000315
Figure 2
PAT000345
GND1016
Stratford landfill (shaded in yellow) and sampling locations
This consent was granted to provide for the remediation of a local sawmill site. The consent (7645-1) is held by Alby M Limited, and compliance monitoring of consent 7645-1 is not included in this report
9
2.2
Resource consent
2.2.1 Water discharge permit SDC held consent 3889-2 to cover discharge of stormwater and leachate from Stratford municipal landfill into the Patea River. This permit was issued by the Council on 27 February 1998 under Section 87(e) of the RMA. This consent expired on 1 June 2010. As discharges were still occurring from the landfill, an abatement notice was issued and the consent holder subsequently re-applied for a consent. Consent 3889-3 was issued by the Council on 6 December 2010. It is due to expire on 1 June 2028, with provision for review the conditions of the consent in June 2016 and/or June 2022. Condition 1 requires that the consent holder adopt best practical option to minimise effects. Condition 2 requires the preparation and maintenance of a Contingency and Landfill Maintenance Plan. Condition 3 requires SDC to maintain certain structures at the site. Condition 4 states that the discharge shall not reduce in-stream water quality after a specified mixing zone. Condition 5 is a review provision. The permit is attached to this report in Appendix I.
2.3
Results
2.3.1 Inspections 20 August 2015 The inspection was conducted in fine weather with moderate gusty wind conditions, following two days of heavy rain. The cap was observed to be intact and well grassed with pasture establishment on going on the cap over the Fazackerly CCA soil area. It was found to be wet underfoot and some minor ponding was present. The site was being grazed by young stock at the time of inspection. The vegetative cover was noted to have a few patchy exposed areas, but no slumping, cracking or exposed refuse was observed. The batters were found to be intact, well fenced and grassed. There was no slumping or cracking evident. This area was being grazed at time of inspection and although there was some minor damage to the eastern batter, no exposed refuse was observed. The stormwater drains on the cap were grassed over but clear of obstructions. It was observed that the drains were not well-defined on the top of the cap and therefore were not free-draining in all areas, which had lead to minor ponding. The eastern perimeter drain adjacent to the waste water treatment plant was full, but not discharging to the river.
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The site was well fenced, with permanent multi-strand electric fencing around the batters and on the cap. The water troughs on the cap were full but not overflowing. The following action was to be taken: Maintain fencing around the exposed areas on the cap to prevent further stock damage. 31 May 2016 The inspection was conducted in overcast conditions with heavy showers. The cap was found to be intact and well grassed. There was some minor ponding on the surface following the recent heavy showers and wet weather. No slumping, cracking or exposed refuse was observed. The water troughs on the cap were not overflowing. The batters were found to be intact, permanently fenced and well-grassed. No slumping, cracking, exposed refuse or stock damage was found at the time of inspection. The stormwater drains on the cap were well grassed and free draining. No ponding was observed in the drains. The site was not being grazed at the time of inspection. There were no odour or dust issues found.
2.3.2 Groundwater Groundwater samples were taken from monitoring bores upslope (GND1015 and GND1016) and down slope (GND1014) of the landfill on two occasions. The results from these samples are shown in Table 2 and Table 3. As with the results from previous samples taken from these monitoring bores, the groundwater down gradient of the landfill (as represented by bore GND1014), shows some evidence of contamination from the landfill. The graphs of historical data given in Figures 3, 4 and 5 show how bore GND1014 is affected by landfill indicator species; ammoniacal nitrogen, chloride, and zinc. The graphs also show how the levels of chloride and ammonia are apt to fluctuate against the more stable background levels found in the two bores mid and up gradient from the filled area (more so in the case of chloride and ammoniacal nitrogen). Zinc is found to be higher in the down gradient bore but is also seen to fluctuate in the up gradient bores as well, which may indicate other local effects in the groundwater. The affected area consists of the narrow riparian strip between the landfill and the Patea River and the contaminated groundwater will eventually permeate through to the Patea River. The results of the monitoring of the Patea River, as discussed below, show that there is, at most, only negligible impact on Patea River water quality. This suggests that either the level of groundwater migration is not of sufficient volume to make any significant changes to the water quality of the Patea River, or that the groundwater contamination is being attenuated by its passage through the soil.
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Table 2
Results of the Stratford landfill groundwater quality survey 28 August 2015
Parameter
Unit
GND1014 down-gradient
GND1015 up-gradient
GND1016 up-gradient
Alkalinity
g/m3
726
24
30
Dissolved arsenic
g/m3
