Bouvard Coast Care Group Inc

Tim’s Thicket Waste Disposal Timeline – Author M Horton 11/9/17
Please note this document is being continually updated as further information/documents become available. Press Ctl F5 or your reload page symbol to ensure you have the latest version.

Colour Key

Black                   Relevant information & bold where important.
Green                  Public/residential comments & complaints
Red                      Oversights by City of Mandurah (COM)
Blue                     Link to document
                             (Note – appropriate sections highlighted where possible)

Site Original History

• 1983 Limestone quarry in what is now Reserve 24198 dug to 6m depth on North side of Tim’s Thicket Rd.
• 1992 Analysis of Tim’s Thicket for waste site, on south side of Tim’s Thicket Rd, due to impending closure of Caddadup Reserve (now under Cut Golf course), due to creation of Dawesville Cut, but land is reserved for “camping & recreation”.
• May 1994 Land swap with CALM proposed to create waste site on north side of Tim’s Thicket Rd.
• Sep 1994 COM meeting where concerned residents point out that maps from Urban Geology Series maps from mines department state Tamala limestone is “undesirable land use” for septage disposal.  (COM subsequently agreed to line the ponds which were then broken during sludge removal and which seeped through the limestone in 2003).
• May 1995 Land swap enacted creating Waste Management & Septage Disposal Site for COM Reserve 43301 with remaining land (Reserve 24198) set aside by Minister for “Camping & Recreation” to be upgraded to “Conservation & Passive Recreation” as per Bulletin 751 , Determination 375  and Consultative Environmental Review (p14). COM has failed to file the paperwork to change the Reserve usage as agreed in 1994. See reserve map.

Inert Landfill – Category 63 Class 1 Inert Landfill & Category 13 Crushing of building material

• 1995 L6860/1995/08 Licence granted for Category 63 – Class 1 inert landfill as per EPA Bulletin 470 1994. which specifically states:
  “the word dry is used to clearly indicate that no liquids such as oils, acids, sewage or sludges should be disposed of at a dry infill site”, further it states; “chemical containers, paper and cardboard waste should not be dumped” .
• 1995 -1998 Inappropriate waste accepted as inert fill and dumped in old limestone quarry in reserve 24198 specifically set aside for camping and recreation, includes old fridges, tyres, cardboard, Asbestos.  (See Photos)
• Sep 1997 Complaints made with photographic evidence of illegal waste acceptance to COM and DER
  – Site waste not removed but immediately covered over with soil.
  – DEP acknowledged receipt of letter & will investigate and advise, however no investigation carried out as site had already been covered over with soil.
• 2010 Aerial photos show stockpiling of concrete crushing material from 2010, in breach of the existing inert landfill licence.
• Jun 2014 Photos of further tip site breaches, this time in Reserve 43301 (COM Waste Site), emailed to DER.  (See Photos)
• Jun 2015 DER issue new licence, removing class 61 Liquid Waste and insert improvement conditions for inert fill site class 63. (Awaiting outcome of FOI request to DER to confirm reasons for these improvement conditions.)
• Jul 2016 License L6860/1995/11 amended to approve crushing of building material on TT site, citing a number of regulations to be followed.
• Feb 2017 Complaint to COM from William St resident regarding 6am start and level of noise from equipment reverse beepers and noise of trucks dumping lorry loads of building materials for crushing. COM call Cleanaway and remind them not to start work prior to 7am.
• Aug 2017 DWER letter requesting submissions regarding Category 63 & 13 licences from 24 respondents of Septage Upgrade proposal.

Transfer Station – Category 62 Solid Waste Transfer

• Jun 2012  Council informed of additional funding of $300K raised from Waste Authority Regional Funding Program for Local Government Authorities 2011-2016 for Regional Transfer Station, with expiry of June 2016. No public/residential notification or request for comment on this proposal.
• 20 Aug 2013 Council adopts outline of intent Report 4 Tims Thicket Transfer & recycling centre G16/8/13T
• 21 Aug 2013 “Green light for Tims Thicket Tip” article in Mandurah Mail, however not yet approved by council and no license from DER.
• 27 Aug 2013 Council approves Report 8 for waste exchange at TT.
• 12 Sep 2014 COM applies to EPA for Transfer Station stating public consultation has taken place, that the proposal will not result in substantial transport of goods, and does not have a copy of the Minister’s determination 375 attached.
• 14 Oct 2014 EPA rule no assessment required.
• 17 Dec 2015 License for Category 62 transfer waste approved via Works Approval W5779/2014/1 with expiry date of 20/12/16 however license approval too late for Waste Authority Regional Funding Program funding allocation so Transfer Station on hold until new funding available.
• Aug 2017 NOTE – DWER letter requesting submissions regarding all licences from 24 respondents but excludes review of this license Category which we believe was erroneously granted due to lack of public consultation and the omission of the Minister’s determination meaning that the decision maker was not properly informed. This matter has been referred directly to the Minister of the Environment. 

Liquid Waste – Category 61 Liquid Waste Facility

• Sep 1994 COM meeting where concerned residents point out that maps from Urban Geology Series maps from mines department state Tamala limestone is an undesirable base for septage disposal.   (COM subsequently agreed to line the ponds which were then broken during sludge removal which seeped through the Tamala limestone in 2003.)
• 1995 – 1997 Septage facility installed along with bores MB1,2,3,4&5.
• 1997 – 2014 Ponds accepting liquid waste.
• Dec 2003 Monitoring Bore 4 (MB4) shows considerable increase in Nitrates. Note coincides with 7 year pond sludge removal which local resident believes caused a break in liner.
• Mar 2005 MB6, 7, 8, 9 water monitoring bores installed.
• Jan 2012 COM 2011 Annual report shows graph data for bores 1 – 5 only and shows large seepage loss.
• Jun 2013 Council approves closure of septage facility due to under use, scheduled to come into effect on 1st October 13.
• Oct 2013 Despite Council resolution in June the septage facility remains open.
• Nov 2013 Recreational water monitoring for TT & Melros beach suspended as per COM Recreational Water Monitoring Program, Health Services Report 2010 – 2014 (p12) which states: “Following a review of the sites in November 2013, it was decided that some of the sites would be removed from the list of designated sites. These sites were either used so infrequently or very unlikely to be affected by faecal contamination or dangerous to access for sampling.” But then on page 16 states: “Melros Beach (Site category: User Level – Low) Appendix 2 shows that 6% of the samples (or 1 in 18 samples) collected at Melros Beach exceeded the maximum recommended number of enterococci organisms.” It goes on to state “Subsequent results have been within the guidelines” Dates not available for these tests so it is unknown whether the subsequent readings were taken in summer, or in winter when they can be affected by adverse sea conditions. In addition Tim’s Thicket shows a persistent median reading of above zero.
• Dec 2013 Council votes to reopen Septage facility, but don’t appear to have been informed of the water monitoring breaches that have already occurred to date in Nov 2008/2010/2011/May 2013 – see entry Jul 2015.
• Jan 2014  Significant septage input, shown in quarterly Oct – Dec Regional Rivers report, shows input to TT site greater than all septage taken in previous two years. This increase coincides with DER investigation and resultant closure of Oakwood site for serious breaches of conditions by Bio-Organics.
• Apr 2014   Request for confirmation that water monitoring is compliant and for test results via MP Kim Hames with minimal/obfuscated responses. 2012 report shows increased nutrient levels for bores 2, 3, 4 & 5 from 2003 onwards, and breaches from 2008 onwards. Request to DER to investigate.
• May 2014 COM Council asked questions on notice regarding water quality with response that there “no breaches have occurred” from Director of Infrastructure. Additional questions confirmed that the proposal had not been put to MEAG (Mandurah Environmental Advisory Group) “as the proposal didn’t require planning approval”. 
• Oct 2014 COM’s request to increase allowance beyond licensed capacity is denied by DER.
• Dec 2014 DER confirms investigation still underway but COM has agreed to cease use. DER requires pond liner conditions to be checked. Ponds fail and DER withdraws licence for past and ongoing breaches.
• Jun 2015 Council is recommended to vote on proposed septage upgrade report but request to defer to July for full presentation.
• Jul 2015 Council given a briefing report and a presentation by TALIS of Tim’s Thicket and are advised of water monitoring breaches from 2008 onwards, and vote to proceed with upgrade.
• Jul 2016 COM Septage site upgrade outline plan passed by Council at Jul 26 meeting. This outline plan makes no mention of the fact that the spray field is located over a previous tip site, or that the spray field location is on land set aside by ministerial directive for public use of camping & recreation.
• Concerns raised regarding outline plan in assessment document. 
• Sep 2016 Question raised by councillor regarding spray field location at Sep 13 meeting.
• Oct 2016  Full upgrade proposal goes to DER who request further information/updates.
• Dec 2016 Upgrade proposal withdrawn by COM as additional information is required. DER state it will have to be resubmitted to EPA.
• Jan 2017 Update by COM Waste Dept. to MEAG meeting at the request of Mel Horton. Location of spray field questioned but told over inert waste. 1997 photo’s tabled as proof of contaminated waste but disregarded and meeting informed location of spray field won’t be moved.
• Apr 2017 Revised Septage upgrade proposal submitted to EPA unchanged, and contains inaccuracies and omissions. See BCCG submission.
• Submissions for assessment level requested by EPA and 24 respondents asked for Public Review within the short 6-day submission period.
• Jun 2017 Further information requested and supplied by COM on 7^th June & 13^th July. On 19^th July, the EPA rules for lowest assessment level of Referral Information.
• Jul/Aug 2017 Copy of additional information, supplied by COM on 7/6/17 & 13/7/17, from EPA have been requested by us however have not been forthcoming. We have had to file an FOI request which will not be fulfilled until AFTER the submission date for the licence review. Thus, we are unable to refute any erroneous additional information supplied by COM in the licence review submissions due in on 8^th September.
• Aug 2017 DWER letter requesting submissions regarding Category 61 license from 24 respondents of Septage Upgrade proposal due by 8^th September.
• Sep 2017 Following submissions, no further information available from DWER so BCCG decide to go public to the newspapers and on the website to attract sympathetic councillors for the upcoming elections with www.bouvardcoastcare.org.au/tims. An online form is made available for voting and comments which is completed by over 100 concerned and angry residents.
• 29 Sep 2017 COM request a meeting with BCCG to discuss our concerns. A number of issues are raised and minuted with an action list for both parties. Importantly CoM agree to move the irrigation field off the old tip site and into & within the boundary of the waste site. 
• Oct 2017 BCCG campaign nets a new mayor and 4 out of 6 concerned councilors elected. Mayor Williams requests to chair the next BCCG/COM meeting. 
• 4 Dec 2017 Second meeting held between COM and BCCG, chaired by Mayor Williams and minuted with action list. BCCG hand deliver letter requesting change of Vestiture for Reserve 24198. COM agree to:
  1. provide BCCG with the opportunity to review any further proposal prior to submission,
  2. propose the green waste facility under a separate license application to include consideration for fire hazard and mulch contamination risks,
  3. consult with nearby residents on future plans/proposals concerning the Tims Thicket & to put such proposals through MEAG (Mandurah Environmental Advisory Group)
  4. respond to BCCG regarding the 32 errors & omissions in the Talis document.
  5. publish water monitoring results from 1995 – 2017 on the COM Website,
  6. reinstate recreational water monitoring on Melros & Tims Thicket beaches,
• Dec 2017 DWER request a series of meetings with COM advising them that the current proposal will not be licensed as it stands.
• 6 Mar 2018 BCCG complete its tasks by providing an annotated copy of the Talis report detailing 32 errors & omissions. Apart from item 6 being actioned, nothing is heard from COM for over a year and BCCG erroneously assume that the Category 61 Liquid Waste proposal has been dropped. 
• 28 Mar 2019 DWER advise BCCG that a new proposal has been submitted by COM to the EPA and ask why we have not commented during the 6-day public comment period? BCCG is given 9 days to respond!
• 29 Mar 2019 BCCG request meeting with Mayor Williams to ask a series of questions and why none of the action items 1-5 above have been actioned by COM? Mayor Williams apologies to BCCG and will endeavour to provide answers and information ASAP, however only the Oct 2018 ground water report (at BCCG’s specific request) is provided to BCCG prior to the submission date.
• 10 Apr 2019 BCCG submits a 57 page reply to EPA noting that:
  • no consultation, as agreed to by COM, have been actioned
  • contrary to COMs propoal, over 100 residents have registered their concern and anger over the Category 61 licence request
  • the new proposal should go through the EPBC
  • COM has not enacted the Vestiture change for Reserve 24198
  • citing concern over ground water monitoring interference
  • citing concern over the environmental damage, resulting from the previous mismanagement and pollution, on the neighbouring reserves & Yalgorup National Park.