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Please note that the format of Barwon Water’s responses have been tailored to fit with the format and
flow of questions and concerns as they have been summarised in the 20B Conference Chairperson’s
Report. Barwon Water’s responses are provided in blue text.
• Note: This issue does not relate to the requirements of the Works Approval
1. The main concern was that Shell is perceived be the sole beneficiary of recycled water
from the plant;
• The project is currently sized to provide recycled water to replace potable water use at the
Shell Refinery. It will also provide recycled water to community sporting fields at Stead Park.
This means the plant will save up to 5 per cent of Geelong’s drinking water, or water used in
10,000 homes every year. This will contribute to greater water security across the Geelong
region. This drinking water saving, in addition to other water recycling by Barwon Water is
significant in securing water for Geelong’s future.
• The facility will be a win-win by cutting treated water discharges into Bass Strait and
responsibly treating increased sewage from the city’s expanding northern suburbs.
• 150 jobs will be created during construction, with flow-on benefits across the region.
• Further, the plant will have the potential to provide future recycled water to other customers
subject to demand, availability and additional investment. Barwon Water is also increasing
the amount of recycled water available to the community with the new Class A recycled
water plant at Black Rock. These projects are in line with Barwon Water’s strategy to secure
water for the region through new water sources, recycling and conservation.
2. It was alleged that early in the project the communication indicated that industry and
community would benefit from the recycled water and that it appears Shell will now be
the sole beneficiary;
• Early in the project, there was consideration that other industrial and recycled water
customers could be found for the NWP. At the time of finalising the project, Shell was the
only industrial customer willing to sign up to the project. Barwon Water also received
sufficient funding from the government to make the project a reality.
• The plant is being designed to allow future expansion, as waste water flows increase with
population growth and recycled water demand increases.
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3. A fear that home owners and other water users will be expected to pay higher prices
for the water was also raised.
• Shell is contributing a significant portion of funding for the project ($45M, i.e. 50%)
• Shell will be fully paying for the cost of treatment of its trade waste and for the recycled water
it receives.
• Barwon Water is only contributing funding that would otherwise be required to improve the
sewerage capacity in the northern suburbs. However, the NWP was established to be the
most cost effective option out of the alternatives that were considered to meet future growth.
• Note: This issue does not relate to the requirements of the Works Approval
1. Shell’s responsibility for dealing with waste is being handed back to the community
through Barwon Water
• Barwon Water will own and operate the Northern Water Plant. Barwon Water has the
expertise and experience to manage waste water treatment processes and currently
manages the treatment of Shell trade waste through the Black Rock Water Reclamation
Plant. Shell is paying its share of costs related to its treatment requirements, while the
community benefits from the recycled water plant asset and drinking water saved.
• Shell, like other industries, is required to meet conditions under its trade waste agreement
(licence).
2. The other concern related to corporate welfare - the public funding private industry.
• The Northern Water Plant project provides the most economical and sustainable solution to
meeting future growth and reducing Shell’s reliance on valuable drinking water. The
alternative solution for Barwon Water would have involved upgrading the main trunk sewer
through Geelong, involving a significantly higher cost and major public disruption. The NWP
is the best value for money solution for the corporation and, in turn, the community.
• The importance of the project has been recognised by both State and Federal Governments.
Government funding ($9.2M State, $20M Federal) is a reflection of the desire to find real
solutions to the national water shortage and fulfils a 2007 election commitment to the region.
3. Similar concerns were raised with a perception that the “business relationship
between Shell and Barwon Water is problematic” and that this project does not equate
to good value for money.
• The Northern Water Plant project takes advantage of a synergy that exists between Barwon
Water and Shell.
Barwon Water’s key drivers for the project include:
- Providing a significant water recycling opportunity in northern Geelong
- Meeting the demand for sewerage infrastructure in northern Geelong and Lara arising
from future population growth
- Developing an integrated water supply system to address the challenges of climate
change and population growth.
Shell’s key drivers include:
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- Increasing the level of treatment of refinery trade waste
- Substituting potable water with recycled water within the refinery
1. The subject of public access to the pilot plant results at Oyster Cover appeared to
be contentious and was the subject of a Resolution later in proceedings. At the
core, the community participants were questioning the validity of the pilot plant
results and have concerns that ‘worst case scenarios‘ have not been factored into
the design.
In Submissions
2. Lack of access to pilot plant results was also identified in many of the
submissions.
• Note: This issue does not relate to the requirements of the Works Approval
1. Validity of pilot plant results/testing worst case scenarios
• The pilot trial was conducted to confirm the proposed treatment process for the Northern
Water Plant was appropriate and would meet expectations. The trial incorporated the key
treatment process planned for the Northern Water Plant and received a mix of waste streams
representative of the inflows into the full scale plant. Barwon Water would not spend money
on a pilot trial if this was not capable of simulating actual inflows to be experienced by the
Northern Water Plant.
• In conjunction with the pilot, computer modeling was undertaken using results from the pilot.
This simulated extreme events that cannot be physically trialled. Historical data was also fed
into this modelling and provided confidence that the plant will be able to deal with extreme
conditions. The pilot commenced operation in December, 2009, and performance was not
affected by a shutdown to Shell operations, which occurred in October-November 2009.
Barwon Water would not have operated the pilot plant during a shutdown, as this would not
have been representative of normal conditions.
• There is no EPA requirement for pilot testing as part of the Works Approval process, This
was undertaken by the contractor to manage its own risk in relation to ensuring the
performance of the treatment processes.
2. Lack of access to pilot plant results was also identified in many of the submissions.
• The technology used in the trials is the intellectual property of the contractor and subject to
commercial confidentiality. This was a specific condition of the contract because a range of
other products are held by competitors. The technology used in the pilot trial is the sole
property of the contractor at this time. Barwon Water will own the design of the facility and
the pilot plant data once the plant is fully operational and has proven its performance.
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4.1.4 Barwon Water’s community engagement processes (4)
20B Issues
1. The key concern appeared to relate to differences between the initial planning
permit application (to City of Greater Geelong) and the current works approval
application. Participants felt that these changes in ‘scope’ of the project had not
been communicated effectively during the consultation process.
2. There was also a perception that the works approval application had already
been approved when participants attended a Barwon Water community forum in
March, 2010.
In Submissions
3. The same concerns were raised with examples provided such as, “notably an
open storage lagoon is contained in the planning permit application”.
1. & 3. Differences between the initial planning permit application (to City of Greater
Geelong) and the current works approval application. Participants felt that these
changes in ‘scope’ of the project had not been communicated effectively during the
consultation process.
• Initially the design included an “Emergency Storage Lagoon” (ESL) which was originally
included in the planning permit application. The ESL was designed to receive the contents of
the biological treatment system in the event of a plant failure. However, following submission
of the planning permit application, Barwon Water and the designers concluded this lagoon
was not required. This also removes a source of odour that would otherwise require
treatment.
• Council was provided with a revised design, as part of a planning permit amendment, and
members of the community who provided submissions to the planning permit application
were notified of the change.
• Barwon Water has not undertaken any targeted consultation on the removal of the ESL as
this is seen as a positive improvement overall, with no concerns anticipated from the wider
community.
• Important Note: The Emergency Storage Lagoon and Wet Weather Storage Lagoon are
different items and should not be confused. For further details on the Wet Weather lagoon,
please refer to responses under section 4.2.1.
2. There was also a perception that the works approval application had already been
approved when participants attended a Barwon Water community forum in March,
2010.
• Barwon Water’s Community Information Bulletin in February, 2010, stated a Works Approval
Application had been made to the EPA and was open for public comment during February,
2010. At the time of going to print with the bulletin (Jan 2010) it was anticipated that the
Works Approval Application would be lodged in February. Due to a delay with finalising the
Works Approval Application with the EPA, this was not formally submitted until May 2010.
• The EPA publically advertised for comment and feedback during May 2010.
4. One of the comments raised at the 20B conference and noted in the table at the end of
the Chairperson’s Report relates to a concern that Barwon Water only reports good
news.
• Barwon Water attends bi-monthly meetings of the Corio Norlane Development Advisory
Board (CNDAB), which represents a number of community interest groups from the northern
suburbs. A number of concerns have been raised by CNDAB members and have been
responded to during the past 18 months. The main concerns relate to odour management
and community benefits from the project.
• A concern raised in March, 2010, related to some residents being unclear that the NWP
would be treating domestic sewage from the northern suburbs as well as trade waste from
Shell.
• In response to this concern, Barwon Water hosted an information kiosk at the Corio
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Shopping Centre over four days in May, 2010. It was advertised in the Geelong Advertiser
and the Geelong Independent, as well as on the Barwon Water website. Staff working at the
kiosk highlighted the sources of domestic sewage inflows and trade waste to the plant and
spoke to visitors about how odour would be managed.
• More than 100 people stopped by the kiosk over the four days. A report detailing their
feedback and comments was presented at the CNDAB meeting in April 2010.
• In addition, earlier media releases and Community Information Bulletins stated clearly that
the plant would be treating sewage and trade waste from Geelong’s northern suburbs.
• Note: This issue does not relate to the requirements of the Works Approval
1. The core concern related to public infrastructure should be located on public land and
not private land.
• Barwon Water will take ownership of the site land as part of the project.
2. Of further concern was the possibility that Shell’s funding component may be
withdrawn if a new owner is found for the Shell site.
• Shell has made a substantial commitment to this Project and to the substitution of potable
use with recycled water. Shell has made no indication to Barwon Water that the Refinery is
up for sale. Even so, the Barwon Water / Shell agreement includes conditions to protect
Barwon Water’s interests in the event the Refinery is closed or sold.
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2. The second is a concern is about heavy metals and other contaminants in the
industrial wastewater from Shell that will be treated by the proposed treatment
plant.
3. A third issue discussed here and in submissions related to commitment that Shell
cease it’s discharge of water into Corio Bay.
In Submissions
4. It was felt that the works approval application lacked information about soil and
ground water contamination;
5. Concerns that in the recycling of Shell’s waste, there is a lack of information
about how heavy metals are to be handled.
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4.2 Questions Raised
In addition to broader concerns, more specific issues were raised and questions asked
that relate to the detail of the works approval application and the plant design and
location.
1. Key concern here related to the possible odour and air emissions from the uncovered
Lagoons.
Odour
• The design of the plant is required to meet the regulations for odour set by the EPA (refer to
the Works Approval). These regulations require that no odour is detectable at the boundary
of the site. Extensive modelling in accordance with EPA standards confirms the plant’s ability
to meet the strict requirements for no odour at the boundary.
• The plant has been designed so that areas with potential for odour will be fully covered, with
air extracted by an enclosed system and then treated on site. (refer to the Works Approval
for details)
Air Emissions – Hydrocarbon compounds
• Modelling also confirms air emissions from the plant for benzene, toluene, xylene and
phenols are 10 times lower than the Victorian regulations for air quality emissions.
2. This also relates to personal health concerns in the local community, particularly in
relation to storm and flooding events.
Storm Flows
• The Northern Water Plant will receive wet weather flow during storm events. This will help
Barwon Water prevent overflows in the main sewer system. This storm flow is treated to a
“Class C” quality and stored in the wet weather lagoon. Once the storm event passes the
Class C water will be discharged back to sewer. This storage does not require covering as
Class C water does not present an odour issue.
• Class C water is used mostly for irrigation including on golf courses, farms, sporting ovals,
tree lots.
• Barwon Water’s Black Rock Water Reclamation Plant has a similar storage for Class C water
and interested parties would be welcome to visit if they have concern regarding potential
odour.
• It is anticipated that the wet weather lagoon will be used 3-4 times during a 5 year period
based on historical data.
• Please note that:-
- no raw sewage will be stored in the wet weather lagoon at any time. It is not possible for
raw sewerage to be stored in the lagoon at the site.
- Public health won’t be affected by use of the wet weather storage lagoon.
- Recycled water customers will be supplied with Class A water from the Northern Water
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Plant. Class C water will only be produced and stored temporarily during a storm event,
Flooding Events
• The site layout is designed to meet flood levels.
• Barwon Water will complete a flood impact assessment for Geelong City Council to
demonstrate how onsite stormwater is managed and affects of stormwater downstream from
the site will be managed.
3. “EPA to address odour concerns raised by residents by EPA being involved in the
development of a Neighbourhood Environment Improvement Plan (NEIP).”
• This is a question for the EPA, please refer to their responses.
4. There was a concern that the works approval application lacked research into the
impacts of possible sea level rise;
• Note: This issue does not relate to the requirements of the Works Approval
• Sea level rise is a long-term planning issue that has the potential to affect many asset
owners.
• The impacts of sea level rise are considered by the Geelong City Council through their
planning processes.
• While Barwon Water is not required to investigate sea level rise for this project, Barwon
Water is responsive to stakeholders such as Geelong City Council and the Department of
Planning and Community Development on this issue.
5. Concerns that the health of local community will be affected negatively and the
information provided in the design does not go far enough.
• Refer to responses above.
Noise
• Major sources of noise at the plant are related to the mechanical equipment required for the
treatment process. This mechanical equipment will be housed within the treatment plant
buildings with acoustic enclosures provided for the noisiest equipment.
• Environmental noise assessments completed for the Works Approval confirmed that the
levels at the plant meet Victorian regulatory requirements.
4.2.2 Questions about design and ‘best practice’ of the proposal (5)
20B Issues
The key question from participants was, “Is this plant an example of best practice?” The
concerns related to the design and location of the proposed plant:
1. Lack of detail in relation to the technical design;
2. Has the proponent researched and visited other plants?;
3. Location was an issue due to its proximity to the refinery, and a long distance
from future residential development and location in the floodplain. Refer also to
response under section 4.2.1
In Submissions
4. Concerns that no plans for the recycling of stormwater;
5. Questions raised about flow rates and bio-reactor digestion;
6. Concerns about how the plant will handle shock loads and wet weather;
7. no pilot plant results from Oyster Cove refer to response under section 4.1.3
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- Technical standards and design standards are consistent with appropriate industry
standards; and
- The project objectives are being met through the Contractors design and performance
specifications.
2. Has the proponent researched and visited other plants?
• Note: This issue does not relate to the requirements of the Works Approval
• In submitting tenders for NWP project, bidders were scored on their previous experience and
track record in designing and constructing similar water treatment plants. Reference checks
were also made at the time.
• In addition, Barwon Water has visited similar treatment plants in Australia and spoken with
the owners of these plants.
3. Location was an issue due to its proximity to the refinery, and a long distance from
future residential development and location in the floodplain.
• Note: This issue does not relate to the requirements of the Works Approval
• In the early stages of the project, four sites were assessed and evaluated based on distance
to residential areas, distance to the refinery, cost of site location etc. The current site was
found to be the best alternative. Refer to section 4 of the Works Approval Application for
further details. Refer also to response under section 4.2.1 regarding flood concern.
4. Concerns that no plans for the recycling of stormwater (assuming this relates to
council stormwater)
• Note: This issue does not relate to the requirements of the Works Approval
• The Northern Water Plant is not designed to treat stormwater from roads and pathways
currently managed by council. The Northern Water Plant is designed to treat wet weather
flows from the sewers.
5. Questions raised about flow rates and bio-reactor digestion;
6. Concerns about how the plant will handle shock loads and wet weather;
• The biological treatment process can treat wet weather flows.
• The biological treatment system is also designed to take variation in quality from the sewer
and from Shell.
• Barwon Water has developed agreed trade waste quality acceptance limits with Shell. If
Shell discharges water beyond these limits, Barwon Water will shut down Shell’s trade
waste.
• Shell has 3 days storage onsite in the event of a problem with the trade waste quality, which
the NWP will not receive if above these limits.
7. No pilot plant results from Oyster Cove
• Note: This issue does not relate to the requirements of the Works Approval
• refer to response under section 4.1.3
8. One of the comments raised at the 20B conference and noted in the table at the end of
the Chairperson’s Report relates to a concern regarding fault lines, seismic studies
geothermal information
• Note: This issue does not relate to the requirements of the Works Approval
• The structural design review takes into account the ground conditions as part of complying
with Australian Standard 1170.4 Earthquake loading standard.
4.2.3 Links with the Master Plan and future expansion plans (4)
20B Issues
1. These concerns were broadly about future water security in Geelong. Participants
also identified that the Northern Water Treatment Plant was not included in the
Central Region Water Strategy and their question was “how does it qualify as part
of the master plan in providing sustainable water for our future?”
2. In addition a number of groups asked if the plant could be scaled up or expanded
to meet future growth.
In Submissions
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3. Concern that this plant does not require Shell to cease discharges into Corio Bay
refer response to 4.1.7, Q3.
1. Northern Water Treatment Plant was not included in the Central Region Water Strategy
and their question was “how does it qualify as part of the master plan in providing
sustainable water for our future?”
• Note: This issue does not relate to the requirements of the Works Approval
• The Northern Water Plant was identified as an alternative option in the Central Region
Sustainable Water Strategy; refer Chapter 6 page 60 and Chapter 7 page 69. The strategy
notes that the project is under investigation and pending assessment of the commercial
viability.
2. In addition, a number of groups asked if the plant could be scaled up or expanded to
meet future growth.
• Note: This issue does not relate to the requirements of the Works Approval
• The plant is being designed to allow future expansion on the current site. The site area
allows for a doubling in size. If Barwon Water seeks to expand the facility, a separate Works
Approval Application would be made at that time.
• The facility is being designed to operate for 20 years. However, this is in essence the first
phase of this plant’s life. As it currently stands, there is just enough sewage flow available to
meet the current recycled water demands (during dry weather periods). Based on expected
growth in the northern suburbs, future sewerage flows is expected to grow in the short to
medium term. Sufficient sewerage flows may be available in 14-15 years to enable a
doubling of the plant.
• If the plant is scaled up, Barwon Water will seek additional community and industrial uses for
recycled water.
3. Concern that this plant does not require Shell to cease discharges into Corio Bay
• Note: This issue does not relate to the requirements of the Works Approval
• Refer to response under section 4.1.7, question 3.
1. ‘if this is how much money we have, is it the best use for the outcomes being
delivered? Is this proposed project the best ‘bang-for-buck?’
• Note: This issue does not relate to the requirements of the Works Approval
• As previously stated, Shell is contributing 50% of the project cost.
• The Northern Water Plant was found to be the preferred option in providing the most
economical and sustainable solution to Barwon Water’s objectives. The contribution by Shell
and the government funding has enabled the project to become a reality.
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1. This was the one theme where other opportunities were identified. Some participants
expressed a desire for alternative energy sources (e.g. solar, wind, tidal) to power the
plant. Another opportunity was to tap the wasted energy from Shell Refinery processes
(e.g. flare energy) and use it to power part of the plant. It was pointed out that any use of
alternative sources should be in addition to existing renewable energy targets.
1. Some participants expressed a desire for alternative energy sources (e.g. solar, wind,
tidal) to power the plant. Another opportunity was to tap the wasted energy from Shell
Refinery processes (e.g. flare energy) and use it to power part of the plant…
• A treatment plant designed to produce high quality water products for reuse requires energy
input for the various processes.
• A key focus through the design process has been minimising the energy requirements and
maximising efficiency. As a result, several approaches to the design and operation of the
plant have been identified and will minimise energy usage. Refer Section 9.2 of the Works
Approval Application.
• The use of waste heat from Shell was considered by the design team. It was ruled out,
however, based on preliminary assessments that identified very high costs and safety issues
in linking the NWP with the Refinery.
• Barwon Water is currently investigating alternative energy sources as part of its Greenhouse
Gas Reduction Strategy.
4.3 Summary of the main concerns received by the EPA in public submissions
EPA Victoria provided the chairperson with a summary of the main concerns contained
in the public submissions they have received. During their analysis of these
submissions, the main topics that emerged included:
• Odour and VOC emissions
• Insufficient design information
• Difference between planning permit application and works approval application
• Public health and environmental impacts
• Location of the treatment plant in flood plain
• Existing potential soil and groundwater contamination
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An update was requested from Shell and EPA Victoria on the implementation of
Shell’s Water Master Plan.
4.5.3 Resolutions
1. Three resolutions were moved by Sue McLean (supported by Peter Linaker and
a majority in favour)
That the applicant/proponent (Barwon Water) provide:
i. the results of the pilot plant trials to the community
ii. the results of the sewerage study from 2009
iii. an explanation of the Barwon Water modelling It is not clear what is
being requested
The community requested that this information be provided by Barwon Water
at least 2 weeks prior to the next meeting on August 3, 2010.
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Questions/Concerns and Responses
• Note: This issue does not relate to the requirements of the Works Approval
1. Three resolutions were moved by Sue McLean (supported by Peter Linaker and a
majority in favour)
i. the results of the pilot plant trials to the community
• The results of the pilot plant contain intellectual property of the designing contractor and is
subject to commercial confidentiality. The reason it is commercially confident is that there are
different market products and technologies being used in the pilot plant that are not owned
by Barwon Water. Barwon Water is legally not entitled to release this information.
ii. the results of the sewerage study from 2009
• Barwon Water is seeking approval from the authors of the Geelong Sewerage Management
Strategy Study shortly (2007) as requested by the community. It is expected this report will
be made available prior to the next 20B conference meeting.
iii. an explanation of the Barwon Water modelling
• Computer modeling was undertaken in conjunction with the pilot trial. This modeling
simulated extreme events that cannot be physically trialled. Results from the pilot trial were
used to develop the model and therefore this modelling also contains intellectual property of
the designing contractor.
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