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Environmental Assessment Report Ridley – Feed Mill, Westbury

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ENVIRONMENTAL ASSESSMENT REPORT

Aqua Feed Mill

16 Integrity Drive, Valley Central Industrial Precinct Westbury

Ridley AgriProducts Pty Ltd

Board of the Environment Protection Authority

December 2017


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Environmental Assessment Report

Proponent Ridley AgriProducts

Proposal Aqua Feed Mill

Location 16 Integrity Drive, Valley Central Industrial Precinct, Westbury

NELMS no. PCE No 9685

Permit application no.

PA18-0018 (Meander Valley Council)

Doc1 folder EN-EM-EV-DE-252180

Doc1 no. H763576

Class of Assessment

2B

Assessment process milestones

22/03/2017 Notice of Intent submitted

9/05/2017 Guidelines issued

23/05/2017 Permit application submitted to Council

28/07/2017 Referral received by Board

16/09/2017 Start of public consultation period

16/10/2017 End of public consultation period

29/11/2017 Additional information submitted to Board


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Acronyms

AHD Australian Height Datum

Air EPP Environment Protection Policy (Air Quality) 2004

AQIA Air Quality Impact Assessment

Board Board of the Environment Protection Authority

BOM Bureau of Meteorology

DPEMP Development Proposal and Environmental Management Plan

DPIPWE Department of Primary Industries, Parks, Water and Environment

EIA Environmental Impact Assessment

EMPC Act Environmental Management and Pollution Control Act 1994

EMPCS Environmental Management and Pollution Control System

EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)

LUPA Act Land Use Planning and Approvals Act 1993

OU Odour Units

RMPS Resource Management and Planning System

SD Sustainable Development


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Report summary

This report provides an environmental assessment of Ridley AgriProducts Pty Ltd (Ridley)’s proposed Aqua Feed Mill. The proposal involves the construction and operation of an Aqua Feed Mill to manufacture extruded aqua feed. The mill will be capable of producing 50,000 tonnes per year or 12 tonnes (12,000 kilograms) per hour of finished feed. It will be located at 16 Integrity Drive1, in the Valley Central Industrial Precinct at Westbury. This report has been prepared based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP) and additional information. Relevant government agencies and the public have been consulted and their submissions and comments considered as part of this assessment. On 2 November 2017, the Deputy Director under delegation, requested that the proponent submit additional information to address public and government agency (including DPIPWE) comments on the DPEMP. The proponent submitted satisfactory additional information on 29 November 2017. Further details of the assessment process are presented in section 1 of this report. Section 2 describes the statutory objectives and principles underpinning the assessment. Details of the proposal are provided in section 3. Section 4 reviews the need for the proposal and considers the proposal, site and design alternatives. Section 5 summarises the public and agency consultation process and the key issues raised in that process. The detailed evaluation of key issues is in section 6, and other issues are evaluated in section 7 and Appendix 1. The report conclusions are contained in section 8. Appendix 2 contains details of comments made and issues raised in the consultation process. Appendix 3 contains environmental permit conditions for the proposal.

1 It should be noted that since the submission and advertising of the application, a subdivision of the Land has been approved and the permit conditions reflect the details of this subdivision. Hence, the address in the DPEMP is not consistent with this report; however ‘the Land’ is the same.


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Table of Contents

1 Approvals process .................................................................................... 1

2 SD objectives and EIA principles .............................................................. 1

3 The proposal ............................................................................................ 2

4 Need for proposal and alternatives ........................................................... 8

5 Public and agency consultation .............................................................. 10

6 Evaluation of key issues ......................................................................... 12

6.1 Air Quality ....................................................................................................................... 12

7 Other issues ........................................................................................... 27

8 Report conclusions ................................................................................. 28

9 References ............................................................................................. 29

10 Appendices ......................................................................................... 29

Appendix 1 Assessment of other issues .............................................................................. 30 Appendix 2 Summary of public and agency submissions .................................................... 43 Appendix 3 Permit Conditions – Environmental No. 9685 .................................................... 44


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1 Approvals process

A Notice of Intent in relation to the proposal was received by the Board of the Environment Protection Authority (the Board) on 22 March 2017. The proposal is defined as a ‘level 2 activity’ under clause 4(e), Schedule 2 of the Environmental Management and Pollution Control Act 1994 (EMPC Act), as a produce processing works, being the conduct of works for the processing of vegetables, seed, grain, fruit or any other agricultural crop material by deep fat frying or roasting or boiling or drying through application of heat, being works with a capacity of 50 kilograms or more per hour. Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The Board required that information to support the proposal be provided in the form of a Development Proposal and Environmental Management Plan (DPEMP) prepared in accordance with guidelines issued by the Board on 9 May 2017. Several drafts of the DPEMP were submitted to EPA Tasmania for comment prior to its finalisation and acceptance on behalf of the Board. The final DPEMP was submitted to Council with the permit application. An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Meander Valley Council on 23 May 2017. The application was received by the Board on 28 July 2017. The DPEMP was released for public inspection for a 28-day period commencing on 16 September 2017. Advertisements were placed in The Examiner and on the EPA website. The DPEMP was also referred at that time to relevant government agencies for comment. One public submission was received. On 2 November 2017 the Deputy Director, under delegation, requested that the proponent submit additional information to address public and government agency (including DPIPWE) comments on the DPEMP. The proponent submitted satisfactory additional information on 29 November 2017.

2 SD objectives and EIA principles

The proposal must be considered by the Board in the context of the objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) (both sets of objectives are specified in Schedule 1 the EMPC Act). The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to further the RMPS and EMPCS objectives.

The Board must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment Principles defined in Section 74 of the EMPC Act.


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3 The proposal

Section 2 of the DPEMP states the Aqua Feed Mill will manufacture extruded aqua feed. Aqua feed production involves the delivery and storage of raw materials, grinding, mixing and drying manufactured products into pelleted feed and packaging prior to dispatch. The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 2.0 of the DPEMP. Table 1: Summary of the proposal’s main characteristics

Activity

Production of a maximum of 50,000 tonnes per annum of aqua feed.

Location and planning context

Location 16 Integrity Drive, Valley Central Industrial Estate, Westbury (Certificate of Title 174186/1), as shown in Figure 1.

Land zoning General Industrial

Land tenure Private Freehold

Existing site

Land Use Agricultural and Industrial uses. Rezoned in 2008 to an Industrial Precinct.

Topography The site is relatively flat with ground slopes less than 2°, rising from approximately 186 metres (AHD) in the south-west of the site to approximately 191 metres (AHD) in the north-east of the site. A shallow man-made drainage line crosses the middle portion of the site from north-west to south.

Geology Regionally, the site lies close (<2.0 km) to a geological boundary comprising to the east Tertiary aged non-marine sequences (gravel, sand, silt, clay and regolith) and to the west predominantly igneous geology consisting of Jurassic aged dolerite and Tertiary aged basalt, all overlain by Quaternary aged sediments (sands, gravels and muds are mapped) adjacent to drainage lines.

The site is entirely underlain by Basalt, with alluvium observed adjacent to the nearby Meander River and Quamby Brook.

Soils The Soil is generally described as being of the following nature:

Top Soil layer - Up to 1m of brown, sandy/clayey topsoil, overlying

Under layer - High plasticity, clay with sand to sandy clay, mottled orange/brown, grey or olive, very stiff to hard.

Hydrology A number of water bodies (dams, drains and rivers) surround the site, including Quamby Brook located approximately 1.4km to the south-east of the site and the Meander River approximately 1.1km to the north.

Fauna Other than the EPBC Act listed Green and Gold Frog, no other natural values are known to occur within the proposed Industrial precinct.

Flora The site is dominated by exotic grasses due to previous agricultural land use. The shallow man-made drain that crosses the subject site contains scattered native sedge species. The remainder of the site contains little or no significant native vegetation.


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Local region

Climate Westbury meteorological station (Valley View) demonstrates that winds are predominantly north-west – south-east orientated. Average rainfall at Westbury is 834 mm. Rainfall data shows the wettest months are May to October.

Surrounding land zoning, tenure and uses

General Industrial and Rural Resource. Other industrial developments on the estate include Delmade (machinery fabrication), Tasbuilt homes, Caltas Filling station, BOC-LNG Facility and Kolmak Steel Fabrication. Tas Alkaloids is located adjacent to the eastern boundary of the industrial estate (see Figure 6 of the DPEMP).

Species of conservation significance

Green and Gold Frog (Litoria raniformis)

Proposed infrastructure

Major equipment

The key items of machinery are:

Conveying equipment

Raw material handling and processing systems

Extrusion, drying and vacuum coating equipment

Packaging equipment

Weighbridge to weigh incoming and outgoing goods

3MW Boiler – (14359 MJ/hour at full load, or approximately 325 kg/hour of natural gas)

Biofilter that will handle excess process air

Waste and stormwater treatment system

Other infrastructure

Silos

Truck Intake

Process Building

Raw Materials / Finished Goods

Liquid Storage

Admin & Amenities

Workshop & Spare Parts

Inputs

Water Connection to current TasWater potable water supply

Energy Connection to current electrical and gas supply as well as LPG gas

Other raw materials

Grains, protein, meals, fat (oil), vitamins and minerals

Wastes and emissions

Liquid Stormwater runoff from rooves and hardstand areas. Wastewater from biofilter, boiler blowdown process and wash bay area.

Atmospheric Odour from organic material processing. Dust during construction.

Solid General refuse including food scraps, paper and packaging.

General inert wastes such as metal waste to be collected periodically.

Controlled wastes

Human waste directed to existing sewer system.


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Noise From construction and operation of the plant including vehicles and equipment.

Greenhouse gases

The total estimated annual greenhouse gas emission is 4,588 t CO2-e per year, with natural gas use making up the majority of the emissions.

Construction, commissioning and operations

Proposal timetable

Ridley was initially aiming for commencement of site preparation works as early as possible in 2017. Table 4 of the DPEMP shows indicative timelines for each major component of construction and would apply from any commencement date.

Operating hours (ongoing)

The plant will operate up to 24 hours per day 5 days per week with the potential to operate 24 hours per day 7 days per week based on market demand.

Other key characteristics

The lot on which the facility will be located has been subdivided since submission of the application and a certificate of title issued.


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Figure 1: General location map (Figure 5 of the DPEMP)


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Figure 2: Site plan (Figure 3 of the DPEMP).


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Figure 3: Process overview (Figure 4 of the DPEMP).


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4 Need for proposal and alternatives

Site Alternatives

Section 3 of the DPEMP, states that as part of its detailed feasibility study, Ridley considered two alternative locations within Tasmania prior to the selection of the Westbury site:

1. Wesley Vale Site - 329 Mill Road, Wesley Vale

The Wesley Vale Site considered by Ridley is a former particle board mill. The site has substantial existing structures with two large warehouses offering some potential for conversion but would have required considerable modification. The structures also contained asbestos and additionally, soil contamination was evident at the site.

This site provided good access to some utilities and services however; the lack of sewer connection and the need for a power supply upgrade reduced suitability. This combined with the need for undefined remediation of asbestos and soil and a site preparation phase which would take up to 14 months did not fit within the Ridley construction and commissioning timeframe.

2. Integrity Drive, Westbury

Two parcels of land were considered at Integrity Drive, Westbury, neighbouring the currently proposed site at Lot 17 Integrity Drive. This site was considered as a potential option as it provides good access to all utilities from Birralee Road.

After further investigation it was deemed unsuitable due to the topography and presence of significant rocky outcrops. These would require additional construction and service connection costs when compared with the current proposed site.

The current site at Integrity Drive was selected due to its location in an area zoned as an industrial precinct and good transport links in proximity to the Bass Highway. Additionally, the site is relatively flat with a 2 degree slope which will reduce construction cost in terms of earth works when compared with other sites. Further, utilities have been provided up to the site boundary allowing for good connections to water, gas, electricity and sewer.

Technology Alternatives

In developing the design for the proposed Aqua Feed Mill, the DPEMP states Ridley considered several alternatives for the management of odour from the production process including incineration and chemical stripping.

Typical odour treatment methods are:

Adsorption of odours e.g. activated charcoal;

Thermal treatment of odours e.g. thermal oxidiser or flare;

Wet scrubbers; and

Biological filters.

Of the odour scrubbing technologies available, the DPEMP concludes the two technologies that could reasonably be used at the Ridley facility are either a wet scrubber or a biofilter. The ultimate selection of the biofilter has been based on its lower capital and maintenance costs compared to the wet scrubber, the known performance of a similar scrubber at a Ridley Facility in Queensland, and the fact that the proposed facility is predicted to have minimal odour impact at receptors.

Modelling of stack emissions was undertaken as part of the Air Quality Impact Assessment (AQIA). The results of the modelling suggest the ground level concentrations would be lower than the results for the biofilter. The DPEMP states:


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The contours suggest the stacks main benefit would be for the industrial estate where the concentration within the estate would be in the order of 1.8-2.0 OU in comparison to the biofilter concentration of ~32 OU at the boundary. It should be noted that this difference is most pronounced close to the biofilter location itself and by the time the plume has reached the boundary of the industrial estate, the concentration difference has decreased to approximately 0.7 OU. At the nearest industrial receptors the difference between the odour performance of the biofilter and stack is expected to be negligible.

The report concludes, ‘given the higher performance of the stack over the biofilter is only experienced close to the site and there is only marginal improvement beyond the boundary of the new industrial estate, the additional costs associated with the stack infrastructure were considered to be excessive relative to the odour improvement outcome.’ The proponent also highlights the stack option would also involve higher energy usage and costs over the life of the facility and additional maintenance costs.

The proponent also highlights biofilters are considered ideal for treating large volumes of low-concentration odorants and are well suited to processing food waste. They comment that there is a significant amount of literature supporting biofilters for the removal of odours such as Hydrogen Sulphide, Dimethyl Sulphide, and Dimethyl Disulphide, gases containing sulphur, ammonia and malodorous gases which may be produced at the plant.

The management options considered for the proposed wastewater treatment include:

Reuse in process – this has been adopted and built into the design such that all process wastes are collected in a wet slurry system for subsequent metering back into production.

Potential for recycling of other wastewater streams – the nature of the remaining wastewater streams (boiler blow down, biofilter leachate and wash bay effluent) are such that recycling on or off-site are not feasible.

Given the anticipated small volume of 20-25 kL/day, the preferred option is for direct disposal to sewer via a Trade Waste Agreement with TasWater.


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5 Public and agency consultation

A summary of the public representations and government agency/body submissions is contained in Appendix 1 of this report. One representation was received. The main issues raised in the representation were:

Air Quality

Stormwater Management The DPEMP was referred to a number of government agencies/bodies with an interest in the proposal during its development. Comments were received from the following:

Meander Valley Council The following Divisions/areas of the Department of Primary Industries, Parks, Water and Environment also provided comments on the DPEMP during its development:

Air Specialist, EPA Tasmania;

Noise Specialist, EPA Tasmania;

Environmental Officer, Northern Regulation Section, EPA Tasmania;

Policy and Conservation Advice Branch (PCAB), Natural and Cultural Heritage Division. The Additional Information prepared by the proponent provides a response to the key issue of air quality raised by the public. The proponent has also undertaken its own public consultation process involving engaging with landowners and stakeholders in the proposed facility as detailed in Table 2 below.


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Table 2: Summary of Stakeholder Consultation by Proponent (Table 5 of the DPEMP)


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6 Evaluation of key issues

The key environmental issue relevant to the proposal identified for detailed evaluation in this report was Air Quality. This issue is discussed in the following subsection.

6.1 Air Quality

Description

Air emissions including pollutants, particulates and odour, have the potential to cause environmental nuisance and harm, particularly to sensitive uses including residences, if not appropriately mitigated and managed.

There are two main sources of air pollutants on the site. The first is the odour from the production processes and the second is the pollutants emitted from combustion of approximately 1300 m3 natural gas per year in the boiler and dryer. Given the scale of emissions associated with combustion and the low expected background concentrations of these pollutants, these sources were not considered further by the Air Quality Impact Assessment (AQIA).

Odour emissions from the facility are all vented through the surface of the biofilter positioned to the south-east of the main process building. An air treatment process flow diagram outlining the different stages of the process where odour is emitted and captured at the facility is shown in Figure 18 of the DPEMP. Process air is collected at each of the production stages and vented through a biofilter prior to being emitted to the environment.

The enclosed nature of the processing equipment is expected to minimise fugitive odour emissions from within the building. Although the proposed activity is not designed as a negative air-pressure building, the airflow required by specific items of equipment assist the capture of unlikely fugitive odours into the process.

The main sources of emissions are as follows:

Raw Materials Intake – air drawn off from around the area from which the raw material is dumped

Hammer Mill – air is extracted directly from the hammer mill

Flash-off – air is extracted directly above the Flash-off area

Dryer – air is extracted directly from the dryer system

Product Cooler – air is extracted directly from the cooler system.

Details of the individual process stages are discussed in the AQIA included as Appendix E of the DPEMP.

Emissions were assumed to be vented through a biofilter at the rates outlined in the AQIA and vented at a concentration of either 250 OU or 500 OU. The proposed biofilter is located to the south-eastern corner of the site as shown in Figure 19 of the DPEMP. The AQIA modelled flow characteristics and emission data for three scenarios:

Scenario 1 – total maximum air flow rate of 95,000m3/hr, each 270m2 biofilter bed has an airflow rate of 13.19 m3/s and a total odour emission rate of 6,597 OU m3/s assuming 500 OU. This equates to an odour emission rate of 24.43 OU m/s.

Scenario 2 – anticipated standard operating conditions with an airflow rate of 70,000m3/hr is expected over the entire biofilter bed. Each 270m2 biofilter bed has an airflow rate of 9.722


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m3/s and a total odour emission rate of 4,861 OU m3/s assuming 500 OU. This equates to an odour emission rate of 18.00 OU m/s.

Scenario 3 – anticipated standard operating conditions with an airflow rate of 70,000m3/hr is expected over the entire biofilter bed. Each 270m2 biofilter bed has an airflow rate of 9.722 m3/s and a total odour emission rate of 2,431 OU m3/s assuming 250 OU. This equates to an odour emission rate of 9.00 OU m/s.

Receptors have been entered into the model using a mixture of arbitrary gridded receptors, boundary receptors located on the facility boundary and discrete receptors situated on the known location of a receptor of interest e.g. house of industrial facility.

Figure 4 Discrete receptor names and locations (Figure 6 of the AIQA)


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Table 3 below presents the peak odour concentration at the boundary of the property of 90.5 OU for Scenario 1, 66.7 OU for Scenario 2 and 33.4 OU for Scenario 3. The 99.5 percentile 1 hour odour concentration at the facility boundary was 87.0 OU, 64.1 OU and 32.0 OU for Scenarios 1, 2 and 3 respectively. These values exceed the EPA odour assessment criteria of 2 OU at or beyond the boundary.


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Table 3: Peak odour concentration at the property boundary (Table 9 of the AIQA)

According to the AQIA, one of the reasons for the possible high odour concentrations at the boundary is that the treated process air is emitted at ground level over a large area with no vertical momentum or thermal buoyancy to aid dispersion. Two stack scenarios were modelled for the AQIA. The decision to install only a biofilter is discussed in section 4 of the EAR.

Table 4 below presents the peak and 99.5th percentile 1 hour average odour concentrations for each of the discrete residential and industrial locations. All residential receptors are predicted to have a concentration below the 2 OU assessment criteria. Four of the five industrial receptors are expected to experience odour concentrations above the criteria. Concentration contours showing the distribution of the odour in the environment (Figures 7 to 12 of the AQIA). The maximum concentration and 99.5% percentile contours for scenario 2 (vented concentration of 500 OU) and scenario 3 (vented concentration of 250 OU) are shown in Figure 5 to Figure 7 below.

Table 4: Odour concentrations at industrial and sensitive receptors surrounding the proposed facility (Table 10 of the AQIA).


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Figure 5: Scenario 2 – Maximum Concentrations (Figure 9 of the AQIA)

Note: the 2 OU assessment criteria value is shown in magenta. The turquoise isopleth represents 10 OU; the green isopleth represents 20 OU and the orange represents 30 OU.


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Figure 6: Scenario 2 – 99.5th Percentile Concentrations (Figure 10 of the AQIA)

Figure 7: Scenario 3 – Maximum Concentrations (Figure 11 of the AQIA)


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Figure 8: Scenario 3 – 99.5th Percentile Concentrations (Figure 12 of the AQIA)

The AQIA acknowledges concerns raised by EPA Tasmania about whether a biofilter can operate at a level lower than 500 OU reliably in the long term. As a result, analysis was undertaken on a facility operated by Ridley at its Narangba Queensland facility. This location has a biofilter designed to operate below 500 OU and has been tested quarterly since January 2015. Results obtained indicated the cell performance averaging 289 OU over the 2 plus year operational life of the biofilter. On this basis, the proponent considers emissions for scenario 3 acceptable and the results reliable from an emissions perspective.

The DPEMP notes the odour assessment required by the Air EPP only takes into account the odour concentration and does not consider other factors that affect the perception of odour or its potential to elicit a negative response (that is, cause an odour complaint or affect amenity at a receptor). They argue, odour is a complex mixture of gases, its effect is based on perception of the odour, and other characteristics of the odour should be considered.

A further assessment of the mitigation factors that apply to odour emissions (frequency, duration and location) concluded the biofilter odour is unlikely to cause an environmental nuisance based on its neutral to slightly unpleasant hedonic tones at weak and distinct perceived intensities. They consider the biofilter odour would not illicit an adverse response from sensitive people until the concentration reached at least 4.6 OU, and more likely 9.6 OU, depending on the sensitivity of the receiving environment.

The dispersion modelling shows existing industrial receptors (receptors designated Industrial 1-5) modelled for the assessment all had predicted concentrations lower than the 9.6 OU concentration (but higher than the 4.6 OU value below which no adverse response is expected). The proponent therefore expects the operation of the activity will have a low likelihood of causing an adverse response at surrounding receptors.

The DPEMP notes the hedonic tone of the odour from the biofilter is considered to have a neutral to slightly unpleasant tone. This means the odour was generally neither agreeable nor offensive to the


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odour panel. This type of odour is common from a biofilter of the type proposed for the activity and the odour is described as a mild bark or fresh wood mulch odour.

The proponent expects the likely duration of odours above the criteria to be low. Residential receptors are not expected to experience any periods of emissions above the 2 OU concentration, whereas the industrial receptors modelled are expected to experience odours above the criteria for less than ~8% for all receptors with the exception of the closest industrial receptor that has a concentration > 2 OU for ~43% of the year. Coupled with the low expected frequency of odour change, the neutral hedonic tone and intensity of the odour, the duration is considered by the proponent to demonstrate that the odours generated will not elicit a negative reaction from the surrounding receptors.

The proponent also contemplated potential impacts from a location perspective, and identified that:

Sensitive receptors (residents) are located at a substantial distance from the activity.

There are existing Industrial receptors situated to the south of the proposed site. It is acknowledged that there is potential for the predicted odour concentration to exceed the 2 OU criterion at locations close to the site. However, the nature of the industries suggests the low level of odour that may occur on occasions will not cause an adverse reaction, with workers on these sites having a lower expectation of air quality than residences.

There is a low population density around the activity, which suggests a correspondingly low risk of impacts on receptors.


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Management measures

Commitments 1 and 2 of the DPEMP are relevant to odour management:

1. Odour generated from the process units listed in the process flow chart in the AQ document will be collected and blown through a biofilter to reduce the nature and concentration of the emitted odour.

2. The biofilter will be maintained to a standard as per the Odour Management Plan.

The proponent believes a well-designed biofilter will work well from the time it is commissioned, removing the required level of odour from the inlet air stream.

An environmental complaints procedure will be established including a complaints register, response protocols and management responsibilities.

Public and agency comment and responses

A single representation was received which raised the following regarding air emissions:

Impacts on the representor’s employees and other businesses in the immediate area.

That the DPEMP does not fully address odour impacts to workers as they are not considered sensitive receptors.

The reliability of meteorological data used for modelling due to location of the station to other buildings.

The exceedance of the Air EPP assessment criteria, and the expectation that the proponent would meet criteria at the boundary.

The lack of 100-percentile concentration modelling in the absence of local high-quality meteorological data.

That Best Practice Environmental Management (BPEM) for odour needs to be implemented for the 100-percentlie concentration.

That the 2 OU criteria will be exceeded at the representor’s boundary based on the Air Modelling report and that they believe it will be greater than predicted due to issues with the modelling.

That approval of a proposal that does not meet assessment criteria will set a precedent for non-compliance of other proposals.

That cumulative impacts and non-enforcement assessment criteria are likely to result in greater impacts on their employees.

According to EPA Tasmania’s Air Specialist, the meteorology of Westbury area is characterised by slow winds and frequent inversion layers, which would affect air dispersion of emitted pollutants by trapping them close to the ground.

They note that in relation to the AQIA, the extent of odour impact has not been discussed in term of distances. Comparing the odour dispersion modelling results provided in the Figures 7 – 10 the specialists estimate the scale of the predicted odour concentrations above 2 OU as circles of diameters approximately 700 m and 1200 m for Scenarios 2 and 1 respectively.

The Air Specialist consider Scenario 3 of the AQIA, where the emissions from the biofilter are 250 OU, to be non-conservative and representing ideal working conditions of the biofilter. They noted measured odour emissions, from a similar biofilter at the Narangba facility provided in the AIQA, are from 100 to 730 OU.

The Air Specialist argued, that during the odour study at the Narangba facility, an odour panel agreed the odour was neutral to slightly unpleasant, this may not be the perception shared by a person living


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or working nearby who is exposed to the same odour. They also noted that the methodology used to derive the odour characteristics is not fully documented in the DPEMP or OMP.

Increasing concentration of odour is considered likely to change perception of the hedonic tone toward ‘unpleasantness’ and therefore a potential nuisance. Nuisance may also result from the duration of exposure to the odour. Figure 22 of the DPEMP confirms that (even for the non-conservative Scenario 3) one of the industrial receptors is expected to experience odours above the Air EPP 2 OU boundary design criteria for more than 40% of the year.

The Air Specialists concluded that there are limitations, which may affect the actuality of emissions and the proponent’s claim: “the assessment of potential impacts has demonstrated that it is highly unlikely that there will be any unacceptable adverse impacts from the proposal”. These limitations include poor air dispersion, the nature of the activity, the level of predicted odour emissions and the limitations of assessing environmental nuisance based on tonal and hedonic characteristics.

Evaluation

The proposal is to be located within the Valley Central Industrial Estate (formerly the Birralee Road Industrial Precinct). The land is zoned as General Industrial under the Meander Valley Interim Planning Scheme 2013 and the proposal is for ‘manufacturing and processing’, a use permitted under the Scheme.

While the use is consistent with the intent of the Industrial Estate, air quality was not considered in the Resource Management and Development Commission of Tasmania decision on the Meander Valley Planning Scheme 1995 Amendment 1/2008 [2008]2 which created the estate. The decision states:

‘concerns about pollution are capable of being managed through permit conditions for individual developments and through ongoing regulation by the Environmental Management and Pollution Control Act 1994’.

Further to this, the decision notes:

‘NEPMs have been created in relation to Ambient Air Quality, National Pollutant Inventory, Movement of Controlled Waste, Used Packaging Materials, Assessment of Site Contamination, Diesel Vehicle Emissions and Air Toxics. Industrial development and use may well be affected by NEPM standards but the relevant issues are capable of being regulated through the provisions of the Environmental Management and Pollution Control Act 1994. The draft amendment contains provisions that require the protection of environmental quality in accordance with EMPCA.’

Any application for a use and development on the Industrial Estate, which is referred to the Board, must be assessed and regulated according to the provisions of the EMPC Act. The assessment must be specific to the application and therefore the land to which the application relates. It must include assessment against the relevant statutory requirements, including the Air EPP made under section 96K of the EMPC Act.

In the Air EPP odour is specifically addressed under section 13. Section 13(1) which states:

If a regulatory authority is satisfied that an odour from an activity is causing or is likely to cause an environmental nuisance or environmental harm, the authority should require that the odour emission from the source not exceed the odour criteria specified in Schedule 3, at or beyond the boundary of the land on which the source is located.

Schedule 3 requires:

an atmospheric dispersion calculation to be performed to ensure that the predicted maximum (“worst case”) ground level concentration does not exceed the concentration criteria specified...The atmospheric dispersion calculation should consider local terrain and meteorology, the effect of

2 TASRPDComm 33 (6 October 2008)


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background concentrations, the contribution of adjacent sources and the need to preserve the capacity

of the local environment to receive future emissions.

The schedule defines the odour criteria to be 2 odour units at or beyond the boundary of a facility.

Section 13 and Schedule 3 specifically relate to odour and form part of Part 4 of the Air EPP, which addresses point sources of air contaminants. According to the DPEMP, the biofilter will capture point sources of emissions for treatment, and therefore Part 4 applies. The biofilter was the only odour abatement technology considered viable by the DPEMP after consideration of alternatives such as wet scrubbers or a stack.

The Air EPP states under section 11(1):

(f) If it is not possible with the application of best practice environmental management to comply with design criteria determined in accordance with [Schedule 2 of the Air EPP or criteria determined by the Director] at the boundary of the land on which the point source of pollution is located, the regulatory authority may permit the emission of the pollutants if it is satisfied that the emission will not –

(i) put at risk the health of any person beyond the boundary of the land on which the point source of the pollution is located;

(ii) allow the pollutant(s) to unreasonably interfere with the enjoyment of the environment by any person living or working beyond the boundary of the land on which the point source of the pollutant(s) is located; or

(iii) otherwise cause serious or material environmental harm; or

(iv) be exceeded outside commissioning, start-up or shutdown periods provided the regulatory authority has specified the conditions under which the excess emissions from such events are permitted; and there is an ongoing commitment to a program of pollution reduction to reach compliance with (d) or (e) as soon as reasonably practical.

Based on the provisions of the Air EPP, 2 OU is the standard design criteria for proposed developments. The representor believed that the proposal should meet this criterion. However, the Air EPP also recognises (through the use of ‘should’ in section 13) that in some circumstances even with the installation of accepted modern technology and best practice environmental management, this criterion will not be met. The Air EPP then allows for the regulatory authority (the Board) to permit the emission of pollutants where it is satisfied that sections (f)(i) and either (f)(ii), (f)(iii) or (f)(iv) are not compromised. It should be noted that the predicted emission exceedances are not limited to commissioning, start-up or shutdown periods to which the Board can apply conditions. The proponent has also not made any commitment to emission reduction to allow future compliance. Therefore section (f)(iv) cannot be applied to this decision and the assessment must focus on (f)(i) and (f)(ii) or (f)(iii).

The proponent has sought to demonstrate that the biofilter is acceptable modern technology and allows for an odour capture system that is best practice environmental management. This is consistent with the expectations of the Air EPP.

The air modelling for the proposed activity demonstrates exceedances of 2 OU at the boundary of the Land based on the technology proposed. However, the model also demonstrates that odours above 2 OU units are unlikely beyond the boundary of the industrial estate based on scenario 3, with levels of 1 OU beyond the industrial estate for scenario 2. No impacts to residences are identified under any of the scenarios.

The representation raised concerns that workers were not sufficiently considered by the DPEMP, which focused on compliance with 2 OU at the nearest residences. However, the level of odour emissions at surrounding industrial sites has been modelled allowing the consideration of impacts to workers as required by the Air EPP. The Board ultimately determines whether the emissions are likely to compromise the environmental values of the Air EPP including interference with the enjoyment of the environment by any person working beyond the boundary of the land (see section 11(i)(f((ii)). It should be noted that based on the standard operating conditions scenario, odour levels


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at the representors site are likely to be below 2 OU under scenario 2 and below 1 OU for scenario 3.

The DPEMP identifies that the Air EPP does not consider the complexity of odour beyond setting a numerical design or regulatory limit. While the proponent acknowledges that levels exceed the standard criteria, they present a case that the levels predicted at both industrial and residential receptors are such that the emissions will not compromise sections (f)(i) and (f)(ii) or (f)(iii).

In particular, the Air Quality Impact Assessment (AQIA) predicts biofilter odour would not illicit an adverse response from sensitive people until the concentration reached at least 4.6 OU, and more likely 9.6 OU, depending on the sensitivity of the receiving environment. With the dispersion modelling showing existing industrial receptors (receptors designated Industrial 1-5) had predicted concentrations lower than the 9.6 OU concentration (but higher than the 4.6 OU value below which no adverse response is expected) the proponent does not expect impacts to workers at these sites. It is noted these predictions are based on the less than conservative scenario 3. The more conservative scenarios 1 and 2 predict higher odour concentrations at the industrial receptors in the range from 11.49 to 15.50 OU for 99.5 percentiles and 15.51 to 20.65 OU for 100 (max) percentiles. No evidence is provided as to the likely effect on receptors at these concentrations.

While this argument is not consistent with the use of the Air EPP and its 2 OU design criterion, the following may allow acceptance of the criteria:

absence of predicted odour impacts at residences, and

the modelling for scenario 3 predicted levels of odour below that likely to cause an adverse reaction at industrial receptors (under worst case scenario conditions for standard operating conditions).

However, the predicted higher concentrations under scenarios 1 and 2 may not result in the same conclusion of no adverse response.

The proponent considers that while the emissions levels may be higher than the 2 OU, they are unlikely to cause a response from nearby receptors, that is, they don’t expect their activity to cause environmental nuisance or harm beyond the boundary of the site. ‘Environmental nuisance’ as defined under the EMPC Act means:

(a) the emission, discharge, depositing or disturbance of a pollutant that unreasonably interferes with, or is likely to unreasonably interfere with, a person's enjoyment of the environment; and

(b) any emission, discharge, depositing or disturbance specified in an environment protection policy to be an environmental nuisance.

EPA Tasmania’s Air Specialists consider hedonistic characteristics an inappropriate measure of the potential impact of odour emissions. An odour that is pleasant to one person may not be considered so to another. Concentration provides a constant level of measure that can be applied to measure potential impact and allow regulation. It should be noted, 2 OU is a measure of concentration at which a majority of people will detect an odour, not whether that odour is pleasant or unpleasant. Although it is expected that once an odour reaches a certain level it will be unpleasant to most people.

Other regulated activities emit odour at a level detectable at or beyond the boundary of the land during normal or abnormal operating conditions, some of which are located in urban areas. EPA Tasmania usually becomes involved when complaints are received, as they are an indication that environmental nuisance may be occurring and that a regulatory response is needed. This is consistent with the approach being proposed for this activity. The difference here is that this is a new activity with a known and predicted level of odour which may, from commencement, emit an odour at a level that could affect workers on the industrial estate.

While it is acknowledged 2 OU cannot be met at the boundary of The Land, consideration of the effects of odour emissions in the context of s.11 of the Air EPP has been undertaken by the Board in its assessment. The proposed aqua feed mill will produce relatively large volumes of odorous air


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that requires collection and treatment. It is noted that biofilters are widely employed elsewhere in Australia, including Tasmania, to treat this type of odour stream. Furthermore, the proponent’s Brisbane facility is known to be located within an industrial estate with little buffer to neighbours and has not been the cause of complaints due to odour emissions from the biofilter.

The Board considered that the proposed odour collection and treatment system represents best practice environmental management for this type of activity, and that the odour emissions would not put at risk the health of any person beyond the boundary of The Land.

To determine whether the odour emissions are likely to cause environmental nuisance more than just the numerical value of the predicted odour emission must be considered, including the type, intensity and duration of the odour. It is accepted, based on the evidence of the proponent’s odour consultant, as well as EPA Tasmania’s own experience, that the odour from a properly functioning biofilter is not normally considered to be offensive, nor a threat to physical human health.

While the proponent argues scenario 3 as being representative of the proposed aqua feed mill, scenario 2 is considered to be a more reasonable base case to consider. It is noted there will be variations in the odour emission levels and that the predicted levels of odour units at receptors will probably be both higher and lower than the modelled outcome of Scenario 2 on occasions. Furthermore, the meteorological data that was used in the modelling would have overestimated rather than underestimated odour levels.

Based on the modelling, it is considered that there should not be any impact from odour on sensitive receptors. It is also noted that odour emissions from the proposed aqua feed mill will not be the only odour source from within the general industrial estate and that it would not be unreasonable or uncommon in such a setting for a higher level of odour to be present than in residential areas.

Based on the evidence supplied and EPA Tasmania’s expertise, it is considered the proposed aqua feed mill could be operated without causing an unreasonable level of odour (i.e. a statutory nuisance) for nearby industrial neighbours. Nonetheless, the proximity of the neighbours means that a very high standard of operation will be required with strict adherence to the conditions contained in Appendix 3. While the detailed range of monitoring and maintenance measures proposed in the Odour Management Plan are considered appropriate, the Plan requires a better analysis of contingencies and responses. It is acknowledged there will remain some risk of nuisance if the plant is not operated to a high standard, however, there are a number of regulatory tools available to the Director, EPA under EMPCA should this situation arise.

To ensure that the activity is managed in accordance with the proponent’s expectation that no nuisance or harm will result from their operations, they will be required to comply with condition A1. This condition requires management measures to be implemented to prevent odours causing environmental nuisance beyond the boundary of the land. The presence of environmental nuisance will rely on detection by complaints and odour surveys (see below). To ensure complaints are received and managed condition G6 requires the establishment of a complaints register. This register then supports regulation with condition A1. In addition, under condition A3, any odour compliant must be reported to the Director, EPA within 24 hours to allow suitable review and response.

To support compliance with condition A1, that is, to ensure the absence of environmental nuisance or harm, the activity must be undertaken in accordance with an Odour Management Plan under condition A2. This is consistent with commitment 2 of the DPEMP. An OMP was submitted as additional information subsequent to the public consultation period, however further refinement of the plan is required. The plan must be approved prior to the commencement of commissioning. The Odour Management Plan provides details of the operating and monitoring instructions for the odour capture system to ensure it performs to prevent environmental nuisance or harm beyond the boundary of the site. The Plan also needs to include a clear Shutdown Procedure in the event of sustained odour impacts. Records of monitoring and maintenance must be made available to an authorised officer on request.


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In addition, the proponent will be required to undertake regular odour surveys under condition A4. The OMP includes an annual Field Ambient Odour Assessment, consistent with an Odour survey. While the OMP proposes the surveys on a biannual and annual basis, a greater frequency is proposed for the first 12 months from commencement of commissioning to ensure the facility is operating in accordance with the proponent’s expectations and the absence of environmental nuisance. Surveys will then be on a biannual basis. Surveys may also be required by the Director, including in response to complaints. This condition requires the odour survey to be undertaken in accordance with the OMP and any additional guidance provided by the Director. This allows EPA Tasmania’s Air Specialists to ensure that the design of the surveys is appropriate.

Condition A5 requires the submission of an odour survey report and details the minimum requirements of the report. It also requires an assessment against the predictions of the DPEMP and recommendations for any mitigation or management measures needed to ensure that the absence of environmental nuisance is maintained.

Should the activity not comply with condition A1, the EMPC Act provides a regulatory framework to require necessary actions to establish compliance. This comes with the risk of additional costs or delays to the proponent, should their assumptions of the absence of likely environmental nuisance or harm from odours not be accurate.

The representation questioned the reliability of the meteorological data used for air modelling and the need for 100th percentile modelling. The DPEMP acknowledges that the calm weather identified in the data may not be a true reflection of the Westbury site as the building located directly to the north of the station may be providing a shadow effect. However, the report also acknowledges the data’s inclusion into the model is a conservative approach as calm and light wind conditions are expected to produce worst-case dispersion conditions from the biofilter. The AQIA also includes the calculation of concentrations for both the 100th (maximum) and 99.5th percentile statistics, due to the doubt over the quality of the meteorological data used for the Westbury region. An analysis of meteorological data is included in Section 5.3 and Appendix A of the AQIA (Appendix E of the DPEMP).

The representation also raised concerns regarding cumulative impacts. The decision on the planning scheme amendment places the focus of air assessment on individual applications and their specific emission sources. However, it is noted that Schedule 3 of the Air EPP states:

The atmospheric dispersion calculation should consider local terrain and meteorology, the effect of background concentrations, the contribution of adjacent sources and the need to preserve the capacity of the local environment to receive future emissions.

The AQIA for the activity report does not include an assessment of the contribution of adjacent sources or need for preservation of the capacity of the air shed to receive future emissions. The potential exists that future development of the Industrial Estate will be limited as other applications, undertaking an AQIA in accordance with Schedule 3, may be unable to demonstrate that the air shed capacity will not be compromised, based on current sources.

The DPEMP identifies emissions from the combustion of natural gas in the dryer and boiler to be small in scale. They were not considered further in the AQIA. The Air EPP expects nitrous oxide (NOx) emissions to be 350 mg/m3. The proponent is reminded in the information schedule that emissions from the boiler stack should meet this criterion. Condition A6 allows the Director to require monitoring of in-stack concentrations of the gas-fired boiler in the event that concerns are raised regarding NOx or other point source emission levels. To support potential in-stack testing, condition A7 requires the installation of appropriate testing facilities.

Conclusions

The proponent will be required to comply with the following standard conditions:

G1 Access to and awareness of conditions and associated documents

G2 Incident response


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G3 No changes without approval

G4 Change of responsibility

G5 Change of ownership

G6 Complaints register

The proponent will be required to comply with the following site-specific conditions:

CN1 Construction Environmental Management Plan

G7 Notification prior to commissioning

A1 Odour Management

A2 Odour Management Plan

A3 Odour Complaints

A4 Odour survey

A5 Odour survey report

A6 Gas-fired boiler emissions

A7 Stack test facilities


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7 Other issues

In addition to the key issues, the following environmental issues are considered relevant to the proposal and have been evaluated in Appendix 1.

1. Liquid Waste, Surface Water and Groundwater

2. Noise Emissions

3. Waste Management

4. Biodiversity and Natural Values

5. Environmentally Hazardous Materials

6. Decommissioning and Rehabilitation

|8 Report conclusions

This assessment has been based upon the information provided by the proponent in the permitapplication, DPEMP, Additional Information and in correspondence and discussion between EPATasmania and the proponent and the proponent's representatives.

This assessment has incorporated specialist advice provided by EPA Division scientific specialistsand regulatory staff, other Divisions of DPIPWE and other government agencies.

This assessment has taken into account issues raised in public submissions.

It is concluded that:

1. the RMPS and EMPCS objectives have been duly and properly pursued in the assessmentof the proposal; and

2. the assessment of the proposal has been undertaken in accordance with the EnvironmentalImpact Assessment Principles.

It is concluded that the proposal is capable of being managed in an environmentally acceptablemanner such that it is unlikely that the RMPS and EMPCS objectives would be compromised,provided that the Permit Conditions - Environmental No. 9685 appended to this report are imposedand duly complied with.

Report approval

Environmental Assessment Report and conclusions, including permit conditions,adopted:

rWarreh JonesCHAIRPERSONBoard of the Environment Protection Authority

Meeting date: 18th December 2017

Environmental Assessment Report Ridley - Feed Mill, Westbury

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9 References

AECOM (2017); Development Proposal and Environmental Management Plan (dated 11 September 2017); Ridley Agriproducts Pty Ltd, Melbourne, Victoria.

Ridley (2017); Westbury Odour Management Plan (HSE-WEST-001), Version 2, Health, Safety & Environment, Westbury (dated 29 November 2017).

10 Appendices

Appendix 1 Assessment of other issues Appendix 2 Summary of public and agency submissions Appendix 3 Permit Conditions – Environmental No. 9685

Appendix 1


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Appendix 1 Assessment of other issues

Issue 1: Liquid Waste, Surface Water Quality and Groundwater

Description of potential impacts

The release of wastewater or contaminated stormwater has the potential to cause environmental nuisance or harm if not appropriately mitigated or managed, particularly through the contamination of water bodies and groundwater.

The main sources of wastewater generated by the facility are from:

The biofilter;

The boiler blowdown process; and

The wash bay area where cleaning of grinder screens takes place.

The majority of waste from processing will be captured by a wet slurry system which is a part of the extrusion process. This process will capture and manage the feed waste (wet and/or dry, mash and/or formed pellets) from pre conditioning and the extruder. All wet slurry will be re-introduced into the process at the pre conditioner in an accurately controlled manner.

No wastewater will be discharged to land or water.

Uncontaminated stormwater will be discharged into the natural drainage system on and around the site.

Management measures proposed in DPEMP

Commitment 3: Preparation of a Construction Environmental Management Plan, which will provide for management of stormwater quality impacts from erosion and sedimentation and dust management.

Commitment 4: Finalise a Trade Waste Agreement (TWA) with TasWater.

Commitment 5: The liquid ingredients unloading area will be bunded to contain spills and prevent stormwater contamination.

Commitment 13: The site stormwater system will have an isolation valve that can be closed, if a major spill occurs, so as to contain the spill on site.

Commitment 14: Stormwater from the wider property will be diverted into the natural drainage system surrounding the property via swales and an interceptor pit as per site design.

Appendix 1


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Public and agency comment

The representation raised concerns regarding stormwater design and management.

Meander Valley Council provided the following comments during the assessment process:

‘The planning scheme provisions for the precinct [Valley Central Industrial Estate] require specific stormwater responses protecting the function of the public stormwater system and water quality through water quality protection devices. In complying with the planning scheme, the proposal will comply with the State Policy on Water Quality Management and the State Stormwater Strategy. The application is required to include a drainage plan that demonstrates compliance with the stormwater provisions…’

Subsequent comments from Council on receiving the representation state:

‘I advise that there is a requirement in the planning scheme provisions for this precinct that all development must connect to the reticulated stormwater system, with all stormwater from individual sites being treated by water quality devices appropriate to the nature of development, prior to discharge to the reticulated system.

This development shows on the plans the interception of stormwater through an interceptor prior to discharge. The development will connect to the reticulated system either through the existing easement or directly to Integrity Drive. Detailed stormwater engineering designs are typically provided for the plumbing permit application whereby sizing of infrastructure ensures that there is no overtopping in peak storm events, however it is clear the proposal collects all stormwater from the site, directs through a water quality device and discharges to the reticulated system which is directed under Birralee Road to the water course on the western side of Birralee Road.

There is no risk of stormwater from this development reaching the [representors] site as expressed in the representation.’

Evaluation

The proponent intends to discharge liquid waste to sewer via a Trade Waste Agreement with TasWater. The assessment of the application is based on this outcome. Operation will not be able to commence until an agreement has been reached. The Trade Waste Agreement will define the quality of effluent to be discharged and subsequently any relevant pre-treatment necessary to meet the requirements. Section 2.1.8 of the DPEMP notes:

‘Discussions have been held with TasWater regarding a Trade Waste agreement. In the event that further evaluation of the Narangba wastewater suggests that exceedances may still occur, further onsite treatment will be implemented into the detailed plant design to satisfy Trade Waste requirements’.

Condition WW1 requires wastewater to discharge to sewer, consistent with the proposal. Condition WW2 requires the discharge to sewer to be with approval from the operator. The information schedule identifies the need to gain a TWA as per the requirements of the Water And Sewerage Industry Act 2008 and Water And Sewerage Industry (General) Regulations 2009.

It is noted that the Council report submitted as part of the Resource Management and Development Commission of Tasmania decision on the Meander Valley Planning Scheme 1995 Amendment 1/2008 [2008] TASRPDComm 33 (6 October 2008) discusses sewerage capacity. The section entitled The Site states: ‘Sewerage is not yet available but extension from the Westbury treatment plant (via new pump stations and rising main) is proposed. However limited capacity of the treatment plant precludes acceptance of large volumes of industrial waste water or high level wastes requiring advanced treatment’.

EPA Tasmania is not aware of any upgrades to Westbury WWTP to manage capacity or suitable treatment. Should the proponent be unable to reach agreement with TasWater on liquid waste disposal, alternative disposal may require additional approvals under both planning and environmental legislation.

Based on comments from Meander Valley Council, stormwater management and regulation will be addressed by them under the provisions of the planning scheme and any permit conditions

Appendix 1


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imposed by Council. The planning scheme does not assess potential impacts during construction. The proponent will therefore be required to prepare and implement a Construction Environmental Management Plan, consistent with commitment 3 of the DPEMP, under condition CN1.

Impacts to groundwater are expected to be limited based on the absence of discharge of wastewater to land or water and proposed stormwater management measures. No conditions in relation to groundwater are therefore proposed.

Conclusion

The proponent will be required to comply with the following site-specific condition:


WW1 Management of Contaminated Water

WW2 Discharges to sewer

No conditions in relation to liquid waste (effluent) or groundwater are proposed.

Condition OI3 in Schedule 3: Information reminds the proponent that they will need to enter into a Trade Waste Agreement with TasWater as per the Water And Sewerage Industry Act 2008 and Water And Sewerage Industry (General) Regulations 2009.

Appendix 1


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Issue 2: Noise Emissions


Noise emissions from the activity have the potential to cause environmental nuisance, particularly at sensitive receptors including residences, unless appropriately mitigated or managed.

The proposed hours of operation of the processing plant are 24 hours a day, five days a week increasing to seven days a week depending on market demand.

The proposed Mill is located on a site in the General Industrial Zone adjacent to Birralee Road, approximately 500 metres north-west of Bass Highway, Westbury. The site is currently surrounded by unoccupied land, with industrial zoned land located to the south.

The proposed site and nearest noise sensitive receivers (both Industrial and Residential) are presented in Figure 29 with noise sensitive receivers listed in Table 13 of the DPEMP.

Typical activities on the site will include;

the delivery and storage of raw materials

grinding feed in a multi-mill

mixing feed

drying into pelleted feed

packaging activities

dispatch of finished products to customers.

According to Section 2.1.10 of the DPEMP, the plant and equipment with noise emissions will include:

Assessment of noise and vibration impacts for construction and operation for the facility were undertaken as part of the DPEMP.

During construction, the predicted noise levels during the loudest stage of construction (site establishment) are predicted to comply with project noise limits at all residential and non-residential receptors. All other stages of construction are therefore expected to comply with all relevant noise levels. The report concludes, that since the nearest off-site receptors are greater than 100 metres from the proposed site, no significant risk of adverse vibration impacts are likely to surrounding receptors.

The results of noise modelling of the operational noise impacts indicate that under worst case weather conditions operational noise is likely to comply at all receptors except Receptor A (residence at 650 metres). Noise emissions at Receptor A are predicted to exceed the evening and night criteria by 1 and 5 dB (A) respectively under worst case weather conditions but only if roller doors on the north-western side of the facility are open. There will be no deliveries during the evening or night, the roller doors on the north-western side of the building will therefore be closed allowing compliance with the noise limits at Receptor A under all weather conditions.

Appendix 1


34


Commitment 6: Where possible, equipment with directional noise emissions will be orientated away from the nearest sensitive receivers that are located to the west of the site.

Commitment 7: Plant equipment work will be regularly maintained in line with fit for purpose site operations.

Commitment 8: Maintenance work on construction plants with the potential to generate noise impacts will be confined to standard daytime construction hours.

Commitment 10: To reduce noise emissions and for security purposes, the roller doors located on the north-western facade will be closed during the evening and night-time periods.


EPA Tasmania’s noise specialist acknowledged there is a faint possibility of night time noise but the expectation is that this will be controlled by basic management measures (closing doors).

They also noted there are some assumptions that may have implications (e.g. providing a specified level of attenuation for certain noisy components) and suggested the inclusion of the requirement for a noise survey following full commissioning.

Evaluation

The Council report submitted for the Resource Management and Development Commission of Tasmania decision on the Meander Valley Planning Scheme 1995 Amendment 1/2008 [2008] TASRPDComm 33 (6 October 2008) states:

The edge of the town of Westbury is located approximately 1 km south of the site and was considered sufficiently distant not to be affected by noise… There are two residences approximately 850m north of the site. Nevertheless, all activities on the site must comply with the Environmental Management and Pollution Control Act 1994 and potential impacts on sensitive uses would be considered.

The Council submitted ‘that the separation of the industrial estate from sensitive uses and Council’s permit conditions relating to emissions…would prevent noise…adversely affecting persons outside the Industrial Zone.’

The noise study undertaken for the DPEMP indicates that environmental nuisance is unlikely to occur at any noise sensitive premises. Noise levels at nearby industrial premises are also likely to comply with relevant noise levels. However, predicted noise levels are only 1 dBA below the assessment criteria at the residence 650 metres from the site for both day and night time. To ensure that the facility continues to meet the predicted levels and does not cause environmental nuisance at the nearest sensitive receptor, noise emission limits will be imposed. The levels of 35, 40 and 45 dBA will apply during night time, evening and day time respectively under condition N1. Under condition G6 a complaints register will also be required to track and manage any complaints, including noise complaints.

The compliance within noise emission limits, as detailed in the DPEMP, is based on a variety of assumptions. To confirm the activity’s ability to comply with the noise emission limits, noise survey will be required within 3 months of the date of the commencement of operations under condition N2. Subsequent surveys may also be required and this is detailed in the condition. Details of noise survey method and reporting is provided in condition N3. As the date for completion of the survey is based on commencement of operation, Condition G8 requires notification prior to commencement of operation.

The predicted noise level for construction is 44 dBA at the nearest sensitive receptor, only 1 dBA below the standard limit of 45 dBA. To ensure that noise emissions from construction activities do not cause impacts to sensitive receptors, construction activities will be limited to the hours of 6 am to 6 pm Monday to Friday and 8 am to 6 pm on Saturdays, unless otherwise approved by the Director, under condition CN2. The CEMP required under condition CN1 will also include management measures for minimising noise impacts during construction.

Appendix 1


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Conclusion

The proponent will be required to comply with the following standard condition:


The proponent will be required to comply with the following site-specific conditions:


CN2 Operating hours - Construction

N1 Noise emission limits

N2 Noise survey requirements

N3 Noise survey method and reporting requirements

Appendix 1


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Issue 3: Waste Management


Inappropriate management of waste has the potential to cause environmental nuisance or harm through disposal to land or water. Section 6.5.2 of the DPEMP states, solid wastes generated directly from the process of feed production are minimal.

The majority of waste from processing will be captured by a wet slurry system. The wet slurry system captures and manages the feed waste (wet and/or dry, mash and/or formed pellets) from pre-conditioning and the extruder, then reintroduces it into the process at the pre-conditioner in an accurately controlled manner.

The fines feed waste (including dusts) from sieves, cyclones and dryer will be collected, weighed, recorded and conveyed automatically to designated macro batching bins for weighing and inclusion into diets.

The solid waste streams generated are:

Used Intermediate Bulk Container (IBC)/totes or bag-in boxes from oils/liquids delivered to the site;

Bulk feed bags (6 kg to 1000 kg capacity);

Waste from dust collection and biofilter (media change-out); and

Normal office and staff wastes.

The bag-in-boxes and bulk feed bags are the main waste streams. It is estimated that up to 2,000 feed bags of different sizes will be generated at the site per week.

Waste streams from the dust collection systems that are not suitable to be reintroduced into the production process and biofilter media change-out are expected to be either relatively small or infrequent and non-hazardous. Biofilter media change-out is expected to be required every 3 years or as specified in the biofilter maintenance schedule. A complete replacement would generate a maximum of 1,000 m3 of solid waste. These wastes will be disposed of to landfill.


The DPEMP states the waste streams will be managed in accordance with the Environmental Management and Pollution Control (Waste Management) Regulations 2010. The intent is to reuse and recycle wherever possible.

Bag-in-boxes and bulk feed bags which are the main waste stream and IBC will either be fully recycled or returned to the supplier or to a third party reconditioner.

Small amounts of waste from dust collection and general office and staff wastes will be disposed of to landfill via traditional municipal or industrial waste collections.

Wastes will be stored in covered areas within the process building to avoid contamination of stormwater runoff.

Commitment 9 of the DPEMP is relevant to waste management:

Reuse of Intermediate Bulk Containers and recycling of other raw material bags.


None

Evaluation

Based on the information provided, solid waste generation will be minimal and the proponent is committed to management of waste in accordance with the waste hierarchy. Commitment 9 of the DPEMP is supported. Any controlled wastes will be disposed of in accordance with requirements under the Waste Management Regulations. No additional conditions are proposed.

Appendix 1


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Conclusion

No conditions in relation to solid waste management will be imposed. Schedule 3: Information provides information on the Waste Management Hierarchy.

Appendix 1


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Issue 4: Biodiversity and Natural Values


Inappropriate location of development can impact on threatened species and communities. The introduction and spread of weeds and diseases to the surrounding environment has the potential to contaminate waterways or impact on the habitats of threatened species and communities, unless appropriately mitigated or managed.

According to section 6.7 of the DPEMP, the site of the proposed Aqua Feed Mill is predominantly flat and is crossed by a shallow drainage line running from south-east to north-west. The site has previously been used for agricultural and has generally been degraded by exotic pasture species.

The biodiversity and nature conservation values of the broader industrial precinct subdivision were assessed as a part of the approvals process for the rezoning and subdivision of the site. The assessments, including the EPBC referral prepared by the Meander Valley Council, report on NRM values, and Green and Gold Frog Habitat assessment are referenced in the DPEMP.

The DPEMP concludes natural flora and fauna values of the proposed Aqua Feed Mill site have been degraded by previous agricultural land uses with the site now characterised by exotic pasture species and weeds. Only the Commonwealth listed Green and Gold Frog has been identified as potentially occurring within the locality. Based on the Green and Gold frog habitat assessment conducted in May 2008, the drainage line that crosses the site of the proposed Aqua Feed Mill contains no habitat for the species. It was therefore concluded that the potential impact of the proposal on the Green and Gold frog is likely to be negligible.


Section 6.7.4 of the DPEMP states opportunities to incorporate native vegetation into any landscaping on site will be investigated.

Once the facility is constructed, vermin prevention measures and control procedures will be implemented. A qualified/certified external service provider will be engaged to manage pest control. A monthly report on pest control will be prepared and reviewed to allow consideration of changes to the service program.

The risk of infection of the Amphibian Chytrid Fungus to the Green and Gold Frog L. raniformis will be managed by:

Ensuring that all machinery and equipment used during construction of the proposed Ridley Aqua Feed Mill will be managed to control the spread of the Amphibian Chytrid Fungus, by adhering to the Tasmanian Wash-down Guidelines for Weed and Disease Control: Machinery, Vehicles and Equipment, Edition 1.

These Guidelines include instructions on:

o When to wash down

o Equipment for wash down and wash down procedures

Specifically, the following instructions should be adhered to:

o All equipment, vehicles and footwear should be dry and clean before entering the site to prevent spread of the Fungus via contaminated soils

o The disposal of water and damp or muddy soils at the proposed development site should be minimised or undertaken as far away as possible from waterways, ponds and/or wetlands

Commitment 15 of the DPEMP states:

Vermin control and weed management procedures will be implemented that will include preventative measures in line with Ridley policies, procedures and relevant certifications.

Appendix 1


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Comments provided by Meander Valley Council at the time of referral of the NOI state:

‘[Flora and fauna] matters were investigated and resolved for the amendment [to the planning scheme to establish the Industrial Precinct]. The nature of the environment has not changed since this was conducted…the only potential species of significance identified was habitat for the Green and Gold Frog in the watercourse to the west of Birralee Road, which has been addressed and approved through a Threatened Species permit’.

The Resource Management and Development Commission of Tasmania decision on the Meander Valley Planning Scheme 1995 Amendment 1/2008 [2008] TASRPDComm 33 (6 October 2008) states:

Investigations into the presence of the Green and Gold Frog had found limited areas of habitat in the proposed zone and noted that drainage lines on the western part of the site would provide linkages for movement of the animals.

As a result the following sub-clause was included in the amendment to the planning scheme to allow the establishment of the Industrial precinct.

3.5.4(7) Environmental Quality

(e) Provision shall be made for the appropriate treatment of the identified drainage lines and associated buffer area to protect the environmental qualities of the watercourses as habitat.”

According to this decision, the permit included recommended hygiene measures to be followed to minimise potential spread of the disease ‘frog chytrid fungus’.

Comments provided by PCAB during DPEMP development were:

Flora

There are no records, within five kilometres, of threatened flora listed under the Threatened Species Protection Act 1995 (TSPA) and/or the Environment Protection and Biodiversity Conservation Act 1999 (EPBCA). Given that the area to be used for the proposed development is already highly disturbed, it is anticipated that the proposed activity is unlikely to impact on listed flora species, no further action is required.

Fauna

Given the proposed development is on highly disturbed land, PCAB has no concerns regarding the impact of the development on threatened fauna on site; no further action is required.

Threatened Native Vegetation

There are no threatened native vegetation communities on site; no further action is required.

However, if during the assessment process it becomes apparent that there may be impacts on listed natural values off site (e.g. through wastewater disposal) these impacts should be considered in the DPEMP and PCAB contacted for further advice.

Evaluation

The potential for impacts to any threatened species or community is considered low. The provisions of the planning scheme were modified to ensure drainage lines on the Industrial Estate are managed to prevent impacts to Green and Gold Frogs. The drainage line located on the proposed mill site had been determined not to have suitable habitat for this species. As such, no specific conditions in relation to flora or fauna management are proposed.

The Planning Commission and Council have recognised the existence of Green and Gold frogs in the surrounding environment and the need to protect them through imposition of appropriate hygiene measures. Such measures will also limit the introduction and spread of weeds in the surrounding agricultural land. The proponent will therefore be required, under condition FF1, to ensure all machinery is washed-down in accordance with the Weed and Disease Planning and Hygiene Guidelines - Preventing the spread of weeds and diseases in Tasmania, by the Department of Primary Industries, Parks, Water and Environment, dated March 2015.

Pest and vermin management measures, reflected in Commitment 15, are supported. Pest and vermin management is considered a food safety issue for management under environmental

Appendix 1


40

health legislation. Council regulates environmental health services. No conditions are to be imposed in relation to this matter.

Conclusion

The proponent will be required to comply with the following standard condition:

FF1 Washdown Guidelines

Appendix 1


41

Issue 5: Environmentally Hazardous Materials


Inappropriate storage, handling and disposal of environmentally hazardous materials can lead to environmental harm through contamination of land or water.

The chemicals, dangerous goods and hazardous substances to be used and stored at the site are presented in Table 29 of section 6.6 of the DPEMP, together with the quantities and Dangerous Goods Categories.

None of the materials being used for the production of aqua feed are classified as Dangerous Goods. The location of the storages for all materials is shown in Figure 3 of the DPEMP. The only Dangerous Good used and stored on the site is LPG used as fuel for the fork lifts.


The storage facility for LPG will be designed in accordance with relevant Australian Standards and emergency protocols defined.

Liquid storage and handling areas will be designed with bunds to Australian Standards and able to accommodate 120% capacity of the largest tank volume plus incident rainfall.

Tanks will be fitted with level alerts.

Internal stormwater system will be able to be fully isolated in the event of a spill.

Commitments 11 and 12 of the DPEMP are relevant to hazardous materials management:

Contingency plans will be developed to address potential incidents such as a major liquid (e.g. fish oil) spill, bulk liquid storage tank failure or over filling, and a fire.

The site will have a number of spill kits located in areas with higher potential for spills and leaks as per site based risk assessments.


None

Evaluation

Environmentally hazardous materials will be stored at the site. Storage and handling must meet the requirements of Dangerous Goods legislation. Information on these legal requirements is provided in Schedule 3: Information. To ensure hazardous materials are stored and handled to prevent environmental impacts, the proponent will be required to implement and comply with conditions H1 and H2. To ensure any spill is managed to prevent discharge that may cause environmental nuisance or harm spill kits will be required under condition H3. This is consistent with Commitment 12 of the DPEMP. The commitment to contingency plans is also supported and will contribute to effective management of environmentally hazardous materials.

Conclusion


H1 Storage and handling of hazardous materials

H2 Hazardous materials (<250 litres)

H3 Spill kits

Appendix 1


42

Issue 6: Decommissioning and Rehabilitation


Inappropriate decommissioning and rehabilitation after the cessation of an activity can lead to environmental nuisance or impact including impacts to waterways from sedimentation and contamination.

The proposed Aqua Feed Mill has an expected life of at least 20 years. Once the timing of decommissioning has been established, a rehabilitation management plan would be developed.

In the event that the plant closed, Ridley would decommission the facility in a responsible manner and in accordance with regulatory requirements. This would include relocation of plant, equipment and unused raw materials to other facilities or sale on the open market. It is likely that the overall warehouse structure would be suited to a wide variety of other industrial uses once clear of plant and equipment.


Commitment 27 of the DPEMP states:

Ridley would decommission the facility in a responsible manner and in accordance with regulatory requirements. This would include relocation of plant, equipment and unused raw materials to other facilities or sale on the open market.


None

Evaluation

To ensure temporary suspension of the activity does not cause environmental nuisance or harm, condition DC1 will be imposed. Environmental management of decommissioning and rehabilitation will be implemented through the requirement under condition DC3 to develop a decommissioning and rehabilitation plan (DRP) 3 years post-commencement and then updated as required. In the event of cessation of the activity, notification under condition DC2 is required. The DRP will then be implemented as per the requirements of condition DC4. As the DRP is required 3 years after the commencement of operations. Condition G8 will require notification of the commencement of operations.

Conclusion


G8 Notification prior to commencement

DC1 Temporary suspension of activity

DC2 Notification of cessation

DC3 Decommissioning and Rehabilitation Plan

DC4 Implementation of the DRP

Appendix 2


43

Appendix 2 Summary of public and agency submissions

In the following table, DPEMP means the Development Proposal and Environmental Management Plan for Ridley AgriProducts Pty Ltd (Ridley), prepared by AECOM Australia Pty Ltd dated 11 September 2017.

Representation No./ Agency

DPEMP section no.

Comments and issues

1 6.1 Concerned about impacts on its employees and other businesses in the immediate area.

1 Consider the DPEMP does not fully address odour impacts to workers as they are not considered sensitive receptors.

1 Questions reliability of meteorological data used for modelling due to location of the station to other buildings.

1 Identifies the exceedance of the Air EPP assessment criteria. Expect proponent to meet criteria at the boundary.

1 Questions the absence of 100-percentile concentration modelling in the absence of local high-quality meteorological data.

1 BPEM for odour needs to be implemented for the 100-percentlie concentration.

1 2 OU will be exceeded at their boundary based on Air Modelling report and they believe will be greater than predicted due to issues with the modelling.

1 Approval of proposal that does not meet assessment criteria will set a precedent for non-compliance of other proposals.

1 Cumulative impacts and non-enforcement of meeting assessment criteria are likely to result in greater impacts on their employees.

1 6.2 Concerned stormwater will enter agricultural land and the representors land, increasing the potential for flooding at the WWTP and increase risk of erosion, degradation on natural drainage channels and increase contaminants (sediments) entering their site.

1 Expect implementation of appropriate stormwater design infrastructure to mitigate risks.

1 Stormwater discharge point should be directed to Council infrastructure along Integrity Drive and Roxford Avenue.

Appendix 3


44

Appendix 3 Permit Conditions – Environmental No. 9685

PCE9685(r1) 1/17

PERMIT PART BPERMIT CONDITIONS - ENVIRONMENTAL No. 9685

Issued under the Environmental Management and Pollution Control Act 1994

Activity: The operation of Produce Processing Works (ACTIVITY TYPE: ProduceProcessing Works (works discharging all wastewater to external approved

Wastewater Treatment Works).)

RIDLEY WESTBURY TASMANIA, 16 INTEGRITY DRIVEWESTBURY TAS 7303

The above activity has been assessed as a level 2 activity under the Environmental Management

and Pollution Control Act 1994.

Acting under Section 25(5)(a)(i) of the EMPCA, the Board of the Environment ProtectionAuthority has required that this Permit Part B be included in any Permit granted under the Land UsePlanning and Approvals Act 1993 with respect to the above activity.

Municipality: MEANDER VALLEYPermit Application Reference: PA.18.0018EPA file reference: 252180

Date conditions approved: _' "/'•

"hI

Signed: ___(.^W^-- '-Jd^SCHAIRPERSON, BOARD OF THE ENVIRONMENTPROTECTION AUTHORITY

CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

PCE 9685(r1) 2/17

DEFINITIONS

Unless the contrary appears, words and expressions used in this Permit Part B have the meaning

given to them in Schedule 1 of this Permit and in the EMPCA. If there is any inconsistencybetween a definition in the EMPCA and a definition in this Permit Part B, the EMPCA prevails tothe extent of the inconsistency.

ENVIRONMENTAL CONDITIONS

The person responsible for the activity must comply with the conditions contained in Schedule 2 ofthis Permit Part B.

INFORMATION

Attention is drawn to Schedule 3, which contains important additional information.

a'CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

^

PCE9685(r1) 3/17

Table Of Contents

Schedule 1: Definitions......................................................................................................................^

Schedule 2: Conditions........................................................................................................................?

Maximum Quantities................................................................................................................. 7

Ql Regulatoiy limits...............................................................................................?

General.......................................................................................................................................?

Gl Access to and awareness of conditions and associated documents.................. 7

G2 Incident response...............................................................................................7

G3 No changes without approval............................................................................?

G4 Change of responsibility................................................................................... 7

G5 Change of ownership........................................................................................ 7

G6 Complaints register........................................................................................... 7

G7 Notification prior to coinmissioning................................................................. 8

G8 Notification prior to coirunencement................................................................ 8

Atmospheric...................................................,...........................................................................8

Al Odour management........................................................................................... 8

A2 Odour Management Plan.................................................................................. 8

A3 Odour complaints.............................................................................................. 9

A4 Odour sm-veys................................................................................................... 9

A5 Odour survey report.......................................................................................... 9

A6 Gas-fu-ed boiler emissions................................................................................ 9

A7 Stack testing facilities..................................................................................... 10

Constmction............................................................................................................................. 10

CN1 Construction Environmental Management Plan...........................................10

CN2 Operating hours - Construction.................................................................... 10

Decoimmssioning And Rehabilitation.....................................................................................11

DC1 Temporary suspension of activity................................................................ 11

DC2 Notificationof cessation...............................................................................11

DC3 Decommissioning and Rehabilitation Plan.................................................. 11

DC4 Implementation of the DRP.......................................................................... 12

Flora And Fauna...................................................................................................................... 12

FF1 Washdown Guidelines................................................................................... 12

Hazardous Substances.............................................................................................................. 12

HI Storage and handling of hazardous materials................................................. 12

H2 Hazardous materials (< 250 litres).................................................................. 13

H3 Spill kits.......................................................................................................... 13

Noise Control........................................................................................................................... 13

N1 Noise emission limits...................................................................................... 13

N2 Noise suivey requirements..............................................................................13

N3 Noise survey method and reporting requirements.......................................... 13

Wastewater Management........................................................................................................ 14

WW1 Management of Contaminated Wastewater............................................... 14

WW2 Discharges to sewer.................................................................................... 14

Schedules: Information.................................................................................................................... 15

Legal Obligations..................................................................................................................... 15

L01EMPCA........................................................................................................ 15

L02 Storage and handling of dangerous goods, explosives and dangerous

substances............................................................................................................. 15

LOS Trade Waste Agreement............................................................................... 15

L04 Gas-fu-ed boiler NOx emissions................................................................... 15


18 DEC 2017

PCE 9685(r1) 4/17

Other InfonTiation.................................................................................................................... 15

Oil Waste management hierarchy........................................................................ 15

012 Notification of incidents under section 32 ofEMPCA .................................15

013 Solid matter in wastewater ............................................................................15

Attachments

Attachment 1: The Land (modified: 17/11/2017 09:19)..............................................................1 page


1 8 DEC 2017

PCE9685(r1) 5/17

Schedule 1: Definitions

In this Permit Part B:-

Activity means any environmentally relevant activity (as defined in Section 3 of EMPCA) to whichthis document relates, and includes more than one such activity.

Authorized Officer means an authorized officer under section 20 ofEMPCA.

Commissioning means the testing of major items of equipment and is taken to be completed when

the item(s) are being used or operated in the course of normal commercial operations.

Construction means activities associated with the constniction phase of the activity, including but

not limited to, activities associated with the clearance of vegetation, site works to create a level site,

rock breaking, installation of fences and other infrastructure whether on land or in water.

Control Location (Noise) means a location chosen to represent the general ambient sound without

contribution from noise sources at the activity.

Director means the Director, Environment Protection Authority holding office under Section 18 ofEMPCA and includes a person authorised in writing by the Director to exercise a power or functionon the Director's behalf.

DPEMP means the the Development Proposal and Environmental Management Plan for RidleyAgriProducts Pty Ltd (Ridley), prepared by AECOM Australia Pty Ltd and dated 11 September2017.

DRP means Decommissioning and Rehabilitation Plan.

EMPCA means the Environmental Management and Pollution Control Act 1994.

Environmental Harm and Material Environmental Harm and Serious Environmental Harm

each have the meanings ascribed to them in Section 5 ofEMPCA.

Environmental Nuisance and Pollutant each have the meanings ascribed to them in Section 3 of

EMPCA.

Environmentally Hazardous Material means any substance or mixture of substances of a nature

or held in quantities which present a reasonably foreseeable risk of causing serious or material

environmental harm if released to the environment and includes fuels, oils, waste and chemicals but

excludes sewage.

Noise Sensitive Premises means residences and residential zones (whether occupied or not),

schools, hospitals, caravan parks and similar land uses involving the presence of individual people

for extended periods, except in the course of their employment or for recreation.

Nominated Exhaust Points means the gas-fu-ed boiler stack.

Person Responsible is any person who is or was responsible for the environmentally relevant

activity to which this document relates and includes the officers, employees, contractors, joint

venture partners and agents of that person, and includes a body corporate.

Stack Test means the taking of measurements and the collection of samples for analysis from

within a chimney, stack or flue.

vV CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

PCE9685(r1) 6/17

Tasmanian Noise Measurement Procedures Manual means the document titled Noise

Measurement Procedures Manual, by the Department of Environment, Parks, Heritage and the

Arts, dated July 2008, and any amendment to or substitution of this document.

The Land means the land on which the activity to which this document relates may be carried out,and includes: buildings and other structures permanently fixed to the land, any part of the landcovered with water, and any water covering the land. The Land falls within the area defined by 16Integrity Drive, Westbuiy forming part of Certificate of Title 174186/1 and as further delineated atAttachment 1.

Washdown Guidelines means the document titled Weed and Disease Planning and HygieneGuidelines - Preventmg the spread of weeds and diseases in Tasmania, by the Department of

Primary Industries, Parks, Water and Environment, dated March 2015, and any amendment to or

substitution of this document.

•^.


18 DEC 2017

PCE9685(r1) 7/17

Schedule 2: Conditions

Maximum Quantities

Ql Regulatory limits

1 The activity must not exceed the following limits :

1.1 12,000 kilograms per hour of processing capacity

General

Gl Access to and awareness of conditions and associated documents

A copy of these conditions and any associated documents referred to in these conditions must

be held in a location that is known to and accessible to the person responsible for the activity.

The person responsible for the activity must ensure that all persons who are responsible for

undertaking work on The Land, including contractors and sub-contractors, are familiar with

these conditions to the extent relevant to their work.

G2 Incident responseIf an incident causing or threatening environmental nuisance, serious environmental harm or

material environmental harm from pollution occurs in the course of the activity, then the

person responsible for the activity must immediately take all reasonable and practicable action

to minimise any adverse environmental effects from the incident.

G3 No changes without approval

1 The following changes, if they may cause or increase the emission of a pollutant which

may cause material or serious environmental harm or environmental nuisance, must

only take place in relation to the activity if such changes have been approved in writingby the EPA Board following its assessment of an application for a permit under theLand Use Planning and Approvals Act 1993, or approved in writing by the Director:

1.1 a change to a process used in the course of carrying out the activity; or

1.2 the construction, installation, alteration or removal of any structure ol- equipment

used in the course of carrying out the activity; or

1.3 a change in the quantity or characteristics of materials used in the course of

carrying out the activity.

G4 Change of responsibilityIf the person responsible for the activity intends to cease to be responsible for the activity, thatperson must notify the Director in writing of the full particulars of any person succeeding himor her as the person responsible for the activity, before such cessation.

G5 Change of ownershipIf the owner of The Land upon which the activity is carried out changes or is to change, then,

as soon as reasonably practicable but no later than 30 days after becoming aware of the

change or intended change in the ownership of The Land, the person responsible must notify

the Director in writing of the change or intended change of ownership.


1 A public complaints register must be maintained and made available for inspection byan Authorized Officer upon request. The public complaints register must, as a

minimum, record the following detail in relation to each complaint received in which itis alleged that environmental harm (including an environmental nuisance) has been

caused by the activity:

'/CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

PCE9685(r1) 8/17

1.1 the date and time at which the complaint was received;

1.2 contact details for the complainant (where provided);

1.3 the subject-matter of the complaint;

1.4 any investigations undertaken with regard to the complaint; and

1.5 the manner in which the complaint was resolved, including any mitigation

measures implemented.

2 Complaint records must be maintained for a period of at least 3 years.

G7 Notification prior to commissioningAt least 14 days prior to the commencement of dry and wet testing of the plant, the personresponsible for the activity must notify the Director of the date on which commissioning isexpected to commence.

G8 Notification prior to commencement

The Director must be notified in writing of the commencement of operations at least 14 days

before that occurs.

Atmospheric

Al Odour management

The person responsible must institute such odour management measures as are necessary to

prevent odours causing environmental nuisance beyond the boundary of The Land.

A2 Odour Management Plan

1 Prior to the commencement of commissioning, or by a date otherwise specified in

writing by the Director, an Odour Management Plan must be submitted to the Directorfor approval. This requirement will be deemed to be satisfied only when the Directorindicates in writing that the submitted document adequately addresses the requirementsof this condition to his or her satisfaction.

2 The plan must be prepared in accordance with any reasonable guidelines provided bythe Director.

3 Without limitation, the plan must include details of the following:

3.1 Identification of all odours sources associated with the proposal during all phases;

3.2 Characterisation of odour sources and assessment of potential to result in

environmental nuisance;

3.3 Hierarchy of control;

3.4 Details of all odour controls with sufficient technical detail;

3.5 Planned verification of plant performance during commissioning;

3.6 Contingency plans for emergency or upset conditions;

3.7 Contingency plans for complaints, including a Shutdown Procedure;

3.8 Monitoring procedures and triggers for response;

3.9 Record keeping and reporting;

3.10 Staff responsibilities;

3.11 Staff competence and training;

3.12 Appended procedural documents including (but not limited to) complaints,emergency response, check sheets, equipment spares etc;

3.13 a table containing all of the major commitments made in the plan;

3.14 an implementation timetable for key aspects of the plan; and

3.15 a reporting program to regularly advise the Director of the results of the plan.

•^ CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

PCE9685(r1) 9/17

4 The person responsible must implement and act in accordance with the approved plan.

5 Records of monitoring and maintenance undertaken in accordance with the Odour

Management Plan must be made available to an authorized officer upon request.

6 In the event that the Director, by notice in writing to the person responsible, eitherapproves a minor variation to the approved plan or approves a new plan in substitution

for the plan originally approved, the person responsible must implement and act inaccordance with the varied plan or the new plan, as the case may be.

A3 Odour complaintsIn the event that an odour complaint is received in relation to the activity, the complaint must

be reported to the Director within 24 hours.

A4 Odour surveys

1 Unless otherwise approved in writing by the Director, a survey of odour emissions from

the activity must be completed:

1.1 quarterly for 12 months from the date of commencement of commissioning and

thereafter biannually.

1.2 within six (6) months of any change to the activity which is likely to substantiallyalter the character or increase odour emissions; and

1.3 at such other times as may reasonably be required by the Director by notice in

writing.

2 The Odour survey must be undertaken in accordance with the 'Field Ambient OdourAssessment' procedure detailed in the Odour Management Plan and any reasonable

guidance provided by the Director.

3 The number and location of measurement location points (MLPs) must be approved inwriting by the Director prior to conducting a survey of odour emissions.

A5 Odour survey report

1 Odour survey results must be submitted to the Director within 30 days of thecompletion of the odour survey in the form of a written odour survey report.

2 Unless otherwise approved in writing by the Director, the report must:

2.1 include a comparison of odour emission rates calculated from the odour survey

and the odour emission rates used as an input to the atmospheric dispersion

modelling included in the DPEMP; and

2.2 discuss any difference between the measured odour emissions and the odour

modelling results in the DPEMP; and

2.3 conclude if odorous gases from the activity are likely to cause environmental

nuisance beyond the boundary of The Land;and

2.4 provide details of any mitigation or management measures to be implemented to

address any odour emission issues that are causing, or are likely to cause,

environmental harm; and

2.5 provide a schedule for the implementation of any proposed mitigation ormanagement measures.

A6 Gas-fired boiler emissions

At any time reasonably required by the Director by notice in writing, monitoring of in-stackconcentrations of the gas-fired boiler must be undertaken, in accordance with methodology

approved by the Director.

^CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

PCE9685(r1) 10/17

A7 Stack testing facilities

1 The following stack testing facilities must be available at all nominated exhaust pointswhen undertaking stack testing required by these conditions:

1.1 sampling positions must be in accordance with Australian Standard AS 4323.1(Stationary source emissions - selection of sampling positions), or as approved in

writing by the Director;

1.2 safe sampling platforms must be located to allow access to the sampling positions

and safe access to these sampling platforms must be provided; and

1.3 all necessary services required for the test method prescribed must be provided.

Construction


1 At least 30 days prior to the commencement of construction activities, or by a date

otherwise specified in writing by the Director, a Construction Environmental

Management Plan ('Construction EMP') must be submitted to the Director.

2 The Construction EMP must contain a detailed description of the proposed timing andsequence of the major construction activities and of the proposed management measures

to be implemented to avoid or minimise the environmental impacts during theconstruction phase. The Construction EMP must include, but not necessarily be limited

to, management measures in relation to the following:

2.1 prevention of impacts upon surface water and waterways;

2.2 erosion and sediment control;

2.3 noise control;

2.4 dust control;

2.5 management of environmentally hazardous materials;

2.6 cultural (Aboriginal and non-aboriginal) heritage considerations;

2.7 flora and fauna management;

2.8 weed, pest and disease management;

2.9 quality control arrangements including supervision by appropriately qualified andexperienced persons, detailed construction specifications for key items of

environmental management infrastructure, documented site procedures, quality

control testing and the keeping of appropriate records; and

2.10 acid sulphate soil management (if identified in pre construction testing).

3 Unless otherwise specified in writing by the Director, construction activities must becarried out in accordance with an approved Construction EMP.

CN2 Operating hours - Construction

1 Unless otherwise approved in writing by the Director:

1.1 Constiiiction activities must not be undertaken outside 0600 hours to 1800 hoursMonday to Friday; and 0800 hours to 1800 hours Saturdays

1.2 Notwithstanding the above paragraph, the construction activities must not be

carried out on Sundays or Public Holidays that are observed State-wide (EasterTuesday excepted).

//CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

PCE9685(r1) 11/17

Decommissionine And Rehabilitation

DC1 Temporary suspension of activity

1 Within 30 days of becoming aware of any event or decision which is likely to give riseto the temporary suspension of the activity, the person responsible for the activity must

notify the Director in writing of that event or decision. The notice must specify the dateupon which the activity is expected to suspend or has suspended.

2 During temporary suspension of the activity:

2.1 The Land must be managed and monitored by the person responsible for the

activity to ensure that emissions from The Land do not cause serious

enviromnental harm, material environmental harm or environmental nuisance; and

2.2 If required by the Director a Care and Maintenance Plan for the activity must besubmitted, by a date specified in writing by the Director, for approval. The person

responsible must implement the approved Care and Maintenance Plan, as may be

amended from time to time with written approval of the Director.

3 Unless otherwise approved in writing by the Director, if the activity on The Land hassubstantially ceased for 2 years or more, rehabilitation of The Land must be carried out

in accordance with the requirements of these conditions as if the activity has

permanently ceased.

DC2 Notification of cessationWithin 30 days of becoming aware of any event or decision which is likely to give rise to thepermanent cessation of the activity, the person responsible for the activity must notify the

Director in writing of that event or decision. The notice must specify the date upon which theactivity is expected to cease or has ceased.

DC3 Decommissioning and Rehabilitation Plan

1 A draft Decommissioning and Rehabilitation Plan (DRP) must be submitted forapproval to the Director by 3 years after commencement of operations.

2 Unless otherwise approved in writing by the Director, a revised DRP must be submittedto the Director for approval:

2.1 when changes to the conduct of the activity are to occur that will result in

significant changes to decommissioning and rehabilitation obligations; and

2.2 within 30 days of the Director being notified of the likely cessation of operations;and

2.3 where required by notice in writing, by a date specified by the Director.

3 The DRP must be prepared in accordance with guidelines issued by the Director. If noguidelines have been issued by the Director the measures described in this plan mustinclude, but should not necessarily be limited to:

3.1 completion of a site histoiy, site contamination assessment and contamination

remediation plan (including consideration ofgroundwater);

3.2 removal of all equipment, structures and waste materials unless they are

considered by the Director to be beneficial to a future use of The Land;

3.3 grading and levelling/recontouring and revegetating (or other approved method ofsoil stabilisation) of the surface of the disturbed area;

3.4 management of drainage on The Land so as to reduce erosion and prevent release

of a pollutant from The Land;

3.5 maintenance of the rehabilitated area for a period of not less than three years from

the date of cessation of operations;

^' I

^-' CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

PCE 9685(r1) 12/17

3.6 an itemised estimate of the costs of carrying out the works listed in the DRP and astatement of how these costs will be provided for; and

3.7 any other detail requested in writing by the Director.

DC4 Implementation of the DRPFollowing permanent cessation of the activity, the decommissioning of the activity and therehabilitation of The Land must be carried out in accordance with the most recent

Decommissioning and Rehabilitation Plan (DRP) approved by the Director, as may beamended from time to time with written approval of the Director.

Flora And Fauna

FF1 Washdown GuidelinesPrior to entering the land, machinery must be washed in accordance with the Washdown

Guidelines, or any subsequent revisions of that document.

Hazardous Substances

HI Storage and handling of hazardous materials

1 Unless otherwise approved in writing by the Director, all environmentally hazardousmaterials, including all chemicals, fuels, and oils, stored on The Land in volumes

exceeding 250 litres must be stored and handled in accordance with the following:

1.1 Any storage facility must be contained within a spill collection bund with a netcapacity of whichever is the greater of the following:

1.1.1 at least 110% of the combined volume of any interconnected vessels within

that bund;or

1.1.2 at least 110% of the volume of the largest storage vessel; or

1.1.3 at least 25% of the total volume of all vessels stored in that spill collectionbund; or

1.1.4 the capacity of the largest tank plus the output of any firewater system over

a twenty minute period.

1.2 All activities that involve a significant risk of spillages, including the loading andunloading of bulk materials, must take place in a bunded containment area or on a

transport vehicle loading apron.

1.3 Bunded containment areas and transport vehicle loading aprons must:

1.3.1 be made of materials that are impervious to any environmentally hazardous

material stored within the bund;

1.3.2 be graded or drained to a sump to allow recovery of liquids;

1.3.3 be chemically resistant to the chemicals stored or transferred;

1.3.4 be designed and managed such that any leakage or spillage is contained

within the bunded area (including where such leakage emanates verticallyhigher than the bund wall);

1.3.5 be designed and managed such that the transfer of materials is adequately

controlled by valves, pumps and meters and other equipment wherever

practical. The equipment must be adequately protected (for example, withbollards) and contained in an area designed to permit recovery of any

released chemicals;

1.3.6 be designed such that chemicals which may react dangerously if they comeinto contact have measures in place to prevent mixing; and


1 8 DEC 2017

PCE9685(r1) 13/17

1.3.7 be managed such that the capacity of the bund is maintained at all times (forexample, by regular inspections and removal of obstructions).

H2 Hazardous materials (< 250 litres)

1 Unless otherwise approved in writing by the Director, each environmentally hazardous

material, including chemicals, fuels and oils, stored on The Land in discrete volumes

not exceeding 250 litres, but not including discrete volumes of 25 litres or less, must be

stored within bunded containment areas or spill trays which are designed andmaintained to contain at least 110% of the volume of the largest container.

2 Bunded containment areas and spill trays must be made of materials that are impervious

to any enviromnentally hazardous materials stored within the bund or spill tray.

H3 Spill kitsSpill kits appropriate for the types and volumes of materials handled on The Land must bekept in appropriate locations to assist with the containment of spilt environmentally hazardous

materials.

Noise Control

N1 Noise emission limits

1 Noise emissions from the activity when measured at any noise sensitive premises in

other ownership and expressed as the equivalent continuous A-weighted sound pressure

level must not exceed:

1.1 45 dB(A) between 0700 hours and 1800 hours (Day time); and

1.2 40 dB(A) between 1 800 hours and 2200 hours (Evening time); and

1.3 35 dB(A) between 2200 hours and 0700 hours (Night time).

2 Where the combined level of noise from the activity and the normal ambient noiseexceeds the noise levels stated above, this condition will not be considered to be

breached unless the noise emissions from the activity are audible and exceed the

ambient noise levels by at least 5 dB(A).

3 The time interval over which noise levels are averaged must be 10 minutes or an

alternative time interval specified in writing by the Director.

4 Measured noise levels must be adjusted for tonality, impulsiveness, modulation and low

frequency in accordance with the Tasmanian Noise Measurement Procedures Manual.

5 All methods of measurement must be in accordance with the Tasmanian Noise

Measurement Procedures Manual.

N2 Noise survey requirements

1 Unless otherwise approved by the Director, a noise survey must be carried out:

1.1 within 3 months from the commencement of operation; and

1.2 within six (6) months of any change to the activity which is likely to substantiallyalter the character or increase the volume of noise emitted from The Land; and

1.3 at such other times as may reasonably be required by the Director by notice in

writing.

N3 Noise survey method and reporting requirements

1 Noise surveys must be undertaken in accordance with a survey method approved in

writing by the Director, as may be amended from time to time with written approval ofthe Director.

2 Without limitation, the survey method must address the following:

/

%'CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

18 DEC 2017

PCE9685(r1) 14/17

2.1 measurements must be canned out at day, evening and night times (where

applicable) at each location; and

2.2 measurement locations, and the number thereof, must be specified, with onelocation established as a control location (noise).

3 Measurements and data recorded during the survey must include:

3.1 operational status of noise producing equipment and throughput of the activity;

3.2 subjective descriptions of the sound at each location;

3.3 details of meteorological conditions relevant to the propagation of noise;

3.4 the equivalent continuous (L ) and L,, L_, L_, L_ and L_ A-weighted sound'eq-' """_"!_'_," 10^ 7A°' "50 """ "99_" ••^"o—"^""

pressure levels measured over a period of 10' mmutes or" an alternative time

interval approved by the Director;

3.5 one-third octave spectra over suitably representative periods of not less than 1

minute; and

3.6 naiTow-band spectra over suitably representative periods of not less than 1 minute.

4 A noise survey report must be forwarded to the Director within 30 days from the dateon which the noise survey is completed.

5 The noise survey report must include the following:

5.1 the results and interpretation of the measurements required by these conditions;

5.2 a map of the area surrounding the activity with the boundary of The Land,measurement locations, and noise sensitive premises clearly marked on the map;

5.3 any other information that will assist with interpreting the results and whether theactivity is in compliance with these conditions and EMPCA; and

5.4 recommendations of appropriate mitigation measures to manage any noise

problems identified by the noise survey.

Wastewater Management

WW1 Management of Contaminated Wastewater

1 Unless otherwise approved in writing by the Director, the following wastewater streams

generated on The Land that are not recycled or reused for beneficial purposes must be

directed to sewer:

1.1 All process wastewater;

1.2 All contaminated and potentially contaminated wastewater, such as wash down

water; and

1.3 Any stormwater identified as having reasonable potential for contamination.

WW2 Discharges to sewer

Wastewater, including treated wastewater, must be discharged to sewer with approval of the

operator of the sewerage system.

'lit!CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY?

18 DEC 2017

PCE9685(r1) 15/17

Schedule 3: Information

Legal Oblisations

L01 EMPCAThe activity must be conducted in accordance with the requirements of the Environmental

Management and Pollution Control Act 1994 and Regulations thereunder. The conditions of

this document must not be construed as an exemption from any of those requirements.

L02 Storage and handling of dangerous goods, explosives and dangerous substances

1 The storage, handling and transport of dangerous goods, explosives and dangerous

substances must comply with the requirements of relevant State Acts and any

regulations thereunder, including:

1.1 Work Health and Safety Act 2012 and subordinate regulations;

1.2 Explosives Act 2012 and subordinate regulations; and

1.3 Dangerous Goods (Road and Rail Transport) Act 2010 and subordinateregulations.

LOS Trade Waste AgreementThe person responsible must enter into a trade-waste agreement with the relevant sewerage

authority as per the Water And Sewerage Industry Act 2008 and Water And Sewerage Industry(General) Regulations 2009 prior to the commencement of operations.

L04 Gas-fired boiler NOx emissionsAtmospheric emissions and in-stack concentrations of the gas-fired boiler nominated exhaust

point should be controlled to meet requirements of the Environment Protection Policy (AirQuality) 2004. Specifically, Schedule l,Table 2: NOx - 350 mg/m3.

Other Information

Oil Waste management hierarchy

1 Wastes should be managed in accordance with the following hierarchy of wastemanagement:

1.1 waste should be minimised, that is, the generation of waste must be reduced to the

maximum extent that is reasonable and practicable, having regard to best practice

environmental management;

1.2 waste should be re-used or recycled to the maximum extent that is practicable;

and

1.3 waste that cannot be re-used or recycled must be disposed of at a waste depot site

or treatment facility that has been approved in writing by the relevant planningauthority or the Director to receive such waste, or otherwise in a manner approved

in writing by the Director.

012 Notification of incidents under section 32 of EMPCAWhere a person is required by section 32 ofEMPCA to notify the Director of the release of apollutant, the Director can be notified by telephoning 1800 005 171 (a 24-hour emergencytelephone number).

013 Solid matter in wastewater

1 Solid matter should be prevented by all reasonable means from entering the wastewater

stream. Without limiting the generality of the term, reasonable means includes:


,/

^ / 18 DEC 2017

PCE9685(r1) 16/17

1.1 effective screening at all points of wastewater ingress to the wastewater treatment

system to prevent the entiy of gross solids;

1.2 implementation of comprehensive operating procedures, and the appropriate

training and supervision of employees, contractors and sub-contractors; and

1.3 good housekeeping including the provision of adequate containers to avoid loss tothe floor and the control of spillage by sweeping, shovelling, impoundment, or theentrapment of wastes in tanks or vessels for further treatment before disposal.

./'

^CHAIRPERSON, BOARD OF THE ENVIRONMENT PROTECTION AUTHORITY

1 8 DEC 2017

Attachment 1: The Land


18 DEC Z017

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