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Environmental Assessment Report Western Tiers Proteins – Rendering facility expansion, Cressy

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ENVIRONMENTAL ASSESSMENT REPORT

Rendering Facility Expansion

Burlington Road, Cressy

Western Tiers Proteins Board of the Environment Protection Authority

September 2014


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Environmental Assessment Report

Proponent Western Tiers Proteins

Proposal Rendering facility expansion

Location Burlington Road, Cressy

NELMS no. 8986

Permit application no.

P14-204 (Northern Midlands Council)

Doc1 folder EN-EM-EV-DE-238495

Doc1 no. H307676

Class of Assessment

2B

Assessment process milestones

17/10/2013 Notice of Intent submitted

14/11/2013 DPEMP Guidelines issued

26/06/2014 Permit application submitted to Council

26/06/2014 Referral received by Board

05/07/2014 Start of public consultation period

02/08/2014 End of public consultation period

22/08/2014 Supplementary information submitted to Board


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Acronyms

Board Board of the Environment Protection Authority

BOD Biochemical oxygen demand

DAF Dissolved air flotation

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)

GLC Ground level concentration

LPG Liquefied petroleum gas

LUPA Act Land Use Planning and Approvals Act 1993

OU Odour unit

RMPS Resource management and planning system

SD Sustainable development

TAPM The Air Pollution Model

TQM Tasmanian Quality Meats

WTP Western Tiers Proteins


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Report summary

This report provides an environmental assessment of Western Tiers Proteins Pty Ltd’s proposed rendering facility expansion. The proposal involves an expansion of the existing red meat rendering plant at 5 Burlington Road, Cressy, to include a new rendering line to process fish and chicken waste and an increase in maximum processing capacity from 2,000 kg per hour to 7,000 kg per hour. This report has been prepared based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP) and DPEMP Supplement. Relevant government agencies and the public have been consulted and their submissions and comments considered as part of this assessment. On 7 August 2014, the Board requested that the proponent submit supplementary information to address public, government agency (including DPIPWE) and Council comments on the DPEMP and to meet other information requirements. Satisfactory supplementary information was submitted by the proponent on 22 August 2014. 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. Attachment 2 of the permit conditions contains the table of commitments from the DPEMP.


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Table of Contents

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

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

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

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

5 Public and agency consultation ................................................................ 8

6 Evaluation of key issues ........................................................................... 9

6.1 Air emissions .................................................................................................................... 9 6.2 Bio-security ..................................................................................................................... 17

7 Other issues ........................................................................................... 20

8 Report conclusions ................................................................................. 20

9 References ............................................................................................. 22

10 Appendices ......................................................................................... 22

Appendix 1 Assessment of other issues .............................................................................. 23 Appendix 2 Summary of public and agency submissions .................................................... 29 Appendix 3 Permit Conditions - Environmental .................................................................... 34


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1 Approvals process

A Notice of Intent (NOI) in relation to the proposal was received by the Board of the Environment Protection Authority (the Board) on 17 October 2013. An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Northern Midlands Council on 26 June 2014. The proposal is defined as a ‘level 2 activity’ under clause 4(f), Schedule 2 of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being a rendering or fat extraction works. 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 application was received by the Board on 26 June 2014. A NOI in relation to the proposal was first received by the Board on 15 July 2013. This was subsequently updated and resubmitted on 17 October 2013. 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 and Northern Midlands Council on 14 November 2013. Several drafts of the DPEMP were submitted to the EPA for comment prior to its finalisation and acceptance on behalf of the Board. The final DPEMP was submitted to Council with the permit application. The DPEMP was released for public inspection for a 28-day period commencing on 5 July 2014. 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. Two public submissions were received. On 7 August 2014, the Board requested that the proponent submit supplementary information to address public, government agency (including DPIPWE) and Council comments on the DPEMP and to meet other information requirements. Satisfactory supplementary information was submitted by the proponent on 22 August 2014.


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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.

3 The proposal

The expansion of Western Tiers Proteins Pty Ltd’s (WTP) rendering plant at Cressy (Figures 1 & 2) will involve the installation and operation of new rendering equipment for the processing of chicken waste, and an increase in maximum processing capacity from 2,000 kg per hour up to 7,000 kg per hour. The proposal will also include the installation of Dissolved Air Flotation (DAF) treatment for the existing red meat rendering process. The new rendering process, including maintenance, waste management and monitoring systems, will be integrated into the existing operation. The process, equipment and steps associated with the new rendering line are shown in Figure 3. Note, the application referred to the Board included the processing of fish waste. Based on information received during the public consultation period, the proponent indicated that fish waste would not be processed (see Section 6.2). An approved (planning permit P13-228) biofilter and storage shed are currently being constructed, and are not considered a part of the proposed expansion. Further, there will be no direct discharge of wastewater from the proposed activity to the environment. Wastewater will be directed to a series of treatment lagoons managed by Tasmanian Quality Meats (TQM). While the specific management of these lagoons is not considered a part of the proposal, consideration is given to the quality of wastewater from the proposed activity in relation to the capacity of the lagoons to receive such effluent (see Appendix 1, Issue 1). The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 2 of the DPEMP. Table 1: Summary of the proposal’s main characteristics

Activity

Installation and operation of a rendering line for the processing of chicken waste, and an increase in maximum processing capacity up to 7,000 kg per hour or 92 tonnes per day.

Location and planning context

Location 5 Burlington Road, Cressy, Figure 1.

Land zoning Rural Resource


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Land tenure The land is owned by Tasmanian Quality Meats (TQM). WTP lease approximately 0.6 hectares of land in the north-east section of the property (Figure 2).

Existing site

Land Use Rendering plant, commissioned in 2007.

Topography The site is located 136 metres above sea level (ASL), approximately 8 metres above Brumbys Creek. An oxbow feature, connected intermittently to the creek, is located on the flood plain immediately to the north west (‘Brumby’s Back Creek’, Figure 1). The site slopes gently towards the floodplain.

Geology Quaternary and tertiary alluvial, aeolian and marsh deposits.

Soils Soils derived from the underlying quaternary and tertiary sediments.

Hydrology Brumbys Creek is located approximately 740 metres to the north west (Figure 1). Waste water from the activity is directed to waste water treatment lagoons managed by TQM (Figure 1). Treated water from the lagoons is used for irrigation on the Cressy Research and Demonstration Station, managed by DPIPWE.

Fauna / Flora The site is an existing industrial facility with some grassed area. There are no records of threatened flora or fauna within the proposed project site.

Local region

Climate (Cressy meteorological station)

Annual mean maximum and minimum temperature is 17.2°C and 5.1°C respectively.

Mean annual rainfall is 626.9 mm.

Year round prevailing winds are from the northwest. Surrounding land zoning, tenure and uses

TQM, immediately to the west of the proposed facility, is an established abattoir which supplies red meat to the existing rendering operation. The land surrounding the abattoir and rendering operation is used for agriculture, and zoned Rural Resource. The Cressy Research and Demonstration Station occupies land to the north, west and south. The land to the east is privately owned agricultural land. Petuna salmon hatchery is located approximately 1.2 kilometres to the north (Figure 1), with Brumby Creek an established trout fishery. Two residential properties owned by TQM and occupied by their employees are located approximately 150 m to the south. Three residential properties in other ownership are located approximately 1000 m to the west and south west (Figure 1). Cressy is located 3 kilometres to the north.

Species of conservation significance

Eight fauna species as identified in the Natural Values Atlas (NVA) and Environment Protection and Biodiversity Conservation (EPBC) databases are recorded within 500 metres of the site (see Table 9 of the DPEMP for species list).

Proposed infrastructure

Major equipment

Proposed chicken rendering equipment (Figure 3) and dissolved air flotation. (DAF) (equipment layout shown in Appendix D of DPEMP).

Existing 1.5 MW liquefied petroleum gas (LPG) boiler, red meat rendering equipment, bio-filter.

Other infrastructure

750 kVA substation on site servicing the abattoir and rendering plant.

1MW backup boiler (currently being re-furbished).

Storage shed.

Amenities on site, shared between TQM and WTP.

TQM waste water treatment lagoons and associated underground drainage network from the WTP rendering site.

Inputs

Water Water for steam generation, vapour cooling and wash down, sourced from “Brumby’s Back Creek” (Figure 1).

Energy Existing 750 kVa substation.


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LPG, expected to be 50,000 L per month. Raw materials Chicken waste.

Wastes and emissions

Liquid Wastewater from processing and washdown (cleaning) will be directed to TQM’s waste water treatment lagoons (“TQM Effluent Lagoons” Figure 1).

Atmospheric Odour, boiler emissions, dust from internal and external traffic.

Solid Construction materials and packaging.

Miscellaneous general waste during operation.

Rendering process solids. Controlled wastes

Small quantities of oils and solvents from equipment maintenance.

Chicken waste generated by out of specification raw material or product, or during upset in processing.

Noise Operation of equipment and movement of traffic.

Greenhouse gases

Emissions from the boiler are estimated to be 919 COe tonnes per year. Total emissions

per tonne of product are expected to be 6 percent lower due to the more efficient process.

Construction, commissioning and operations

Proposal timetable

Construction period of 2 months, commencing 3 weeks following approval.

Commissioning period of 1 to 2 weeks for the new rendering process line and DAF.

Operating hours

Monday to Friday, 0900 to 0100 hours.

On occasions Saturdays, 0700 to 1100 hours.


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Figure 1: Proposed location (Figure 1 of the DPEMP)


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


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Figure 3: Process overview (Figure 3 of the DPEMP). Note, the DAF will not be located externally, as shown, but will be contained within the process building, see Section 6.1.


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4 Need for proposal and alternatives

According the DPEMP, the new rendering process will provide an additional processing facility for wastes from Tasmania’s chicken processing industries, creating a value added product and contributing to industry security. The rendering process will incorporate the latest technology, producing product suitable for export with improved wastewater quality. WTP currently employs three staff. A further four staff will be employed, creating additional local jobs and flow on employment benefits in transport, packaging and trade services. The construction phase of the project will involve the engagement of local businesses. Alternative sites The proposal involves the expansion of an existing rendering facility, utilising existing infrastructure and services. No other alternative sites were considered. Alternative technology According to the DPEMP, the following rendering options were considered; high temperature continuous, high temperature batch, and low temperature continuous (press and decanter systems). Other processes, such as composting, were also considered. The low temperature continuous process was selected on the basis that it:

Produces a higher quality product;

Provides for lower energy costs in converting the waste into saleable product; and

Allows for easier capture of point source emissions. Options considered for wastewater treatment include DAF treatment to treat the higher solids content of the existing red meat process wash-down water, and various in-process modifications applying an evaporator on different waste streams to assist in solids recovery and operational efficiency. A DAF was considered the most effective means of reducing biological loading of the current red meat wastewater stream, which has high biochemical oxygen demand (BOD).

5 Public and agency consultation

A summary of the public representations and government agency/body submissions is contained in Appendix 2 of this report. Two representations were received. The main issue raised in the representations was:

Biosecurity surrounding the processing of fish waste. The DPEMP was referred to a number of government agencies/bodies with an interest in the proposal. Responses were received from the following:

Northern Midlands Council; and


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Department of State Growth. The following Divisions/areas of the Department of Primary Industries, Parks, Water and Environment also provided submissions on the DPEMP:

Air Specialist, EPA Division;

Noise Specialist, EPA Division; and

Biosecurity Tasmania, Animal Biosecurity and Welfare Branch. The DPEMP Supplement prepared by the proponent provides a response to each of the relevant environmental issues raised by the public and government agencies/bodies. According to the DPEMP, the proponent has also undertaken its own consultation process involving consultation with:

North Midlands Council;

EPA;

DPIPWE, Cressy Research and Demonstration Station; DPIPWE, Biosecurity Tasmania;

Residents adjacent to TQM’s abattoir; and

Petuna Salmon Hatchery.

6 Evaluation of key issues

The key environmental issues relevant to the proposal that were identified for detailed evaluation in this report were:

Air emissions; and

Biosecurity.

These issues are discussed in the following subsections.

6.1 Air emissions

Description

The sources of air emissions from the proposed activity are dust during construction and from operational vehicle movements, gases such as nitrogen oxides (NOx) and sulphur oxides (SOx) from the LPG boiler, and odour from the processing facility; predominantly the biofilter. Five privately owned residences are located between 980 metres and 1290 metres to the west and southwest. Two residential properties owned by TQM, and let to TQM employees, are located on the abattoirs property, approximately 150 metres and 190 metres south of the rendering facility (Figure 1). Dust According to the DPEMP, during construction there is minimal risk of dust emissions as the rendering equipment will be installed indoors, with construction of the evaporator outdoors (Figure 3) not requiring land clearing.


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Vehicle movements during construction and operation may generate dust from the gravel surface along Burlington Road. Boiler emissions According to the DPEMP, the use of LPG is expected to increase from 30,000 L to 50,000 L per month, resulting in an increase in the emissions of nitrogen and sulphur oxides. Odour GHD Pty Ltd (GHD) was engaged by WTP to conduct an odour dispersion assessment for the proposed rendering facility. The odour assessment report “Western Tiers Protein (WTP) Pty Ltd, Cressy Rendering DPEMP, Odour Assessment Report, June 2014” was included in the DPEMP (Appendix E). The Air Section, EPA Division, reviewed the odour assessment report prior to the public consultation period. The odour dispersion modelling was performed using Ausplume 6.0 with a TAPM (4.03) derived terrain dependant meteorological file (year 2011). The modelling was undertaken in accordance with the Environmental Protection Policy (Air Quality) 2004 (the EPP). Schedule 3 of the EPP requires background odour concentrations to be considered. The existing scenario was modelled using estimated odour emissions from the red meat rendering plant and existing biofilter (WTP owned), combined with background emissions from the abattoir and wastewater treatment ponds (TQM owned). The proposed scenario was modelled using estimated emissions from the expanded rendering plant (red and white meat) and new biofilter, combined with background emissions from the abattoir and upgraded wastewater treatment pond (assuming installation of an aerator and lagoon de-sludging). According to the DPEMP, the rendering process will be contained within a new building under negative pressure with all point source odours ducted to the biofilter, the prime odour source (Table 12 of the DPEMP). TQM’s primary and secondary waste water treatment lagoons represent the main background odour source. According to the DPEMP, the odour emission rates used in the model were derived from previous measurements at abattoirs, rendering plants, and waste water treatment plants. The quantitative inputs used in the model are detailed in Table 12 of the DPEMP, with all odour sources shown in Figure 14 of the DPEMP. The ground level odour concentrations for the existing operations (WTP & TQM combined) are predicted to exceed the 2 OU EPP criterion beyond the boundary of both the WTP lease area and TQM’s land holdings, extending to cover a section of Burlington Road and Powranna Road (Figure 4). The model predicts a slight reduction in the odour impact zone for the proposed operations (Figure 5), although the 2 OU EPP criterion is still exceeded. Odour concentrations at the two residential properties owned by TQM are predicted to decrease, although remain above 4 OU. Odour concentrations at the residences in other ownership (west of the facility, Figure 1) are predicted decrease to under 1 OU (Table 2). According to the DPEMP, there is potential for odour emissions to increase following an extended process interruption (e.g. power outage) due to extraction fans sourcing the biofilter not functioning. Further, there is expected to be a short commissioning period (1-3 weeks) during which odour emissions may be slightly elevated as the microbiology of the biofilter re-adjusts to the new nutrient source.


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Figure 4 Existing odour emissions showing predicted 1-Hour 99.5 percentile peak Ground Level Concentrations (GLC), including the EPP 2 OU design criterion (Figure 15 of the DPEMP).


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Figure 5 Proposed odour emissions showing predicted 1-Hour 99.5 percentile peak Ground Level Concentrations (GLC), including the EPP 2 OU design criterion (Figure 16 of the DPEMP).


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Table 2 Summary of predicted 99.5th percentile peak GLC at the nearest residences for existing and proposed conditions

Receptor Location Predicted 1-Hour 99.5 Percentile Peak GLCs

Existing operation odour (OU)

Proposed operation odour (OU)

Far SW 0.74 0.47

Near SW 1.11 0.70

Far W 1.04 0.66

Near W 1.24 0.78

Far S# (TQM property) 4.81 4.11

Near S# (TQM property) 6.75 6.42

# Properties located within the boundary of TQM’s abattoir (Figures 1)

Note, the following changes to the proposal have taken place since the modelling was undertaken (see addendum to the odour assessment report, Appendix E of the DPEMP), due to an explosive event which took place on 21 March 2014 resulting in the loss of red meat rendering equipment and the partial destruction of the process building;

All rendering processes will be contained within a new process shed kept under negative pressure and ventilated with 4-5 volume changes per hour, reducing potential for fugitive emissions;

The red meat material bin will be contained within the new process building behind a roller door, with odours subsequently directed to the biofilter; and

The DAF will be contained within the process building, with fugitive emissions directed to biofilter.

With regard to background odour sources, an increase in the size of the wastewater treatment winter storage ponds also took place since the modelling was undertaken. While the change in dimensions is likely to result in an increase in odour emissions, it is expected to be negligible compared to that from the biofilter and primary / secondary treatment lagoons (addendum to the odour assessment report, Appendix E of the DPEMP).

Management measures

Dust No management measures were proposed. Boiler emissions All new steam lines and equipment will have thermal insulation to minimise heat losses. The boiler will continue to be maintained as per the current red meat operating and maintenance program. Odour

Raw material will be processed within 3 hrs of receipt or otherwise directed to an alternative processor or EPA approved disposal option (commitment 1).

Back up equipment and parts will be held on site as a contingency for equipment failure on the processing line (commitment 2).

Enclosed transport vessels for the transport and delivery of raw chicken and fish waste will be used and raw material storage will be in sealed tanks (commitment 3) (Note, fish waste will not be processed, see Section 6.2).

The biofilter will be monitored during commissioning and operation on a daily basis for moisture content and discernable odours (commitment 4).

The biofilter will be maintained and operated as follows:


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o the volume and moisture content of the biofilter medium will be maintained at optimum levels.

o weeds will be removed as necessary from the surface of the biofilter. o the biofilter medium will be turned and/or replaced in accordance with supplier

recommendations.

An odour survey will be undertaken to measure odour emissions from all sources in the model following commissioning of the new process. Further action will be taken in consultation with the EPA if required following the survey (commitment 5) (e.g. expansion of the biofilter and or refurbishment of media within problematic cells, as outlined in DPEMP supplement).

All raw material deliveries will be inspected on site and any out of specification material (e.g. pH exceeding 4.6 or as otherwise determined by supplier contracts) will be rejected (commitment 11).

The rendering will be contained within a new process building capable of good ventiliation control and negative air pressure. The integrity of the building’s roof and walls, the gas condenser of the odour reduction system and any pipework or ducting conveying odorous gases will be maintained so as to prevent the escape of odorous gases to the atmosphere prior to entering the biofilter.

All major point source process odours, as well as fugitive emissions from the building, will be ducted and humidified prior to biofilter treatment.

The new biofilter will be constructed and operational (as part of planning permit P13-288) prior to the project being implemented.

In the event that the rendering process is unable to operate (e.g. power outage), then raw material will be kept in the sealed raw material tank until the process can recommence.

In the unlikely event that a spill would occur outside the process building, the spilt raw material will be immediately cleaned up prior to odour becoming an issue.

Public and agency comment and responses

No comment was received.

Evaluation

Dust Dust is unlikely to become an issue during construction as the new rendering lines will be established within the process building. Dust is unlikely to be an issue during operation due to the nature of the activity. Given the limited extent of gravel roads in the vicinity, a small section along Burlington Road, dust generated by vehicle movements to and from the site is unlikely to result in an environmental nuisance. Boiler emissions In considering the capacity of the boiler is greater than 100 megajoules, and the activity will likely result in an increase in nitrogen and sulfur oxide emissions, schedule 1 of the EPP (in-stack concentrations) will apply (condition A1). The proponent is required to undertake a stack test within 6 months of commencement of operations to show compliance with schedule 1 of the EPP (nitrogen oxides, condition A2), and maintain stack testing facilities (condition A3).


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The EPA Air specialist advised that testing for particulate matter and sulphur oxides is not necessary due to the negligible emission levels of these pollutants expected from a boiler of this size and type. Odour According to the Air Section, the modelling was undertaken in accordance with the EPP, containing all the elements of an appropriate odour impact analysis. The model accounted for background odour in assessing the cumulative effect of all proposed odour sources (WTP & TQM). Note, the ‘proposed scenario’ modelling assumed an upgrade to TQM’s waste water treatment lagoons. While considered necessary in order to accept the proposed effluent from WTP (see Appendix 1, Issue 1, Condition E2), it is accepted the upgrade would also act to reduce background odour levels, and thus contribute to the reduced 2 OU GLC noted in Figure 5. The Air Section considers that modelling of the WTP odour sources in isolation would necessarily predict a much smaller impact zone, although the 2 OU EPP criterion would still be exceeded at the WTP boundary due to the small size of the WTP lease area and the anticipated biofilter emissions. The Air Section noted however that the odour emissions from the new biofilter substrate will likely be lower and have an earthy character that is not offensive. It is reasonable to consider that the total odour emissions, accounting for background sources and proposed changes thereof, will be lower than the existing emissions, under 1 OU at the residences to the west of the facility (Figure 1), and unlikely to result in environmental nuisance. Indeed, the Air Section noted that the improvements to the proposal brought about by the explosive event on 21 March 2014, as described above, are likely to result in a smaller odour impact area to that presented by the model (Figure 5). Further, the proponent indicated in the DPEMP supplement report that fish will not be processed on site (condition G12, Section 6.2), thereby removing a potentially significant odorous source. With regard to the two residences on TQM land, the DPEMP indicates that they are occupied by employees of the abattoir and not available for rent by the general public. It is reasonable to consider these residences to be a part of the abattoir. It is noted that the proposal will likely result in a reduction in odour at these residences and an improvement in odour character, with the establishment of a properly functioning biofilter designed fit for purpose (condition A4). It is further noted that no odour complaints have been received in the past from these residences, and it is likely workers of the abattoir living on site are accustomed to odour generated by the food industry. The imposition of odour emission limits on the rendering facility would therefore be inappropriate, and may result in operational restrictions where none are necessary. To ensure odour does not result in environmental nuisance beyond the industrial site, appropriate management of incoming raw material (commitment 3, condition G10) and the improved air control management system, including the capture and ducting of all process building emissions (point source and fugitive) to the biofilter (condition A4) is required. It is noted that the odour emission rates used in the odour model assume a properly operating biofilter. It is further noted that they were derived from estimates, rather than actual measurements. The commitment (commitment 5) to undertake an odour survey to measure odour emissions from the biofilter following commissioning of the new process is important, and required by condition A5. According to the DPEMP, there is expected to be a commissioning period (1-3 weeks) during which the microbiology of the biofilter re-adjusts to the new nutrient source(s), after which odour emissions are expected to stabilise. Note, this assumes the new biofilter will be constructed (planning permit P13-288) and fully commissioned prior to the project being implemented.


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If the results of the odour survey demonstrate that the biofilter emissions are greater than those assumed in the model, condition A5 also requires a review of the odour model to determine the likely extent of the odour impact zone. The DPEMP supplement stated several actions that could be undertaken if odour emanating from the biofilter was an issue, including expansion of the biofilter area thereby reducing the odour concentration loading per unit area, and refurbishment of the media. Condition A6 requires appropriate measures be undertaken to prevent odour from causing an environmental nuisance. Appendix C of the DPEMP contains a comment from The Odour Unit in regard to the design of the biofilter, highlighting the need for maintenance of moisture within the medium to ensure good performance. The commitment (commitment 4) to monitor the biofilter during commissioning and operation on a daily basis (condition G9), and maintain the medium in an optimum condition, are considered necessary (condition A4). Condition A4 also requires the bio-filter medium be turned or replaced every three years, in keeping with that proposed in Appendix E of the DPEMP (Odour assessment report). According to the DPEMP, the proposed odour controls are designed to handle maximum production capacity, with peaks in production, anticipated during December and January, not expected to impact biofilter operation. The commitment (commitment 1) to process chicken waste within 3 hours, or otherwise direct to an alternative processor (e.g. red meat processor) or an approved disposal site, will ensure the integrity of the odour control/management system is maintained, and significant odour sources are not created on site (condition G11). Further, condition G11 will ensure odour does not become an issue if a disruption to power occurs, or in the event of equipment failure, the cause of previous odour complaints, received from a residence on Cressy Road to the west of the rendering facility during the first 18 months of operation (commencing 2007). Note, no odour complaints have been received since July 2008, when backup equipment has been held onsite. The commitment (commitment 2) to maintain back-up equipment on-site is supported and required (condition G9). Standard condition A7 will ensure material is managed appropriately when transported.

Conclusions

The proponent will be required to comply with the relevant DPEMP commitments summarised above.

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

G9 Commitments

G10 Management of material imported onto The Land

G11 Processing of material

A1 Stack emission limits for the LPG boiler

A2 Stack testing

A3 Stack testing facilities

A4 Capture and treatment of rendering odours

A5 Odour survey

A6 Odorous gases

A7 Covering of vehicles


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6.2 Bio-security

Description

According to the DPEMP, fish (salmon) waste from locations around the state will be processed into fish meal and oil. The proposed site is located within Brumbys Creek Catchment, approximately 1.2 km upstream of Petuna salmon hatchery (Figure 1). While there is no direct discharge of wastewater to Brumbys Creek or any other surface waters, there is the potential for fish pathogens to enter the environment via raw material spillage/leakage, or the discharge of process wastewater effluent to TQM’s wastewater treatment lagoons and irrigation scheme. According to the DPEMP, wastewater from TQM’s lagoons is used to irrigate land within 100m of Brumbys Creek and 200m from the Petuna salmon hatchery. The release of fish pathogens into the environment may impact the Petuna salmon hatchery, potentially resulting in the transfer of pathogenic organisms beyond the catchment via hatchery contamination. Brumbys Creek fishery may also be impacted.

Management measures

Enclosed transport vessels and sealed storage tanks will be used for the transport and storage of raw chicken and fish waste (commitments 3 and 14).

A minimum 5 log reduction in microbiological numbers (thermotolerant coliforms) will be achieved using heat treatment applied to all wastewater streams from the fish and chicken rendering process (commitment 6).

Wastewater quality will be monitored during commissioning and operation to verify the effectiveness of wastewater treatment (commitments 9 and 15) (Tables 18 and 19 of the DPEMP).

All raw material deliveries will be inspected on site and any out of specification raw materials (e.g. pH exceeding 4.6 or as otherwise determined by supplier contracts) will be rejected (commitment 11).

Out of specification raw material unable to be accepted into the process will be managed in accordance with Waste Regulations and consultation with the EPA and the Supplier of raw materials to ensure environmental and biosecurity risks are managed (commitment 12).

All fish raw waste received will be acid stabilised (commitment 14).

The raw material unloading area will be bunded such that spillage during unloading will be contained and directed through the processing line (commitment 16).

All raw material delivery vehicles will be rinsed and all contaminated wastewater passed through the heat treatment.

In the event that there is a disruption to the rendering process (e.g. power outage), the liquids in the system will be contained such that there will be no uncontrolled discharge of wastewater to the drainage system without heat treatment.

Public and agency comment and responses

The representors raised the following concerns with respect to biosecurity:

The establishment of a fish waste rendering facility immediately upstream (1.2 km) of a hatchery is in direct contravention of the principles of the draft Biosecurity Strategy Plan for the Tasmanian salmon farming industry.


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The transporting of fish waste material (including fish farm mortalities) to the site from a range of fish farming regions increases the biosecurity risk to Petuna hatchery, representing a direct threat to the viability of the business.

Petuna hatchery supplies fish to all growing regions in the state (South-east, West, and North), including other freshwater hatcheries. The ramifications of a biosecurity breach at the hatchery could be transferred to all marine farming regions, threatening the viability of the Tasmanian salmon farming industry.

The processing of fish waste material in close proximity to Brumby’s Creek threatens the recreational fishing stocks in this system.

The proposal threatens the salmon farming operations downstream at Rowella.

In addition to salmonid waste, a representor is also strongly opposed to any other ‘fish’ waste being processed on site.

Biosecurity Tasmania, Animal Biosecurity and Welfare Branch, expressed strong concerns as the facility is located immediately upstream of a major salmonid hatchery. The basis for these concerns are summarised as follows:

Salmon waste, in particular salmon mortalities, would be considered high risk material with respect to disease pathogens.

The transfer of waste from marine farms to a facility in close proximity to a freshwater hatchery provides the potential for the establishment of disease not previously established within this ecosystem. It is considered that a number of pathogens would have significantly greater impact if transferred to a hatchery environment.

Establishment of disease within freshwater populations provides an opportunity for it to be spread throughout Tasmania within smolt supplies.

Wild fish species are considered to be major reservoirs of infection for fish produced under intensive farming conditions and, although contact with such species cannot be avoided in sea-cage systems, these marine culture systems represent an end stage for production. By bringing waste into close association with hatcheries, there is potential to close the infection loop, thus bringing pathogens into close association with all stages of the fish lifecycle. Such situations have potential to enhance expression of new diseases.

Evaluation

Biosecurity Tasmania, Animal Biosecurity and Welfare Branch, acknowledged the measures proposed by the proponent to mitigate the risk of pathogen transfer, noting however that the ongoing maintenance of biosecurity at the facility is fully reliant on maintaining operational procedures, which have potential to fail. In considering the potential impact to the salmonid environment from pathogen transfer to the salmonid hatchery downstream from the rendering facility, Biosecurity Tasmania recommended the proponent not be permitted to source fish waste, directly or indirectly, from salmonid producers. In addition to salmonid waste, a representor is also opposed to any other ‘fish’ waste being processed. Biosecurity Tasmania however considers the processing of non-salmonid fish waste to the biosecurity standards described within the proposal to be acceptable. The proponent nevertheless stated in the DPEMP supplement that no fish waste will be processed, negating the need to impose biosecurity measures, such as isolating the raw material delivery area and heat treating process wastewater to specific biosecurity standards. Condition G12 thus prohibits the receipt and processing of fish waste at the rendering facility. Biosecurity Tasmania has no concerns in relation to the processing of chicken waste.


19

Conclusions



G12 No fish waste


20

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 effluent

2. Solid waste management

3. Noise

4. Transport

5. Dangerous goods and environmentally hazardous materials

6. Decommissioning and rehabilitation

7. Flora and fauna

8. Heritage (European and Aboriginal)

8 Report conclusions

This assessment has been based upon the information provided by the proponent in the permit application, DPEMP, DPEMP Supplement and in correspondence and discussion between the EPA Division and the proponent and the proponent’s representatives. This assessment has incorporated specialist advice provided by EPA Division scientific specialists and 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 assessment of the proposal; and

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

It is concluded that the proposal is capable of being managed in an environmentally acceptable manner such that it is unlikely that the RMPS and EMPCS objectives would be compromised, provided that the Permit Conditions - Environmental No. 8986 appended to this report are imposed and duly complied with, including commitments made by the proponent in the DPEMP.


22

9 References

GHD (June, 2014), Western Tiers Proteins Rendering Process Expansion, Development Proposal and Environmental Management Plan.

Western Tiers Proteins Pty Ltd (August, 2014), DPEMP Supplement Report: Rendering Process Expansion.

10 Appendices

Appendix 1 Assessment of other issues Appendix 2 Summary of public and agency submissions Appendix 3 Permit conditions, includes Attachment 2 - DPEMP commitments

Appendix 2


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Appendix 1 Assessment of other issues

Issue 1: Liquid effluent

Description of potential impacts

Pollution of surface water, groundwater and or soil as a result of inappropriate management of liquid effluent. Wastewater from the activity is directed to waste water treatment lagoons managed by TQM (Figure 1). There is no proposed discharge of wastewater to surface waters. According to the DPEMP, the rendering wastewater quality is generally high in BOD, nutrients and microbiological loads. The expected effluent quality from the new rendering process is however expected to improve as a result of the DAF treatment and operation of the evaporator and drier to recover solids and nutrients (Table 3 of DPEMP). The total suspended solids (TSS), nitrogen and phosphorous loadings however are expected to increase due to the increased wastewater volumes (Table 4 of the DPEMP).

Management measures proposed in DPEMP

Inspections of drainage pipeline areas to detect blockages, leaks and spills followed by immediate investigation by maintenance staff (commitment 7).

WTP and TQM will amend the existing lease agreement to include agreed limits on wastewater volume and quality to be discharged to the TQM treatment lagoons. The upper limits for the rendering process wastewater will be 15 ML per year (55 kL/day) and 145kg BOD/day (commitment 8).

Wastewater quality will be monitored during commissioning and operation (commitment 9). Monitoring of the following process wastewater parameters will be undertaken (Tables 18 and 19 of the DPEMP); pH, Temp, BOD, EC, TSS, Ammonia Nitrogen, Nitrate, Nitrite, Total Nitrogen, Total Phosphorous.

In the event that wastewater is unable to be directed to TQM, alternative wastewater transport and disposal options will be determined in consultation with the EPA and in accordance with regulations.

Wastewater volumes will be estimated via mass balances based on quantities of raw material and finished product.

Public and agency comment


Evaluation

There are no proposed changes to stormwater infrastructure. Condition E1 will ensure appropriate stormwater management is maintained. According to a review of TQM’s wastewater treatment lagoons and irrigation scheme (Appendix B of the DPEMP) the current treatment system is under performing. The review recommended several actions be undertaken prior to commencement of the new rendering facility to ensure a sustainable irrigation scheme. It is understood that TQM are in the process of upgrading their wastewater treatment facility to a standard that would be able to accept the increased TSS and nutrient loadings from the proposed rendering facility. A draft waste water and irrigation management plan is currently with the EPA for review. Condition E2 ensures all process wastewater, including wash down water, generated by the activity that is not recycled or reused, be directed to a wastewater treatment system approved by the Director. It is noted that the existing WTP and TQM lease agreement states that the lessor (TQM) is solely responsible for the management and disposal of all liquid waste from the lessee (WTP), and that the proponent has agreed to amend the agreement to include appropriate effluent concentration limits. The limits presented in commitment 8 however may need to be reconsidered pending the finalisation of

Appendix 2


24

the TQM waste water and irrigation management plan. It is considered appropriate that a wastewater agreement be developed and ratified between the person responsible for the activity and the person responsible for the wastewater treatment lagoons, currently TQM, pending finalisation of the above plan. The agreement must specify appropriate concentration limits for key WTP wastewater characteristics and the monitoring requirements for WTP wastewater (commitment 9) (condition E2). Notwithstanding, condition E3 is required to ensure that solid matter is prevented, by all reasonable means, from entering the wastewater stream. Regular inspection of the drainage pipeline (commitment 7) is also regarded as necessary (condition G9).

Conclusion



E1 Stormwater

E2 Management of contaminated wastewater

E3 Solid matter in wastewater

Issue 2: Solid waste management


Environmental harm or nuisance as a result of inappropriate management of solid waste. During construction, solid waste in the form of general construction materials and packaging may be generated. Small quantities of miscellaneous waste will be generated during operation of the new rendering process, which will be disposed of in the existing sealed general waste bins. There is the potential to generate quantities of waste through upset processing conditions (e.g. extended power outage) or out of specification raw material or product.


Out of specification raw material unable to be accepted into the process will be managed in accordance with Waste Regulations and in consultation with the EPA and the Supplier of raw materials to ensure environmental and biosecurity risks are managed (commitment 12).

Finished product that is not within specification can either be reprocessed or sold at discounted rate.

Any construction materials, packaging waste or waste generated by the contractors will be placed in general waste bins. These materials will then be disposed of regularly through the existing solid waste and recycling facilities.



Evaluation

The handling (including dispatch) of a controlled waste (animal waste), under the Environmental Management and Pollution (Waste Management) Regulations 2010, (the Regulations) requires approval. Commitment 12, to manage out of specification raw material in accordance with Waste Regulations is necessary, and reinforced by conditions WM1 and G11. The measures to handle general refuse waste during construction and operation are considered adequate.

Conclusion

Appendix 2


25

The proponent will be required to comply with the relevant DPEMP commitment summarised above.


WM1 Controlled waste transport

G11 Processing of material

Issue 3: Noise


Environmental nuisance caused by noise emissions. According to the DPEMP, the potential for construction noise from vehicles and machinery to impact the local environment is low due to daylight hours only construction over a short period (two month).

Operational noise will be confined to running the rendering process equipment, contained within the process building, and the evaporator located adjacent to the process building, on the outside. According to the DPEMP, the potential for noise impacts is low due to the majority of equipment being housed indoors and the lack of sensitive receptors in close proximity to the rendering facility. The noise impact from increased traffic (an additional four truck movements per day) is not expected to be significant.


All noise complaints will be investigated and practicable measures taken to reduce noise levels (commitment 10), e.g. improved noise insulation.

Construction activities will be undertaken five days per week between the hours of 7.00 am and 6.00pm. Construction activities will not be undertaken on Sundays or public holidays and in such a manner as not to disturb the property owner (TQM) or neighbours.

All vehicles and machinery will be maintained to minimise noise.



Evaluation

The hours of operation will be consistent with the current operating hours. The proponent has indicated in the DPEMP Supplement Report that the plant will be operated with the building doors closed at all times. It is expected that the new process building, being clad to provide air control, will assist in keeping noise levels low. Given the nature of the activity, the EPA noise specialist considers the nearest residences, other than those associated with TQM’s industrial site, are unlikely to experience a noise nuisance, and as such it is not necessary to impose noise limits. For the reasons given in section 6.1, the EPA noise specialist considers the imposition of noise limits to apply at the two residences owned by TQM would be inappropriate, and may result in operational restrictions on WTP where none are necessary. It is noted that no noise complaints have been received in the past. The commitment (commitment 10) to investigate any complaints that may arise, and take action where appropriate, is considered necessary (condition G9). Condition G6 requires a compliant register be maintained and be available for inspection by an Authorised Officer. Note, the current WTP EPN (8982/1) imposes a standard noise condition requiring that noise emissions from the activity be controlled to the extent necessary to prevent environmental nuisance. The imposition of this condition is not considered necessary, as the intent is covered by section 53 of EMPCA. The proponent should nevertheless be directed to section 53 of EMPCA (legal obligation LO3), which will ensure noise emissions do not unreasonably interfere with a person’s enjoyment of the environment.

Appendix 2


26

Conclusion


Noise emissions must not unreasonably interfere with a person’s enjoyment of the environment (refer Legal Obligations LO3).

Issue 4: Transport


It is expected that an additional two to three vehicle deliveries (raw material) and an additional one to two finished product collections per day will occur, via Burlington Road, Powanna Road and Cressy Road. According to the DPEMP, a possible impact on traffic may occur if WTP is required to move liquid effluent off site, should an issue arise with TQMs wastewater lagoons. This may result in an additional 5 vehicle movements per day for a short period of time (e.g. 1-3 weeks). The EPA and Northern Midlands Council will be notified should such an event occur.


No measures were proposed.



Evaluation

Northern Midlands Council did not request a traffic impact assessment.

Conclusion

No conditions are necessary.

Issue 5: Dangerous goods and environmentally hazardous materials


Spillage of environmentally hazardous materials. During construction small quantities of fuel, lubricants and other chemicals may be stored on-site. During operation minor quantities of cleaning chemicals and oils, small tanks of oxygen and acetylene, and three 6000 L tanks of LPG gas will be stored on site.


All chemicals and dangerous goods will be stored in accordance with relevant dangerous good standards and legislative requirements (commitment 13).

The transport of dangerous goods will be in accordance with relevant standards and legislative requirements.



Evaluation

The regulation of the boiler and LPG tank is a matter for Worksafe Tasmania.

It is considered that there should be minimal impact from dangerous goods and environmentally hazardous materials providing they are stored in accordance with condition H1 (Storage and handling of hazardous materials), spill kits are available (condition H2), and they are stored, handled and transported in accordance with the relevant State Acts (commitment 13) (Legal Obligation LO1).

Conclusion

Appendix 2


27


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

H1 Storage and handling of hazardous materials

H2 Spill Kits

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 (refer Legal Obligations LO1).

Issue 6: Decommissioning and rehabilitation


Land, surface and groundwater contamination and erosion as a result of inappropriate decommissioning and rehabilitation.


A draft decommissioning and rehabilitation plan (DRP) will be prepared within 30 days of notifying the Director of any decision that is likely to give rise to the temporary or permanent cessation of the activity.

Rehabilitation will be carried out in accordance with the DRP.



Evaluation

The land area is flat and should not be prone to erosion.

The proposed management measures are considered adequate and required by conditions DC1 and DC2. Standard conditions DC3 (Notification of cessation) and DC4 (Temporary suspension of activity) are also required to ensure adequate notification and management during a temporary suspension of the activity.

Conclusion


DC1 DRP requirements

DC2 Rehabilitation following cessation

DC3 Notification of cessation

DC4 Temporary suspension of activity

Issue 7: Flora and fauna


Loss of threatened species and or habitat. No threatened species or vegetation communities are not known to be present on site. According to the DPEMP, impacts to native flora and fauna are anticipated to be negligible due to the highly disturbed industrial nature of the site.

Appendix 2


28


No measures were proposed.



Evaluation

PCAB did not require a survey of the area, and considers the risk of impacting on any threatened flora or fauna species is low.

Conclusion

No conditions are necessary.

Issue 8: Heritage (European and Aboriginal)


Destruction or interference with European and or Aboriginal heritage. According to the DPEMP, no impacts on Aboriginal or European heritage are expected given the highly disturbed industrial nature of the site.


If any Aboriginal relics are identified during construction, the provisions of the Aboriginal Relics Act 1975 will apply and a permit to damage or destroy Aboriginal heritage will be required.



Evaluation

AHT have no objection to the project proceeding, noting that all Aboriginal heritage is protected under the Aboriginal Relics Act 1975. The management measure proposed is appropriate (Legal obligation LO4).

Conclusion

Any relics discovered should be managed in accordance with the Aboriginal Relics Act 1975 (refer Information Schedule LO4).

Appendix 2


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Appendix 2 Summary of public and agency submissions

Western Tiers Protein – Rendering facility, Cressy

Summary of public representations and agency and Council comments

Details of comments on the project are provided in following tables:

Table A, a summary of comments made in the representation.

Table B, a summary of comments, including requests for further information from State

Government agencies.

Table C, a summary of comments, including requests for further information from Northern

Midlands Council.

Table D, a summary of comments, including requests for further information from the EPA.

In the following tables, DPEMP means the Western Tiers Proteins Rendering Process Expansion DPEMP, dated June 2014.

A. Public representations

Representation No.

Comment

Environment – Biosecurity issue

1 Representor is strongly opposed to this proposal, with particular concern in the proposal to accept and render fish processing waste (including fish farm mortalities) from a number of Tasmanian sources (Devonport, Strahan and Hobart), in close proximity to the Petuna hatchery site.

1,2 The Tasmanian Salmonid Growers Association (TSGA) in conjunction with the Office of the Chief Veterinary Officer (CVO) have recently developed a draft Biosecurity Strategy Plan for the Tasmanian salmon farming industry. The two representors consider the establishment of a fish waste rendering facility in close proximity (1.2 km) to a hatchery (i.e. same catchment, immediately upstream) is in direct contravention of the principles of this plan. For example, strict restrictions are in place to prohibit movement of biological material (i.e. eggs, live fish, harvest fish, fish waste) from marine growing regions back to freshwater hatchery regions.

1 Representor considers the transporting of waste material (including fish farm mortalities) to the Western Tiers Proteins site from a range of fish farming regions, increases the biosecurity risk to Petuna hatchery above current levels. This is a direct threat to the viability of the Petuna business and a significant reputational threat to the Petuna brand in the event of a significant fish health or mortality event.

1 Representor considers the processing of waste material in close proximity to the Brumby’s Creek system threatens recreational fishing stocks and in-turn the viability of an important recreational fishing destination for locals and visitors to the area.

1,2 The following statement is provided in the DPEMP: “The proposed raw material will come from various locations in the state and so has potential to transfer organisms from one region to another, presenting an additional element of biosecurity risk if exposed to the fish farming industry. With the

Appendix 2


30

exception of the Petuna Salmon Hatchery 1.2 km from the WTP processing facility and TQM wastewater lagoons, the proposed rendering facility is predominantly isolated from the majority of fish farming operations in Tasmania therefore inherently provides some control from pathogens by isolating the contaminated materials from the viable fish farming”. A representor considers that this statement fails to recognise that the Cressy hatchery currently supplies fish to all growing regions in the state (South-east [Hobart], Western [Strahan], and Northern [Rowella] regions). In addition, stocks from the hatchery are routinely moved from Cressy to other freshwater hatcheries across the state (for example – the SALTAS hatchery at Wayatinah and Mountain Stream Fisheries near Targa). These movements are permitted under the State Biosecurity Plan. Any increased biosecurity risk at the Cressy hatchery site therefore threatens the ongoing viability of the entire salmon farming industry in Tasmania. Another representor notes that the ramifications of a biosecurity breach at the Western Tiers Proteins site could easily be transferred to all marine farming regions through the distribution of fish should the Petuna hatchery become affected. Therefore impacts are not necessarily limited to the Petuna hatchery which is significant enough in its own right. The representor considers this is a very serious and commercially significant matter for the salmonid industry. The industry sincerely hopes that the Northern Midlands Council understands the potential commercial damage that can be done to the salmonid industry if there was a breach in biosecurity and contaminated materials were introduced into the Petuna Salmon Hatchery, less than 1.2km downstream. Members of the Tasmanian Salmonid Growers Association Ltd are very concerned about the ramifications of a biosecurity breach at the Western Tiers Proteins site.

1 Representor considers that as the Brumby’s Creek system forms part of the Tamar River catchment, the proposal also directly threatens salmon farming operations downstream at Rowella (Van Diemen Aquaculture).

1 In addition to salmonid waste (i.e. processing waste or fish farm mortalities - Atlantic salmon or Ocean trout [Rainbow trout]) the representor is also strongly opposed to any other ‘fish’ waste being processed on the Western Tiers site due to biosecurity concerns.

1 Reprensentor notes that the three largest salmon producers in the State (Petuna Aquaculture, Tassal Ltd. and Huon Aquaculture) will not be supplying waste material to the Western Tiers Proteins facility now or into the future. Representor considers that the proposal does not appear to be viable from the perspective of fish waste processing.

2 Reprensentor has been contacted by Tassal, Huon Aquaculture and Petuna Aquaculture, who have all indicated that they do not intend to supply salmon waste to the proponent.

Appendix 2


31

B. Agency comments

Agency Comment

DPIPWE, Biosecurity Tasmania, Animal Biosecurity & Welfare Branch

Officers within the DPIPWE Animal Biosecurity & Welfare Branch expressed strong concerns in relation to this proposal, primarily due to the facility being located immediately upstream of a major salmonid hatchery. As a general principle, Animal Biosecurity would consider the establishment of such a facility in such close proximity to a hatchery to be poor biosecurity practice for the following reasons.

1. The type of salmon waste received, in particular salmon mortalities, would be considered high risk material with respect to disease pathogens.

2. Although the proponent has outlined a range of measures designed to mitigate risk of transferring pathogens present within the fish waste stream, these measures rely solely on operational procedures and do not incorporate exclusion in any significant way. Therefore, the ongoing maintenance of biosecurity for the facility is fully reliant on maintaining such procedures, which have potential to fail.

3. Throughout the history of salmonid aquaculture in Tasmania, major diseases affecting the industry have been shown to originate primarily from wild fish populations. This is particularly evident within marine production systems. The transfer of waste from marine farms back to a facility in close proximity to a freshwater hatchery provides potential for the establishment of disease not previously established within this ecosystem. Examples of particular concern include aquatic birnavirus, atypical strains of Aeromonas salmonicida, salmon orthomyxovirus and Tasmanian rickettsial-like organism, all of which are present in Tasmanian marine environments.

4. A number of those pathogens listed above would be considered to have significantly greater impact if transferred to a hatchery environment. Aquatic birnavirus is one such example where the impact on marine sites is limited, but clinical presentation in younger hatchery stock would be much more severe.

5. Establishment of disease within freshwater populations, be they wild or farmed stock, provides opportunity for the disease to be spread further throughout Tasmania within smolt supplies. All of the examples listed in point 3 have restricted regional distribution. Movement of infected smolt has potential to expand geographic distribution of these diseases.

6. Wild fish species are considered to be major reservoirs of infection for fish produced under intensive farming conditions, and, although contact with such species cannot be avoided in sea-cage systems, these marine culture systems represent an end stage for production. By bringing waste into close association with hatcheries, there is potential to close the infection loop, thus bringing pathogens into close association with all stages of the fish lifecycle. Such situations have potential to enhance expression of new diseases. Salmon orthomyxovirus is an example of a salmon disease which has only recently emerged and is thought to be associated with contact with wild fish.

Information outlined within the proposal suggests that the proponent is relying primarily on salmonid aquaculture waste as the source of fish product. During discussions with members of the Tasmanian salmonid industry, members

Appendix 2


32

indicated that, due to their own biosecurity concerns, they would not be sending waste product to the Western Tiers Protein facility. An email is attached (attached below) from the Executive Officer of the Tasmanian Salmonid Growers Association for reference. It appears that the proponent has over-emphasised the availability of salmonid waste. Notwithstanding our concerns relating to salmonid waste, Animal Biosecurity considers that disease risks associated with the processing of wild caught fish product to be significantly less, and considers that the processing of non-salmonid fish waste to standards described within the proposal to be acceptable. Similarly, this office has no concerns in relation to the processing of chicken waste at the facility. Animal Biosecurity recommends that the proponent not be permitted to source fish waste, either directly or indirectly, from salmonid producers.

Appendix 2


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C. Council comments

Issue Comment

Bushfire code Northern Midlands Council is of the view that the site is in a bushfire prone area.

Planning scheme

The reference to the planning scheme needs to be updated to the Northern Midlands Interim Planning Scheme 2013.

D. EPA Division comments

Issue Comment

Odour It is stated in the DPEMP (page 42) that an odour survey will be undertaken following commissioning of the new process to measure and confirm odour emissions from all modelled odour sources, and that further action will be undertaken if the odour emissions post upgrade are not acceptable.

TQM Residences

It is noted that there are two residential properties in other ownership, (owned by TQM) located within 200 metres from the rendering facility, which are occupied by employees of TQM.

Production limit It is noted that the capacity of the facility will be 92 tonne per day.

Raw material delivery area

It is noted in the DPEMP (page 54) that raw material delivery will be via a transport vehicle parked partly inside the building and partly outside the building, and that the unloading area outside the building will be bunded. It is unclear in Figure 2 of the DPEMP whether the entire boundary of the unloading area outside of the new building is within the WTP Lease area.

Appendix 3


34

Appendix 3 Permit Conditions - Environmental

rendering facility expansion - epa tasmaniaepa.tas.gov.au/documents/western tiers proteins -...

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