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ENVIRONMENTAL ASSESSMENT REPORT

TASSAL PRODUCTION INTENSIFICATION

NARROWS ROAD, STRATHBLANE

Tassal Group Ltd Report and recommendations of the EPA Division Department of Primary Industries, Parks, Water and Environment to the Board of the Environment Protection Authority March 2011

Environmental Assessment Report – Tassal Dover Production Intensification

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Environmental Assessment Report Proponent Tassal Group Ltd

Proposal Fish processing production intensification

Location Dover

NELMS no. 7861

DA number 229/2010

File 111654 Document Class of Assessment

G:\EEO_Enviro_Ops\EAS_Assessments\EAS_Projects\Tassal Dover\Assessment Report\Tassal Dover EAR. 2B

Assessment process milestones 14/8/2009 Notice of Intent submitted

18/9/2009 DPEMP Guidelines issued

15/11/2010 Permit application submitted to Council

23/11/2010 Application received by Board

27/11/2010 Start of public consultation period

24/12/2010 End of public consultation period 22/2/2011 Supplementary information submitted to Board

Acronyms Board Board of the Environment Protection Authority

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

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

LUPA Act Land Use Planning and Approvals Act 1993

PCAB Policy and Conservation Branch (DPIPWE)

SD Sustainable development

WWTP Wastewater Treatment Plant


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Report summary This report contains an environmental assessment and recommendations to the Board of the Environment Protection Authority in relation to Tassal Group Ltd’s proposed intensification of production at their fish processing plant located at Strathblane.

The proposal involves the intensification of production at the Dover processing facility located at Narrows Rd Strathblane, approximately 15km south of Dover to 25,000 tonnes per annum by 2015. The major component of the production increase is the upgrade of the wastewater treatment plant (WWTP) which discharges to Port Esperance.

This report has been prepared by the EPA Division of the Department of Primary Industries, Parks, Water and Environment based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP) and DPEMP Supplement. The advice of relevant Government Agencies and the public has also been sought and considered as part of this assessment.

On 7 January 2011, the Director requested that the applicant submit supplementary information to address public, government agency (including DPIPWE) and Council comments on the DPEMP. The DPEMP supplementary information was submitted by the applicant on 22 February 2011.

Background to the proposal and details of the assessment process are presented in Section 1 of this report. Section 2 describes the context of this assessment. Details of the proposal are contained in Section 3. Section 4 reviews the need for the proposal and considers the project, 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 contained in Section 6. Section 7 identifies other environmental issues and the report conclusions are contained in Section 8.

Appendix 1 contains a tabular evaluation of other environmental issues referred to in Section 7. Appendix 2 contains a summary of issues raised in the consultation process. Appendix 3 contains recommended environmental permit conditions for the proposal. Attachment 2 of the recommended permit conditions contains the table of commitments from the DPEMP.


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Table of Contents

1 Approvals process ..................................................................................... 5

2 SD objectives and EIA principles .............................................................. 5

3 The proposal ............................................................................................. 6 4 Need for proposal and alternatives ........................................................... 8

5 Public and agency consultation ................................................................. 8 6 Evaluation of key issues ............................................................................ 9

6.1 Water quality impacts from outfall discharge ...................................................................... 9

7 Other environmental issues ..................................................................... 16

8 Conclusions ............................................................................................. 16 9 References .............................................................................................. 17 10 Summary of appendices ....................................................................... 17

Appendix 1 Assessment of other environmental issues ........................................................ 17 Appendix 2 Summary of issues raised by public and agency submissions .......................... 25 Appendix 3 Proposed permit conditions ................................................................................ 27


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1 Approvals process An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Huon Valley Council on 15 November 2011.

The proposal is defined as a ‘level 2 activity’ under Schedule 2 Subsection (4)(c) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being a Fish Processing activity. 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 23 November 2010.

The Board required that additional information to support the proposal be provided in the form of a Development Proposal and Environmental Management Plan (DPEMP) prepared in accordance with guidelines jointly issued by the Board and Huon Valley Council. The final guidelines were issued to the proponent on 18 September 2009.

One draft of the DPEMP was submitted to the Department for comment prior to its formal submission. A final DPEMP was submitted to Council with the permit application. The DPEMP was released for public inspection for a 28-day period commencing on 27 November 2010. Advertisements were placed in the Mercury newspaper and on the EPA web site. The DPEMP was also referred at this time to relevant government agencies for comment. Three public submissions were received.

On 7 January 2011, the Director requested that the proponent prepare a DPEMP Supplement to address public, government agency (including DPIPWE) and Council comments on the DPEMP. The DPEMP Supplement was submitted by the proponent on 22 February 2011.

2 SD objectives and EIA principles The proposal must be considered by the Board in the context of the sustainable development 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) established by 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 protect the environment of Tasmania, and 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 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 key proposal characteristics

Activity Intensification of fish processing and upgrade of a wastewater treatment plant (WWTP).

Location and planning context Location 564 Narrows Rd, Strathblane.

Land zoning The site is zoned “Aquaculture” under the 1989 Esperance Planning Scheme.

Land tenure Lot 1 on Registered Plan 36627; and Lot 1 on Registered Plan 27973. The proponent noted that it was brought to their attention that some of the WWTP is located on forestry land adjacent to Lot 1 Plan 36627, and that they have entered negotiations with Forestry Tasmania (FT) to lease or purchase the required land.

Lease area As noted above, the proponent may need to lease or purchase a small area from FT.

Existing site

Land Use The factory site is zoned “Aquaculture” under the 1989 Esperance Planning Scheme. The site of the existing WWTP, including where the WWTP upgrade will occur, is zoned “Rural C”.

Topography The site slopes in an easterly direction and borders Port Esperance

Geology Predominantly dolerite.

Soils Thin clay soil over dolerite vegetated with dry sclerophyll open forest.

Hydrology The water table is approx 10 – 11m depth at nearby Hawkers Point and is assumed to be the same depth. There are several small local creeks – the largest of which is Stringers Creek 1km to South East.

Fauna There are eight species recorded within 500 metres of the site that are listed as threatened, rare or vulnerable (refer Flora and Fauna section of Appendix 1).

Flora No threatened species are recorded within 500 metres of the site. The site consists predominantly of Eucalyptus pulchella (White Peppermint) Woodland with scattered Eucalyptus ovata (Black Gum), E.obliqua (Stringybark) and an understory dominated by Allocasuarina littoralis (Bull Oak) and Lomandra longifolia (Sagg).

Local region

Climate Predominant wind direction is SW, and the mean annual rainfall is 878mm.

Surrounding land and uses

Predominantly land managed by Forestry Tasmania.

Species of conservation significance

Accipiter novaehollandiae (Grey Goshawk), Aquila audax subsp.fleayi (Wedge‐tailed Eagle), Halieetus leucogaster (White‐bellied Seaeagle), Lathamus discolor (Swift Parrot), Lissotes menalcas (Mt. Mangana Stag Beetle), Pardalotus quadragintus (Forty‐spotted Pardalote), Perameles gunnii (Eastern Barred Bandicoot) Tyto novaehollandiae subsp. castenops (Masked Owl (Tasmanian))

Proposed infrastructure

Major equipment A new wastewater treatment plant.


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Other infrastructure

Aurora will install a new power supply.

Inputs

Water There will be a slight increase in water usage.

Energy There will be a slight increase in electricity usage.

Wastes and emissions

Liquid The existing outfall will be upgraded to discharge a maximum of 490 kilolitres per day (current discharge is 240 kilolitres per day)..

Atmospheric Potential odour from solid fish waste. Dust from construction activities.

Solid General litter. Fish waste that is transported for reprocessing offsite.

Noise Construction activity and operations.

Greenhouse gases

According to the DPEMP, there is only expected to be a slight increase in greenhouse emissions. Projected Greenhouse Gas Emissions (GHGE) = 7.44 kt CO2-e per year

Commissioning and operations

Operating hours Construction 0630 to 1930 hours, Monday to Friday –(weekends only when required) Operational - as required

Project timetable Construction is to begin after approvals have been granted. Construction and commissioning period expected to be approximately 12 months.

Other key characteristics

None

Figure 1: Location of existing plant (from Figure 1 of the DPEMP)


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Figure 2: Aerial view of site (from Figure 2 of the DPEMP).

4 Need for proposal and alternatives According to the DPEMP, the proposed increase in production is required to meet demand. The WWTP upgrade is required to meet the projected increase in the production of liquid waste at the fish processing factory.

5 Public and agency consultation A summary of the public representations and government agency/body submissions is contained in Appendix 2 of this report. The proponent’s response to those issues is contained in the DPEMP Supplement.

Three representations were received. The main issues raised in the representations included:

• Impact from increased noise;

• Light intrusion on residences;

• Impacts on operation of wastewater treatment plant;

• Impact from nutrient and metal discharges from the wastewater treatment plant; and

• Overall environmental impact.


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

• Policy and Conservation Assessment Branch; and

• Water Specialist, EPA Division.

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, consultation has occurred with the EPA, Huon Valley Council, neighbouring residents and Forestry Tasmania.

6 Evaluation of key issues The key environmental issues relevant to the proposal that were identified for detailed evaluation in the project specific guidelines issued to the proponent were:

• Potential effects on water quality in Port Esperance from the proposed intensification; and

• Potential effects on threatened species from habitat clearing associated with the construction of the proposal.

Subsequent to the issuing of the project specific guidelines, the key environmental issues relevant to the proposal for detailed evaluation in this report are:

• Potential effects on water quality in Port Esperance from the proposed intensification

This issue is discussed in the following Section. The table of commitments from the DPEMP is included as Attachment 2 in Appendix 3 of this report.

6.1 Water quality impacts from outfall discharge

Description

The proponent currently discharges up to 240 kilolitres of effluent per day from the WWTP via an outfall pipe that extends 3,000 metres east of the plant. The discharge is directly from the pipe at a depth of approximately 20 metres.

The proponent also has an approval to discharge up to 5,000 litres of treated effluent per day from the adjacent netwash, into the WWTP under the Environmental Management and Pollution Control (Waste Management) Regulations 2010 (Regulations), subject to conditions. The majority of nets treated at the netwash are antifouled with a copper based product. One condition of the approval states:

Discharge of treated netwash effluent to the WWTP must cease within six hours of the person responsible becoming aware that total copper concentrations in the treated netwash effluent have exceeded 2 mg/L, or that copper concentrations in the WWTP discharge water have exceeded 0.5 mg/L.

It is proposed that the new WWTP will be a Sequencing Batch Reactor (SBR). New inlet works will incorporate fine screening, a 250 m3 balance tank, and final effluent disinfection will be achieved by using sodium hypochlorite.

The current mass loading from the WWTP is provided in Table 2. The projected mass loads (average and maximum) are lower for all parameters than the historic loads.


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Table 2:Organic Loadings at Outfall (From revised Table 12 provided in Supplement)

Parameter Projected

Mass Loadings Average

Projected Mass

Loadings Maximum

Historic Averages

(2006-2010)

Historic Effluent

Averages Mass

Loadings

% Proposed vs Historic Loadings

Current Background

Level

kg/day kg/day mg/L kg/day % mg/L

BOD 4.4 9.8 52.19 12.76 38 2.14

TSS 4.4 14.7 150.98 36.92 13 1

Ammonia 2.2 5.88 36.16 8.84 28 0.1

TN 6.6 14.7 49.17 12.02 61 0.1

TP 0.44 3.68 4.98 1.22 40 0.3

Table 3: Proposed Discharge Effluent Quality Standards (From Table 4 of the DPEMP).

*Total N and ammonia limits are proposed as greater than the guideline recommendations to avoid the costs of heating the influent to achieve higher levels of N removal during winter months and in recognition of the good mixing characteristics of the outfall. Accepted Modern Technology (AMT) values for total N and ammonia are shown in brackets.

According to the DPEMP, ammonia removal within the upgraded WWTP may be inhibited because the influent from the factory is colder than most WWTP influents. This is caused by the need to direct ice slurries to the WWTP for treatment. One option is to heat the influent prior to it entering the WWTP to assist in the reduction in the levels of ammonia. Tassal decided to not do this because it was projected that this would require significant quantities of energy (around 350,000kWhr per annum) to do so, which in turn would significantly increase the carbon footprint of the site, and in Tassal’s view result in a negative net environmental benefit. The proponent has opted to conservatively size the WWTP to allow for the slower rate of ammonia reduction at the lower temperature. Even with this increase in size, it is projected that the maximum ammonia and TN emissions will at times be in excess of the (Accepted Modern Technology) AMT Guidelines (Tableo3). All other parameters shown in Table 3 meet AMT guidelines.

Parameter Marine Waters 50% ile 90 %ile Maximum

BOD (mg/L) 10 15 20

TSS (mg/L) 10 20 30

Thermotolerant Coliforms (cfu/100mL) 200 500 750

Oil & Grease (mg/L) 2 5 10

Total N (mg/L) 15*(7) 20*(10) 30*(15)

Ammonia-N (mg/L) 5*(1) 10*(2) 12*(5)

Total P (mg/L) 1 3 5

pH 6.5-8.5


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In order to assess the potential impact on the marine environment from the proposed discharge, the proponent conducted a qualitative marine benthic study of the area surrounding the existing effluent outfall by utilising a remote operated vehicle (ROV) with a video recorder. A description of that study and the results obtained were provided in Appendix K in the DPEMP, and the DVD record of the survey was provided to the EPA Division, who forwarded it to the Policy and Conservation Assessment Branch (PCAB) for comment. The study also included a control site with similar biophysical characteristics (ie depth, tide, exposure and sediment type) located approximately 2km away, i.e. outside the zone of influence of the outfall. While the study was qualitative, the proponent was of the opinion that there appeared to be minimal difference between the two sites, and suggested that the existing outfall has had negligible impact on the benthos of Port Esperance. The proponent also deployed a current meter at the outfall location to gather information relating to current and tidal movements at the outfall. The meter took 10 readings at 2m depth increments each and every hour during this period. Table 9 of the DPEMP provided the resultant maximum, minimum and average current velocities at the outfall, and the results of water quality monitoring adjacent to the outfall were provided in Table 10 of the DPEMP. Based on the measurements at the outfall site, effluent would be diluted at a ratio of 1:164 within four metres of the outfall diffuser under most conditions. According to the DPEMP, recent testing using video inspection and pressured air testing had confirmed the structural integrity of the outfall.

Tassal propose to continue directing netwash effluent into the new WWTP. According to the DPEMP, the expected future quantity and quality of the treated netwash effluent will be as follows:

• Flow: 40 m3/day maximum; • Ammonia-N: 170 mg/L; • Copper: 1 mg/L; and • Zinc: 0.1 mg/L.

Table 4 provides details of expected mass loads and water quality from the proposed increase in netwash effluent being directed through the new WWTP.

Table 4: Copper and Zinc Loadings at Outfall (From Table 13 of the DPEMP)

Unit Zn Cu

Effluent Concentration Limit ug/l 166 133 Projected Mass Loading to Sea kg/day 0.073 0.059 Historical Background Level at Outfall ug/l 1 1 Projected Concentration in Mixing Zone (incl. existing background levels)

ug/l 2.0 1.8

Management measures

The proponent has committed to installing a diffuser on the end of the discharge pipe. According to Appendix D of the DPEMP, the diffuser will consist of three arms configured such that regardless


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of current direction, the effluent discharge into the marine environment will occur over a 15m wide line, perpendicular to the direction of the current. The quality of water from Hawkers (the netwash facility), in particular Cu, Zn and ammonia concentrations, will continue to be tested prior to pumping it to the upgraded Dover WWTP to check that it complies with the water quality requirements of the environmental approval under the Waste Management Regulations. As a contingency measure, should the water not meet the limits required by the upgraded Dover WWTP (ie 1 mg/l Cu and 0.1 mg/l Zn) then this water will be re-treated and analysed. If this fails to meet the required quality criteria the netwash effluent will be tankered to an EPA approved wastewater treatment plant for disposal until other arrangements can be agreed with the EPA. According to the DPEMP, chlorine was selected over other technologies (such as Ultra Violet light or ozone) to ensure a more robust virus elimination system to reduce the chances of fish viruses being transferred to the Dover region from other South East Tasmanian waters. The proponent stated that the depth and mixing profile of the outfall decreased the potential impact of any chlorine residuals causing environmental harm. In the event that harm was detected, an alternative is to install a UV system and/or to dose the effluent with sodium metabisulphide to reduce free chlorine residuals.

• Tassal commits to upgrading the diffuser on the existing effluent outfall (Commitment 2)

• Tassal commits to constructing, commissioning and operating an AMT WWTP that will treat the effluent flows associated with 25,000tpa production to the standards as described in section 2.1.1.1 Wastewater Treatment Plant Upgrade (Commitment 3).

Submissions

Public submissions and proponents response provided in Supplement.

1. A public submission queried whether algal growth and rubbish around the shoreline may in part be attributable to Tassal Operations. The proponent responded in the Supplement that the project will reduce nutrient loadings through treating the wastewater to a higher standard than the current situation. There are various nutrient inputs into Port Esperance from a variety of sources, including aquaculture, other WWTPs and non point sources such as agriculture. The aquaculture industry as a whole contributes to the Broadscale Environmental Monitoring Program (BEMP) which monitors nutrients and benthic health in the D’Entrecasteaux Channel and the Huon River. In addition to this monitoring, and in order to limit nutrient input from the aquaculture sector the Marine Farming Branch of DPIPWE monitors a nitrogen cap on feed inputs at salmon farms in the Huon and D’Entrecasteaux Channel. This ensures that there is a regulated limit to the loading of nutrients from aquaculture to the marine environment. It is also not anticipated that the proposal will contribute to shoreline rubbish.

2. Query as to the relevance of the DPIPWE sewerage treatment plant discharge guidelines. The Supplement stated that the DPIPWE sewerage treatment plant discharge guidelines are based on the notion of Accepted Modern Technology (AMT) which means that the discharge guidelines are the best that can be reasonably achieved with the current known and commercially viable technology. For this reason these guidelines have been adopted as being relevant and appropriate for this project.

3. Concern that even after the proposed upgrade, the WWTP and other marine farming activities will continue to release significant and accumulating amounts of the toxic


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metals copper and zinc into Port Esperance and the Channel. The proponent responded in the Supplement that copper (Cu) and zinc (Zn) emissions are covered in the DPEMP under section 4.2. It is important to note that there is going to be a high dilution/dispersion at the outfall and Tassal expects the EPA to set emission limits and requirements that the effluent discharged is analysed for Cu and Zn, based on the receiving environment. In addition, Tassal is phasing out the use of antifouled nets at its marine locations, and intends to be free of antifouled nets by 2015.

4. Concern in relation to the large amount of sodium hypochlorite with potential to alter the marine environment. The Supplement stated that sodium hypochlorite (NaClO4 ) is deemed to be Accepted Modern Technology and is used as the disinfection agent at numerous Waste Water Treatment Plants across the world.

5. Query as to the adequacy of the control site in the benthic survey. The Supplement stated that the control site was selected for it’s similarity to outfall site in terms of its depth and benthic characteristics. It should also be noted that the outfall location exhibited a similar benthic condition to that of the control site. The control site is also used as a compliance site that must be monitored to assess Tassal’s compliance to marine farm licence conditions for the Dover marine farm. Compliance reports submitted to DPIPWE show that the control site has not been impacted by Marine Farming activities.

6. What assurances can Tassal provide that the proposed intensification will not have a negative environmental impact? The proponent responded in the Supplement that Tassal has undertaken a comprehensive environmental impact assessment (DP&EMP) that considered all of the possible impacts from the proposal. The proposal is designed to mitigate the environmental impacts and will lessen the potential impacts through significantly improving the quality of the effluent discharged from the operation.

7. Queries in relation to the evidence that the inhibition effects on the nitrification process will be minimal. The Supplement stated that the concept design of the WWTP was conducted by a qualified and experienced wastewater treatment process designer who has been involved in the successful completion of numerous WWTPs. The inhibition of the nitrification process (potentially leading to higher ammonia emissions) will be more noticeable during the winter (colder) months. At this time of year, the production levels at the factory are at their lowest. Any inhibition of the nitrification process will therefore coincide with lower throughput and will have a minimal effect on emissions.

8. Queries in relation to the evidence that the discharge levels of ammonia, copper and zinc directly into Port Esperance as not being dangerous and that they will not be exceeded. The proponent responded in the Supplement that ammonia (NH3) amongst other parameters have limits set for their maximum allowable discharges to marine waters based on known impacts. At these levels it is not anticipated that environmental impacts would occur. AMT also allows for a mixing zone of up to 40m to mitigate for impacts in the vicinity of the outfall. Cu and Zn limits are not specified in the guidelines, and will be set by the EPA based on the site specific nature of the discharge, if approval is granted, based on advice from water quality specialists.

9. What regular monitoring of environmental impacts has Tassal completed in the past ten years. The Supplement stated that Tassal subscribes to the Broadscale Environmental Monitoring program (BEMP) for the D’Entrecasteaux Channel and the Huon River. This includes water quality and sediment samples.

Tassal routinely monitors the WWTP effluent discharge into Port Esperance and reports this to the EPA. Tassal also undertakes marine water quality monitoring directly above the discharge pipe and also downstream of the discharge. No elevation of any parameter has ever been recorded in the monitoring of the marine waters.


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Comment provided by PCAB

10. The survey does not appear to be conducted by a suitably qualified/experienced environmental consultant, and no sediment samples were collected. The proponent responded in the Supplement The ROV survey was completed by an experienced Tassal operator who has more than 7 years experience working in the marine environment and has a tertiary degree in this field. The staff member conducts all Tassal’s routine compliance ROV work company-wide to the requirements of the Marine Farming Branch of DPIPWE. The marine farming branch regularly audit the work of the Tassal operator, and no issues of non compliance have been raised. In the view of Tassal, the operator is suitably qualified to complete this report.

No sediment samples were collected owing to advice from qualified consultants that this would not provide any meaningful data to make an assessment by. The ROV work coupled into a comparison with the control site provides a visually acceptable method for examining benthic health.

PCAB subsequently advised the EPA Division that in their opinion a sediment survey, including infaunal assemblages, should be conducted prior to the establishment of the operation of the new WWTP, and surveys should also be conducted after the new WWTP has commenced operations.

Evaluation

The two main components relating to the discharge from the WWTP are the adequacy of the WWTP design and operation, and the outfall itself.

WWTP design and operation

The proposed WWTP is a standard design used throughout the world. The EPA Division is of the opinion that using significant quantities of energy to heat water would not be considered best practice. Consequently, the proposed emission limits (E4) for total nitrogen (TN) and ammonia are higher than those recommended for AMT WWTPs. However, any increase in ammonia and TN discharge levels would be expected to coincide with colder weather which reduces the likelihood of eutrophication because of the reduced daylight length and colder water temperatures. In addition, large inputs of nitrogen from the Southern Ocean naturally occur in the winter and spring seasons which reduces the influence of potentially elevated nitrogen from the outfall. In addition, the projected mass loads are less than are currently being discharged, and the proposed outfall monitoring (proposed non standard condition M4 - Sediment monitoring plan) would be expected to detect any deleterious impacts

Although the proponent stated that the use of sodium hypochlorite is regarded as accepted modern technology, the Emission Limit Guidelines for Sewage Treatment Plants, (2001) produced by Department of Primary Industries, Water and Environment state that chlorination of effluent is not considered best practice within the definition of accepted modern technology. The proponent also considered that using chlorine was the most robust technology for managing the potential risk of the transfer of viruses. In situations where a biosecurity risk applies to wastewater streams from the processing of aquatic animals, Food and Agricultural Organisation (FAO) (2000) encourages and specifies disinfection treatment technologies that do not use disinfection chemicals for wastewater treatment. The FAO identified only the use of UV and ozone, after effective filtration producing small to no suspended particulate levels, for the treatment of microbiological pathogens. The proponent has another fish processing facility that uses four tiers of disinfection (filtration, UV, ozonation, and chlorination as a final barrier) because of the high risk of transfer of diseases from Macquarie Harbour raised fish to fish farmed in D’Entrecasteaux Channel. Note, Macquarie Harbour raised fish will not be processed at the Dover plant.

The EPA Division water specialist is of the opinion that the proponent should be required to fully assess alternative disinfection strategies because of the FAO position, and that chlorination in new


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WWTPs is not considered AMT in Tasmania. Non-standard condition OP1 (Disinfection Plan) would require the proponent to provide an assessment of alternative disinfection strategies, a justification for the preferred strategy and any potential impacts of their preferred strategy.

The current WWTP can receive up to 5,000 litres of treated netwash effluent per day. This represents approximately 2% of the influent to the WWTP. The proponent proposes to direct up to 40,000 litres netwash effluent per day in the future. This will require the proponent to apply to the Director, EPA for an environmental approval under the Environmental Management and Pollution Control (Waste Management) Regulations 2010 (the Regulations) to increase the volumes. An increase to 40,000 litres per day would represent 10% of the influent, which increases the potential for the netwash effluent to have an impact on the functioning of the WWTP. It is the opinion of the EPA Division that the proponent should be required to demonstrate that the increased volumes of netwash effluent will not have an impact prior to gaining an approval under the Regulations. It is also recommended that the proponent be required to prepare a contingency plan to manage potential impacts on the operation of the WWTP through unplanned events such as power failure etc (OP2).

Outfall

The video survey conducted by the proponent suggested that minimal impact has occurred as a result of the current outfall. However, this survey was qualitative and the EPA Division’s water specialist agrees with PCAB that sediment surveys should be conducted prior to, and subsequent to the operation of the new WWTP. Non-standard permit condition M4 would require the proponent to submit a sediment monitoring plan to the Director for approval. The proposed outfall is to be located in the same location (proposed non-standard permit condition E3 - Effluent discharge locations) which is in relatively deep water. The proposed diffuser would be expected to improve the dispersion of the effluent. Non-standard permit condition E5 (Outfall discharge diffuser) would require the proponent to install the diffuser as described in the DPEMP, or a variation approved by the Director. Non standard condition M2 stipulates the frequency of effluent monitoring. The monitoring of the dilution/dispersion characteristics within the vicinity of the outfall reported by the proponent also suggest that any impacts from the discharge would be mitigated within a short distance from the outfall. Non-standard condition M3 (Wastewater plume dispersion characterisation) would require the proponent to monitor the actual dispersion characteristics of the new outfall.

Several representations raised concerns about the impact of effluent discharge on water quality within Port Esperance. While the WWTP discharge from the proponent's site does contribute to the overall nutrient load in Port Esperance, the EPA Division agrees that there are many sources of nutrients within the catchment and it is difficult to assign any one source to observed impacts from eutrophication. The proposed upgrade, and the addition of a diffuser, would also be expected to reduce the impact from this site.

In summary, the EPA Division is of the opinion that, providing the proponent complies with the proposed permit conditions relating to discharge quality, and the dilution/dispersion characteristics are similar to those reported in the DPEMP, there will be minimal impact from the discharge.

Recommendations

It is recommended that relevant management commitments outlined in the DPEMP and summarised above are included in the permit.

The following standard (generic) conditions are recommended for inclusion in the permit:

M1 samples to be analysed at NATA laboratories

The following non-standard permit conditions are recommended for inclusion in the permit:

E3 Effluent discharge locations E4 Effluent quality limits for discharge to water


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E5 Requires the placement of the diffuser M2 Wastewater monitoring stipulates the frequency of monitoring

M3 Wastewater plume characterisation study to be completed within 90 days of the commencement of discharge from the new WWTP and a report submitted to the Director 30 days after the study.

M4 Sediment monitoring plan.

OP2 Contingency management.

7 Other environmental issues In addition to the key issues, the following environmental issues are considered relevant to the proposal and have also been evaluated.

• Aboriginal heritage

• Atmospheric (odour)

• Controlled and solid waste management

• Decommissioning and rehabilitation

• Flora and fauna

• Groundwater

• Hazardous substances

• Noise

• Traffic impacts

• Weed management

Details of this evaluation, along with recommended permit conditions, are contained in Appendix 1.

8 Conclusions The EPA Division is of the view 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; and

3. the recommendations set out in this report accord with the Board’s responsibilities in relation to these objectives and principles.

This assessment has been based upon the information provided by the proponent in the DPEMP and DPEMP Supplement.

This assessment has incorporated specialist advice provided by Divisions of DPIPWE in relation to a number of key issues.

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 recommendations made in this report are satisfactorily implemented, including the commitments made by the proponent in the DPEMP and DPEMP Supplement.


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9 References Food and Agricultural Organisation (2000). Waste from processing aquatic animals and animal products: implications on aquatic animal pathogen transfer. FAO Fisheries Circular No 956 FIIU/C956(EN).

Tassal Operations Pty Ltd, November 2010. Dover Processing Plant Production Intensification Development Proposal and Environmental Management Plan

Tassal Production Intensification/Dover (DA-229/2010) DPEMP Supplement

10 Summary of appendices Appendix 1 Assessment of other environmental issues

Appendix 2 Summary of issues raised by public and agency submissions

Appendix 3 Proposed permit conditions, includes DPEMP Commitments at Attachment 2

Appendix 1 Assessment of other environmental issues

Issue

Aboriginal heritage

Description of potential impacts

Loss of Aboriginal heritage values through disturbance during construction.

Management measures proposed in DPEMP

According to the DPEMP, an Aboriginal heritage survey was conducted by Aboriginal heritage officer Leigh Maynard on 25th February 2010. The results of this survey showed that there were no Aboriginal heritage sites present and that the potential for Aboriginal heritage occurring at the location is minimal. The heritage report has been provided to Aboriginal Heritage Tasmania The area of the proposed development has little or no identifiable post-European settlement heritage value.

Public and agency comment

AHT commented that they had no objection to the project continuing, but did note that under Aboriginal Relics Act 1975 all works had to stop if Aboriginal heritage was suspected and AHT to be contacted for advice.

Evaluation and Recommendations

It is considered unlikely that earthworks during the construction phase of the proposal will impact on Aboriginal heritage. Provisions of the Aboriginal Relics Act 1975 to be included in the Information Schedule of the permit part B.


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Issue

Atmospheric (odour)


Inappropriate management of WWTP or fish waste handing leading to odour emissions beyond the Land.


WWTP • Influent wastewater will be screened with a new milli-screen, • Screening waste will be binned and taken offsite for either disposal or reprocessing at a

rendering plant. • The balance tank will be equipped with an aerator for mixing, maintenance of aerobic

conditions and to minimise odours. Fish waste

• Wet fish waste to be dosed with acid to reduce odours during transport and storage; • All dry fish waste is stored in sealed 1,000 L bins in a bunded area. • The facility and all equipment is routinely maintained and cleaned to prevent the

accumulation of putrescible materials that may give rise to odours. • The introduction of refrigerated shipping containers for storage of fish waste will provide

further odour reduction.


No issues were raised in relation to odour


To date, there have been no recorded complaints relating to odour. Considering the improvement in operations (refrigerated shipping containers etc) it is considered that any potential odour sources can be managed to prevent environmental nuisance beyond the boundary of The Land. It is recommended that the proponent be required to comply with standard permit condition A2 (odorous gases).

Appendix 1


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Issue

Controlled and solid waste management


Animal wastes from fish processing facilities are controlled wastes. Potential impact resulting from uncontrolled transport and handling of controlled wastes, and inappropriate management of solid wastes. The WWTP will also require periodic desludging

Management measures proposed in DPEMP It is expected that annually, nearly 4,000 tonne of solid fish waste will be collected, stored and transported to Seafish (Triabunna) for rendering. Tassal plan to upgrade the existing collection and storage arrangements (as described above).. Public and agency comment

No issues were raised in relation to controlled and solid wastes.


The proponent currently transports solid fish waste to Seafish using approved controlled waste transporters and as such is familiar with the requirements under the Environmental Management and Pollution Control (Waste Management Regulations) 2010. The sludge from the WWTP would be expected to contain copper and zinc at elevated levels because it is assumed that the majority of these two metals will partition to the sludge. Copper and zinc are two analytes that must be measured within any sludge management system prior to disposal offsite. It is proposed that up to 4,000 tonne of solid fish waste will need to be transported offsite for processing in another company’s facility. Disruptions through unplanned events onsite, or to the operations of the transporter or treatment facility, could result in environmental impacts such as an increase in odour, or effluent discharge from the stored fish waste. It is recommended that the proponent be required to prepare, and update as required, a contingency management plan (OP2). The management measures are considered appropriate. It is recommended that the proponent be required to comply with standard conditions WM1 Waste management hierarchy, WM2 Controlled waste transport, WM3 Fish waste management, WM4 Removal of fish waste, WM5 Sewage sludge management plan, and OP2 (Contingency management).

Appendix 1


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Issue

Decommissioning and rehabilitation


Inappropriate decommissioning and rehabilitation.


There is no plan for the decommissioning of the proposed facility in the foreseeable future. In the event that the facility becomes redundant a decommissioning and rehabilitation plan will be produced and provided to the Director, Environment Protection Authority at least six months prior to decommissioning.


No issues were raised in relation to decommissioning and rehabilitation


In the opinion of the Division, it is reasonable that a Decommissioning and Rehabilitation Plan (DRP) has not been prepared. Any issues relating to decommissioning and rehabilitation can be managed through compliance with the following standard conditions; DC1 requiring notification of cessation, DC3 rehabilitation following cessation and DC4 requirements during suspension of activity. Non standard condition DC2 requires the submission of a draft DRP within 30 days of notification of cessation. It is recommended that the proponent be required to comply with standard conditions DC1, DC3 and DC4 and non standard conditions DC2 and G5 (Commitments).

Appendix 1


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Issue

Flora and fauna habitat

Description of potential impacts The proponent commissioned Sinclair Knight Merz (SKM) to conduct a flora and fauna survey of the proposed site. Their report was included as Appendix G of the DPEMP. According to SKM there are eight species of fauna recorded with 500 metres of the site, that are listed under the Tasmanian Threatened Species Protection Act 1995 (TSPA 1995) and/or The Commonwealth’s Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act). The threatened fauna species are Accipiter novaehollandiae (Grey Goshawk), Aquila audax subsp.fleayi (Wedge‐tailed Eagle), Halieetus leucogaster (White‐bellied Seaeagle), Lathamus discolor (Swift Parrot), Lissotes menalcas (Mt. Mangana Stag Beetle), Pardalotus quadragintus (Forty‐spotted Pardalote), Perameles gunnii (Eastern Barred Bandicoot) Tyto Novaehollandiae subsp. Castenops (Masked Owl (Tasmanian)). Management measures proposed in DPEMP SKM’s report concludes that the development is not likely to significantly affect local flora or fauna, but recommends that:-

• Further advice be sought from DPIPWE Threatened Species Unit prior to clearing any E.ovata (black gum) trees, which are of benefit to the Swift Parrot. Tassal note that at this stage it is not proposed to clear any Black Gums.

Tassal will act in accordance with the Weed Management Act, 1999. It is noted that there are some weed species on the proposed construction site which will be eradicated during the construction phase. A planning approval will be needed from the Huon Valley Council for any clearing of land or destruction of native vegetation.

Tassal will act in accordance with the Weed Management Act, 1999 (Commitment 9).

Retain native trees around WWTP area (Commitment 10).


Policy and Conservation Assessment Branch (PCAB) responded that they were supportive of the recommendations outlined in the Flora and Fauna Assessment conducted for the proposal. In particular, PCAB agreed that removal of any mature Eucalyptus ovata trees must involve prior consultation with the Department. Further, PCAB recommended that the management of weeds and disease on the site be formalised in a Weed Management and Hygiene Plan. This Plan should include measures aimed at ensuring that any rehabilitation works are weed free.

Evaluation and Recommendation

Based on the advice of PCAB, it is considered unlikely that the proposal would have a significant impact on flora and fauna on the site providing vegetation and weeds are managed in an appropriate manner. It is recommended that the proponent be required to comply with non standard permit condition G5 (Commitments) and FF1 (Weed and Pathogen Management Plan).

Appendix 1


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Issue

Groundwater


Impact on groundwater from construction and operations.


The closest boreholes to the site are a series of six bores installed by Tassal to monitor groundwater at the Hawkers Net Slab site. These are approximately 1km west of the Processing facility and Tassal has received advice from a qualified hydrogeologist that the groundwater levels monitored here would be similar to the groundwater levels at the WWTP site. Groundwater levels are approximately 11meters below ground level; and at these depths, the planned upgrade of the WWTP is not seen to have any likely impact on groundwater. Construction activities will be generally limited to 1-2m below the surface. If groundwater is intersected drainage lines will be installed to direct groundwater around the WWTP as it makes it way down the sloping terrain. Public and agency comment

No issues were raised in relation to groundwater.


It is considered that the management measures are appropriate. The assessment of hazardous materials (such as fuels) is detailed below. The proposed upgrade includes the use of existing lagoons. The water specialist recommended that a groundwater monitoring plan (standard condition M6) be submitted to the Director. Monitoring the site would provide data relating to historic or ongoing contamination of groundwater by the WWTP.

Issue

Hazardous materials


Contamination of the Land, surface and groundwaters.


The existing storage arrangements will be examined with upgrades proposed to ensure that they are appropriately and legally stored. Tassal commits to reviewing the existing hazardous and dangerous goods stores to ensure compliance. (Commitment 7)


No issues were raised in relation to hazardous materials.

Evaluation

The management methods proposed for storage areas are considered appropriate. It is recommended the applicant be required to maintain spill kits on site (H1). Hazardous materials would also have to be appropriately stored within bunded areas to comply with H2 (storage of materials in volumes greater than 250 litres) and H3 (volumes less than 250 litres). It is recommended that the proponent be required to comply with standard conditions H1, H2 and H3, and non-standard condition G5 (Commitments).

Appendix 1


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Issue

Noise


Noise from construction and operational activities causing environmental nuisance


According to the DPEMP, the nearest residential property is 1.2 km from the site. Employ best practice construction techniques to reduce any noise emitted during construction activities (Commitment 4). Tassal commits to maintaining a public complaints register during and after construction (Commitment 5).


One public representor queried the impact of intrusion of noise from the plant and sea craft over time and objected to proposed construction over 13 hour days for an eleven month period. The proponent responded in the supplement that; The proposed construction hours are standard and that noise generating activities are unlikely to take up the full 13 hour period every day. Tassal will take all reasonable steps to minimize construction noise impact on sensitive receivers and if deemed necessary, will assess noise emissions from the construction site in order to demonstrate compliance to EPA noise emission standards. Evaluation and Recommendations

While noise will be generated by construction and operations, there are no sensitive receptors in the vicinity of the site. The representor resides in Dover approximately 3.5 km from the plant, but has line of sight (over water) to the proponent’s premises. The Division noise specialist reviewed the DPEMP and has suggested that there is a very low likelihood that the proposed activity would cause an environmental nuisance through the generation of noise. The specialist advised that construction noise impacts can be managed through the Construction EMP (CN1). The specialist also recommended that the noise limits, for both construction and plant operations at the plant at the nearest noise sensitive receptor should be

• 45 dB(A) between 0800 hours and 1800 hours (Day time); and • 40 dB(A) between 1800 hours and 2200 hours (Evening time); and • 35 dB(A) between 2200 hours and 0600 hours (Night time).

In relation to the concerns of the representor, the specialist advised that the proposed noise emission limits are the lowest that are ever applied by the EPA and providing that the proponent complies with these limits (which is highly likely given the separation distances), noise from the activity should not cause environmental nuisance. The specialist also advised that the EPA would normally only regulate seacraft noise when the vessel is tied up to a wharf. It is recommended that the proponent be required to comply with standard conditions CN1 (Construction Environmental Management Plan) and, non standard permit condition N1 (Noise emission limits).

Appendix 1


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Issue

Traffic impacts


Impacts from noise and dust


According to the DPEMP, the construction and operation of the facility is anticipated to lead to a minor increase in trucking and other vehicle usage. Tassal commits to conducting community consultation to advise nearby residents of the modest traffic increase (Commitment 14).


No issues were raised in relation to traffic.


It is considered unlikely that the addition of an extra 3-5 truck movements will significantly increase dust or noise in the area. It is recommended that the proponent be required to comply with non-standard condition G5 (Commitments).

Issue

Weed management


According to the DPEMP, one species of declared weeds, within the meaning of the Tasmanian Weed Management Act 1999, was found during a survey on the site. This was Genista monspressulana (Montpellier Broom).

Management measures proposed in DPEMP The weed species on the proposed construction site will be eradicated during the construction phase.

Tassal will act in accordance with the Weed Management Act, 1999 (Commitment 9).


PCAB recommended that the management of weeds and disease on the site be formalised in a Weed Management and Hygiene Plan.


The advice from PCAB appears appropriate. The proposed permit condition FF1 requires the submission of a Weed and Pathogen Management Plan. It is recommended that the proponent be required to comply with non standard permit conditions G5 (Commitments) and FF1 (Weed and Pathogen Management Plan).

Appendix 2


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Appendix 2 Summary of issues raised by public and agency submissions

TASSAL PRODUCTION INTENSIFICATION Summary of Public, Agency and Council comments

A. Relevant Public Submissions

Issue Comment Further Information required?

Environmental Noise Complaint of intrusion of noise over time and objection to construction

proposed over 13 hour days Y

Visual Complaint of intrusion of light into the rooms of a residence. Algal growth and rubbish around the shoreline may be in part attributable to Tassal operations

Nutrient and metal discharges

Query as to the relevance of the DPIWE sewage treatment plant discharge limits. Concern that even after the proposed upgrade, the waste water plant and other marine farming activities will continue to release significant and accumulating quantities of the toxic metals copper and zinc into Port Esperance and the Channel. Added to this will be large quantities of sodium hypochlorite with potential to alter the marine environment. Query as to the adequacy of the control site used for the benthic survey

Y

Environmental impact

What assurance can Tassal provide that the proposed intensification will not have a negative impact

Y

Queries in relation to the evidence that: • The inhibition effects on the nitrification process will be minimal • That the discharge levels of ammonia, copper and zinc directly into Port

Esperance as not being dangerous and that they will not be exceeded

Y

What regular monitoring of environmental impacts has Tassal completed in the past ten years?

Y

General Negative impact on property values.

Appendix 2


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B. Referral Agency Comments Agency Chapter Section/

page Additional information required

Environmental

DPIPWE – Policy and conservation Assessment Branch

The information contained within the Pipe Outfall Benthic Survey is considered deficient for the following reasons.

• The survey does not appear to be conducted by suitably experienced/qualified environmental consultants, and no sediment samples were collected.

PCAB have advised the EPA Division that a survey should be required as part of a permit condition and can be undertaken post-approval.

Appendix 3


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Appendix 3 Proposed permit conditions

tassal production intensification narrows road, …epa.tas.gov.au/documents/tassal_dover_ear.pdf ·...

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