PROPOSED PROTEIN RECOVERY PLANT (PRP) 24 SCOTT STREET, WARRNAMBOOL. WORKS APPROVAL APPLICATION RESPONSE TO s.20(b) CONFERENCE REPORT

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1 PROPOSED PROTEIN RECOVERY PLANT (PRP) 24 SCOTT STREET, WARRNAMBOOL WORKS APPROVAL APPLICATION RESPONSE TO s.20(b) CONFERENCE REPORT 3 December

2 INTRODUCTION Midfield has prepared this response to the report prepared under Section 20B of the Environment Protection Act The Conference Report, prepared by Kismet Forward, are recommendations and relate to Midfield s application for a Protein Recovery Plan, Scott St Warrnambool. The content of the response can be made publicly available. RECOMMENDATIONS AND RESPONSE The following recommendations have been considered and Midfield provides a response. Prior to determination of the Works Approval Application, the following actions should be undertaken by the applicant at the EPA s direction: Recommendation 1 Verify, through an independent odour assessment, the exact nature and extent of odour likely to be generated by the biofilter (i.e. the bark smell). An independent consultant, Air Quality Professionals Pty Ltd, has provided an assessment and recommendations for the proposed PRP (18 May 2018). This report formed part of the original Works Approval Application. Biofiltration provides an environmentally benign technology that in itself does not create any further pollutants as a result of the process (Proand Associates, 1998); The Air Quality Professionals report undertook odour modelling and analysis of the proposed PRP and Biofilter and reported: Odour discharged from a biofilter has a musty, earthy character that blends rapidly with natural background odours as it disperses in the wind. The biofilter odour will not be noticeable even at much higher odour concentrations than the default odour assessment criteria Atmospheric dispersion modelling demonstrated that the available separation distances to residences were sufficient for odour emissions from the biofilter under upset operating conditions. Overall, it is concluded that the potential impact of odour emissions from the proposed PRP is low, and the default buffer distances specified in EPA Publication 1518 can be reduced Biofilter type odours even at elevated levels will be of a bark or earthy nature and proven not to travel, therefore unlikely to impact even the closest receptors Midfield has continued to work with the EPA regarding the design of the biofilter, the main odour source, to ensure that risk management and air security. Haarslev has guaranteed that the odour from the biofilter would be a maximum of 200 OU provided the raw material is not older than 24 hours. Midfield will only accept material less than 24 hours old and less. Odour modelling from Air Quality Professionals has confirmed that at 200 OU to 400 OU from the biofilter, therefore the nearest residences are not expected to be affected. 2

3 Recommendation 2 Provide supporting evidence of the successful application of both the PRP and biofilter technologies in comparable locations within close proximity of residential, educational and/or recreational uses, particularly regarding odour, air and noise emissions. The main odour source for this project is the Biofiler as the PRP design incorporates a full point source capture system. Whilst other plants have been designed and constructed by Haarslev, the provider of the PRP and biofilter, not all sites have implemented the same integrated design approach (ie biofilters have been separately commissioned). Midfield has provided details of other biofilter operations, but there is no exact match based on proximity to residences and operational use. Other referenced examples include Baiada Tamworth, and plants in Europe, Russia, USA, Brazil, South America. Baiada and other Australian plants process poultry material. Poultry raw material degrades more than red meat and hence a plant processing poultry raw material will produce more odour. We understand that Baiada plants and other Haarslev plants have the same odour scrubbing system that is proposed for the PRP. The scrubber has a series of spray nozzles that scrub the gases from the rendering plant with water to remove particulate matter. The above references relate particularly to the installed point source and equipment quality and the internal plant odours. Biofilters at these other facilities have not been designed by Haarslev. Recommendation 3 Provide written assurance that the PRP and biofilter design, construction and operation will be compliant with relevant EPA policy and legislation parameters, and what contingency measures will be put in place in case of equipment or system failure. Midfield s proposed PRP and biofilter design, construction and operation will be compliant with current and relevant EPA policy and legislation parameters. A detailed risk management plan will be adopted which will provide mechanisms for all potential areas of risk in the operation. The Biofilter is the main odour source, however the maintenance is low. Midfield s will focus on biofilter management which includes having a spare fan onsite or taking the material off site should the need arise. Midfield have a co-generation powerplant onsite in the event of power failure which provide additional assurances in the event of a power failure. 3

4 The biofilter procedures as follows: Maintenance Continuous monitoring of pressure, inlet temp, humidity and flow. Daily visual inspection Daily addition of water where required Weekly digital manometer to ensure negative building pressure Weekly moisture of biofilter media Monthly ph of media Quarterly for first 2 years then half-yearly testing of microorganism Annual odour assessment inc. media depth o Lateral design periodically blowing out of lines with compressed air if there is an increase in back pressures Re-fluffing To date the biofilter at the current render has not required re-fluffing Will occur when above monitoring indicates compaction of the bed material Replacing biofilter medium based on back pressure Again, this is yet to be required at the current render biofilter Is dependent on the design o Lateral design this could be every years o Plenum floor design could be every 3-5 years Would occur when the back pressure exceeds 2.5 kpa If there is an event whereby raw material needs to be diverted, Midfield proposes two options: MBL Keith facility has capacity to receive diverted material, if required. MBL Keith is a service renderer. We understand that they have spare capacity and with increased future capacity. Current supply is known to be about to decrease; and CSF foods Melbourne are also a service render with potential spare capacity. The PRP point source and room suctions include monitoring equipment to measure pressures and temperatures in the system which be connected to the facilities main SCADA control system and alarm points established. These set points will be determined following the commissioning and calibration of the plant under normal operating conditions. This would also include monitoring probes installed into the key ducts of the point source system to give early warning of any changes in pressure and temperature. 4

5 Warrnambool City Council should request the following information from the applicant to assist consideration of the Planning Permit Application: Recommendation 4 Justification as to why the proposal seeks 24-hour, 7-day operation, given the stated intention for reduced hours of operation. The Abattoir planning permit allows a 24/7 operation. The PRP is designed to operate as downstream processing of the raw material from the Abattoir. Whilst the Abattoir usually operates 5 days a week and sometimes 6 the PRP needs to finish the processing of the raw material produced. e.g. In the event that the Abattoir works on a Saturday this may see the PRP operate into Sunday morning. It is not proposed to amend the permitted hours, but the use will comply with NIRV and could also be addressed in a Management Plan. Recommendation 5 A Transport Management Plan that includes: - An assessment of traffic movements into, out of and within the site, including transport routes, number of traffic movements and hours; - A description of the differences in traffic impacts (noise, odour and congestion) on residential areas between current and intended operation; and - Measures to minimise the impact of reversing beepers on surrounding residential areas. The proposed use will decrease traffic movements between Swinton Street and the Scott Street site, which is approximately 200 movements per week. The current transport route for raw material would no longer use the extension along McMeekin Rd into Gay St then onto Swinton St. This is means there is a great reduction of transport vehicles in residential areas. All internal movements will be managed by either hook lift trucks of forklifts. Midfield are also investigating direct transfer of raw material via a ducting or a pumping system which would greatly reduce internal traffic movements. The future traffic movements are expected to reduce to 15 to 25 movements per week. The use of reversing beepers is important to OHS within the existing abattoirs and any related to the PRP would be likely only during daytime hours. 5

6 Recommendation 6 Rationale for the current and proposed future mode of product transport being primarily via road rather than rail. Midfield continually review the option of utilising rail as a transport option, this includes logistical issues of loading and unloading, the end market location and access to the same, along with economic assessment of rail compared to road transport. Should the Works Approval Application be approved, the following actions should be undertaken by the applicant at the EPA s direction: Recommendation 7 Regularly make noise, dust and odour data publicly available, such as on a website or social media platform, and in an easily understandable format to demonstrate compliance Midfield supports regular noise and odour reporting. Dust is not a feature of the proposal as it is inside an enclosed building. As part of the application there are key monitoring activities with the operation of the PRP that will be recorded both automatically as well as manually. These records will form the background for annual reporting. A format for making this information available to external parties could be developed and could be agreed too. Odour and noise monitoring during commissioning can also be made available to external parties as agreed by the EPA and Midfield. Midfield will provide information to the EPA and Council as required. Recommendation 8 Ensure the completion of all required technical and engineering assessments, including a geoengineering survey (to satisfy concerns relating to noise/vibration carrying through sandstone). Geotechnical assessments will be required as part of the civil design works for the PRP. Watson Moss Growcott (an independent noise consultant engaged by Midfield) has provided comment as follows: Initial review of the proposal has indicated that any possibility of perceptible vibration would be limited to within the building, so no detailed consideration of possible off-site vibration effects has been conducted. 6

7 Should the Works Approval Application be approved, the following actions should be undertaken by EPA Victoria Recommendation 9 Ensure that the odour and noise level guarantees regarding construction and ongoing operation are enforced. Relevant levels and commissioning results can be provided to confirm these have been met based on an agreed program to collect results. Recommendation 10 Explain (and make publicly available via website and potentially media release): - the rationale as to why EPA Guidelines (with respect to buffer distance) have been varied for this application, and - answers to community questions regarding noise and odour limits considered acceptable to the EPA The EPA Recommended Separation Distance for Industrial Residual Air Emissions - Guideline (Publication 1518) provides advice on recommended separation distances between industrial land uses that emit odour or dust, and sensitive land uses, such as the proposed PRP. A reduction of the recommended separation distance of 1000m has been considered and justified in detail in the report provided by Air Quality Professionals Pty Ltd. Refer to Recommendation 1 for response to odour and the Noise will comply with NIRV as supported by the Watson Moss Growcott report. Should the Planning Permit Application be approved, the following actions should be undertaken by Warrnambool City Council: Recommendation 11 Ensure the development of a Section 173 agreement requiring the decommissioning of the Swinton Street facility following the PRP becoming fully operational. The s.173 Agreement is current being prepared which provides a statutory mechanism for the cessation of the use of Swinton Street following the PRP becoming fully operational. Recommendation 12 Consider limitations on the hours of operation to minimise after hours impact on residential areas. As per above response to Recommendation 4. Recommendation 13 Require screening of the site through onsite and boundary planting. Landscape plan to show how this may be addressed where possible and deemed safe considering truck movements and line of sight for safe entry and exit. 7

8 Recommendation 14 Require the applicant to develop (and make broadly available) an FAQ (or similar) about the closure and remediation of the Swinton St site. The information updates can be provided to the key stakeholders as part of an agreed communication plan. Regardless of whether the Works Approval Application is approved or rejected, the following actions should be undertaken by EPA: Recommendation 15 Enforce compliance with relevant requirements and undertake regular site audits. Since engaging the community in this proposal process, Midfield has directly addressed complaints. Midfield will continue to work with the community and the EPA if any issues or non-compliance arise. Recommendation 16 Provide community feedback about the outcomes of audits and compliance activities. Agreed. Recommendation 17 Make this report available to all conference attendees. Noted. Regardless of whether the Works Approval application is approved or rejected, the following actions should be undertaken by the applicant at the EPA s direction: Recommendation 18 Develop an ongoing and authentic community engagement vehicle (such as a Community Liaison Committee) that has a clear Terms of Reference and enables transparent sharing of information and discussion of current and emerging issues and community concerns (with the aim of resolution). Midfield will undertake key stakeholder engagement regarding the proposed timelines, development and other milestones. This information will be provided by way of updates at each stage to the key stakeholders. 8