George Town Seafoods - EPA Tasmaniaepa.tas.gov.au/documents/geroge town seafoods, production... ·...

George Town Seafoods Production Increase Environmental Effects Report

December 2015

GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | i

Table of contents 1. Introduction..................................................................................................................................... 1

1.1 Purpose of this report........................................................................................................... 1

2. Part A – Proponent Information ..................................................................................................... 2

2.1 Proponent Details ................................................................................................................ 2

2.2 Background .......................................................................................................................... 2

3. Part B – Project Description ........................................................................................................... 4

3.1 Description of Project ........................................................................................................... 4

3.2 Project Area ....................................................................................................................... 10

3.3 Map and Site Plan .............................................................................................................. 10

3.4 Rational and Alternatives ................................................................................................... 13

4. Part C – Potential Environmental Effects ..................................................................................... 14

4.1 Flora and Fauna ................................................................................................................. 14

4.2 Rivers Creeks, Wetlands and Estuaries ............................................................................ 14

4.3 Significant Areas ................................................................................................................ 15

4.4 Coastal Zone ...................................................................................................................... 15

4.5 Marine Areas ...................................................................................................................... 15

4.6 Air Emissions ..................................................................................................................... 16

4.7 Liquid Effluent .................................................................................................................... 17

4.8 Solid Wastes ...................................................................................................................... 24

4.9 Noise Emissions ................................................................................................................ 25

4.10 Transport Impacts .............................................................................................................. 26

4.11 Other off site Impacts ......................................................................................................... 27

4.12 Hazardous substances and chemicals .............................................................................. 28

4.13 Site contamination ............................................................................................................. 29

4.14 Sustainability and Climate change ..................................................................................... 30

4.15 Cultural Heritage ................................................................................................................ 31

4.16 Sites of Public interest ....................................................................................................... 31

4.17 Rehabilitation ..................................................................................................................... 31

5. Part D – Commitments ................................................................................................................. 32

5.1 Management Commitments ............................................................................................... 32

6. Part E - Public Consultation ......................................................................................................... 33

6.1 Public consultation ............................................................................................................. 33

7. Disclaimer..................................................................................................................................... 34

8. References ................................................................................................................................... 35

Table index

ii | GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760

Table 2-1 Proponent Details .................................................................................................................... 2

Table 3-1 Existing and Proposed George Town Seafoods Fish Processing Quantities ......................... 4

Table 3-2 Water, Chemical and Liquid Waste Estimated Volumes ......................................................... 8

Table 3-3 Project area information (ListMap accessed 07/09/15) ..................................................... 10

Table 4-1 Likely Tradewaste Discharge Rates During Peak Salmon Production .................................. 19

Table 4-2 Tradewaste and Component Volumes ................................................................................... 19

Table 4-3 Existing Tradewaste Quality .................................................................................................. 20

Table 4-4 Sources of Sodium in Tradewaste ........................................................................................ 21

Table 4-5 Annual Chemical Volumes* ................................................................................................... 28

Table 5-1 Management Commitments ................................................................................................... 32

Figure index

Figure 3-1 Current and Proposed Seasonal Production Trend (tonnes) ................................................. 5

Figure 3-2 Proposed Salmon (Hog) Process Flow ................................................................................... 6

Figure 3-3 Site Area Map ....................................................................................................................... 11

Figure 3-4 Site Layout ........................................................................................................................... 12

Figure 4-2 Proposed Improved Efficiencies ........................................................................................... 30

Appendices Appendix A – Draft Biosecurity Management Plan (Tassal September 2015)

Appendix B – Current Containment Areas

Appendix C Biosecurity Permit

GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 1

1. Introduction 1.1 Purpose of this report

The purpose of this Environmental Effects Report (EER) is to provide information to support a

development application by George Town Seafoods to the George Town Council for a

production quantity increase.

The EER provides information for the Environmental Protection Authority to consider

environmental aspects of the proposal. The information will be used to determine the conditions

under which approval may be given.

The EER also provides information for interested individuals and groups to gain an

understanding of the proposal.

The EER has been prepared in accordance with the Environmental Effects Report Guidelines

for George Town Seafoods Proprietary Limited, Proposed Increase in Capacity of Fish

Processing Factory 38-42 Franklin Street, George Town, the EPA general guidelines for

preparing Environmental Impact Statements for level 2B activities (EPA April 2013) and the

Draft Aquaculture Farm Biosecurity Plan Guidelines and Plan Template (Australian Government

Department of Agriculture 2015).

2 | GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760

2. Part A – Proponent Information 2.1 Proponent Details

The proponent for the George Town Seafoods Production Increase EER is shown below in

Table 2-1.

Table 2-1 Proponent Details

Proponent Name Managing Director, George Doumouras

George Town Seafoods Pty Ltd

Proponent Address

38 - 44 Franklin Street,

George Town,

TAS 7253

ABN 76 076 219 988

There are no known legal proceedings against the proponent and they are considered capable

of meeting the financial and resource implications of the project.

GHD Pty Ltd (GHD) has provided environmental assistance in preparing this EER on behalf of

the proponent. The GHD contact for the George Town Seafoods Production Increase EER is:

Susan McLeod

Senior Environmental Consultant

GHD Pty Ltd

23 Paterson St

Launceston TAS 7250

Phone: (03) 6332 5531

2.2 Background

George Town Seafoods Pty Ltd is an existing seafood processing and exporting facility located

in the light industrial area of George Town, Tasmania. Established in 1993, George Town

Seafoods was has always been an export accredited facility; regularly audited by AQIS to meet

the strict hygiene requirements for the export of seafood. Currently, George Town Seafoods is

registered under an approved arrangements system with AQIS, and is one of few processing

facilities registered as a preferred processor for the European Union (EU).

The criteria which George Town Seafoods adheres to in order to be EU registered demands

that world regarded best processing practices be utilised throughout all facets of the processing

line. These criteria include fish waste and waste management. The site is also audited by a

third party HACCP (hazard analysis and critical control plan) auditor to maintain HACCP

accreditation.

George Town Seafoods process raw fish (white fish and salmon), scallops, oysters and crayfish

The site operates under an existing EPN issued by the Tasmanian EPA and has a licenced

processing capacity of 5,000 tonnes of product produced per year. Seafood raw products (live,


chilled or frozen) are processed by filleting, heading, gutting, skinning and boning. The resulting

products are for human consumption and for bait.

The site has been undergoing continuous improvement and upgrade to improve quality,

environmental and biosecurity management. Examples of recent improvements include:

Rearranging the process flow with building modifications to enable;

o better containment of raw fish areas and confinement of areas draining to

tradewaste and sewer;

o Prevention of the cross movement of raw and finished product;

Purchase and installation of low noise air compressor; and

Provision of bunded containment facilities around wastewater tanks and bulk chemical

storage areas.

George Town Seafoods have been issued with a current planning (DA 2015/18), building and

plumbing permit (2015/27) to undertake the following amendments to the existing process

building and setup:

Upgrade and relining of processing rooms to achieve improved segregation,

temperature control and hygiene and allow for fitting and installation of new automated

gutting equipment.

Installing automated salmon processing equipment

Upgrading the salmon tipping station prior to automated processing.

Constructing a roof over the northern unloading and dewatering station area to prevent

rainwater entering the Tradewaste system.

The site operates under the following licences, permits and plans:

EPN 7489-1 Fish Processing

EPN 8836-1 Fish Processing Waste Disposal

Biosecurity Animal Health Act 1995 Permit MH 15-03

AQIS Approved Arrangements REG. EST. NO. 5485

Approval is now being sought for an increase in production capacity from 5,000 tonnes seafood

product produced per year to 10,000 tonnes product produced per year (the focus of this

application).


3. Part B – Project Description 3.1 Description of Project

3.1.1 Overview

George Town Seafoods are proposing to increase their licenced production capacity from 5,000

tonnes seafood product produced per year to 10,000 tonnes product produced per year. This

proposal relates to the increased production of salmon head on and gutted (HOG) product only.

The proposal does not include any building or site modifications. Table 3-1 below shows the

proposed breakdown of annual raw materials and product expected from the proposed

increased production capacity. The increased capacity will be achieved solely through

increased quantities of farmed Atlantic Salmon (“salmon”). The quantities of other seafood

(“wildfish”) are expected to remain similar to existing quantities processed.

This proposal relates solely to the receival, processing and waste management of salmon on

site at George Town Seafoods facility and does not include production at the fish farm.

Table 3-1 Existing and Proposed George Town Seafoods Fish Processing Quantities

Existing Annual Quantities (taken

from June 2014 – May 2015)

Proposed Annual Quantities

(Jan 2016 –Dec 2017)

Raw Material

(tonnes)

Product (tonnes) Raw Material

(tonnes)

Product (tonnes)

Farmed Atlantic

salmon

6,130 5,394 11,136 9,800

Wild Fish (other

seafood)

324 167 385 200

Total 6,450 5,561 11,521 10,000

3.1.2 Timeframe

George Town Seafoods are seeking to increase production immediately following environmental

and planning approvals, in order to take advantage of peak production periods over months

January – May 2016. An existing planning, building and plumbing permit has already been

issued to George Town Seafoods to allow for the required building modifications which are

currently in the process of being implemented. New equipment proposed for use has been

purchased by George Town Seafoods and is currently being installed. Installation and

commissioning of the new equipment does not depend on the outcomes of this EER for

increased production quantities and is likely to occur prior to December 2015 for use in the

2015/2016 salmon processing season (regardless of the outcomes of this application).

All production on the new equipment will be limited by the requirements of the existing EPN

licence limits, or any interim EPA approvals until necessary approvals for the increased

production quantities are obtained. That is, production quantities will be limited to those in line

with previous years until such time as approval for the higher production quantities are obtained.


3.1.3 Operating Hours

The proposed production increase will be met within the existing operating hours 5 am - 5.30

pm Monday to Friday and 5 am to 5 pm Saturday and Sunday. The processing facility will

operate 12 months of the year for wild fish production (as per current conditions), whilst salmon

will be processed for approximately 6-7 months of the year (also similar to current). As

observed from Figure 3-1, the proposed seasonal production trends will result in 5-6 months of

the year where minimal quantities of fish (wild fish only) are processed through the facility. The

increased salmon production quantities will be met by running more consistent production days

for 7 days a week with higher output, rather than shorter and variable production days

experienced in previous years.

3.1.4 Seasonal Volumes

Farmed salmon is currently processed in months October through to May, while wild fish is

processed all year round. Peak processing periods for salmon are typically between the months

of February and April and these peak seasonal trends are expected to continue following the

proposed increased salmon production. Figure 3-1 below shows the observed trend of salmon

production volumes in the June 2014- May 2015 season (“existing farmed salmon”) and the

expected trend in salmon production volumes following the increased production (“proposed

farmed salmon”). As illustrated the majority of salmon will continue to be processed over a 3-4

month period starting in late January.

Figure 3-1 Current and Proposed Seasonal Production Trend (tonnes)

3.1.5 Process and Equipment

The increase in salmon production capacity will be primarily achieved by operating automated

equipment for gutting and grading. As described in Section 3.1.2, new automated equipment

proposed for use has already been purchased by George Town Seafoods and is currently being

installed (under approval from Georgetown Council). Commissioning of the new equipment

does not depend on the approval of increased production quantities (as it will be used for

existing production levels regardless of the proposed production increase) and is likely to occur

in October and November 2015. The new equipment currently being installed includes:

Two automatic “Baader” gutting machines;

One automatic-manual gutting station;

One grading and weighing machine;


Conveyors between receival, gutting and grading machines;

Two new vacuum pumps installed on the roof above the wastewater treatment area;

and

Additional chemical dosing station for fish guts received off two Badder gutting

machines.

All other processing equipment and services (e.g. compressed air, refrigeration, water, chemical

and waste storage facilities) will remain as per the current operations. There are no proposed

changes to the wild fish production processes.

The process that will apply to the proposed increased salmon production is shown in Figure 3-2

and described below. A site layout (Figure 3-4) showing the key process activity areas is

provided in Section 3.3.

Figure 3-2 Proposed Salmon (Hog) Process Flow

Receival There are no proposed changes to the raw material receival processes. The method of salmon

receival will be as per the current unloading arrangements. Volumes of materials received by

the site and frequency of turnover will increase as shown in Table 3-1 (fish raw material), Table

3-2 (chemicals, wastes and water) and described in Section 3.1.6. Salmon processed from the

months of October to December are currently and will continue to be received in 1000 L bins.

There is no proposed change in quantities during these months. The proposed increased

quantities are expected to be received between months of January and April. The additional

raw salmon between January and April are expected to be delivered entirely in bulk tankers.

Raw salmon received on site via bulk tankers will be unloaded in the existing designated

unloading Transvac Station at the north east corner of the factory (refer Figure 3-4). Raw

1. Receival

2. De‐watering and Initial Storage

3. infeed

4. Gutting

5. Grading

6. Packing

7. Storage

8. Dispatch


salmon received in 1000 L insulated bins with chilled water and ice will continue to be received

at the loading bay at the south end of the factory and moved to the northern end of the factory

for interim storage and processing (refer Figure 3-4).

Chemicals are received in loading bay at the northern end of the site. Unloading of packaging

and other dry goods will continue to occur at the southern loading/unloading zone adjacent to

Thompson Avenue. Dry goods are stored in designated areas within the building as per the

conditions of the Approved Arrangements (George Town Seafoods 19/05/2015), so as to

prevent cross contamination of food products.

De-Watering & Initial Storage

The whole fish from tankers will be de-watered during the unloading process by pumping fish

from the Transvac station to the dewatering station (refer Figure 3-4). Ice water and any blood

drained from the whole fish is directed to the tradewaste system. Salmon will be placed in 1000

L insulated bins with fresh chilled water (dosed with chlorine dioxide) and ice. The salmon will

be kept at a temperature of 0-2 degrees Celsius ready for processing the same day. The

drained blood water from the dewatering station, comprised of blood, salt water and iced water,

will be dosed with sodium hypochlorite in accordance with the site’s current Approved

Biosecurity Management Plan (Appendix A). The blood water will be stored in a 28 kL blood

water tank adjacent to the bulk tanker unloading area, prior to being transferred to the

wastewater tanks and discharged through the tradewaste system.

The de-watering and initial storage process described for bulk transport received salmon will not

change from the current operations. The process area however is being progressively

upgraded as part of the recently issued building permit. The de-watering process area is

currently uncovered and drains to tradewaste, whilst the building upgrades provide for covering

the dewatering and initial storage areas (Figure 3-4).

Process Infeed

Following dewatering, all salmon in the 1000 L insulated bins will be loaded onto a covered

tipping station which will empty the salmon onto a speed controlled infeed belt. Any liquid from

the tipping station will drain to the sites tradewaste system. This tipping station has been

recently upgraded.

Gutting From the infeed conveyor belt the salmon will be processed through one of two automatic

Baader machines which guts and cleans the salmon. Fish not able to be processed through the

Baader machines will be manually gutted in an automatic-manual gutting station. The viscera

(gut) which is removed either by the machines or manually will be sucked or pumped into the

existing 32 kL holding tank. This holding tank is stainless steel and jacketed.

The viscera will be pumped into the 32 kL tank and stored. From the fish viscera storage tank

the waste will be sucked into a tanker which is transported to Triabunna for processing at a

licenced fish waste facility into downstream products. The proposed disposal of fish viscera

follows the same process as the current operations. Volumes of fish viscera waste will increase

however the frequency of collection is expected to be once every 1-2 days compared to the

current frequency of once every 2-3 days during the salmon processing season. Aside from an

increase in frequency all other aspects of the waste collection and disposal will remain

unchanged.


Grading

Salmon will be graded in quality and weighed with an automatic weighing machine. Based on

the grading, salmon are sent to the appropriate packing line, either premium whole fish or fish

for further processing off-site.

Packing, Chilling and Freezing

Processed premium whole salmon (HOG) will be placed into polystyrene eskies which will be

shipped out the same day. All other salmon (HOG) will be placed into either AFC’s (Austral

Folding Containers) transported interstate or 1000 L insulated bins which will travel via truck to

Margate or Huonville for value add processing (filleting etc.). All containers will include either

ice (AFCs) or ice water (insulated bins) and will be kept refrigerated in cool rooms shown in

Figure 3-4 until departure.

Dispatch

Goods will be removed from storage, and will then be placed into transport vehicles for dispatch.

Product in bins will be dispatched via the southern loading/unloading zone adjacent to

Thompson Avenue. Premium whole fish in eskies will be loaded directly off the processing line

to transport vehicles in the northern loading bay. Quantities for dispatch will increase but the

dispatch process remains unchanged.

3.1.6 Chemicals, Water and Waste

Quantities of water, chemicals used and wastes from the proposed production increase

compared to the existing operation are provided below in Table 3-2. Two types of liquid wastes

will be produced from the increased salmon production 1) Tradewaste containing blood water

and cleaning water and 2) Fish Viscera Waste. Volumes of fish viscera waste are expected to

increase in proportion with the proposed production quantities (x 1.8), whilst the volume of

tradewaste is estimated to increase by approximately 1.3 x the existing volume during salmon

processing. The current processing facility produces a third type of waste (liquid fertiliser) from

the processing of all wild fish waste. Quantities of liquid fertiliser waste are expected to remain

similar to current as this waste stream is generated during the production of wild fish only (which

is not proposed for increase).

Other solid waste general waste (packaging etc.) will be disposed of via secure landfill as per

the current operations, in accordance with the Approved Arrangements (George Town Seafoods

19/05/2015) and the Approved Biosecurity Management Plan (Tassal Nov 2015).

Water use at the site is largely driven by the use of fresh water to produce ice and ice water

which is used in interim storage of fish and also used during packing prior to dispatch. It is

estimated that approximately 50% of the site’s water use ends up being dispatch out with

finished product. The rest of the water used is for cleaning of tankers, bins and processing

equipment as well as in the on-site shop and amenities. Approximately 45% of the current

incoming water is estimated as ending up as tradewaste.

Table 3-2 Water, Chemical and Liquid Waste Estimated Volumes

Volumes Existing per year Volumes proposed per year

Water use* 14,220 kL 19,170 kL

Blood water** 2,034 kL 2,596 kL

Chemicals (sodium

hypochlorite, sanitiser, CIP,

42.9 kL 67.3 kL


Volumes Existing per year Volumes proposed per year

Topax) ***

Liquid Waste 1. Tradewaste ^ 8,470 kL 11,290 kL

Liquid Waste 2. Fish Viscera

Waste ^^

1,400 kL 2,520 kL

Liquid Waste 3. Liquid

Fertiliser^^^

37.6 kL 37.6 kL (no change)

Solid Waste (general) 15 m3 collected 1-2 x per

week

15 m3 collected 1-2 x per

week

* Existing water use is based on billed water use quantities October 2014 – Sept 2015.

Proposed water use is estimated based on 1.5 x existing water use, during salmon processing

season.

**Existing blood water quantities are based on average percentages of salt water (29%) and ice

(8%) in a typical salmon delivery tanker. Proposed quantities are based on 18% salt water and

8% ice in a typical salmon delivery tanker.

*** Existing chemical volumes based on 12 months purchase records. Proposed volumes

estimated based on 1.5 x existing quantities.

^ Existing tradewaste volume estimated broadly based on 45% of current water use, 100%

chemical use quantities and typical blood water volumes. Proposed tradewaste volumes are

based on the 45% of the proposed water volume, and proposed chemical and blood water

volumes as described above.

^^ Fish viscera waste quantities are based on 20 kL every 3 days of production for 7 months of

the year, assumes 210 days of production per year. Proposed volumes estimated based on 20

kL every 1-2 days during the salmon processing months.

^^^ Existing liquid fertiliser quantities for 12 month period September 2014 – August 2015.

Proposed quantities are the same as current as this is not impacted by salmon production.


3.2 Project Area

The project area occupies 4327 m2 at 38 - 44 Franklin St, Georgetown. Key information relating

to the project area is summarised in Table 3-3 below.

Table 3-3 Project area information (ListMap accessed 07/09/15)

Street Addresses 38-44 Franklin Street, George Town, TAS 7253

Approximate Grid Coordinates 486188E, 5448726N

General Description of site

The current site occupies 4327 m2 of Lot 1 on Plan 251964 (38-44 Franklin St, George Town). The site is located adjacent to other light industrial sites and is across the road from the South George Town Primary School (approximately 50 m). The nearest residential property is approximately 140 m away. There is vegetation around the boundary of the school (dry eucalypt forest and woodland) and to the north of the facility itself (classed as agricultural, urban and exotic vegetation). The nearest watercourse (York Creek) is over 500 m away and the Tamar Estuary is over 750 m away.

Title Identifiers Title Reference PID

251694/1 6438126

Owner Doumouras Investments Pty Ltd (proponent parent company)

Local Government Area George Town Council

Current and Historic Land Use Fish Processing Facility (historical use unknown)

Future Land Use Light industrial

Land Use Zoning George Town Interim Planning Scheme 2013 - Light Industrial (Zone 24)

Surrounding Land Uses

The immediate area to the north, east and south of the site is zoned light industrial (zone 24) and comprises commercial and light industrial premises. This area includes a commercial garden centre to west of Franklin St. The area immediately to the west is zoned residential (Zone 10) and includes the South George Town Primary School (approximately 50 m). The nearest residential properties are located mostly north of Victoria St (140 m) with some lower density residential properties close to Edgar St (400 m). There are some small areas zoned Open Space (Zone 19) located approximately 200 m to the north of the site.

Geology and Soil

The site sits on tertiary sediments from the Cenozoic era. Soil type is classed as Dalrymple association (Soils developed from Pleistocene littoral sands on gently undulating sand plains).

3.3 Map and Site Plan

© 2015. While GHD has taken care to ensure the accuracy of this product, GHD make no representations or warranties about its accuracy, completeness or suitability for any purpose. GHD cannot accept liability of any kind (whether in contract, tort or otherwise) for any expenses, losses, damages and/or costs(including indirect or consequential damage) which are or may be incurred as a result of the product being inaccurate, incomplete or unsuitable in any way and for any reason.

GHD\Launceston\32\2217760_LTN_01.cdr

Figure 3-3

Job Number

Revision A

32-17760

6 Oct 2015Date

GEORGE TOWN SEAFOODSEER PRODUCTION INCREASE

SITE LOCATION

21 Paterson Street Launceston 7250 61 3 6332 5500 61 3 6332 5555 [email protected] www.ghd.comT F E W

NLEGEND

General residential

Open space

Light industrial

Community purpose

Waterway

Paper size A4

0 100 200

Scale (metres)

PrimarySchoolPrimarySchool

LIGHT INDUSTRIALLIGHT INDUSTRIAL

NEAREST

RESIDENTS

NEAREST

RESIDENTS

CommercialGarden Centre

CommercialGarden Centre

SITE

LOCATION

GEORGE TOWNGEORGE TOWN

Tamar EstuaryTamar Estuary

York CreekYork Creek

© 2015. While GHD has taken care to ensure the accuracy of this product, GHD make no representations or warranties about its accuracy, completeness or suitability for any purpose. GHD cannot accept liability of any kind (whether in contract, tort or otherwise) for any expenses, losses, damagesand/or costs (including indirect or consequential damage) which are or may be incurred as a result of the product being inaccurate, incomplete or unsuitable in any way and for any reason.

GHD\Launceston\32\2217760_LTN_02.cdr

Figure 3-4

Job Number

Revision A

32-17760

6 Oct 2015Date

GEORGE TOWN SEAFOODSEER PRODUCTION INCREASE

SITE LAYOUT

21 Paterson Street Launceston 7250 61 3 6332 5500 61 3 6332 5555 [email protected] www.ghd.comT F E W

NLEGEND

Salmon Processing Area

Loading/unloading

Chemical storage

Waste storage

Wild fish

processing

area

Wild fish

processing

area

Tipping stationTipping station

Unloading of 1KL bins

finished product load out

Unloading of 1KL bins

finished product load out

Bulk tanker unloading bayBulk tanker unloading bay

Dewatering

station

Dewatering

station

Fin

ish

ed

pro

du

ct

load

ou

t

an

d c

hem

ical receiv

al

Fin

ish

ed

pro

du

ct

load

ou

t

an

d c

hem

ical receiv

al

Sodium hypochlorite

dosing

Sodium hypochlorite

dosing

CIP waterCIP water

Chemical dosing

for fresh water

treatment

Chemical dosing

for fresh water

treatment

Fresh water storageFresh water storage

Refrigerated waterRefrigerated water

Temporary

chemical

storage area

Temporary

chemical

storage area

Chemical dosingChemical dosing

Blood water

storage

Blood water

storage

Fish viscera

storage

Fish viscera

storage

Liquid fertiliserLiquid fertiliser

Trade waste

batching and

storage

Trade waste

batching and

storage

Blood waterBlood water

Liquid fertiliserLiquid fertiliser

Salmon processing

and storage

Salmon processing

and storage


3.4 Rational and Alternatives

The processing of farmed salmon at George Town Seafoods has previously been a manual

process. This manual process has limited the processing capacity of the operation. George

Town Seafoods have recently been issued with a planning and building permit from the George

Town Council to allow for a number of upgrades to the existing processing facility which will

provide the ability to process larger quantities of farmed salmon (development application

2015/18 approval issued 17/04/2015). The upgrades in particular allow for greater levels of

automation during the receival, gutting and grading processes.

The proposed increased production capacity addressed in this EER will result in an increase in

the people employed at the site. The increased salmon quantities will utilise the recent

upgrades to the facility and will therefore be produced with improved levels of hygiene,

biosecurity management and environmental control compared to past salmon production.

Due to the suitable location, space, services, and proven acceptable operation of the existing

site, no alternative sites for increased production capacity were relevant for consideration in this

proposal.


4. Part C – Potential Environmental Effects 4.1 Flora and Fauna

The current site is fully cleared and free of vegetation. This site consists of concreted hardstand

areas, gravelled driveway and buildings.

As the project does not propose an expansion of the footprint of the current processing facility,

there will be no direct clearance or disturbance of any native vegetation or habitat areas

required.

The proposal does not involve any impacts to flora and fauna values of the site.

4.2 Rivers Creeks, Wetlands and Estuaries

4.2.1 Potential Impacts

As outlined in the EER guidelines, the project will not result in:

Stormwater draining to a river, creek, wetland or estuary;

Filling or excavating a river, creek, wetland or estuary;

Impounding a river, creek, wetland or estuary;

Works within within 200 m of a river, creek, wetland or estuary; or

Clearing of vegetation within 200 m of a river, creek, wetland or estuary.

Stormwater will be managed as per existing sites stormwater drainage system as the site

outdoor infrastructure will not change as a result of the Project. The parts of the facility that are

connected to stormwater runoff drains include downpipes from the building roof areas,

driveways and carpark areas.

Key areas within the site that have potential to leak or spill materials have drains installed to

capture runoff directly to the site’s tradewaste system or sewer (refer to Appendix B for further

information about existing containment areas). Therefore no direct impacts to rivers, creeks,

wetlands or estuaries are likely to occur as a result of the normal operation from the project due

to the drainage systems on site established to collect all contaminated runoff and liquids.

During abnormal conditions, spills of materials in the vicinity of site stormwater drains could

occur. The following two abnormal conditions or equipment failures have been considered for

potential impacts on stormwater.

Power failure

In the event of a power failure all processing will cease. Valves will default to closed positions

(e.g. pumping fish from tanker to dewatering station or pumping of tradewaste). All powered

processing areas are located within areas draining to the tradewaste, valves default to close

and no wastewater will be generated during the outage. Therefore there is no increased risk of

uncontrolled discharge to stormwater during a power outage. All salmon in mid process will be

removed and held in refrigerated storage. Depending on the length of the power outage – some

quantities of salmon may need to be disposed. This would be undertaken in accordance with

the sites biosecurity management plan (Appendix A) and is discussed in Section 0.


Spills outside bunded areas

The current 28 kL blood water storage tank located adjacent to the bulk tanker and tradewaste

tanks in the wastewater area are located in a tradewaste drainage catchment. In the event of

small-moderate leaks from the tanks or pipework, drainage would be captured by the

tradewaste drainage. In the case of the blood water tank a small to medium spill may fall into

the tanker unloading bay pit which can contain up to 3000 L and directs all liquids to the

tradewaste system. In the event of a significantly larger leak from these tanks e.g. due to tank

rupture, it is possible for blood water or tradewaste to spill out onto the adjacent northern

stormwater drainage area. However the likelihood of a major tank rupture is considered

extremely rare and will not change with the proposed increased production. The existing

pumping stations are protected with bollards to prevent damage from on-site vehicle movement.

Similarly the current storages of fresh water, refrigerated water and CIP water along the eastern

end of containment area 2, although slope towards the tradewaste system do not have a bund

to contain significant leaks spilling out the eastern side. Small to medium leaks and spills

would be contained. The contents are fresh water and even in the result of tank rupture would

not result in any significant environmental impact. There is no traffic movement around these

tanks and regular inspections means that the risk of spills to stormwater from this area does not

increase with the proposed production.

4.2.2 Mitigation Strategies

Power Failure

No additional controls are proposed to mitigate risks to stormwater from power failure. The

existing drainage system and processes are regarded as sufficient to mitigate any impacts on

stormwater.

Spills out side bunded areas

George Town Seafoods plan to seal the northern driveway and install stormwater drainage

points in future (prior to the 2016/2017 salmon processing season). This will enable improved

control in the event of a spill in this area by isolating the stormwater drainage points with drain

covers to prevent any spill leaving the site.

Commitment 1 Implement plan to seal the northern driveway and install stormwater drainage points in future.

4.3 Significant Areas

The project is not located within or adjacent to an existing reserved area and no impacts to any

such areas are expected.

4.4 Coastal Zone

The project is approximately 750 m from the coast of the Tamar Estuary and there are no

impacts to coastal areas anticipated as a result of the project.

4.5 Marine Areas

As the project is restricted to an onshore location there will be no direct impact on sensitive

marine areas, conservation areas, or areas used extensively for recreational or commercial

fishing activities.


The proposed project does not relate to fishing activities and only includes increased processing

capacity on shore. This application involves increased processing only and excludes any

consideration of increased salmon production at fish farm sites.

4.6 Air Emissions


Odour

Areas on the site that may be sources of odour include:

the bulk tanker unloading area;

salmon processing areas; and

the waste storage and processing areas.

The site is located within a light industrial zone. The nearest resident is approximately 140 m to

the north west. The South George Town Primary School property is located opposite the site to

the west approximately 50 m from the George Town Seafoods boundary and 80 m from the

processing area. A commercial garden centre is located in the light industrial zone

approximately 100 m to the north west (refer Figure 3-3). Prevailing wind direction is from the

west, away from the school and general direction of residents (Low Head wind speed and

direction 1998 – 2010 accessed from BOM 09/09/2015).

Owing to the existing facility dealing with fresh produce and waste only remaining onsite for

short periods, odour impacts offsite have not historically been an issue for the facility.

The increased number of salmon bulk truck deliveries in the salmon processing season from 2-3

per day to 4 per day will result in more frequent washing of tankers in the unloading area.

Consistent with the existing operation, due to the frequency of cleaning and the adherence to

the Approved Biosecurity Management Plan there is no additional risk of odours from this area.

Similarly, strict hygiene and disinfection requirements within the salmon processing area,

mitigates the risk of odour.

The most odorous area of the current operation is the liquid fertiliser waste processing area

(refer to Figure 3-4 for location). The liquid fertiliser waste processing facility is not impacted by

the proposed increases of salmon for processing as all wastewater during salmon processing

by-passes the liquid fertiliser plant for discharge to tradewaste. The liquid fertiliser waste

processing facility is influenced only by wildfish volumes, which are not affected by this

proposal.

All wastes generated from the proposed increased production will continue to be managed

strictly in accordance with George Town Seafoods Approved Arrangements for export

(GeorgeTown Seafoods 2015) and the George Town Seafoods Approved Biosecurity

Management Plan (Appendix A) to prevent cross contamination, quality and odour issues. The

requirements of the biosecurity plan and approved arrangements (e.g. disinfection regular

removal, controlled transport and disposal) mitigate any build-up of wastes or storage in

condition that generate odour.

The frequency of waste collection from the site following the proposed production will actually

increase therefore mitigating any risk of odours (refer Section 4.7 and Section 0 for further detail

on waste generation and removal).

In the event of power failure, the processing ceases to operate. All salvageable fish will be

moved to a cool store area until the power is restored. All liquid wastes stored on site will be


removed daily or once every 1-2 days in the case of fish viscera. Waste holding tanks are

cleaned and disinfected when emptied to minimise the build-up of waste and potential for odour.

The process for disposal of any solid waste from a power failure is described in Section 0.

It is expected the potential for odour issues from the project will remain low, consistent with the

existing process, or may in-fact be lessened due to the increased frequency of cleaning and

waste pickups.

Dust

The unloading area to the North of the processing facility is accessed currently by a gravel

driveway from the Franklin St. There have been no prior issues in regards to dust in this area.

Traffic in this area will increase by up to five vehicles per day (refer Section 4.10 for further

information on proposed traffic changes).

Although the vehicle movements on the northern delivery driveway are expected to increase (by

approximately 4-5 vehicles per day), the speed of vehicle movement is restricted and there is

not expected to be any notable impact from dust due to the slightly increased activity.


Odour

Odours from processing areas are minimal and will continue to be frequently cleaned in

accordance with the facilities Approved Biosecurity Management Plan, Approved Arrangements

and Good Manufacturing Practice. This includes the regular removal of all wastes and cleaning

and disinfection of waste bins and tanks.

A complaint register will be maintained at site and odour or dust complaints dealt with

accordingly in line with EPA recommendations.

During abnormal conditions or power outage all wastes will continue to be managed in

accordance with site’s Approved Biosecurity Management Plan (Appendix A).

Dust

As part of the continued improvements on the site, George Town Seafoods have future plans to

seal the Northern driveway which will eliminate the risk of dust on site altogether. This action is

planned to occur prior to the second season of increased production (2016/2017).

Commitment 2 A complaint register will be maintained at site and odour, dust and noise complaints dealt with accordingly in line with EPA recommendations

4.7 Liquid Effluent

4.7.1 Proposed Conditions

The facility produces three liquid waste streams:

1. Tradewaste discharged under licence to TasWater;

2. Salmon viscera (guts) transported to Triabunna; and

3. Liquid fertiliser produced from wildfish wastes

Of these waste streams only the first two will be affected by the proposed production increase

as the third (liquid fertiliser) uses only wildfsh wastes which are not proposed for increase.


A comparison of existing compared to proposed liquid waste volumes is provided in Section

3.1.6 in Table 3-2.

Tradewaste

Additional tradewaste from the salmon processing wash water will be generated and discharged

to TasWater George Town Sewage Treatment Plant (STP) under a tradewaste agreement with

TasWater. All tradewaste from the increased production will be managed by the site’s current

tradewaste management system. This includes preliminary screening on drainage points prior

to batch dosing with sodium hypochlorite and storage in bulk tradewaste tanks.

The current tradewaste is discharged under an existing (transitional) agreement D13/101 with

TasWater (issued 30 September 2015). This interim agreement includes a maximum daily

discharge of 90kL/day and specifies maximum flow rates from 8am – 4pm of 1L/s during

operating hours and up to 2L/s from 4 pm to 8 am.

All potentially contaminated areas of the salmon processing area will be captured and drained

to the site’s tradewaste management system as per the existing site conditions (refer Appendix

B – Current Containment Areas). The drainage systems capture all blood water from the tanker

unloading area, all drainage from the Northern unloading area and all drainage from the

processing areas (i.e. cleaning water) and wastewater management areas. Blood water from

the 28 kL tank in the unloading area is transferred to the 56 kL blood water tank prior to

blending with other factory waste water in the tradewaste storage tanks.

The tradewaste system includes two 22.8 kL tanks and one 20 kL storage tank in a bunded

area. The two 22.8 kL tradewaste storage tanks are batch dosed with sodium hypochlorite to

ensure that all wastewater from salmon processing is treated to control odour and prevent

spread of pathogens off the site. An oxygen reduction potential (ORP)of 400 mv in accordance

with the Approved Biosecurity Management Plan (Appendix A) must be maintained for a

minimum of 30 minutes prior to discharge off site to the George Town Sewage Treatment Plant

(STP).

The total wastewater storage capacity of the site is 149 kL. This is includes 65 kL tradewaste

storage (2x 22.8 kL tanks and 1x 20 kL tank) and two blood water storage tanks (56 kL and 28

kL).

The proposed increased salmon processing capacity is expected to result in an increase of

approximately 2820 kL of tradewaste over the 6-7 months salmon processing season (Table

4-2). This equates to an average volume of 13 kL/day, but may be higher on peak days.

Historically there has not been routine monitoring of tradewaste volumes. Proposed tradewaste

volumes presented in this EER are based on extrapolations from existing metered water usage,

measured chemical use quantities and records of salt water and ice volumes in salmon received

into the facility (as presented in Table 4-2). The current tradewaste estimate is based on a sum

of measured volumes and can be regarded as reasonably accurate.

Volumes of tradewaste as a result of the proposed salmon production increase have been

conservatively estimated based on likely portions of blood water, expected chemical

consumption and expected water use. Assumptions for these estimations are provided with

Table 4-2.

As there has not been regular flow monitoring it is not possible to determine what the maximum

daily discharge rate has been. However based on records of daily water use during peak times

and the assumption that 55% of water used is used in ice or ice water dispatched with product

or used for shop and site amenities, the maximum current discharge rate is likely to be


approximately 55 kL/day1. The peak daily discharge during salmon processing months from the

proposed increase in salmon quantities is expected to increase and may be up to 80 kL/day

(Table 4-1 Likely Tradewaste Discharge Rates During Peak Salmon Production).

Table 4-1 Likely Tradewaste Discharge Rates During Peak Salmon Production

Volumes Likely maximum rates kL/day

- Current

Likely maximum rates kL/day

- Proposed

Tradewaste – peak 55 kL /day 80 kL/day

Tradewaste from the increased salmon production will not include fish viscera or solids from the

fish process operation. These sources of waste are segregated and managed separately (refer

section on Fish Viscera Waste below).

Table 4-2 Tradewaste and Component Volumes

Tradewaste Volumes Volumes Existing per year Volumes proposed per year

Water use* 14,220 kL 19,170 kL

Blood water (salt water, ice

and blood)**

2,034 kL 2,596 kL

Chemicals (sodium

hypochlorite, sanitiser, CIP,

Topax) ***

37.2 kL 55.8 kL

Total Tradewaste ^ 8,470 kL 11,290 kL

* existing water use is based on billed water use quantities October 2014 – Sept 2015. Proposed water

use is estimated base on 1.5 x existing water use quantities during 6-7 months salmon production.

** existing blood water quantities are based on average percentages of salt water (29%) and ice

(8%) in a typical salmon delivery tanker. Proposed quantities are based on 18% salt water and

8% ice in a typical salmon delivery tanker.

*** Existing chemical volumes based on 12 months purchase records. Proposed volumes estimated based

on 1.5 x existing quantities (i.e. increased in direct proportion to production quantities).

^ existing tradewaste volume estimated broadly based on 45% of current water use, 100%

chemical use quantities and typical blood water volumes. Proposed tradewaste volumes are

based on the 45% of the proposed water volume, and proposed chemical and blood water

volumes as described above.

Although tradewaste composition has not been routinely monitored, a series of analysis was

undertaken over 22 different production days between October 2014 and April 2015. The

average results from this analysis shown in Table 4-3 below show that the wastewater is within

the short term tradewaste limits established for the site. Results from the 2014-2015 analysis

show that sodium, BOD/COD and nitrogen concentrations of the wastewater exceed the

1 The average daily water use from February 2015 – April 2015 was 80 kL/day, peaks are

estimated at maximum 55 kL/day.


possible TasWater long term limits. Long term limits however have not been finalised and will

be confirmed by TasWater following further analysis of Tradewaste from the 2015/2016 salmon

processing season.

Comparative calculations on sources of sodium (Table 4-4) reveal that the overwhelming source

of sodium in wastewater is likely to be and will continue to be from salt water received with

salmon product due to the volumes involved. The concentration of sodium calculated from

existing inputs (2158 mg/L from Table 4-4) was slightly more than the average actual tested

concentrations from production between October 2014 and April 2015 (1583 mg/L from Table

4-3). The calculated proposed sodium level from inputs should therefore represent a

conservative estimate of sodium concentrations.

The typical quantity of salt water (L) per kg of salmon received is currently 0.29 L/kg (29%).

This is expected to reduce to 18% with the increased salmon quantities processed due to larger

numbers of fish able to be included per bulk tank delivery. Due to the reduced portion of salt

water, the likely concentration of sodium in the wastewater will be lower, however the total

sodium loads are expected to increase from approximately 18.25 to 20.5 tonnes per year (Table

4-4).

Table 4-3 Existing Tradewaste Quality

Parameter

Unit Tradewaste Agreement long term limits

Tradewaste Agreement Short term

limits

Average GTS Tradewaste

Quality (n=22)

Temperature oC <38 <38 n/a

pH 6‐10 6‐10 7.70

BOD mg/ L TBA or 600 1500 756.5

COD mg/L TBA or 1500 6000 3561.9

Total Dissolved Solids (TDS)

mg/L <10,000 <10,000 8390 conductivity µs/cm

Total suspended solids (TSS)

mg/L TBA or 600 1500 446.7

Oil and Grease mg/L TBA or 200 400 126.0

Total Nitrogen mg/L TBA or 200 320 212.0

Total Kjeldahl Nitrogen (TKN)

mg/L TBA or 150 320 211.7

Ammonia mg/L 100 100 6.5

Total Phosphorus mg/L 50 50 15.7

Sulphate mg/L 1500 1500 309.6

Sulphite mg/L 15 15 4.75

Thiosulphate mg/L 300 300 15.2

Sulphide mg/L 1 1 0.26

Cyanide mg/L 1 1 0.06

Sodium mg/L 200 2500 1583

Bold denotes exceedance of the proposed long term tradewaste limits in the transitional TW

agreement.


Table 4-4 Sources of Sodium in Tradewaste

Sodium Sources Annual volume Annual sodium loads

(tonnes)

Resultant

concentration in

tradewaste during

salmon processing

mg/L

Existing

Salt Water (incoming)

10,800 mg/L Na

1576 kL 17.0 2010 mg/L

10% Sodium

Hypochlorite (NaClO)

solution contains

37,000 mg/L Na

33.7 1.25 148 mg/L

Total 18.25 2158 mg/L

Proposed

Salt Water (incoming)

10,800 mg/L Na

2450 kL 19.0 1687 mg/L

10% Sodium

Hypochlorite (NaClO)

solution contains

37,000 mg/L Na

50.1 kL 1.5 133 mg/L

Total 20.5 1820 mg/L

Fish Viscera Waste

Fish viscera (guts) removed during the processing will be pumped and stored in a covered 28

kL tank as per existing processing conditions. The viscera waste will be stored in the tank prior

to collection via licensed transport to Triabunna in Tasmania for further processing. The

management of this waste source is conducted in compliance with George Town Seafoods EPN

8836/1 and the Approved Biosecurity Management Plan (Appendix A). Any solid waste from

the processing area floor or floor drains will be passed through the manual fish gutting station

for dosing and storage as per fish viscera waste.

The existing fish viscera waste 28 kL storage tank will be sufficient to store at least two days of

waste generated during the peak production time. The expected frequency of viscera waste

collection will therefore increase from once every 2-3 days (current peak production) to once

every 1-2 days (proposed peak production). The current designated transport vehicle can

continue to be used to transport the waste between George Town and Triabunna. As required

in the Approved Biosecurity Management Plan, all waste handling tanks and transport vessels

will be cleaned and sanitised prior to being used again. This is consistent with existing

operations.



Tradewaste Volume

Based on the estimates made in this report, the tradewaste volume during the proposed salmon

peak processing periods is expected to remain within the maximum daily discharge limit of 90

kl/day specified in the existing TasWater Tradewaste Agreement. The estimated peak daily

discharge during salmon processing months based on Tradewaste volumes provided in Table

4-2 may increase to approximately 80 kL/day which is well within the maximum daily discharge

limit.

The proposed daily tradewaste volume is well within the storage and processing capacity of the

existing site (149 kL) and can be fully discharged each day whilst remaining within the maximum

discharge rate in the TW agreement of 1L/s during the day and 2L/s during the night.

Sodium and TDS

The sources of salt water and sodium hypochlorite will increase over the peak salmon

production process period (Table 4-4). Although the relative percentage of salt water per kg fish

received will decrease and concentrations of sodium in wastewater are likely to decrease, the

total annual load of sodium in tradewaste is expected to increase by approximately 14% (Table

4-4). As the Tradewaste is discharged to TasWater’s system via controlled batches, the sodium

concentrations and loads are not expected to vary greatly throughout the day. The seasonable

variability in sodium concentrations is expected to be very similar to what has been received

and accepted by TasWater in the past. The overall 14% increase in load will be due to higher

volumes of slightly lower concentrations during a peak 3 month period.

Nitrogen/BOD/COD

As a result of increased production it is possible that the concentration of blood and therefore

nitrogen and BOD/COD in the trade waste discharge may increase compared to the previous

average analysis (due to greater numbers of fish received per bulk tanker). TasWater have

indicated to George Town Seafoods that organic loading to the George Town STP is generally

received well as it helps balance other inorganic Tradewaste loads from the municipality. The

additional concentrations and/or loads are expected to follow similar trends to previous

Tradewaste accepted by TasWater and are not likely to cause a notable impact compared to the

current operation.

Spills to Trade Waste

Spills of liquid waste to the tradewaste area from the processing area or storage tanks are

unlikely to occur and the risk of spills should not increase with increased production quantities.

The existing bund containment capacity in the waste storage area is regarded as sufficient to

contain large volumes of process or wastewater (description of containment areas provided in

Appendix B. The existing storage capacity of the tradewaste system is 149 kL. This allows for

ample volume to store any spills to the bunded tradewaste drainage area and allow for

controlled discharge to the tradewaste system.

Fish Viscera Waste

The existing storage tank for fish viscera is sufficient to hold two days of the processing

quantities during proposed peak production and the existing bund around the waste tanks is

regarded as sufficient to manage risk of spills. Back up transport and disposal (via deep burial

at Remount Rd Landfill) is available should the existing waste tanker or disposal become

unusable. Therefore there are no adverse environmental impacts expected as a result of the

increased production quantities of salmon viscera waste.


Biosecurity Risk from liquid waste handling

Potential impacts on biosecurity risks associated with liquid waste handling are discussed in

Section 4.11.


Tradewaste Volume

The automated salmon processing and bulk delivery, minimises the volumes of water required

for cleaning and processing. Therefore the increase in tradewaste volume will be minimised.

George Town Seafoods propose to maintain compliance with the maximum volume and

discharge rate requirements of their existing interim TasWater Agreement. The Tradewaste

Agreement includes a number of commitments in regards to improving the monitoring and

measurement of Tradewaste and a process to establish appropriate long term targets. This

includes the immediate installation of an in-line flow meter to continuously measure discharge

volumes.

Tradewaste Quality

George Town Seafoods will commit to undertake the required intensive monitoring program of

the salmon processing effluent in February 2016, as included in the Interim Agreement with

TasWater. The monitoring will be undertaken over 4 weeks and will include 3 daily composite

samples for each week. Parameters to be tested are currently being confirmed by TasWater

but are likely include pH, BOD/COD, TDS, TSS, nitrogen, Total Kjeldahl Nitrogen (TKN)

ammonia, sodium and sulphide. The results of this program will be used to determine

appropriate long term TW licence limits.

George Town Seafoods will undertake a regular monthly sampling program in compliance with

their tradewaste agreement with TasWater to confirm the key characteristics of the wastewater

and basis for TasWater charges to be calculated. This program is currently being determined by

George Town Seafoods and TasWater.

George Town Seafoods will continue to work with Tassal to reduce the volume of salt water

included in incoming salmon deliveries. A target maximum of 18% saltwater per bulk tanker will

result in at least a 16% reduction in sodium concentrations in final tradewaste volumes.

George Town Seafoods have recently identified opportunities to reduce the use of sodium

hypochlorite without compromising the biosecurity standards. This may result in further

reduction of TDS and sodium in the final effluent. The dosing and mixing of sodium

hypochlorite is currently manually operated and checked. Although not part of this project

George Town Seafoods have future plans to automate this process to further control the use of

chemicals.

Biosecurity Risk from liquid waste handling

Refer to Section 4.11.3.

Fish Waste

There are no proposed additional mitigation strategies for fish viscera waste as the existing controls are regarded as adequate. The following existing controls will be maintained:

All salmon fish gut and solid salmon waste is to be collected in the designated bunded

gut tank.

Regular daily or once every two day removal, cleaning and disinfection of fish viscera

waste tanks

Fish waste must only be transported off site using a registered and approved transporter.


The fish waste is only to be delivered to EPA and Chief Veterinary Officer approved sites

such asSeafish Triabunna.

Back-up disposal of deep burial at the Remount Rd Landfill may be implemented (in

accordance with the Approved Biosecurity Management Plan) if all other approved

methods are unavailable.

Spills to Trade Waste

Due to the proposed increased use of the pumps and valves, regular condition inspection of the

pipework, unions, valves and tanks will be undertaken and preventative maintenance checks on

all pumps and valves will be scheduled on an annual basis in order to reduce the risk of a major

pipework leak.

A spill register will be maintained and all spills will be investigated to ensure root causes and

preventative actions are identified.

There are no proposed additional mitigation strategies for spills to tradewaste as the existing controls are regarded as adequate.

Commitment 3 Undertake all monitoring programs and activities in compliance with TasWater Tradewaste Agreement

Commitment 4 Continue to work with Tassal to reduce the volume of salt water included in incoming bulk salmon deliveries.

Commitment 5 Regular condition inspection of the pipework, unions, valves and tanks will be undertaken and preventative maintenance checks on all pumps and valves will be scheduled on an annual basis.

Commitment 6 A spill register will be maintained and all spills will be investigated to ensure root causes and preventative actions are identified.

4.8 Solid Wastes


The types of solid wastes generated in the process will be similar to the existing operation.

Sources of solid wastes include consumable items used in the delivery and processing of

salmon (e.g bin liners, gloves, hand towel, packaging etc.) and solid fish waste screened at

tradewaste drainage points in the site.

All non-fish consumable items will continue to be disposed of as required under the existing

Movement (Biosecurity) Permit MH 15-03 and Biosecurity Management Plan (Appendix A).

Consumable items include but are not limited to:

Bin liners for ITR and HOG, labels and cable ties.

Consumable items soiled during product handling and packing.

Hygiene garments, gloves, paper towel, and associated items that have been in contact

with fish or associated with secondary contact.

All consumable wastes will be disposed of in a designated salmon waste bin supplied by an

approved contractor. Management and disposal of the salmon waste bins will be in accordance

with the Biosecurity Permit (MH 15-03) and the Approved Biosecurity Management Plan


Appendix A which requires use of bin liners and the requirement for all consumable wastes to

undergo deep burial at an EPA approved landfill Remount Road Landfill.

Any solid fish wastes (e.g. salmon waste from factory floor or drainage screens) will be minced

in the factory and added to the “gut” (fish viscera) tank. This will be undertaken at the manual

gutting station in the salmon processing area The waste salmon will then be managed in

accordance with fish viscera waste as described in Section 4.7.

The quantities of consumable items as solid waste are not expected to increase significantly.

This is because the proposed increase in salmon processing quantities will be delivered in the

form of bulk tanker deliveries only and therefore will not result in more bin liners for disposal.

The quantities of other consumables are not expected to increase significantly as the number of

processing days will not be increasing. The existing process controls and infrastructure are

regarded as sufficient to manage the increased quantities of solid wastes expected from the

increased production capacity and any association biosecurity risks.


The following existing waste management controls will be continued in accordance with the

Approved Biosecurity Management Plan:

Drains to the tradewaste and to the gut tank will continue to be cleaned daily to minimise

the likelihood of the presence of opportunistic vermin

Processing fish wastes will be placed in designated fish waste bins in the processing

factory.

Fish waste bins will be emptied daily, sanitised and reused.

All bins used for salmon and consumables associated with salmon from Macquarie

Harbour will be identified clearly and segregated from all other waste bins at the site.

All solid salmon wastes will be minced and added to the “gut” tank.

All consumable waste will be collected 1-2 times per week by a licenced waste

transporter and disposed of via secure landfill disposal.

Further detail on management of solid wastes for disposal is provided in the Approved

Biosecurity Management Plan (Appendix A).

4.9 Noise Emissions


Noise has not previously been a concern at the facility, given its industrial siting and distance to

nearest sensitive receptors (as shown in Figure 3-3) and the generally low noise emission levels

produced by the facility. The only previous potential source of nuisance noise has been limited

to the outdoor compressor for refrigeration and vacuum pumps. As identified in Section 4.6.1,

prevailing wind direction is from the west, away from the school and general direction of

residents (Low Head wind speed and direction 1998 – 2010 accessed from BOM 09/09/2015).

There are no new refrigeration compressors or noise generating plant and equipment proposed

as part of this production increase project. The project will result in increased use of recently

purchased and installed equipment.

The project will utilise additional fixed equipment (approved separately by Council) housed

within the existing facility that will emit noise at a similar level to that which is currently produced

within the facility. The new equipment in the processing area includes the two gutting machines


and automatic weighing/grading machine. Any noise emitted from this equipment is attenuated

by the processing building walls which have been recently replaced.

Two new 15 kW vacuum pumps are currently being installed on the roof above the waste

processing area (approved separately by Council). These vacuum pumps, required during

operation of the automatic gutting machines, are fitted with mufflers to minimise noise emissions

and are located in a position such that noise from the running of the pumps with prevailing

westerly winds is most likely to travel in a north easterly direction.

The facility will maintain its operational hours to a maximum of 5 am to 5:30 pm during

weekdays and 5:00 am to 5:00 pm on weekends during the peak salmon processing season.

There have been no noise complaints recorded under the previous processing regime and the

majority of new equipment will be housed within the existing facility. The additional use of

processing machinery located at the site is not anticipated to produce peak noise levels

significantly above current operating levels.


A complaint register will be maintained at site and noise complaints dealt with accordingly in line

with EPA recommendations.

All noise emitting equipment will be regularly maintained. The existing maintenance contract

with local refrigeration mechanics for the maintenance of the aforementioned compressor

system will remain in place.

Should noise complaints be received, additional noise controls e.g. silencers or buffers can be

applied.

4.10 Transport Impacts


The Project will result in an estimated additional two tankers delivering salmon to the site during

mornings and conversely up to two additional trucks collecting processed product in the

afternoons.

As described in Section 4.7.1 there will also be additional trucks from current operation to collect

fish viscera waste for delivery to third party recyclers (currently once every 2-3 days and will

become once a day with the proposed production increase).

There is likely to be a small increase in small vehicle movements from the site from employees

and minor deliveries.

All traffic will enter and leave the site using existing transport routes.

The potential impacts from an additional five truck movements and increased small vehicle

movements to the area in any one day are not considered to be significant in terms of impact on

local roadways.


A complaints register will be maintained on site for any transport related issues that arise from

the Project.

As described in Section 4.6.2, the continuous improvement plans for the site include sealing the

Northern driveway. This action will eliminate the need for further maintenance on the gravel

driveway. This action is planned to occur prior to the second season of increased production.


4.11 Other off site Impacts

4.11.1 Proposed Conditions

Fish originating from Macquarie Harbour on the west coast are known to carry Aeromonas

salmonicida and the Tasmanian aquabirna virus (pathogens), which are not found in south-east

Tasmanian waters. Therefore salmon product derived from Macquarie Harbour is required to

comply with biosecurity controls to prevent the spread of diseases present in the Macquarie

Harbour area to other locations in Tasmania.

Biosecurity risks associated with transport of salmon from Macquarie Harbour into the George

Town Seafoods processing facility are currently governed by a Movement (Biosecurity) Permit

MH 15-03 issued under the Animal Health Act 1995.

Under the existing biosecurity permit, GTS is approved to process salmon from Macquarie

Harbour into HOG and ship the product to the Tassal Margate and Huonville processing

facilities.

The movement (biosecurity) permit also allows GTS to discharge wastewater to the George

Town Sewage Treatment Plant (GTSTP) under strict disinfection conditions.

A copy of the permit conditions are provided in Appendix C.

George Town Seafoods has an Approved Biosecurity Management Plan provided in Appendix

A, which provides procedural controls and details on how the conditions of the Movement

(biosecurity) Permit will be achieved.


Additional sources of salmon received into the George Town Seafoods site have the potential to

impact on biosecurity should the existing controlled processes be insufficient for increased

volumes.

Impacts may occur with:

Movement of fish onto and off the site;

Disposal of plastic liners in transport containers;

Spread of diseases from movement of transport containers between regions; and

Disposal of blood, viscera and other waste.


Conditions for transport receival and processing of the increased salmon quantities at George

Town Seafoods will continue to be managed in accordance with the existing Movement

(biosecurity) Permit conditions (Appendix C) and the Approved George Town Seafoods

Biosecurity Management Plan (Appendix A).

A full description of the mitigation strategies is included in Approved George Town Seafoods

Biosecurity Management Plan (Appendix A). In summary, these include:

All unloading and loading of 1000 L bins containing salmon to and from transport vehicles

must be conducted on designated containment aprons in containment area 4 (refer

Appendix B).

All transport bins are to be cleaned and disinfected before being returned to areas used

for farming of fish.

All bulk tankers are cleaned and disinfected immediately after unloading prior to be

returned to areas used for farming of fish.


The harvest tanker trailer must not be used to transport fish from regions other than

Macquarie Harbour unless it has been demonstrated that it has undergone appropriate

decontamination.

Where drains are at significant risk of collecting and releasing potentially contaminated

fish related water or liquid to the environment, the drain must have control measures

(closed valves) to hold the liquid (as described in Biosecurity Management Plan).

The Southern bin receival and HOG dispatch apron is managed during use by a manual

check of the strip drain that collects spillage from the area and manual disinfection and

washdown prior to release of the treated water to sewer. As spillage is rare and

accidental it is managed on a case by case basis by the factory supervisor.

If a spill occurs then any spilt fish are to be placed in a bin and secured, along with

salmon fish waste. All water from the spill and the clean-up water must be directed to

drainage to the tradewaste system and all vehicles and the area involved are to be

thoroughly cleaned and sanitised.

Disinfection of spill areas and drains must be carried out to ensure live pathogens do not

leave the site.

Drains to the tradewaste and to the gut tank are cleaned daily to minimise the likelihood

of the presence of opportunistic vermin.

All solid salmon wastes are to be minced and added to the “gut” tank.

All consumable waste will be bagged and placed in secure bins collected 1-2 times per

week by a licenced waste transporter and disposed of via secure landfill disposal.

A record of chlorine treatments of wastewater and residual levels achieved prior to

discharge is to be retained.

Further description of the drainage controls and management of tradewaste was provided in

Sections 4.2 and Section 4.7.

Commitment 7 Comply with the existing Movement (biosecurity) permit conditions (Appendix C) and the Approved George Town Seafoods Biosecurity Management Plan (Appendix A) at all times

4.12 Hazardous substances and chemicals


The site uses the chemicals as listed below in Table 4-5 for both stabilising waste products and

cleaning and sanitising the process and equipment. All chemicals used in cleaning and

sanitation are disposed to the tradewaste stream. A comparison of the chemical volumes used

in the existing operation and those proposed during increased salmon production are shown in

Table 4-5.

Table 4-5 Annual Chemical Volumes*

Chemical Purpose Current Proposed

Cleaning and Sanitising

Sanimaxx Sanitising 2000 L 4000 L

Topax Cleaning 4000 L 8000 L

CIP cleaner Cleaning 3,200 L 4,800 L


Waste Stabilisation

Sodium hypochlorite XY-12

Treating blood water

33,700 L 50,500 L

Other

Lubes etc. Minor quantities Minor quantities

Gas (storage) 8-16 bottles 8-16 bottles

*volumes of chemical are sourced from 12 months purchase records from March 2014 to April

2015.

The blood water and tradewaste is treated with XY-12 (sodium hypochlorite). The XY-12 is

delivered in 205 L drums (4 to a pallet) and then moved and placed in bunded areas adjacent to

the tradewaste storage tank or adjacent to blood water storage tank for use.

CIP Cleaner is a detergent used to clean out the salmon delivery tankers and the Transvac

System. CIP cleaner is dosed into water from a 5 kL storage tank as shown on Figure 3-4.

Topax is an alkaline chlorine type cleaner used in process area for cleaning machinery also

supplied in 205 L drums. Sanimaxx is an alkaline cleaner used to sanitize the factory equipment

and is supplied in 205 L drums.

All 205 L drums are delivered and temporarily stored on the northern hardstand area, adjacent

to the dewatering station prior to moving to their point of use. As described in Section 4.2, this

hardstand area (containment area 2), drains to tradewaste.

The volume of chemicals stored on site at any one time will remain similar to current, whilst the

frequency of use/ turnover will increase.

There are currently between 8 and 16 forklift gas bottles stored for forklift consumption. These

are stored in a designated area within a designated, approved BOC Gas crate. No change is

proposed to this gas storage.

Proposed delivery and usage volumes of most chemicals will increase, however the storage

volume held on site will remain the same. In the event of a spill all chemicals can be contained

within the tradewaste system. The existing containment and bunding is regarded as sufficient

and the additional chemical volumes are not expected to have any additional impact including

impact as a result of spills. There will be no impact on public health from the increased use of

chemicals on site.


No additional mitigation strategies are proposed to manage hazardous substances on site.

Existing storage bunds, containment and drainage controls as described in Section 4.7 and

Appendix B will be maintained.

Any chemical spill will be recorded and investigated by George Town to enable preventative

actions to be implemented on site.

4.13 Site contamination

The proposed production increase does not include any disturbance to soil or groundwater that

may have been contaminated in the past, therefore there will be no impact in relation to

contaminated land or groundwater.


Consideration of impacts associated with liquid waste, spills, chemicals and stormwater are

dealt with separately in the relevant sections of this report.

4.14 Sustainability and Climate change


The proposed increase in production quantities will also be met through increased quantities of

fish transported in existing bulk tankers and more frequent deliveries of these tankers. Currently

during the peak processing period there are up to four tankers per day, but mostly two. The

proposed production increase will result in more consistent deliveries of four tankers per day.

There is no proposed change to the volume of 1000 L salmon bins received into the site.

The operational days and hours of the factory will remain the same as the current operation.

The use of automated equipment and recent site upgrades are contributing to the sites overall

improvement in energy and water efficiency.

The proposed increased production will result in increased use of water, chemicals, energy and

fuel; due to the additional transport, volume of fish received into the site, cleaning of tankers and

chemical treatment of tradewaste. However the use of materials, water and transport energy

will all improve per quantity of fish produced (i.e. the efficiency will improve). The water use per

tonne of salmon produced is expected to decrease by approximately 26%, whilst chemical use

per tonne of salmon is likely to decrease by approximately 16%.

The number of transport trips per tonne of salmon (due to the increased numbers of fish per

tanker) is expected to decrease by approximately 8 %.

Figures on total site power use are not available, however are also expected to increase overall,

whilst improving in efficiency (i.e. power use per tonne of salmon).

Emissions of greenhouse gases from the site may increase slightly from the use of bottled gas

on site. Similar to power use the overall efficiency of gas and greenhouse gas emissions per

tonne of salmon are expected to improve.

Figure 4-1 Proposed Improved Efficiencies

Existing Proposed % Reduction

Water Use Efficiency

(kL/tonne salmon)

26.4 19.6 26%

Chemicals Use

Efficiency (L/tonne

salmon)

7.4 6.2 16%

Tradewaste (kL/tonne

of salmon)

1.57 1.14 27%

Transport (number of

trips per 1000 tonnes

of salmon)

1.67 1.53 8 %


George Town Seafoods are continuing to improve the efficiency of their manufacturing site

through upgrades to the plant and equipment. The proposed increased in salmon processing


numbers will assist the site in achieving greater efficiency of water, chemicals and energy use

per tonne of product by getting greater utilisation out of equipment and processes.

4.15 Cultural Heritage

Heritage impacts are not applicable as no aspect of the proposed development will impact on

items of European or Aboriginal heritage. There is no planned disturbance on the existing

industrial factory site.

4.16 Sites of Public interest

The project site is located adjacent to the South George Town Primary School.

Potential noise and odour impacts on the South George Town Primary School have been

addressed in Sections 4.6 and 4.9. The project is not likely to cause an increased noise or

odour impact to the George Town Primary School.

Sections 4.6.2 and 4.9.2 identify mitigation measures that relate to potential odour and noise

impacts.

4.17 Rehabilitation

The project does not involve disturbance of land that will require future rehabilitation.

Rehabilitation requirements for the site remain consistent with those required for the existing

operation which is specified in clauses 20 -22 of EPN 7489-1.

George Town Seafoods will comply with their existing EPN 7489-1 in regards to the requirement

to notify the EPA upon permanent cessation of the business and to prepare a decommissioning

and rehabilitation plan which will include:

Removing or mitigating any environmental hazards or land contamination;

Stabilising any land surfaces that may be subject to erosion; and

Decommissioning any equipment that has not been sold.


5. Part D – Commitments 5.1 Management Commitments

The following commitments shown in Table 5-1 are provided in relation to the proposed

production increase.

Table 5-1 Management Commitments

No Commitment EER

Reference

Completion Date Responsibility

1 Implement plan to seal the

northern driveway and install

stormwater drainage points in

future.

4.6.2 Prior to the

2016/2017 salmon

processing season.

George Town

Seafoods

2 A complaint register will be

maintained at site and odour, dust

and noise complaints dealt with

accordingly in line with EPA

recommendations

4.6.2,

4.9.2

Effective immediately George Town

Seafoods

3 Undertake all monitoring

programs and activities in

compliance with TasWater

Tradewaste Agreement

4.7.3 As per tradewaste

agreement

timeframes agreed

with TasWater

George Town

Seafoods

4 Continue to work with Tassal to

reduce the volume of salt water

included in incoming bulk salmon

deliveries.

4.7.3 Ongoing George Town

Seafoods and

Tassal

5 Regular condition inspection of

the pipework, unions, valves and

tanks will be undertaken and

preventative maintenance checks

on all pumps and valves will be

scheduled on an annual basis.

4.7.3 Effective immediately George Town

Seafoods

6 A spill register will be maintained

and all spills will be investigated

to ensure root causes and

preventative actions are

identified.

4.7.3 Effective immediately George Town

Seafoods

7 Comply with the existing

Movement (biosecurity) permit

conditions (Appendix C) and the

Approved George Town

Seafoods Biosecurity

Management Plan (Appendix A)

at all times

4.11.3 At all times George Town

Seafoods


6. Part E - Public Consultation 6.1 Public consultation

Consultation in regards to this proposal has been undertaken with George Town Council, EPA,

DPIPWE Animal Biosecurity and Welfare Branch and TasWater.

A joint meeting with EPA and TasWater was held on the 6th August 2015 to confirm the

requirements and guidelines to be addressed in this EER.

A letter from DPIPWE Animal Biosecurity and Welfare Branch was sent to the EPA and passed

to George Town Seafoods on 6th August 2015. This letter detailed the requirement for George

Town Seafoods to submit a Biosecurity Management Plan for approval by the Tasmanian Chief

Veterinary Officer as part of this EER. Approval of the Biosecurity Management Plan for

George Town Seafoods was granted by the Chief Veterinary Officer on 1st December 2015 and

its content has been incorporated into this EER.

A meeting was held between George Town Seafoods and TasWater on 30th September 2015 to

discuss the Interim Tradewaste Agreement and to discuss the likely requirements following the

increased production.


7. Disclaimer This report: has been prepared by GHD for George Town Seafoods and may only be used and relied on by George Town Seafoods and the EPA for the purpose agreed between GHD and the George Town Seafoods as set out in Section 1 of this report.

GHD otherwise disclaims responsibility to any person other than George Town Seafoods arising in connection with this report. GHD also excludes implied warranties and conditions, to the extent legally permissible.

The services undertaken by GHD in connection with preparing this report were limited to those specifically detailed in the report and are subject to the scope limitations set out in the report.

The opinions, conclusions and any recommendations in this report are based on conditions encountered and information reviewed at the date of preparation of the report. GHD has no responsibility or obligation to update this report to account for events or changes occurring subsequent to the date that the report was prepared.

The opinions, conclusions and any recommendations in this report are based on assumptions made by GHD described in this report. GHD disclaims liability arising from any of the assumptions being incorrect.

GHD has prepared this report on the basis of information provided by George Town Seafoods and others who provided information to GHD (including Government authorities)], which GHD has not independently verified or checked beyond the agreed scope of work. GHD does not accept liability in connection with such unverified information, including errors and omissions in the report which were caused by errors or omissions in that information.

The opinions, conclusions and any recommendations in this report are based on information obtained from, and testing undertaken at or in connection with, specific sample points. Site conditions at other parts of the site may be different from the site conditions found at the specific sample points. Investigations undertaken in respect of this report are constrained by the particular site conditions, such as the location of buildings, services and vegetation. As a result, not all relevant site features and conditions may have been identified in this report. Site conditions (including the presence of hazardous substances and/or site contamination) may change after the date of this Report. GHD does not accept responsibility arising from, or in connection with, any change to the site conditions. GHD is also not responsible for updating this report if the site conditions change.


8. References Australian Government Department of Agriculture (2015), Draft Aquaculture Farm Biosecurity Plan Guidelines and Plan Template.

EPA (2015) Environmental Effects Report Guidelines for George Town Seafoods Proprietary

Limited, Proposed Increase in Capacity of Fish Processing Factory 38-42 Franklin Street,

George Town.

EPA (April 2013) EPA general guidelines for preparing Environmental Impact Statements for

level 2B activities.

George Town Seafoods (02/12/2015) Approved Arrangements - Model Part 1


Appendices


Appendix A – Approved Biosecurity Management Plan (Tassal November 2015)

Biosecurity Management Plan

for the Processing of Macquarie Harbour Fish

at the George Town Seafoods Processing Facility

Final

November 2015

Author: Malcolm Cummins

Environmental Coordinator – Processing

Tassal Operations Pty Ltd

George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 1

TableofContents1. The George Town Factory ............................................................................................................... 3

Processing at the Facility ................................................................................................................. 3

2. Biosecurity Issue ............................................................................................................................. 3

3. Approvals ........................................................................................................................................ 4

4. Biosecurity Management Issues Identified Under This Plan .......................................................... 5

5. Biosecurity Management ............................................................................................................... 6

5.1. Containment ........................................................................................................................... 6

Issue ................................................................................................................................................ 6

Management ................................................................................................................................... 6

Control Points ................................................................................................................................. 6

5.2. Managing Spillage on Site ....................................................................................................... 7

Issue ................................................................................................................................................ 7

Management ................................................................................................................................... 7

Control Points ................................................................................................................................. 7

5.3. Delivery of MAQ Fish – MAQ Identification and Tracking ...................................................... 8

Issue ................................................................................................................................................ 8

Management ................................................................................................................................... 8

Control Points ................................................................................................................................. 8

5.4. MAQ ITR fish Delivery ............................................................................................................. 9

Issue ................................................................................................................................................ 9

Management ................................................................................................................................... 9

Control Points ................................................................................................................................. 9

5.5. Transport Vehicles – Vehicle Hygiene ................................................................................... 10

Issue .............................................................................................................................................. 10

Management ................................................................................................................................. 10

Control Points ............................................................................................................................... 10

5.6. Hygiene and bin management .............................................................................................. 11

Issue .............................................................................................................................................. 11

Management ................................................................................................................................. 11

Control Points ............................................................................................................................... 11


5.7. Wastewater Containment within Processing Operations .................................................... 12

Issue .............................................................................................................................................. 12

Management ................................................................................................................................. 12

Control Points ............................................................................................................................... 12

5.8. Management of Wastes for Disposal .................................................................................... 13

Issue .............................................................................................................................................. 13

Management ................................................................................................................................. 13

Control Points ............................................................................................................................... 13

5.9. Management of MAQ Fish Wastes ....................................................................................... 13

Issue .............................................................................................................................................. 13

Management ................................................................................................................................. 14

Control Points ............................................................................................................................... 14

5.10. Collection and Treatment of Contaminated Wastewater ................................................ 14

Issue .............................................................................................................................................. 14

Management ................................................................................................................................. 14

Control Points ............................................................................................................................... 15

6. Treatment of Wastewater ‐ Disinfection for Discharge ............................................................ 15

Issue .............................................................................................................................................. 15

Management ................................................................................................................................. 15

Control Points ............................................................................................................................... 16

7. Communication, Contacts and Review ..................................................................................... 16

7.1. Communication of this biosecurity plan ............................................................................... 16

7.2. Biosecurity contacts .............................................................................................................. 16

7.3. Review and audit................................................................................................................... 17

Attachment 1 – Site Plan ............................................................................................................... 18

Attachment 2 – Permit to move MAQ fish to George Town Seafoods ......................................... 19

Attachment 3 – Monitoring Record Form..................................................................................... 21

Attachment 4 – Daily Tanker Cleaning Protocol and Record Forms ............................................. 23

Attachment 5 Wastewater Treatment ORP Validation for Free Chlorine .................................... 27

Attachment 6 – Biosecurity Contact List ....................................................................................... 31


1. TheGeorgeTownFactoryThe George Town Seafoods factory (the facility) is located at 38 – 44 Franklin Street George Town.

The facility undertakes the processing of dead harvested Atlantic salmon (Salmo salar) “in the

round” (ITR) fish sourced from Macquarie Harbour (MAQ) into “head on gutted” (HOG) fish on

behalf of Tassal Group Limited, collectively referred to as the fish in this plan. The HOG are

subsequently shipped to markets on the Australian mainland or to a Tassal value add (VA)

processing facilities in Margate or Huonville.

The facility also processes wild caught spiecies for local and interstate markets and direct sale;

however this is managed as a separate activity, generally during times when Atlantic salmon are not

being processed.

ProcessingattheFacilityThe facility is designed to receive ITR in two ways – ITR are delivered to the site in insulated purpose

built road transport tanker units or when necessary in ‘chiller’ bins by road transport from Tassal

farms on Macquarie Harbour. An average of 400kg of fish per bin are delivered with ice and water

(blood water), or more usually fish in a tanker with ice and blood water in 8 tonne loads.

Bins of fish are delivered via the southern side of the facility (also the dispatch area) and moved

directly by forklift to the ITR bin storage area at the northern side of the facility. This arrangement is

only for a brief period at the beginning of the annual processing cycle until the tanker trucks are

brought into service the facility. Tankers unoad at a purpose built fully contained unloading and

dewatering station on the south side of the factory. The fish are then collected in insulated bins and

stockpiled for processing in the same secure area.

A plan of the site (the site plan) is provided in Attachment 1.

The ITR are fed into automated gutting machines that remove the gut under vacuum. The resultant

HOG are subsequently packaged for shipment or placed in ice slurry in a HOG bin for transport to a

VA facility in Tasmania.

2. BiosecurityIssueFish that originate from Macquarie Harbour on the west coast are known to carry Aeromonas

salmonicida and the Tasmanian aquabirna virus (the pathogens), which are not found in south‐east

Tasmanian waters. Macquarie Harbour together with all connecting bays and estuaries, is a

Restricted Area sub ject to a declaration in force under section 35 of the Animal Health Act 1995 (the

AHA). There are also pathogens found in south‐east Tasmanian waters that are not necessarily

endemic to all south‐east Tasmanian waters. Fish feedstock for the facility may carry the pathogens.

Protection of other restricted areas is essential and it is essential that the facility has the necessary

measures in place to ensure that all potentially contaminated wastewater and stormwater from the

facility is contained and managed appropriately.


The facility and its operation under this plan is within the existing context of Tassal’s “Farm Disease Management & Bio‐security Protocol” (internal document MO‐116), which has been developed to provide high level biosecurity management and to facilitate a coordinated, well informed and timely response to bio‐security risks and issues company‐wide. This is predominantly to ensure that there is no discharge of potentially contaminated waters to the marine environment.

3. ApprovalsGeorge Town Seafoods (GTS) currently operates under Environment Protection Notice 7489/1 (the

EPN), issued to George Town Seafoods Pty Ltd by the Director Environment Protection Authority

under Section 44(1)(d) of the Environmental Management and Pollution Control Act, 1994 (EMPCA),

which contains current conditions for the operation of the facility and permits the processing of up

to 5000t of product per year. A new land use planning permit for the processing of up to 10,000t of

product per year is currently being sought from George Town Council and an application for planning

approval has been submitted.

A permit(the Movement Permit) under Section 37 of the AHA, issued by the Chief Veterinary Officer

(CVO), of Animal Biosecurity & Welfare Branch within Biosecurity Tasmania, DPIPWE, is also in place

to allow the movement of the fish out of MAQ Restricted Area (RA) and into other designated

Restricted Areas. This permit allows the movement of ITR for processing into HOG and for the

movement of HOG to other approved facilities for value add processing.

Under the biosecurity permit, GTS is approved to process MAQ ITR into HOG and ship the product

to the Tassal Margate and Huonville processing facilities. The Movement Permit also allows GTS to

discharge wastewater to the George Town Waste Water Treatment Plant (GTWWTP) under strict

disinfection conditions. A copy of the permit in place at the time of preparation of this plan is

attached (Attachment 2). The facility meets the requirements of the Movement Permit for the

movement of MAQ fish.

The facility is permitted to pretreat it’s wastewater in batches to ensure disinfection and

subsequently discharge the wastewater to the GTWWTP operated by TasWater under a Trade Waste

Agreement (TWA).

This plan also complies with the Tassal Farm Disease Management and Biosecurity Protocol.

The following plan has been prepared for the biosecurity management of the facility in accordance

with any requirements of the Director and the CVO.


4. BiosecurityManagementIssuesIdentifiedUnderThisPlanThe following key aspects have been identified for operations at the facility addressed by this plan:

All potentially contaminated wastewater from all operations including ITR fish transport

bins, transport tanks, processing, and from cleaning is to be captured and disinfected on site,

in batches in accordance with an approved disinfection protocol.

All wastewater treated is to be comply with the CVO specified disinfection criteria of

maintenance of 1 mg/L free residual chlorine for a minimum of 30 minutes prior to being

discharged to the GTWWTP.

Any spillage during unloading, loading and bin movement at the facility must be captured

(i.e. prevented from entering unsecured stormwater drains) and the area and impacted

drains disinfected;

Any rare spillage captured in secured stormwater drains is to be disinfected with a suitable

chlorine solution and held for 30 min prior to release.

All transport vehicle unloading of MAQ ITR fish bins or dispatch loading of HOG fish bins,

uloading of ITR tankers, and internal handling of HOG fish is to occur in the respective

designated containment area.

Containment areas (contained hardstand aprons, bunds) are to be purpose built to collect,

contain and direct runoff (or facilitate pumping) to the wastewater disinfection system

(WWDS);

All storage of the fish and fish waste is to occur in a designated containment area.

All plastic bins liners and consumable items used in processing are to be segregated, bagged,

and enclosed in a lined skip bin then disposed of to landfill by deep burial;

All bins are to be segregated according to their origin, for cleaning, and for dispatch of

empties to MAQ;

MAQ harvest fish transport tankers are to be disinfected after load delivery and prior to

returning to service. The transport tankers are to be dedicated to the transport of MAQ ITR

fish until the end of the harvest season and they have been disinfected, sanitised and meet

the CVO requirements for service in other RAs;

ITR bins are not to be dispatched to SE Tasmania farms unless fully disinfected and sanitised

and meet the CVO requirements for service in other RAs and approved by Tassal senior

management.

MAQ HOG fish bins must not be reused for fish from another RA (must be dedicated to

movement of fish between GTS and processing premises at Margate and Huonville and not

taken to marine farms) unless fully disinfected and sanitised and meet the CVO

requirements for service in other RAs;

All MAQ HOG and harvest ITR bins must be clearly marked and identifiable;

Bins containing fish and fish waste must be clearly marked and identifiable as containing fish

from Macquarie Harbour; and

Solids from or contaminated with the fish are to be contained and disposed of at an

approved facility.


5. BiosecurityManagement

5.1. Containment

IssueThe loss of potentially contaminated fish related material or liquids to the off‐site environment must

be prevented.

The handling of the fish must be conducted within fully contained areas to prevent any loss of MAQ

related fish material or liquids to the off‐site environment.

ManagementThe handling, storage and processing of the fish must be conducted within fully contained areas

within the internal areas of the facility to prevent any loss of potentially contaminated fish related

material or liquids to the off‐site environment. These areas report all wastewater or potentially

contaminated stormwater to the facility’s drainage system reporting to the WWDS .

The facility’s designated containment areas, as shown on the site plan, are designed to ensure

contaminated wastewater and potentially contaminated stormwater is contained and treated by the

WWDS or manually disinfected. The containment areas are:

1. All internal processing areas, chillers and freezers of the factory

2. Northern tanker unloading dock and dewartering system, bunds, bin wash area and associated

hardstand.

3. The Waste Water Disinfection System and associated bunds.

4. The Southern receival and HOG dispatch apron.

The Southern bin receival and HOG dispatch apron is the only location that falls outside the facility’s

drainage system reporting to the WWDS.

ControlPoints All activities involving processing of the fish, fish storage, and fish waste management are to

be conducted within the facility in the containment areas and in a manner that ensures all

associated wastewater is captured and reports to the WWDS storage or direct to treatment.

As a minimum requirement containment areas 1, 2, and 4 and fork lifts are to be routinely

cleaned and sanitised when in use.

Vehicles are to be routinely cleaned and sanitised when in use.

Forklift vehicles are to have tyres sanitised prior to exiting the facility building.


5.2. ManagingSpillageonSite

IssueTo prevent pathogen transmission, any spillage of potentially pathogen contaminated water must be

captured and treated. Cross contamination between ITR bins and HOG bins must be prevented.

ManagementAll handling of MAQ fish, waste products and wastewater is done within designated containment

areas.

All unloading of MAQ ITR from both onsite vehicles and road transport vehicles are conducted on

designated containment areas 2 and 4, and loading of HOG on containment area 4.

Any spillage of potentially pathogen contaminated water is captured and treated in the facility’s

WWDS. All reasonable and practicable precautions are taken and containment measures are in

place to prevent the escape of fish solids and related liquids into the stormwater drains or off site.

The Southern bin receival and HOG dispatch apron is managed during use by a manual check of the

strip drain that collects spillage from the area and manual disinfection and washdown prior to

release of treated water to sewer. As spillage is rare and accidental it is managed on a case by case

basis by the factory supervisor.

If a spill occurs then any spilt fish are to be placed in a bin and secured with MAQ fish waste. All

water from the spill and the clean‐up water must be directed to drainage to the WWDS and all

vehicles and the area involved are to be thoroughly cleaned and sanitised.

Disinfection of spill areas and drains must be carried out to ensure live pathogens do not leave the

site.

ControlPoints All unloading and loading of bins containing MAQ ITR & HOG to and from transport vehicles

must be conducted on designated containment aprons containment areas 2 &4.

All handling of the fish and fish waste is to be done within the designated containment

areas.

Any spilt fish or waste must be collected and returned to a secure container immediately

and segregated with MAQ fish waste. Processing fish waste on the facility floors is to be

cleared as soon as practicably possible.

Any fish solids, fish related water or ice must be prevented from entering any stormwater

drains where it is reasonable and practicably possible to do so and be directed to the WWDS

drainage system.

Where drains are at significant risk of collecting and releasing potentially contaminated fish

related water or liquid to the environment, the drain must have control measures (closed

valves) to hold the liquid.

Spilt fish related water or ice or other liquid entering stormwater drains must be captured,

held in the drains where possible and disinfected.


Spillage, wash down and sanitising water must be collected and disposed of in the WWDS as

far as practicably possible.

The area is to be cleaned up as soon as possible, and the area sanitised.

5.3. DeliveryofMAQFish–MAQIdentificationandTracking

IssueHOG are to be delivered to the facility clearly identified as MAQ fish, recorded and traceable.

ManagementAll transport containers (insulated plastic with an insulated lid bins or “bins”) used within and

between restricted areas or are dedicated for the purpose and identified clearly and distinctly.

All bins holding fish from the restricted area are specifically and distinctly marked with the following

symbols:

VA MAQ HOG Symbol Macquarie Harbour Harvest (ITR) symbol

Each bin containing MAQ HOG destined for Value Add processing is also clearly marked and

identified by clearly marked bin labels containing details of the fish:

Harvest Date

Processing Date

HOG processing facility

VA facility destination

Records:

Records are to be maintained relating to the movement to and from the facility of MAQ ITR, MAQ

HOG, and by‐products (wastes), including the amount, description, the date of despatch and the

destination.

ControlPoints VA bins must be appropriately marked and labelled as above.

Records are to be maintained for at least two years relating to the movement of MAQ ITR

and HOG to and from the facility, including the amount, description, the date of despatch

and the destination.

Likewise records are to be maintained of all fish by‐products (wastes) disposed of from the

facility.


5.4. MAQITRfishDelivery

IssueThe loss of potentially contaminated fish related material or liquids to the off‐site environment must

be prevented. The handling of the fish must be conducted in a manner that prevents any loss of

MAQ related fish material or liquids to the off‐site environment. Spillage and leakage presents an

unacceptable biosecurity risk.

ManagementMAQ fish are generally delivered by purpose built tanker. Tanker transport is specially designed to

prevent leakage and keep the fish and liquid contents contained. This is checked prior to

transportation and on arrival at GTS. However, when the tankers are unavailable the fish may be

delivered to the facility in marked bins, containing approximately 400kg of fish with approximately

250kg of ice each. Bin delivery is typically only short term until the close of the SE harvest.

The ITR bin storage is on the northern side of the plant. Bin deliveries use the southern apron for

forklift unloading and direct movement to the northern storage area well before use as dispatch

area. The southern apron is disinfected prior to using the area for bin dispatch.

The bins must be in good condition, have sealed bungs, no leaks or cracks and without spillage for

transport. However, the use of bins may afford an opportunity for leakage during transit if the bin is

damaged. To ensure this is managed, each bin of fish is lined with a plastic liner (bag) and ‘cable tied’

closed before the lid is secured to the bin. The bins are fitted with a lid that recesses into the top of

the bin, which is designed to prevent liquid splashing out of the bin at the bin‐lid interface. The lids

are also fixed down to the bin by cable tie.

Damaged bins must be immediately withdrawn from service, high pressure cleaned, sanitised prior

to repair, or be condemned. Condemned bins must be disposed of or be destroyed to ensure that

they do not enter another restricted area or put to alternative use in fish farming or fish processing.

This applies to bins used for harvested ITR transport and for HOG transport to Tassal VA factories.

ControlPoints Tanker transport is to be checked for leakage prior to transportation and on arrival at GTS.

Bins must be checked prior to each use for leak points and serviceability.

Bins with ITR must be moved directly from the delivery vehicle to the northern storage area.

The southern apron is to be isinfected prior to using the area for bin dispatch

Bins and lids must be fully sanitised prior to use.

Full bins must be plastic lined and the liner cable tied closed prior to dispatch.

Lids are to be properly fitted and cable tied down prior to dispatch.

Damaged bins must be marked or tagged and immediately withdrawn from service, high

pressure washed and sanitised, and segregated.

Condemned bins must be disposed of or destroyed such that they do not enter another

restricted area or be used in farming or processing for alternative use.


5.5. TransportVehicles–VehicleHygiene

IssueMAQ ITR can at times be transported to the facility in accordance with the AHA permit in curtained

semi‐trailer road transport. Spills may occur during transit, a bin may be damaged and leak or a spill

may occur during unloading.

Transport vehicles carrying the fish are dedicated to the Restricted Area (RA) they service for the

period of the harvest season, unless approved to move between RA following sanitisation. Following

the completion fo the harvest season transport vehicles must be completely sanitised in an

approved manner as the vehicles may service other RAs.

ManagementIf there is a spill of the ITR or liquid during transport the driver is aware of, the driver is to notify the

facility manager whilst in transit if possible otherwise on arrival. The truck is to be parked on arrival

on the factory containment apron and the truck tray and tyres pressure cleaned and sanitised

thoroughly following unloading and before departure from the site.

If there is a spill of liquid or fish feedstock during transport that the driver is aware of, the driver is to

notify the facility manager whilst in transit if possible, otherwise on arrival. The truck is to be parked

on arrival within the facility for full cleaning and sanitisation.

Transport vehicles are dedicated to the RA they service; however, vehicles may service another

region if need be if fully sanitised in accordance with a standard protocol.

The vehicle tray or tank, wheels and wheel wells will be sanitised before loading clean bins to ensure

there is no potential pathogen transference.

Tanker trucks must be cleaned daily in accordance with the George Town Seafoods Standard

Operating Procedures and a record kept (Attachment 4).

End of season cleaning must include additional cleaning that ensures the vehicle is not contaminated

with fish residues.

ControlPoints In the event of any significant leakage or spillage of bins while in transit, the vehicle must be

secured on the southern containment apron and sanitised as soon as possible on arrival.

Spillage and sanitising wash water is to be collected where possible and further treated in

the WWDS.

If there is a spill of liquid or fish during transport or other related issue that may affect

biosecurity that the driver is aware of, the driver is to notify the facility manager or the

Tassal representative whilst in transit if possible, otherwise on arrival.

The truck tray (or tank) and tyres are to be pressure cleaned thoroughly with Hydrofoamer

concentrated detergent.

The truck must not leave the facilitiy’s containment apron until cleared to do so by the

facility manager or delegate.


Trucks servicing one RA must not be used to service another RA unless cleaned, sanitised

and cleared to do so by the facility manager or delegate or as otherwise approved under this

plan.

GTS Form 59 is to be used to record tanker cleaning details and sign off using GTS Form

60. Records are to be kept with the GTS QA officer.

End of season cleaning must include additional cleaning:

fill tanker with double strength CIP cleaner solution and soal soak for 20 minutes

recirculate through system for 30 minutes

drain

fresh CIP solution is placed in the tanker as per normal CIP routine

tank and system is double rinsed with fresh water

visual inspection of tank

exterior wash and sanitize as per daily routine.

5.6. Hygieneandbinmanagement

IssueAll equipment in contact with the fish can potentially carry pathogens. Bins containing fish may leak.

Opportunity for pathogen transfer directly between RAs must be prevented by restricting the

movement of vehicles and bins that may carry pathogens between RAs.

ManagementAll equipment in contact with the fish must be cleaned and sanitised after use and before being

taken from the facility’s containment areas or off site. This specifically includes empty bins, other

containers, equipment, parts, and structures in possible contact with the fish.

Bins are to be thoroughly sanitised in accordance with Tassal’s current sanitisation protocols with QA

management, cleaned and segregated for transport, and transported on dedicated vehicles. Bins

must be appropriately sanitised and approved for use in a different RA.

Bins (and lids) are dedicated for use by marine operations or VA processing (Margate and Huonville)

and movement is to be restricted between the facility and the RA or VA processing facility of origin;

bins and lids are coded as such.

Bins may leak or spill during transit if the bin is damaged. The bins must be in good serviceable

condition, must have sealed bungs, no leaks or cracks. Damaged bins must be immediately

withdrawn from service, high pressure cleaned, sanitised prior to repair, or be condemned.

Condemned bins must be disposed of or be destroyed to ensure that they do not enter another

restricted area or put to alternative use in fish farming or fish processing.

ControlPointsBin cleaning and sanitising (and other containers, equipment, parts and structures):


All equipment in contact with the fish must be cleaned and sanitised after use and before being taken outside the facility building or off site.

Bins must be totally empty prior to commencing cleaning and sanitising.

The cleaning is to occur in a designated containment area within the facility and all water is to be collected and directed to the irrigation storage pond.

Bins must be high pressure cleaned and sanitised thoroughly.

Where applicable, clean bin lids must be applied once bins have been cleaned.

Where bins are to be dispatched to a different biosecurity zone, which must be as approved by the CVO, bins must be high pressure cleaned and sanitised following an approved disinfection protocol, and high pressure cleaned again.

All bins must be marked in a recognised manner indicating the RA or VA point of origin.

As a minimum colour coding is to be used for this purpose.

All staff associated with the handling of fish feedstock for the facility must be aware of

the bin colour coding or marking used.

All MAQ marked or colour coded bins are to be segregated following cleaning for

dispatch. These bins are not to be dispatched to SE Tasmania farms unless fully

disinfected and sanitised and meet the CVO requirements for service in other

biosecurity zones and approved by Tassal senior management.

Damaged bins must be immediately withdrawn from service, high pressure cleaned,

sanitised prior to repair, or be condemned.

Condemned bins must be disposed of or be destroyed to ensure that they do not enter

another restricted area or put to alternative use in fish farming or fish processing.

5.7. WastewaterContainmentwithinProcessingOperations

IssueAll potential pathogen contaminated process water is to be prevented from escape to the

environment. Wastewater from within processing operations needs to be captured and directed to

the facility’s WWDS for treatment.

ManagementAll the processing floor area in the factory within Containment Area 1 is fully contained with floor

drains that feed into the WWDS. The adjoining containment aprons also feed into the WWDS

system (one drain to stormwater is securely closed and is subject to regular inspection, cleaning and

disinfection).

ControlPoints All processing and handling of MAQ ITR, HOG and waste must be within a designated

containment areas.

All potentially pathogen contaminated process water from processing must be captured and

directed to the facility’s WWDS.

All drains in designated containment areas must have sufficient capacity to meet flow

demand and be kept clear and functional at all times and be in service.

Foreign objects must not be allowed to enter or be placed in or over the drains.

Fish solid residues must be prevented from entering drains as far as reasonable practicable.


5.8. ManagementofWastesforDisposal

IssueConsumable items used in the delivery and processing of MAQ HOG, fish products and by‐products

can carry the pathogens. All non‐fish consumable items must be disposed of as required under the

AHA Movement Permit.

Consumable items include but are not limited to:

Bin liners for ITR and HOG, labels and cable ties.

Consumable items soiled during product handling and packing.

Hygiene garments, gloves, paper towel, and associated items that have been in contact with

MAQ fish or associated with secondary contact.

ManagementAll consumable items must be segregated for disposal at designated locations, segregated waste

clearly marked MAQ waste or similar. If it is reasonable and practicable to clean an item free of fish

residue it should be done (such as bin liners). Plastic bin liners are to be well drained, ‘bagged’

securely and placed in a dedicated hook bin for landfill disposal.

All wastes must be disposed of in a designated MAQ waste bin supplied by an approved contractor

(currently Veolia). Management and disposal of the waste in the MAQ waste bin is to be in

accordance with the AHA permit requirement for deep burial at an EPA approved landfill, Remount

Road Landfill.

ControlPoints All MAQ contaminated packaging must be disposed of as MAQ waste for deep burial.

All MAQ contaminated used consumables must be segregated for disposal as MAQ Waste.

If it is reasonable and practicable to clean an item free of fish residue it should be done.

Plastic bin liners are to be drained, ‘bagged’ securely and placed in a dedicated hook bin

located on a designated containment area for disposal by an approved contractor.

Management and disposal of the waste in the MAQ waste hook bin is to be in accordance

with the AHA permit requirement for deep burial at an EPA approved landfill.

5.9. ManagementofMAQFishWastes

IssueMAQ fish wastes are a high risk for carrying pathogens and secure containment is essential. MAQ

fish waste pathogenic risks are principally from:

Vermin, birds and other pathogen transmission vectors carrying the pathogen or pathogen

containing material.

Improper disposal.

Uncontained spillage and leakage.


ManagementAll solid fish wastes need to be secured in serviceable (i.e.no leaks and significant damage)

designated fish waste bins.

Fish viscera “gut” is pumped directly from the processing line into a bunded “gut” tank.

All fish wastes (i.e. whole fish) are minced in the factory and added to the “gut” tank. This prevents

access from birds or vermin. Drains to the WWDS and to the gut tank are cleaned daily to minimise

the likelihood of the presence of opportunistic vermin. There are no other fish wastes.

All of fish waste, viscera with some minced rejects go to Seafish Tasmania or will go to Tassal

Triabunna rendering plant. In the event that fish waste cannot be processed by these means, it will

be directed to Remount Road Landfill for deep burial with GTS solid wastes.

ControlPoints Processing fish wastes must be placed in designated fish waste bins in the processing

factory.

Fish waste bins must be emptied daily and sanitised.

All solid MAQ fish wastes (i.e. whole fish) are to be minced and added to the “gut” tank.

All MAQ fish gut is to be collected in the designated bunded gut tank where it may be

treated chemically to ameliorate odour and preserve gut quality prior to rendering.

Fish waste must only be transported off site using a registered and approved transporter.

The fish waste is only to be delivered to EPA and CVO approved sites such as Tassal

Triabunna for rendering or Remount Road Landfill for deep burial.

Drains are to be thoroughly cleaned daily to minimise the likelihood of the presence of

opportunistic vermin and other vectors.

5.10. CollectionandTreatmentofContaminatedWastewater

IssueAll potentially pathogen contaminated wastewater and stormwater must not be allowed to

transport pathogens off site and therefore must be captured on site within relevant processing,

loading, unloading, storage, and cleaning areas and directed for treatment to the facility’s WWDS.

ManagementMAQ ITR delivery bin and tanker water, processing wastewater, cleaning wastewater and

stormwater from Containment Areas is directed to the WWDS.

Cleaning of equipment of any nature, bins and vehicles used in the handling of MAQ HOG or

unpackaged fish product must take place on a containment apron with all water directed to the

sewer drains or other designated containment structure that is supported by such drains.


ControlPoints Processing of MAQ ITR and handling of HOG product must take place within the confines of

the processing factory.

All potentially contaminated wastewater and stormwater must be directed to the WWDS.

Cleaning of equipment of any nature, bins and vehicles used in the handling of MAQ fish

must take place within a designated Containment Area, with all water directed to the

WWDS.

6. TreatmentofWastewater‐DisinfectionforDischarge

IssueAppropriate disinfection is necessary for the pathogens Aeromonas salmonicida and the aquabirna

virus prior to discharge of fully treated effluent into the Tamar Estuary from the George Town Waste

Water Treatment Plant (TasWater WWTP).

It should be noted that the latter pathogen, the aquabirna virus, is difficult to kill; however, any

infection that may be in the fish is likely to be removed with the viscera during gutting of the fish.

All wastewater may carry pathogens and cannot leave the facility site unless treated and disinfected

as approved, or it is to be treated and disposed of by other means approved by the CVO and the

EPA.

The facility treats all wastewater and potentially contaminated stormwater in the site’s wastewater

disinfection system to ensure that the wastewater is sufficiently disinfected prior to discharge to the

TasWater WWTP. The TasWater WWTP provides a second level of disinfection during the biological

treatment of the wastewater by the Plant. The combined process of disinfection is approved by the

CVO.

ManagementSolids in the wastewater and stormwater are captured by appropriate hardstand grates, processing

area floor drain grates, screens and traps or other suitable equipment to minimise fish solids from

entering the WWDS.

The facility wastewater disinfection system (the WWDS) consists of several bunded primary

treatment tanks into which wastewater is pumped and chlorinated by automatic dosing with sodium

hypochlorite. Wastewater is treated in batches and held on site until it qualifies for discharge. The

chlorinated wastewater is recirculated and dosed until such time as a free residual chlorine level of

1mg/L is reached. This level of free residual chlorine is maintained for at least one half hour. This

ensures that sufficient disinfection of the wastewater has been achieved.

Treated wastewater is tested using a Dulcotest DT1B Photometer. Batch testing is conducted by

sampling direct from the recirculation line from the tank and then immediately testing as per the

manufacturer’s instructions. All details are recorded on a monitoring record form (Attachment 3).

Oxidation Reduction Potential (ORP) is also used as a measure of disinfection. By maintaining sufficiently high ORP (mV) the level of disinfection is assured. ORP is the preferred form of


determining there is sufficient free chlorine (oxidiser) in the wastewater and disinfection potential within the wastewater.

A benefit of ORP as the disinfection level indicator is that ORP does not need to be combined with pH readings and adjusted for pH, and ORP can be relied upon when there is complex water quality such as produced by the George Town facility. ORP readings are also recorded on the disinfection record form.

Attachment 5 contains a comparison report following a study of ORP recordings taken in parallel with Dulcotest DT1B Photometer chlorine readings in January 2013. The report shows that by maintaining 400mV in the treated wastewater a free residual chlorine level of at least 1 mg/L is maintained (range of approximately 1 – 1.5 mg/L).

On approval of this plan, ORP will be the measure of disinfection potential in the wastewater per batch, for a minimum 30 minutes at an ORP level of 400mV prior to release to sewer to the TasWater WWTP. A Dulcotest DT1B Photometer chlorine reading will be taken daily for two weeks on annual commencement of MAQ fish processing, and on a weekly basis thereafter and as a backup.

ControlPoints All potential pathogen contaminated water must pass to the WWDS for treatment.

All containment area drains, processing area drains, associated pipework, are to be clear of

obstruction and fit for purpose.

Solids in the wastewater (including stormwater) must be captured by fit for purpose and

operational screens, traps, or other process prior to entering the WWTP system proper.

ORP is to be used to measure disinfection potential in wastewater batches.

Along with ORP, a Dulcotest DT1B Photometer chlorine reading is to be taken daily for two

weeks on annual commencement of MAQ fish processing, and on a weekly basis thereafter.

ORP readings and Dulcotest readings are to be recorded routinely on the monitoring record form (Attachment 3).

Wastewater and captured stormwater must be treated in batches for a minimum 30

minutes at an ORP level of 400mV prior to release to sewer to the TasWater WWTP.

ORP probes must be cleaned at least once a month and calibrated as necessary in

accordance with the manufacturer’s instructions.

7. Communication,ContactsandReview

7.1. CommunicationofthisbiosecurityplanThis biosecurity plan is to be communicated to staff by the GTS manager and the GTS QA officer,

and to Tassal staff using Tassal “QPulse” electronic document management and communication

system. Relevant standard operating procedures and task breakdowns for staff and contractors

will be developed within six months of approval of the biosecurity plan.

7.2. BiosecuritycontactsA list of contacts for biosecurity management, issues or events in relation to the facility is

provided in Attachment 6.


7.3. ReviewandauditThe plan will be reviewed every three years to ensure it is current and fit for purpose. Auditing

against the plan will be conducted annually.


Attachment1–SitePlan


Attachment2–PermittomoveMAQfishtoGeorgeTownSeafoods



Attachment3–MonitoringRecordForm

Form 48 Waste Water Treatment – George Town Seafoods Reg. Est. 5485

Tank number (A or B):_______________ Date: _____________________

Start up checks

YES / NO If NO, record action taken

Sodium Hypochlorite stocks sufficient (min 2 Drums)

Dosing day tanks are full

Dosers functioning

Discharge valves closed

Infeed valves checked (only one tank valve open)

Supplementary dosing record

Add dosage of hypo before filling begins

YES / NO

Start circulating pump when tank at least 25% full

Controller reading (Mv)when 50% full

Controller and tank level recording (at start up and every 2 hrs. during production)

Production start time:_________________

Time of check Controller readings (Mv) Tank levels (Litres) Comments

Preparation for discharge

Time Tank full

Controller reading (min 320Mv)

Titration result* Manual dose required

30 minute titration***

YES / NO YES** / NO

*If the reading is min. 1ppm, wait 30 mins and titrate again. If reading is below 1ppm manually dose

tank and titrate again in 15 minutes.

**If YES, record the details of dosing in section below.

***If reading has consistently remained above 1ppm for 30 minutes proceed with discharge. If

reading is below 1ppm manually dose tank and titrate again in 15 minutes.


Manual addition record

Time of addition Quantity added Reason for addition

Discharge record

Discharge NOT to occur until titration confirms min 1ppm has been achieved consistently for 30

mins

Discharge start time

Discharge end time Discharge valve closed

YES / NO

Comments

Completed by name: __________________________ Signature:

______________________________

Checked by QA: ______________________________ Signature:

______________________________

Form 48 – Waste Water Treatment V3 Issue date: 10/1/2013 Last Updated: 20/3/2013


Attachment4–DailyTankerCleaningProtocolandRecordForms





Attachment5WastewaterTreatmentORPValidationforFreeChlorine

George Town Seafoods

Wastewater Treatment ORP Validation for Free Chlorine

Introduction:

George Town Seafoods began processing Tassal’s Macquarie Harbour fish in January 2013. As it is

directly from another biosecurity zone the wastewater from this process must be fully contained and

treated on site prior to release to sewer.

Wastewater Treatment:

Wastewater is treated by dosing with sodium hypochlorite in batches in treatment tanks. The

analogy behind how to treat the wastewater is based on some testing performed at our Dover

facility on fish blood water. Several samples of blood water at differing dilutions were treated with

Hypochlorite with the aim to achieve better than 1mg/L of residual free chlorine after treatment.

1mg/L of residual free chlorine is maintained for at least 30 minutes to ensure full contact with

pathogens.

Measuring residual free chlorine:

Treated wastewater is tested using a Dulcotest DT1B Photometer for free chlorine.

A true free chlorine probe has to be installed in a low pressure (max 1 bar) sample line and has a

membrane which may clog if there are solids, oil or grease in the line. If there is salt water then a

total chlorine probe is used, which has the same, or similar membrane. Both types of probes

measure chlorine only and do not detect other oxidants, including chlorine dioxide, and are a much

better way to measure but must be kept clean. It was decided that the Chlorine Probes were not

suitable for the current application.

Oxidation Reduction Potential (ORP) is also used as a measure of disinfection. By maintaining

sufficiently high ORP (mV) the level of disinfection is assured. ORP is the preferred form of

determining there is sufficient free chlorine (oxidiser) in the wastewater and disinfection potential

within the wastewater. A benefit of ORP as the disinfection level indicator is that ORP does not need

to be combined with pH readings and adjusted for pH, and ORP can be relied upon when there is

complex water quality such as produced by the George Town facility.

The ORP probe monitors all oxidants in the water, one of which will be chlorine, and displays the

result in millivolts. It is not a chlorine probe per se but if chlorine is the major oxidant present then it

will give good control, which is the case. It is used as a low cost chlorine probe and is quite common

in simple water applications like swimming pools. It is also a glass probe and can take pressures of up

to 10 bar so can be installed in line, and is not as susceptible to oil, grease or other coating products.



Graphed results:

Interpreting the results from the graph: It is concluded that a millivolt reading in the order of 400 Millivolts represents a residual free chlorine level of

between 1.0 – 1.5 ppm.

0

0.5

1

1.5

2

2.5

3

0

50

100

150

200

250

300

350

400

450

500

Date 9‐Feb 10‐Feb 11‐Feb 12‐Feb 13‐Feb 14‐Feb 15‐Feb 16‐Feb 17‐Feb 18‐Feb 19‐Feb 20‐Feb 21‐Feb

Series1 Series2

Millivolts versus ppm Chlorine residual

ppm/Chlorine

DateMillivolts ppm / Chlorine Residual

Millivolts

Dosing and Control:

From start of production in early January 2013 the dosing of hypochlorite into the wastewater has

been regulated and monitored continuously with a view to confirm the correlation between the

millivolt reading of the ORP probe and the Titrated Residual Chlorine required prior to release.

Application to George Town Seafoods chlorine dose monitoring:

The use of ORP as a legitimate alternative to the use of the Dulcotest DT1B Photometer for free

chlorine is considered legitimate in this application as it correlates well with the Photometer and is

reliable under the conditions in which it is used.

It is concluded that a millivolt reading in the order of 400 Millivolts will result in a residual free

chlorine level of between 1.0 – 1.5 ppm having been obtained.

After several months of dosing and control, coupled with significant monitoring, it is concluded that

the Wastewater Treatment System can be reliably run via this dosing control methodology.



Attachment6–BiosecurityContactList

Contact Organisation Name Contact Number

Head of Supply Chain and

Commercial Services, Logistics

Tassal Operations Pty Ltd Ben Daley 0438 291 224

Manager (Director)


George Dourmouras 03 6382 3466

Quality Assurance Manager


Megan Lutz 03 6382 3466

Senior Manager Fish Health

Tassal Operations Pty Ltd Christine Huynh 0400 608 590

Senior Manager Wet Processing

Tassal Operations Pty Ltd Duane Baker 0427 870 867

Environmental Coordinator

Processing

Tassal Operations Pty Ltd Malcolm Cummins 0417 359 861

Senior Environmental Officer

Industrial Operations

EPA Division Department of Primary Industries Parks Water and Environment

Jane Rapkins 0407836203

EPA AH

1800 005 171

Senior Veterinary Officer

Aquatic Health &

Epidemiology

Animal Biosecurity and Welfare Biosecurity Tasmania Division Department of Primary Industries Parks Water and Environment

Kevin Ellard 6165 3260


Appendix B – Current Containment Areas

From a biosecurity aspect, all areas contaminated with fish product are either treated by the

tradewaste management system or manually disinfected prior to release to the sewage system.

The containment areas are:

1. All internal processing areas, chillers and freezers of the factory (Tradewaste)

2. Northern tanker unloading dock and dewatering system, bunds, bin wash area and

associated hardstand (Tradewaste).

3. The Waste Water Disinfection System and associated bunds (Tradewaste).

4. The Southern receival and HOG dispatch apron (Controlled discharge to Sewer).

Each of the four containment areas have been identified in the figure shown below taken from

the Approved Biosecurity Management Plan (Tassal 2015).

The bulk tanker salmon unloading area (containment area 2) takes place over a large pit which

is capable of containing 3000 L of liquid. This area drains to the site’s tradewaste system and

captures all washdown water whilst cleaning out tankers. There is no risk of spills to stormwater

during normal unloading conditions. The 28 kL blood water storage tank is located adjacent to

the bulk tanker unloading area in a tradewaste drainage area (also in containment area 2). This

area is bunded by a concrete raised edge along the northern side of the concrete hard stand.

The slope of the concreted area is such that all spills flow from west to east and are captured by

a tradewaste drain.

Chemical and waste storages are located in tradewaste drainage areas (containment area 2

and 3). The waste storages and chemicals located in containment area 3 (wastewater

disinfection and bund) are fully bunded to contain liquids in the event of a spill or leak either in

their own stand-alone chemical storage bund (refer in Section 4.12) or the larger bund for the

whole wastewater storage area. Chemicals located in containment area 2 (the bin storage area

near the dewatering station) are either temporarily stored here until placement for use either in

containment area 3 or are placed adjacent to the blood water tank or CIP tank for dosing. As

described above any spills in this area flow east and are captured by the tradewaste drainage

system.

The Southern bin receival and HOG dispatch apron (containment area 4) is the only location

that falls outside the facility’s tradewaste capture system. The majority of this area is covered

(roofed) and drainage in the area is directed to the sewer. The project will not result in any

change to incoming raw salmon into the southern receival area of the factory. Increased

volumes of raw salmon will be received via bulk tanker unloading only. There will be increased

quantities of packaged finished product dispatched from the southern dispatch apron - however

this does not pose an increased risk of spills.


Spill Containment Areas (Sourced George Town Seafoods Approved Biosecurity Management Plan v3)

GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760

Appendix C Movement (Biosecurity) Permit

GHD

23 Paterson St Launceston Tasmania 7250 T: (03) 6332 5500 F: (03) 6332 5555 E: [email protected]

© GHD 2015

This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited.

G:\32\17760\WP\22074.docx

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Rev No.

Author Reviewer Approved for Issue Name Signature Name Signature Date

0 S McLeod A. Jungalwalla On file A. Jungalwalla

12/10/2015

1 S McLeod D.Elson On file D.Elson On file 03/12/2015

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