Tassal Huonville Factory Expansion - EPA...

ENVIRONMENTAL ASSESSMENT REPORT

Tassal Huonville Factory Expansion

20 Glen Road, Huonville

Tassal Group Limited

Report and recommendations of the Environment Division Department of Environment, Parks, Heritage and the Arts to the Board of the Environment Protection Authority May 2009

Environmental Assessment Report – Tassal Huonville Factory Expansion

II

Environmental Assessment Report

Proponent Tassal Group Limited

Proposal Tassal Huonville Factory Expansion

Location 20 Glen Road, Huonville

NELMS no. 7805

DA number DA-54/2009

File 111599

Document

Class of Assessment

G\:\EEO_Enviro_Ops\EAS_Assessments\EAS_Projects\Tassal_Huonville Expansions\Assessment Report\Tassal Assessment Report.docx

2A

Assessment process milestones

12 March 2009 Permit application submitted to Council

24 March 2009 Application received by Board

18 April 2009 Start of public consultation period

4 May 2009 End of public consultation period

Glossary

Air EPP

Air NEPM

Environment Protection Policy (Air Quality) 2004

National Environment Protection (Ambient Air Quality) Measure

(1994)

Board Board of the Environment Protection Authority

DEPHA Department of Environment, Parks, Heritage and the Arts

DPIW Department of Primary Industries and Water

EIA Environmental Impact Assessment

EMPC Act Environmental Management and Pollution Control Act 1994

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

LUPA Act Land Use Planning and Approvals Act 1993

SD Sustainable development


IV

Table of Contents

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

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

3 The proposal ............................................................................................ 6

4 Need for proposal and alternatives ........................................................... 9

5 Public and agency consultation ................................................................ 9

6 Evaluation of environmental issues ........................................................ 10

7 Conclusions ........................................................................................... 15

8 References ............................................................................................. 15

9 Summary of appendices ......................................................................... 16


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1 Approvals process

An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Huon Valley Council on 12 March 2009.

The proposal is defined as a ‘level 2 activity’ under Schedule 2 Subsection (4)(c) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being an animal product processing factory, producing more than 100 tonnes of product per year. Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The application was received by the Board on 24 March 2009.

The assessment has been undertaken by the Director, Environment Protection Authority under delegation from the Board.

A Development Application Supporting Report was submitted to Council with the permit application. The EPA called for further information about air emissions, liquid effluent, transportation impacts, dangerous good and chemicals, operating hours and public consultation. Supporting information was released for public inspection for a 14-day period commencing on 18 April 2009. A detailed Air Quality Impact Report was received on 11 May 2009. Advertisements were placed in The Mercury and on the EPA web site. No public submissions were received.

2 SD objectives and EIA principles

The proposal must be considered by the Director in the context of the sustainable development objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) established by the EMPC Act. The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to protect the environment of Tasmania, and to further the RMPS and EMPCS objectives.

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


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3 The proposal

Tassal Group Limited is applying for a permit to expand current operations of its fish processing factory in Huonville. The factory produces value-added salmon products, and on-site activities involve smoking, slicing and packaging.

Tassal’s current permit (approved 1997; ELMS No. 6072) limits production to 2,000 tonnes per year of fish products, and Tassal is seeking to increase production by 15% to 2,300 tonnes per year. The increase requires extensions to the current building and the installation of new items of equipment within the building (of similar functionality to existing) and provision of increased amenities. In increasing production, Tassal have proposed a doubling in the proportion of smoked product, which may result in increased particulate emissions from the site.

The main characteristics of the proposal are summarised in Table 1, which uses information obtained from the supporting documentation. A detailed description of the proposal is provided in Section 2 of the Development Application Supporting Report.

Table 1: Summary of key proposal characteristics

Characteristic Description/quantities

Activity description The activity is a Level 2 fish processing factory producing value-added salmon products via the smoking and preparation of fish material. The proponent is seeking approval to increase production by 15% to enable 2,300 tonnes of fish produce to be produced per annum. The proposal will not introduce any new operations that are not currently undertaken at the factory.

Location The factory is located at 20 Glen Road, Huonville; adjacent to the Huon Highway. Access is via Glen Road, approximately 1 kilometre north of the Huonville township.

Land zoning The area is zoned Intensive Rural under the Huon Planning Scheme 1979. As stated in the supporting documentation, the proposal is classified Rural Industry under the planning scheme, which is a discretionary use within the zone provided there is no direct access onto the Huon Highway.

Land tenure Tassal’s Huonville operations are situated on four land parcels (Title references: 113587/2, 113587/3, 113587/7, 129264/2), each owned by Tassal Operations Pty Ltd. The greater proportion of extensions will occur on Title 129264/2 (15.52 hectares).

Site overview The factory is surrounded by flat, grassed paddocks that extend to the property boundary. The site is bounded on three sides by the Huon Highway, Glen Road and North Glen Road.

Surrounding area overview

Two titles owned by local residents are located directly next to Tassal’s site, with access via the Huon Highway. The nearest neighbour is located approximately 100 metres from the factory.

The surrounding area is mixture of residential houses and houses associated with small business. A sawmill (Porter’s Timber) is located nearby off North Glen Road.

The factory is visible from the Huon Highway.

Major equipment The expansion requires the addition of a further three smoke ovens (a total of six ovens on-site), additional automatic slicers and silk cut slicers and additional thermoform/vacuum sealing units. The expansion with utilise the surplus operating capacity of machines currently at the site.

Other infrastructure The proposal involves an enlargement of the current factory building towards the Huon Highway, a new smoke generator room, an enlargement of the


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Characteristic Description/quantities

electrical substation, and the creation of a two five-metre wide vehicle entrances.

Inputs

Water Water is used in processing and cleaning phases.

Energy The expansion is not anticipated to change the use or storage of fuel or oils.

Other raw materials Fish product is the major input material received at the site. The site receives head-on gutted (HOG) fish, which are packed in ice slurry and graded to size.

Wastes

Liquid Liquid waste will increase with the expansion. Wastewater is collected in a wet well and pumped through a screen before being collected in a wastewater attenuation tank. Under an existing Trade Waste Agreement with the Huon Valley Council, all wastewater is transferred to the Ranelagh Wastewater Treatment Plant for treatment.

Atmospheric The smoking kilns generate fine particulate emissions, and emissions are anticipated to increase with the expansion of the factory. Odour is not a significant emission.

Solid The expansion will increase the amount of solid waste. Solid waste is mainly composed of fish heads, skins and trimmings. Solid waste is collected in sealed insulated bins, placed in waste chillers and then collected by a third party operator for transportation to Triabunna for value added processing into fish oil and fish meal.

Noise Main sources of noise include truck movements between 0700 and 1630 hours and traffic noise generated from the change of day and afternoon shifts (1430 to 1530 hours). Noise associated with other shift changes (between 0600 to 0730 hours, and 2245 and 2330 hours) is expected.

Operating hours Processing will occur five days per week, and additionally on weekends as required to meet demands. Shift work covers the full 24 hour period. Smoking kilns will operate 20 hours/day for up to 6.5 days a week.

Project timetable Construction to expand current operations will commence upon the permit being issued.


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Figure 1: Site plan (from the Development Application Supporting Report).


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4 Need for proposal and alternatives

Tassal’s Huonville fish processing facility is an established operation that is currently permitted to produce 2,000 tonnes of fish product per annum. Tassal has submitted a proposal to expand production to 2,300 tonnes of fish product per annum. The increase in production is needed to accommodate expanding business operations and to satisfy product demand. Production levels will be increased using a large proportion of existing infrastructure and equipment involved in current operations and will not introduce operations that are not currently undertaken at the factory. Some additional machinery and equipment will be required to meet production demands, however new machinery will not differ in functionality from existing machinery. The increase in production is anticipated to create benefits in employment. The proposed increase will employ an additional 32 full-time equivalent workers. Due to the nature of the proposal, operation at an alternative site is not a viable option.

5 Public and agency consultation

Public comment was invited over a two-week period commencing on 18 April 2009.

No public representations were received.

The Development Application Supporting Report was referred to government agencies/bodies with an interest in the proposal. A response was received from:

• Public and Environmental Health Service, Department of Health and Human Services.

The following Divisions/Areas of the Department of Environment, Parks, Heritage and the Arts provided submissions on the Development Application Supporting Report:

• (Air Modelling Specialist) Environment Division;

• (Noise Specialist) Environment Division;

• (Food and Textiles Specialist) Environment Division;

• (Wastewater Specialist) Environment Division.

The proponent has undertaken its own public consultation process and, as stated in the Development Application Supporting Report, has consulted the Premier’s Office, the Treasurer’s Office, the Department of Economic Development and Tourism, and the Minister for Department of Environment, Parks, Heritage and the Arts.

The report states that consultation will take place with neighbours of the factory and employee groups, including unions.


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6 Evaluation of environmental issues

The environmental issues considered relevant to the proposal have been evaluated by the Environment Division. Details of this evaluation, along with recommended permit conditions, are shown in Table 2.

Table 2 Assessment of environmental issues

Issue 1

Air emissions

Description of potential impacts

The facility intentionally generates smoke for the smoking of fish products, therefore there is significant potential for emissions from the facility to transport particulate matter into the surrounding atmosphere. Polycyclic aromatic hydrocarbons may also be formed through incomplete combustion of organic matter.

Management measures proposed in supporting documentation

Tassal committed to the installation of best practice smoke emission reduction technology for the existing and new smoke ovens. Tassal also committed to consulting with the EPA during the design, trialling and commissioning of smoke emission reduction technology.

Public and agency comment

No public representations were received.

The Department of Health and Human Services provided a brief comment stating that maintenance of the existing buffer area between the factory and surrounding residences was considered essential to minimise potential smoke and odour nuisance.

Evaluation and recommendation

Atmospheric dispersion modelling was conducted in close consultation with the Division’s Air Modelling Specialist. Odour was not considered a significant issue.

The modelling used results from a 2001 stack test on a single smoke generator. The release conditions (temperature, velocity, volumetric flow) and PM10 emissions (in-stack concentration and mass emission rate) were used to characterise all three existing smoke generators and the proposed three additional smoke generators.

The 2001 stack test measured an in-stack particulate concentration of 502 mg/m3, which exceeds the 100 mg/m3 Air EPP in-stack limit by a factor of five. It was therefore clear that emissions from the existing smoke generators, and from the proposed additional generators, would require pollution abatement technology to meet the Air EPP in-stack limit.

Five modelling scenarios were developed to investigate different aspects of the project:

1. TAPM modelling of daily mean PM10 ground level concentrations;

2. Ausplume modelling of daily mean PM10 concentrations (for comparison);

3. Ausplume modelling of daily mean PM10 concentrations assuming a 3 m extension to all stack heights;

4. TAPM annual mean ground level concentrations for unit emissions (for PAH emissions); and

5. TAPM modelling of 8-hour mean PM10 ground level concentrations in the near field for workplace occupational health and safety purposes.

Scenario 1 predicts a peak off-site daily-mean PM10 concentration of 400 µg/m3 arising from expected emissions generated by six smoke generator stacks without abatement. The equivalent


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Ausplume Scenario (Scenario 2) corroborates this result, predicting a peak of 450 µg/m3.

Given that the Air EPP design criterion for particulates is 150 µg/m3 and the Air NEPM PM10 standard is 50 µg/m3 (with five allowable exceedences p.a.), it is clear that ambient criteria would be significantly exceeded in the absence of pollution abatement equipment.

Scenario 3 shows that adding a three metre extension to each of the six stacks provides a significant improvement in ground level concentrations (a 10 % decrease), but this is not enough to meet regulatory requirements.

Scenario 4 was used to calculate the in-stack concentration required to be achieved in order to meet the Air Toxics NEPM annual-average investigation level for benzo-α-pyrene (BαP). The calculated value, 4.2 µg/m3, can be used as the basis for determining a permitted in-stack emission limit. A 20% increase is recommended to allow for fluctuations about the mean (See Condition A1).

Scenario 5 is concerned with occupational health and safety within the boundaries of the premises. It is not considered further in this assessment report.

The remainder of the Air Quality Impact Study deals with mitigating the effects of the existing and additional proposed emissions from the smoke generators. Two important and conservative assumptions have been made. Firstly, given that the modelling was based on the results of a single stack test and that process emissions can vary dramatically over time, a 1.25 factor of safety was applied to the Scenario 1 results, thus increasing them by 25%. This is the equivalent of applying a 25% increase in smoke emissions from each stack.

The second assumption relates to the goal of mitigating emissions to such an extent that a peak daily mean PM10 resulting from the Tassal facility does not exceed 25 µg/m3. This is 50% of the Air NEPM PM10 Standard and 17% of the Air EPP PM10 design criterion.

Table 6.1 of the Air Quality Impact Study (see Appendix 2) shows that to meet such stringent assumptions under a six smoker scenario, any pollution abatement equipment utilised must have a particle capture efficiency of at least 95%. The report then identifies a particular make and model of electrostatic precipitator (ESP) that appears to meet this requirement. It notes that this equipment has been successfully used in similar facilities in the United States.

The identified ESP can be obtained in two configurations: a single-pass unit, with an efficiency of approximately 95%; and a tandem-pass unit with an efficiency of about 97.5%. The tandem-pass unit is effectively two precipitators joined together in series. The advantage to the tandem-pass unit is that if one unit fails, or is out of commission for maintenance, then the other unit remains in place to mitigate emissions.

Tassal have agreed to install and trial an ESP on a single smoke generator flue to ensure that it meets the performance requirements. If a stack test shows that the trial is successful then ESP’s will be installed on all six stacks.

Section 7.3 concludes the Air Quality Impact Study with recommendations arising from the study. All six of these recommendations are sensible and are supported. Condition G7 requires Tassal to comply with the recommendations and effectively allows a period of time during which pollution abatement equipment can be installed and ‘tweaked’ to secure compliance with the emission limits established by recommended Condition A3. The Air Modelling Specialist recommends that tandem-pass ESP’s be installed rather than single-pass units, in any event Condition A3 requires compliance during maintenance activities.

Recomended Condition A2 requires periodic stack tests to test compliance with the emission limits and Condition A3 requires provision of facilities for performing stack tests.

Issue 2

Liquid effluent treatment



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Negative impact to waterways if discharged; potential overloading of the Ranelagh Wastewater Treatment Plant.


Wastewater effluent is to be treated via a series of management measures that are currently deployed at the site.

• Wastewater is collected in a wetwell and pumped through a screen before being collected in an attenuation tank (approximately 200kl).

• A flow-control system manages out-flow from the attenuation tank, so that flows directed to the Council Wastewater Treatment Plant comply with specified flow rate and quality variability levels.

• Wastewater within the attenuation tank is constantly aerated to minimise odour and assist BOD reduction.

• An automatic tank wash system washes the tank floor and walls clean.

• The wastewater system is continuously monitored via a SCADA (Supervisory Control And Data Acquisition) system to measure water quality parameters and inflows.

• The site will be inspected regularly.

A letter from Huon Valley Council, included in the supporting documentation, confirms that the Ranelagh Wastewater Treatment plant is able to receive the increased liquid effluent from the proposal.

Estimated values for wastewater quality and flow rates from the supporting documentation are replicated in Appendix 2.


No public submissions were received. Comments received from the Environment Division’s Wastewater Specialist were that the increase in trade waste to the Ranelagh Wastewater Treatment Plant was satisfactory.


Liquid effluent is an issue for the proposal, as a greater level of discharge is anticipated with increased in operations at the site. Council has confirmed that the Ranelagh Wastewater Treatment Plant is able to receive the increased level of effluent from the proposed expansions. The management strategies for effluent treatment proposed in the supporting document are considered adequate, and should enable effluent to be effectively managed at the site. To aid the management of liquid effluent treatment, it is recommended that the permit include the standard condition that solid matter be prevented by all reasonable means from entering wastewater streams, including effective screening at points of ingress, implementation of comprehensive operating procedures and training, and good housekeeping (E1) and that discharged wastewater must comply with the Trade Waste Agreement and the requirements of the sewerage system operator (E2). To ensure commitments are complied with, it is recommended that the permit contain a standard condition that the activity be carried out in accordance with the commitments made in the supporting documentation (G7). The Wastewater Specialist raised concerns about the delivery of increased loads to the Ranelagh Wastewater Treatment Plant which is not fully compliant. It is recommended that this matter be taken up separately with the Wastewater Treatment Plant operator. With the approval of these recommendations, effluent treatment is considered adequate.

Issue 3

Solid waste disposal


Odour and environmental nuisance from inappropriate disposal.


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• Fish heads, skin, fat, frames and other wastes are collected in sealed insulated bins and held in the waste chillers.

• Waste is then collected by a third party operator and transported to Triabunna for value-added processing into fish oil and fish meal.

There is no anticipated change from current practices of waste storage and removal other than a small increase in quantity.


No public representations were received. Comments received from Environment Division’s Food and Textiles Specialist specified that the permit should limit the holding of unrefrigerated fish waste on site to 24 hours (3 days if refrigerated).


Odour and health issues are potential issues associated with the disposal of solid waste. These issues are managed effectively by the current disposal system at the site, and there have been no recent complaints regarding odour or the disposal of waste from the site. Solid waste disposal is unlikely to be an issue for the site, as the company will apply the same methods that it uses in its current practices.

To manage solid waste, it is recommended that the permit contain the standard condition that fish waste and putrescible material be kept in leak-proof, lidded containers that must be kept closed wherever practicable; and that containers holding waste must be refrigerated within eight hours of generation and removed from the site within 24 hours of generation unless frozen (S1). It is recommended that the permit specify where fish waste and fish processing by-product can be disposed. A standard condition is recommended that waste can only be disposed by removal to an approved secondary processing facility, another site of beneficial use or an approved waste depot (S2). To manage the transport of waste, it is recommended that the permit contain the standard condition that the permit holder ensures that wastes are transported by a holder of a current waste transport business Environment Protection Notice (S3).

With the approval of these recommendations, management provisions for solid waste disposal are considered adequate.

Issue 4

Noise


Nuisance to nearby residences due to noise from operations and associated transport.


The proposed expansion will use polyisocyanurate panelling which will assist in reducing noise. New production equipment will be installed within the expanded processing building, and there will be no material change to the externally located equipment (which is predominantly used in refrigeration). Shift timing and the timing of deliveries and despatch are not expected to change with the proposal.


No public comments were received. Comments from the Environment Division Noise Specialist were that the permit should define noise emission limits from the site and that a noise survey should be completed once commissioning has concluded.


Noise is a potential issue for the proposal as incrementally greater noise emissions are likely to be generated following expansion. Expanding production will increase truck movements, employee


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Issue 5

Decommissioning and Rehabilitation


Potential degradation and contamination.


No management measures were proposed for this issue.


No public or agency comments were received on this issue.


Decommissioning and rehabilitation are not considered to be pressing environmental concerns, as the proponent has indicated an intent to expand production and activity in the future. However it is recommended that the permit contain conditions relating to decommissioning and rehabilitation should unforeseeable changes occur. It is recommended that the permit contain the standard conditions that the Director be notified within 14 days of permanent cessation of the activity (DC1); that a draft Decommissioning and Rehabilitation Plan be submitted for approval within 30 days of the Director being notified of the likely cessation of operations (DC2); and that the land must be rehabilitated upon permanent cessation of the activity and include stabilisation of all land surfaces, removal or mitigation of all environmental hazards and decommissioning of any equipment that is not sold (DC3).

With the approval of these conditions, decommissioning and rehabilitation is considered adequate.

transport activity and will require the installation of more machinery; which may each contribute to elevated noise emissions from the site. Historically, the factory has not received any noise complaints, and it is considered that with management strategies, noise emissions can be adequately controlled.

It is recommended that the permit specify emission limits to control noise emissions during sensitive periods. A non-standard condition is recommended specifying noise be limited to 55 dB(A) between 0700 hours and 1900 hours, and 45 dB(A) between 1900 hours and 0700 hours (N1). A noise limit of 55 dB(A) during daytime hours essentially follows on from previous permit conditions and is likely to be higher than the current operating performance. The otherwise ambient noise will be relatively high due to the proximity of the highway and this figure is considered reasonable in the first instance, thus the 55 dB(A) limit. However it is appropriate to review the current acoustic situation, and it is recommended that the permit contain the standard conditions that a noise survey be completed six months from granting of the permit, incorporating specific survey requirements (N2), and that the survey must be completed within 30 days from the date the survey is completed and is formatted according to essential requirements (N3). The site currently operates under noise management Condition N4 of EPN 529/1 which limits the arrival and departure of truck movements to between 0700 and 2200 hours. Tassal have indicated that there a no anticipated changes in the timing of deliveries and despatch following expansion, and it is therefore recommended that this condition be included as a non-standard condition in the new permit (N4). By limiting truck activity to between these hours, the acoustic impact and sleep disturbance to neighbouring landowners is minimised.

With the approval of these recommendations, management provisions for noise emissions are considered adequate.


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7 Conclusions

The Environment Division is of the view that:

(i) the RMPS and EMPCS objectives have been duly and properly pursued in the assessment of the proposal; and

(ii) the assessment of the proposal has been undertaken in accordance with the Environmental Impact Assessment Principles; and

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

This assessment has been based upon the information provided by the proponent in the permit application and the supporting documentation.

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

It is concluded that the proposal is capable of being managed in an environmentally acceptable manner such that it is unlikely that the RMPS and EMPCS objectives would be compromised, provided that the recommendations made in this report are satisfactorily implemented, including the commitments made by the proponent in the supporting documentation.

8 References

Carter, S. (May 2009). Tassal Group Ltd Huonville Plant – Wood Fired Fish Smoker Kilns Air Quality Impact Study.

Daley, B. (15 April 2009). Additional matters to be addressed in order for the Environment Protection Authority to complete its assessment of Tassal’s proposed expansion of the Huonville processing facility – Final.

GHD (March 2009). Tassal Huonville Expansion - Development Application Supporting Report.


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9 Summary of appendices

Appendix 1 Summary of issues raised by public and agency submissions

Appendix 2 Wastewater and Air Quality Estimations

Appendix 3 Proposed permit conditions


Appendices

Appendix 1 Summary of issues raised by public and agency submissions

No representations were received during the public comment period. Issues raised by agency submissions are summarised in Table 3.

Table 3 Summary of agency issues

Referral agency Issues and comments

Public and Environmental Health Service (DHHS) • Documentation adequately considers issues that may impact upon public health and safety, particularly odour and smoke emissions.

• It is essential that the existing buffer zone between the factory and the surrounding residential development is maintained to ensure that potential nuisances from noise and/or odour nuisance are minimised.

Air Modelling Specialist, Environment Division (DEPHA)

• Further information is required regarding the emission of particulates to air.

• In-stack emission limits specified in the Environment Protection Policy (Air Quality) 2004 must be achieved.

• Potential impacts of air emissions beyond the boundary of the premises and at nearby sensitive uses should be assessed against the National Environment Protection Measure (Air Quality) standard for PM10 and the Environment Protection Policy (Air Quality) 2004.

• Information about how potential air impacts will be managed should be provided.

• The above information should be developed on the basis of atmospheric dispersion modelling. Modelling must comply with the Draft Atmospheric Dispersion Modelling Requirements.

• Clarification is needed that the investigation has been conducted on the basis of atmospheric dispersion modelling, and that the EPA will be provided with the final modelling report for their comment.

• Clarification is required that preliminary results from the investigation have indicated that air impacts can be managed via the installation of best best practice smoke emission reduction technology on existing smoke ovens and the proposed new installations.

• Further detail is required demonstrating that relevant in-stack and ambient air quality standards will be achieved using best practice smoke emission reduction technology for the existing smoke ovens and proposed new installations.

• Clarification is required that the EPA will be consulted throughout the design, trial and commissioning of the smoke abatement


Appendices

technology.

Noise Specialist, Environment Division (DEPHA) • The ‘impact for noise’ is likely to be fairly correct given the type of orientation and distance to the nearest residence.

• At some stage, a day/night time noise survey should be carried out to justify the limits in condition N1; i.e. 55 dB(A) in the daytime and 45 dB(A) at night - essentially as measured at the nearest residence. This should be done sooner rather than later and then the results are available for consideration for the extra expansion. This noise survey would be to provide details of the current ambient acoustic environment and an estimate of the current noise levels resulting from the operation. It is suggested that this requirement would be provided to the company as an additional condition in their EPN along the lines of what is provided in standard conditions for noise surveys and subsequent report.

Food and Textiles Specialist, Environment Division (DEPHA)

• Further information is required in relation to the discharge of liquids (including to sewer). Details of the nature of the discharge including estimated volume, flow rates, discharge patterns and characteristics (Biological Oxygen Demand, total Nitrogen, total Phosphorous, total suspended solids, and oil and grease) should be provided.

• An outline of planned pre-treatment systems at the Tassal premises needs to be provided, including a description of proposed works and associated timeframes.

• Details of any proposed effluent treatment or water monitoring activities are required.

• The holding of unrefrigerated fish waste on site should be limited to 24 hours and 3 days if refrigerated.

Wastewater Specialist, Environment Division (DEPHA)

• An outline of planned pre-treatment systems at the Tassal premises and / or modifications to the Ranelagh WWTP to deal with the additional trade waste needs to be provided, including a description of proposed works and associated timelines.

• The proponent needs to detail how the increased hydraulic and organic trade waste load discharged to sewer will affect the receiving Wastewater Treatment Plant (WWTP). The information submitted must adequately demonstrate that the Ranelagh WWTP can treat the additional load without negative impacts on plant performance. In this context, the current performance of the Ranelagh WWTP against the specified emission limits needs to be considered.


Appendices

Appendix 2 Wastewater and Air Quality Estimations

Table 4. Wastewater parameters and estimated values (replicated from supporting documentation).

Projected Parameter Current Sep-10

Flow (average) kl/d 87 118 Flow (max) kl/d 117 127 Flow (min) kl/d 66 98 BOD mg/l 1220 1220 TSS mg/l 664 650 pH 8.4 8.4 TKN mg/l 112 112 EC uS/cm 7500 7500

Table 6.1 of the Air Quality Study (replicated from supporting documentation)


Appendices

Appendix 3 Proposed permit conditions

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