Appendix F Material Safety Data Sheet (MSDS)€¦ · Works Approval Application ... materials including: manure, spent bedding from chicken farms, rice hulls, wheat straw and plant

T h e G o o d D i r t C o m p a n y 79 | P a g eW o r k s A p p r o v a l A p p l i c a t i o nJ u l y 2 0 1 9

Appendix F Material Safety Data Sheet (MSDS)

ABN 88 791 901 688 Postal Address Email 1403 Mt Mercer Rd [email protected] MEREDITH

Materials Safety Data Sheet

Composts, soil conditioners, animal manures & other organic materials

The dust and mists (bio aerosols) from these products are hazardous

according to the guidelines of Worksafe Australia

Identification

Product Name: - Compost

- Bokashi Fert

- Farm Compost

- Chicken Manure

UN Number: none allocated

Dangerous Goods Class: none allocated

Subsidiary Risk: none allocated

Hazchem code: none allocated

Poisons Schedule Number: none allocated

Use: Used as agricultural fertiliser and soil conditioner

Physical Description and Properties:

Appearance: brown to dark blend of natural organic and mineral substances

Odour: non-specific “earthy” odour

Boiling Point: not applicable

Melting Point: not applicable

Vapour Pressure: not applicable

Flashpoint: not applicable

Specific Gravity (water=1) varies according to composition and moisture content

Molecular Weight: not applicable

Solubility in water: not applicable

pH:

5.0 to 7.5

Ingredients:

Composts, organic fertiliser and soil conditioners are made by blending naturally occurring

materials including: manure, spent bedding from chicken farms, rice hulls, wheat straw and

plant mulch. The materials contain living micro-organisms including bacteria, fungi and

protozoa.


Health Hazard Information Acute health effects:

Swallowed:

Unlikely under normal conditions and procedures. Swallowing compost and organic

materials may cause abdominal discomfort and risk of intestinal infections.

Eye:

The dust and or liquid mist (bio aerosols) may be irritating to eyes resulting in redness,

watering or eye infection.

Skin:

Skin contact with these products and their dusts may result in skin irritation and in some

cases itching and dermatitis.

Inhaled:

Inhalation of dust and or liquid mists may irritate, inflame or sensitise the nose, throat and

lungs and exacerbate pre-existing medical conditions such as asthma.

Chronic health effects:

All people working with composts, landscaping and horticultural products should take

adequate measures to protect themselves from possible health effects and should ensure

they are protected from tetanus. Repeated inhalation from dust and liquid mist from these

products may result in respiratory irritation, inflammation, hay fever, asthma and

pneumonia-like symptoms.

First Aid:

Swallowed:

Give water to drink and seek medical attention if any abdominal symptoms persist.

Eyes:

Flush eyes with water and seek medical attention if irritation persists.

Skin:

Wash thoroughly with soap and water

Inhaled:

Remove to fresh air


Precautions for use

Exposure Standards

Worksafe Australia Exposure Standard

There is no specific standard for composts and potting mixes

The Good Dirt Company Pty Ltd recommends:

Keep exposure to dust and liquid mist as low as is practical during handling.

Engineering controls:

All work with these products should be carried out so as to avoid skin contact and minimise

exposure to dust and liquid mist.

Respiratory protection:

Avoid breathing dust and mist from these products. Wear an approved respirator for

particulates which conform with AS/NZS 1715 and 1716 when exposed to dust and mist.

Skin protection:

Wear standard gloves AS 2161, long sleeved shirt and trousers and boots. Launder clothes

regularly and wash skin with soap and water.

Eye protection:

Wear non fogging dust resistant safety glasses AS/NZS 1336 if risk of dust and mist.

Flammability:

Not flammable.

Contact Point Further information may be obtained by contacting The Good Dirt Company on:

Dugald: 0409 889 250 or Rachel: 0400 916 902

Emergency Telephone:

Poisons Information Centre: 13 11 26

Disclaimer: The information contained in this MSDS is based on data that to the best of our knowledge was accurate at the

time of preparation. No responsibility accepted for errors or omissions. Users are advised to determine themselves as to

the suitability of this information in relation to their particular purpose and specific circumstance. Since the information

contained in this MSDS may be applied under conditions beyond our control, no responsibility can be accepted by us for

any loss or damage caused by any persons acting or refraining from action as a result of this information.

Issue Date: 1/10/2018


Appendix G Greenhouse Assessment Report (GHD, 2019)

Good Dirt Company

GHG Assessment Report

June 2019

GHD | Report for Good Dirt Company – GHG Assessment, 3137010 | i

Executive summary

GHD Pty Ltd has been engaged by Good Dirt Company to conduct a desktop greenhouse gas

(GHG) assessment of the potential composting facility, situated at 1403 Mount Mercer Road,

Meredith, Victoria.

The assessment estimates Scope 1 and Scope 2 emissions associated with the operation of the

facility. The main emission sources identified that are associated with the operation of the

proposed facility include:

Emissions directly related to composting activities (Scope 1)

Combustion of diesel fuel for the operation of heavy machinery (Scope 1)

Table 1 Summary of annual GHG emissions

Process Step Scope 1 (tonnes CO2 e / annum)

Scope 2 (tonnes CO2 e / annum)

Total Amount (tonnes CO2 e / annum)

Emissions from composting activities 882 - 882

Emissions from operation of heavy equipment

121 - 121

Total (tonnes CO2 e) 1003 0 1003

Given these estimated emissions, the project would not meet the facility threshold for Scope 1

or Scope 2 emissions of greenhouse gases. The Good Dirt Company would not be obligated to

register and report under the National Greenhouse and Energy Reporting Act 2007 (NGER Act).

GHD | Report for Good Dirt Company – GHG Assessment, 3137010 | ii

Table of contents

Executive summary .............................................................................................................................. i

1. Introduction ............................................................................................................................... 1

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

1.2 Scope of work ................................................................................................................. 1

1.3 Scope and limitations ...................................................................................................... 1

1.4 Assumptions.................................................................................................................... 1

2. Assessment methodology ......................................................................................................... 2

2.1 Greenhouse gases considered ........................................................................................ 2

3. Calculation of GHG emissions ................................................................................................... 4

3.1 GHG emissions from composting activities ...................................................................... 4

3.2 GHG emissions from combustion of diesel fuel ................................................................ 5

4. Assessment results ................................................................................................................... 7

4.1 Predicted project emissions ............................................................................................. 7

4.2 Impact assessment ......................................................................................................... 7

5. Conclusion ................................................................................................................................ 8

6. References ............................................................................................................................... 9

Table index

Table 1 Summary of annual GHG emissions ................................................................................. i

Table 2 Greenhouse gases and 100 year global warming potentials ............................................. 2

Table 3 Equation factors – composting ......................................................................................... 4

Table 4 Equation factors – fuel consumption ................................................................................ 5

Table 5 Annual greenhouse gas emissions .................................................................................. 7

GHD | Report for Good Dirt Company – Assessment Report, 3137010 | 1

1. Introduction

1.1 Purpose of this report

GHD has been engaged by the Good Dirt Company to provide a high level greenhouse gas

assessment of the potential composting facility, located at 1403 Mount Mercer Road, Meredith,

Victoria.

1.2 Scope of work

The following tasks were undertaken as part of this GHG assessment:

1. Consider total energy use and GHG emission calculation based upon data provided by

client

2. Undertake total Greenhouse Gas (GHG) emission calculations based upon the yearly

electricity consumption, amount and type of fuel used and quantity of chicken manure

composted in the operations area

3. Use of standard GHG emission factors for all the calculations

4. Short report on the analyses conducted above

1.3 Scope and limitations

This report has been prepared by GHD for Good Dirt Company and may only be used and

relied on by Good Dirt Company for the purpose agreed between GHD and the Good Dirt

Company as set out in section 1.1 of this report.

GHD otherwise disclaims responsibility to any person other than Good Dirt Company 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 (sections 1.4 and 3). GHD disclaims liability arising from

any of the assumptions being incorrect.

GHD has prepared this report on the basis of information provided by Good Dirt Company 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.

1.4 Assumptions

The following general assumptions have been made as part of this GHG report:

Client supplied figures for Fuel, power usage, composting throughput are accurate

Peak, intermediate, and off peak periods are accurate


2. Assessment methodology


composting facility.

Scope 1 emissions are the release of greenhouse gases into the atmosphere as a direct result

of an activity, or series of activities (including ancillary activities) that constitute the facility.

These are considered to be ‘direct’ emissions.

Scope 2 emissions are the release of greenhouse gases into the atmosphere as a direct result

of one or more activities that generate electricity, heating, cooling or steam that is consumed by

the facility but do not form part of the facility. These are considered to be ‘indirect emissions’.

Factors used as input to calculations have come from the following sources:

Provided by Good Dirt Company

National Greenhouse and Energy Reporting (Measurement) Determination 2008 as

amended (Commonwealth of Australia) (July 2018) (‘Measurement Determination 2018’).

National Greenhouse Account Factors (July 2018)

Given that the facility is not connected to the mains power, there are no Scope 2 emissions

associated with the project.

The main emission sources identified associated with the operation of the proposed facility

include:

Emissions directly related to composting activities (Scope 1)

Combustion of diesel fuel for the operation of heavy machinery and equipment (Scope 1)

The GHG emission estimates associated with composting activities and combustion of diesel

fuel for the facility were calculated in accordance with the current techniques set out in the

Clean Energy Regulator’s (CER’s)) National Greenhouse and Energy Reporting (Measurement)

Determination 2008 as amended (Commonwealth of Australia).

2.1 Greenhouse gases considered

The greenhouse gases considered in this assessment and the corresponding global warming

potential (GWP) for each GHG are listed in Table 2. The GWPs from the Intergovernmental

Panel on Climate Change (IPCC) Fifth Assessment report were used in this assessment for

consistency with the IPCC guidelines.

Table 2 Greenhouse gases and 100 year global warming potentials

Greenhouse gas Global warming potential

Carbon dioxide (CO2) 1

Methane (CH4) 28

Nitrous Oxide (N2O) 265


Use of the Measurement Determination 2018 is in accordance with EPA Victoria requirements

and guidance provided in EPA Victoria’s Protocol for Environmental Management –

Greenhouse Gas Emissions and Energy Efficiency in Industry (PEM), Publication 824 (EPA

2002).

The annual emissions from the facility are calculated from fuel usage estimate data provided by

Good Dirt Company.


3. Calculation of GHG emissions

GHG emissions from composting and the use of heavy equipment were calculated. A number of

assumptions were used for the process calculations and these are considered preliminary. The

assumptions included:

There is no recovery system for gaseous emissions

All fuel for heavy machinery operation is diesel

All heavy equipment conforms to Euro I design standards

Diesel fuel to power a small generator used for welding is considered negligible

Calculations have utilised the Greenhouse Gas Global Warming Potential (GWP) provided in

Appendix 1 of the National Greenhouse Accounts Factors (July 2018) Department of

Environment and Energy.

3.1 GHG emissions from composting activities

The following method taken from the Measurement Determination 2018 is used for estimating

emissions from the treatment of solid waste. Given the high level of this assessment, this

method was deemed appropriate:

Where:

Eij - is the emissions of the gas type (j), being methane or nitrous oxide, released from the

facility during the year from the biological treatment type (i) measured in CO2-e tonnes.

EFi - is the emission factor for each gas type (j), being methane or nitrous oxide, released from

the biological treatment type (i) measured in tonnes of CO2-e per tonne of waste processed.

Mi - is the mass of waste treated by biological treatment type (i) during the year measured in

tonnes of waste.

R is:

a. For the gas type methane—the total amount of methane recovered during the year at the

facility from the biological treatment of solid waste measured in tonnes of CO2-e

b. For the gas type nitrous oxide—zero

It has been assumed that the Good Dirt Company has no recovery system in place, as such R

will be equal to 0.

Table 3 Equation factors – composting

Factor Unit Value Source

Mi tpa 18,000 Provided by Good Dirt Company

R tpa 0 Assumption

EF

t CO2 -e/t

waste treated

0.019 (CH4) Division 5.2.6 of Measurement Determination 2018

0.029 (N2O) Division 5.2.6 of Measurement Determination 2018


3.2 GHG emissions from combustion of diesel fuel

The following method taken from the Measurement Determination 2018 is used for estimating

emissions released from combustion of a liquid fuel:

Where:

Eij - is the emissions of gas type (j), being carbon dioxide, methane or nitrous oxide, from each

gaseous fuel type (i) released from the operation of the facility during the year measured in

CO2-e tonnes.

Qi - is the quantity of fuel type (i) combusted, whether for stationary energy purposes or

transport energy purposes, from the operation of the facility during the year measured in cubic

metres or gigajoules and estimated under Division 2.4.6.

ECi - is the energy content factor of fuel type (i) estimated under section 6.5.

EFijoxec - is the emission factor for each gas type (j) released during the year (which includes the

effect of an oxidation factor) measured in kilograms CO2-e per gigajoule of fuel type (i)

according to source as mentioned in:

c. for stationary energy purposes—Part 3 of Schedule 1

d. for transport energy purposes – Part 4.1 of Schedule 1

The GHG emissions associated with fuel combustion for electricity generation were based on

the fuel consumption estimates provided by the Good Dirt Company. Since the make and model

of the heavy equipment to be used is unknown, it has been assumed that they all conform to

Euro I standards. This is a conservative approach to calculating transport emissions and

provides a worst-case estimate.

Table 4 Equation factors – fuel consumption

Factor Unit Value Source

Qi kL 44.5 Provided by Good Dirt Company

ECi GJ/kL 38.6 Schedule 1 Part 4 of Measurement Determination 2018

EF kg CO2 -e/GJ

69.9 (CO2) Schedule 1 Part 4 of Measurement Determination 2018

0.2 (CH4) Schedule 1 Part 4 of Measurement Determination 2018

0.5 (N2O) Schedule 1 Part 4 of Measurement Determination 2018

i i ijoxec

ij

Q C EFE =

1 000


4. Assessment results

4.1 Predicted project emissions

The estimated greenhouse gas emissions are presented in Table 5.

Table 5 Annual greenhouse gas emissions

Process Step Scope 1 (tonnes CO2 e / annum)

Scope 2 (tonnes CO2 e / annum)

Total Amount (tonnes CO2 e / annum)

Emissions from composting activities 864 - 882

Emissions from operation of heavy equipment and welding plant.

121 - 121

Total (tonnes CO2 e) 1003 0 1003

Given these estimated emissions, the project would not meet the facility threshold for Scope 1

or Scope 2 emissions of greenhouse gases. The Good Dirt Company would not be obligated to

register and report under the National Greenhouse and Energy Reporting Act 2007 (NGER Act).

4.2 Impact assessment

Victoria’s emissions data was sourced from the Department of the Environment and Energy,

State and Territory Greenhouse Gas Inventories 2016, accessed 11/04/19. Data for 2016 was

the most recent available at the time of this report.

Based on currently available data, the worst case annual GHG emissions for the project are

estimated as approximately 0.001 Mt CO2-e per annum (refer to Table 5). Compared with the

estimated GHG emissions for Victoria’s agricultural sector in 2016 of 16.3 Mt CO2-e, the

average annual emissions from the project are insignificant.


5. Conclusion

This report analyses the greenhouse gas impact of the Good Dirt Company’s potential

composting facility, located at 1403 Mount Mercer Road, Meredith, Victoria.


facility.

The composting facility is estimated to be responsible for 1003 t CO2-e per annum.

Given these predicted emissions, the project would not be obligated to register and report under

the National Greenhouse and Energy Reporting Act 2007 (NGER Act) and are considered

insignificant when compared with the estimated GHG emissions for Victoria’s agricultural sector

in 2016 of 16.3 Mt CO2-e.


6. References

National Greenhouse and Energy Reporting (Measurement) Determination 2008, July, 2018

Compilation No. 10, F2018C00431

National Greenhouse and Energy Reporting Act 2007 (NGER Act), December 18, Compilation

No. 19, C2019C00044

Department of the Environment and Energy, 2018: National Greenhouse Accounts Factors –

Australian National Greenhouse Accounts, July 2018

IPCC, 2007: Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and

III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Core

Writing Team, Pachauri, R.K and Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, 104 pp.

EPA, 2002: Protocol for Environmental Management – Greenhouse Gas Emissions and Energy

Efficiency in Industry (PEM), Publication 824 (EPA 2002)

GHD

180 Lonsdale Street Melbourne Victoria 3000 T: (03) 8687 8000 F: (03) 8687 8111 E: [email protected]

© GHD 2019

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.

3137010-88443/https://projects.ghd.com/oc/Victoria3/organiccompostingair/Delivery/Documents/3137010-REP-GDC_Organic_Composting_GHG Assessment.docx

Document Status

Revision Author Reviewer Approved for Issue

Name Signature Name Signature Date

DRAFT 12/04/2019

0 Jesse Finkelstein

Shashank Pandey

Signed on original

Craig McVie

16/04/2019

1 Jesse Finkelstein

Shashank Pandey

Signed on original

Craig McVie

22/06/2019

www.ghd.com

T h e G o o d D i r t C o m p a n y 81 | P a g e W o r k s A p p r o v a l A p p l i c a t i o n J u l y 2 0 1 9

Appendix H Buffer Risk Assessment (GHD, 2019)

The Good Dirt Company

Organic Composting Facility

Buffer Risk Assessment

April 2019

GHD | Report for The Good Dirt Company - Organic Composting Facility, 3137010 | i

Table of contents

1. Introduction ............................................................................................................................... 1

1.1 Overview ......................................................................................................................... 1


1.3 Limitations ....................................................................................................................... 1

1.4 Scope of works ................................................................................................................ 2

1.5 Assumptions.................................................................................................................... 2

2. Site description ......................................................................................................................... 3

2.1 Site location .................................................................................................................... 3

2.2 Sensitive receptors .......................................................................................................... 3

2.3 Site process .................................................................................................................... 5

2.4 Potential odour and dust sources ..................................................................................... 6

2.5 Complaint history............................................................................................................. 7

3. Relevant policies and guidelines ................................................................................................ 9

3.1 Victorian State Environmental Protection Policy (Air Quality Management) (SEPP AQM) ................................................................................................................... 9

3.2 EPA Publication 1518, Recommended Separation Distances for Industrial Residual Air Emissions .................................................................................................... 9

3.3 EPA Publication 1588.1, Designing, constructing and operating composting facilities ........................................................................................................................... 9

4. Default buffer assessment ....................................................................................................... 10

5. Risk assessment ..................................................................................................................... 12

5.1 Emission potential scenarios ......................................................................................... 12

5.2 Site specific meteorology ............................................................................................... 15

5.3 Directional buffer ........................................................................................................... 18

6. Conclusions ............................................................................................................................ 23

Table index

Table 1 Emission potential scenarios ......................................................................................... 14

Table 2 Emission scenarios ....................................................................................................... 15

GHD | Report for The Good Dirt Company - Organic Composting Facility, 3137010 | ii

Figure index

Figure 1 Site location and receptors .............................................................................................. 4

Figure 2 Site features ................................................................................................................... 8

Figure 3 Default buffer................................................................................................................. 11

Figure 4 Annual wind rose for She Oaks...................................................................................... 16

Figure 5 Emission potential scenario wind rose ........................................................................... 17

Figure 6 High emission potential scenario directional buffer ......................................................... 20

Figure 7 Medium emission potential scenario directional buffer.................................................... 21

Figure 8 Low emission potential scenario directional buffer.......................................................... 22

GHD | Report for The Good Dirt Company - Organic Composting Facility, 3137010 | 1

1. Introduction

1.1 Overview

GHD has been engaged by The Good Dirt Company (GDC) to provide an assessment of

potential air emission impacts from a composting facility located on Tall Tree Road west of

Lethbridge, Victoria.

The assessment was undertaken following discussions with EPA regarding the need for a buffer

assessment for the GDC site. Air dispersion modelling in the form of ‘directional buffers’ was

undertaken to determine the likely direction of air emissions from the GDC site during different

operating times.


The purpose of this report is to provide an assessment of potential air emission impacts from

the composting facility in the form of an environmental risk assessment. The appropriate buffers

for the GDC site, based on a future operating capacity of 18,000 tpa accounting for local

meteorological conditions at operating times will also be assessed.

The findings, conclusions and recommendations of this assessment should be read in

conjunction with the limitations presented in Section 1.3.

1.3 Limitations

This report: has been prepared by GHD for The Good Dirt Company and may only be used and relied on by The Good Dirt Company for the purpose agreed between GHD and the The Good Dirt Company as set out in section 1.2 of this report.

GHD otherwise disclaims responsibility to any person other than The Good Dirt Company 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 (refer section 1.5 of 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 The Good Dirt Company 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.


1.4 Scope of works

The scope of works for this report included the following:

Site visit

Assess EPA default buffers in accordance with Publication 1588.1 (2017)

Undertake a meteorological analysis using data obtained from the She Oaks Bureau of

Meteorology (BoM) station to determine air dispersion characteristics at the site

Conduct an environmental risk assessment to determine the likely offsite impacts from site

processes during different time periods

Create directional buffers in response to the meteorological analysis and environmental risk

assessment conducted

1.5 Assumptions

The following assumptions were used in this report:

Data obtained from the She Oaks Bureau of Meteorology Automatic Weather Station

(AWS) is deemed to be representative of the meteorology at the GDC site

For the emissions scenarios, it is assumed that greater movement/ disturbance of

composting material will increase the potential for odour and dust to be generated

Emissions scenarios were created using operation periods supplied by the client, which

GHD assume are correct

The site activity boundary used for dispersion modelling is based on site process areas

provided by the client, which GHD assume are correct


2. Site description

2.1 Site location

The GDC site is located approximately 6 km west of the town centre of Lethbridge and 7 km

north of the town centre of Teesdale, Victoria. The activity area of the site (area where

operations occur) is approximately 7.72 ha. The GDC site is located within the Golden Plains

Food Production Precinct, which was established for the protection of agricultural land for long

term investment in agribusiness. The precinct covers 4,000 ha and is designated for intensive

agriculture. Land use zoning surrounding the site is predominantly farming, with the exception of

a public conservation and resource reserve, and special use zone adjacent to the site’s western

boundary.

Land uses surrounding the GDC site include egg, broiler and pig production facilities. Other

nearby land uses include a veterinary incinerator approximately 800 m to the south west and

chicken farms more than 2.2 km to the south east and north east.

2.2 Sensitive receptors

The nearest sensitive receptor to the site is a residential dwelling which is located approximately

1.3 km south-southeast from the facility (Figure 1).The next closest sensitive receptors are rural

residences approximately 2.7 km and 5.5 km from the site.

Indicative Site Boundary Sensitive receptor

LEGEND

N:\AU\Melbourne\Projects\31\37010\GIS\Maps\Working\Site.qgz

Map Projection: Universal Transverse MercatorHorizontal Datum: Geocentric Datum of Australia 1994

Grid: Map Grid Of Australia, Zone 55

Paper Size A4

FIGURE 1

13/03/2018-3136718

Date.Revision No.

Project No.The Good Dirt Company

Lethbridge Composting Facility

Site Location andReceptors

N:\AU\Melbourne\Projects\31\36718\GIS\Maps\Working2018. While GHD has taken care to ensure the accuracy of this product, GHD and DATA CUSTODIAN(S), make no representations or warranties about its accuracy, completeness or suitability for any particular purpose. GHD and DATACUSTODIAN(S) 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 wayand for any reason. Google Earth Imagery 2018. Created by: DC

Figure 1 Site location and receptors


2.3 Site process

The following two sections outline the existing operation at the composting facility and the

proposed future operation with an increase in receipt of chicken litter and broiler bedding

material.

2.3.1 Current operation

The existing GDC facility currently receives and stockpiles approximately 12,000 tonnes per

annum of chicken litter and broiler bedding from nearby egg and broiler farms (locally sourced).

The material is composted in open windrows over 4 ha, before being sold as a high value soil

conditioner.

Feedstock sources

GDC receives two types of material as feedstock:

Chicken litter is delivered from Farm Pride Foods (FPF).

Broiler bedding is delivered from Rural Funds Management (RFM).

Process

The composting process is segmented into different areas on the site as shown in Figure 2 and

described below:

Receival and aging of feedstock.

– Feedstock from FPF is delivered every second day to a designated area of 2 hectares

at the north of the site. The chicken litter is tipped from trucks into 100 m long wind

rows each 2 m apart. It takes approximately 2 weeks to complete one wind row. Ten

centimetres of aged dry broiler bedding is used to cover litter at the end of each

delivery day.

– Feedstock from RFM is delivered over an 8 day period every ~2.5 months to a

designated area of 2 hectares at the north of the site. The broiler bedding is allowed to

age undisturbed for 6 weeks. Delivery rounds occur during the months of March, May,

August, October, and December.

Mixing and composting of feedstock

– Broiler bedding and chicken litter are blended at a ratio of 1:1 m3 and wind rows are

formed

– Wind rows are turned via front end loader only approximately every 10 to 30 days to a

total of 5 turns during this process, which is approximately 8 to 10 weeks long. It is

during this stage the pasteurisation occurs

Aging and curing finished compost

– Wind rows are moved via front end loader to the curing area and stockpiled in 10 m x

100 m rows at a height of 5 m. The rows are stockpiled for a further 5 to 6 weeks to

age.


Onsite storage

Finished product is stored at the south of the site and remains there until the next peak

delivery period, with occasional screening and mixing operations during summer as

required. The two peak delivery periods at the GDC site are:

– Spring. September to October (3,000 t)

– Autumn. February to April (7,000 t)

During these periods, dust and bio aerosols are possible in this part of the site.

2.3.2 Future operation

Proposed future upgrades to GDC operations may include:

Receipt of an additional 6,000 tonnes per annum of chicken litter and broiler

bedding material (to a total of 10,500 tpa of litter and 8,000 tpa of bedding)

No change to current process method of mixing and composting activities at the site

2.4 Potential odour and dust sources

The following section outlines the potential dust and odour sources that have the potential to

cause offsite impacts if not managed adequately.

2.4.1 Fixed sources

The following fixed sources have the potential to emit odour and dust from the GDC site:

Feedstock windrows in the receival area

Windrows in the mixing/ composting area

Windrows in the curing area

Finished compost windrows in the loadout area

Of the fixed sources, the windrows in the receival and composting areas are expected to

generate the most odour, as the litter in these sources is freshest. As the feedstock is

pasteurised and matured (and dries out in the process) it is expected to generate less odour but

higher levels of dust, therefore windrows from the curing and loadout areas are expected to

generate a higher proportion of dust.

2.4.2 Operational sources

The following operations have the potential to generate odour and dust emissions from the GDC

site:

Turning stockpiles

Driving vehicles on unsealed surfaces within the site

Offloading feedstock from trucks

Loading finished product onto trucks

Of the operations, offloading feedstock from trucks and turning of stockpiles are expected to

generate the greatest proportion of odour, while loading finished product onto trucks and driving

on unsealed surfaces are expected to generate the greatest proportion of dust.


2.5 Complaint history

The past performance of the site is a good indicator as to whether the existing buffer is

appropriate and sufficient for protection of sensitive uses against loss of amenity.

Golden Plains Shire Council (Council) provided GDC with a record of complaints within the

locality dating back to 20101. Council were not able to provide complaints from earlier than

2010.

Council received one complaint in November 2017 which was related to the ‘burning of manure’.

The complaint was located in the Southern Part of the Food Production Precinct within which

GDC is located.

1 Email from Stuart Symes of Golden Plains Shire Council to Jacquelle Gorski of Sustainable Project Management, 29 March

2019.

Indicative Site Boundary

Receivals area (Broiler litter)

Receivals area (Chicken Manure -

Layers)

Mixing area

Composting and curing area

Finished product and loadout area

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Site features


Figure 2 Site features


3. Relevant policies and guidelines

The following section outlines the relevant polices and guidelines used for this assessment.

3.1 Victorian State Environmental Protection Policy (Air Quality

Management) (SEPP AQM)

This policy outlines the air quality objectives to be achieved by industries, including for odour.

Schedule A of the SEPP AQM states the averaging times and design criteria to be used for air

quality assessments.

3.2 EPA Publication 1518, Recommended Separation Distances

for Industrial Residual Air Emissions

EPA publication 1518 responds to the Environment Protection Act 1970 (EP) and to Victoria

Planning Provisions (VPP), specifically to the need for regulation and management of

separation distances from industries creating residual air emissions. A buffer distance can be

used to provide separation of sensitive land uses (i.e. residential, schools, hospitals) from

existing premises with the potential for offsite emissions (odour or dust) that can cause

disamenity in the event of an upset/malfunction. Under routine operations, any impact is to be

confined onsite so that an external buffer should not be required.

The purpose of the EPA separation distance guidelines (EPA Guidelines 1518)2 are to provide

recommended minimum separation distances between odour or dust emitting industrial land

uses and sensitive land uses to allow Industrial Residual Air Emissions (IRAEs) to dissipate

without adverse impacts on sensitive land uses.

Publication 1518 directs the reader to refer to further guidelines for composting facilities (EPA

Publication 1588.1).

3.3 EPA Publication 1588.1, Designing, constructing and

operating composting facilities

This guideline assists composting facilities in meeting the requirements of the SEPP AQM and

EPA publication 1518. The guideline specifies recommended separation distances, feedstock

related risk factors and best practice methods for siting and operation of a composting facility.

The guideline includes management measures to control dust and odour emissions from a

compost facility.

2 EPA Recommended Separation Distances for Industrial Residual Air Emissions, Publication 1518, March 2013


4. Default buffer assessment

Two default buffer distances have been assessed for the site, namely 1,300 m and 2,000 m.

The two buffers are presented in Figure 3 and have been scribed from the site activity boundary

(method 2 in EPA Publication 1588.1). The activity boundary is deemed more appropriate than

the site boundary, due to the nature of the odour sources being in a fixed location within the

site.

The 1,300 m buffer was calculated using Table 3 of EPA Publication 1588.1. The table specifies

separation distances for several composting plant sizes. An interpolation was made between

values given in the table to determine the separation distance appropriate for the future plant

capacity of 18,000 tpa. The subsequent value, rounded to the nearest hundred metres, is

1,300 m.

The 2,000 m buffer was also requested to be assessed by EPA following discussions with the

authority.

From Figure 3, it can be seen that the 1,300 m buffer does not encompass any sensitive

receptors. The 2,000 m buffer encompasses one sensitive receptor which is a residential

property, this is identified in Figure 3 as the red dot labelled ‘Receptor’. The other buildings

visible in the figure are egg and broiler farms.


Indicative Activity Boundary

Sensitive receptor

1300m default buffer

2000m default buffer

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Default buffer


Figure 3 Default buffer


5. Risk assessment

The EPA allows for a site-specific variation to the default buffer distance for a given industry so

long as certain criteria are met. Table 4 of the EPA 1518 guideline3 (refer to section 3.2)

specifies the 6 criteria which can be assessed in order to create a site-specific buffer variation.

These criteria are listed below:

1. Transitioning of the industry – If an industry has plans to transition out of the area in the

foreseeable future then a reduced buffer can be negotiated for those industries

2. Plant equipment and operation – If the plant has a high standard of emission technology or

has evidence of no upset or malfunctions occurring then a reduced buffer may be more

appropriate

3. Environmental risk assessment (ERA) – An ERA would need to be completed to assess

this option, this would require specific knowledge of process operations

4. Size of the plant – If the throughput is small compared to large examples within the same

industry then it may be possible to de-rate the buffers based on throughput

5. Topography or meteorology – If there are exceptional topographic or meteorological

characteristics which will affect dispersion of IRAEs

6. Likelihood of IRAEs – The likelihood of residual emissions from the identified industry would

need to be assessed once specific operational information was obtained regarding their

operations including how frequently upset conditions occur and if the assessment would be

required to utilise a detailed complaint history from the surrounding residential area.

GHD understands that GDC has variable rates of production and activity on site throughout the

year. Based on the information available to GHD, the site-specific criteria applicable include a

risk assessment, assessing the emission potential during different process operations

throughout the year and the subsequent change in the default buffer due to local meteorology

during these different periods in the form of ‘directional buffers’. The results of this analysis is

presented sections 5.1 to 5.3 below.

5.1 Emission potential scenarios

A risk assessment was undertaken to assess the potential for dust and odour to be emitted off

site, not taking into account relative amounts or concentrations of emissions. The risk of dust

and odour being emitted from site is primarily dependant on two factors: the type of operations

occurring at the site and the meteorology at the time of those operations. Based on the

information provided by GDC, GHD has identified the following operational periods and

subsequent emission potential scenarios at the site:

Peaks

– These periods occurs from September to October and again from February to April,

when large quantities of finished compost product are loaded onto trucks for export

from site. This activity has the potential to generate raised levels of dust and odour.

The frequency of loading activities during this period also heightens the potential for

emissions as material is likely to be left loose and potentially uncovered between

loads.

3 EPA publication 1518 (2013) Recommended separation distances for industrial residual air emissions


Intermediate

– This period occurs in summer (from November to January), when the compost product

is screened and mixed according to tailored specifications and customer demand.

Stockpiles are expected to be partially characteristic of both the peak and non-peak

periods.

Non-peak

– This period occurs in winter (from May to August) and involves fortnightly delivery of

feedstock; mixing, pasteurisation and composting of feedstock; and aging and curing of

feedstock. These processes involve limited turning of composting piles.

Meteorology

A diurnal variation in wind speed and direction is characteristic of the local meteorology. As

such, the risk of dust and odour emissions will vary due to the time of day. Daytime periods

have been adjusted to reflect operational hours between 7 am and 5 pm, while night time

periods correspond to the hours outside of daytime. Meteorology will also differ between

the seasons in which operational periods occur.

Table 1 presents the level of risk, in terms of possibility of odour and dust emissions occurring

from the facility, according to time of day and operational activities. The characteristics of the

risk categories are:

High

– Large amount of loose material expected on site.

– Stockpiles frequently disturbed (multiple times daily).

– Broken apart wind rows on site for extended periods (>2 hours) expected on most

days.

– Delivery of feedstock.

Medium

– Some loose material on site.

– Stockpiles disturbed most days, freshly turned stockpiles.

– Chance for uncovered stockpiles on some days.

– Delivery of feedstock.

Low

– Traces of loose material on site, most material well compacted.

– No onsite activity.

– Stockpiles on site are well covered.

– No delivery of feedstock.


Table 1 Emission potential scenarios

Meteorological period

Day (7 am to 5 pm) Night (5 pm to 7 am) O

pera

tion p

eriods

Peak

1

High Medium

Inte

rmedia

te2

High Low

Non-p

eak

3

Medium Low

1 Peak periods onsite occur at the load out area from September to October and from February to April.

2 Intermediate periods onsite occur from late spring to summer when operations at the load out area are

performed on demand.

3 Non-peak periods onsite occur from late autumn to winter, when routine operations mainly involve

delivery of compost materials.

The periods identified in Table 1 were used in the dispersion modelling software AERMOD to

create ‘directional buffers’ specific to each emission potential scenario at the site. For each

scenario, only the time periods identified for the selected emission potential scenario were given

emission rates. This results in the generation of a directional buffer specific to each emission

scenario. Table 2 describes the three model scenarios.


Table 2 Emission scenarios

Emission potential scenario Months selected Time selected

High September - April 7 am – 5 pm

Medium February - October Peak period: 5 pm to 7 am

Non-peak period: 7 am to 5 pm

Low May – August

November - January

5 pm – 7 am

5.2 Site specific meteorology

The local meteorology largely determines the pattern of off-site impact. The characterisation of

local wind patterns requires accurate site-representative hourly recordings of wind speed and

direction over a period of at least 12 months (one year).

GHD has access to high quality meteorological data (five years at 1-minute intervals) from the

She Oaks automatic weather station (AWS) operated by the Australian Bureau of Meteorology.

The She Oaks AWS has been in operation since 1990 and is located approximately 10 km from

the subject site. GHD has also accessed an AWS at Avalon airport (five years at 30-minute

intervals) for cloud data.

GHD selected the years 2014 – 2018 as it was the most recent period with a complete record

from the She Oaks AWS.

The effect of wind on dispersion patterns can be examined using the general wind climate and

atmospheric stability class distributions. The general wind climate at a site is most readily

displayed by means of wind rose plots, giving the incidence of winds from different directions for

various wind speed ranges.

The features of particular interest in this assessment are:

(i) the prevailing wind directions and

(ii) the relative incidence of more stable light wind conditions and

(iii) good dispersion condition winds over 5 m/s.

5.2.2 Long term wind patterns

Annual wind patterns at She Oaks are displayed in Figure 4 and show that:

The predominant annual average wind direction is from the north and north-northwest,

comprising 28% of all incident winds

The incidence of westerly winds (~10%) is significantly higher than easterlies occurring

~2% of the time

The average wind speed measured was 3.6 m/s

The observed wind speed distribution indicates that the largest proportion of high wind

speeds (> 6 m/s) are from the north and north-northwest, while the largest proportion of

light winds (<1.5 m/s) are also from these directions


Figure 4 Annual wind rose for She Oaks

5.2.3 Emission potential scenario wind patterns

Wind patterns at She Oaks BoM station for the emission potential scenarios in section 5.1 are

displayed in Figure 5 and show that:

During the high emission scenario, the predominant wind directions are from the north and

the southeast, at approximately equal proportions. 10% of incident winds are westerly,

compared with approximately 3% easterly winds and minimal winds from the northeast

sectors. The average wind speed is 3.5 m/s.

During the medium emission scenario, the predominant wind directions are north and north-

northwest, comprising approximately 30% of all incident winds. There is a low contribution

of incident winds from the east and south directions (<4% for any direction). The incidence

of west, west-northwest and northwest winds is approximately even at 10% for each

direction. The average wind speed is 3.71 m/s.

During the low emission scenario, the predominant wind directions are north and north-

northwest, comprising approximately 30% of all incident winds. The incidence of northeast

and southwest component winds is low (<5% for any direction). The incidence of southeast

component winds is approximately 3% higher than the medium emission scenario. The

average wind speed is 3.77 m/s.


High Emission Potential Scenario

(average wind speed = 3.50 m/s)

Legend

Medium Emission Potential Scenario


Low Emission Potential Scenario


Figure 5 Emission potential scenario wind rose


5.3 Directional buffer

5.3.1 Methodology

Section 9.2 of the EPA Publication 15184 allows for site-specific variation on the basis of

topographical or meteorological features which will affect dispersion of industrial residual air

emissions. GHD has developed an approach to provide directionally-dependent buffers on the

basis of the dispersive ability of the atmosphere, as assessed using atmospheric dispersion

modelling (Clarey & Pollock, 2004).

Where site-representative meteorological data is available, the direction of good and poor

dispersion can be identified as shown in Section 5.2Error! Reference source not found..

Further, if the five year dataset is configured into the dispersion modelling format then

dispersion modelling (using EPA regulatory model AERMOD) can be conducted using a

nominal air source emission rate to assess the directional change in the buffer extent from a

default radial buffer5. The directional buffer adapts the default radial buffer to take account of the

directions of good and poor dispersion – found from the meteorological data representative of

local conditions.

In the directions of poor dispersion the buffer is extended and in the directions of good

dispersion the buffer is retracted. The effect is to produce the same degree of protection from

exposure to impact as the default buffer but shaped by the local meteorology to represent a

more realistic site specific buffer in the event of a process upset.

5.3.2 Directional buffer results

The directional buffer analysis for the three emissions scenarios has been applied to the 1,300

m and 2,000 m default buffers.

High emission potential scenario

The directional buffer for the high emission potential scenario contracts to the southwest of the

site and has a relatively even spread in other directions (Figure 6). The buffer’s largest

extensions are towards the northeast and northwest of the site. The buffer has a larger northern

component than the other emission potential scenarios and a reduced extent to the south of the

site. The reduced southern extent is reflective of this emission scenario occurring in the spring-

autumn period, without the influence of the northeasterly component winds which occur in winter

(Figure 5). The 1,300 m buffer does not encompass any sensitive receptors, while the 2,000 m

buffer encompasses the receptor identified in Figure 1.

Medium emission potential scenario

The directional buffer for the medium emission potential scenario has a large extension to the

south of the site (approximately 2.5 km for the 1,300 m buffer and 4 km for the 2,000 m buffer),

which is reflective of a high incidence of northerly winds during the operating periods and time of

day periods in this scenario (Figure 7). This buffer also has notable spikes to the east and north-

northwest of the site. Both buffer distances encompass the receptor identified in Figure 1, which

is the proponent’s home.

4 EPA publication 1518 (2013) Recommended separation distances for industrial residual air emissions

5 Clarey P, Pollock T “Integrating Separation Distances with Dispersion Modelling” Enviro 04, 28 Mar – 1 April, Darling harbour,

Sydney


Low emission potential scenario

The directional buffer for the low emission potential scenario has a similar extent to the south as

the medium emission potential scenario, with the main difference being a slightly shorter extent

to the northwest and east (Figure 8). The extent of the buffer to the south is also increased

slightly from that of the medium emission potential scenario. Both buffer distances encompass

the receptor identified in Figure 1.



Sensitive receptor

1,300m directional buffer


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High emission potentialscenario directional

bufferN:\AU\Melbourne\Projects\31\37010\GIS\Maps\Working2019. While GHD has taken care to ensure the accuracy of this product, GHD and DATA CUSTODIAN(S), make no representations or warranties about its accuracy, completeness or suitability for any particular purpose. GHD and DATACUSTODIAN(S) 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 wayand for any reason. Google Earth Imagery 2018. Created by: DC

Figure 6 High emission potential scenario directional buffer



Sensitive receptor



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Medium emissionpotential scenariodirectional buffer


Figure 7 Medium emission potential scenario directional buffer



Sensitive receptor



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Low emission potentialscenario directional

bufferN:\AU\Melbourne\Projects\31\37010\GIS\Maps\Working2019. While GHD has taken care to ensure the accuracy of this product, GHD and DATA CUSTODIAN(S), make no representations or warranties about its accuracy, completeness or suitability for any particular purpose. GHD and DATACUSTODIAN(S) 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 wayand for any reason. Google Earth Imagery 2018. Created by: DC

Figure 8 Low emission potential scenario directional buffer


6. Conclusions

The directional buffers incorporating site-specific meteorology for various emission scenarios

are significantly different to the default buffers presented in section 4. Generally, the directional

buffers extend further to the south and contract to the west of the site.

Two distinct directional buffers can be concluded from the analysis in this report, namely:

During high emission potential periods, emissions are likely to be dispersed in relatively

even proportions between the northwest and eastern directions in the event of an upset.

Emissions may also be dispersed towards the south-southeast during an upset. Minimal

emissions will occur to the west and southwest of the site.

During medium and low emission potential periods, emissions will predominantly disperse

south of the site in the event of an upset, while there will be a reduced distribution of

emissions to the northeast and southwest of the site during an upset.

The nearest sensitive receptor (Figure 1) is within the buffer boundary for the medium and low

scenario buffers, and is outside the buffer for the high emission scenario.

The directional buffers presented in section 5.3.2 can be used to estimate the possible likely

offsite odour impact from site activities during an upset event.

The directional buffers indicate that the risk to odour amenity impact at the nearby sensitive

receptors is low given only one receptor falls within the buffers.

Furthermore, this conclusion is supported by the Council complaint history which indicates that

only a single complaint was recorded which could be attributed to GDC since 2010,

approximately eight years of operation at the site.

GHD

Level 18 180 Lonsdale Street Melbourne VIC 3000 T: 61 3 8687 8000 F: 61 3 8687 8522 E: [email protected]

© GHD 2019


3137010-31046/https://projects.ghd.com/oc/Victoria3/organiccompostingair/Delivery/Documents/3137010-REP-0_GDC_Organic_Composting_Buffer_Risk_Assessment.docx

Document Status



0 M.Turner M.Asimakis C.McVie 23/04/2019

www.ghd.com


Appendix I Air Quality Management Plan (GHD, 2019)

The Good Dirt Company

Organic Composting Facility

Air Quality Management Plan

April 2019

GHD | Report for The Good Dirt Company - Organic Composting Facility, 3137010 | i

Table of contents

1. Introduction ............................................................................................................................... 1

1.1 Overview ......................................................................................................................... 1


1.3 Limitations ....................................................................................................................... 1

1.4 Scope of works ................................................................................................................ 2

1.5 Assumptions.................................................................................................................... 2

2. Site description ......................................................................................................................... 3

2.1 Site location .................................................................................................................... 3

2.2 Sensitive receptors .......................................................................................................... 3

2.3 Site process .................................................................................................................... 5

2.4 Meteorology .................................................................................................................... 8

2.5 Odour and dust sources ................................................................................................ 12

3. Legislative requirements.......................................................................................................... 14

4. Odour management ................................................................................................................ 15

5. Dust management ................................................................................................................... 17

6. Administrative controls ............................................................................................................ 19

6.1 Document management ............................................................................................... 19

6.2 Emergency contacts ..................................................................................................... 19

6.3 Incident response procedure ......................................................................................... 19

7. Summary ................................................................................................................................ 21

Table index

Table 1 Operational periods ......................................................................................................... 6

Table 2 Emergency contact details ............................................................................................. 19

Figure index

Figure 1 Site location and receptors .............................................................................................. 4

Figure 2 Site features ................................................................................................................... 7

Figure 3 Annual wind rose for She Oaks........................................................................................ 9

Figure 4 Operational period wind rose ......................................................................................... 11

GHD | Report for The Good Dirt Company - Organic Composting Facility, 3137010 | ii

Appendices

Appendix A – Odour complaint form

Appendix B – Odour survey form


1. Introduction

1.1 Overview

GHD has been engaged by The Good Dirt Company (GDC) to develop an Air Quality

Management Plan (AQMP) for the GDC composting facility located on Tall Tree Road west of

Lethbridge, Victoria. This report was undertaken following discussion with EPA Victoria

regarding the need for an Air Quality Management Plan (AQMP) for the GDC site. This AQMP

includes a review of sources and processes onsite which may contribute to offsite odour and

dust emissions, legislative requirements, and management procedures for minimising

discharges to air from the facility.


The purpose of the AQMP is to provide GDC with a consolidated tool for management of odour

and dust emissions from the subject site.

1.3 Limitations

This report: has been prepared by GHD for The Good Dirt Company and may only be used and relied on by The Good Dirt Company for the purpose agreed between GHD and The Good Dirt Company as set out in section 1.2 of this report.

GHD otherwise disclaims responsibility to any person other than The Good Dirt Company 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 (refer section 1.5 of 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 The Good Dirt Company 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.


1.4 Scope of works

The scope of works for this report includes the following

Review client supplied information and aerial photography

Undertake a meteorological analysis using data obtained from She Oaks Bureau of

Meteorology (BoM) station

Undertake a site visit and identify sources of odour and dust from the GDC site

Review Legislative requirements for the site

Develop recommendations for managing odour and dust emissions

Develop recommendations for incident response management

Provide the above in report format as an Air Quality Management Plan (AQMP)

1.5 Assumptions

The following assumptions were used in this report

Data obtained from the She Oaks Bureau of Meteorology Automatic Weather Station

(AWS) is representative of the meteorology at the GDC site

The site processes and operational periods in the future are expected to resemble current

practices at the subject site as provided by the client, which GHD assume are correct at the

time of writing this AQMP


2. Site description

2.1 Site location

The GDC site is located approximately 6 km west of the town centre of Lethbridge and 7 km

north of the town centre of Teesdale, Victoria. The activity area of the site (area where dust and

odour sources are operating) is approximately 7.72 ha. The GDC site is located within the

Golden Plains Food Production Precinct, which was established for the protection of agricultural

land for long term investment in agribusiness. The precinct covers 4,000 ha and is designated

for intensive agriculture.

Land zoning surrounding the site is predominantly farm land, with the exception of a public

conservation and resource reserve and special use zone adjacent to the site’s western

boundary. Nearby land uses include a veterinary incinerator approximately 800 m to the south

west and poultry farms more than 2.2 km to the south east and north east.

2.2 Sensitive receptors

The nearest sensitive receptor to the site is a residential dwelling, located approximately 1.3 km

south-southeast from the facility. The next closest sensitive receptors are rural residences

approximately 2.7 km and 5.5 km from the site.

Indicative Site Boundary Sensitive receptor

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Site Location andReceptors


Figure 1 Site location and receptors


2.3 Site process

The following two sections outline the existing operation at the composting facility and the

proposed future operation with an increase in receipt of chicken litter and broiler bedding

material.

2.3.1 Current operation

The existing GDC facility currently receives and stockpiles approximately 12,000 tonnes per

annum of chicken litter and broiler bedding material from nearby egg and broiler farms (locally

sourced). The material is composted over 4 ha and cured in large windrows on another 3 ha,

before being reloaded onto trucks and delivered to customers.

Feedstock sources

GDC receives two types of material as feedstock:

Chicken litter is delivered from Farm Pride Foods (FPF)

Broiler bedding is delivered from Rural Funds Management (RFM)

Process

The composting process is segmented into different areas on the site as shown in Figure 2 and

described below:

Receival and aging of feedstock.

– Feedstock from FPF is delivered every second day to a designated area of 2 hectares

at the north of the site. The chicken litter is tipped from trucks into 100 m long wind

rows each 2 m apart. It takes approximately 2 weeks to complete one wind row. Ten

centimetres of aged dry broiler bedding is used to cover litter at the end of each

delivery day.

– Feedstock from RFM is delivered over an 8 day period every ~2.5 months to a

designated area of 2 hectares at the north of the site. The broiler bedding is allowed to

age undisturbed for 6 weeks. Delivery rounds occur during the months of March, May,

August, October, and December.

Mixing and composting of feedstock

– Chicken litter and broiler bedding are blended at a ratio of 1:1m3 and wind rows are

formed

– Wind rows are turned via front end loader only approximately every 10 to 30 days to a

total of 5 turns during this process, which is approximately 8 to 10 weeks long. It is

during this stage the pasteurisation occurs.

Aging and curing finished compost

– Wind rows are moved via front end loader to the curing area and stockpiled in 10 m x

100 m rows at a height of 5 m. The rows are kept stockpiled for a further 5 to 6 weeks

to age.

Onsite storage

– Finished product is stored at the south of the site and remains there until the next peak

delivery period, with occasional screening and mixing operations during summer as

required. The two peak delivery periods at the GDC site are:

– Spring. September to October (3,000 t)

– Autumn. February to April (7,000 t)

During these periods, dust and bio aerosols are possible in this part of the site.


2.3.2 Future operation

Proposed future upgrades to GDC operations will include:

Receipt of an additional 6,000 tonnes per annum of chicken litter and broiler

bedding material (to a total of 10,500 tpa of litter and 8,000 tpa of bedding)

No change to current process method of mixing and composting activities at the site

2.3.3 Operational periods

Site operations vary at the GDC facility throughout the year, and as such the potential for offsite

emissions is variable. Based on current and predicted future site operations, the following

operational periods have been identified below and summarised in Table 1.

Peak

This period occurs from September to October and from February to April, when large

quantities of finished compost product are loaded onto trucks for export from site. This

activity has the potential to generate high levels of dust and odour. The frequency of

loading activities during this period also heightens the potential for emissions as material is

likely to be left loose and potentially uncovered between loads.

Intermediate

This period occurs in summer (from November to January), when compost product is

screened and mixed according to tailored specifications and customer demand. Stockpiles

are expected to be partially characteristic of both the peak and non-peak periods.

Non-peak

This period occurs in winter (from May to August) and involves fortnightly delivery of

feedstock; mixing, pasteurisation and composting of feedstock; and aging and curing of

feedstock. These processes involve intermittent turning of composting piles.

Table 1 Operational periods

Operational period Months

High September – April

Medium February – October

Low May – August

November – January


Receivals area (Broiler litter)

Receivals area (Chicken Manure -

Layers)

Mixing area

Composting and curing area

Finished product and loadout area

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Site features


Figure 2 Site features


2.4 Meteorology

2.4.1 Site specific meteorology

The local meteorology largely determines the pattern of off-site impact. The characterisation of

local wind patterns requires accurate site-representative hourly recordings of wind speed and

direction over a period of at least 12 months (one year).

GHD has access to high quality meteorological data (five years at 1-minute intervals) from the

She Oaks automatic weather station (AWS) operated by the Australian Bureau of Meteorology.

The She Oaks AWS has been in operation since 1990 to and is located approximately 10 km

from the subject site. GHD has also accessed an AWS at Avalon airport (five years at 30-minute

intervals) for cloud data.

GHD selected the years 2014 – 2018 as it was the most recent period with a complete record

from the She Oaks AWS.

The effect of wind on dispersion patterns can be examined using the general wind climate and

atmospheric stability class distributions. The general wind climate at a site is most readily

displayed by means of wind rose plots, giving the incidence of winds from different directions for

various wind speed ranges.

The features of particular interest in this assessment are: (i) the prevailing wind directions and

(ii) the relative incidence of more stable light wind conditions and (iii) good dispersion condition

winds over 5 m/s.

2.4.2 Long term wind patterns

Annual wind patterns at She Oaks are displayed in Figure 3 and show:

The predominant annual average wind direction is from the north and north-northeast,

comprising 28% of all incident winds

The incidence of westerly winds (~10%) is significantly higher than easterlies occurring

~2% of the time

The average wind speed measured was 3.6 m/s

The observed wind speed distribution indicates that the largest proportion of high wind

speeds (> 6 m/s) are from the north and north-northeast, while the largest proportion of light

winds (<1.5 m/s) are also from these directions


Figure 3 Annual wind rose for She Oaks


2.4.3 Operational period wind patterns

Wind patterns at She Oaks for the operational periods in section 2.3.3 are displayed in Figure 4

and show that:

During the high operational period, the predominant wind directions are from the north and

the southeast, at approximately equal proportions. 10% of incident winds are westerly,

compared with approximately 3% easterly winds and minimal winds from the northeast

sectors. The average wind speed is 3.5 m/s.

During the medium operational period, the predominant wind directions are north and north-

northeast, comprising approximately 30% of all incident winds. There is a low contribution

of incident winds from the east and south directions (<4% for any direction). The incidence

of west, west-northwest and northwest winds is approximately even at 10% for each

direction. The average wind speed is 3.71 m/s.

During the low operational period, the predominant wind directions are north and north-

northeast, comprising approximately 30% of all incident winds. The incidence of northeast

and northwest component winds is low (<5% for any direction). The incidence of southeast

component winds is approximately 3% higher than the medium operational period. The

average wind speed is 3.77 m/s.


High Operational Period


Legend

Medium Operational Period


Low Operational Period


Figure 4 Operational period wind rose


2.4.4 Meteorological risk conditions

An automatic weather station (AWS) installed onsite can be used to determine the potential for

good or poor air dispersion. An on-site AWS is more reliable than an off-site weather station

such as the BoM station at She Oaks. High risk meteorological conditions to monitor are

detailed below.

Odour

The likelihood of negative impact from odour emissions is greatest when the following

meteorological and operational conditions occur:

Calm to light winds

Sensitive receptors are directly downwind of the feedstock receival area during delivery

periods

Wind speeds to be monitored for possible odour nuisance include light winds (<2 m/s) as these

wind speeds are most likely to contribute to odour incidences.

Dust

The likelihood of negative impact from dust emissions is greatest when the following

meteorological conditions occur:

Dry conditions

Strong wind conditions

Sensitive receptors are directly downwind of major dust sources during peak operational

periods

Wind speeds to be monitored for dust include high winds (>6 m/s). During these wind speeds

the potential for dust should be visually monitored onsite while operations are occurring and

operations should be suspended in wind- exposed locations.

2.5 Odour and dust sources

The following section outlines the dust and odour sources that occur onsite with the potential to

cause offsite impacts if not managed adequately.

2.5.1 Fixed sources

The following fixed sources have the potential to emit odour and dust from the GDC site:

Feedstock windrows in the receival area

Windrows in the mixing/ composting area

Windrows in the curing area

Finished compost windrows in the loadout area

Of the fixed sources, the windrows in the receival and composting areas are expected to

generate the most odour, as the compost in these sources is freshest. As the feedstock is

pasteurised and matured (and dries out in the process) it is expected to generate less odour but

higher levels of dust, therefore windrows from the curation and load out areas are expected to

generate a higher proportion of dust.


2.5.2 Operational sources

The following operations have the potential to generate odour and dust emissions from the GDC

site:

Turning stockpiles

Driving vehicles on unsealed surfaces within the site

Offloading feedstock from trucks

Loading finished product onto trucks

Of the operations, offloading feedstock from trucks and turning of stockpiles are expected to

generate the greatest proportion of odour, while loading finished product onto trucks and driving

on unsealed surfaces are expected to generate the greatest proportion of dust.


3. Legislative requirements

3.1.1 Act

Environment Protection Act 1970

The principle legislation for pollution control in Victoria is the Environment Protection Act 19701

(the Act). The Act regulates the discharge or emission of waste to water, land, or air by a

system of works approvals and licences. The Act also specifically controls pollution of the

atmosphere including under the heading of ‘beneficial use’, the protection of public benefit from

the effects of waste discharges, such as odour emissions, emission of noise, and the transport

and disposal of waste.

3.1.2 Policy

State Environmental Protection Policy (Air Quality Management) (SEPP AQM)

The Victorian State Environmental Protection Policy (Air Quality Management) (SEPP AQM)

details the air quality objectives to be met by industries in Victoria. Odour and dust are included

in the SEPP AQM as unclassified indicators, being “indicators of the beneficial uses of local

amenity and aesthetic enjoyment”. Schedule A of the SEPP AQM sets the design criteria which

must be met by industry. For odour, this is 1 Odour Unit (OU) at the site boundary over a 3-

minute average. For total suspended particulates (nuisance dust), this is 0.33 mg/m3 over a 3-

minute average.

3.1.3 Guideline

EPA Publication 1588.1, Designing, constructing and operating composting facilities

EPA Publication 1588.1, Designing, Constructing and operating composting facilities, is the

most relevant guideline to this assessment. This guideline assists composting facilities in

meeting the requirements of the SEPP AQM. The guideline specifies recommended separation

distances, feedstock related risk factors and best practice methods for siting and operation of a

composting facility. The feedstock at the GDC facility is fresh manure, which falls under the

medium to high risk category in the guideline for harm to human health and environment. A

recommended composting method for this category is an enclosed or covered environment;

given the location of this site in an intensive agriculture precinct and sufficient separation

distances to sensitive receptors, the risk of an open compost at the GDC is considered low. The

guideline recommends the use of an odour management plan on site which may include; an

odour source inventory, odour sources and controls under normal conditions, odour monitoring

and reporting regime and management during upset conditions. The guideline includes

operational measures to control odour and dust emissions, which have been included in this

management plan.

1 At the time of writing this document, the EP Act 1970 is under amendment, and the amended Act is due to be commenced in

July 2020.


4. Odour management

Air quality should be continually assessed and managed onsite in order to meet regulatory

requirements and to protect beneficial land uses off site. The following sections provide a

summary of some of the controls available to GDC to manage and minimise off site discharges

of odour.

4.1.1 Operational and administrative control measures

The following operational and administrative controls should be implemented onsite to reduce

the potential for odour impacts beyond the property boundary:

Administrative

Train staff about the importance of regulatory compliance and management for achieving

compliance

Identify relevant operating procedures and control parameters to minimise emissions

Keep an inventory of mitigation equipment and materials

Prepare emergency procedures and train staff in its use

Implement a preventative maintenance programme to minimise equipment failure and

unplanned downtime for all Front End Loaders (FEL) used onsite

Operational

Undertake regular checks for odour off site

As required, change operations to minimise odour. This may mean stopping work and

waiting for a change in wind speed or direction, changing the frequency of stockpile

covering or applying a thicker layer of bedding cover

Maintain 10 cm of aged dry broiler bedding cover over litter stockpiles at the end of each

day

Minimise the surface area of stockpiles where possible. This favours increasing the height

of stockpiles before width/ length. However this must be balanced against dust generation

which will increase in stockpiles/windrows greater than 3-4 m in height.

In the event that an odour complaint is registered, the source of the odour should be

investigated to validate the complaint (see section 4.1.2) and assess if operating

procedures require adjustment to reduce odour generation

Avoid turning stockpiles during wind directions which place sensitive receptors downwind of

the site

Turn stockpiles using an excavator rather than top turner

4.1.2 Odour monitoring

When required (i.e. after receipt of an odour complaint), short odour surveys should be

undertaken. When an odour is detected, this should be investigated to assess the source and if

operating procedures require adjustment to reduce odour generation.


Survey method

The odour survey should be conducted off site and include several locations, starting upwind

and furthest away from the site operation areas, and finishing at locations closer and downwind

from the site. Short odour surveys should be performed for 5 minutes at each location along the

survey path.

A hand held anemometer can be carried to check wind speed and direction at each survey

location, and the survey path should be adjusted to select locations downwind of odour sources.

Odour surveyors should be familiar with the German VDI scale for describing odour intensity.

This scale is used in Europe, Australia and New Zealand for grading odour intensity. The scale

is used to characterise how easily the odour can be detected.

Surveyors should also characterise the odour according to the FIDOL factors, which describe

the following:

F – Frequency

I – Intensity

D – Duration

O – Offensiveness

L – Location

Description tables for FIDOL factors and intensity ratings, as well as an odour survey form and

impact summary table, can be found in Appendix B.


5. Dust management

Air quality should be continually assessed and managed onsite in order to meet regulatory

requirements and to protect beneficial land uses off site. The following sections provide a

summary of some of the controls available to GDC to manage and minimise off site discharges

of dust.

5.1.1 Operational and administrative control measures

The following operational controls should be implemented onsite to reduce the potential for dust

emission and impact:

Administrative

Train staff about the importance of regulatory compliance and management for achieving

compliance

Identify relevant operating procedures and control parameters to minimise emissions

Keep an inventory of mitigation equipment and materials

Prepare emergency procedures and train staff in its use

Implement a preventative maintenance programme to minimise equipment failure and

unplanned downtime for all front end loads used onsite

Implement a monitoring program to check on overall performance

Operational

Undertake regular daily checks for dust

Changes to daily operations as required to minimise dust. This may include responding to

weather conditions, for example ceasing work if high winds occur or applying water sprays

on dry days.

Light watering of compost stockpiles

Proposed weather forecasts for the next 24 hour period to be communicated to relevant

operational staff and a ‘daily’ management plan posted for the proposed conditions. This

can include

– Surface water sprinkling of the stockpiles overnight (or as required) where high wind

conditions are forecasted

– Watering stockpiles under conditions resulting in sensitive receptors being downwind of

the major dust sources

– Watering stockpiles under dry, strong wind conditions

Undertake further regular visual inspections throughout the day and cease operations if

required

In the event that dust impacts occur off site, the source of the dust should be investigated to

asses if operating procedures require adjustments to reduce dust generation


5.1.2 Dust monitoring

Dust can be monitored during site activities by means of visual inspections. If dust is visually

identifiable, changes in site activities may be required.

Monitoring to avoid dust impacts may also include checking weather forecasts the day before

site activities and during site activities, to determine whether dust will be blown toward sensitive

receptors.

If complaints about dust are received by GDC or EPA/Council from the closest sensitive

receivers in the area, then GDC may wish to investigate dust levels from the operation using

directional dust deposition gauges.


6. Administrative controls

The following sections provide guidance on the administrative controls such as document

management and upkeep of emergency contacts, and the incident response procedures.

6.1 Document management

6.1.1 Continual improvement process

A review of the performance of the AQMP should be undertaken annually for the first two years

of use and bi-annually thereafter, and updates to the AQMP made where relevant. This ensures

the AQMP stays appropriate to conditions onsite. Changes made to the AQMP may include

updates to any policies or guidelines, changes in operational procedures or seeking continual

improvement.

6.1.2 Copies of the AQMP

The AQMP is intended to be a live document; meaning it is continually being used and updated.

An online/ electronic version of the AQMP takes the position of a master document, and any

printed copies of the document are subordinate and should be stamped with “copy only”. Copies

should be stored and maintained in such a way that they are protected from damage or loss.

6.2 Emergency contacts

Emergency contact details for site operations and odour and dust complaints should be kept up

to date and accessible to people who may be involved in or impacted by site activities. The

contact details in Table 2 are relevant at the time of writing this AQMP.

Table 2 Emergency contact details

Name Role Contact Phone number Email Address

Dugald Buchanan Site manager 0409889250 [email protected]

6.3 Incident response procedure

6.3.1 Incident/ complaint

In the event that an incident/complaint occurs, the source(s) of complaint should be mitigated as

soon as practicable. In addition to mitigation, an incident/complaint report form should be

completed and relevant information recorded by GDC. The site manager will contact the

complainant and discuss corrective action(s). Details recorded will include complainant name,

time and date of complaint, nature of the complaint/incident and any actions/response

undertaken. Refer to Appendix A for an example complaint log sheet.

6.3.2 Incident assessment

An incident assessment will include; assessing the likely causes of the event using information

regarding prevailing weather conditions, the nature of composting activities taking place and the

undertaking of an odour/dust monitoring survey. In the event that a complainant considers that

odour/dust from the GDC operation is impacting on their amenity, an odour/dust investigation

will be undertaken by a trained staff member as soon as practicable and the complaint register

and odour/dust survey forms in Appendix A and Error! Reference source not found. or similar

will be completed.


6.3.3 Additional actions

After an incident or odour/dust complaint, an assessment of any additional odour/dust mitigation

and/or management measures will be considered.

Additional odour surveys may be required to clearly identify sources of odour. Once mitigation

measures have been implemented, further odour surveys will be required to assess their

effectiveness.

For dust incident management, dust gauges may be set up to monitor the deposition of dust at

various directions from the site.


7. Summary

This AQMP has been developed for use by GDC to provide a tool to enable the minimisation of

dust and odour from the 18,000 tpa composting facility on Tall Tree Road west of Lethbridge,

Victoria.

This AQMP includes a review of sources and processes onsite which may contribute to offsite

odour and dust emissions, legislative requirements, and management procedures for minimising

discharges to air from the facility.

It is expected that this AQMP will be reviewed and updated on an annual basis for the first two

years and then bi-annually after this time by GDC to ensure the document remains relevant to

the composting facilities operation.

It is expected that by adhering to the concepts and controls laid out in this AQMP that offsite

impacts from dust and odour will be minimised from the site.

Appendices

Appendix A – Odour complaint form

Example Odour Complaint Log Sheet

Odour Log Record Sheet

Name: ________________________________ Address: __________________________________________________________________ Address of Suspected Odour Source: _________________________________________

Date Start Time

Finish Time

Description of Odour (e.g. smelled like Bakery, Coffee, Paint, Mothballs, Wet Dog etc)

Other Comments (e.g. Intensity, or if odour detected at location other than your above address)

Declaration of True Record I (Name) ______________________ confirm that the above list is a true record of events recorded From (Date) ___________ to (Date) ___________. Signature:_________________________________ Date:___________________

Appendix B – Odour survey form

Odour Investigation Form Showing FIDOL Factors and Odour Character Descriptors

Odour Survey Form

File: ________________ Date: _________/____________/_____________ Staff: __________________________ Signed: ____________________

L

Location

Time

24 Hour

F

Frequency

How often?

I

Level

0-6

Table 4.2

D

Total

Sum of “F”

O

Offensiveness

Table 4.4

Character: Description of

Odour

(001-040)

Wind Direction

& Speed m/s:

Comments and Alleged Source:

From:

To:

From:

To:

From:

To:

From:

To:

From:

To:

FIDOL Factors

FIDOL Factor Description

F - Frequency How often the odour is noticed i.e. once for 20 seconds then went away for 30 seconds, or it was a constant odour for two minutes.

I - Intensity The strength of the odour (refer to the German VDI odour intensity scale – Table 4.2).

D - Duration The length or total sum of an odour event at a particular site i.e. there were two 20 second wafts in the three minutes at one location, therefore the

duration was 40 seconds.

O - Offensiveness This determines how adverse the odour is. The odour may be pleasant, neutral or unpleasant but still be offensive (refer to Table 4.4 as an

example of rating adverse effects – if the odour is not offensive, then the value is 0).

L – Location The location is the place where the observations are recorded. Location needs to include the type of land use/activities in the vicinity i.e.

residential/industrial etc.

Odour

Character

Descriptors

001 Fragrant, 002 Perfumy, 003 Sweet, 004 Fruity, 005 Bakery (fresh bread), 006 Coffee-like, 007 Spicy, 008 Meaty (cooked, good), 009

Sea/marine 010 Herbal, green, cut grass, 011 Bark-like, birch bark, 012 Woody, resinous, 013 Medicinal, 014 Burnt, smoky, 015 Soapy, 016 Garlic,

onion, 017 Cooked vegetables, 018 Chemical, 019 Etherish, anaesthetic, 020 Sour, acrid, vinegar, 021 Like blood, raw meat, 022 Rubbish, 023

Compost 024 Silage, 025 Sickening, 026 Musty, earthy, mouldy, 027 Sharp, pungent, acid, 028 Metallic, 029 Tar-like, 030 Oily, fatty, 031 like

gasoline, solvent 032 Fishy, 033 Putrid, foul, decayed, 034 Paint-like, 035 rancid, 036 Sulphidic, 037 Dead animal, 038 Faecal (like-manure), 039

Sewer odour, 040 Describe the odour yourself

Table 4.2 German VDI 3882 Odour Intensity Scale Table 4.4 An Example of Scale for Rating Adverse Effects

Odour Intensity Intensity

Level

Extremely strong 6

Very strong 5

Strong 4

Distinct 3

Weak 2

Very Weak 1

Not perceptible 0

Perceived odour strength

Intensity level rating

Description

Extremely strong

6

In normal circumstances, this should be very rare in a field situation. For an offensive type of odour, the reaction would be to mitigate against further exposure. This remains the dominant thought and motivation until the exposure level is reduced. The odour cannot be tolerated.

Very strong 5 The odour character is clearly recognisable. For an offensive type of odour, exposure to this level is considered unpleasant/undesirable to the point that action to mitigate against further exposure is considered or taken.

Strong 4 The odour character is clearly recognisable. For an offensive type of odour, exposure to this level would be considered unpleasant/undesirable.

Distinct 3

The odour character is clearly recognisable. Note that this must still apply even if in a different context or situation – for example, not knowing or expecting what type of odour may be present. The odour is tolerable – even for an offensive odour.

Weak 2 The assessor is reasonably sure that odour is present but not 100% sure of that the odour character represents odour from the source, assuming no prior knowledge of the source.

Very Weak 1

The odour character is not recognisable. There is probably some doubt whether the odour is actually present (i.e. it simply doesn’t smell like ‘fresh air’). A useful strategy where the odour is borderline between ‘not perceptible’ and ‘very weak’ is to alternate such observations between 0 and 1.

No odour 0 No odour

GHD

Level 18 180 Lonsdale Street Melbourne VIC 3000 T: 61 3 8687 8000 F: 61 3 8687 8522 E: [email protected]

© GHD 2019


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