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ENVIRONMENTAL ASSESSMENT REPORT Fish Oil & Protein Extraction Plant Parramatta Creek, East Sassafras Huon Aquaculture Group Pty Ltd Board of the Environment Protection Authority May 2016

Fish Oil & Protein Extraction Plant - EPA Websiteepa.tas.gov.au/documents/huon aquaculture group pty ltd - ear.pdf · Proposal Fish Oil & Protein Extraction Plant Location Parramatta

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ENVIRONMENTAL ASSESSMENT REPORT

Fish Oil & Protein Extraction Plant

Parramatta Creek, East Sassafras

Huon Aquaculture Group Pty Ltd

Board of the Environment Protection Authority

May 2016

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Environmental Assessment Report

Proponent Huon Aquaculture Group Pty Ltd

Proposal Fish Oil & Protein Extraction Plant

Location Parramatta Creek, East Sassafras

NELMS no. PCE No. 9110

Permit application no. 27/2016 (Latrobe Council)

Folder EN-EM-EV-DE-242879

Document. H524474

Class of Assessment 2A

Assessment process milestones

10/07/2014 Notice of Intent lodged

24/07/2014 EER Guidelines issued

24/02/2016 Permit application submitted to Council

11/03/2016 Application referral received by Board

19/03/2016 Start of public consultation period

04/03/2016 End of public consultation period

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Acronyms

Board Board of the Environment Protection Authority

EER Environmental Effects Report

DPIPWE Department of Primary Industries, Parks, Water and Environment

EIA Environmental impact assessment

EMPC Act Environmental Management and Pollution Control Act 1994

EMPCS Environmental management and pollution control system

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

LUPA Act Land Use Planning and Approvals Act 1993

RMPS Resource management and planning system

SD Sustainable development

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Report summary

This report provides an environmental assessment of Huon Aquaculture Group Pty Ltd’s (Huon’s) proposed fish oil and protein extraction plant (‘the extraction plant’) at its existing Parramatta Creek processing facility at East Sassafras. The extraction plant is proposed to convert existing process by-product and waste streams into oil and stock feed components (fishmeal and protein concentrate). This report has been prepared based on information provided by the proponent in the Environmental Effects Report (EER). Relevant government agencies and the public have been consulted and their submissions and comments considered as part of this assessment. Further details of the assessment process are presented in section 1 of this report. Section 2 describes the statutory objectives and principles underpinning the assessment. Details of the proposal are provided in section 3. Section 4 reviews the need for the proposal and considers the alternatives to the proposal. Section 5 summarises the public and agency consultation process and the key issues raised in that process. The detailed evaluation of environmental issues is contained in section 6. The report conclusions are contained in section 7. Appendix 1 contains the environmental permit conditions for the proposal. Attachment 2 of the permit conditions contains the table of commitments from the EER.

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Table of Contents

1 Approval process ..................................................................................... 1

2 SD objectives and EIA principles .............................................................. 1

3 The proposal ............................................................................................ 2

4 Need for the proposal and alternatives ..................................................... 6

5 Public and agency consultation ................................................................ 6

6 Evaluation of environmental issues .......................................................... 7

7 Report conclusions ................................................................................. 14

8 Report approval...................................................................................... 15

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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1 Approval process

A Notice of Intent in relation to the proposal was received by the Board of the Environment Protection Authority (the Board) on 10 July 2014. An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Latrobe Council on 24 February 2016. The proposal is defined as a ‘level 2 activity’ under clause 4(f), schedule 2 of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being a rendering or fat extraction works – the conduct of works at which fish is processed or is capable of being processed by extraction to produce proteinaceous matter, being works with a total processing capacity of 50 kilograms or more per hour where a continuous cooker is used, or 50 kilograms per batch where a batch cooker is used. This proposal is for a waste production rate of 850 kilos per hour. Section 25(1) of the EMPC Act required Council to refer the application to the Board for assessment under the Act. The application was received by the Board on 11 March 2016. The assessment has been undertaken by the Director, Environment Protection Authority under delegation from the Board. The Board required that information to support the proposal be provided in the form of a Environmental Effects Report (EER). Several drafts of the EER were submitted to the Department for comment prior to its finalisation and acceptance on behalf of the Board. The final EER was submitted to Council with the permit application. The EER was released for public inspection for a 14-day period commencing on 19 March 2016. An advertisement was placed in The Advocate and a notice was placed on the EPA website. The EER was also referred at this time to relevant government agencies for comment. No public submissions were received.

2 SD objectives and EIA principles

The proposal must be considered by the Director in the context of the objectives of the Resource Management and Planning System of Tasmania (RMPS), and in the context of the objectives of the Environmental Management and Pollution Control System (EMPCS) (both sets of objectives are specified in Schedule 1 the EMPC Act). The functions of the Board are to administer and enforce the provisions of the Act, and in particular to use its best endeavours to further the RMPS and EMPCS objectives. The Director must undertake the assessment of the proposal in accordance with the Environmental Impact Assessment Principles defined in Section 74 of the EMPC Act.

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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3 The proposal

The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in Section 3 of the EER. Table 1: Summary of the proposal’s main characteristics

Activity

Conversion of existing process by-product and waste streams into oil and stock feed components (fishmeal and protein concentrate) at a rate of 850 kilos per hour.

Location and planning context

Location At the existing Parramatta Creek processing facility site, at Lot 1, 7218 Bass Highway, Sassafras, Tasmania, 7307 as shown in Figure 1. Certificate of Title 158261/1.

Land zoning Rural Resource under the Latrobe Interim Planning Scheme 2013

Land tenure Private Land owned by proponent.

Existing site

Land Use Existing fish processing facility. The broader site consists of 56 hectares and the majority of the land is grassland and ryegrass pasture.

Topography The geomorphology of the plant site is generally flat and gently undulating.

Geology The geology of the area is covered by the 1:50 000 sheet for Frankford. The whole site is composed of Permian mudstone, sandstone and siltstone beds except for the very north east corner of the property situated near the Parramatta Creek, where Quaternary alluvium is found. There are no adverse geological features for the plant.

Hydrology The site is located between Felmingham and Parramatta Creeks. Parramatta Creek crosses the north east corner of the site. These creeks join to the north west of the site. Both creeks are located over 200 m away from the proposed oil plant.

Flora & Fauna The vegetation at the Parramatta Creek site largely comprises grasslands.

Flora and fauna assessments were conducted as part of the 2009 DPEMP1 for approval of the Parramatta Creek fish processing facility.

No species of conservation significance, no threatened flora or fauna species and no threatened vegetation communities were found within 500 m of the site.

There are no known weeds and diseases that might affect native fauna present on the site or near the site.

Local region

Climate The average annual rainfall is approximately 900 mm per annum, with average annual evaporation of 1100 mm per annum. Prevailing wind speed and direction is from the north to northwest at 20 km/h.

Surrounding land zoning, tenure and uses

State Forest to the north, east and south. Agriculture (orchards) to the west by orchards. The closest residences are located on Byrons Road and on Conservatory Road off the Bass Highway, well over 1 km away.

Proposed infrastructure

Major stages & equipment

The plant will consist of the following key stages and components (see also Figure 3 below):

1. Collection and feed of raw materials into the plant:

a. Raw material storage hopper fed directly via an enclosed piping system

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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from the salmon processing environment.

b. Raw material mincer to macerate all components into a homogenous format.

c. Intermediate storage tank.

d. Feed pump for the thermal heat exchanger.

e. Low temperature ‘pipe in pipe’ thermal heat exchanger for the gentle heating of high viscose products utilising hot water as the indirect heating medium to 55 degrees Celsius.

2. Initial separation phase removing solid matter for collection as a fish meal:

a. Intermediate storage tank with agitator.

b. Feed pump for the decanter.

c. 2-phase decanter centrifuge designed for fish processing industries and particularly suitable for the cold separation of the released oil.

d. Eccentric screw pump to distribute solid outputs from the decanter stage.

e. Liquid/oil discharge tank/feed tank for separator.

3. Secondary separation phase polishing salmon oil

a. Centrifugal pump to feed the separator.

b. Low temperature plate heat exchanger for maintaining heat to liquid.

c. Oil polishing centrifuge separator.

d. Eccentric screw pump for discharge of protein liquor from the separator.

e. Buffer tank for clean oil.

f. Centrifugal pump to discharge clean oil.

g. Optec system for the detection of turbidity and oil quality.

h. Low temperature plate heat exchanger for cooling the oil.

Other infrastructure

A set of control valves, field instruments and PLC electrical components.

Storage tanks and handling systems for derivative products of salmon oil, salmon protein concentrate, and salmon fishmeal.

Inputs

Water Connection to existing services onsite

Energy Connection to existing services onsite

Other raw materials

Fish waste from existing facility onsite

Wastes and emissions

Liquid Wastewater directed to existing WWTP.

Stormwater collected in drains and then directed to interceptor traps to remove sediment and hydrocarbons before discharge into Felmingham and Parramatta Creeks.

Atmospheric Odours from processing of fish waste.

Solid Unprocessed fish waste during plant shutdown removed to appropriate facility off-site.

Controlled wastes

None

Noise Noise sources consistent with existing facility.

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Greenhouse gases

Vehicles transporting produce offsite.

Construction, commissioning and operations

Proposal timetable

2-3 month construction and commissioning period on issue of a valid permit.

Operating hours (ongoing)

No operating hours specified.

Other key characteristics

The activity is to be conducted at the location shown in Figure 3 of the EER (Figure 2 below). The Land as defined by CT 158261/1 includes the existing fish processing facility and the regulatory framework that relates to that activity.

Figure 1: Location map of HUON Parramatta Creek existing site and of proposed oil extraction facility (Figure 2 of the EER).

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Figure 2: Aerial view of existing processing facility and proposed plant (Figure 3 of the EER).

Figure 3: Schematic of base components of the salmon oil processing plant (Figure 1 of the EER).

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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4 Need for the proposal and alternatives

According to Section 3.4 of the EER, the proposal will ensure self-sufficiency and eliminate the need for third party processing of its by-product and waste streams. This aligns with the company’s ongoing sustainability program and objective of utilising every component of its salmon in a commercial manner. The plant is also expected to reduce traffic in and out of the Parramatta Creek wet processing site as less freight movements of volatile and logistically challenging outputs will be transported to external parties for secondary processing from the existing process. The by-products and waste streams will be concentrated and stabilised for ease of logistical handling and freight.

5 Public and agency consultation

No government agency submissions were received for this application. No public representations were received. The following Divisions of the Department of Primary Industries, Parks, Water and Environment also provided submissions on the EER:

Air Specialist, EPA Division

Senior Waste Management Officer, EPA Division

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6 Evaluation of environmental issues

The environmental issues considered relevant to the proposal have been evaluated by the EPA Division. Details of this evaluation, along with the permit conditions required by the Director, are discussed below.

Issue 1: Air Emissions

Description of potential impacts

Air emissions, including odour and dust, has the potential to cause environmental nuisance on nearby receptors, including staff and visitors as well as nearby residences, if not appropriately mitigated and managed.

The extraction plant is likely to produce odorous condensate as a result of processing fresh fish by-products.

According to the EER, odour production by oil and protein extraction plants is a combination of technology, processing material, processing rates and management, and cannot be precisely predicted in advance of installation and operation. An odour modelling assessment was undertaken as part of the EER to evaluate compliance of the proposed plant with the Tasmanian Environmental Protection Policy (Air Quality) 2004 (‘Air EPP’) and concluded that the extraction plant was unlikely to breach the 2OU level at the site boundary.

Management measures proposed in EER

Commitment 5 of the EER dictates that during construction “dust emissions will be minimised where possible by: minimising the duration of exposure by clearing land immediately prior to work and revegetating bare soil once work has been completed; stockpile topsoil for use in landscaping and/or revegetation; and covering or dampening stockpiles and disturbance areas as necessary to minimise soil loss”.

The EER states that the process equipment and the plant building will be maintained under negative pressure, in order to prevent leakage of odour to the atmosphere. An air handling system is to be installed, which is likely to comprise an exhaust fan drawing from the three process exhaust ports on the plant and a small packaged biofilter unit with a vertical discharge vent extending to approximately 9 m above ground level (2 m above roof height).

The EER also indicates that the proposed plant will only handle fresh raw salmon waste streams generated on the site.

Commitments 13, 14 and 15 are relevant to managing odours from the proposal. These state that:

“a suitable biofilter (or equivalent alternative, such as an activated carbon filter) will be installed and maintained;

the biofilter discharge vent will be equipped with the required fittings and access arrangements to allow stack testing to be carried out in accordance with the appropriate Australian Standards; and

a stack test will be carried out following commissioning of the plant to confirm the actual odour generation rate and validate the odour modelling assessment.”

Public and agency comment

None

Evaluation

Dust has the potential to be generated during the construction of the extraction plant. The proponent will be required to manage dust during construction under condition A1. Commitment 5 of the EER supports the requirements of this condition.

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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While the Odour Assessment indicated that the requirements of the Air EPP are likely to be met. The activity has the potential to cause odour that may cause nuisance to sensitive receptors on and off-site. The proponent will therefore be required to manage odour in accordance with condition A2.

To ensure that the potential for odour emissions is limited the proponent will also be required, under condition OP1, to ensure that only fresh by-products and waste streams generated on the Land are processed at the extraction plant.

The EER recommends that a stack test be undertaken post commissioning to ensure that the odour emissions reflect the modelling undertaken and are unlikely to cause environmental nuisance. As the design of the odour management system has not yet been finalised it is considered necessary to impose a conditions for an odour survey that allows for consideration of all potential odour emissions sources. An odour survey will therefore be required under condition A3 and a subsequent report will be required under condition A4. The proponent will be required to notify the Director, EPA of the commencement of commissioning under condition G4.

The odour survey and subsequent odour assessment report under conditions A3 and A4, respectively, will compare actual modelled odour emissions against emission rates used as input to the atmospheric dispersion modelling conducted for the EER. This will then allow an assessment as to whether odour emissions from the activity are likely to cause environmental nuisance beyond the boundary of the Land. Atmospheric dispersion modelling will be required under condition A5 to ensure the extraction plant meets the 2OU limits at the site boundary and where a breach or breaches are identified, the proposed remedial action proposed. The Director has the discretion to not require this modelling, where the odour survey and subsequent report demonstrate that it is not necessary.

To ensure that the activity is constructed at a location that reflects the dispersion modelling undertaken as part of the EER, and therefore the lack of potential impacts on sensitive receptors, the proponent will be required to undertake the activity at the location shown in Figure 3 of the EER under condition OP2.

Conclusion

The proponent will be required to comply with the following standard conditions:

G4 Notification prior to commissioning

A1 Control of dust emissions during construction

A2 Odour Management

The proponent will be required to comply with the following site-specific condition:

OP1 Fish waste management

OP2 Operational footprint

A3 Odour Survey

A4 Odour Survey Report

A5 Atmospheric Dispersion Modelling

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Issue 2: Stormwater & Liquid Effluent

Description of potential impacts

Inappropriate management of stormwater and liquid effluent have the potential to impact on nearby waterways and cause groundwater contamination.

Stormwater is currently collected in drains and then directed to interceptor traps to remove sediment and hydrocarbons before discharge into Felmingham and Parramatta Creeks.

The approximate daily volumes of wastewater generated by the oil extraction plant will comprise:

Initial flush of the system (water): 5,000 litres

CIP (caustic wash): recirculating 2,000 litres

Intermittent acid wash (when needed): recirculating 2,000 litres

Final rinse (water): 2,000 litres.

The total wastewater volumes from the extraction plant will therefore be in the order of 10 kilolitres per day.

The existing processing facility uses an existing waste water treatment plant (WWTP) to handle blood water, factory process water, equipment clean down water, truck and bin washing, and stormwater. The site currently produces a maximum of 180 kilolitres per day of wastewater.

The WWTP consists of initial screening in a rotary sieve, fat separation, and clarifying tanks, followed by a four (4) stage lagoon treatment for aerobic treatment. The storage capacity of the lagoons is approximately 10 megalitres, and treated wastewater has a residence time of approximately 40 days.

The treated water is dispersed within an effluent irrigation system across a zone of approximately 12 ha for ryegrass cropping.

Management measures proposed in EER

Commitment 1 of the EER states that a “Construction Safety and Environmental Management Plan will be prepared or adopted, appropriate to the construction complexity and risks”.

Commitment 2 states that “Best practice principles for stormwater management will be implemented. If and as required by site conditions, temporary sediment traps will be installed to prevent silt run-off from the construction areas”.

Commitments 16 of the EER relates to management of liquid effluent and states that “the plant will initially produce a maximum of 10 kL per day, which can be accommodated within the site existing WWTP; increases beyond this rate will be subject to a production increase approval under a separate DPEMP process.”

Commitment 17 is also relevant. “In the event that the plant has a non-scheduled stoppage or extended scheduled period of maintenance, actions include ceasing wet processing operation, short term freezing and storage of waste streams as per existing waste stream management protocols. During extended periods of nonoperation the waste streams will be removed from the processing site to appropriate and accredited external service providers.”

Public and agency comment

None

Evaluation

The existing processing plant on the Land has an established stormwater system that will be suitable to manage stormwater run-off during construction and operation of the extraction plant. Commitments 1 and 2 of the EER will support stormwater management during construction. No additional conditions are required.

The extraction plant is expected to produce a maximum of 10 kL of liquid effluent per day which will require treatment. A WWTP exists on the Land and according to the EER has capacity to manage the wastewater from the extraction plant. However there are plans to expand the main

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processing facility that may require upgrades to the WWTP capacity to manage all effluent from the Land. The current irrigation system may also be modified over time to ensure its sustainability.

To ensure that wastewater discharged from the activity is suitably treated and managed the proponent will be required to direct all wastewater from the extraction plant to a wastewater treatment facility that is approved to take the wastewater from this activity under condition E1. This means that the capacity of the WWTP on the Land and the irrigation system, to manage the additional input from the processing facility will need to be confirmed before wastewater can be discharge to the plant. Other disposal options may have to be considered, or operation of the processing facility suspended, until appropriate wastewater treatment and disposal is available.

To ensure that the WWTP is able to process the wastewater from the extraction plant the proponent will be required to ensure that solid matter is prevented from entering the wastewater stream under condition E2.

Conclusion

The proponent will be required to comply with the following site-specific condition:

E1 Wastewater Management

E2 Solid matter in wastewater

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Issue 3: Solid Waste

Description of potential impacts

The proposal intends to process all existing processing plant by-product and waste streams for the production of more stable derivatives including salmon oil, salmon protein concentrates, and salmon fishmeal. This will result in a site wide reduction in the production and storage of solid wastes.

Solid waste, in the form of fish by-products, is only expected during non-scheduled stoppage or extended scheduled period of maintenance.

Management measures proposed in EER

Commitments 11 and 12 are relevant to waste management during construction:

All waste material generated will be removed from site for disposal at an appropriately authorised facility.

Any construction wastes amenable to recycling will be taken to the recycling section of a municipal transfer station or taken directly to an authorised recycler.

The EER also states that “in the event that the plant has a non-scheduled stoppage or extended scheduled period of maintenance, actions include ceasing wet processing operation, short term freezing and storage of waste streams as per existing waste stream management protocols. During extended periods of non-operation the waste streams will be removed from the processing site to appropriate and accredited external service providers.”

Public and agency comment

None

Evaluation

Construction waste from the activity is expected to be limited and commitments 11 and 12 of the EER are appropriate to manage any solid waste produced.

Solid waste, in the form of fish by-products, from the processing plant is only expected to be produced where there is a shutdown of the extraction plant. Appropriate storage measures have been proposed to manage this event, allowing the waste to be retained for conversion to value-add products or disposed of to an appropriate facility.

The proponent is required to only process fish waste generated on the Land under condition OP1, preventing the accumulation of solid waste from other sources. The management of this waste prior to discharge to the extraction plant is managed under the regulatory framework for the processing facility. Solid waste management is also required in relation to wastewater with condition E2 preventing solids entering the wastewater stream.

Fish waste is a controlled waste under the Environmental Management and Pollution Control (Waste Management) Regulations 2010 (the Waste Regulations) and the disposal of any material not processed by the activity is required to be managed in accordance with these regulations. Therefore no specific conditions in relation to disposal are proposed.

Conclusion

No additional conditions required. Refer to Issues 1 (Air Emissions) and Issue 2 (Stormwater & Liquid Effluent) for discussions of conditions OP1 and E2.

The proponent should also consider the Waste Hierarchy as detailed in the Other Information section of the permit conditions in managing waste produced during construction and operation. The proponent must comply with the Waste Regulations.

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Issue 4: Hazardous Materials Management

Description of potential impacts

The inappropriate use and storage of waste and hazardous substances has the potential to cause environmental nuisance or harm through discharge to the land or nearby waterways.

Only by-product from the existing processing plant will be used in the extraction plant. A Biosecurity Plan is in place for the existing processing plant and is likely to prevent issues associated with the use of material from this plant in the extraction plant. According to the EER, only small amounts of chemicals currently stored on the Land and are managed in accordance with NOHSC:2017 (2001) Appendix 3. A dangerous goods register, hazard analysis and risk assessment report including specified bunding, isolation and actions plans is maintained as part of Huon’s current Operation procedures and are expected to apply to the extraction plant.

Management measures proposed in EER

The following commitments are relevant to management of hazardous substances during construction. These commitments state:

Commitment 6 - Any hazardous substances, including fuels, will be stored on site within a suitable bunded area.

Commitment 7 - Sufficient and appropriate contaminant spill cleanup equipment will be available to respond to spills of hydrocarbons and other contaminating substances.

Commitment 8 - Any spills of potentially contaminating liquids will be reported to the construction manager immediately and cleaned up as soon as practicable.

During operation the following commitments will apply in relation to hazardous materials management:

Commitment 19 - The plant will be operated in accordance with HUON’s approved Biosecurity Plan

Commitment 20 - Hazardous chemicals will be stored in dry, bunded areas that comply with AS3780-1994 Storage and Handling of Corrosive Substances

Commitment 21 - The management of hazardous substances will be in accordance with the National Standard and National Code for the Storage and Handling of Workplace Dangerous Goods.

Commitment 22 - A dangerous goods register, hazard analysis and risk assessment report including specified bunding, isolation and action plans, is maintained as part of HUON’s Operational Procedures.

Public and agency comment

None

Evaluation

The risk of release to the environment of hazardous material is expected to be low, due to the low storage volumes at the extraction plant. The commitments in the EER, as stated above, reflect operational procedures suitable for appropriately managing hazardous materials on the Land, including Biosecurity Issues. No additional conditions are required.

Conclusion

No specific hazardous waste management conditions are required.

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Issue 5: Noise Emissions

Description of potential impacts

Noise emissions, from construction and operation of the activity, have the potential to cause environmental nuisance to sensitive receptors, including residences.

The complete processing plant will be contained in a purpose built food grade building with negative air pressure in proximity to the existing processing plant.

Noise emission sources from the existing processing plant include vehicle movements, refrigeration units, condenser systems and other process equipment items such as centrifuge, pumps and blowers.

The nearest residence is located over 1 kilometre to the north west of the existing processing plant.

Management measures proposed in EER

The EER states that existing noise minimisation measures will be continued for the proposed plant.

Commitments 9 and 10 relate to management of noise during constriction. These states that “the use of construction machinery at the site will comply with Schedule 7 of the Environmental Management and Pollution Control Act (Miscellaneous Noise) Regulations 2004” and that “all vehicles and machinery will have noise controls that comply with relevant standards.”

Commitment 18 dictates that “activities at the site will not cause a noise nuisance and will incorporate best practice environmental management to reduce noise emissions to the greatest extent that is reasonable practical.”

Public and agency comment

None

Evaluation

The extraction plant is to be located within a purpose built building in proximity to an existing processing plant. The processing plant currently has numerous noise emission sources that are managed under the relevant permit for the activity. The extraction plant is not expected to significantly contribute to or increase the noise emissions from the Land and sensitive receptors are unlikely to be impacted. Commitments 9, 10 and 18 are appropriate for managing noise issues during construction and operation. No noise conditions are therefore considered necessary. Any noise complaints can be managed through the regulatory framework defined under EMPCA.

Conclusion

No specific noise conditions are required. If noise complaints are received they will be managed under the regulatory framework defined under EMPCA.

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7 Report conclusions

This assessment has been based on the information provided by the proponent, HAC, in the permit application, EER, and in correspondence and discussion between the EPA Division and the proponent and the proponent’s representatives. This assessment has incorporated specialist advice provided by EPA Division scientific specialists and regulatory staff. It is concluded that:

1. the RMPS and EMPCS objectives have been duly and properly pursued in the assessment of the proposal; and

2. the assessment of the proposed activity has been undertaken in accordance with the Environmental Impact Assessment Principles.

It is concluded that the proposed activity is capable of being managed in an environmentally acceptable manner such that it is unlikely that the objectives of the Environmental Management and Pollution Control Act 1994 (the RMPS and EMPCS objectives) would be compromised, provided that the Permit Conditions - Environmental No. 9110 appended to this report are imposed and duly complied with.

8 Report approval Environmental Assessment Report and conclusions, including permit conditions, adopted:

Wes Ford DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY Acting under delegation from the Board of the Environment Protection Authority Date: 19th May 2016

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

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9 References

Pitt & Sherry; Fish Oil & Protein Extraction Plant, Environmental Effects Report, (dated 29/10/2015), Huon Aquaculture, Parramatta Creek, Tasmania

10 Appendices

Appendix 1 Permit conditions

Environmental Assessment Report Huon – Fish Oil & Protein Plant, Parramatta Creek

Appendix 1

Appendix 1 Permit conditions - Environmental

PERMIT PART BPERMIT CONDITIONS - ENVIRONMENTAL No. 9110

Issued under the Environmental Management and Pollution Control Act 1994

Activity: The operation of a fish oil processing plant (ACTIVITY TYPE: Rendering orFat Extraction Works (works not discharging all wastewater to externalapproved Wastewater Treatment Works).)PARRAMATTA CREEK PROCESSING FACILITY, 7218 BASS HWYEAST SASSAFRAS TAS 7307

The above activity has been assessed as a level 2 activity under the Environmental Managementand Pollution Control Act 1994 under delegation from the Board of the Environment ProtectionAuthority.

Acting under Section 25(5)(a)(i) of the EMPCA, the Board of the Environment ProtectionAuthority has required that this Permit Part B be included in any Permit granted under the Land UsePlanning and Approvals Act 1993 with respect to the above activity.

Municipality: LATROBEPermit Application Reference:EPA file reference: 242879

Date conditions approved: ______________________________________________

Signed: ______________________________________________

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

PCE 9110 (r1) 1/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

19 May 2016

DEFINITIONS

Unless the contrary appears, words and expressions used in this Permit Part B have the meaninggiven to them in Schedule 1 of this Permit and in the EMPCA. If there is any inconsistencybetween a definition in the EMPCA and a definition in this Permit Part B, the EMPCA prevails tothe extent of the inconsistency.

ENVIRONMENTAL CONDITIONS

The person responsible for the activity must comply with the conditions contained in Schedule 2 ofthis Permit Part B.

INFORMATION

Attention is drawn to Schedule 3, which contains important additional information.

PCE 9110 (r1) 2/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Table Of Contents

Schedule 1: Definitions....................................................................................................................... 4

Schedule 2: Conditions........................................................................................................................5Maximum Quantities................................................................................................................. 5

Q1 Regulatory limits ..............................................................................................5General.......................................................................................................................................5

G1 Access to and awareness of conditions and associated documents.................. 5G2 Incident response...............................................................................................5G3 No changes without approval............................................................................5G4 Notification prior to commissioning................................................................. 5

Atmospheric...............................................................................................................................5A1 Control of dust emissions during construction................................................. 5A2 Odour management........................................................................................... 6A3 Odour survey.....................................................................................................6A4 Odour survey report.......................................................................................... 6A5 Atmospheric Dispersion Modelling ................................................................. 6

Effluent Disposal....................................................................................................................... 7E1 Wastewater management...................................................................................7E2 Solid matter in wastewater................................................................................ 7

Operations..................................................................................................................................7OP1 Fish waste management.................................................................................. 7OP2 Operational Footprint .....................................................................................7

Schedule 3: Information...................................................................................................................... 8Legal Obligations.......................................................................................................................8

LO1 EMPCA.......................................................................................................... 8LO2 Storage and handling of dangerous goods, explosives and dangeroussubstances............................................................................................................... 8LO3 Aboriginal relics requirements....................................................................... 8LO4 Change of responsibility.................................................................................8

Other Information...................................................................................................................... 9OI1 Waste management hierarchy..........................................................................9OI2 Notification of incidents under section 32 of EMPCA ...................................9OI3 Commitments...................................................................................................9

Attachments

Attachment 1: The Land (modified: 12/05/2016 09:32)..............................................................1 page

Attachment 2: Operational Footprint (modified: 12/05/2016 09:32).......................................... 1 page

Attachment 3: Commitments (modified: 05/05/2016 15:56).......................................................1 page

PCE 9110 (r1) 3/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Schedule 1: Definitions

In this Permit Part B:-

Aboriginal Relic has the meaning described in section 2(3) of the Aboriginal Relics Act 1975.

Activity means any environmentally relevant activity (as defined in Section 3 of EMPCA) to whichthis document relates, and includes more than one such activity.

Commissioning means the testing of major items of equipment and is taken to be completed whenthe item(s) are being used or operated in the course of normal commercial operations.

Construction means activities associated with the construction phase of the activity, including butnot limited to, activities associated with the clearance of vegetation, site works to create a level site,rock breaking, installation of fences and other infrastructure whether on land or in water.

Director means the Director, Environment Protection Authority holding office under Section 18 ofEMPCA and includes a person authorised in writing by the Director to exercise a power or functionon the Director's behalf.

EER means document entitled Huon Aquaculture, Parramatta Creek, Fish Oil & ProteinExtraction Plant, Environmental Effects Report prepared by Pitt & Sherry and dated 29 October2015.

EMPCA means the Environmental Management and Pollution Control Act 1994.

Environmental Harm and Material Environmental Harm and Serious Environmental Harmeach have the meanings ascribed to them in Section 5 of EMPCA.

Environmental Nuisance and Pollutant each have the meanings ascribed to them in Section 3 ofEMPCA.

Operational Footprint means the area defined as the 'proposed salmon oil exrtraction plant' inFigure 3 of the EER and as delineated in Attachment 2 of these conditions.

Person Responsible is any person who is or was responsible for the environmentally relevantactivity to which this document relates and includes the officers, employees, contractors, jointventure partners and agents of that person, and includes a body corporate.

The Land means the land on which the activity to which this document relates may be carried out,and includes: buildings and other structures permanently fixed to the land, any part of the landcovered with water, and any water covering the land. The Land falls within the area defined by:

1 certificate of title 158261/1; and2 as further delineated at Attachment 1.

Waste has the meaning ascribed to it in Section 3 of EMPCA.

Wastewater means spent or used water (whether from industrial or domestic sources) containing apollutant and includes stormwater which becomes mixed with wastewater.

PCE 9110 (r1) 4/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Schedule 2: Conditions

Maximum Quantities

Q1 Regulatory limits1 The activity must not exceed the following limits (annual fees are derived from these

figures):1.1 850 kilograms per hour or kilograms per batch of product.

General

G1 Access to and awareness of conditions and associated documentsA copy of these conditions and any associated documents referred to in these conditions mustbe held in a location that is known to and accessible to the person responsible for the activity.The person responsible for the activity must ensure that all persons who are responsible forundertaking work on The Land, including contractors and sub-contractors, are familiar withthese conditions to the extent relevant to their work.

G2 Incident responseIf an incident causing or threatening environmental nuisance, serious environmental harm ormaterial environmental harm from pollution occurs in the course of the activity, then theperson responsible for the activity must immediately take all reasonable and practicable actionto minimise any adverse environmental effects from the incident.

G3 No changes without approval1 The following changes, if they may cause or increase the emission of a pollutant which

may cause material or serious environmental harm or environmental nuisance, mustonly take place in relation to the activity if such changes have been approved in writingby the EPA Board following its assessment of an application for a permit under theLand Use Planning and Approvals Act 1993, or approved in writing by the Director:1.1 a change to a process used in the course of carrying out the activity; or1.2 the construction, installation, alteration or removal of any structure or equipment

used in the course of carrying out the activity; or1.3 a change in the quantity or characteristics of materials used in the course of

carrying out the activity.

G4 Notification prior to commissioningAt least 14 days prior to the commencement of commissioning of the processing equipmentassociated with the activity, the person responsible for the activity must notify the Director ofthe date on which commissioning is expected to commence.

Atmospheric

A1 Control of dust emissions during construction1 Construction activities must be managed using such measures as are necessary to

prevent dust emissions causing environmental nuisance. Such measures may include butare not limited to:1.1 using a dust suppression method such as watering dust generating surfaces; and1.2 ceasing construction activities in windy weather when dust may be blown in the

direction of residences.

PCE 9110 (r1) 5/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

A2 Odour managementThe person responsible must institute such odour management measures as are necessary toprevent odours causing environmental nuisance beyond the boundary of The Land.

A3 Odour survey1 Within 30 days of the completion of commissioning of the activity, a proposed odour

survey methodology must be submitted to the Director for approval.2 The methodology must include:

2.1 proposals for measurement of odour emissions;2.2 recommendations for seasonal and operating conditions most suitable for

undertaking the odour survey; and2.3 a timetable for the completion of the odour survey.

3 Unless otherwise approved in writing by the Director, a survey of odour emissions fromthe activity must be completed within 12 months of the date of completion ofcommissioning.

4 The survey of odour emissions must be undertaken in accordance with the approvedmethodology.

A4 Odour survey report1 Odour survey results for the activity must be submitted to the Director wihtin 30 days of

the completion of the odour survey in the form of a written odour survey report.2 Unless otherwise approved in writing by the Director, the report must include:

2.1 a comparison of odour emission rates calculated from the odour survey and theodour emission rates used as an input to the atmospheric dispersion modellingincluded in the EER; and

2.2 discuss any difference between the measured odour emission rate values and thoseassumed as atmospheric dispersion modelling input values in the EER andconclude if odorous gases from the activity are likely to cause environmentalnuisance beoynd the boundary of The Land.

A5 Atmospheric Dispersion Modelling1 Unless otherwise approved in writing by the Director, atmospheric dispersion modelling

must be completed within 60 days of the odour survey report being submitted to theDirector.

2 The atmospheric dispersion modelling must be submitted to the Director in the form ofa written report.

3 The report must include:3.1 A map of the activity and surrounds with the following particulars:

3.1.1 The location of emission sources;3.1.2 The boundary of the Land;3.1.3 Ground level concentration contours with a key or legend; and3.1.4 The location of the nearest sensitive receptors.

3.2 Details of the limits and criteria specified in the Air Quality EPP relevant to theactivity.

3.3 Odour concentrations at the nearest sensitive receptors.3.4 Identification of any breaches of the relevant limits and criteria specified in the

Air Quality EPP and explanation of reasons for the presence of breaches.

PCE 9110 (r1) 6/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

3.5 Details of actions proposed to address each identified breach of the limits orcriteria.

Effluent Disposal

E1 Wastewater managementWastewater generated from the activity must be discharged to a wastewater treatment facilityapproved, in writing by the Director, to receive the wastewater from the activity.

E2 Solid matter in wastewater1 Solid matter must be prevented by all reasonable means from entering the wastewater

stream. Without limiting the generality of the term, reasonable means includes:1.1 effective screening at all points of wastewater ingress to the wastewater treatment

system to prevent the entry of gross solids;1.2 implementation of comprehensive operating procedures, and the appropriate

training and supervision of employees, contractors and sub-contractors; and1.3 good housekeeping including the provision of adequate containers to avoid loss to

the floor and the control of spillage by sweeping, shovelling, impoundment, or theentrapment of wastes in tanks or vessels for further treatment before disposal.

Operations

OP1 Fish waste management1 Only fish waste streams generated on the Land are to be procsessed by the activity.2 Fish waste streams must be processed or removed from the Land within 48 hours of

generation, unless frozen.

OP2 Operational FootprintThe activity must be undertaken within the operational footprint.

PCE 9110 (r1) 7/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Schedule 3: Information

Legal Obligations

LO1 EMPCAThe activity must be conducted in accordance with the requirements of the EnvironmentalManagement and Pollution Control Act 1994 and Regulations thereunder. The conditions ofthis document must not be construed as an exemption from any of those requirements.

LO2 Storage and handling of dangerous goods, explosives and dangerous substances1 The storage, handling and transport of dangerous goods, explosives and dangerous

substances must comply with the requirements of relevant State Acts and anyregulations thereunder, including:1.1 Work Health and Safety Act 2012 and subordinate regulations;1.2 Explosives Act 2012 and subordinate regulations; and1.3 Dangerous Goods (Road and Rail Transport) Act 2010 and subordinate

regulations.

LO3 Aboriginal relics requirements1 The Aboriginal Relics Act 1975, provides legislative protection to Aboriginal heritage

sites in Tasmania regardless of site type, condition, size or land tenure. Section 14(1) ofthe Act states that; Except as otherwise provided in this Act, no person shall, otherwisethan in accordance with the terms of a permit granted by the Minister on therecommendation of the Director of National Parks and Wildlife:1.1 destroy, damage, deface, conceal or otherwise interfere with a relic;1.2 make a copy or replica of a carving or engraving that is a relic by rubbing, tracing,

casting or other means that involve direct contact with the carving or engraving;1.3 remove a relic from the place where it is found or abandoned;1.4 sell or offer or expose for sale, exchange, or otherwise dispose of a relic or any

other object that so nearly resembles a relic as to be likely to deceive or becapable of being mistaken for a relic;

1.5 take a relic, or permit a relic to be taken, out of this State; or1.6 cause an excavation to be made or any other work to be carried out on Crown land

for the purpose of searching for a relic.2 If a relic is suspected and/or identified during works then works must cease immediately

and the Tasmanian Aboriginal Land and Sea Council and the Aboriginal HeritageTasmania be contacted for advice before work can continue. In the event that damage toan Aboriginal heritage site is unavoidable a permit under section 14 of the AboriginalRelics Act 1975 must be applied for. The Minister may refuse an application for apermit, where the characteristics of the relics are considered to warrant theirpreservation.

3 Anyone finding an Aboriginal relic is required under section 10 of the Act to report thatfinding as soon as practicable to the Director of National Parks and Wildlife or anauthorized officer under the Aboriginal Relics Act 1975. It is sufficient to report thefinding of a relic to Aboriginal Heritage Tasmania to fulfil the requirements of section10 of the Act.

LO4 Change of responsibilityIf the person responsible for the activity ceases to be responsible for the activity, they mustnotify the Director in accordance with Section 45 of the EMPCA.

PCE 9110 (r1) 8/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Other Information

OI1 Waste management hierarchy1 Wastes should be managed in accordance with the following hierarchy of waste

management:1.1 waste should be minimised, that is, the generation of waste must be reduced to the

maximum extent that is reasonable and practicable, having regard to best practiceenvironmental management;

1.2 waste should be re-used or recycled to the maximum extent that is practicable;and

1.3 waste that cannot be re-used or recycled must be disposed of at a waste depot siteor treatment facility that has been approved in writing by the relevant planningauthority or the Director to receive such waste, or otherwise in a manner approvedin writing by the Director.

OI2 Notification of incidents under section 32 of EMPCAWhere a person is required by section 32 of EMPCA to notify the Director of the release of apollutant, the Director can be notified by telephoning 1800 005 171 (a 24-hour emergencytelephone number).

OI3 CommitmentsThe person responsible for the activity has a general environmental duty to conduct theactivity in accordance with the commitments contained in Attachment 3.

PCE 9110 (r1) 9/12

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Attachment 1: The Land

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Attachment 2: Operational Footprint

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY

Attachment 3: Commitments

DIRECTOR, ENVIRONMENT PROTECTION AUTHORITY