RESOURCE CONSENT APPLICATION AND ASSESSMENT ......6.4 Waikato Regional Council Waste Minimisation Strategy 37 6.5 Waikato-Tainui Environmental Management Plan 38 6.6 Part 2 of the

TUAKAU PROTEINS LTD

RESOURCE CONSENT APPLICATION AND ASSESSMENT OF ENVIRONMENTAL EFFECTS

Air Discharges from Tuakau Site FINAL

January 2018

Tuakau Proteins Ltd Air Discharge Consent Application and AEE

TABLE OF CONTENTS

Part A: Resource Consent Application

Part B: Assessment of Environmental Effects

1. Introduction ___________________________________________________________ 1

2. Existing Environment ___________________________________________________ 2

2.1 Existing Site and Locality 22.2 Land Use Planning Zones 6

3. Description of Proposed Activities _________________________________________ 12

3.1 Introduction 123.2 Background to Historic Issues and Improvements 123.3 Existing Activities 143.4 Proposed Changes 153.5 Contingency Measures 163.6 Proposed Consent Conditions 16

4. RMA Status of Proposed Activities ________________________________________ 18

5. Assessment of Environmental Effects ______________________________________ 19

5.1 Positive Effects 195.2 Odour and Dust Effects 19

6. Statutory Assessment _________________________________________________ 24

6.1 Introduction 246.2 Waikato Regional Policy Statement 256.3 Waikato Regional Plan 286.4 Waikato Regional Council Waste Minimisation Strategy 376.5 Waikato-Tainui Environmental Management Plan 386.6 Part 2 of the RMA 386.7 Alternatives 41

7. Consultation and Notification ___________________________________________ 42

7.1 Consultation with Local Community 427.2 Tangata Whenua Consultation 427.3 Notification 42

8. Conclusions _________________________________________________________ 44

LIST OF APPENDICES

Appendix 1: Waikato Regional Council Application Forms A, B and C

Appendix 2: Computer Freehold Registers

Appendix 3: Tonkin & Taylor ‘Assessment of Air Quality Separation Distances’ report

Tuakau Proteins Ltd Air Discharge Consent Application and AEE

Appendix 4: 2013 and 2015 Golder reviews of odour discharges

Appendix 5: 2017 Golder odour effects assessment report

Appendix 6: Air Quality Management Plan

Appendix 7: Proposed resource consent conditions

Appendix 8: PDP 2016/17 annual monitoring report

REPORT INFORMATION

Final

20386

Hamilton

David Ray

Lucy Smith and Stephen Daysh

© Mitchell Daysh Limited (2018).

This document and its contents are the property of Mitchell Daysh Limited. Any unauthorised employment or reproduction, in full or in part, is forbidden.

PART A

Resource Consent Application

Tuakau Proteins Ltd Air Discharge Consent Application and AEE 1

FORM 9

APPLICATION FOR RESOURCE CONSENT

Sections 88 and 145, Resource Management Act 1991

To Waikato Regional Council

Tuakau Proteins Limited (Lapwood Road, Tuakau); applies for the following type(s) of resource consent:

air discharge consent

The activity to which the application relates (the proposed activity) is as follows:

Air discharge consent is sought to discharge contaminants into the air from a meat rendering and processing plant.

The site at which the proposed activity is to occur is as follows:

(a) The location of the proposed activity is 30 Lapwood Road, off River Road, approximately 1.5km south of Tuakau;

(b) Map reference: NZTM 1771500E 5871900N NZTopo50-BC32 715719

(c) The property is legally described as Allot 54A Suburbs of Tuakau, Part Allot 54 Suburbs of Tuakau and Lot 1 Deposited Plan 43146 (Computer Freehold Register contained in Appendix 2 in Part B of this document)

The site is owned by Tuakau Proteins Limited.

There are no other activities that are part of the proposal to which this application relates.

No additional resource consents are needed for the proposal to which this application relates.

I attach an assessment of the proposed activity’s effect on the environment that—

(a) includes the information required by clause 6 of Schedule 4 of the Resource Management Act 1991; and

(b) addresses the matters specified in clause 7 of Schedule 4 of the Resource Management Act 1991; and

(c) includes such detail as corresponds with the scale and significance of the effects that the activity may have on the environment.


I attach an assessment of the proposed activity against the matters set out in Part 2 of the Resource Management Act 1991.

I attach an assessment of the proposed activity against any relevant provisions of a document referred to in section 104(1)(b) of the Resource Management Act 1991, including the information required by clause 2(2) of Schedule 4 of that Act.

Date: 26 January 2018

David Ray, Mitchell Daysh Ltd Person authorised to sign on behalf of applicant.

Address for Service: Mitchell Daysh Limited PO Box 1307, Hamilton 3240

Attention: David Ray

Telephone: +64 4 838 5677 Mobile: +64 27 419 1166 Email: [email protected]

Contact person: David Ray

Billing Address: Stephen Dahlenburg Tuakau Proteins Ltd PO Box 172 Hawera

PART B

Assessment of Environmental Effects

Tuakau Proteins Ltd Air Discharge Consent Application and AEE - DRAFT

EXECUTIVE SUMMARY

Tuakau Proteins Limited (TPL) owns and operates a meat byproducts processing plant at Lapwood Road, near Tuakau. TPL holds WRC resource consent number 117492 for the discharge of contaminants from the site into the air. This document comprises an application to renew consent 117492 for a term of 25 years.

The rendering process is an essential function of the agricultural, poultry, fish, meat and related industries, and these industries could not function effectively at scale without it. Rendering is essentially a recycling service; large volumes of by-product material that would otherwise require disposal as waste are collected and processed. Almost all of the TPL site’s products are exported, generating valuable export earnings. The site employs 33 people. The operation therefore provides significant social and economic benefits to the communities of the Tuakau/Pukekohe/Pokeno area and, more generally, the upper North Island. The operation also helps support the economy of ‘NZ Inc.’, given that almost 100% of the site’s product is exported. Furthermore, the operation supports the Waikato Region’s and New Zealand’s waste minimisation strategy, by helping to avoid the deposition of meat processing byproducts into landfills, and other less environmentally-friendly disposal methods.

A range of upgrades have been carried out since 2012 to improve odour control at the TPL site, being in summary:

ducting upgrades to process lines to improve capture of odorous gases from the rendering process

biofilter upgrades, to improve the odour removal performance of those biofilters

improvements to the anaerobic pond gas control systems

the LTR2 raw material receipt building and associated low temperature rendering line, meal dryer and blood drying activities have been decommissioned, and replaced by the LTR2b and HT processing lines, with improved odour control systems

the exhaust air cooling systems have been upgraded with installation of new cooling towers, significantly improving the odour removal performance of the biofilters

general improvement in operational and management procedures to minimise odour emissions

In addition, a third cooling tower has been installed during December 2017, which will improve the efficiency and effectiveness of the exhaust air cooling system.

These improvements have significantly reduced odour emissions from the site.

There are now significant further changes planned for the site as part of ongoing modernisation and upgrade of the facility. This includes the installation of a new meal processing building and loadout area, and demolishing the disused DAF plant (previously


a potential source of unpleasant odour). Internal rearrangement of the LTR1 processing line will concentrate the cooking sources together and allow the dryer and meal processing areas to be co-located. Additionally, relocation of the tallow recovery separators and tanks will allow further targeted extraction of odour sources in these areas. These changes will allow for improved odour control, as they will minimise the escape of odorous gases into the building air space. The above upgrades are planned to be completed by 30 June 2018.

The potential effects of the discharges to air from the TPL site will be no more than minor. The following key points support this conclusion:

The odour mitigation measures listed above have significantly reduced odour emissions. This has been evidenced by the marked reduction in odour complaints from neighbours in the past few years, and feedback from the most recent Community Liaison Group Meetings.

The range of further odour mitigation improvements proposed by TPL will further reduce odour emissions.

The plant will be operated in accordance an Air Quality Management Plan that is appended to this document, which will help ensure that:

odour emissions are controlled appropriately on a day-to-day basis and also in the event of untoward incidents occurring, e.g. equipment failure

regular maintenance works are carried out as required to avoid deterioration of odour control equipment and measures.

A two-yearly review process of the odour management system is proposed, which will ensure that any unforeseen problems are identified and addressed.

The proposed activities are consistent with Part 2 of the Resource Management Act 1991 and the relevant objectives and policies of the Waikato Policy Statement and Waikato Regional Plan.

Consultation has been undertaken with neighbours. The general consensus is that odour generation from the site has reduced markedly over the last two years. Consultation is ongoing.

It is requested that this consent application be processed on a limited notification basis to people occupying or owning dwellings within 1 km of the site.


1. INTRODUCTION

Tuakau Proteins Limited (TPL) owns and operates a meat byproducts processing plant at Lapwood Road, near Tuakau. The plant has been in operation under various owners since the late 1970’s. Lowe Corporation, through its subsidiary company Graeme Lowe Protein, assumed full ownership in 2000. The plant was purchased by TPL in 2014.

TPL holds WRC resource consent number 117492 for the discharge of contaminants from the site into the air. Consent 117492 expires on 1 August 2018. This document comprises an application to renew consent 117492. The term of consent sought is 25 years. WRC’s standard consent application forms A, B and C are included in Appendix 1 of this Assessment of Effects on the Environment (AEE).

TPL also hold resource consent 137431.01.01 for the discharge of contaminants to air from two 10 MW natural gas fired boilers. TPL has considered consolidating the two consents into a single air discharge consent for the site (i.e. including the boiler discharges within the scope of the subject consent application), but it has decided to retain consent 137431, primarily because (i) the boiler discharges are discreet discharges separate from the other site discharges, and (ii) consent 137431 does not expire until 2041.

The structure of this AEE is as follows:

Section 2 describes the existing environment.

Section 3 describes the activities for which the consent is sought.

Section 4 identifies the status of the proposed activities under the RMA.

Section 5 provides an assessment of the effects on the environment associated with the proposed activities.

Section 6 provides an analysis of the proposed activities in relation to the provisions of the relevant policy and planning documents, along with Part 2 of the RMA.

Section 7 discusses the consultation undertaken and notification requirements for the consent applications.

Section 8 describes the key conclusions of this AEE.

A number of reports supporting this AEE are reproduced in the appendices of this AEE, as follows:

Tonkin & Taylor ‘Assessment of Air Quality Separation Distances’ report (Appendix 3)

2013 and 2015 Golder reviews of odour discharges (Appendix 4)

2017 Golder odour effects assessment report (Appendix 5)

Air Quality Management Plan (Appendix 6)

PDP 2016/17 annual monitoring report (Appendix 8)


2. EXISTING ENVIRONMENT

2.1 EXISTING SITE AND LOCALITY

The TPL site is located adjacent to the Waikato River, on Lapwood Road, which is accessed from River Road, about 1.5 kilometres south of Tuakau (Figure 1 below). It occupies a raised site overlooking adjoining fields to the north. The total site area is 5.5 ha. The plant was established on the present site in 1972. The company processes meat by-product from a variety of licensed meat processing sources.

The main features of the site are (refer to Figure 2 below):

Inward materials load-in area at the eastern end of the processing buildings

Rendering plant buildings and meal hall

Boilerhouse

Workshop

Administrative buildings and staff facilities

Wastewater treatment plant, comprising a covered anaerobic pond, storage pond, aerobic pond, clarifier and rock outfall

Two biofilters, used to treat air discharges from the plant

Site roading, mainly unsealed

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The site’s existing processing activities are described in Section 3 below.

Table 2.1 below identifies all existing and relevant resource consents.

Table 2.1: Existing Resource Consents held by the site

Reference Number Details

117492 Discharge odour and particulate matter into the air from a meat rendering and blood processing plant – Expiring 1 August 2018 (subject of this resource consent renewal application)

134280 Discharge of treated effluent, clean process water and stormwater to the Waikato River and to land via seepage – Expiring 12 November 2035

137431 Discharge contaminants to air from two new 10 MW natural gas fired boilers – Expiring November 2041

107996 Surface water take – Expiring 1 October 2029

115652 Ground water take – Expiring 1 July 2023

121874 Discharge to Air – 10 MW Boilers – Expiring 15 October 2035

125896 Biosolids Discharge to Land and Air – Expiring 31 January 2027

LUC0175/17 (Waikato District Council)

Construct a new boilerhouse in association with the existing and consented activities on the site that is unable to comply with height in relation to boundary on the southern boundary, parking spaces and earthworks in the Business Zone – Expiring 15/11/2021

The site is surrounded by a mix of residential and commercial operations. The nearest residential property is located across Lapwood Road, which has been purchased recently by TPL. The nearest two dwellings not owned by TPL are immediately adjacent to the eastern site boundary, approximately 130m east of the plant and approximately 170m southeast of TPL’s wastewater treatment plant. There is a light engineering firm and a chicken hatchery that are both off River Road, approximately 400-500m to the northeast of the TPL site. EnviroFert, a composting facility, also is located approximately 600-700m to the northwest of the TPL site.

The site is exposed to a significant percentage of south-westerly to westerly winds (45% of total time). This is discussed in greater detail in a Golder report, as referred to in Section 5.2.1 below.

Although the TPL site is located adjacent to the Waikato River, it is elevated above river level on a river terrace/rise.


In terms of the investment in the Plant, the replacement value is approximately $50M (buildings and plant; excludes land value). In addition, approximately $1M is spent on maintenance per year, much of that using external contractors.

2.2 LAND USE PLANNING ZONES

Although this AEE is for an air discharge consent which is administered by Waikato Regional Council, it is considered relevant to understand the existing land use planning zone and the potential for the land use planning policy to change. This is relevant as when environmental effects such as odour are considered, it is important to understand the potential of the existing environment to be altered in the future towards different land uses.

2.2.1 Operative Waikato District Plan

The TPL site is located within the Business Zone of the Operative Waikato District Plan (2013) – Franklin District Plan section, and the surrounding area within 1 km of the TPL site comprises mainly Rural Zone and Recreation Zone land (as shown in Figure 3). There is an area of Rural Residential zoned land with its south-western extremity located approximately 900 m from the site. There is also a strip of land along the west side of the northern end of River Road zoned Business Zone.


Figure 3: Operative Waikato District Plan Planning Map, with legend (TPL site is indicated at bottom left)

2.2.2 Tuakau Structure Plan

The Tuakau Structure Plan was prepared by WDC in December 2014 as a guide to the long-term development of the town over the next 30 years. One of its purposes was to inform a plan change to the Waikato District Plan to incorporate appropriate rezoning and development controls to enable the future growth and development of Tuakau.

Figure 4 below shows the proposed rezoning signalled in the Structure Plan. The main changes proposed in relation to the TPL site was the rezoning of a strip of land along the west side of River Road from Rural Zone to Light Industrial Zone, and the rezoning of the

TPL site


Rural Residential zone at the south end of the Tuakau township (shown in Figure 3 above) to Residential Zone.

Figure 4: Tuakau Structure Plan – Staging of Development (Figure 20 from the Plan)

Following the development of the Structure Plan, WDC commissioned Tonkin & Taylor Ltd (T&T) in May 2015 to prepare an assessment of air quality effects and separation distances1 to support Council’s plan change process. The T&T report (reproduced in Appendix 3 of this AEE) suggested a 1 km ‘air quality separation distance’ around the TPL site, to separate the TPL industrial activity from more sensitive activities such as dwellings or schools (Figure 5 below).

1 ‘Tuakau Structure Plan – Assessment of Air Quality Separation Distances’. Tonkin & Taylor Ltd, August 2015.


Figure 5: T&T recommended 1 km air quality separation distance for TPL site (purple circle) (Figure 2 from 2015 T&T report)

2.2.3 Plan Change 16 (withdrawn)

Plan Change 16 to the Waikato District Plan (PC16) was notified in July 2016. It envisaged two zone changes in the vicinity of the TPL site (Figure 6 below):

Rezoning the TPL site and another industrial area to the north of the TPL site from Business to Industrial Zone

Rezoning the Rural Residential zoned land at the south end of the township to Residential Zone.

The Structure Plan proposal to rezone the larger area of land along the west side of River Road from Rural Zone to Light Industrial Zone was not carried forward in PC16. An area at the southern extremity of the Tuakau township was proposed to be rezoned from Rural Residential to Residential, the boundary of which is located approximately 900 m from the TPL site.

Submissions on PC16 closed in November 2016. The industrial component of PC16 was withdrawn by WDC in December 2016, on the grounds that it was more appropriate to address new provisions for industry in Tuakau through the upcoming comprehensive District Plan review. The Plan Change was withdrawn in its entirety in September 2017, on the basis that the proposed new Waikato District Plan would address the growth of Tuakau


and provide significantly more flexible options for residential development, effectively addressing the many submissions on PC 16 seeking greater flexibility.

Figure 6: Map 4 of Plan Change 16 to the Waikato District Plan (from page 33 of PC 16)

2.2.4 Waikato District Plan Review

A review of the District Plan is currently underway, with public open days held in November and December 2017. WDC have indicated that the draft plan will be notified in mid 2018.

At the time of writing, the draft plan is proposing to change the zone of the TPL site from business to industrial, similar to PC16 (see Figure 7 below). It also does not envisage land use zoning allowing for increased density of residential development within 1 km of the TPL site greater than that provided for under the Operative District Plan (the only exception being proposals to rezone from Rural Residential to Residential in an area 900m from the site).

Due to concerns about potential reverse sensitivity, TPL will continue to monitor the Waikato District Plan Review and to be involved in submissions as it is important to ensure that the 1,000m air quality separation distance is ratified as minimum setback for future residential development in Tuakau.


Figure 7: Draft Proposed Changes to Waikato District Plan (map prepared by Mitchell Daysh, based on WDC’s draft plan change maps).


3. DESCRIPTION OF PROPOSED ACTIVITIES

3.1 INTRODUCTION

This section provides a summary of the recent history of the TPL site, and the existing and proposed activities, relating to the site’s air discharges (apart from the gas-fired boiler, as discussed in Section 1 above).

TPL is a contract renderer that processes meat by-product materials from a variety of licensed meat processing sources. Raw material is mainly bovine, chicken and ovine, with some pork, equine and fish material also being processed at times.

The TPL plant currently employs 33 people and operates 24 hours a day, seven days a week.

The locations of key plant items are shown in Figure 2 on page 4 above.

3.2 BACKGROUND TO HISTORIC ISSUES AND IMPROVEMENTS

While the existing activities at the site are described in Section 3.3 below, it is relevant to review the recent history of air discharges management at the TPL site since the last air discharge consent was granted in 2012.

The current air discharge consent for the site, number 117492, commenced on 19 October 2012, for a term expiring on 1 August 2018. Conditions 3 to 5 of that consent specified a range of site upgrades to improve odour control at the site, being in summary:

ducting upgrades to process lines LTR1 and LTR2 to improve capture of odorous gases from the rendering process;

biofilter upgrades, to improve the odour removal performance of those biofilters; and

anaerobic pond gas control systems, including:

upgrade of the entire piping system, extending from the pond biogas collection chambers to the biogas flare;

flame detection system for the biogas flare to detect any failure of the flare and activate an automatic alarm in the event of failure.

Condition 6 of the consent required reviews of the performance of the odour control system during 2013 and 2015. Those reviews were undertaken by odour control specialists Golder Associates. The 2013 and 2015 Golder review reports are reproduced in Appendix 4 of this AEE.

The Golder reports commented on the improvements that had been made in accordance with the requirements of the consent conditions, and identified some further issues that required addressing, for example:


odorous steam emissions from the liquid phase tank of LTR1

fugitive emissions from some of the buildings, including the DAF building

uneven loading of the biofilters

uneven and on some cases inadequate vacuum applied to process lines

inadequate cooling of exhaust air, resulting in a reduction in the odour removal performance of the biofilters

Golder noted that odour emissions from the wastewater treatment system had been well managed since 2012, and all ongoing odour issues were related to the rendering process systems rather than the wastewater treatment system.

In addition to the upgrades that have been carried out as required by consent 117492, TPL has proactively undertaken a range of further improvements, partly in response to the Golder reports, and as part of general ongoing site improvements, such as (further detail is contained in the Golder reports):

The LTR2 raw material receipt building and associated low temperature rendering line, meal dryer and blood drying activities have been decommissioned, and replaced by the LTR2b and HT lines, with improved odour control systems

the blood dryer and associated baghouse filter were decommissioned, removing this as an odour source

the exhaust air cooling systems have been upgraded with installation of new cooling towers, significantly improving the odour removal performance of the biofilters – this has been one of the most significant odour control improvements at the site in recent years, as discussed in Section 3.3 below

the gas-fired boilers have been upgraded recently with more powerful units, which will be more reliable than the old boilers, and can process product more quickly and efficiently; both these aspects reduce the potential for off-site odour effects from unprocessed raw material

general improvement in operational and management procedures to minimise odour emissions

These improvements have significantly reduced odour emissions from the site, which has been evidenced by a marked reduction in odour complaints from neighbours, as discussed in greater detail in Section 6 below. Further improvements are proposed, as discussed in Section 3.4 below.

In addition, a third cooling tower has been installed during December 2017, which will improve the efficiency and effectiveness of the exhaust air cooling system, and thus help reduce the potential for odour discharges further.


3.3 EXISTING ACTIVITIES

This section describes the existing activities that lead to air discharges at the TPL site (apart from the gas-fired boiler, as addressed in Section 1 above). The activities are described in greater detail in a 2017 Golder report which is reproduced in Appendix 5 of this AEE.

The primary processes at the site include receipt and storage of the raw by-products. Raw materials are delivered by truck and unloaded inside the reception halls, which are fitted with roller doors that remain closed except when being used for delivery of incoming materials or when cleaning up.

The raw materials are ground up, cooked, pressed, and dried. The dried cooked material is milled to produce meat and bone meal, which is then stored in large bins. Some of the product is bagged and some is dispatched from the site in bulk containers. There are two low temperature by-product rendering lines (LTR1 and the newer LTR2b) as well as one high temperature (HT) rendering line. Due to market requirements, the different lines generally process different input materials.

Typically LTR1 processes bovine material, LTR2b processes chicken and ovine material and the HT line processes hard offal and butchery waste that is made up of mixed material including pork. Blood is also received and processed as an additional protein source through LTR1.

The cooking and pressing processes produce a liquid stream containing tallow and protein. This stream is separated from the cooked solids at various process stages. Tallow is separated from the liquor in tallow separators (disk centrifuges). The resultant protein-rich liquor remaining after the tallow recovery is called ‘stickwater’. The stickwater is concentrated via evaporation and recycled into the process. The evaporated vapours are condensed and discharged to the site’s wastewater treatment plant (WWTP). Treated wastewater from the WWTP is discharged to the Waikato River, as authorised by WRC consent 134280.

Process air and vapours and building air streams are extracted from the three rendering lines and pre-cooled prior to treatment via two biofilters that remove odour before discharging the treated air streams to the atmosphere. This is the primary method of capturing and mitigating rendering odour at the site, and is referred to as a ‘point source extraction system’. Provided that the point source extraction system is well operated and maintained, only minimal odour will escape into the rendering buildings. The way in which the system will be operated and maintained is set out in a draft Air Quality Management Plan (AQMP) for the site, reproduced in Appendix 6 of this AEE. The AQMP will be updated whenever there are any significant changes to the site processes or odour management systems, or every two years, whichever occurs sooner.


Biofilters are a well-proven and industry best-practice odour treatment system. They rely mainly on micro-organisms living within the biofilter for odour treatment. These micro-organisms utilise the organic compounds within the air discharge as a food source, and thereby convert the odorous gases into less odorous gases. As discussed in Section 3.2 above, the performance and reliability of the biofilters has improved markedly in recent years due to the upgrade of the air cooling system.

Ambient air within the raw material receiving building and the process line buildings is also extracted and passed through the biofilters. However, provided the point source air extraction system as described in the previous paragraph operates properly, this building ambient air treatment is not necessary to avoid off site odour effects. Nevertheless, TPL proposes to maintain the existing building ambient air extraction, which can be regarded as a ‘back-up’ control system to the point source extraction system, in the event that any short-term problems develop with the point source extraction system.

3.4 PROPOSED CHANGES

There are significant layout changes planned for the site as part of ongoing modernisation and upgrade of the facility. This includes a new weigh bridge, installation of a new meal processing building and loadout area adjacent to the LTR1 and LTR2b buildings. It is also planned to demolish the disused DAF plant (previously a potential source of unpleasant odour). The DAF plant is no longer required as part of the wastewater treatment process, as the high strength wastewater that was treated in the DAF is now recirculated within the rendering plant, and fats and other material is recovered for incorporation into saleable product.

Subsequent to the construction of the new meal processing building, demolition of the old meal room and some of the old LTR2 buildings on the southern side of the site will be completed.

Internal rearrangement of LTR1 will concentrate the cooking sources together and allow the dryer and meal processing areas to be co-located. This will increase plant efficiencies in the situation when product needs to be reprocessed. Additionally, relocation of the tallow recovery separators and tanks is planned, which will allow them to be centrally located in the building and allow further targeted extraction of odour sources in these areas. Associated improvements to the point source extraction system will be designed by Golder or another suitably qualified and experienced person(s).

These changes will allow for improved odour control, as they will minimise the escape of odorous gases into the building air space.

The above upgrades are planned to be completed by 30 June 2018.

TPL will engage an odour management specialist to review the point source extraction system after the rearrangement of the LTR1 process line. The review will include


measurements to confirm that vacuum is maintained within the point source extraction ducts (near to the point of connection to equipment), to confirm there that there is adequate extraction / containment of fugitive process odour emissions. This review will be repeated two-yearly for a minimum period of 6 years from the commencement of the new consent. TPL has proffered a consent condition requiring this review, as set out in the proposed conditions contained in Appendix 7 of this AEE. It is noted that this proffered condition is contingent on a 25 year term consent being granted by WRC.

3.5 CONTINGENCY MEASURES

As is best practice for any large primary processing industrial site, TPL has in place a range of contingency measures to manage untoward events such as equipment failure, to ensure that offsite odour effects continue to be managed appropriately.

The key contingency measure is the ability to process material through either of the LT lines or the HT line, which provides redundancy to the processing capacity. This avoids the risk of raw material having to be stored for long periods, awaiting processing, in the event that one of the processing lines has a major equipment failure.

Furthermore, in the event that one of the gas-fired boilers breaks down, the site can continue to operate using only one boiler (albeit at a slower throughput rate), which provides for redundancy of the power plant.

TPL also has contracts with engineering services to ensure that plant breakdowns are resolved as soon as is practicable. Key spare equipment for biofilter fans and cooling towers are readily available. In the event that TPL is unable to process material in a sufficiently fresh or stabilised state, contingency arrangements exist with other rendering sites and authorised landfills to ensure that material can be moved offsite if required.

Contingency measures are outlined in the site’s AQMP.

3.6 PROPOSED CONSENT CONDITIONS

TPL proposes a set of conditions for the new air discharge consent in Appendix 7 of this AEE.

Fallen Stock

In general, only raw materials from licensed meat works, wholesale and retail butcheries, other retail outlets and home killing are accepted for processing at the site.

Condition 10 of existing consent number 117492 specifies that no more than 2.5 % of inward material can comprise animals that have died of natural causes (i.e. ‘fallen stock’). This condition was imposed by WRC in an attempt to help address odour management issues at the site when the existing consent was granted in 2012. However, cause of death


has never been a contributor to odour issues. Plant capability and management were the key contributors, with time of death and mode of delivery playing minor roles.

As discussed above, since the consent was granted in 2012 there have been numerous improvements in the site’s infrastructure and management, which have reduced off-site odour emissions significantly, as evidenced by a marked reduction in odour complaints from neighbours. To this end TPL considers that the consent restrictions on fallen stock are no longer necessary, as TPL now manages the operation in a manner that avoids adverse effects on neighbours. It is considered that condition 10 is impractical, and would be difficult to assess compliance with and enforce. For example, animals at abattoirs sometimes die of natural causes prior to being slaughtered. The key to avoiding adverse odour effects is careful management of the odour management system, as described above.

TPL therefore seeks that condition 10 not be reused in the new consent conditions.


4. RMA STATUS OF PROPOSED ACTIVITIES

This section outlines the status of the proposal in terms of the Resource Management Act 1991 as determined by the relevant statutory document, being the Waikato Regional Plan (WRP) (reprint as at April 2012). The relevant rule in the WRP for the discharge to air from the site is identified in Table 2.1. Overall, resource consent is required for discharges to air from WRC as a discretionary activity.

Table 4.1 Resource consent required

Activity Rule reference / description Activity status

Discharges to air from animal matters processes

Rule 6.1.9.1 states that the permitted level is the discharge of contaminants into air from animal matters processes that singly or together have a raw material capacity not exceeding 0.5 tonnes per hour and being processes for rendering or reduction or drying through application of heat to animal matter.

The raw material processing capacity exceeds 0.5 tonnes per hour, therefore, the permitted rule 6.1.9.1 is not met. Resource consent is therefore required under Rule 6.1.9.2. The status of the application is ‘discretionary’.


5. ASSESSMENT OF ENVIRONMENTAL EFFECTS

The following assessment identifies and assesses the effects that may arise from the ongoing discharges to air from the site.

5.1 POSITIVE EFFECTS

The TPL plant has been in operation since the 1970s under various predecessors. The TPL plant currently employs 33 people and operates 24 hours a day, seven days a week. It services an area from Kerikeri in the north to Taupo in the south, receiving and rendering protein-based material from supermarkets, butchers, farmers, meat and poultry processors. The low temperature rendering process used by the plant essentially recycles material that would otherwise require disposal as a waste product into stable, value-added products including tallow, meat and bone meal and blood meal.

The rendering process is an essential function of the agricultural, poultry, fish, meat and related industries, and these industries could not function effectively at scale without it. Rendering is essentially a recycling service; large volumes of by-product material that would otherwise require disposal as waste are collected and processed. The cost and environmental impact of alterative disposal methods for this material (e.g. incineration, landfill) can be significant, and do not provide any recoverable value.

The operation therefore provides significant social and economic benefits to the communities of the Tuakau/Pukekohe/Pokeno area and, more generally, the upper North Island. The operation also helps support the economy of ‘NZ Inc.’, given that almost 100% of the site’s product is exported. Furthermore, the operation supports the Waikato Region’s and New Zealand’s waste minimisation strategy, by helping to avoid the deposition of meat processing byproducts into landfills, and other less environmentally-friendly disposal methods (discussed further in Section 6 below).

5.2 ODOUR AND DUST EFFECTS

5.2.1 Golder Associates Assessment

Odour effects assessment specialists Golder Associates, who have been involved with odour effects assessment and management at the TPL site for several years, have prepared an odour effects assessment report in relation to the subject consent application. A copy of that report is reproduced in Appendix 5 of this AEE, and the Executive Summary of the report is reproduced below, verbatim.

“Potential Environmental Effects

Tuakau Proteins Limited (TPL) currently holds a resource consent (117492) from the Waikato Regional Council (WRC) for the discharge of contaminants into air from its meat rendering plant located off Lapwood Road, Tuakau (the site). Resource consent 117492 will expire on 1 August 2018, and therefore TPL will be applying for a


new resource consent to replace it. This report is a technical assessment of the air quality effects on the environment associated with the discharge of contaminants into air from the existing and proposed activities at the site.

TPL is a contract renderer that processes meat by-product materials from a variety of licensed meat processing sources. Raw material is mainly bovine, chicken and ovine, with some pork, equine and fish material also being processed at times. Only raw materials from licensed meat works, wholesale and retail butcheries, other retail outlets and home killing are accepted for processing. In line with the current consent conditions, minimal (less than 2.5 %) quantities of fallen stock are accepted.

Of the other activities onsite, by-product rendering is the most significant in terms of discharges into air, with the WWTP and the flaring system contributing to a smaller degree. Odour is the most significant discharge from the site but there are also dust discharges from the onsite roading and yard area.

Assessment Approach

The assessment of odour effects resulting from the TPL site has been undertaken in a manner consistent with the recommendations by MfE (2016) and WRC (2011) and with assessments that have been carried out previously by Golder for other rendering operations throughout New Zealand. This approach is based on the expected performance of the odour control system including planned plant upgrades and additional mitigation measures recommended by this report.

This assessment approach was based on a consideration of the Best Practicable Option (BPO) for minimising the odour emissions. This requires practical measures to be implemented to an extent that accounts for the actual effects and economic feasibility. The mitigation assessment included recent and regular historical field visits to review the rendering process and odour system. These visits have allowed the various odour sources and associated method of mitigation to be documented and the effectiveness of these systems to be assessed and compared to good industry practices.

To confirm the existing potential for odour effects the following has been considered:

Complaint records (January/2012 to October/2017);

Minutes from the Community Liaison Group meetings;

Site wind patterns;

Site review of odour mitigation system(s);

Site Management and contingency procedures.

Results of Assessment

Analysis of complaints and other community feedback confirm although there has been a substantial reduction in complaints in the last two years following the implementation of site upgrades, it is clear that there are still ongoing offsite odours being observed at nearby residences. These are considered to be at minor levels and further improved mitigation is considered appropriate to further reduce offsite effects.


Review of the site odour mitigation has found that the discharge of cooking type odours from the LTR1, LTR2b and HT plants are minimised via targeted and building air extraction and treatment of the extracted air by biofiltration. TPL has extraction on all point sources of odour and with the installation of the new cooling towers is considered to have a sufficient level of cooling. The biofilters are considered to be appropriately sized for the site. With the increased cooling on the site, which has historically been a restriction, the targeted extraction system can be tuned to further reduce the reliance of the system on the building air extraction.

The installation of a flare and gas extraction on the anaerobic pond has resulted in minimal odour from this historical source, to the extent that it is not considered a significant offsite odour and the WWTP is now operated in a manner that is considered BPO.

Suggested Approach for Effects Identified

An effective point source extraction system that has little reliance on building air extraction is considered BPO for this plant and expected to result in further reduction in offsite odour effects. It is concluded that TPL meets good practice odour control currently and with the future plant and cooling upgrades in combination with increased targeted extraction/reduced building air extraction will be able to meet BPO. It is recommended that following the rearrangement of the LTR1 rendering line, and thereafter regularly, a review of the point source extraction system is completed. This review of the ducts should include measurements to confirm that vacuum is maintained within the point source extraction ducts (near to the point of connection to equipment), to confirm there that there is sufficient extraction / containment of fugitive process odour emissions. It is recommended that targeted extraction is increased relative to building air extraction. To achieve BPO for the site, the targeted extraction should be at a level that rendering hall building air extraction is no longer required. The increased cooling capacity should ensure that even with the increased extraction, the biofilter air inlet temperature is maintained at a sufficiently low level to ensure good biofilter operation. It is concluded that adopting the BPO for control of rendering and wastewater management is likely to ensure only minor odour effects beyond the site boundary.

With regard to dust effects, it is considered that the key measure for controlling dust emissions from vehicle movements is through suppression of the dust from unpaved surfaces. To achieve this, TPL proposes to use water spraying on dry days to dampen down the unsealed yard area close to the site’s entrance. It is recommended this is used as a regular preventative measure, rather than in response to community feedback to ensure that dust effects are minimised to an acceptable level.”

As previously discussed in Section 3.4 above, TPL proposes to undertake Golder’s recommended actions by 30 June 2018 which are in summary:

Installation of a new meal processing building and loadout area adjacent to the LTR1 and LTR2b buildings, and subsequent demolition of the old meal room and some of the old LTR2 buildings on the southern side of the site;


Internal rearrangement of LTR1, which will concentrate the cooking sources together and allow the dryer and meal processing areas to be co-located. This will increase plant efficiencies in the situation when product needs to be reprocessed;

Relocation of the tallow recovery separators and tanks, which will allow them to be centrally located in the building and allow further targeted extraction of odour sources in these areas.

Furthermore, as recommended by Golder, a review of the point source extraction system will be completed following the rearrangement of the LTR1 rendering line. This review will be repeated two-yearly. TPL has proffered a consent condition requiring this regular review process (refer to Appendix 7 of this AEE).

5.2.2 Latest annual monitoring review report

Condition 31 of consent 117492 requires a monitoring report to be prepared annually and submitted to the Waikato Regional Council. The 2016/17 annual monitoring report, prepared by PDP Ltd (reproduced in Appendix 8 of this AEE), reported a significant reduction in odour complaints and identified reduced odours from the site, as assessed by an independent odour assessor, when compared with previous annual monitoring periods. The report attributes this to reducing biofilter temperatures and better management of biofilter pH and moisture levels. It also acknowledges that TPL has focused on improving the efficiency of energy supplies to the site which will have a flow on effect to maintaining the reliability of odour management systems and reducing the risk of odour generation. It is noted that since the PDP report was completed, the new cooling tower for non-condensable hot sources has been installed, so odour mitigation has improved since the report was completed.

5.2.3 Conclusions

Based on the above assessment, it is concluded that the potential effects from discharges to air will be no more than minor. The following key points support this conclusion:

As described in the Golder report, the site has undertaken a range of odour mitigation measures over the past several years, which has significantly reduced odour emissions. This has been evidenced by the marked reduction in odour complaints from neighbours in the past few years.

A range of further odour mitigation improvements are proposed by TPL, which will further reduce odour emissions.


The plant will be operated in accordance with the AQMP that is appended to this AEE, which will help ensure that:



The two-yearly review process that is proposed will ensure that any unforeseen problems with the point source extraction system will be identified and addressed.


6. STATUTORY ASSESSMENT

6.1 INTRODUCTION

Section 104 of the RMA sets out the matters to which a consent authority must have regard to, subject to Part 2 of the RMA, when considering an application for resource consent. These are:

Any actual and potential effects on the environment of allowing the activity;

Any relevant provisions of: o a national environmental standard; o other regulations; o a national policy statement; o a New Zealand coastal policy statement; o a regional policy statement or proposed regional policy statement; o a plan or proposed plan; and

Any other matter the consent authority considers relevant and reasonably necessary to determine the application.

Section 105 of the RMA sets out additional matters in which a consent authority must have regard to with regards to discharge permits if they contravene section 15 or section 15B of the RMA, including:

The nature of the discharge and the sensitivity of the receiving environment to adverse effects;

The applicant’s reasons for the proposed choice; and

Any possible alternative methods of discharge, including discharge into any other receiving environment.

The above matters have been considered in preparing this resource consent application. An assessment of effects of the proposal is provided in section 6 above. An assessment of any relevant provisions of a plan or proposed plan is provided below.

In addition to the above, section 104B of the RMA is relevant is terms of assessing the proposal as a discretionary activity. The Consent Authority may grant or refuse the application. If the Consent Authority grants the application, it may impose conditions under section 108 of the RMA only for matters over which discretion has been retained.

These provisions form the statutory basis for assessment of this application. They are, however, subject to Part 2 of the RMA. Part 2 outlines the central purpose of the RMA as the promotion of sustainable management of natural and physical resources. An assessment of the application against Part 2 of the Act is set out below.

The relevant policy and planning documents are:


Waikato Regional Policy Statement

Waikato Regional Plan; and

Waikato-Tainui Environmental Management Plan

The Resource Management (National Environmental Standards for Air Quality) Regulations 2004 (NESAQ) have little relevance to the subject consent application, as they address the protection of human health from airborne contaminants, rather than odour per se. Their main focus is on:

standards banning activities that discharge significant quantities of dioxins and other toxic substances into the air

standards for ambient (outdoor) air quality

a design standard for wood burners

a requirement for large landfills to collect greenhouse gas emissions.

The NESAQ is therefore not considered further in this AEE.

TPL have been engaging with the Guardians Establishment Committee in preparation of the Vision and Strategy for the Waikato River. TPL acknowledges that as an operator sited near the Waikato River, that they have a part to play to ensure that the vision is met. The Vision and Strategy is not considered further in this AEE as it is not directly relevant as it relates to activities in relation to the Waikato River.

There are no other National Environmental Statements or National Policy Statements considered relevant to the proposed activity.

6.2 WAIKATO REGIONAL POLICY STATEMENT

The Waikato Regional Policy Statement (RPS) was made operative on 20 May 2016. The RPS integrates the management of natural and physical resources across the Waikato region.

6.2.1 RPS Issues

The RPS sets out six regionally significant resource management issues and/or issues of significance to iwi authorities of the region headed as follows:

1. Issue 1.1 – State of Resources

2. Issue 1.2 – Effects of Climate Change

3. Issue 1.3 – Providing for Energy Demand

4. Issue 1.4 – Managing the Built Environment

5. Issue 1.5 – Relationship of Tangata Whenua with the Environment (Te Taiao)

6. Issue 1.6 – Health and Wellbeing of the Waikato River Catchment


All of these issues except Issue 1.6 are, to varying degrees, relevant to the reconsenting of the site.

6.2.2 RPS Assessment

The air quality objectives of the RPS are included in Section 3.11 and the policies are included in Section 5 of the RPS.

Objectives in Section 3.11 of the RPS are to ensure “air quality is managed in a way that:

a) Ensures that where air quality is better than national environmental standards and guidelines for ambient air, any degradation is as low as reasonably achievable;

b) Avoids unacceptable risks to human health and ecosystems, with high priority placed on achieving compliance with national environmental standards and guidelines for ambient air; and

c) Avoids, where practicable, adverse effects on local amenity values and people’s wellbeing including from discharges of particulate matter, smoke, odour, dust and agrichemicals, recognising that it is appropriate that some areas will have a different amenity level to others.”

Section 5 of the RPS details policies for the management of air quality including:

Policy 5.1 – Improvement of degraded air quality: “Reduce the adverse effects on air quality caused by cumulative, diffuse, broad scale or multiple discharges from home heating appliances and transport, with particular emphasis on: a) discharges of fine particulate matter; and b) areas where there are unacceptable risks to human health and ecosystems.”

Policy 5.2 – Management of discharges to air: “Manage discharges to air (other than from home heating or transport) to ensure any resulting degradation avoids unacceptable risks to human health, and is as low as reasonably achievable. In determining whether any degradation is as low as reasonably achievable, the following will be taken into account: a) existing air quality; b) the age of and ability to upgrade existing infrastructure; c) any alternative modes/methods of discharge; d) applicable emission control techniques; e) the extent to which it is possible to apply the best practicable option; f) the relative effects on the environment of the options; g) economic and social factors; h) managing discharges to air where there is high or good air quality; i) national environmental standards and guidelines for ambient air; and


j) the duration of the discharge and whether the discharge is temporary or short term.”

Policy 5.3 – Management of adverse effects on amenity: “Ensure discharges to air are managed so as to avoid, remedy or mitigate objectionable effects beyond the property boundary.”

The activity is consistent with the policies and objectives as assessed in the AEE in Section 5. TPL have ensured that air quality is managed in a way that aims to avoid, where practicable, adverse effects on local amenity values and people’s wellbeing. Since TPL took ownership they have introduced a series of site improvements (as guided by the options suggested in Policy 5.2) to minimise the adverse effect of odour on those properties surrounding theirs and have engaged with them in order to understand the issue better. As stated in the Golder report (reproduced in Appendix 3 of this AEE), the site “…meets good practice odour control currently and with the future plant and cooling upgrades in combination with increased targeted extraction/reduced building air extraction will be able to meet BPO”. TPL has confirmed it will make the further improvements recommended by Golder and these are captured within the AQMP.

The RPS acknowledges that some areas will have a different amenity level to others. The site is currently in the process of potential being re-zoned from Business to Industrial and for the surrounding land to continue to be zoned as Rural (as explained in Section 2) and not Rural Residential. Although the odour sensitivity levels in these zones are typically less sensitive than Residential zoned land, it is relevant to note that TPL has made significant efforts to ensure that offsite odours are no more than minor beyond their site boundary and that they have been involved in the plan change processes in order to avoid reverse sensitivity effects as they recognise the potential for these effects to arise (which is consistent with Policy 5.3).

In addition, the proposal is consistent with other relevant objectives and policies including:

Objective 3.2 (Resource Use and Development) and Policy 4.4 (Regionally Significant Industry and Primary Production):

“Recognise and provide for the role of sustainable resource use and development and its benefits in enabling people and communities to provide for their economic, social and cultural wellbeing, including by maintaining and where appropriate enhancing:

a) access to natural and physical resources to provide for regionally significant industry and primary production activities that support such industry;

b) the life supporting capacity of soils, water and ecosystems to support primary production activities;


c) the availability of energy resources for electricity generation and for electricity generation activities to locate where the energy resource exists;

d) access to the significant mineral resources of the region; and

e) the availability of water for municipal and domestic supply to people and communities.”

The TPL site is an example of a regionally significant industry, seeking access to natural resources (discharges to the air) to facilitate the ongoing operation of activities which enable people and communities to provide for their economic, social and cultural wellbeing.

Objective 3.9 (Relationship of Tangata Whenua with the Environment):

“The relationship of t ngata whenua with the environment is recognised and provided for, including:

a) the use and enjoyment of natural and physical resources in accordance with tikanga M ori, including m tauranga M ori; and

b) the role of t ngata whenua as kaitiaki.”

The relationship of tangata whenua with the environment and their ability to exercise their role as kaitiaki has been provided for by way of the consultation undertaken by TPL.

Objective 3.21 (Amenity):

“The qualities and characteristics of areas and features, valued for their contribution to amenity, are maintained or enhanced.”

The TPL site will manage odour effects to ensure that current levels of amenity are maintained and that offsite odours are managed to ensure they are no more than minor.

6.3 WAIKATO REGIONAL PLAN

The relevant parts of the Waikato Regional Plan (WRP) (reprinted April 2012) for this consent application are Sections 6.1 and 6.3, which are addressed in Table 6.1.

Table 6.1: Objectives and Policies Assessment

WRP Section

Objective/Policy Assessment

Section 6.1.2 Objective 1

Significant characteristics of air quality as identified in Table 6-1 are:

a) protected where they are high b) enhanced where they are degraded

The significant characteristics of air quality are not considered to be relevant for this application as the


WRP Section


c) otherwise maintained. issue is not ambient air quality but odour.

In regards to odour, air quality in the area has improved over recent years because of TPL’s site improvements and through the AQMP it is considered that these enhancements will be maintained.


No significant adverse effects from individual site sources on the characteristics of air quality beyond property boundary.

The Golder report (in Appendix 5) confirms that the installation of a flare and gas extraction on the anaerobic pond has resulted in minimal odour from this historical source, to the extent that it is not considered a significant offsite odour and the WWTP is now operated in a manner that is considered BPO. There are therefore no significant adverse effects from individual site sources beyond the property boundary and offsite odour effects are considered to be no more than minor.


Cumulative effects of discharges on ambient air quality do not:

a) present more than a minor threat to the health of humans, flora and fauna

b) cause odour that is objectionable to the extent that it causes an adverse effect

c) result in levels of suspended or deposited particulate matter that are objectionable to the extent that they cause adverse effects

d) have a significant adverse effect on visibility

e) cause accelerated corrosion of structures

Section 5.2 of the Golder effects assessment report (see Appendix 7 of this AEE) notes:

“The assessment of cumulative effects of odour arising from different sources in the receiving environment is undertaken where off site sources give rise to odour with a character that is the same or similar to the odours generated on site and likely to impact on the same sensitive receptors. In other words, the odour effects are likely to be additive. While there are other potential sources of odour in the area, such as Envirofert, Golder


WRP Section


f) cause significant adverse effects on the relationship tangata whenua as Kaitiaki have with their identified taonga such as air, ancestral lands, water and waahi tapu.

considers that the character of the odour from Envirofert and other nearby operations are distinctly different from that of TPLs and it is sufficiently far enough away to not require the potential for cumulative odour effects to be assessed”.

Section 6.1.3 Policy 2

Manage other discharges of contaminants to air through controlled and discretionary activity rules having particular regard to the effects of the discharge on:

a) ambient air quality compared to the Regional Ambient Air Quality Guidelines (RAAQG) levels provided in Chapter 6.3,

b) ambient air quality compared to internationally accepted air quality guidelines or standards for managing and understanding the effects of contaminants on human health, the health of flora and fauna and amenity values,

c) ambient odour and particulate matter levels compared to the guidelines for assessment provided in Chapter 6.4 of the Plan for odour and particulate matter

d) adverse effects from contaminants that are hazardous in ambient air, particularly with respect to human health,

e) the significant characteristics of air quality within an area,

f) significant adverse effects of the discharge on the identified values of tangata whenua as Kaitiaki,

g) the sensitivity of the receiving environment,

h) existing ambient air quality and any cumulative effects as a result of the

It is considered that the ambient air quality guidelines referred to in a), b), d) and e) of this policy have little relevance to the subject consent application, as the levels of the RAAQG contaminants that occur in the TPL air discharges (apart from the separately consented boiler discharge) are insignificant.

The Golder report has referred to guidelines for assessment provided in Chapter 6.4 of the Plan for odour. In order to make their assessment they reviewed complaint records (January/2012 to October/2017), minutes from the Community Liaison Group meetings, site wind patterns, site review of odour mitigation system(s) and Site Management and contingency procedures. They also assessed whether the best practicable option is being applied for the discharge.

The effect of the discharge on the identified values of tangata whenua has been addressed through appropriate consultation with tangata whenua.

As stated earlier, the site is not within a residential zone which would be especially sensitive to odour. The location of the TPL site


WRP Section


discharge on the receiving environment,

i) nationally accepted codes of practice for the relevant activity.

within the Rural Zone does not remove the need for TPL to manage its air discharges to avoid causing an odour that is “objectionable to the extent that it causes an adverse effect” beyond the site’s boundaries. However, within the Rural Zone there are a number of activities that involve the emission of odours which are permitted as of right under the District Plan.

As noted above, the Golder effects assessment report notes that the character of the odour from Envirofert and other nearby operations are distinctly different from that of TPLs and is sufficiently far enough away to not require the potential for cumulative odour effects to be assessed.

There are no relevant codes of practice, but Golder has taken into account the Ministry for the Environment’s ‘Good Practice Guide for Assessing and Managing Odour in New Zealand’ (2016) in its assessment report.


While having regard to the provisions in Policies 1, 2 and 3, and the likely effects of activities on ambient air quality, Waikato Regional Council will promote the best practicable option to prevent or minimise the discharge of contaminants to air where:

a) numerical guidelines or standards establishing a level of protection for a receiving environment are not available or cannot easily be established,

b) the maintenance or enhancement of the existing air quality is desirable or

It is considered that the best practicable approach is suitable for this discharge where the primary concern is odour.

TPL has made improvements to the site in order to do everything they reasonably can do in order to minimise the effect. The odour effects at the site have historically been of concern, therefore, TPL undertook significant improvements to the site in order


WRP Section


there is uncertainty over existing air quality,

c) the known adverse effects and costs associated with adopting the best practicable option for an operation are small and the costs of investigating the effect on air quality is large in comparison to the potential effects.

to enhance amenity levels in the area.

An effective point source extraction system that has little reliance on building air extraction is considered BPO for this plant and expected to result in further reduction in offsite odour effects. It is concluded by Golder that TPL meets good practice odour control currently and with the future plant and cooling upgrades in combination with increased targeted extraction/reduced building air extraction will be able to meet BPO. In line with Golder’s recommendations, TPL will rearrange the LTR1 rendering line, and thereafter regularly review the point source extraction system once it is completed.


Recognise the positive benefits to people and communities arising from activities that affect air quality by enabling a range of activities to use the air (including existing activities) whilst ensuring that:

a) high quality air resources are protected,

b) degraded air quality is enhanced, c) adverse effects on air quality are

avoided, remedied or mitigated.

The positive benefits have been acknowledged in the AEE. The proposal is considered to be consistent with this policy as it will allow the positive benefits of operating TPL’s site to continue, whilst ensuring that the adverse amenity effects on air quality are avoided, remedied or mitigated.

It is considered that this should be taken account of in Council’s decision making in regards to consent duration as TPL believes that their improvements and AQMP justifies the consent duration of 25 years that is being sought.


6.3.1 Assessment Criteria of the WRP

Section 8.1.5.1 of the WRP provides the assessment criteria and information requirements for discretionary activities. Table 6.2 provides an assessment of the proposal against each criterion.

Table 6.2: WRP Assessment Criterion for Discharge to Air (Discretionary Activity)

Criteria Assessment

a. The extent to which the Regional Ambient Air Quality Guidelines are complied with.

The RAAQG are not considered to be relevant for this application as the primary issue is odour, not ambient air quality.

b. The extent to which the discharge will have an adverse effect on ambient air quality.

This criterion is not considered to be relevant for this application as the primary issue is odour, not ambient air quality.

c. The extent to which the discharge will have an actual or potential adverse effect on the existing air quality characteristics of an area.

As stated earlier, the existing air quality of the area in regards to ambient air quality is not considered relevant for this application. However, it is relevant to consider that the adverse effect of odour from the site has been reduced over the years since TPL has had ownership through the various improvements to the site that have been described in Section 2.

The Golder report concludes that the site improvements will mean that the site will meet BPO and that offsite odour effects will be no more than minor. TPL will ensure that this occurs through the introduction and regular review of a AQMP.

d. The extent to which the discharge will have an adverse effect on human health and the health of flora and fauna.

The discharge is not considered to have an adverse effect on human health or the health of flora and fauna – the focus is on odour and the effect it can have on amenity levels.

e. The extent to which the discharge will have an adverse effect on amenity values, including any objectionable effects as a result of an odour or particulate discharge (refer also to Guidelines for Assessment in Chapter 6.4).

When considering the extent to which the discharge will have an adverse effect on amenity values, it is important to recognise that the site is currently in the process of being re-zoned as Industrial and that the surrounding land is zoned as Rural (as explained in Section 2). Although the odour sensitivity levels in these areas are typically less sensitive than residential areas, TPL has made significant efforts to ensure that offsite odours are no more than minor.

The Golder report has referred to guidelines for assessment provided in Chapter 6.4 of the Plan for


Criteria Assessment

odour. In order to make their assessment they reviewed complaint records (January/2012 to October/2017), minutes from the Community Liaison Group meetings, site wind patterns, site review of odour mitigation system(s) and Site Management and contingency procedures. They also assessed whether the best practicable option is being applied for the discharge.

f. The extent to which the frequency, intensity, duration, offensiveness and location of the discharge causes adverse effects.

As recognised in the Golder report, as this discharge to air is in regards to the adverse effect of odour and not in regards to ambient air quality or the NESAQ, the methodology for assessing the adverse effect is not as exact as for other air discharge applications.

Golder have reviewed the extent of the discharge in regards to the available information at hand and made recommendations which relate to BPO for the site which TPL will implement in order to reduce the adverse effect of odour and ensure it is no more than minor. Golder’s report has taken into account the location (particularly topography and wind direction) and has reviewed the complaints records to understand the extent of the odour issue.

g. The extent to which the discharge will be reduced at source.

Process air and vapours and building air streams are extracted from the three rendering lines and pre-cooled prior to treatment via two biofilters that remove odour before discharging the treated air streams to the atmosphere. This is the primary method of capturing and mitigating rendering odour at the site, and is referred to as a ‘point source extraction system’. This is a significant improvement as if the point source extraction system is well operated and maintained, only minimal odour will escape into the rendering buildings. The way in which the system will be operated and maintained is set out in a AQMP.

h. The nature of the discharge and the extent to which it is hazardous (refer Hazardous Air Contaminants List in Chapter 6.7).

This is not considered relevant for the application.


Criteria Assessment

i. The existing air discharge sources in the area (point and non-point).

The primary source of odour from the low temperature rendering lines include the vapours emitted from the pre-cooker, solids press, liquid phase tanks, decanters and dryer exhaust (the main source), as well as from the various transfer conveyers for moving cooked and pressed solids between these processes.

The existing air discharge sources are shown in schematic diagram form within the Golder report. Section 2.2.3 of the Golder report goes into further detail of the existing air discharge sources.

j. The influence of meteorology and topography on the discharge.

Wind patterns have been analysed on the site in Section 4.2 of the Golder report.

k. The extent to which the method of discharge is the most efficient and effective means of carrying out an activity.

The Golder report concludes that the TPL site has made substantial improvements in its operation, odour control and odour cooling and treatment systems since the previous consent was granted in 2012. The changes required have resulted in a more robust operation with good practice odour control. The newer LTR2b and HT lines are operating well and with the dryer upgrade the LTR1 is also expected to operate well. Improved air extraction cooling systems are reducing the thermal load on the biofilters and will allow the plant to move towards increased reliance on the more efficient point source extraction system. This in combination with increased monitoring and therefore control of the system will result in the rendering plant odour control systems being considered to represent the BPO.

It is considered that this method is the most efficient and effective means of carrying out the activity.

l. The extent to which any alternative location or method(s) of discharging any contaminant, such as into a different medium, was considered.

When TPL took ownership in 2014, they considered the various alternative options to improving the site in regards to its odour impact. The result of that was to make significant improvements to the internal site layout and the method of discharge. These improvements are proposed to continue in this application as TPL is proposing to implement Golder’s additional recommendations and increase monitoring through the AQMP in addition to


Criteria Assessment

improving the air extraction cooling systems. This is considered to be BPO.

m. Whether the option minimises any adverse effects on the environment.

The option proposed in this application is considered to be BPO as it will minimise the adverse effect of odour and ensure that the effect is no more than minor for those living offsite.

n. The extent to which tangata whenua as Kaitiaki concerns have been recognised and provided for.

Please refer to Section 7.

o. The extent to which the activity will have the potential to affect significant heritage sites or areas of historic and cultural significance.

This is not considered relevant for this application.

p. The extent to which the discharge creates actual or potential effects on other receiving environments (i.e. land or water).

This is not considered relevant for this application.

q. The extent of any consultation undertaken (as per the reporting requirements in Schedule Four of the RMA).

Please refer to Section 7.

r. The extent to which the discharge creates actual or potential effects on the global atmosphere (within the scope of central government policy).

This is not considered to be relevant as the adverse effect of odour is localised and not related to ambient air quality.

s. The extent to which to which the discharge creates cumulative effect which may arise over time or in combination with other effects.

As noted above, the Golder effects assessment report notes that the character of the odour from Envirofert and other nearby operations are distinctly different from that of TPLs and is sufficiently far enough away to not require the potential for cumulative odour effects to be assessed.

t. Any effects of low probability but high potential impact.

The potential for high impact from dour discharges is mitigated adequately by the contingency measures outlined in Section 3.5 above.

u. Whether management plans and contingency plans have been provided.

An Air Quality Management Plan has been drafted for approval by WRC.


Criteria Assessment

The site has contingency plans in case of emergency which are described in detail in the AQMP.

v. The risk of abnormal emissions and the level of control employed.

This aspect is addressed in Section 3.5 of this AEE, Contingency Measures. Abnormal emissions will be controlled by the contingency measures, and as set out in the AQMP.

w. The extent to which relevant codes of practice or other guidelines are adhered to.

There are no relevant codes of practice, but Golder has taken into account the Ministry for the Environment’s ‘Good Practice Guide for Assessing and Managing Odour in New Zealand’ (2016) in its assessment report.

x. The extent to which the discharge may affect aircraft safety.

This is not considered to be relevant.

y. Any other relevant matters. No other matters have been identified.

6.4 WAIKATO REGIONAL COUNCIL WASTE MINIMISATION STRATEGY

WRC’s Waste and Resource Efficiency Strategy (WRES) sets out how WRC will work with key stakeholders to achieve collective regional waste minimisation objectives. The two key goals of the strategy are to:

Protect our communities, land, water and air from harmful and hazardous wastes

Encourage resource efficiency and beneficial reuse that creates sustainable, economic growth

The TPL proposal supports these goals, as it encourages resource efficiency and beneficial reuse by making use of what might otherwise be regarded as a ‘waste’ product, and creating a saleable export product, which helps create sustainable, economic growth. The proposal also protects our communities, land, water and air from harmful and hazardous wastes by:

treating liquid wastes and discharging those treated wastes in a legal and environmentally friendly manner (as authorised by WRC resource consents), and

managing odour discharges as described in this AEE so that they do not create an objectionable effect on neighbours.


6.5 WAIKATO-TAINUI ENVIRONMENTAL MANAGEMENT PLAN

The Waikato-Tainui Environmental Plan, Tai Tumu Tai Pari Tai Ao (‘the Plan’), is developed out of Whakatupuranga 2050. Whakatupuranga 2050 is a long-term development approach to building the capacity of Waikato-Tainui marae, hapuu, and iwi and will be a legacy for those who come after.

For the purposes of the RMA, particularly of section 35A, Waikato-Tainui Te Kauhanganui Incorporated (‘WTTKI’) confirms that it is the Iwi Authority for Waikato-Tainui and that the Tai Tumu Tai Pari Tai Ao, the Waikato-Tainui Environment Plan (the ‘Plan’) represents the Waikato-Tainui environmental planning document.

The goal of Waikato-Tainui is to ensure that the needs of present and future generations are provided for in a manner that goes beyond sustainability towards an approach that enhances the environment. An ‘enhancement’ approach requires the consideration of, not only individual resource use, activities, buildings, or elements, but also an holistic approach to the whole environment. It aims for positive ecological and social outcomes where the resource use and activities effecting the environment becomes a conduit for producing resources and energy, improving physical and psychological health, remedying past pollution, and transforming and filtering waste into new resources.

6.5.1 Assessment

It is acknowledged that Waikato-Tainui is in favour of an approach to resource use and activity operation that sees a net benefit back to the environment, and consider it necessary to provide a net benefit when considering social, economic, environmental, spiritual and cultural impacts.

The proposal is for the renewal of an air discharge consent. As demonstrated in the AEE, TPL have focused on managing the effects to ensure that the adverse effects are minimised and mitigated. Investment has been made over the years to improve the processes that occur on site to reduce the adverse effect of odour and dust. It is considered that the positive benefits that TPL bring outweighs these negative effects, particularly due to the improvements that have been made.

6.6 PART 2 OF THE RMA

As required by Schedule 4, Clause 2(1)(f) of the Act, the following is an assessment against the matters set out in Part 2. It is noted that recent case law in the High Court decision on RJ Davidson Family Trust v Marlborough District Council (2017) NZHC 52 determined that “the Court is not required to consider Part 2 of the RMA beyond its expression in the planning documents…”. However, the ‘Davidson’ decision is currently under appeal, because of this and for completeness in regard to RMA Schedule 4 an assessment against Part 2 is provided below.


Part 2 of the RMA sets out the purpose and principles of the Act. The purpose of the RMA is to promote the sustainable management of natural and physical resources.

Section 5 states “in this Act, sustainable management means managing the use, development, and protection of natural and physical resources in a way, or at a rate, which enables people and communities to provide for their social, economic, and cultural well-being and for their health and safety while—

(a) sustaining the potential of natural and physical resources (excluding minerals) to meet the reasonably foreseeable needs of future generations; and

(b) safeguarding the life-supporting capacity of air, water, soil, and ecosystems; and

(c) avoiding, remedying, or mitigating any adverse effects of activities on the environment.”

It is considered that TPL have managed the discharge to air of contaminants associated with the rendering plant in a way which enables them to continue to provide for their economic well-being and their health and safety while safeguarding the life-supporting capacity of air and avoiding, remedying or mitigating any adverse effects on the environment. As discussed earlier, TPL have significantly invested in the site to ensure that the adverse effects can be mitigated further than has been achieved in the past.

Section 6 states that “in achieving the purpose of this Act, all persons exercising functions and powers under it, in relation to managing the use, development, and protection of natural and physical resources, shall recognise and provide for the following matters of national importance:

(a) the preservation of the natural character of the coastal environment (including the coastal marine area), wetlands, and lakes and rivers and their margins, and the protection of them from inappropriate subdivision, use, and development:

(b) the protection of outstanding natural features and landscapes from inappropriate subdivision, use, and development:

(c) the protection of areas of significant indigenous vegetation and significant habitats of indigenous fauna:

(d) the maintenance and enhancement of public access to and along the coastal marine area, lakes, and rivers:

(e) the relationship of Maori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, and other taonga:

(f) the protection of historic heritage from inappropriate subdivision, use, and development:


(g) the protection of protected customary rights:

(h) the management of significant risks from natural hazards.”

It is not considered that any matters of national importance recognised in Section 6 of the RMA are relevant for this application.

Section 7 states that “in achieving the purpose of this Act, all persons exercising functions and powers under it, in relation to managing the use, development, and protection of natural and physical resources, shall have particular regard to—

(a) kaitiakitanga:

(aa) the ethic of stewardship:

(b) the efficient use and development of natural and physical resources:

(ba) the efficiency of the end use of energy:

(c) the maintenance and enhancement of amenity values:

(d) intrinsic values of ecosystems:

(e) [Repealed]

(f) maintenance and enhancement of the quality of the environment:

(g) any finite characteristics of natural and physical resources:

(h) the protection of the habitat of trout and salmon:

(i) the effects of climate change:

(j) the benefits to be derived from the use and development of renewable energy.”

Amenity values and the quality of the environment will be maintained. In addition, the relationship of tangata whenua with the environment and their ability to exercise their role as kaitiaki has been provided for by way of the consultation undertaken by TPL.

Section 8 of the RMA states that “in achieving the purpose of this Act, all persons exercising functions and powers under it, in relation to managing the use, development, and protection of natural and physical resources, shall take into account the principles of the Treaty of Waitangi (Te Tiriti o Waitangi).”

It is considered that TPL have taken into account the principles of the Treaty of Waitangi be engaging with tangata whenua in their pre-application consultation.

It is therefore considered that the proposal is consistent with Part 2 of the RMA.


6.7 ALTERNATIVES

Section 105 of the RMA is relevant to applications to discharges under Section 15 (such as this application). Section 105 requires the consent authority to have regard to the nature of the discharge and the sensitivity of the receiving environment, the applicant’s reasons for the proposed choice and possible alternative methods of discharge.

Clause 6(1)(a) to Schedule 4 of the RMA specifies that a description of any possible alternative locations or methods for undertaking the activity is only a statutory requirement if the proposal is expected to result in significant adverse environmental effects. The site is an existing activity and the effects have been assessed in the AEE as being no more than minor.

Nonetheless, regarding Section 105 of the RMA, the nature of the discharge and the sensitivity of the receiving environment has been described in Section 2 of this AEE. The proposed improvements to the site and the monitoring is in direct relation to the recommendations provided by Golder, who have stated that the improved air extraction cooling systems will allow the plant to move towards increased reliance on the more efficient point source extraction system. This in combination with increased monitoring and therefore control of the system will result in the rendering plant odour control systems being considered to represent the BPO.


7. CONSULTATION AND NOTIFICATION

7.1 CONSULTATION WITH LOCAL COMMUNITY

TPL has regular ongoing consultation through a community forum which was first established in 2010 and which convenes three or four times per year, as decided from meeting to meeting. The invitation to this forum is extended to up to as many as 500 people on an email mail out, and this includes immediate neighbours and other community members who have an interest in the plant. The forum sessions are also attended by representatives of Waikato Regional Council, and sometimes Waikato District Council. At this forum all operational matters associated with the plant can be and are discussed with explanations from the Plant Manager regarding any concerns, and actions are agreed to remedy or mitigate valid concerns. For this reconsenting process, the meeting has been updated on progress regarding the application and the Plant Manager has met with some of the immediate neighbours to discuss the application. There has been no specific feedback from these discussions and the consultation is intended to be ongoing.

7.2 TANGATA WHENUA CONSULTATION

The Te Taniwha o Waikato Working Group (a working group with representatives from six marae of the Ki te Puaha O Waikato and Tuakau Proteins Ltd) met on 11 December 2017. At this hui the air discharge consent renewal process was discussed. The attendees were provided with an information sheet that summarised the consent being applied for and why, recent and proposed improvements to the odour systems and comments on the assessment of environmental effects.

The initial comments from the tangata whenua representatives were they wanted to take this information away to digest and consider. The tangata whenua representatives advised they would consider this information outside of the Working Group and come back to the Working Group at the next meeting. In summary, no issues have as yet been raised by the representatives, and TPL will follow up this matter at the next meeting.

7.3 NOTIFICATION

Section 95A of the RMA is relevant when a consent authority is considering whether a consent application should be notified. It is therefore relevant to consider that:

This AEE concludes that the adverse effects on the environment from the proposal are likely to be no more than minor;

The applicant does not request public notification of the application;

There is no rule or national environmental standard that requires public notification of this application; and

No special circumstances exist in relation to the application.


We consider that this proposal meets the RMA tests to be processed without public notification.

For applications that are not publicly notified, under section 95B, the consent authority must give limited notification of the application to any affected person or any affected protected customary rights group or customary marine title group, unless (in the case of affected persons) a rule or national environmental standard precludes limited notification of the application.

Section 95E states that a consent authority must consider a person to be an affected person if the activity’s adverse effects on the person are minor or more than minor (but not less than minor). The effects of the proposed activity have been assessed to be no more than minor. For persons living more than 1 km from the site, it is considered that the effects on those people will be less than minor.

It is therefore requested that the application be processed on a limited notification basis to people occupying or owning dwellings within 1 km from the site.


8. CONCLUSIONS

The rendering process carried out by TPL at its Tuakau site is an essential function of the agricultural, poultry, fish, meat and related industries, and these industries could not function effectively at scale without it. Rendering is essentially a recycling service; large volumes of by-product material that would otherwise require disposal as waste are collected and processed. The cost and environmental impact of alterative disposal methods for this material (e.g. incineration, landfill) can be significant, and do not provide any recoverable value.

The TPL operation provides significant social and economic benefits to the communities of the Tuakau/Pukekohe/Pokeno area and, more generally, the upper North Island. The operation also helps support the economy of ‘NZ Inc.’, given that almost 100% of the site’s product is exported. Furthermore, the operation supports the Waikato Region’s and New Zealand’s waste minimisation strategy, by helping to avoid the deposition of meat processing byproducts into landfills, and other less environmentally-friendly disposal methods.

It is concluded that the potential effects of the discharges to air from the TPL site will be no more than minor. The following key points support this conclusion:

As described in the Golder report, the site has undertaken a range of odour mitigation measures over the past several years, which has significantly reduced odour emissions. This has been evidenced by the marked reduction in odour complaints from neighbours in the past few years, and feedback from the most recent Community Liaison Group Meetings.

A range of further odour mitigation improvements are proposed by TPL, which will further reduce odour emissions.

The plant will be operated in accordance with the AQMP that is appended to this AEE, which will help ensure that:



The two-yearly review process that is proposed will ensure that any unforeseen problems will be identified and addressed.

The statutory assessment under the RMA has been undertaken and all relevant matters have been considered. The activities are consistent with Part 2 of the RMA and the relevant objectives and policies of the Waikato Policy Statement and Waikato Regional Plan.


Consultation has been undertaken with neighbours. The general consensus is that odour generation from the site has reduced markedly over the last two years. Consultation is ongoing.

It is requested that the application be processed on a limited notification basis to people occupying or owning dwellings within 1 km from the site.

The term of consent sought is 25 years. This will provide certainty for the site’s ongoing operations, and will:

provide economic security for the site’s 33 employees and external contractors, which in turn provides flow-on economic and social benefits to Tuakau and the wider District;

provide security for TPL’s existing approximately $50 million investment at the site;

enable TPL to make long term strategic decisions for the site.

Documents

RESOURCE CONSENT APPLICATION AND ASSESSMENT ......6.4 Waikato Regional Council Waste Minimisation Strategy 37 6.5 Waikato-Tainui Environmental Management Plan 38 6.6 Part 2 of the