Milk Powder Processing Facility - EPA Tasmaniaepa.tas.gov.au/documents/tasmanian dairy products -...

ENVIRONMENTAL ASSESSMENT REPORT

Milk Powder Processing Facility

Irishtown Road, Smithton

Tasmanian Dairy Products Co Ltd

Report and recommendations of the

EPA Division

Department of Primary Industries, Parks, Water and Environment

to the Board of the Environment Protection Authority

September 2011

Environmental Assessment Report

Proponent Tasmanian Dairy Products Co Ltd (TDP)

Proposal Milk Powder Processing Facility

Location RA 2 Irishtown Road, Smithton

NELMS no. 8607

DA number 2011/00065

File 112219

Document EEO\EAS\P\TasDairy_MilkProcessing_Site2\AR\TasDairy_EAR.docx

Class of Assessment

2B

Assessment process milestones

21 April 2011 Notice of Intent submitted

6 May 2011 DPEMP Guidelines issued

17 June 2011 Permit application submitted to Council

22 June 2011 Application received by Board

2 July 2011 Start of public consultation period

30 July 2011 End of public consultation period

19 August 2011 Supplementary information submitted to Board

Environmental Assessment Report – TDP, Milk Powder Processing, Smithton

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Acronyms

AHD Australian Height Datum

AMF Anhydrous Milk Fat

ASS Acid Sulphate Soils

Board Board of the Environment Protection Authority

CIP Cleaning in place

CMW Cradle Mountain Water (authority)

DPEMP Development Proposal and Environmental Management Plan

DPIPWE Department of Primary Industries, Parks, Water and Environment

EIA Environmental impact assessment

EMPC Act Environmental Management and Pollution Control Act 1994

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

EPP (Air) Environment Protection Policy (Air Quality)

EPP (Noise) Environment Protection Policy (Noise)

GDE Groundwater Dependant Ecosystems

GHG Greenhouse Gases

kL kilolitre

LUPA Act Land Use Planning and Approvals Act 1993

PCAB Policy and Conservation Assessment Branch, DPIPWE

PEV Protected Environmental Values

RA Rural Address

SD Sustainable development

SMP Skimmed milk powder

SPWQM State Policy on Water Quality Management 1997

TDP Tasmanian Dairy Products Company Ltd

TWA Trade waste agreement

WMP Whole milk powder


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Report summary This report contains an environmental assessment and recommendations to the Director, Environment Protection Authority in relation to Tasmanian Dairy Products Co Ltd’s (TDP) proposed milk powder processing facility.

The proposal involves the construction and operation of a milk powder processing facility near Smithton with the capacity to process up to 480 kilolitres of milk per 8 hour shift.

This report has been prepared by the EPA Division of the Department of Primary Industries, Parks, Water and Environment based on information provided by the proponent in the Development Proposal and Environmental Management Plan (DPEMP) and DPEMP Supplement. The advice of relevant Government Agencies and the public has also been sought and considered as part of this assessment.

On 12 August 2011, the Deputy General Manager, EPA Division acting on behalf of the Board, requested that the applicant submit supplementary information to address public, government agency (including DPIPWE) and Council comments on the DPEMP. The DPEMP supplementary information was submitted by the applicant on 19 August 2011. Background to the proposal and details of the assessment process are presented in Section 1 of this report. Section 2 describes the context of this assessment. Details of the proposal are contained in Section 3. Section 4 reviews the need for the proposal and considers the project, site and design alternatives. Section 5 summarises the public and Agency consultation process and the key issues raised in that process. The detailed evaluation of key issues is contained in Section 6. Section 7 identifies other environmental issues and the report conclusions are contained in Section 8.

Appendix 1 contains a tabular evaluation of other environmental issues referred to in Section 7. Appendix 2 contains an A3 Site Plan. Appendix 3 contains recommended environmental permit conditions for the proposal. Attachment 2 of the recommended permit conditions contains the table of commitments from the DPEMP and DPEMP Supplement.


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Recommendations It is recommended that the Director, Environment Protection Authority under delegation from the Board of the Environment Protection Authority:

1. Consider the Division’s evaluation of environmental issues associated with the proposal in Section 6 and Section 7 of this report

2. Note that the evaluation has concluded that the proposal is capable of being managed in an environmentally acceptable manner such that it is unlikely that the RMPS and EMPCS objectives would be compromised, provided that the recommendations made in this report are satisfactorily implemented. These recommendations include the implementation of the commitments made by the proponent in the DPEMP.

3. Approve the proposal subject to the conditions attached to this report.

4. In accordance with s.25(5)(a)(i) of the EMPC Act, notify Circular Head Council that the conditions and restrictions detailed in Appendix 3 (recommended permit conditions) must be contained in a permit granted by the planning authority under the LUPA Act in respect of the proposal, if a permit is to be granted.

5. In accordance with s.25(5)(a)(ii) of the EMPC Act, provide Council with a copy of this report to outline the reasons for the conditions and restrictions.


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Table of Contents 1 Approvals process ................................................................................................................. 1

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

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

4 Need for proposal and alternatives ....................................................................................... 8

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

6 Evaluation of key issues ...................................................................................................... 10

6.1 Wastewater Management ..................................................................................... 10

6.2 Hazardous Substances ......................................................................................... 14

6.3 Noise ..................................................................................................................... 16

6.4 Atmospheric Emissions ........................................................................................ 20

7 Other environmental issues ................................................................................................ 22

8 Conclusions ......................................................................................................................... 23

9 References .......................................................................................................................... 24

10 Summary of appendices ..................................................................................................... 24

Appendix 1. Assessment of other environmental issues ........................................................ 25

Appendix 2. Site Plan ............................................................................................................. 34

Appendix 3. Proposed permit conditions ................................................................................ 35


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1 Approvals process An application for a permit under the Land Use Planning and Approvals Act 1993 (LUPA Act) in relation to the proposal was submitted to Circular Head Council on 17 June 2011.

The proposal is defined as a ‘level 2 activity’ under Schedule 2 Subsection (4)(d) of the Environmental Management and Pollution Control Act 1994 (EMPC Act), being:

Milk Processing Works: the conduct of works at which milk is separated, evaporated or otherwise processed for the manufacture of milk powder … being works with a processing capacity of 3,000 litres or more of whole milk, skimmed milk or cream in an 8 hour working day.

Section 25(1) of the EMPC Act required Council to refer the application to the Board of the Environment Protection Authority (the Board) for assessment under the Act. The application was received by the Board on 22 June 2011.

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

The Board, required that information to support the proposal be provided in the form of a Development Proposal and Environmental Management Plan (DPEMP) prepared in accordance with guidelines jointly issued by the Board and Circular Head Council. The guidelines were issued to the proponent on 6 May 2011.

A draft of the DPEMP was submitted to the Department for comment prior to its formal submission. A DPEMP was submitted to Council with the permit application. The DPEMP was released for public inspection for a 28-day period commencing on 2 July 2011. Advertisements were placed in the Saturday Advocate and on the EPA web site. The DPEMP was also referred at this time to relevant government agencies for comment. No public submissions were received.

On 12 August 2011, the Board requested that the proponent prepare a DPEMP Supplement to address issues raised in the consultation period. A DPEMP Supplement was submitted by the proponent on 16 August 2011 and further information in the form of a letter was submitted on 19 August 2011. Together these will be referred to as the Supplement.


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

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


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3 The proposal Tasmanian Dairy Products Company Ltd (TDP) proposes to construct and operate a milk powder processing facility near Smithton. The facility will have the capacity to process 480,000 litres of milk per 8 hour working day (1.5 ML of milk per 24 hours); producing approximately 120 tonnes of milk powder and 3.5 tonnes of anhydrous milk fat (AMF), a saleable by-product.

The Process The main stages of the milk powder process are described below and shown in Figure 2.

• Milk is delivered and stored in silos. It is pumped to centrifuges and separated into cream and skim milk. This process also removes any extraneous matter from the milk (referred to as milk sludge).

• Skim milk is standardised for protein content by the addition of lactose powder and is then directed to an evaporator where up to 90% of the water is removed under vacuum to produce a concentrate.

• Concentrate passes to spray drying: it is sprayed at high pressure into the drying chamber and mixes with heated air to remove remaining water. Powder at a maximum of 4% moisture is produced from the chamber.

• Depending on customer specifications the powder may be gas packed, with a mixture of nitrogen and carbon dioxide, and stored prior to dispatch.

• As a by product - surplus cream is converted to Anhydrous Milk Fat (AMF), also known as butter oil. The process involves concentration of the fat to 99.5% butterfat by using a series of centrifuges. This product will be packed into 200 litre drums and sold to the food industry.

The main characteristics of the proposal are summarised in Table 1. A detailed description of the proposal is provided in the DPEMP.

Table 1: Summary of key proposal characteristics Activity

The production of milk powder. Processing up to 480,000 litres of milk per 8 hour working day. Location and planning context

Location RA 2 Irishtown Road, Smithton (Figure 1). Approximately 3 km south of Smithton, 5 km north of Irishtown. CT 107370/4, 226397/1, 108510/4

Land zoning ‘General Industry’ according to the Circular Head Planning Scheme 1995. Circular Head Council has stated that the proposal will be defined as ‘Industry, Noxious and Hazardous’ owing to the large production capacity. Noxious Industry is a discretionary use in the General Industry Zone. Private: currently in other ownership; the proponent intends to purchase the land. Land tenure

Existing site The site is currently operated by Gunn’s as a sawmill and wood processing activity. Wood processing has been undertaken at the site since the 1960’s.

Land Use

Topography The site is relatively flat with few undulations or topographical features. The site ranges from 26 m AHD towards the northern extent of the site, to 31 m AHD on the southern boundary. Slightly elevated areas (north and east) of the site are located on Quaternary windblown sands. Lower areas (west and south) on Quaternary alluvium. These sediments are underlain by chert and dolomite of the Cambrian Smithton Dolomite.

Geology

The site is mapped as a low risk of acid sulphate soils (ASS) being present on site. Soils Hydrology An ephemeral waterway to the west of the site (known colloquially as Bellinger’s Creek),

runs south to Coventry Creek which flows north-west to the Duck River.


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Local region Climate Mean annual rainfall: 1106.3 mm/year;

Maximum mean monthly temperature: 21.5°C in February; and Minimum mean monthly temperature: 4.5°C in July

Surrounding land and uses

Adjacent land is general industrial and rural residential. Ta–Ann veneer mill is immediately to the south; an abattoir, a wood processing plant and a timber preservation plant are within 1 kilometre to the north-west. Other land within a 1 kilometre radius is rural and residential. The nearest residence in other ownership is approximately 380 m to the east on the Bass Highway. The southern part of the site is mapped as being in the geo-conservation feature Smithton District Mound Springs and Spring Deposits.

Geo-conservation

Proposed infrastructure Major equipment • Milk unloading bay (x2)

• 3 x silos up to 200 kL capacity for milk storage • A wet processing area, including a fully bunded chemical storage area • Vapour recompression evaporator • Spray dryer (with bag-house emission control) • Powder packing system (hermetically sealed) • A palletising system

Other infrastructure

• Electrical Transformer bay • Administration and office area (including amenities -existing) • Services supply, including water treatment and compressed air supply (internal) • Car parking and site access • Despatch awning • Storage and warehouse building • Compressor/electrical control room • 1 potable water tank and 2 fire water tanks

Mobile construction equipment

• 1 x mobile crane • 3 x trucks (1 at night) • 1 x forklift • 3 x angle grinders (or similar power tools) (2 at night), • 1 x mobile air compressor/generator (daytime only), • 1 x excavator (daytime only) • excavators, bobcats and backhoes will be utilised to excavate footings and service

trenches. Inputs

Approximately 180 kL per day, predominantly from recycled evaporator condensate. Water Energy Electricity usage has been estimated as 8,280 kW.

Up to 3, privately owned transformers will be installed. Electricity supply will generally be from the mains, but small generators may be used occasionally. Fuel for mobile equipment.

Steam The proposed plant requires steam to be provided in one of two forms: • 30 bar pressure- 9 tonnes/hour and 10 bar - 4 tonnes/hour; or • 10 bar pressure- 15 tonnes/hour with electricity used for top up. Steam will be sourced under a supply contract from the adjacent Ta Ann boiler, with water (where not from the condensate reuse system) and electricity sourced from the local network.

Other raw materials

Approximately 1.5 megalitres of milk per day. Powdered lactose to standardise protein concentrations delivered to site as needed. It is estimated the process will require approximately 1,850 tonnes per annum.

Wastes and emissions Liquid Up to 971 kL per day, to be discharged to sewer under a trade waste agreement (TWA).

Some excess condensate, not used on site, will be provided to Ta-Ann as boiler feed. Dust and particles. Atmospheric

Solid General waste, packaging etc. Milk sludge (up to 1.5 cubic metres per day).


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From construction, operations and traffic movements. Noise Greenhouse gases (GHG)

Greenhouse gases will be generated by the project as a result of diesel powered mobile equipment operations, processing operations, onsite and offsite transport activities. The location, central to dairy production, minimises the offsite transport requirements. Estimated GHG emission of operations is 0.14 tonne CO2e per tonne of product at the port (corresponds to 56TJ per annum). The DPEMP states that the primary contributor to the greenhouse footprint for most plants is about 80-84% thermal energy. The use of steam from the burning of wood waste (greenhouse neutral under the IPCC rules) means this plant will produce much lower GHG emissions than the 1.4 tonne CO2e per tonne of product from other current plants. There are no reporting requirements under the National Greenhouse and Energy Reporting Act 2007 as the thresholds of 100 terrajoules of energy consumed or 25 kilotonnes of CO2e produced are not exceeded by the operation.

Commissioning and operations Operating hours Peak production: 24 hours a day; 7 days a week. Milk powder production will occur for

21.5 hours per day, with the remaining 2.5 hours used for cleaning and maintenance (as required). Factory operating hours for non-peak production will be determined by milk supply. Potentially as low as 8 hours a day from May to August when on-farm milk production is lower. Construction and commissioning (10 months) nominally commencing from September 2011. Some construction of key infrastructure will take place interstate and be delivered to site during the construction programme.

Project timetable


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Proposal Site

Figure 1: Proposed location


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Figure 2: Process overview (Figure 5 of the DPEMP).

4 Need for proposal and alternatives The DPEMP state that TDP have spent over 3 years investigating a suitable site for the operation and that numerous factors were considered when making the choice, including but not limited to:

• Proximity to high quality milk and abundant supply;

• Proximity to port facilities for transport of finished product to market;

• Availability of skilled or semi skilled labour;

• Appropriate infrastructure;

• Ability to discharge process wastewater to sewer; and

• Price and availability of industrial land.

Prior to submitting the NOI for this application the proponent submitted a NOI for the same type of facility on a site approximately 350 metres to the south. That site was discounted as it required significant works to construct site buildings, establish services and upgrade access.

The final site was selected for the existing reticulated infrastructure (power, water and wastewater), site buildings and road accesses some of which can be retained and used for this proposal.

The DPEMP states that the facility will use best practice dairy processing technology; similar technology is currently being used in Victoria, South Australia, New Zealand and South America.


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5 Public and agency consultation A summary of the submissions is contained in Appendix 2 of this report. The proponent’s response to those issues is contained in the DPEMP Supplement.

One representation was received; this was from the EPA Division, acting on advice from the Chairman of the Resource Management and Planning Appeal Tribunal. The purpose of the representation was to ensure that the EPA had the right to join any appeal that might be lodged in regard to the application.

The DPEMP was referred to government agencies/bodies with an interest in the proposal. Responses were received from the following:

• DIER.

The following Divisions/Areas of the Department of Primary Industries, Parks, Water and Environment also provided comment on the DPEMP:

• Air Modelling Specialist, EPA Division;

• Noise Specialist, EPA Division; and

• Water Specialist, EPA Division.

The DPEMP Supplement prepared by the proponent provides a response to each of the relevant environmental issues raised during the consultation period.

6 Evaluation of key issues The key environmental issues relevant to the proposal that were identified for detailed evaluation in this report were:

• Wastewater Management

• Hazardous Substances

• Noise

• Atmospheric Emissions

These issues are discussed individually in the following Sections. The table of commitments from the DPEMP and DPEMP Supplement is included in Appendix 3 of this report.

6.1 Wastewater Management

Description The proposal has the potential to impact on the quality of water in the receiving environment through the release of effluent.

Receiving Environment The proposed facility will be located in the Duck River catchment; the Duck River is located approximately 3 kilometres west of the site.

The protected environmental values (PEVs) for the Duck River catchment (DPIW 2000), in the area of the proposed facility are:

A: Protection of Aquatic Ecosystems: (ii) Protection of modified (not pristine) ecosystems from which edible fish are harvested.

B: Recreational Water Quality & Aesthetics (ii) Secondary contact water quality

D: Agricultural Water Uses (i) Irrigation

E: Industrial Water Supply – Food Processing

A drainage line, known colloquially as Berringer’s Creek, runs through the western part of the site for approximately 250 metres and then flows south to join Coventry Creek, a tributary of the Duck River.

The DPEMP describes Berringer’s Creek as a drainage line highly modified by agricultural activities, with vertical embankments, flat gradient, and little, or no, riffles or pools. An abattoir and a number of wood processing sites discharge stormwater to Berringer’s Creek.

Wastewater Disposal In addition to general domestic wastewater, wastewater will be produced by the process in the form of evaporator condensate (also referred to as ‘Cow Water’). Generated during the evaporation and drying stages of the milk powder production process, it is essentially the separated water component of the incoming milk stream.

TDP expect to generate an average of 411 kilolitres (kL) of wastewater per day during the first three years of production increasing to an annual average of 738 kL/day at full production. Maximum peak volume will be 971 kL/day which will be disposed of as follows (the following is based on full production maximum quantities):


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Some will be disinfected (probably by chlorine dioxide) and used for the ‘cleaning in place’ (CIP) process. CIP is a fully automated cleaning of all equipment involving rinsing with detergents and cold water and with nitric or phosphoric acid.

• CIP is expected to use, and produce, an average of 171 kL/day with a monthly higher quality clean producing 236 kL/day. This will be disposed of to sewer in accordance with a trade waste agreement (TWA).

• 63 kL/day will be sent to Ta- Ann for re-use as boiler feed.

• The remaining volume is condensate that will be discharged to sewer. In the future it is proposed to release condensate to Berringer’s Creek. A Discharge Management Plan (DMP) will be developed taking into consideration the final quality of the evaporator condensate, water quality in the receiving environment and volumetric flows. The DMP will be submitted to the Director for approval.

Management measures • Evaporator condensate will be reused as per the reuse hierarchy (Commitment 3).

• All evaporator condensate discharged from the process evaporator/dryer will be monitored for pH, dissolved oxygen, conductivity and temperature.

• Unless a Discharge Management Plan for discharge of evaporator condensate to the drainage line has been approved, all evaporator condensate will be discharged to CMW via the dedicated sewer line (Commitment 4).

• During the first 3 months of production, evaporator condensate will be tested once a week to ensure the online monitoring equipment is performing to specification. Thereafter tests will be undertaken annually (Commitment 5).

• On line water quality equipment will be monitored to ensure it is operational and calibrated as per manufacturer’s specification; performance deficiencies will be addressed accordingly.

• Domestic wastewater will be discharged to sewer.

• Milk tanker washing (either inside tanks or general cleaning of exterior) will not occur on site under any circumstances.

• Surface water monitoring will be undertaken in Berringer’s Creek during operations, as detailed below:

- Three surface water monitoring locations are proposed one upstream where the drainage line enters the proposed site, one within the boundaries of the site and one downstream.

- The following parameters will be field analysed monthly for 6 months following wet and dry commissioning: pH, Dissolved Oxygen (%), Conductivity (µS/cm), temperature (°C), general appearance: scums, floating material, discolouration or odours etc

- water quality samples collected for laboratory analysis, will be analysed for the field parameters and the following: Oil and Grease, Total Nitrogen, Total Phosphorous, Total heavy metals (including Mercury), Biochemical Oxygen Demand, Total Suspended Solids

- At the end of 6 months, if monitoring data is consistent with the ambient water quality data, the frequency will be reduced to 3 monthly. Otherwise, monitoring will continue as normal and reviewed at the 12 month anniversary of commissioning.


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• All surface water quality monitoring data will be forwarded to the Director, EPA as soon as reasonably practicable after results are received (Commitment 20).

Submissions No submissions received.

Cradle Mountain Water (CMW) can require Council to include conditions in any permit granted by Council. While no formal advice was received from Cradle Mountain Water during the consultation process, they did provide the EPA Division with a set of draft conditions which were likely to be required to be included in the permit. One of these conditions was the requirement that any effluent pump station installed was to be the responsibility of the proponent.

Supplement A pump station operated as part of a Level 2 activity has the potential to increase potential impacts from odour, noise and spillages.

The Board requested further information in the form of a DPEMP Supplement to address environmental issues associated with the operation of the pump station.

The Supplement included a letter from the Chief Executive Officer of CMW confirming that the water authority will operate the pump station, associated infrastructure and be responsible for its ongoing performance and maintenance.

Evaluation Discharge to sewer Appendix I of the DPEMP was a letter from CMW confirming the acceptance standards for the TWA. The limits outlined a 3-staged approach with increasingly tight limits over 6 years.

The DPEMP states that these limits can be achieved and of the parameters addressed in the DPEMP the expected levels are well below even the tightest (year 6) levels to be included in the TWA. No on-site pre-treatment is proposed to meet these levels and no buffer storage is proposed to control the volume of water discharged.

It is also intended that some of the condensate will be discharged to a nearby industry for re-use as boiler feed. This is generally supported as it is in keeping with the principles of the State Policy on Water Quality Management 1997 (the SPWQM), however it should be noted that there is the potential for this to cause odour emissions at the boiler site (University of Queensland 2004). It is recommended that the Director be notified when the release of water to another industry commences.

It is recommended that the permit require that all effluent be discharged to those points identified in the DPEMP: sewer; re-use as boiler feed, Berringer’s Creek in accordance with a DMP (condition E1). It should be noted that, if monitoring of wastewater demonstrates that the parameters for the wastewater cannot meet those on the TWA some form of wastewater treatment plant may need to be installed on site. A new wastewater treatment plant is likely to require a new environmental assessment and possible development application.

The decision by CMW to accept responsibility for the pump station means that the pump station does not form part of the Level 2 activity and the environmental impacts associated with it are beyond the scope of this assessment.


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Discharge of condensate to the environment No emission limit guidelines have been set under the SPWQM for milk processing facilities.

The DPEMP states that the expected concentrations are comparable with Australian Drinking Water Guidelines. The predicted concentrations of contaminants such as nutrients and solids are very low, with no or very little concentrations of metals due to the organic nature of milk.

The State of the Rivers Report (DPIWE 2003) concluded that water quality in Coventry Creek and its tributaries is adversely impacted by high nutrient levels from upstream discharges and agricultural runoff; and suffers from high concentrations of suspended sediments from bank erosion and damage by stock; this has resulted in poor water quality characterised by excessive siltation and algal blooms.

The DPEMP states that the quality of water currently in Berringer’s Creek has elevated concentrations of total metals and nutrients; that levels of oil and grease are low but a number of surface sheens were observed.

Given the expected low levels of contaminants in the condensate and the impacted quality of water in Berringer’s Creek it would seem unlikely that contaminants in wastewater will compromise the PEV’s in the Duck River or adversely impact the water quality in Berringer’s Creek.

However; condensate inevitably has low dissolved oxygen and can be acidic, can be odorous, can contain product carry-over and the temperature can lead to the growth of thermophilic bacteria (University of Queensland 2004). Also, the sheer volume of wastewater has the potential to cause erosion and associated sedimentation, displacement of riparian vegetation; and overflow of the channel particularly during heavy rainfall events.

Advice from the Water Specialist, EPA Division, is that the proponent should be required to demonstrate that the discharge of wastewater to the environment will not have unacceptable impacts and should demonstrate how the discharge will be managed. It is recommended that while the permit should allow for the discharge of effluent, no effluent be permitted to be discharged until further data and assessment of impact can be provided. It is recommended that the proponent be required to prepare a discharge management plan and submit this to the Director for approval (condition E2). The plan should include consideration of the existing environment, contaminants of concern on wastewater and discharge volumes.

While it is not recommended that the proponent be required to undertake ongoing monitoring of water quality in the receiving environment; any discharge management plan will need to include monitoring and samples taken should be appropriately handled (condition M1).

Recommendations It is recommended that relevant management commitments outlined in the DPEMP and summarised above are included in the permit.

The following standard conditions are recommended for inclusion in the permit:

M1 Dealing with samples obtained for monitoring.

The following site-specific conditions are recommended for inclusion in the permit:

E1 Approved Wastewater Discharge Methods.

E2 Discharge Management Plan.


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6.2 Hazardous Substances

Description The inappropriate storage and handling of hazardous substances has the potential to cause contamination of land and water. Hazardous substances on site include:

• Hydrocarbons - No bulk fuel stores will be located on site.

• Chemicals – Sodium hydroxide as a cleaning agent (4,000 litres); Nitric or phosphoric acid for CIP (4,000 litres) chlorine dioxide for condensate sterilisation prior to use in CIP (1,000 litres)

• Gases - Carbon Dioxide and Nitrogen to gas pack the finished product and protect whole milk powder from oxidising (2,000 m3 each); Liquid Petroleum Gas (200kg).

• Milk and milk products – Up to 1.5 Megalitres of milk delivered daily; approximately 1,850 tonnes per annum. Approximately 2 weeks of milk powder (2,000 tonnes) will be stored prior to dispatch.

• Transformer oil - Up to 3 privately owned transformers will be installed. The transformers will be an oil filled type for outdoors installation.

Management Measures • Should a spill occur appropriate measures will be employed to contain the spill using

dedicated equipment.

• Dangerous Goods storage and handling will comply with the requirements of Dangerous Substances (Safe Handling) Act 2005 (Commitment 11).

• Implement the monitoring regimes as detailed in Section 5.1 of the DPEMP (Commitment 19) (as discussed in section 6.1 of this report).

• Undertake a review of the environmental management plan on the 12 month anniversary for approval by the Director, Environment Protection Authority (Commitment 21).

• Transformers will be installed in a separate fenced and bunded area at ground level.

Milk and Milk products

• Milk spillage in the unloading area will be 100% discharged to sewer.

• Milk delivery will only occur when TDP staff are on site. Strict speed limits will be set on site (5 km/hr) to ensure tankers and dispatch vehicles have little chance of accident and to minimise damage if an accident occurs.

• The milk unloading area has been specifically designed with the following:

- The unloading area will be hard-stand with no opportunity for spilt product to contaminate nearby surface soils or enter groundwater.

- Any unloading will be strictly monitored by the tanker driver. Interconnecting pipes will be regularly checked to ensure they do not rupture or have any slow leaks.

- The milk unloading/delivery bay will be contoured to direct any spilt milk into a dedicated sump and hard piped to sewer for discharge. Note that all unloading is undertaken in a covered area with all drainage directed to sewer. No stormwater will enter this system.

- A perimeter strip will also capture any spilt milk and direct to the collection sump. Site stormwater will be prevented from entering the strip drain.


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• Any spills outside the perimeter strip drain will be controlled with temporary booms and remediated appropriately.

• If milk is spilt from the process or during delivery an operator (or milk delivery driver) will activate a valve located at the outlet of the triple interceptor, capturing the (potentially) contaminated water prior to off-site discharge. This will provide TDP with time to address the spill and clean up where necessary.

• The interceptor will be of sufficient capacity to take the largest anticipated annual rainfall event, with buffer capacity to contain milk spillage.

• Milk powder handling (including truck loading) is undertaken within the confines of the building, and therefore has very little chance of entering the stormwater system.

• All lactose delivered to site will be stored within the warehouse (Commitment 12).

• Any lactose spills will be immediately cleaned up and disposed in secure covered waste bins (Commitment 13).

Chemicals/Hydrocarbons/Gases

• If any soil is contaminated during construction, it will be removed and the excavation area remediated. The contaminated soil will be disposed of at an appropriate treatment facility by an authorised controlled waste transporter. If necessary, appropriate authorities will be notified.

• The Chlorine dioxide dosing system is likely to take the form of a small fully contained and bunded package plant.

• Laboratory chemicals and acids will be stored and bunded in accordance with the Dangerous Substances (Safe Handling) Act 2005. Quantities to be stored on site will be kept to a minimum.

• All necessary chemical licenses will be sought from Workplace Standards Tasmania.

• Material Safety Data Sheets will be filled as necessary for chemicals stored on site and used by emergency authorities and referenced as required.

• All chemicals will be handled appropriately and training undertaken by staff if necessary.

• Gas is likely to be stored in either banks (skid mounted) of bottled gas, or larger single tanks filled from delivery vehicles.

Submissions Cradle Mountain Water, have the power to require Council to include conditions in any permit, relating to the development application, granted by Council. While no formal advice was received from Cradle Mountain Water, they did provide the EPA Division with a set of draft conditions which were likely to be required to be included in the permit.

One of these was a condition requiring that any spills within the processing area were not to be directed to sewer in a concentrated form.

Supplement The supplement clarified that any milk spilt in the covered and contoured unloading station will be captured and contained in the unloading station perimeter drainage. To maintain compliance with the CMW TWA, it is intended to dilute any spilt milk using the standing volume in the pump station.

If necessary a licensed waste contractor will remove the spilt milk.

In the highly unlikely event any milk enters the triple interceptor, via spillage outside the unloading area, the interceptor will be closed and all milk removed by a waste contractor.


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Evaluation Any spillage of milk or milk products will be costly for the proponent and the facility has been designed, and will be operated, to prevent such spills. Measures such as computer controlled unloading pumps, pressure sensors on the milk silos to prevent over-flow and completely sealed, fully welded piping and tank storage equipment with minimal flanged joints are considered to minimise the risk of such an occurrence.

The measures presented are considered appropriate to prevent most spills of hazardous substances, including milk, from entering waterways and thus to minimise environment harm. They should be formalised in the conditions (conditions H1, H2, H3).

However, the proponent has not demonstrated that in the event of a catastrophic failure of a milk storage tank (200 kL) the facility has sufficient capacity to contain the volume of milk released. This should be addressed prior to construction, it is recommended that the proponent be required to demonstrate how such an event would be managed to prevent milk leaving the Land and causing environmental harm (condition H4).

Recommendations It is recommended that the proponent be required to comply with the following standard conditions:

H2 Hazardous materials (< 250 litres)

H3 Spill kits

It is recommended that the proponent be required to comply with the following non-standard conditions:

H1 Storage and handling of hazardous materials

H4 Milk Spill Management Plan

6.3 Noise

Description Noise emissions from the proposal during construction and operation have the potential to cause an environmental nuisance at sensitive uses, including residences, in the vicinity.

Nearest residences are approximately 380 metres to the east on the Bass Highway. Other residences are approximately 560m to the south on Irishtown and Marthick’s Roads and 425m to the north on Bacon Factory Road.

The proposal is for 24 hour operations, seven days per week, although this is likely to be seasonal with potentially only 8 hours of operation from May to August.

A noise assessment was undertaken, and provided as Appendix J of the DPEMP. Measurements of the existing noise levels at nearby residences were taken and noise emissions from the new plant were modelled.

Existing conditions Noise measurements were taken at 12 residences at 3 sites. Measured noise levels are shown in table 2 below.

The existing acoustic environment was described as:

• Site 1: evening and night times are dominated by noise from refrigeration equipment at the abattoir. During daytime hours, vehicles including forklifts and trucks at the abattoir were audible.


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• Sites 2 and Site 3: evening and night times are dominated by noise from Ta Ann, veneer mill. Ta Ann is adjacent to the south of the proposal site and operates 24 hours per day. Noise appeared to be mostly from ventilation fans and was relatively constant, no dominant tones or impulsive noises were noted. During the daytime, noise from the Gunns’s sawmill, which was not operating during the night and evening measurements, was also audible.

In addition to the industrial noise, significant noise was contributed by traffic on Irishtown Road and the Bass Highway, both of which carry significant numbers of light and heavy vehicles. As would be expected, traffic was much less frequent during the evening and night measurements.

Construction Noise The DPEMP states that while construction will generally be limited to 0630 to1800, Monday to Saturday, it is possible that construction will need to occur on a 24 hour basis (3 shifts) Monday to Saturday, and 0700 to 1600 Sunday.

The construction of the proposed plant will utilize conventional building and equipment installation techniques and equipment. No high noise operations such as pile driving or blasting will be required.

Major building components and process equipment will be fabricated off site, requiring only final assembly on site. All onsite fabrication will be carried out inside existing site sheds. For the modelling it was assumed that a forklift truck and two angle grinders (or similar power tools) were operating inside the warehouse.

The following external noise sources were used to characterize the noise emissions:

• 1 Mobile Crane - to assist with the erection of building components and the installation of process equipment

• 3 Trucks (1 at night),

• 1 Forklift truck,

• 3 Angle Grinders (or similar power tools) (2 at night),

• 1 Mobile Air Compressor / Generator (daytime only),

• 1 Excavator (daytime only)

In addition material deliveries will be received on site from utility trucks, rigid trucks, semi-trailers and concrete agitator trucks. Tracked excavators, bobcats and backhoes will be utilised to excavate footings and service trenches.

Electricity supply will generally be from the mains, but small generators and other petrol or diesel powered equipment may be used from time to time.

Maximum predicted construction noise levels at local residences were 46.5 dB(A) (daytime) and 44.2 dB(A) (night time).

Operational Noise The proposed plant includes a milk tanker unloading area, a powdered milk production facility and associated packaging plant, warehouse and services. Most equipment will be installed inside the drying tower or wet processing buildings. The Noise Report stated that noise measurements in similar plants indicate that typical noise pressure levels throughout the interior of these buildings would not exceed 95 dB(A).


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External equipment includes two milk transfer pumps, a water supply pump, a nitrogen generation plant (modelled, but no longer planned to be installed), a cooling tower and two rooftop exhaust fans.

Some traffic noise will be generated by milk tankers and dispatch trucks entering and leaving the milk unloading bay and the warehouse.

Section 4.4.3 of the DPEMP states that following noise mitigation measures have been included in the plant design:

• The dryer tower building, which contains the most noise generating equipment, will be constructed with precast concrete walls, have no open-able windows and all access will be via other connecting buildings.

• All vehicle doorways to the warehouse are equipped with fast roller doors that will normally be kept shut.

• All external personnel doors will be provided with door closers and be kept shut.

• All ventilation fans, inlets and outlets will be provided with silencers.

• Any night time fabrication work will be completed in existing site workshops with doors and windows closed. Once the main building is erected, installation works may continue overnight or when scheduling permits.

• The nitrogen generation plant, if installed, will be provided with an acoustic enclosure.

• All external pumps will be provided with acoustic enclosures.

• All access roads on the site will be sealed to minimise tyre noise and a low speed limit set.

• All vehicles and equipment used will fully comply with or exceed the requirements of the current Australian vehicle design rules.

The calculated noise emissions from the proposal are shown in Table 2 below.

Management measures Undertake a further noise measurement survey after commissioning to provide confirmation of the results (Commitment 7). Implement the noise mitigation measures as described in Section 4.4.3 of the DPEMP (Commitment 8).


Evaluation Advice from the Noise Specialist, EPA Division, is that the modelling was appropriate and conservative in that: the reference data selected for the equipment is likely to be higher than the actual noise emissions of the equipment that is to be installed; and the wind was set at 4 m/s (good propagation), blowing from source to receiver.

The acoustic environment is noisy with most of the residences already experiencing daytime noise levels which exceed the outdoor living indicator for moderate annoyance as stated in the EPP (Noise).

The day-time noise measurements included the Gunn’s sawmill operating, this activity will cease operations soon and so the ambient acoustic environment will be less noisy than that measured. However; the Noise Specialist, EPA Division advised that Ta Ann and the abattoir are the dominant noise sources even at locations where the sawmill is nearer. This suggests that the noise reduction


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after the Gunns sawmill closes will be small and the inclusion of the sawmill in noise measurements is not considered to have significantly influenced the conclusions from the modelling.

Night-time noise levels at one of the sites already exceed the levels indicating likely sleep disturbance. The Gunn’s sawmill does not operate at night.

Table 2: Measured and Predicted Noise Levels

Location Model Result

Measured Background Noise Level (L90) Day Evening Night

Bass Highway House 1 27.9

53.8 43.8 House 2 43.8 28.7 House 3 31.8 House 4 21.0 Irishtown Road & Marthick’s Road House 6 20.9

46.2 43.1 House 7

36.6 19.5

House 7 16.8 House 8 26.0 House 9 16.8 House 10 22.1

55.4 48.6 48.3 House 11 22.4 House 12 24.4

The construction of the proposed plant will utilize typical conventional building erection and process equipment installation, techniques and equipment. No high noise operations such as pile driving or blasting will be required. Major building components and process equipment will be fabricated off site, requiring only final assembly on site.

Construction noise emission levels at residences are predicted to range between 30.2 and 46.5 dB(A) in the day-time and between 23.3 and 44.2 dB(A) at night time.

The Noise Report stated that the noise from the proposed plant during operations will be generated predominantly by fans, pumps and vehicles; qualitatively it will blend in well with the other industrial sources and be difficult to distinguish from the other sources.

The predicted noise emissions for operations are substantially lower than the measured noise levels from existing sources. The Noise Report stated that the Ta Ann emission levels would need to reduce by more than 17 dB(A) before the proposed milk plant’s noise would become intrusive (5 dB(A) above ambient) at any of the residences.

The DPEMP suggests that noise emission limits should be set to the same levels as the neighbouring Ta Ann timber processing facility. These levels are 45 dB(A) daytime, 43 dB(A) evening and 37 dB(A) night time. The results of the modelling shows that the proposed milk processing facility will be able to achieve these limits comfortably during operations. These levels are lower than the relevant noise policy indicator levels, by sufficient margin to preserve the amenity of residents living in the surrounding area and allow for future industrial development in the area.

These noise limits should also apply during construction; this will ensure that, if construction is to occur during night –time hours, some louder activities may need to be limited to those hours when they are less likely to cause environmental nuisance.


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The Noise Specialist, EPA Division advised that the proposal is relatively quiet compared to existing activities in the area; it is considered unlikely that noise from the activity will be a significant impact of this proposal. The proposed noise emission limits are suitable and achievable for both the construction and operational phases; and are in keeping with other activities in the area. They should be included in the permit conditions (condition N1).

The Noise Report recommended that the model was based on reference noise source data, a limited number of site measurements and a number of noise modelling assumptions, a further noise measurement survey should be carried out after the commencement of operation to provide confirmation of the results. This is supported and should be formalised in the permit conditions (conditions N2 and N3).

Recommendations It is recommended that relevant management commitments outlined in the DPEMP and summarised above are included in the permit.

The following standard (generic) conditions are recommended for inclusion in the permit:

N3 Noise survey methodology and reporting requirements.

The following site-specific conditions are recommended for inclusion in the permit:

N1 Noise Emission Limits.

N2 Noise survey requirements.

6.4 Atmospheric Emissions

Description Emissions of particulate matter from any source have the potential to adversely affect air quality, and the health of the residents in the local area.

Dominate winds are south westerly, with strong north easterly winds in the afternoons.

The nearest residence, in other ownership, is 380 metres to the east.

An air quality assessment was undertaken of predicted stack emissions and the report included as Appendix G of the DPEMP.

The DPEMP states that the bag-house will capture all particulates from the fully contained production process (the evaporator and spray dryer) and the facility will use some of the best available modern technology, including continually operating reverse air jet cleaning and CIP cleanable bags (which will get washed once per day).

The AUSPLUME dispersion model assessment focused on emissions of PM10 and total suspended particulate matter from the stack. An odour assessment was not part of the scope of works as the DPEMP states that odour emissions are not associated with a milk powder processing facility.

In addition to point source particulate emissions, fugitive emissions may be generated by vehicle movements and from disturbed areas.

Fugitive particulate emissions from the factory site were not part of the scope of works as:

• All driveway areas will be sealed

• Packaging is undertaken internal to the factory, and in fully enclosed equipment, as dictated by strict food health and safety hygiene requirements

• Finished milk powder will be stored undercover in a large warehouse. Any spillage will be cleaned up at the end of each shift (if not immediately).


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Management measures • Dust emissions from the site will be managed during periods of high winds with watering

and construction will cease if site activities are causing dust nuisance.

• The bag-house will be maintained in accordance with the manufacturer’s specifications. It is likely that a complete bag filter replacement will be required every two years.

• The performance expectations of the bag filter will be monitored and deficiencies addressed accordingly commissioning

• Bag filters will be cleaned and maintained in line with operating specifications


Evaluation Advice from the Air Modelling Specialist, EPA Division is that that the modelling undertaken was appropriate; it was informed with local meteorological data and stack emission tests from the Ta Ann boiler.

Due to the AUSPLUME analysis confirming that stack emissions are below the Tasmanian Environment Protection Policy (Air Quality) 2004 requirements, no potential effects have been identified and no formal mitigation measures are proposed:

The AUSPLUME analysis concluded the following:

• The maximum predicted ground level concentration of PM101 was 34.6 µg/m3

• The maximum concentration expected to occur at any of the surrounding sensitive receptors is 27.9 µg/m3

• These concentrations are well below the EPP (Air) ground level concentration criteria for PM10 of 150 µg/m3

• The maximum in-stack concentration was predicted to be 27.13 mg/m3

• This level is below the EPP (Air) guideline value of 100 mg/m3.

The DPEMP states that there is little risk of powder spills being transported offsite as the packing line and storage areas are indoors. When completed, the milk processing building will be fully sealed by an internal positive pressure air system to prevent ingress of foreign materials, thereby maintaining the strict hygiene requirements dictated by food manufacturing legislation and standards.

Advice from the Air Specialist, EPA Division is that it is recommended that the proponent be required to install and maintain stack testing facilities to allow monitoring of atmospheric emissions (condition A1) and that in order to validate the modelling, to monitor future changes in emissions over time and demonstrate compliance with the EPP (Air), it is recommended that the proponent be required to undertake a stack test for particulates within 3 months of commissioning and annually thereafter unless results demonstrate that this is no longer necessary (condition A6).

1 Particulate Matter with a diameter of less than 10 microns


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It is therefore considered appropriate that no further mitigation measures are required. The proponent should be required to control dust emissions sufficiently that they do not cause an environmental nuisance (condition A2).

The DPEMP states that odour should not be a part of normal milk powder processing operations. However; odour nuisance could occur if spills are not appropriately cleaned up or waste is allowed to putresce. Advice from the regulator (Vic EPA) of a similar plant in Gippsland that following complaints odour sources had been identified as the wastewater treatment plant and solid waste handling. It is recommended that the proponent be required to manage the sources of odour (condition A3).

Recommendations It is recommended that the proponent be required to comply with the following standard conditions:

A2: Control of dust emissions

A3: Odorous gases

It is recommended that the proponent be required to comply with the following standard conditions:

A1: Stack testing facilities

A6 Stack testing frequency

7 Other environmental issues In addition to the key issues, the following environmental issues are considered relevant to the proposal and have also been evaluated.

• Stormwater

• Solid and Controlled Waste Management

• Traffic Impacts (noise, dust and odour)

• Acid Sulphate Soils (ASS)

• Site Contamination

• Heritage

• Geoconservation

• Flora/Fauna

• Decommissioning and Rehabilitation

Details of this evaluation, along with recommended permit conditions, are contained in Appendix 1.

8 Conclusions The EPA Division is of the view that:

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

2. the assessment of the proposal has been undertaken in accordance with the Environmental Impact Assessment Principles; and

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

This assessment has been based upon the information provided by the proponent in the permit application, DPEMP and DPEMP Supplement.

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

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


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9 References Pitt & Sherry (29 June 2011) Milk Powder Processing Facility - DPEMP.

University of Queensland (August 2004) Eco Efficiency for the Dairy Processing Industry

DEPHA (2009) Environment Protection Policy (Noise)

DPIW (2000) Environment Management Goals for Tasmanian Surface Waters, Catchments within the Circular Head & Waratah/Wynyard Municipal Areas

DPIWE (2003) State of the Rivers Report for the Duck River

DTAE (2004) Environment Protection Policy (Air Quality)

10 Summary of appendices Appendix 1 Assessment of other environmental issues

Appendix 2 Summary of issues raised by public and agency submissions

Appendix 3 Site Plan

Appendix 4 Proposed permit conditions, includes DPEMP Commitments at Attachment 3.


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Appendix 1. Assessment of other environmental issues Issue 1

Stormwater

Description of potential impacts

In addition to the handling of hazardous substances as discussed in section 6 of this report; the proposal has the potential to impact on stormwater through sedimentation and turbidity during construction and operations.

Management measures proposed in DPEMP

The DPEMP provided a range of measures to prevent stormwater contamination including:

• Erosion and sediment controls will be established prior to works and maintained by the site supervisor as necessary and after prolonged and/or heavy rainfall (Commitment 2);

• Construction management controls, including silt stop fences, will be installed to manage sediment discharges from disturbed areas during construction. All controls will be maintained appropriately during construction and repairs carried out where required;

• Strip drains will be inspected daily to ensure that they are free from debris and remain operational;

• Site stormwater will be directed to a triple interceptor prior to discharge. The interceptor will be inspected weekly and maintained as needed;

• Drainage lines will be inspected weekly to identify any potential impacts or obvious changes in appearance. Issues will be addressed as appropriate;

• Implement the monitoring regimes as detailed in section 5.1 of the DPEMP (commitment 19) (see section 6.1 of this report).

Public and agency comment

No comments received

Evaluation and Recommendation

The sediment controls proposed for use during construction are considered appropriate.

During operations stormwater impacts will be minimal as the majority of site surfaces will be hard-stand areas with little or no potential for sediment discharges.

Ongoing monitoring of stormwater quality is not generally required of activities such as this and is not recommended. However; monitoring undertaken as per Commitment 19 will also have indicate any impacts on stormwater.

It is recommended that the proponent be required to comply with the following standard condition:

E3 Stormwater. It is recommended that the proponent be required to comply with the following non-standard conditions: E4 Maintenance of stormwater treatment system.


Appendix 1

Issue 2

Solid and Controlled Waste Management


Waste should be collected and disposed of appropriately to avoid causing environmental harm or nuisance. Milk waste has the potential to cause odour nuisance if allowed to putresce.

The proposed facility will generate the following solid wastes:

• Milk sludge (essentially dirt/excrement in milk) estimated at up to 1.5 kL per day.

• Non-conforming product.

• Powder spills in the packing line and storage area.

• Miscellaneous packaging wastes including plastic bags, cardboard, packaging tape and shrink wrap, bag filters from the bag house, small quantities of waste chemicals.


• Milk sludge will be stored in secure, bunded, storage containers (200 litre drums) inside the factory to prevent unnecessary discharges (Commitment 9). Containers will be loaded onto pallets and shrink wrapped for safe transport It will be collected daily. Sludge will be reused as pig feed.

• General wastes and bag-house filters will be stored in lidded waste bins for collection and disposal (Commitment 10).

• Powder spills will be vacuumed up using mobile vacuum cleaners and disposed in sealed bags for use as stock feed.

• Non-conforming product will be packaged as if for sale (confirmation of non-conformance is generally undertaken after packaging).

• Out of specification milk will not be delivered to site as it is tested prior to loading into the milk delivery vehicle at the farm.

• The factory layout and wet/dry processing areas are designed to maintain critical hygiene and there are no feasible pathways for solid wastes to travel outside the building.

• Waste laboratory chemicals will be disposed of according to legislated requirements, by suitably trained operators

• All liquid wastes will be enclosed in the building and discharged in properly constructed and maintained pipes of appropriate capacity for the anticipated loads.




The Waste Management Section of the EPA Division, have advised that milk sludge is not considered a controlled waste and that storage and handling is therefore not regulated by the Environmental Management and Pollution Control (Controlled Waste Tracking) Regulations 2010.

The use of spilt powder and milk sludge as feed is in keeping with the waste hierarchy and is supported. It is recommended that the proponent be require to comply with standard condition:

WM1: Waste Hierarchy.

In order to prevent odour from waste milk products it is recommended that the proponent be require to comply with non-standard condition:

WM2: Milk Waste Management.


Appendix 1

Issue 3

Traffic Impacts (noise, dust and odour)


Noise, dust and odour emissions from traffic movements have the potential to cause an environmental nuisance along transport routes.

A traffic impact assessment was completed. The report was included as Appendix L of the DPEMP.

Vehicles will access the site via the Bass Highway and the established site access on Irishtown Road.

It is estimated that peak truck movements will be 44 per day for milk delivery and despatch.

Milk delivery and despatch movements are expected during daylight hours only (nominally 08:00 to 17:00 hours), 7 days per week.


Widen the left turn out junction at Bass Highway/Irishtown Road to facilitate B-Double access (Commitment 17).

Widen the internal access road to provide dual access (Commitment 18).

All transport will be under contract using reputable drivers and licensed transport companies. Strict compliance with speed limits and safety driving protocols will be a requirement of the transport contract.


DIER made comments relating to traffic safety and intersection upgrades.


The DPEMP states that the vehicle movements associated with milk delivery and despatch is a re-direction of existing traffic which transports milk from the farm, to processing facilities in either Burnie or Wynyard. The traffic impact generated by the proposed facility was found to be minimal.

Truck movements will be on a major sealed highway. Therefore, noise from traffic is not expected to be a significant impact of this proposal and dust from traffic is not expected to be a significant impact of this proposal providing material is not allowed to spill along transport routes (condition A4).

A similar plant has recently been commissioned in Gippsland, advice from the Victorian EPA regulator is that odour from the transport of waste has caused complaints (condition A5).

It is recommended that the proponent be required to comply with the following standard condition:

A4: Covering of vehicles

It is recommended that the proponent be required to comply with the following non-standard condition:

A5: Prevention of odour from vehicles


Appendix 1

Issue 4

Acid Sulphate Soils (ASS)


Disturbance, and exposure to air, of soils containing iron sulphides produce sulphuric acid and can lead to the release of toxic quantities of metals.

The DPEMP states that no known validation sampling has been undertaken following the mapping to quantify or delineate the potential ASS and no signs of ASS have been observed on site.


If any ASS are intercepted on site during construction, they will be handled in accordance with State guidelines (Commitment 1).

Construction work will be restricted to existing site sheds and the footprint of the new buildings.


No comments received.


The site is mapped as having a low probability of ASS occurrence with the notation that no analytical data is available and hence classification is provisional.

DPIPWE (2009) Tasmanian Acid Sulphate Soil Management Guidelines states that no further action is required regarding ASS if a project is unlikely to disturb more than 100 cubic metres of material and will only disturb ground of above 20 metres AHD. According to these criteria, the project does trigger further investigation. No recommendations.


Appendix 1

Issue 5

Historic Site Contamination


Inappropriate or incomplete decommissioning of the existing wood processing activity may lead to disputes over responsibility should contamination of the site become evident in the future.


The DPEMP states that, as a condition of the purchase of the site, the operator of the sawmill will decommission the site and remove any contamination.




Advice from the Wood Processing Unit, EPA Division is that Phase 1 of the Gunn’s Decommissioning and Rehabilitation Plan (DRP) has been satisfactorily completed; that the portions of The Land covered in the report are suitable to be used as an ongoing commercial/industrial site and that pollution has not, nor is likely to, migrate off these areas.

While Phase 1 of the Gunns’ DRP included the removal of all underground storage tanks and asbestos, there exist identified sites of potential contamination within the area to be defined as The Land for the milk powder processing facility. In particular the glue mixing area, stormwater system and traverser line are within the area to be used for the proposal and have been identified as potentially contaminated. This areas should be assessed and remediated prior during the construction of the new facility (condition G11).

It is recommended that the proponent be required to comply with the following non-standard permit condition:

G11: Removal of site contamination.


Appendix 1

Issue 6

Heritage


Loss of Aboriginal and/or European cultural heritage through disturbance.

A desktop European Heritage review was undertaken and the report included as Appendix F of the DPEMP. No European heritage values of local, State or Federal significance were identified.

The DPEMP states that no Aboriginal heritage sites or areas of potential archaeological sensitivity are likely to be present on site as the ‘footprint’ proposed facility is within the boundary of the previous industry.


No specific avoidance or mitigation measures are proposed. However, all site works will be conducted in accordance with the Aboriginal Relics Act 1975.

In the event that any Aboriginal artefacts are discovered during the land clearance, all work will stop immediately in that area and the Tasmanian Aboriginal Land Council and the Manager of the Aboriginal Heritage Tasmania (AHT), DPIPWE, will be contacted to assess the situation.


At the scoping phase AHT advised that no Aboriginal Heritage survey was required.


It is considered unlikely that the proposal will impact on heritage values.

The provisions of the Aboriginal Relics Act 1975 still apply. Information regarding the provisions of the Aboriginal Relics Act 1975 should be included in the information schedule of the permit.


Appendix 1

Issue 7

Geoconservation


The southern part of the site lies in the Smithton District Mound Springs and Spring Deposit area. These Groundwater Dependant Ecosystems (GDEs) could potentially be impacted by direct disturbance or indirectly through impacts on the quality or flow of groundwater.

The proposal has the potential to impact on groundwater quality through spills of hazardous substances.


The proposed facility will not use groundwater and therefore the groundwater bore will be decommissioned during the construction phase of the project. No measures proposed.


At the scoping phase PCAB advised that the Smithton area contains the densest concentration and largest individual examples of mound springs in Tasmania. They have yielded important palaeo-environmental information and are unusual nationally.


The DPEMP states that surveying has confirmed that the spring mounds are located in the Circular Head Wood Centre, not within the proposed site.

Given the geoconservation features in the area it is important to protect GDE’s in the area. Measures discussed above regarding Hazardous Substances will minimise the risk of pollution of groundwater

There will be no underground storage of fuels or other liquid wastes, with potential to leak into site groundwater and the site will be hardstand, with no pathways for liquid wastes to enter groundwater.

There will be no groundwater extraction and so the proposal will have no impact on groundwater flows.

No recommendations.


Appendix 1

Issue 8

Flora/Fauna


Loss of threatened flora through vegetation clearance and soil removal and the subsequent impacts on threatened fauna through loss of habitat and disturbance.

The site has been industrial in nature since 1960’s and is largely void of vegetation, aside from some perimeter trees planted by Gunn’s and pockets of vegetation along the drainage line traversing the site. The riparian vegetation is described as reeds in poor condition; this is attributed to poor water quality from industrial runoff over a long period of time.

An aquatic survey of the adjacent drainage lines was undertaken for Giant Freshwater Lobster (Astacopsis gouldi) and Australian Grayling (Prototroctes maraena) and the report included as Appendix D of the DPEMP. No evidence of these species was observed.


Due to the absence of botanical and aquatic values of local, State or Federal significance, no formal mitigation measures are proposed.


At the scoping phase PCAB did not require a flora and fauna survey.


The site is already an industrial site. Impacts on natural values are not considered to be a significant impact of this proposal. No recommendations.


Appendix 1


Appendix 1

Issue 9

Decommissioning and Rehabilitation


Lack of appropriate rehabilitation may cause future degradation of the natural values of the site and may cause environmental harm or nuisance.


A formal decommissioning and rehabilitation plan will be developed during the 3 year review of the DPEMP and reviewed periodically thereafter (Commitment 22).

The hazards and risks associated with the decommissioning and rehabilitation of the site will be identified, assessed, and managed when the nature of these works is known.


No comments received.


The DPEMP outlined a three phase Decommissioning and Rehabilitation Strategy that has been developed; it initially involves attempting to sell the facility as a going concern and failing that as an industrial site.

It is considered appropriate that no detailed DRP has yet been developed. This should be required to be prepared should it become known that the facility is to close (conditions DC1, DC2, DC3, DC4).

It is recommended that the proponent be required to comply with the following standard conditions:

DC1: Notification of cessation. DC3: Rehabilitation on cessation. DC4: Suspension of activity.

It is recommended that the proponent be required to comply with the following non-standard conditions:

DC2: DRP requirements.

Appendix 2. Site Plan


Appendix 2

Appendix 3. Proposed permit conditions


Appendix 3

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