Environment Bay of Plenty

Bay of Plenty Regional Council

Report From: Ryder Consulting Limited

Paula Golsby

Associate Director / Planner

Date: 25 October 2012

File Reference: 1370 67131

Report to:

The Hearing Committee

Meeting of 20 November 2012

Limited Notified Resource Consent Application Number 67131

AFFCO New Zealand Limited

Discharge Combustion and Odorous Gases

State Highway 2, Rangiuru, Te Puke

1 Introduction

My name is Paula Golsby. I am an Associate Director and Planner at Ryder Consulting Limited. I hold a Bachelor of Arts (Geography) and a Post-Graduate Diploma in Arts (Geography) from the University of Otago. I also have a Diploma in Business from the Swinburne University of Technology in Melbourne, Australia.

I have over eleven years planning experience and have worked in both local government and consultancy planning roles. I have been employed by Ryder Consulting since June 2010.

I have processed, overseen the processing of, and prepared a variety of district and regional resource consent applications. Examples of regional council consents that I have been involved with include: the reconsenting project for the Okere Gates and Ohau Channel Weir, which I processed on behalf of the Bay of Plenty Regional in 2010; the proposed Puketoi Wind Farm located in Manawatu-Wanganui Region; and the Tauranga Waterfront Project for which I was the lead author of the Assessment of Environmental Effects Reports and project co-ordinator. I am also currently involved in Environment Court processes associated with consents to take and use of water for irrigation in the Mackenzie Basin.

Ryder Consulting was retained to assist the Bay of Plenty Regional Council (‘BOPRC’) in processing the application made by AFFCO New Zealand Limited (‘AFFCO’) in June 2012.

2 Purpose

This report has been prepared in accordance with section 42A of the Resource Management Act 1991 (‘RMA’). The report provides an analysis of the resource management issues in respect of the proposal. The assessment and recommendations contained in this report are not binding on the Regional Council or the Hearing Committee. This report has been prepared without knowledge of the content of any evidence or submissions that will be made at the hearing; consequently it cannot be assumed that the Hearing Committee will reach the same conclusions as those provided in this report.

3 Background

AFFCO currently operates a meat processing plant (‘processing plant’) on State Highway 2, Rangiuru, near Te Puke. The processing plant currently operates under a number of resource consents that enable the discharge of contaminants to ground, water and air associated with its operations. Consents are also in place enabling structures within the Kaituna River.

Resource consent 30096 was granted by the BOPRC on 29 November 2002 and enables the discharge of combustion and odorous gases to air from the meat processing plant, subject to a number of conditions. The resource consent is due to expire on 30 November 2012. A copy of resource consent 30096 is attached as Appendix 1.

This application is for a replacement resource consent to enable the continuation of existing discharges of combustion and odorous gases to air.

4 The Application

4.1 Site Description

The site is located on the south side of State Highway 2 in Rangiuru, approximately 6 kilometres (km) east of Te Puke, and is occupied by a meat processing plant owned and operated by AFFCO. The site includes a number of buildings used for the holding, slaughtering and processing of animals. The site includes a rendering plant and a wastewater treatment system. The wastewater treatment system includes pits, wetlands, anaerobic ponds and oxidation ponds. The site operates seven (7) days per week, for approximately 48 weeks of the year and the wastewater system operates continuously.

The surrounding area is generally rural in land use and character. The area is used predominantly for horticultural and agricultural activities, and associated dwellings and activities, such as fruit packing facilities and cool stores. The Assessment of Environmental Effects report (‘AEE’) lodged with the application identifies that there are twenty-two dwellings located within a 1km radius of the rendering plant, and of these seven are within a 500 metre (m) radius.

Other notable land use activities within close proximity to the site include;

(a) The KIWI360 visitor and function centre, located north-east of the site on Young Road;

(b) A visitor accommodation facility located on Young Road (east of KIWI360);

(d) A church and Marae are also located on Rangiuru Road, approximately 1km southwest of the site boundary.

Wind patterns at the site are described within section 3.1 of the AEE (page 16). The prevailing winds are described as southerly and westerly.

4.2 Description of the Proposal

The application seeks to replace an existing resource consent allowing for the discharge of combustion and odorous gases from the Processing Plant to air. The application and AEE provides a detailed description of the site processes and odour sources on the site.

In summary, there are three sources of discharges to air from the processing plant. These are:

(a) The two gas fired boilers, which provide heating to various components of the processing plant;

(b) The rendering plant, which involves the rendering of meat, bones and offal to produce dried meat meal and tallow. It also includes the processing of animal blood; and

Figure 3 within the AEE (page 4) shows the overall layout of the site, including the location of the boiler stacks, the rendering plant, and the wastewater treatment facility. The following sections provide a description of the sources of discharges to air.

4.2.1 Gas Fired Boilers

The gas fired boilers use natural gas and have the capacity to generate 5.25 megawatts (‘MW’) and 5.67MW of heat. The 5.25MW boiler is used predominantly, with the 5.67MW boiler used only when the other is unavailable (due to maintenance, for example).

There are two stacks for discharges from the boilers, and these are 32m and 20m in height. Contaminants, including smoke and vapour, from the boilers are discharged via the stacks.

Conditions 5.11 to 5.13 of the existing resource consent relate to the gas fired boilers and place requirements on the height of the boiler stacks, the operation of the boilers to limit smoke emissions, and restrictions on burning waste materials that could produce toxic products of combustion.

4.2.2 Rendering Plant

Material processed in the rendering plant is sourced from the livestock processing operation on the site, or is brought in from other processing sites.

The material to be processed in the rendering plant is loaded into a ‘load-bin’ located outside the rendering plant. The load-in bin includes a lid, which is designed to contain material and prevent odour emissions. The lid opens automatically when the gate to the bin is opened for the unloading of material to it, and closes automatically when the gate closes following the completion of unloading.

The quality of material sourced from off-site is controlled by ensuring the pH of the material is kept at less than 6.5, and the temperature is maintained at less than 20 degrees prior to processing. This is currently a requirement of the existing resource consent (30096 – Condition 5.3).

The rendering plant processes meat, bone and offal in a cooker and separation equipment to produce dry meat meal and tallow, which is stored on site in heated tanks. Blood collected from on-site slaughtering is heat-coagulated and dewatered in the rendering plant, before being transported to another off-site facility for further processing.

Vapours from the rendering process are cooled by a heat exchanger and then discharged through a biofilter, which treats the odours. Condensates from the heat exchanger are discharged to the effluent treatment system, along with blood liquid from the blood processing operation.

4.2.3 Waste Treatment Facility

The processing plant includes its own waste treatment facility which uses a combination of methods to remove solids and treat effluent before it is discharged to the Kaituna River in accordance with a separate Bay of Plenty Regional Council consent (Resource Consent 24932). The waste treatment process is described in detail within Section 2.4 of the AEE (from page 9) and is depicted in Figures 4 and 8 of the AEE (pages 5 and 10, respectively).

In summary, effluent from the processing plant receives primary treatment by screening, dissolved air flotation or sedimentation (or combinations of these methods). The recovered solids may be rendered in the rendering plant, or stabilised and detwatered in a stabilisation area. Wastewater is then biologically treated in anaerobic ponds, oxidation ponds and wetlands prior to being discharged to the Kaituna River.

The solids pits are used for storage and treatment of animal waste as part of the primary treatment process. The pits form thick floating crusts, which act to reduce the quantity of solids and produce gases that keep the crust afloat. Excess solids are removed and deposited in the ‘stabilisation area’ when the pits become full.

Stockyard pits are generally emptied once a year in summer, however, the frequency can increase to four times a year when the site is more productive than it is currently. The ‘save-all’ solids pits are usually emptied at the same time as the stockyard pits, however, they are not emptied as frequently.

The dry solids pit receives floatable fats and beef paunch. The application states that due to the relatively low volume of material deposited in this pit, there is no effluent discharge from this pit. Lime is applied to material in the pit to control odour. Solids are removed from this pit periodically, and again this is usually at the same time as the removal of solids from the stock pits.

The solids stabilisation area is located to the north of the anaerobic ponds (as shown in Figure 3 in the AEE). Solids are deposited in this area from the solids pits and allowed to dry out. Stockpiles of older material are kept nearby and spread over the new solids to control odour, if required.

The ‘save-all’ is a sedimentation tank which pre-treats all of the site’s wastewater (except backwash water) before it is discharged into the anaerobic ponds. Solids are removed from the tank and either rendered or deposited in the dry solids pit.

Effluent from the ‘save-all’ sedimentation tank discharges to three anaerobic ponds operated in a series. Anaerobic Pond 1 is the first in the series receives the highest organic loading and has the highest potential to generate odour. Anaerobic Ponds 1 and 2 have crusts of approximately 1m and 0.3m thick, respectively. The AEE states that organic loading in Anaerobic Pond 3 is insufficient to sustain a complete crust.

Following treatment in the anaerobic ponds, effluent is discharged to the oxidation ponds, which were constructed in 2004. The final step in the treatment process is the treatment of effluent in the wetlands, which act to reduce contaminants levels in the wastewater before being discharged to the Kaituna River.

4.3 Consent Conditions

The applicant proposes that the majority of the conditions within the existing resource consent be retained. Some changes are proposed by the Applicant, however, and these include:

(a) Amending condition 5.3 of 30096 to allow for an alternative preservative, such as chlorine dioxide;

(b) Deleting condition 5.4 of 30096, as the applicant states no stickwater is stored on-site and therefore the condition is not necessary;

(d) Deleting condition 6.5, of 30096 which relates to the commissioning of a report into the efficiency of the bio-filter process that existed at the time the consent was assessed in 2002. This condition is no longer considered relevant as a new bio-filter was installed in 2007.

4.4 Reasons for Resource Consent

The following activities require consent:

(a) Under section 15(1)(c) of the Resource Management Act1991 and Rule 19(b) of the Bay of Plenty Regional Air Plan being a discretionary activity to discharge contaminants to air from an animal rendering and by-product processing plant;

(b) Under section 15(1)(c) of the Resource Management Act1991 and Rule 19(w)(ii) of the Bay of Plenty Regional Air Plan being a discretionary activity to discharge contaminants to air from commercial treatment and disposal of waste.

It is noted, for completeness, that the discharge of contaminants to air from the gas fired boilers is a permitted activity in accordance with Rule 4(2) of the Bay of Plenty Regional Air Plan. In accordance the ‘bundling’ principle, however, the application has been assessed under the most restrictive activity status, being a ‘discretionary’ activity.

Section 104B of the RMA allows a consent authority to grant or refuse applications for discretionary activities. If resource consent is granted, conditions may be imposed under section 108 of the Resource Management Act (RMA).

4.5 Other Consents and Approvals Required

I am not aware of any other approvals required for the discharges to air. As identified earlier, however, the processing plant operates under a number of resource consents which enable various discharges to land and water associated with the plant.

4.6 Timeframes

Application Received: / 20 June 2012
Section 95 Letter Issued: / 3 July 2012
Limited Notification: / 12 July 2012
Period for Submissions Closed: / 10 August 2012
Timeframes extended (s37)[1]: / 16 August 2012
Draft Conditions Sent to Applicant for Comment: / 27 August 2012 & 17 September 2012
Timeframes extended (s37)[2]: / 3 October 2012
Hearing Commencement: / 20 November 2012

4.7 Technical Review

To assist in the assessment of the application, the application was reviewed by Mr Shane Iremonger, an Environmental Scientist at the Regional Council who specialises in air quality matters. The primary purpose of this process was to undertake a technical audit of the application for completeness and scientific robustness, to assess the environmental effects of the discharges to air, and to provide expert advice on specific aspects of the proposal.

Input has also been sought from Mr Iremonger and Mr David Ede (Pollution Prevention Officer at the Regional Council) regarding recommended conditions of consent.