AUTH-20158595-02
Cnr North Road and Pr
ice Street
(Private Ba g 90116
DX Y
X 20175)
In
vercargill
Discharge Permit
Telephone (03) 211 5115
Fax No. (03) 211 5252
Southland Freephone No. 0800 76 88 45
Pursuant to Section 104B of the Resource Management Act 1991, a resource consent is hereby
granted by the Southland Regional Council to
Alliance Group Limited of
PO Box 845,
Invercargill 9840 from
30 November 2016
Please read this Consent carefully, and ensure that any staff or
contractors carrying out activities under this Consent on your behalf
are aware of all the conditions of the Consent.
Details of Permit
Purpose for which permit is granted:
To discharge contaminants to air for the purpose of
operating a meat processing and export plant and
associated activities and all other on-site activities
including the disposal of waste.
Location - site locality
Lorneville
- map reference
NZTM2000 1237821E 4856201N
Expiry date:
30 November 2041
History of Changes and Transfers:
Consent corrected on 23 December 2016
Schedule of Conditions
General Conditions
1.
Subject to complying with the conditions of this consent, the activities authorised by this
consent shall be undertaken so as to be consistent with the application for this consent and
the documents entitled:
(a) Assessment of Environmental Effects dated November 2015
Environment Southland is the brand name of
the Southland Regional Council
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(b) Technical Reports:
(i)
Appendix E - Background Ambient Air Quality Report – Golder Associates
(ii) Appendix F – Baseline Odour Survey – Golder Associates
(iii) Appendix G – Process Odour Mitigation – Golder Associates
(iv) Appendix M – Coal Fired Boiler Assessment – Golder Associates
(v) Appendix R – Wastewater Treatment Odour Mitigation – Golder Associates
(vi) Appendix U – Draft Air Quality Discharge Management Plan
2.
Any incident causing abnormal and/or excessive emissions to the atmosphere, including
odour, shall be abated as soon as is reasonably practicable. On becoming aware of such an
incident, the Consent Holder shall immediately advise the Consent Authority and follow up
with a written report on the cause, and the actions taken to prevent a recurrence.
3.
Trade wastes may be burnt in the existing concrete lined area designated for this purpose.
The wastes to be burned shall be limited to wood or paper waste and shall specifically
exclude copper-chromium-arsenic (CCA) treated timber and painted timber. There shall be
no other open air burning of trade waste on the premises.
General Requirements – Certification of Management and Monitoring Plans
4.
In carrying out its functions in relation the certification process associated with any
management or monitoring plan required by the conditions, the Consent Authority shall be
satisfied that the plan meets the purpose stated within the relevant condition. The Consent
Authority shall complete its certification within twenty working days of receipt of the
management or monitoring plan. In the event of any dispute, disagreement or inaction
arising as to any certification of any plan required by the conditions, or as to the
implementation of, or monitoring required by the conditions, matters shall be referred in
the first instance to the Consents Manager determine a process for resolution of the
dispute, disagreement or inaction.
5.
If a resolution cannot be agreed within ten working days of any dispute, disagreement or
inaction arising, the matter may be referred to an independent appropriately qualified
expert, acceptable to both parties, setting out the details of the matter to be referred for
determination and the reasons the parties do not agree.
6.
The qualified expert shall be appointed within five working days of the Consent Holder or
the Consent Authority giving notice of their intention to seek expert determination. The
expert shall issue a decision on the matter within fifteen working days.
7.
The decision of the qualified expert is binding on the Consent Holder and shall be
implemented.
8.
The dispute resolution process above shall be applied before any formal enforcement
action is taken by the Consent Authority.
Management Plan
9.
No later than three months after the commencement of this consent, the Consent Holder
shall prepare and submit to the Consent Authority an Air Discharge Management Plan.
The purpose of the Air Discharge Management Plan shall be to ensure that any adverse
effects from the air discharges authorised by this consent are avoided, remedied or
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mitigated and that the discharges are appropriately monitored for compliance purposes.
The Air Discharge Management Plan shall contain, but not be limited to:
(a) A description of the air discharges arising from onsite activities and processes
including:
(i)
Boiler operations and emissions requirements;
(ii) Rendering plant operating requirements;
(iii) Odour management;
(iv) Methods to manage the effects of the air discharges including particulate
emissions and odours.
(b) Monitoring and reporting requirements.
The Air Discharge Management Plan shall be reviewed at least annually. The purpose of
this review shall be to confirm that it accurately reflects on-site activities and operations
and to identify if changes to management procedures contained within the Air Discharge
Management Plan are required. The results of the review shall be reported to the Consent
Authority within twenty working days of the review being undertaken. If the review results
in amendments to the Air Discharge Management Plan, the amended sections shall be
provided to the Consent Authority for certification at this time.
This permit shall be exercised in accordance with the Air Discharge Management Plan at all
times. Where there is inconsistency between the Air Discharge Management Plan and the
conditions of this consent, the conditions of this consent shall prevail.
Boiler Operating and Emission Requirements
10. The height of the stacks above surrounding ground level shall not be less than:
(a) 30.9 m for the Babcock and Wilcox boiler;
(b) 34.1 m for the Foster-Wheeler boiler.
11. (a) The sulphur content of fuel used for the boilers shall not exceed 0.5 wt% (as-
received), based on the results of the following testing:
(i)
A grab sample of the supplied coal for the boilers shall be collected at least
once per week and sent to an IANZ accredited laboratory for analysis for
combustible sulphur as percent by weight of coal both on an as-received and
dry basis.
(ii) If the coal source changes then a representative analysis of the sulphur content
shall be carried out to confirm compliance with the 0.5 wt% limit before the
new coal source is accepted.
(iii) The preparation of a monthly monitoring report which shall summarise grab
sample test results including a comparison with the limit specified in this
condition. A copy of this report shall be submitted to the Consent Authority
each month upon completion.
12. The discharge from the boiler stacks shall be directed vertically into the air and shall not be
impeded by any obstruction that could impede the vertical efflux velocity.
13. The opacity of smoke discharged from any boiler shall not exceed Ringelmann Shade 1 as
described in New Zealand Standard 5201:1973 except:
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(a)
for 60 minutes when lighting a boiler after a shutdown period of up to eight hours;
or
(b) for four hours when lighting a boiler after a shutdown period of longer than eight
hours; and
(c)
at any other time, to allow for cleaning the fires and manual soot blowing of the
boilers, for periods not exceeding two minutes at a time and not exceeding five
minutes in any period of 60 minutes.
14. The Consent Holder shall install industry standard opacity meters within the boiler
discharge stacks, using either light extinction or light scattering based technologies. The
system shall be installed within eight months of the commencement of this consent and
enable percentage opacity of the two boilers exhaust to be recorded and displayed to boiler
operator staff.
15. The storage of coal and ash shall be managed so that there is no visible emission of coal
and ash dust beyond the boundary of the site.
16. The coal fired boiler(s) used on the site shall be serviced at least once every year and the
servicing shall be supervised by a person competent in servicing of such boilers. This
servicing shall include:
(a) Internal cleaning and replacement or repair of damaged equipment and services as
necessary;
(b) Adjustment of the air to fuel ratio to optimise energy efficiency and to minimise the
emission of products of incomplete combustion; and
(c) Calibration and adjustment of boiler monitoring equipment consistent with the
monitoring obligations of this consent.
Servicing reports shall be prepared following each servicing event. Confirmation that this
servicing has been undertaken, and a copy of the servicing report shall be supplied to the
Consent Authority by 30 November each year.
17. (a) The exhaust air from the two coal fired boilers shall have a flow weighted PM10
concentration of 300 mg/Nm3 at standard atmospheric pressure and temperature
(STP) corrected to 12 vol.% CO2 and dry, which equates to a maximum PM10 mass
rate of 21.4 kg/hr.
(b) By no later than three years from the first exercise of this consent, and thereafter the
flow weighted PM10 concentration from the two coal fired boilers shall not exceed
250 mg/Nm3 at STP corrected to 12 vol.% CO2 and dry, which equates to a
maximum PM10 mass rate of 17.8 kg/hr.
For the avoidance of doubt, in the event that any review, required to be undertaken in
accordance with Conditions 22 - 25, results in a requirement for the Consent Holder to
achieve a more restrictive discharge standard for PM10 or any other determinand (e.g.
PM2.5), then that discharge standard shall supersede and replace clause (b) of this
condition.
Monitoring
17A. The concentration of PM10 in the combustion gas in each of the boiler stacks shall be
measured at least once every 12 months for the duration of this consent. Measurement
shall occur when the tested boiler is being operated at a rate of at least 75% of its
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maximum continuous rating. The method of sampling and analysis for PM10 shall be
USEPA Methods 201A and 202 or an equivalent method approved in writing by the
Consent Authority. The testing time shall be at least two hours continuous, within which at
least three samples shall be collected. Testing and analysis of samples shall be carried out by
an organisation and laboratory accredited by International Accreditation New Zealand
(IANZ) for the tests and analyses involved. The results of the emission test, including
comparison to the concentration and mass emission limits in Condition 17, shall be
provided to the Consent Authority within 40 working days of the test being completed.
For the avoidance of doubt, any stack testing that may be required to be undertaken in
accordance with Condition 19 (where ambient air quality limits are exceeded) may be used
as fulfilment of the annual stack testing required by this condition.
18. The Consent Holder shall undertake continuous monitoring and logging of ambient 1-hour
and 24-hourly average respirable particulate (PM10 and PM2.5) concentrations in conjunction
with wind speed and direction. The monitoring location shall be as close as practical to
New Zealand Transverse Mercator coordinates (NZTM) 1240.240, 4856.670 (Eastings and
Northings in kilometres (km)) being a site nearby the dwelling at 237 Steel Road. The
monitoring campaign shall commence either before or by 1 December after the
commencement of this consent and operate all year round.
Specific features of the methodology shall include:
(a) The ambient PM10 and PM2.5 monitoring shall be by Beta Attenuation Monitor
(BAM) in accordance with AS/NZ 3580.9.11:2008 ‘
Determination of suspended particulate
matter - PM10 beta attenuation monitors’ or equivalent semi-continuous method. The
sampling height shall be 3 metres above ground level.
(b) Concurrent monitoring of wind speed and direction at the monitoring site and
logging of 10 minute and hourly averaged data at the same site as the ambient
monitoring. Wind speed and direction shall be monitored using industry standard
meteorological monitoring instrumentation that is attached to a mast at a height of 6
metres above ground level. Specifically the wind direction and speed monitoring
equipment shall meet the following specifications:
Wind Speed Instrumentation:
Range: 0 to ≥ 30m/s
Accuracy: ≤ ±5% @ 3 m/s
Resolution: ≤ 0.1 m/s
Response Time: ≤ 1 second
Wind Speed Threshold: ≤ 0.5 m/s
Wind Direction Instrumentation:
Range: 0-359º
Accuracy: ≤ ±5% @ 3 m/s
Resolution: 1º
Response Time: ≤ 1 second
Wind Speed Threshold: ≤ 0.5 m/s
(c) Ambient PM10 and PM2.5 concentrations in micrograms per cubic metre shall be
recorded in electronic form as 1-hour and 24-hour averages (midnight to midnight).
Wind speed in metres per second, and wind direction in degrees clockwise of true
north, shall be recorded in electronic form as 1-hour and 10 minute averages.
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(d) The Consent Holder shall report the hourly PM10 and PM2.5 concentration
measurements that occur when the monitoring site is downwind of the boiler stacks.
This includes 1-hour average wind directions that are between 245 and 270 degrees
from true north (or whichever directions are within 13 degrees of the direction
bearing between the monitor sample point and the boiler stacks). The Consent
Holder shall also report all 24-hour PM10 concentration measurements.
(e) From the downwind ambient 1-hour PM10 results, the Consent Holder shall report
the maximum, 95th and 50th percentile values (ie. X, Y, Z indicated in Table 1,
respectively). The maximum and 95th percentiles (X and Y) shall meet their
respective PM10 concentration percentile limits listed in Table 1. These are
appropriate limits that relate to the applicable coal-fired boiler stack PM10 discharge
limits of 300 mg/Nm3 and 250 mg/Nm3 (at 12 vol.% CO2 and dry STP condition).
The applicable stack discharge limit for PM10 is defined in Condition 17.
Table 1: Ambient Pm10 Percentile Limits for Off-Site Monitoring
Hourly
Monitored hourly PM10 Ambient PM10 (µg/m3)
Ambient PM10 (µg/m3)
Downwind PM10
(µg/m3), downwind
limits for stack
limits for stack
Percentile
conditions
concentration of 300
concentration of 250
mg/m3 (applicable for
mg/m3 (applicable for
up to the first three
the period post the first
years of the consent)
three years of the
consent)
100%
x
122
117
95%
y
37
35
50%
z
18
17
19. (a) Should the monitoring and reporting of hourly downwind ambient PM10 percentiles
undertaken in accordance with Condition 18 identify that either of the appropriate
95th and/or the 100th percentile PM10 limits listed in Table 1 of Condition 18(e),
are
exceeded by 2 μg/m3, or more, then testing of PM10 discharges from the boiler stacks
using US EPA Methods 201A and 202 (or equivalent methods agreed with the
Consent Authority) shall be undertaken no later than two months post the
exceedance.
(b) Should the monitoring and reporting of 24-hour ambient PM10 concentrations
undertaken in accordance with condition 18 identify any exceedance of a trigger
value of 42 μg/m3, then testing of PM10 discharges from the boiler stacks using
US EPA Methods 201A and 202 (or equivalent methods agreed with the Consent
Authority) shall be undertaken no later than two months post the exceedance. This
requirement for stack testing shall not apply in circumstances where the ambient
monitoring and wind direction data indicate that the 24-hour trigger exceedance was
likely to be caused by abnormally high background PM10 concentrations caused by
emission sources not controlled by the Consent Holder. In these circumstances the
supporting data shall be submitted to the Consent Authority and agreement obtained
in writing from the Consent Authority that the additional stack testing is not
required.
20. The results of the stack testing undertaken in accordance with Condition 19, and
completed ambient monitoring for the concurrent period undertaken in accordance with
Condition 18 shall be reported to the Consent Authority within
30 working days of its
completion. If the monitoring determines that the operation of the boilers is likely to have
caused or contributed to an exceedance of the ambient limits set out in Condition 18(e)
this report shall also identify the likely cause and remedial actions that are necessary to be
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undertaken in order to prevent such exceedances occurring again, and the appropriate
timeframe for implementation. The Consent Authority may, at the Consent Holder’s
expense, engage a suitably qualified person to review the report and shall subsequently
confirm in writing the necessary remedial actions and the timeframe for those actions. The
Consent Holder shall implement the required action specified in writing by the Consent
Authority in accordance with the specified timeframes.
Reporting and Review
21. By 30 November each year, the Consent Holder shall provide a monitoring report to the
Consent Authority that summarises the monitoring results for the 12 month period ending
on 30 September of the previous year, which shall include the following:
(a) Electronic data set containing the time series of monitored hourly PM10 and PM2.5,
wind speed and wind direction;
(b) Table containing the monitored results versus PM10 percentiles;
(c) Time series plot of monitored 24-hour average PM10 and comparison with a trigger
value of 42 μg/m3 and the National Environmental Standard criterion for 24-hour
PM10; and
(d) Results of any stack discharge testing carried out.
22. No later than five years from the consent commencing and at five yearly intervals
thereafter, the Consent Holder shall conduct a review of:
(a) The results of the monitoring required by the conditions of this consent;
(b) Relevant guidelines or standards for discharges to air applicable at the date of the
review; and
(c) Available technology for the control of emissions to air from the discharge sources at
the site.
(d) The current and relevant health related science to confirm the best practicable option
(as defined in section 2 of the Resource Management Act 1991) for the control of
emissions to air from the discharge sources at the site.
23. The reviews required by Condition 22 shall identify if there is a need to implement
additional methods for controlling the effects of the emissions at the site to ensure
adherence to best practicable option obligations. The review shall detail any additional
emissions control technology that is necessary, a programme of procurement and
implementation associated with any required additional emissions control technology and
the predicted emissions reduction that is likely to accrue from the implementation of this
technology.
24. A report detailing the reviews required by Condition 22 shall be provided to a suitably
qualified, independent air quality expert (or experts) for verification that the review has
been undertaken in accordance with achieving the best practicable option for controlling
emissions. The suitably qualified, independent air quality expert (or experts) shall be a
person (or people) agreed to by the Consent Authority in writing before their engagement
by the Consent Holder. The results of the review, and the advice received from the
independent air quality expert (or experts)shall be reported to the Consent Authority for
certification that the requirements of Condition 23 have been met. This report (or
reports)shall be submitted to the Consent Authority immediately upon completion of the
review(s). The Consent Holder’s obligations to undertake each review and the associated
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reporting process shall be completed not more than three months after each review is
initiated.
25. The Consent Holder shall implement any recommended emissions control measures in
accordance with the procurement and implementation programme set out within the
certified report. Within three months of commissioning any required emissions control
measures the Consent Holder shall provide a report to the Consent Authority that
confirms that the work has been completed and which details future monitoring
requirements and expected emissions performance standards. The Consent Holder shall
meet these monitoring requirements and emissions performance standards for the
remainder of the term of this consent.
Rendering Plant Operating Requirements
26. Other than slink carcases or dead stock seasonally in the spring (fallen stock), only fresh or
suitably stabilised material shall be processed in the rendering plant. This includes material
from offsite sources. Slink carcases or fallen stock shall be processed as soon as practicable
after arrival at Lorneville Plant.
Note:
For the purposes of Condition 26:
1) “Fresh” means; for material derived from the slaughter and dressing of stock, no older than 24
hours from the time of slaughter; for chilled or frozen materials derived from the cutting, boning, or
further processing operations, no older than 24 hours from the time of delivery to the rendering
department.
2) “Stabilised” means stabilised by a recognised method which may include acid stabilisation or the use
of proprietary stabilisation agents applied at manufacturer’s recommended dose. Stabilisation should
occur as soon as is practicable but shall be no later than 8 hours from the time of slaughter or 8
hours from the removal of the animal carcase from a chilled facility.
27. Material shall not be left in an uncooked or partially cooked condition overnight in the
rendering processing line.
28. No blood older than 48 hours shall be processed.
29. The Consent Holder shall ensure that an odour control system is installed and functional
with respect to the rendering plant activities at all times. The odour control system shall be
operated according to an assigned set of protocols which set out:
(a) A description of the odour extraction, cooling and biofilter systems;
(b) A description of the operating parameters, the target values, methods and frequency
and location of odour control systems;
(c) Performance monitoring procedures for the odour control systems including daily,
weekly, monthly and annual observations and monitoring that is required; and
(d) Methods for managing the biofilter which includes operational parameters and
monitoring obligations.
30. The protocols for managing the biofilter prepared in accordance with Condition 29(d) shall
ensure that the biofilter associated with the rendering plant is operated and maintained to
an appropriate standard to minimise odour effects. The following parameters shall be
monitored at the frequencies specified:
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(a) Daily visual observations of the state of the biofilter bed, particular for short
circuiting and clogging of the bed;
(b) Continuous monitoring of the inlet temperature;
(c) Weekly monitoring of pressure drop across the biofilter bed;
(d) Monthly monitoring of biofilter bed moisture content; and
(e) Monthly monitoring of biofilter bed pH.
31. The inlet gas temperature to the biofilter shall be maintained at less than 40oC at least 99%
of the time.
32. Floors, conveyors, and other equipment shall be kept free of accumulations of raw material
which may putrefy and generate odours.
33. The Consent Holder shall have in place a contingency plan of actions that shall be
implemented in the event that the rendering plant is inoperative due to equipment failure.
A copy of this contingency plan shall be provided to the Consent Authority within three
months of the first exercise of this consent. If the contingency plan is changed or updated
to reflect a change in operational practices a copy of the revised plan shall be submitted to
the Consent Authority within one month of the change or update being made.
Odour Management
34. The Consent Holder shall ensure that its activities, including the rendering plant and
wastewater treatment facility, are operated in such a way as to ensure that there are no
odour discharges to air that are noxious, dangerous, offensive or objectionable to the
extent that it causes an adverse effect at or beyond the boundary of the site in the opinion
of an officer of the Consent Authority.
35. Following any non-compliance with Condition 34 being identified, the Consent Holder
shall immediately advise the Consent Authority and follow up with an investigation of the
likely source of the odour and shall as soon as practicable prepare a report identifying the
source and the methods to be implemented to reduce or properly manage the odour. The
report shall be submitted to the Consent Authority. The methods set out within the report
shall be implemented by the Consent Holder.
36. The Consent Holder shall keep a log of all odour complaints, which shall include:
(a) The location where the odour was detected by the complainant;
(b) The date and time when the odour was detected;
(c) A description of the odour character, intensity and duration of exposure;
(d) The most likely cause of the odour detected;
(e) Note if there were any abnormal activities at or discharges from the Plant that may
have resulted in the complaint; and
(f)
Weather conditions at the time of the complaint.
This log shall be provided to the Consent Authority upon request.
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37. No later than five years from the consent commencing and as required by Condition 14 of
consent AUTH-20158595-01 (discharge of treated wastewater to water), the Consent
Holder shall prepare and submit to the Consent Authority a Wastewater Treatment Plant
Upgrade Plan. This Plan shall address measures to manage odour from the Wastewater
Treatment Plant Upgrade, including the proposed disposal of dewatered biosolids. The
objective of this part of the plan shall be to ensure that any adverse effects on sensitive
receptors arising from discharges from the existing Wastewater Treatment Plant and the
upgraded Wastewater Treatment Plant are appropriately avoided, remedied or mitigated.
This part of the plan shall:
(a) Identify appropriate methods that will be undertaken as part of the overall plant
upgrade in order to reduce fugitive odour emissions from the existing wastewater
treatment system. This shall include but not be limited to the segregation of pickle
liquors and oxidation of sulphides within the waste lime wash liquors.
(b) Identify appropriate methods that will be undertaken as part of the overall plant
upgrade in order to manage and minimise fugitive odour emissions from the
upgraded treatment plant. This shall include but not be limited to:
(i)
A description of the potential sources of odour associated with the Wastewater
Treatment Plant Upgrade;
(ii) Methods to manage or minimise odours arising from the Wastewater
Treatment Plant Upgrade including the storage and application of biosolids
and design and management of the monofill sites;
(iii) Ongoing monitoring of the Wastewater Treatment Plant Upgrade with respect
to potential odour sources and reporting requirements.
38. The Consent Holder shall be required to implement the measures contained within the
Wastewater Treatment Plant Upgrade Plan.
39. Once the upgraded wastewater system has been commissioned in accordance with consent
AUTH-20158595-06, and has been fully operational for twelve months, the Consent
Holder shall be required to undertake a review of the effectiveness of the relevant odour
measures and methods contained within the Wastewater Treatment Plant Upgrade Plan
and provide a report to the Consent Authority. Should the report identify that any changes
are necessary these shall be implemented in agreement with Consent Authority within three
months following receipt of the report.
40. The Consent Holder shall ensure that any new anaerobic lagoon(s) required as part of the
Wastewater Treatment Plant Upgrade Plan are to be constructed with a synthetic cover that
is designed to allow for the collection and storage of biogas. The Consent Holder shall
ensure that biogases emitted from the anaerobic lagoon are thermally combusted at all
times except under the following circumstances:
(a) in the event of a combustion equipment failure; or
(b) for combustion equipment maintenance purposes; or
(c) when adverse weather conditions prevent safe combustion equipment operation.
Where biogases are not thermally combusted then they shall be vented to a biofilter.
Review
41. The Consent Authority may, in accordance with section 128 of the Resource Management
Act 1991, serve notice on the Consent Holder of its intention to review the conditions of
this consent during the period 1 February to 30 September each year, or within
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two months of any enforcement action being taken by the Consent Authority in relation to
the exercise of this consent, or on receiving monitoring results, for the purposes of:
(a) determining whether the conditions of this permit are adequate to deal with any
adverse effects on the environment; or
(b) amending the monitoring programme to be undertaken; or
(d) adding or adjusting compliance limits; or
(e) requiring the Consent Holder to adopt the best practicable option to remove or
reduce any adverse effects; or
(f) requiring ambient monitoring of sulphur dioxide for a period of at least one year in
the event that there is a change to any national environmental standard (NES) or
ambient air quality guideline set by the New Zealand Government or the Southland
Regional Council that sets a guideline or standard for sulphur dioxide of less than or
equal to 50 µg/m3 (24 hour average); or
(g) requiring measures to reduce sulphur dioxide emissions from the coal fired boiler
plant to a level that is predicted to comply with the standard or air quality guideline
described in Condition 41(f).
Decision made by an independent panel of commissioners.
Reissued 23 December 2016 after correction to conditions 17A and 24
for the
Southland Regional Council
Michael Durand
Consents Manager
