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Australian Meat Group Pty Ltd 572 Temora Road, Cootamundra Fish Rendering: Odour Impact Assessment March 2020

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Page 1: Australian Meat Group Pty Ltd · Australian Meat now seek a development application for ongoing fish rendering at the site. This report aims to provide an air quality assessment in

Australian Meat Group Pty Ltd

572 Temora Road, Cootamundra

Fish Rendering: Odour Impact Assessment

March 2020

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Table of contents

Glossary of terms and abbreviations ........................................................................................................ 1

1. Introduction..................................................................................................................................... 2

1.1 Background .......................................................................................................................... 2

1.2 Purpose of this report........................................................................................................... 2

1.3 Existing EPL ......................................................................................................................... 2

1.4 Scope ................................................................................................................................... 3

1.5 Assumptions ........................................................................................................................ 3

1.6 Report structure ................................................................................................................... 3

1.7 Limitations ............................................................................................................................ 4

2. Existing environment and sensitive receptors................................................................................ 5

2.1 Site context .......................................................................................................................... 5

2.2 Existing air quality ................................................................................................................ 5

2.3 Nearby sensitive receptors .................................................................................................. 5

3. Assessment criteria ........................................................................................................................ 8

3.1 State legislation .................................................................................................................... 8

3.2 EPA criterion for odour......................................................................................................... 8

3.3 Adopted odour criteria........................................................................................................ 10

4. Meteorology ................................................................................................................................. 11

5. Odour assessment ....................................................................................................................... 13

5.1 Odour generating activities ................................................................................................ 13

5.2 Emissions inventory ........................................................................................................... 15

5.3 Dispersion modelling.......................................................................................................... 20

5.4 Predicted odour impacts .................................................................................................... 20

6. Management measures and best practice ................................................................................... 24

6.1 Site weather station ........................................................................................................... 24

6.2 Industry best practice ......................................................................................................... 24

7. Conclusions .................................................................................................................................. 26

8. References ................................................................................................................................... 27

Table index

Table 2-1 Location of identified sensitive receptors ............................................................................. 6

Table 3-1 Odour criterion for the assessment of odour (Approved Methods) ..................................... 9

Table 4-1 TAPM configuration ........................................................................................................... 11

Table 4-2 CALMET configuration ....................................................................................................... 12

Table 5-1 Emissions inventory ........................................................................................................... 19

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Table 5-2 Predicted peak (99th percentile, short term averaged) odour impact at nearby

receptors ............................................................................................................................ 21

Figure index Figure 1 Site location and identified sensitive receptors .................................................................... 7

Figure 2 Peak to mean ratios (from NSW Approved Methods) ....................................................... 10

Figure 3 CALMET generated wind rose at site – Annual (2014) ..................................................... 12

Figure 4 Rendering process diagram (SEMA, 2018) ....................................................................... 13

Figure 5 Site odour sources ............................................................................................................. 14

Figure 6 Predicted odour impacts (Existing operations), 99th percentile, short term

averaged (OU) ................................................................................................................... 22

Figure 7 Predicted odour impacts (Proposed operations – fish feedstock), 99th

percentile, short term averaged (OU) ................................................................................ 23

Appendices

Appendix A – The Odour Unit – November 2019

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Glossary of terms and abbreviations

Term/ Abbreviation Definition

AWS Automatic Weather Station

Background levels Existing concentrations of pollutants in the ambient air.

BoM Bureau of Meteorology

EPA NSW Environment Protection Authority

Far-field The far-field region is the zone where plume rise and meandering have

fully occurred and the plume is well mixed in the vertical plane from the

ground level to the base of the first temperature inversion.

MOER Mass odour emission rate

The total OER for each specific source of odour, determined by

multiplying the SOER by the area of each source.

Near-field The near-field is the zone where source structure directly affects plume

dispersion. The near field is typically 10 times the largest source

dimension, either height or width.

NPI National Pollutant Inventory

OER Odour emission rate

The odorant flow rate (odour emission rate) is the quantity of odorous substances passing through a defined area at each time unit. It is the product of the odour concentration, cod, the outlet velocity, v, and the outlet area, A, or the product of the odour concentration, cod, and the pertinent volume flow rate, V. Its unit is OU.m3/min or OU.m3/s.

Note: The odorant (emission) flow rate is the quantity equivalent to the emission mass or volume flow rate, for example in dispersion models.

OU Odour units; indicates concentration of odorous mixtures. The number

of odour units is the concentration of a sample divided by the odour

threshold or the number of dilutions required for the sample to reach

the threshold. This threshold is the numerical value equivalent to when

50% of a testing panel correctly detect an odour. For complex mixtures

of odours, odour is specified in OU/m3 (odour units per cubic metre) as

a noise-response-time average.

Peak-to-mean ratio A conversion factor that adjusts mean dispersion model predictions to

the peak concentrations perceived the human noise.

Sensitive receptor A location where people are likely to work or reside; this may include a

dwelling, school, hospital, office or public recreational area.

SOER Specific odour emission rate

The odour flux rate of the emitting surface, expressed as an emission rate per unit surface area (OER per square metre). Calculated by dividing the airflow through the chamber and the odour concentration of the exhaust air by the area covered by the chamber.

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1. Introduction

1.1 Background

GHD was engaged by Australian Meat Group Pty Ltd (Australian Meat) to undertake an odour

impact assessment (‘the project’) of the facility located at 572 Temora Road, Cootamundra (‘the

site’). The site was previously owned by Manildra Meat and possesses a rendering facility, an

abattoir and associated supporting infrastructure.

The existing approved uses of the site relate to lamb and cattle processing and rendering

activities. The proposed uses of the site include fish processing activities while normal livestock

processing operations are shut down.

1.2 Purpose of this report

This report aims to provide a comprehensive air quality assessment of potential impacts from

both existing (approved) and future (proposed) uses of the site.

This report describes the existing ambient environment, identified sensitive receptors, the

pollutant inventory of odorous emission sources associated with both existing and proposed

activities, predicted air quality impacts and potential management and mitigation measures to

reduce impacts.

1.2.1 Comparison to previous work

Previous air quality assessments were prepared by GHD to address specific issues raised by

the Cootamundra Gundagai Regional Council (Council) in correspondence with Manildra Meat

(the previous owner of the site) (dated 27 September, 2019).

As a result of these assessments, Council approved the fish rendering at the project site on 11

December, 2019. The approval was granted on a provisional (trial) basis for a period of three

months. Australian Meat now seek a development application for ongoing fish rendering at the

site.

This report aims to provide an air quality assessment in support of this development application.

GHD note that the modelling and results, as presented in this report, are unchanged from the

previous air quality assessment (as the odour sources remain unchanged from previous

assessments).

1.3 Existing EPL

The site operates under an existing environment protection license (EPL) (License number

3889, issued 1 May 2000), with license variations granted in 2010 and 2016.

The license relates to livestock processing scheduled activities involving rendering or fat

extraction and slaughtering or processing animals. The license also provides details of works

undertaken to date to minimise odour and air quality impacts from the site such as the

installation of equipment to improve wastewater quality (30 June 2003), works to control

emission of offensive odour from the waste water collection pit (30 August 2005) and rendering

plant improvements (11 March 2011).

Clause L3.1 of the existing license states that “No condition of this license identifies a potentially offensive odour for the purposes of section 129 of the Protection of the Environment Operations Act 1997”.

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1.4 Scope

GHD have undertaken the following scope of works:

Reviewed the information provided by Australian Meat and the study area surrounding the

site to identify and classify sensitive receptors, including an Odour Performance

Assessment prepared by The Odour Unit (TOU) dated 21 November 2019

Established relevant odour criteria for all sensitive receptors in line with the Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (Approved Methods) (EPA, 2016).

Prepared an emissions inventory of existing and proposed odour sources on site.

Undertaken a level 2 air quality assessment of odour in accordance with the Approved

Methods. Dispersion modelling was conducted in CALPUFF v5.8.

Prepared a summary of odour impacts at the nearest sensitive receptors and provided a

comparison against the relevant EPA criteria.

Recommended mitigation measures to comply with the odour criteria, if required.

1.5 Assumptions

The major assumptions used in this assessment are as follows:

The emission measurements undertaken by TOU are accurate and representative of fish

rendering operations on site, and do not vary significantly. Actual measurements are

dependent on site conditions at the time of measurement and these conditions may

change. GHD does not accept any responsibility for updating the measurements or

estimates made by TOU.

Emission measurements of lamb or cattle processing and rendering have not been

undertaken to date. GHD have reviewed emissions measurements undertaken by

Stephenson Environmental Management Australia (SEMA, 2018) during trial chicken

rendering operations and conducted literature reviews of emissions data from cattle

processing sites. This has been used to assign conservative emission values to assess

existing odour sources associated with these activities.

The odour dispersion modelling using the NSW EPA approved regulatory Gaussian puff

dispersion model CALPUFF v5, which was considered appropriate for the location.

Odour emissions from the major sources of odour were modelled as area sources in

CALPUFF with appropriate dispersion characteristics.

No site representative meteorological data exists. Therefore, a synthetic meteorological

data file for a representative modelling year was constructed using TAPM and CALMET.

Further details on the meteorological modelling are provided in Section 4.

1.6 Report structure

This report is structured as follows:

Section 2 - Describes the existing locality, air quality emission sources and nearby

sensitive receptors.

Section 3 - Provides the legislative context and applicable odour criteria.

Section 4 - Provides a summary of the meteorological data surrounding the site and used

in the modelling.

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Section 5 - Provides a summary of the site operations, emissions inventory and the results

of the odour dispersion modelling.

Section 6 - Outlines best practice odour management measures for emission sources on

site.

Section 7 - Outlines the limitations of the analyses and conclusions presented.

Section 8 - Lists the references used to prepare this assessment.

1.7 Limitations

This report: has been prepared by GHD for Australian Meat Group Pty Ltd and may only be used and relied on by Australian Meat Group Pty Ltd for the purpose agreed between GHD and the Australian Meat Group Pty Ltd as set out in section 1.4 of this report.

GHD otherwise disclaims responsibility to any person other than Australian Meat Group Pty Ltd arising in connection with this report. GHD also excludes implied warranties and conditions, to the extent legally permissible.

The services undertaken by GHD in connection with preparing this report were limited to those specifically detailed in the report and are subject to the scope limitations set out in the report.

The opinions, conclusions and any recommendations in this report are based on conditions encountered and information reviewed at the date of preparation of the report. GHD has no responsibility or obligation to update this report to account for events or changes occurring subsequent to the date that the report was prepared.

GHD has not been involved in the preparation of the planning submission and has had no contribution to, or review of the submission. GHD shall not be liable to any person for any error in, omission from, or false or misleading statement in, any other part of the submission.

The opinions, conclusions and any recommendations in this report are based on explicit assumptions made by GHD, described in this document, and limitations of the modelling software CALPUFF. GHD disclaims liability arising from any of the assumptions being incorrect. GHD has prepared this report on the basis of information provided by Australian Meat Group Pty Ltd and others who provided information to GHD (including Government authorities), which GHD has not independently verified or checked beyond the agreed scope of work. GHD does not accept liability in connection with such unverified information, including errors and omissions in the report which were caused by errors or omissions in that information.

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2. Existing environment and sensitive

receptors

2.1 Site context

The site is located at the corner of Old Cootamundra Road and Temora Road at 572 Temora

Road, Cootamundra, NSW (Lot 1, DP 611755). The township of Cootamundra lies

approximately 2 kilometres to the south of the site.

The site is surrounded by agricultural land uses and isolated, rural residences. The

Cootamundra Turf Club lies approximately 1.5 kilometres South-East of the site.

The location of the site within the broader locality is shown on Figure 1.

2.2 Existing air quality

EPA’s National Pollutant Inventory (NPI) was reviewed to identify existing sources of air quality

and odour pollutants in the broader locality.

Existing sources of air quality emissions were identified within the township of Cootamundra.

These include the Cootamundra Meter Station (Gas supply), Aero Refuellers Cootamundra

(Mineral, Metal and Chemical Wholesaling), Cootamundra Depot (Mineral, Metal and Chemical

Wholesaling) and Pacific National Cootamundra (Rail Freight Transport). Emissions from these

facilities are located outside the project study area.

The Australian Meat site is expected to be the dominant source of emissions in the study area.

These emissions include a mixture of volatile organic compounds (VOCs) emitted from the

rendering operations and the wastewater ponds.

Potential VOC emissions from site operations include organic sulphides, disulfides, C-4 to C-7

aldehydes, trimethylamine, C-4 amines, quinolone, dimethyl pyrazine, other pyrazines, and C-3

to C-6 organic acids. In addition, lesser amounts of C-4 to C-7 alcohols, ketones, aliphatic

hydrocarbons, and aromatic compounds are also potentially emitted (US EPA AP 42 9.5, 1995).

Individually, the detection threshold for these VOCs is low. The VOC mixture is likely to be

detected as odour at sensitive receptors.

No odour complaints have been received from the site over the past three years.

2.3 Nearby sensitive receptors

The Approved Methods define a sensitive receptor as “a location where people are likely to

work or reside; this may include a dwelling, school, hospital, office or public recreational area”.

The site is proximate to a number of rural homesteads and other sensitive receptors. The

nearest sensitive receptors are located between 115 to over 600 metres from the nearest site

odour sources. The sensitive receptors are labelled on Figure 1.

As part of their previous assessment for the site, Stephenson Environmental Management

Australia (SEMA, 2018) noted receptor R1 (receptor R7 in SEMA, refer to Figure 1) contained

greyhound kennels.

Further advice provided by Australian Meat indicates that receptor R1 has no residence or

business operating on it. The owners have some animals on the property (greyhounds and

sheep) and normally check up on the animals between 7-8 am and between 5-6 pm daily, not

onsite for more than 30 minutes during those time periods. Therefore, receptor R1 is not a

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location “where people are likely to work or reside” and has not been considered to be a

sensitive receptor with relevance to odour criteria.

The nearest sensitive receptors to the site have been included in the modelling and are listed in

Table 2-1, including the approximate distances and orientation of each receptor from the site.

The land use at the site and surrounding sensitive receptors is ‘RU1-Primary production’.

Table 2-1 Location of identified sensitive receptors

Receptor Lot, DP MGA55.

Easting (m) MGA55.

Northing (m) Nearest

odour source

Distance from nearest odour

source, m

Direction from site

R2 Lot 1,

DP793676 592652.4 6170259.0 Pond 1 485 NE

R3 Lot 2,

DP628945 591638.2 6170522.0 Press pit 600 NW

R4 Lot 12,

DP1204301 592516.6 6169387.9 Biofilter 680 SE

R5 Lot 4,

DP746100 592011.4 6169382.2 Biofilter 590 SW

R6 Lot 2,

DP746100 591929.1 6169455.3 Biofilter 540 SW

R7 Lot 3,

DP746100 591809.8 6169426.7

Rendering receivables

600 SW

R8 Lot 1,

DP746100 591770.3 6169511.5

Rendering receivables

550 SW

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COOTAMUNDRA LAKECARGELLIGO RAILWAY

RATH

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S LAN

E

OLD COOTAMUNDRA ROAD

RACECOURSE LANE

TEMORA STREET

BARANA ROAD

BERT

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ROA

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STOCKINBINGAL ROAD

R1

R2

R3

R4R5

R6R7

R8

FIGURE 1

0 0.075 0.15 0.225 0.3

Kilometers

Project No.Revision No. -

21-28243Date 08/05/2019

Map Projection: Transverse MercatorHorizontal Datum: GDA 1994Grid: GDA 1994 MGA Zone 55

Paper Size ISO A4

oData source: General topo data: NSW LPI. Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community. Created by: afoddyG:\21\28243\GIS\Maps\Deliverables\21_28243_Z001_SiteLocation.mxd

Print date: 08 May 2019 - 15:19

LegendProject site

!Sensitivereceptors

Australian Meat Group Pty Ltd 572 Temora Road, Cootamundra

Odour Impact Assessment

Site location and identifiedsensitive receptors

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3. Assessment criteria

3.1 State legislation

The Protection of the Environment Operations Act 1997 (POEO Act) provides the statutory

framework for managing pollution in NSW, including the procedures for issuing licences for

environmental protection on aspects such as waste, air, water and noise pollution control.

Activities undertaken onsite must not contribute to environmental degradation, and pollution and

air emissions must not exceed the standards.

Obligations under Section 129 of the POEO Act relate to emissions of odours from premises

licensed for scheduled activities and state the following:

(1) The occupier of any premises at which scheduled activities are carried on under the authority conferred by a licence must not cause or permit the emission of any offensive odour from the premises to which the licence applies.

(2) It is a defence in proceedings against a person for an offence against this section if the person establishes that:

(a) the emission is identified in the relevant environment protection licence as a potentially offensive odour and the odour was emitted in accordance with the conditions of the licence directed at minimising the odour, or

(b) the only persons affected by the odour were persons engaged in the management or operation of the premises.

(3) A person who contravenes this section is guilty of an offence.

Where offensive odour is defined as an odour:

(a) that, by reason of its strength, nature, duration, character or quality, or the time at which it is emitted, or any other circumstances:

(i) is harmful to (or is likely to be harmful to) a person who is outside the premises from which it is emitted, or

(ii) interferes unreasonably with (or is likely to interfere unreasonably with) the comfort or repose of a person who is outside the premises from which it is emitted, or

(b) that is of a strength, nature, duration, character or quality prescribed by the regulations or that is emitted at a time, or in other circumstances, prescribed by the regulations.

3.2 EPA criterion for odour

3.2.1 Odour units

Odour 'strength' or concentration is measured in odour units (OU), where 1 OU represents the

concentration of a sample that can just be detected by 50% of people in a controlled situation

where there is no background ‘ambient ‘ odour.

The most common method of measuring odour concentration is Dynamic Olfactometry using the

‘forced choice’ method. Dynamic olfactometry simply dilutes the odour sample in known ratios

with odour-free air. At each dilution, the diluted odour and a zero odour is presented in turn to

six panellists via two ‘sniffing’ ports. Further, the selection of the port with the diluted odour

sample is randomly reassigned at each presentation. Each panellist is required (forced) to

nominate the port (left or right) from which the diluted odour emanates. Each panellist’s

response (i.e. 'guess', 'likely' or 'certain') is recorded. The sequence of presentations generally

follows a decreasing dilution ratio, and when half of the panellists have correctly returned a

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‘certain’ response, that dilution ratio is numerically equal to the concentration of the original,

undiluted odour sample. Hence, for example, if the dilution needed to get the 50% response

was 250:1, then by definition the original sample had an odour concentration of 250 OU.

3.2.2 EPA criterion

Air quality (including odour) impact assessment criteria are prescribed by the Approved

Methods for the Modelling and Assessment of Air Pollutants in NSW (EPA, 2016) (known as

‘the Approved Methods’).

The Approved Methods specify how the criteria should be applied in dispersion modelling to

assess the likelihood of nuisance impact arising from the emission of odour. It should be noted

that odour impact is a subjective experience and has been found to depend on many factors,

the most important of which are:

The Frequency of the exposure

The Intensity of the odour

The Duration of the odour episodes

The Offensiveness of the odour

The Location of the source

These factors are often referred to as the FIDOL factors.

EPA defined the odour criterion to take account of two of these factors (F is set at 99 percentile,

I is set at from 2 to 7 OU). The choice of criterion odour level has also been made to be

dependent on the population of the affected area, and to some extent it could be said that

population is a surrogate for location – so that the L factor has also been considered. The

relationship between the criterion odour level C to affected population P is given below.

C = [log P-4.5]÷-0.6 Equation 1

Table 3-1 lists the values of C for various values of affected populations as obtained using

equation 1.

Table 3-1 Odour criterion for the assessment of odour (Approved Methods)

Population of affected community Odour performance criteria (nose response odour

certainty units at 99th percentile), OU

Single Residence (≤ ~2) 7

~ 10 6

~ 30 5

~ 125 4

~ 150 3

Urban (~2,000) 2

The NSW Approved Methods specifies a criterion of two odour units at the 99th percentile over

a short term averaging nose-response time of one second for a complex mixture of odorous air

pollutants in an urban area (population greater than 2000 or with schools and hospitals). The

criterion is applied at the location of the nearest sensitive receptor or likely future location of

sensitive receptors.

5 OU is commonly taken as a conservative measure of the odour level which can be

distinguished against the ambient background level of odour, and which if offensive, could result

in complaint.

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1 OU generally cannot be detected in a non-laboratory situation (i.e. where the ambient

background odour levels reduce the detectability of a given odorant).

Peak to mean ratios

As discussed above, the odour criterion specified in the Approved Methods are based on a

short term averaging noise-response time of one second.

The dispersion model utilised in this assessment is CALPUFF. CALPUFF is a

micrometeorological model that can only predict concentrations over an averaging period of one

hour. Therefore, a ratio between the one second peak concentration and 60 minute average

concentration is required to be applied to the source odour emission rates.

This ratio is known as the peak to mean ratio (PM60). PM60 is a function of source type,

stability category and range (i.e. near or far-field). The peak to mean ratios are specified in the

Approved Methods and reproduced below in Figure 2.

With the application of the peak to mean ratios, the predicted one hour odour levels predicted in

CALPUFF represent the corresponding one second short-term levels required to be compared

to the Approved Methods criterion.

Figure 2 Peak to mean ratios (from NSW Approved Methods)

3.3 Adopted odour criteria

The site is surrounded by a number of isolated sensitive receptors. The affected community has

been defined as the number of sensitive receptors experiencing an odour level of 2 OU or more.

Therefore, an odour criteria of 7 OU has been considered applicable for the study area.

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4. Meteorology

Site specific weather data was not available. The nearest weather station is located at Young

Airport (Station ID 73138), 48 kilometres North-East of the site.

The last complete five years (2013-2018) of weather data (wind speed, wind direction, rainfall,

temperature and relative humidity) at Young Airport was analysed to select a representative

meteorological modelling year.

2014 was chosen as the representative modelling year as:

2014 had the lowest overall deviation from the 5-yearly (2013-2018) distribution in the

meteorological parameters

2014 did not have an anomalously high or low rainfall amount

2014 did not have a strong or moderate ENSO classification (associated with la nino or el

nina events).

A 12 month synthetic meteorological dataset was constructed using the 3D prognostic modelling

package, The Air Pollution Model (TAPM). TAPM was developed by CSIRO and produces a

three-dimensional upper air data file of relevant meteorological parameters, including wind

speed, wind direction, temperature and pressure. TAPM also includes the ability to assimilate

actual wind observations from weather stations located in the broader area. However, due to the

distance between the project site and the nearest weather station, TAPM was run without

additional data assimilation.

The model settings used for the TAPM run are summarised in Table 4-1.

Table 4-1 TAPM configuration

TAPM parameter Value

TAPM version 4.0.4

Time period 1 January 2014 to 31 December 2014

Centre of analysis (MGA 55) (592075, 6170123)

Number of receptor grid points 25 x 25 x 25

Number of grids (and spacing) 4 nested grids (30 km, 10 km, 3 km, 1 km)

The upper air outputs from TAPM were fed into the diagnostic 3D meteorological model,

CALMET. CALMET is used to refine the wind field in the local study area, taking into account

the influences of topography, land uses and surface roughness. The final wind field produced

from CALMET is across a finer grid than used in TAPM.

CALMET modelling was undertaken using the ‘no observations’ (no-obs) approach and a

horizontal grid spacing of 300 metres. The CALMET configuration is summarised in Table 4-2.

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Table 4-2 CALMET configuration

CALMET parameter Value

Time period 1 January 2014 to 31 December 2014

Centre of analysis (MGA 55) (592075, 6170123)

Meteorological grid resolution 22.5 km by 22.5 km, 300 m

Vertical cell heights 12 (0 m, 20 m, 40 m, 60 m, 90 m, 120 m,

180 m, 250 m, 500 m, 1000 m, 2000 m, 3000

m)

Terrain radius of influence, TERRAD (km) 6

An annual wind rose generated using CALMET is provided in Figure 3 to show the wind field at

the centre of analysis. The following trends are evident from the wind rose and the wind data:

Annual average wind speed of 3.3 m/s

Very low percentage of calms (winds less than 0.5 m/s) - 1.4% of the year

Winds are most prevalent from the north, along the north-south axis due to valley

channelling flows in the area. The frequency of light winds (dark blue) is similar from the

north and south directions

Winds are least prevalent along the north-east to south-east directions

Figure 3 CALMET generated wind rose at site – Annual (2014)

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5. Odour assessment

5.1 Odour generating activities

Existing approved odour generating activities on site include lamb and cattle processing and

rendering, and the ponds used to process the waste water generated on site. Odour generated

from other activities undertaken on site is not expected to be significant.

The rendering operations are undertaken inside the enclosed rendering building and odorous

vapours are vented to the atmosphere via a vapour condenser and biofilter. Rendering involves

feeding a receivables bin with raw feedstock, which is then grinded and converted into fat

(and/or oils and other products). The rendering process diagram has been sourced from SEMA

(2018) and is reproduced in Figure 4.

Odour generating activities associated with rendering process include the receivables bin, the

press pit and biofilters. All odour sources (rendering and waste water ponds) are labelled on

Figure 5.

Both existing and future operations are anticipated to have the same major odour sources with

the key difference being the choice of the raw feedstock utilised in the rendering process. For

the existing operations, the raw feedstock is lamb and cattle, while for the future operations, the

raw feedstock will be fish (which is currently approved for a three month trial by Council).

Further details on the individual emission sources, including existing and proposed quantities of

raw feedstock, are provided in Section 5.2.

Figure 4 Rendering process diagram (SEMA, 2018)

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Pond 3

Pond 2

Pond 1

Biofilter

Press pit

COOTAMUNDRA LAKECARGELLIGO RAILWAY

OLD COOTAMUNDRA ROADSTOCKINBINGAL ROAD

FIGURE 5

0 0.025 0.05 0.075 0.1

Kilometers

Project No.Revision No. -

21-28243Date 08/05/2019

Map Projection: Transverse MercatorHorizontal Datum: GDA 1994Grid: GDA 1994 MGA Zone 55

Paper Size ISO A4

oData source: General topo data: NSW LPI. Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community. Created by: afoddyG:\21\28243\GIS\Maps\Deliverables\21_28243_Z002_SiteOdourSources.mxd

Print date: 08 May 2019 - 15:23

LegendProject site

OdourSources

Biofilter

Pond 1

Pond 2

Pond 3

Press pit

Australian Meat Group Pty Ltd 572 Temora Road, Cootamundra

Odour Impact Assessment

Site odour sources

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5.2 Emissions inventory

Significant existing and future odour sources from the site are expected to include the plant

associated with the rendering process and the waste water ponds. As discussed in Section 5.1,

this includes the following:

Render receivables bin

Press pit

Biofilter

Ponds 1, 2 and 3.

For existing approved (lamb/cattle processing and rendering) processing and rendering

activities, emission values have been derived from a literature review from measurements

undertaken on similar facilities and from previous measurements undertaken by SEMA (2018).

For proposed fish processing and rendering activities, measurements undertaken by The Odour

Unit (2019) during fish processing trials at the site have been used.

5.2.1 Render receivables inlet

The render receivables inlet is a metal bin located inside the rendering building. A roller door is

opened to allow raw material to be tipped from a truck directly into the bin. The door is then

closed. The entire process is expected to take approximately 30 minutes and will occur a

maximum of three to four times in a 24 hour period. The render receivables inlet will handle the

following:

For the existing approved operations, the site would normally process and render

approximately 4000 lambs and 200 cattle per day.

For the current trial and proposed permanent fish rendering operations, approximately 100

tonnes of fish per 24 hours (three to four trucks) will be processed. The fish will be fresh off

the fishing boat (fished daily) and will be kept refrigerated on the boat (2-5 degrees).

Currently, the fish are not refrigerated during transport. A significant increase in

temperature during transit has not been observed so far. If there are any material delays on

site before processing, the surplus fish will be placed in a cold storage under active

refrigeration.

The rendering building is maintained at negative pressure and all process gases are extracted

through the vapour condenser and the biofilter system.

Therefore, the render receivables inlet is not considered to be a significant odour source.

5.2.2 Biofilter

One rectangular biofilter is used to treat exhaust flows from the rendering building. The biofilter

is a 20 m by 12.5 m by 1.5 m (250 m2) concrete structure packed with a biologically active

medium (compost, tree bark, etc.). The odorous gases are absorbed and then broken down by

aerobic bacteria within the medium.

The outlet biofilter emissions depend on the inlet odour concentrations and the biofilter removal

efficiency. The adopted biofilter emission concentrations for various feedstock rendering inputs

are discussed below.

As part of Australian Meat’s commitment to minimise odour impacts, TOU undertook an

extensive review of the biofilter operations on site in July 2019. As a result of this review, the

biofilter media depth was increased from 0.9 metres to 1.5 metres. The existing media was also

replaced with new media as part of these upgrades.

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Lamb and cattle rendering

Measurements of biofilters undertaken at similar lamb and cattle rendering sites indicate a wide

range of emission concentrations, ranging from less than 200 OU to over 1000 OU.

For example, in their study for MLA, Katestone Environmental (2004) measured a biofilter inlet

sample of 2680 OU and a biofilter outlet sample of 710 OU with an odour removal efficiency of

73.5%. The measured samples were point samples and were for a “large abattoir and rendering facility”.

Similarly, measurements undertaken by Pacific Air & Environment (PAE) for the MLA in 2003

(PAE, 2003) evaluated the performance of a biofilter at the Australian Country Choice Cannon

Hill meat-processing site. The dimensions of the biofilter were 16 m (length) by 4 m (width) by 3

m (height) per module with four modules in total. Therefore, the total area of the biofilter was

approximately 256 m3 and comparable to the biofilter at Australian Meat. Measured outlet

biofilter odour concentrations ranged from 456 OU to 2080 OU, with odour removal efficiencies

ranging from 59% to 91%. PAE concluded that an “overall odour removal efficiency of approximately 83% can be assigned to the biofilter.”

Measurements commissioned as part of a GHD odour study of a beef processing facility in

Bomen measured odour concentrations of 140 to 370 OU. This was for a site processing

approximately 1100 cattle per day. Though, it should be noted that these measurements were

undertaken after significant maintenance and upgrade works at the site. Measurements

undertaken prior to maintenance and odour reducing upgrades indicated emission levels from

the biofilter of over 1600 OU.

SEMA (2018) measured biofilter concentrations of 600 OU during trial chicken rendering

operations.

Therefore, conservatively, an odour concentration of 2000 OU has been adopted for existing

approved lamb and cattle rendering operations. The odour concentration has been applied

across the entire biofilter area source (refer to Table 5-1).

Fish rendering

Australian Meat propose to utilise fresh fish as inputs into the rendering process. The MLA

Environmental best practice manual Odour (MLA, 2010) notes that the odour emissions of fresh

raw material receivables are typically lower than imported or aged receivables.

Measurements of trial fish rendering operations at the site were undertaken by The Odour Unit

in November 2019 post biofilter optimisation. The measurement report is attached in Appendix

A. The measurement results (when compared to SEMA 2018) confirm the effectiveness of the

modifications made to the biofilter.

These measurements indicate biofilter outlet concentrations of 59 to 64 OU. The maximum

measured odour concentration of 64 OU has been conservatively applied across the entire

biofilter area source (refer to Table 5-1).

5.2.3 Press pit

The press pit is used to remove water from the water-fat mixture extracted as part of the

rendering process. The press pit opening a small 21 m2 rectangular grill at ground level.

SEMA measured an odour concentration of 2900 OU during chicken rendering trial operations

on the site during 2018. The odour emissions from the press pit are assumed to be independent

of the raw feedstock used in the rendering process as the extracted water-fat mixture would be

of a similar composition for different feedstock.

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This odour concentration has been adopted for this assessment and applied across the press

pit area source for all rendering inputs (refer to Table 5-1).

5.2.4 Waste water ponds

The effluent pit and ponds accumulate the liquid waste from the abattoir slaughter and boning

operations as well as the rendering operations.

Process waste water from the site drains to sumps. Each sump has a submersible cutting style

pump. The water is then pumped to primary solids removal consisting of a screw press where

major solids are removed. Water gravity drains to another sump where it is collected and from

there pumped with a centrifugal pump to an anaerobic pond. Effluent passes through the

anaerobic pond to an aeration pond and finally to the settlement (storage) ponds.

Lamb and cattle rendering

Measurements were undertaken by SEMA for three wastewater ponds on site during trial

chicken rendering operations in 2018:

Ponds 2 and 3 were aerobic and settlement ponds with measured odour concentrations of

91 OU and 194 OU respectively

Pond 1 was an anaerobic pond with a dry/crusty surface and a measured odour

concentration of 1200 OU. It is noted that emissions to atmosphere from such ponds are

potentially high intensity odour and the emissions depend on the crust and underlying

characteristics of the pond.

Similar concentrations would be anticipated during the existing approved lamb and cattle

rendering operations. Therefore, all settlement ponds (Pond 2 and Pond 3) have been

conservatively modelled with an odour concentration of 194 OU.

For the anaerobic pond (Pond 1), an additional review of available literature was undertaken:

SLR cited measurements of two 1400 m2 anaerobic ponds as part of the odour assessment

for meat processing activities at 50 Tahmoor Road, Tahmoor (SLR, 2018). The measured

odour concentrations for the ponds were 1977 OU (Pond 1) and 451 OU (Pond 2)

Holmes Air Sciences undertook an odour assessment of odour sources around the Bomen

Industrial Estate in Wagga Wagga, NSW (Holmes Air Sciences, 2008). They cited a

measured odour concentration of 3113 OU for the anaerobic pond on site.

Based on the measurements undertaken by SEMA and the variability of values cited in the

literature, a moderately conservative odour concentration value of 2000 OU has been adopted

for the anaerobic pond for existing approved lamb and cattle rendering operations (refer to

Table 5-1).

Fish rendering

Measurements of the wastewater ponds during typical fish rendering operations at the site were

undertaken by The Odour Unit in November 2019. The measurements indicate the following:

Pond 1 (Anaerobic pond): Odour concentrations of 45 to 332 OU.

Pond 2 (Storage pond): Odour concentrations of 128 to 152 OU.

Pond 3 (Aerobic pond): Odour concentrations of 108 to 152 OU.

The storage and aerobic pond emissions are similar to those measured by SEMA (2018). The

anaerobic pond emissions are lower as extensive improvements were made to the pond

operations as part of Australian Meat’s commitment to odour reduction between July and

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November, 2019. The reduction in odour emission levels confirms the effectiveness of these

measures.

Conservatively, the modelling has been based on the highest measured odour concentrations

for each pond, applied across the pond area (refer to Table 5-1).

5.2.5 Emissions inventory summary

The final modelled emissions inventory, which includes existing operations and proposed fish

rendering operations is summarised in Table 5-1.

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Table 5-1 Emissions inventory

Source Model

ID

Source

type

Modelled odour

concentration, OU

Scaling method Hood flow

velocity1 (m/s)

Existing

operations

SOER,

OU

m3/m2/s

Fish

rendering

SOER,

OU

m3/m2/s

Area,

m2

Existing

operations

MOER2, OU

m3/s

Fish

rendering

MOER2,

OU m3/s Existing

operations

Fish

rendering

Pond 1

(Anaerobic) P001 Area 2,000 332

Isolation flux hood 0.00064

1.28 0.19 2,070 2,660 393

Pond 2

(Aerobic) P002 Area 194 152 0.12 0.089 3,250 405 289

Pond 3

(Storage) P003 Area 194 152 0.12 0.088 6,401 798 563

Press pit PPIT Area 2,900 2900 1.86 1.86 21 39 39

Biofilter BFIL1 Area 2,000 64

Static hood (SEMA, existing) and

based on measured flow rate (3.3

m3/s, TOU for fish)

0.0265 53.0 0.84 250 13,250 210

Total MOER 17,152 1,495

Note 1: For the isolation flux hood, this is calculated based on the US EPA standard flow rate of 5 L/min and an area of 0.13 m2 (corresponding to a hood diameter of 406.4

mm). For the static hood, this is calculated based on the witches hat hood discharge velocity of 0.0265 m/s and an area of 0.008 m2 (corresponding to a witches hat discharge

vent diameter of 100 mm).

Note 2: The modelling applied the following peak to mean ratios to the MOERs for the area sources: 2.5 (stability classes A, B, C and D) and 2.3 (stability classes E and F).

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5.3 Dispersion modelling

The odour dispersion modelling was conducted using the non steady state Gaussian puff model

CALPUFF Version 5.8. This model is a recognised regulatory model in NSW. CALPUFF is

especially suited for modelling light to calm wind conditions.

The following settings were used in the simulations:

Model: CALPUFF Version 5.8

The receptor grid was modelled at 150 m grid resolution

The receptors have been modelled at ground level

No elevated sources (such as stacks on buildings) are associated with the project. All

sources are ground based area sources. Therefore, building downwash affects have not

been considered in the modelling

Emissions were scaled based on a nose-response time for odour of one second, applying

a peak-to-mean ratio to the one hour average concentration. All receptors for the project

have been conservatively considered as near field.

Two modelling scenarios were run: Existing (approved) operations and Future operations (Fish

rendering).

5.4 Predicted odour impacts

Figure 6 to Figure 7 show the predicted 99th percentile odour impacts (one second nose-

response time) for the existing and proposed modelling scenarios.

Table 5-2 shows the predicted odour levels at all modelled receptors for all scenarios.

The results show that the odour concentrations are predicted to comply with the criteria for both

existing (approved) and proposed (permanent fish rendering) operations. Furthermore, the

odour levels are predicted to decrease when transitioning feedstock from existing (lamb/cattle)

to fish.

Odour management and best practice measures are discussed in Section 6 to minimise impacts

from the site.

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Table 5-2 Predicted peak (99th percentile, short term averaged) odour impact

at nearby receptors

Receptor Distance from nearest odour

source, m

To nearest odour source

Direction from site

Criteria, OU

Odour impact, OU, 99th percentile, nose-

response time

Existing (approved)

Fish (proposed)

R2 485 Pond 1 NE 7 2.5 0.6

R3 600 Press pit NW 7 0.7 0.3

R4 680 Biofilter SE 7 1.6 0.0

R5 590 Biofilter SW 7 1.5 0.1

R6 540 Biofilter SW 7 1.4 0.1

R7 600 Rendering receivables

SW 7 1.2 0.1

R8 550 Rendering receivables

SW 7 1.3 0.1

Note 1: R1 is not considered to be a sensitive receptor as per the discussion in Section 2.3

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!

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!!

!!

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COOT AMU N DR ALA K E

CARGEL L IGORA IL WAY

RATH

MELL

S LAN

E

OLD COOTAMUNDRA ROAD

RACECOURSE LANE

TEMORA STREET

BARANA ROAD

STOCKINBINGAL ROAD

BERTHONG ROAD

R1

R2

R3

R4R5

R6R7

R8

FIGURE 6

0 75 150 225 300

Metres

Project No.Revision No. -

21-28243Date 16/07/2019

Map Projection: Transverse MercatorHorizontal Datum: GDA 1994Grid: GDA 1994 MGA Zone 55

Paper Size ISO A4

oData source: General topo data: NSW LPI. Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community. Created by: ppandey

LegendProject site

OdourSources

Biofilter

Pond 1

Pond 2

Pond 3

Press pit

Odour unit,OU

2

5

10

15

20

Australian Meat Group Pty Ltd572 Temora Road, Cootamundra

Odour Impact AssessmentPredicted odour impacts

Existing operations99th percentile, short term averaged (OU)

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!

!

!

!!

!!

!

COOT AMU N DR ALA K E

CARGEL L IGORA IL WAY

RATH

MELL

S LAN

E

OLD COOTAMUNDRA ROAD

RACECOURSE LANE

TEMORA STREET

BARANA ROAD

STOCKINBINGAL ROAD

BERTHONG ROAD

R1

R2

R3

R4R5

R6R7

R8

FIGURE 7

0 75 150 225 300

Metres

Project No.Revision No. -

21-28243Date 26/11/2019

Map Projection: Transverse MercatorHorizontal Datum: GDA 1994Grid: GDA 1994 MGA Zone 55

Paper Size ISO A4

oData source: General topo data: NSW LPI. Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community. Created by: ppandey

LegendProject site

OdourSources

Biofilter

Pond 1

Pond 2

Pond 3

Press pit

Odour unit,OU

1

2

3

Australian Meat Group Pty Ltd572 Temora Road, Cootamundra

Odour Impact AssessmentPredicted odour impacts

Proposed operations (Fish feedstock)99th percentile, short term averaged (OU)

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6. Management measures and best

practice

The results of the odour modelling indicate that the predicted odour levels comply with the

criteria at all sensitive receptors during proposed fish rendering activities.

Australian Meat should aim to minimise potential offensive odour emissions from the site as per

the POEO Act and Technical framework: Assessment and management of odour from

stationary sources in NSW (DEC, 2006). In line with the Act and the odour emission sources on

site, the following best practice recommendations are made.

6.1 Site weather station

Currently, the weather station at the site is not capable of long term weather data logging. It is

recommended that the weather station should be upgraded to enable long term logging of (at a

minimum) wind speed, wind direction, temperature and relative humidity in 30 minute (or finer)

increments.

Long term data should be stored and kept for future reference in the event of potential odour

complaints.

6.2 Industry best practice

The MLA Environmental best practice manual Odour (MLA, 2010) recommends a number of

best practice measures to minimise odour emissions from meat processing facilities. These are

discussed below and compared against existing site practices.

Raw material receival ventilation

Recommendation: Fresh material received on site should be located within the rendering

building and be ventilated as part of the building ventilation system. The receivals area should

be designed to meet normal industrial ventilation criteria and receival bins should be vented to

the rendering odour capture and treatment system.

Existing site practices: The site receivals occurs within the rendering building. The rendering

building is kept closed except during receivals. All odour from the building is vented via the

biofilters. The procedure is deemed to generally follow industry best practice- though could be

further improved by ensuring that fugitive emissions do not result from the rendering building

during the receival unloading process.

Rendering building

Recommendation: Primary emission sources should be captured and treated through an odour

control system.

Rendering building should be fully enclosed, with all doorways normally closed, air inlets to

building via purpose designed louvres and appropriate air change rate to achieve both

satisfactory working conditions and removal of remnant steam and odour. For rendering rooms

where odour problems occur, 25-30 air exchanges/hour or more are recommended.

Existing site practices: All odour from the rendering building is vented to the biofilter.

Australian Meat have undertaken extensive optimisation of the biofilter to increase biofilter

performance and efficiency.

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Waste water management

Recommendation: Wastewater streams should be treated (primary and/or secondary) to

reduce coarse and suspended solids and fat concentrations prior to further treatment.

Equipment associated with treatment can include screens, screw presses, collection pits and

pumps. Additional best practice measures for wastewater management could include:

Minimising generation of hot vapours and odours

Removing all solids and fats recovered from the area, frequently

Adopting enclosed technologies (such as screw press)

Enclosing static or rotary screens

Minimising pit openings to the atmosphere

Ensuring the establishment of a strong and stable crust on anaerobic ponds with the only

penetration being a relatively small area around the wastewater inlet. The pond condition

should be monitoring for any areas of crust breakdown. Discharges from the pond into

downstream units should be submerged on entry.

Existing site practices: Treated wastewater is transferred to settlement ponds. Best practice

measures listed above should be considered to minimise odours from the anaerobic pond.

Australian Meat have recently undertaken an extensive review of wastewater systems onsite

and implemented measures to reduce the potential for odour impacts. These measures have

included increasing the dose of the biostimulant, changing the infeed to the anaerobic pond so

that the effluent enters the pond under the crust, removing scum from the aerobic pond,

replacing one of the aerators with a much larger unit and increasing the operation of the

aerators.

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7. Conclusions

Australian Meat propose to obtain a permanent development application for fish rendering

operations at 572 Temora Road, Cootamundra. GHD was engaged by Australian Meat to

undertake an odour air quality impact assessment in support of this development application.

Existing (approved) sources of odour on site include processes associated with lamb and cattle

processing and rendering and wastewater ponds. Future sources of odour on site are likely to

include fish processing and rendering.

Odour dispersion modelling was undertaken using the CALMET-CALPUFF system, with upper

air meteorological data generated using TAPM. Odour dispersion modelling was undertaken for

both existing and proposed operations. The results of the modelling show compliance with the

odour criteria for both existing and proposed operations.

GHD have discussed best practice management and mitigation measures to reduce the

potential for odour impacts during these activities.

The proposed fish rendering operations are not predicted to increase the environmental impacts

of the total development compared to the existing approved operations. Therefore, from an air

quality perspective, this assessment supports the transition of the current trial fish rendering

approval into a permanent approval.

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8. References

EPA. (2016). Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales. Sydney: NSW Government.

Holmes Air Sciences (2008). Odour modelling and impact assessment: Bomen industrial estate, Wagga Wagga. Eastwood, NSW.

Katestone Environmental (2004), Utility of odour intensity for the meat processing industry.

MLA (2010). Environmental best practice manual Odour

Pacific Air & Environment (2003), Biofilter performance evaluation Summary report PRENV.015

SLR (2018). Odour assessment 50 Tahmoor Rd, Tahmoor. Liverpool, NSW.

Stephenson Environmental Management Australia. (2018). Air Quality Impact Assessment Manildra Meat Company Pty Ltd 572 Temora Road, Cootamundra, NSW 2590: Auburn, NSW.

The Odour Unit (2019), Manildra Meat Company Wastewater Treatment Pond System and Biofilter System – Odour performance assessment: 21 November 2019

US EPA (1995). AP 42 Section 9.5.3 Meat Rendering Plants. USA.

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Appendices

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Appendix A – The Odour Unit – November 2019

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MANILDRA MEAT COMPANY WWTPS and Biofilter System Odour Performance Assessment – 21 November 2019

1

THE ODOUR UNIT PTY LTD

Level 3 Suite 12 56 Church Avenue

MASCOT, NSW, 2020

Phone: +61 2 9209 4420 Website: www.odourunit.com.au

A C N 091 165 061

A B N 53 091 165 061

Manildra Meat Company Pty Ltd Attn: Jason Graham 572 Temora Road PO BOX 63 COOTAMUNDRA NSW 2590

25 November 2019

by email: [email protected]

MANILDRA MEAT COMPANY WASTEWATER TREATMENT POND SYSTEM AND BIOFILTER SYSTEM - ODOUR PERFORMANCE ASSESSMENT: 21 NOVEMBER 2019 Dear Jason, The following letter-style report contains the methodology and outcomes from an odour performance assessment of the wastewater treatment pond system (WWTPS) and biofilter system at the Manildra Meat Company Abattoir Rendering Facility, Cootamundra, New South Wales (the Cootamundra Facility) on 21 November 2019 by The Odour Unit Pty Ltd (TOU).

1. Relevant Background

The odour assessment performance conducted on 21 November 2019 is a follow-up to previous assessments conducted by TOU at the Cootamundra Facility and post-remediation works on the WWTPS and biofilter system, namely:

▪ Odour testing of the WWTPS on 12 September 2019 (see TOU report dated 2 October 2019);

▪ A biofilter condition and performance assessment conducted on 17 July 2019 (see TOU report dated 7 August 2019);

▪ Optimisation and remediation of the WWTPS including, but not limited to, injection of a biological stimulant agent and installation of a second aerator on the Aerobic pond; and

▪ A complete refurbishment of the biofilter system including a replacement of the inlet air plenum distribution system, biofilter medium and increase of the medium bed depth to 1.4 metres.

This following report reflects the performance of the WWTPS and biofilter system at the Cootamundra Facility as found on 21 November 2019. 1.1 Operating Conditions The operating conditions on 21 November 2019 at the Cootamundra Facility were normal, with the rendering plant processing at a production rate of 4 tonnes an hour of raw mackerel fish. The weather conditions throughout the odour performance assessment visit was predominately light (0.5 – 2 m/s) to moderate (2 - 4 m/s) winds, an ambient dry-

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THE ODOUR UNIT PTY LTD

MANILDRA MEAT COMPANY WWTPS and Biofilter System Odour Performance Assessment – 21 November 2019

2

bulb temperature ranging from 36oC to 39oC, clear skies, relative humidity of 15 - 20%, and presence of bushfire haze in the atmosphere.

2. Odour Performance Assessment Methodology

2.1 WWTPS The odour sampling methodology adopted for the collection of odour samples from the WWTPS at the Cootamundra Facility was area source sampling from a liquid surface. The objective of the area source sampling was to collect representative odour samples from the WWTPS at the Cootamundra Facility. The sampling involves the use of an isolation flux hood (IFH). All sampling using the IFH is carried out according to the method described in the United States Environment Protection Agency (US EPA) technical report ‘EPA/600/8-86/008’, from which Australian Standard 4323.4:2009 (AS4323.4) is based. TOU’s IFH adheres to the design specifications, materials of construction and supporting equipment that the US EPA report ‘EPA/600/8-86/008’ defines. The IFH has a diameter of 0.406 metres (m), a chamber surface area of 0.126 square metres (m2) and a chamber volume of 30 litres (L), equivalent to 0.03 cubic metres (m3), when the skirt of the hood is inserted into the liquid or solid surface by the specified 25 millimetres (mm). Dry nitrogen gas (N2) is then introduced to the IFH at a sweep rate of 5 litres per minute (lpm). As these area sources are open to the atmosphere, the wind is a major factor in the release of odorous pollutants from the surface and conveying the pollutant from the source to areas beyond the boundary. The IFH system is designed to simulate the transfer of odorous pollutants by the wind, resulting in a controlled and consistent sampling environment. This is achieved by the flux of dry N2 into the IFH that is positioned on the liquid surface by floating the IFH within an inflated tyre inner tube. The N2 then transports the odour from the surface in the same way the wind does, albeit at a very low sweep velocity. This odorous air is then collected for odour and/or gas speciation analysis. As the IFH has a constant 5 lpm inflow of nitrogen gas to it, the sampling chamber remains under positive pressure and produces a net outflow through the vent on top of the IFH, therefore eliminating any chance of contamination of external air from the atmosphere. The IFH’s volume of 30 L and the 5 lpm nitrogen sweep rate results in a gas residence time of 6 minutes. The US EPA method prescribes a minimum of four (4) air changes to achieve optimum purging and equilibrium in the hood, and therefore a total of 24 minutes is allowed before sampling commences. The sample is then collected over 10 minutes to obtain a 20 L sample for odour analysis. The US EPA method followed by TOU may be summarised as follows, and as described in the schematic of the sampling equipment shown in Figure 2.1:

▪ Dry nitrogen is directed into the IFH via odour free polytetrafluoroethylene (PTFE), commercially known as Teflon, tubing until it has reached equilibrium. The nitrogen is channelled to a manifold fitted with small outlets above the surface, which direct the air towards the centre of the surface;

▪ The nitrogen flow (5 lpm) purges the flux hood with a residence time of four (4)

times the chamber volume occurring before sampling begins; and

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▪ The odorous sample is drawn through a Teflon tube, into a single-use, odour-free Nalophan sample bag secured inside a drum that is under vacuum. The balance of the gas flow is vented to the atmosphere.

The IFH is manufactured from acrylic resin to ensure it does not contribute to the odour sample. All other surfaces in contact with the sample are made from Teflon or stainless steel.

Key A B C

Inlet gas from the gas cylinder. Outlet to sample bag. Additional gas outlet points for other sampling, or temperature and moisture monitoring.

Figure 2.2 - IFH Chamber Details

2.1.1 Determination of Specific Odour Emission Rate For area source samples collected using the IFH method (see Section 2.1), the results from odour concentration testing, derived in odour units (see Section 3 for details), is multiplied by an emission rate to obtain a specific odour emission rate (SOER). SOER is

Key A Cylinder of medical air, nitrogen or any neutral gas. B Isolation Flux Hood (a detailed diagram is shown in Figure 2.2) C Lung chamber (sampling drum) D Nalophan sampling bag E Sampling pump F Air flow meter

Figure 2.1 - IFH Setup Schematic

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a measure of odour released from a representative point at a source. The SOER is multiplied by the area of the source to obtain the odour emission rate (OER), or the total odour released from each source, that is:

▪ SOER (ou.m3 m-2 s-1) = OC Q / A; and

▪ OER (ou.m3 s-1) = SOER area of source (m2) where:

▪ OC = odour concentration of compound from the air in the chamber (ou);

▪ Q = sweep gas volumetric flow rate into the chamber (m3 s-1); and

▪ A = sample source total surface area (m2) The SOER is presented in the units ou.m3/m2/s as per convention, and as referred to in the document – Klenbusch, M.R., 1986. USEPA Report No. EPA/600/8-86/008 ‘Measurement of gaseous emission rates from land surfaces using an emission isolation flux chamber, - Users Guide’. The OER is presented in the units ou.m3/s as referenced in the Australian Standard 4323.3:2001 (AS4323.3). Note: the odour performance assessment at the Cootamundra Facility undertaken on 21 November 2019 did not collect a duplicate sample set. 2.2 Biofilter System The biofilter system was assessed in the following manner:

▪ Measurement of physical performance indicators, including:

o Duct velocity and inlet airflow into the biofilter; and

o Pressure, temperature and relative humidity measurements into the biofilter.

▪ The undertaking of:

o a visual and olfactory assessment of the biofilter system; and

o odour sampling and testing of inlet and outlet air samples. The inlet sample was collected from the common inlet duct to the biofilter and upstream of the centrifugal fan. The biofilter outlet samples were collected as a composite of multiple locations using a ‘witches hat’ style sampling hood, which is designed to collect only outflow air from the biofilter surface. A total of one (1) inlet and three (3) biofilter cell surface outlet samples were collected on 21 November 2019. The method used for collecting samples involved drawing the sample gas through a polytetrafluoroethylene (PTFE) sampling tube into a single-use, Nalophan sample bag. The bag is housed within a container (sampling drum) that is evacuated with a vacuum pump, and the sample collected by induced flow. The “lung method” (or “drum and pump”

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method), by which this sampling procedure is known, allows the sample air to be collected without coming into contact with any potentially odorous material. Figure 2.3 illustrates a schematic of the point source sampling method.

Figure 2.3 – Point source sampling method

3. Odour Concentration Measurement Method

TOU’s odour laboratory operates to AS4323.3 for odour laboratory measurement, which prescribes a method for sample analysis that provides quality assurance/quality control and ensures a high degree of confidence in the accuracy, repeatability and reproducibility of results. The concentration of the gaseous odour samples was measured using a technique known as dynamic olfactometry. Dynamic olfactometry involves the repeated presentation of both a diluted gaseous odour sample and an odour-free air stream to a panel of qualified assessors through two adjacent ports on the olfactometer (known as the Odormat™). TOU utilises four to six trained assessors (or panellists) for sample analysis, with the results from four qualified panellists being the minimum allowed under the AS4323.3. For the laboratory analysis of the odour samples collected from the WWTPS, four panellists were used. The method for odour concentration analysis involves the odorous gas sample initially being diluted to the point where it cannot be detected by any member of the panel. The

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assessor’s step-up to the olfactometer, in turn, take a sniff from each port, then choose which port contains the odour and enter their response. At each stage of the testing process, the concentration of the odorous gas is systematically increased (doubled) and re-presented to the panellists. A round is completed when all assessors have correctly detected the presence of the odour with certainty. The odour is presented to the panel for three rounds and results taken from the latter two rounds, as stated in AS4323.3. The results obtained give an odour measurement measured in terms of odour units (ou). One (1) ou is the concentration of odorous air that can be detected by 50% of members of an odour panel (persons chosen as representative of the average population sensitivity to odour). It is effectively the concentration of an odour at detection threshold level. This process is defined within AS4323.3. 3.1 Odour Measurement Accuracy The repeatability and odour measurement accuracy of the Odormat is determined by its deviation from statistically reference values specified in AS4323.3. This includes calculation of instrumental repeatability (r), where r must be less than 0.477 to comply with the standard criterion for repeatability. Its accuracy (A) is also tested against the 95th percentile confidence interval, where A must be less than 0.217 to comply with the accuracy criterion as mentioned in AS4323.3. The Odormat TOU-OLF-001 calibration details can be found in the appended laboratory results – Result sheets: Repeatability and Accuracy. The calibration gas used is 51.4 parts per million (ppm), by volume, n-butanol in N2 gas, as required by AS4323.3.

4. Results 4.1 Odour Testing Results The odour testing results for the WWTPS and biofilter system are summarised in Table 1 and Table 2, respectively, with the laboratory results report appended to this letter report. In summary, the following sources were sampled:

▪ Anaerobic Pond, at three discrete locations. An image of the Anaerobic Pond during sampling on 21 November 2019 is shown in Photo 1;

▪ Aerobic Pond, at three discrete locations. An image of the Aerobic Pond during sampling on 21 November 2019 is shown in Photo 2;

▪ Storage Pond, at two discrete locations. An image of the Storage Pond during

sampling on 21 November 2019 is shown in Photo 3; and

▪ Biofilter system, including a single common inlet and three composite outlets.

4.2 Biofilter Physical Measurement Results

The biofilter physical measurement results collected on 21 November 2019 between 1315

hrs and 1330 hrs yielded the following:

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Airflow (actual conditions): 6.5 m/s, 11,800 m3/hr (ɸ = 800 mm)

Inlet air temperature: 47.5oC

Inlet air relative humidity: 43% (wet bulb temp 34.8oC)

Fan inlet air pressure: -540 Pa

5. General remarks

Based on the odour performance assessment outcomes of the WWTPS and biofilter system, the following comments are made:

▪ The WWTPS was found to be operating in a condition that is conducive with very low odour emission release from the pond surface; and

▪ The performance of the biofilter system was excellent, with an odour destruction of 99% and the absence of the inlet odour character in all outlet samples (earthy, piney).

5.1 Recommendations To maintain sustainable biofilter performance, the following is recommended:

▪ Design and install an in-duct spray humidification system that will condition the inlet process air prior to biofiltration. This feature will humidify the airstream, provide a means of adiabatically cooling that will reduce the high inlet air temperature (increasing the operating life of the medium), and minimise the risk of sub-optimal bed moisture conditions.

Yours sincerely, The Odour Unit Pty Ltd Signed by:

Michael Assal MEngSc, B. Eng (Hon)/B.Sc, AMIChemE, MIEAust, CAQP

Senior Engineer & Consultant Attachments:

▪ Odour Laboratory Testing Results Report: 22 November 2019

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Table 1 – WWTPS Odour Testing Results: 21 November 2019

Sample Location TOU Sample ID Odour Concentration

(ou) SOER

(ou.m3/m2/s) Odour Character

Sample 1 – Storage Pond 1 of 2 SC19598 128 0.074 musty, stagnant water, ammoniacal

Sample 2 – Storage Pond 2 of 2 SC19599 152 0.088 musty, stagnant water, ammoniacal

Sample 3 – Aerobic Pond 1 of 3 SC19600 152 0.089 musty, muddy water, ammoniacal

Sample 4 – Aerobic Pond 2 of 3 SC19601 108 0.063 musty, muddy water, ammoniacal

Sample 5 – Aerobic Pond 3 of 3 SC19602 108 0.063 musty, muddy water, ammoniacal

Sample 6 – Anaerobic Pond 1 of 3 SC19603 332 0.190 muddy water, ammoniacal, fatty

Sample 7 – Anaerobic Pond 2 of 3 SC19604 256 0.150 muddy water, grassy, earthy

Sample 8 – Anaerobic Pond 3 of 3 SC19605 45 0.026 musty, grassy

Table 2 – Biofilter Odour Testing Results: 21 November 2019

Sample Location TOU Sample ID Odour Concentration

(ou) Odour Character

Biofilter Outlet

Closet to inlet SC19606 59 earthy, piney

Middle section SC19607 59 earthy, piney

Furthest from inlet SC19608 64 earthy, piney

Biofilter Common Inlet SC19609 8,190 fishy, offal, oily

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Photo 1 – An image of the Anaerobic Pond during sampling on 21 November 2019 (Sample 6)

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Photo 2 – An image of the Aerobic Pond during sampling on 21 November 2019 (Sample 4)

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Photo 3 – An image of the Storage Pond during sampling on 21 November 2019 (Sample 1)

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THE ODOUR UNIT PTY LTD

Level 3 Suite 12 56 Church Avenue

MASCOT NSW 2020

Phone: +61 2 9209 4420 Email: [email protected] Internet: www.odourunit.com.au ABN: 53 091 163 061

Accreditation Number:

14974

The Odour Unit Pty Ltd Issue Date: 13.11.2003 Revision: 11 ABN 53 091 165 061 Issued By: SB Revision Date: 29.08.2018 Form 06B – Odour Concentration Results Sheet - B Last printed 11/24/2019 2:54:00 PM Approved By: TJS

1

Odour Concentration Measurement Report The measurement was commissioned by:

Organisation Manildra Meat Company Telephone +61 428 149 704 Contact Jason Graham Facsimile --

Sampling Site Cootamundra, NSW Email [email protected] Sampling Method Isolation Flux Hood Sampling Team TOU

Order details: Order requested by Jason Graham Order accepted by M. Assal

Date of order September 2019 TOU Project # N2270L Order number Refer to correspondence Project Manager M. Assal

Signed by Refer to correspondence Testing operator A. Schulz Investigated Item Odour concentration in odour units ‘ou’, determined by sensory odour concentration measurements, of an

odour sample supplied in a sampling bag. Identification The odour sample bags were labelled individually. Each label recorded the testing laboratory, sample

number, sampling location (or Identification), sampling date and time, dilution ratio (if dilution was used) and whether further chemical analysis was required.

Method The odour concentration measurements were performed using dynamic olfactometry according to the

Australian/New Zealand Standard: Stationary source emissions – Part 3: ‘Determination of odour concentration by dynamic olfactometry (AS/NZS4323.3:2001). The odour perception characteristics of the panel within the presentation series for the samples were analogous to that for butanol calibration. Any deviation from the Australian standard is recorded in the ‘Comments’ section of this report.

Measuring Range The measuring range of the olfactometer is 22 ≤ ≤ 218 ou. If the measuring range was insufficient the

odour samples will have been pre-diluted. The machine is not calibrated beyond dilution setting 217. This is specifically mentioned with the results.

Environment The measurements were performed in an air- and odour-conditioned room. The room temperature is

maintained at 22 oC ±3 oC. Measuring Dates The date of each measurement is specified with the results. Instrument Used The olfactometer used during this testing session was:

ODORMAT TOU-OLF-001. Instrumental Precision

The precision of this instrument (expressed as repeatability) for a sensory calibration must be r 0.477 in accordance with the AS/NZS4323.3:2001. ODORMAT TOU-OLF-001 : r = 0.280 (October 2019) Compliance – Yes

Instrumental Accuracy

The accuracy of this instrument for a sensory calibration must be A 0.217 in accordance with the AS/NZS4323.3:2001. ODORMAT TOU-OLF-001 : A = 0.076 (October 2019) Compliance – Yes

Lower Detection Limit (LDL)

The LDL for the olfactometer has been determined to be 16 ou, which is 4 times the lowest dilution setting.

Traceability The measurements have been performed using standards for which the traceability to the national

standard has been demonstrated. The assessors are individually selected to comply with fixed criteria and are monitored in time to keep within the limits of the standard. The results from the assessors are traceable to primary standards of n-butanol in nitrogen.

Accredited for compliance with ISO/IEC 17025 - Testing.

This report shall not be reproduced, except in full.

Date: Monday, 25 November 2019

Panel Roster Number: SYD20191122_094

A. Schulz NSW Laboratory Coordinator

D. Hepple

Authorised Signatory

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THE ODOUR UNIT PTY LTD

Accreditation Number: 14974

The Odour Unit Pty Ltd Issue Date: 13.11.2003 Revision: 9 ABN 53 091 165 061 Issued By: SB Revision Date: 15.08.2018 Form 06 – Odour Concentration Results Sheet Last printed 11/24/2019 2:54:00 PM Approved By: TJS

2

Odour Sample Measurement Results

Panel Roster Number: SYD20191122_094

Sample Location

TOU

Sample

ID

Sampling

Date &

Time

Analysis

Date &

Time

Panel

Size

Valid

ITEs

Nominal

Sample

Dilution

Actual

Sample

Dilution

(Adjusted for

Temperature)

Sample Odour

Concentration

(as received,

in the bag)

(ou)

Sample Odour

Concentration

(Final, allowing

for dilution)

(ou)

Specific Odour Emission Rate (ou.m3/m2/s) (See Note:1)

Sample 1 – Storage Pond 1 of 2

SC19598 21.11.2019 0932 hrs

22.11.2019 1019 hrs

4 8 -- -- 128 128 0.074

Sample 2 – Storage Pond 2 of 2

SC19599 21.11.2019 0933 hrs

22.11.2019 1100 hrs

4 8 -- -- 152 152 0.088

Sample 3 – Aerobic Pond 1 of 3

SC19600 21.11.2019 1024 hrs

22.11.2019 1151 hrs

4 8 -- -- 152 152 0.089

Sample 4 – Aerobic Pond 2 of 3

SC19601 21.11.2019 1022 hrs

22.11.2019 1214 hrs

4 8 -- -- 108 108 0.063

Sample 5 – Aerobic Pond 3 of 3

SC19602 21.11.2019 1110 hrs

22.11.2019 1304 hrs

4 8 -- -- 108 108 0.063

Sample 6 – Anaerobic Pond 1 of 3

SC19603 21.11.2019 1122 hrs

22.11.2019 1326 hrs

4 8 -- -- 332 332 0.190

Sample 7 – Anaerobic Pond 2 of 3

SC19604 21.11.2019 1205 hrs

22.11.2019 1352 hrs

4 8 -- -- 256 256 0.150

Sample 8 – Anaerobic Pond 3 of 3

SC19605 21.11.2019 1211 hrs

22.11.2019 1424 hrs

4 8 -- -- 45 45 0.026

Samples Received in Laboratory – From: TOU Date: 21/11/2019 Time: 1900 hrs

Note: The following are not covered by the NATA Accreditation issued to The Odour Unit Pty Ltd:

1. The collection of Isolation Flux Hood (IFH) samples and the calculation of the Specific Odour Emission Rate (SOER). 2. Final results that have been modified by the dilution factors where parties other than The Odour Unit Pty Ltd have performed the dilution of samples.

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Accreditation Number: 14974

The Odour Unit Pty Ltd Issue Date: 13.11.2003 Revision: 9 ABN 53 091 165 061 Issued By: SB Revision Date: 15.08.2018 Form 06 – Odour Concentration Results Sheet Last printed 11/24/2019 2:54:00 PM Approved By: TJS

3

Odour Sample Measurement Results

Panel Roster Number: SYD20191122_094

Sample Location

TOU

Sample

ID

Sampling

Date &

Time

Analysis

Date &

Time

Panel

Size

Valid

ITEs

Nominal

Sample

Dilution

Actual

Sample

Dilution

(Adjusted for

Temperature)

Sample Odour

Concentration

(as received,

in the bag)

(ou)

Sample Odour

Concentration

(Final, allowing

for dilution)

(ou)

Specific Odour Emission Rate (ou.m3/m2/s) (See Note:1)

Sample 9 – Biofilter Outlet (Closet to inlet, composite)

SC19606 21.11.2019 1254 hrs

22.11.2019 1517 hrs

4 8 -- -- 59 59 --

Sample 10 – Biofilter Outlet (Middle section, composite)

SC19607 21.11.2019 1303 hrs

22.11.2019 1544 hrs

4 8 -- -- 59 59 --

Sample 11 – Biofilter Outlet (Furthest from inlet, composite)

SC19608 21.11.2019 1311 hrs

22.11.2019 1613 hrs

4 8 -- -- 64 64 --

Sample 12 – Biofilter Common Inlet

SC19609 21.11.2019 1328 hrs

22.11.2019 1640 hrs

4 8 -- -- 8,190 8,190 --

Samples Received in Laboratory – From: TOU Date: 21/11/2019 Time: 1900 hrs

Note: The following are not covered by the NATA Accreditation issued to The Odour Unit Pty Ltd:

1. The collection of Isolation Flux Hood (IFH) samples and the calculation of the Specific Odour Emission Rate (SOER). 2. Final results that have been modified by the dilution factors where parties other than The Odour Unit Pty Ltd have performed the dilution of samples.

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Accreditation Number: 14974

The Odour Unit Pty Ltd Issue Date: 13.11.2003 Revision: 9 ABN 53 091 165 061 Issued By: SB Revision Date: 15.08.2018 Form 06 – Odour Concentration Results Sheet Last printed 11/24/2019 2:54:00 PM Approved By: TJS

4

Odour Panel Calibration Results

Reference Odorant Reference Odorant

Panel Roster Number

Concentration of

Reference gas

(ppb)

Panel Target Range

for n-butanol

(ppb)

Measured

Concentration

(ou)

Measured

Panel Threshold

(ppb)

Does this panel

calibration

measurement

comply with

AS/NZS4323.3:2001

(Yes / No)

n-butanol SYD20191122_094 51,400 20 ≤ ≤ 80

724

71

Yes

Comments

Odour characters (non-NATA accredited) as determined by odour laboratory panel: SC19598 musty, stagnant water, ammoniacal SC19599 musty, stagnant water, ammoniacal SC19600 musty, muddy water, ammoniacal SC19601 musty, muddy water, ammoniacal SC19602 musty, muddy water, ammoniacal SC19603 muddy water, ammonical, fatty SC19604 muddy water, grassy, earthy SC19605 musty, grassy SC19606 earthy, piney SC19607 earthy, piney SC19608 earthy, piney SC19609 fishy, offal, oily

Disclaimers 1. Parties, other than The Odour Unit Pty Ltd, responsible for collecting odour samples have advised that they have voluntarily furnished these odour samples, appropriately collected and labelled, to The Odour Unit Pty Ltd for the purpose of odour testing. 2. The collection of odour samples by parties other than The Odour Unit Pty Ltd relinquishes The Odour Unit Pty Ltd from all responsibility for the sample collection and any effects or actions that the results from the test(s) may have. 3. Any comments included in, or attachments to, this Report are not covered by the NATA Accreditation issued to The Odour Unit Pty Ltd. 4. This report shall not be reproduced, except in full, without written approval of The Odour Unit Pty Ltd.

END OF DOCUMENT

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© GHD 2020

This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited.

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Revision Author Reviewer Approved for Issue

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