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Ref:   L18113/BH/10-054


11 September 2013


W Donald Milligan Pty Ltd
124 Top Forestry Road
Ridgewood QLD 4563

Attention:     Mr David Milligan


Dear David


Re: Response to Sunshine Coast Regional Council Outstanding Issues
    Request –
    Odour Issues -
    Proposed Poultry Growing Sheds, Ridgewood

Further to your request, MWA Environmental has reviewed the Sunshine Coast
Regional Council (“SCRC”) ‘Outstanding Issues Request’ (28 June 2013) (“the
outstanding issues request”) in relation to the proposed poultry farm at 124 Top
Forestry Road, Ridgewood.

The outstanding issues request is for further information regarding:

   •   Operational management;
   •   Traffic engineering;
   •   Odour; and
   •   Stormwater treatment and water quality management.

This letter responds to the additional information requested by SCRC in relation to
odour issues, as follows:




                        Max Winders & Associates Pty Ltd tas MWA Environmental
                  Level 15, 241 Adelaide St, Brisbane GPO BOX 3137, Brisbane Qld 4001
                        P 07 3002 5500 F 07 3002 5588 E [email protected]
                                        W www.mwaenviro.com.au
                                          ABN 94 010 833 084
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Page 2

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002




Detailed responses to each of the odour issues raised in the outstanding issues
request are provided separately in the following sections. It is noted that for clarity,
the order of response has been modified from the above request.

•      Provide a revised Air Quality Impact Assessment which assesses in addition to the
       proposed sheds:

       •   Provide all assumptions made for the odour modelling including the litter stock piling
           times, footprint of the spreading area, spreading area timeframes, litter moisture
           content with respect to the storage areas and the spreading/breakdown of litter.
           Where the modelling indicates that the relevant guidelines are exceeded, then the
           report should make recommendations for amelioration accordingly.

           The broiler chicken growing cycle is typically a 55 to 59 day period with a
           break of approximately 14 days between batches to allow for shed clean-out,
           maintenance and preparation. Five to six batches per year are generally
           produced from broiler farms.

           The preference of poultry processors is typically for all sheds at a farm to be
           stocked with new birds within a period of 1 to 3 days to allow for efficiency by
           way of synchronisation of feed, catch-out and cleanout schedules. There is
           the potential to ‘stagger’ batches (e.g. 4 sheds day 1 then 4 sheds day 31) to
           minimise the peak odour emissions from a farm. This is typically a measure
           that may be considered as a corrective action in accordance with a Site-
           Based Environmental Management Plan in the event of a farm causing odour
           nuisance. For the purpose of this response, the standard stocking regime
           has been considered.

           Odour emissions from the sheds after final removal of birds and the clean-out
           of the litter are negligible for the period between batches. Similarly, due to
           low bird mass and higher target temperatures, overall odour emissions from
           the broiler sheds are minimal during the first 3 weeks of a batch cycle1.

           In order to minimise the potential cumulative odour impact from the
           stockpiling and spreading of the spent litter, the proponent intends to spread
           within 4 to 5 weeks of the shed clean-out. Under this operational regime,
           odour emissions from the stockpiling and spreading of the spent litter occur
           during the period when only minor emissions are generated from the broiler
           sheds. Overall odour emissions from the litter stockpiles are significantly
           lower than from the broiler sheds and thus the stockpiling period is not
           anticipated to generate peak odour impacts beyond that of the broiler farm.

           A review of the required area for the litter stockpiling has been undertaken in
           conjunction with Callaghan & Toth and a compost stockpiling / turning
           machine manufacturer2. The initially proposed 280m2 bunded stockpile area
           was found to be inadequate to efficiently stockpile the litter.




1
    Typically 10% to 15% of peak odour emissions during later stages of the batch cycle
2
    Seymour Rural Equipment Pty Ltd


                                                     2

Page 3

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002



          The volume of litter has been calculated as follows for the purpose of
          designing the stockpile areas:

                 •   75mm depth of litter within the sheds (conservative assumption)
                 •   full litter replacement of all sheds at the end of each batch
                     (conservative assumption)
                 •   total floor area of 8 sheds 13,695m2
                  Total litter volume of 1027m3 per batch3

          It has been determined by the proponent that the use of a compost turning
          machine (tow-behind tractor) will be the most efficient means of stockpiling
          the spent litter and maintaining aerobic conditions to minimise odour
          emissions during the stockpiling period. Potential systems are manufactured
          by ‘JPH Equipment’ (http://ozturners.com.au/icwp/products/compost-turners/)
          and          Seymour          Rural         Equipment         Pty        Ltd
          (http://www.seymourrural.com.au/compost-turner-4000.html)        and     can
          integrate stockpile covers (i.e. pick and replace covers after turner passes
          along stockpile). The compost turning machines produce linear stockpiles
          approximately 1.5 metres high by 3 metres wide.

          Advice from the manufacturer is that a Seymour ‘Compost Turner 4000’
          produces linear stockpiles that will hold approximately 2.5m3 of litter per lineal
          metre of stockpile.

          The required length of stockpiles is calculated as follows:

                 •   Total litter volume of 1027m3
                 •   Stockpile capacity of 2.5m3 of litter per lineal metre
                  Total 410 lineal metres 4 of stockpile required

          Based upon advice from Seymour Rural Equipment Pty Ltd, Callaghan & Toth
          has designed two bunded stockpile storage areas to accommodate up to 486
          lineal metres of the litter stockpiles. This provides a reserve stockpile length
          of 76 metres as a redundancy in the event that a larger litter volume is
          produced from the sheds than anticipated or that a smaller volume compost
          turning machine is used as the site.

          The two litter stockpile areas are shown on Callaghan & Toth Plan 01 Rev D
          Page 9 (September 2013) (refer Attachment 1) and are generally described
          as follows:




3                      3
    0.075 x 13695 = 1027m
4          3       2
    1027m ÷ 2.5m = 410 metres


                                              3

Page 4

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002



                Northern Stockpile Area (adjacent Shed 5)
                300 lineal metres of stockpile within a 120m x 22.5m bunded area
                76 lineal metres of reserve stockpile within a 82m x 14m bunded area

                Southern Stockpile Area (adjacent Shed 3)
                110 lineal metres of stockpile within a 75m x 19m bunded area


        Specific details requested by SCRC are summarised as follows:

            Litter stockpiling time
                4 to 5 weeks (including spreading) commencing from day of cleanout.

                If, due to unforeseen circumstances, litter is not able to be spread
                within the available 4 to 5 week period then, in the event of odour
                nuisance, the litter may be removed from the site by a regulated waste
                transport company as occurs for many broiler farms that do not have
                to ability to reuse the material on-site.


            Footprint of the Spreading Area
               Litter is to be spread on the terraces containing avocado trees (not to
               steep slopes) which will act to control runoff from the fertilised areas.
               In accordance with the Queensland Department of Agriculture,
               Fisheries and Forestry Guidelines: Meat Chicken Farms (2012) a
               minimum buffer of 50 metres is to be maintained between litter
               spreading areas and waterways, including Blackfellow Creek. It is
               also recommended that a minimum setback of 50 metres is retained
               from spreading areas to the southern, eastern and northern property
               boundaries to avoid near-field odour influence on adjacent properties.

            Spreading Area Timeframes
               Litter will be spread from the stockpiles within 4 to 5 weeks of the litter
               being removed from the sheds. It is recommended that litter only be
               spread during the 6am to 6pm period and when winds are from
               easterly directions to ensure that odour emissions are directed
               towards the state forest and away from sensitive receptors.

            Litter Moisture Content
                In order to manage odour and dust emission potential from the sheds,
                litter moisture content is to be maintained in the range 15% to 30%.
                This will be the moisture content upon placement in stockpiles. For a
                commercial composting operation, litter moisture content may
                approach 50% but this is unlikely to be the case at the subject site
                given that the stockpiles are to be covered and will only be maintained
                for 4 to 5 weeks. The final moisture content in the stockpiles is likely
                to be in the order of 30 to 40% prior to spreading.




                                              4

Page 5

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002




    •   The quantitative odour impacts from the required amount of shed litter stockpile
        storage areas to be used for storage of the litter prior to disposal/spreading on site.

        It is proposed to minimise potential odour impacts from the stockpiling of the
        spent litter by:

            •   Stockpiling and spreading spent litter only during the period when
                odour emissions from the broiler sheds is minimal (i.e. between
                batches and during the first 3 weeks of the next batch);
            •   Covering stockpiles to reduce fugitive odour emissions; and
            •   Maintaining aerobic conditions in stockpiles using a dedicated
                compost-turning machine.


        MWA Environmental has calculated that the total surface area of 486 lineal
        metres of stockpile will be approximately 2141m2. Odour emissions from the
        litter stockpiles have been taken from monitoring undertaken at Queensland
        Organics for the purposes of the Queensland Health study of the Narangba
        Industrial Estate5. The measured odour emission rate from a ‘fresh (poultry)
        manure stockpile’ was 350 OU.m3/minute/m2.

        Odour emission rates from the litter stockpiles are thus estimated to be a total
        of 12,500 OU.m3/second6 during the potential 35 day stockpiling period. As a
        conservative assumption, no odour emission reduction has been applied to
        account for the covering of the stockpiles.

        MWA Environmental has represented odour emissions from the spent litter
        stockpiles in the CALPUFF dispersion model for the 35 day period from the
        completion of each batch cycle (i.e. 35 days from shed cleanout). Litter
        stockpiling emissions were modelled as area sources representing the
        dimensions of the proposed northern and southern stockpile pads. Aside
        from the representation of odour emissions from the litter stockpile, no further
        changes to the odour model described in the report Noise and Air Quality
        Impact Assessment – Proposed Poultry Growing Sheds – 124 Top Forestry
        Road, Ridgewood (MWA Environmental, 5 November 2012).

        A plot of the model-predicted cumulative 99.5th percentile 1 hour average
        odour concentrations over the model domain for the default Stocking
        regime with litter stockpiling are included in Attachment 2. The model-
        predicted cumulative 99.5th percentile 1 hour average odour concentrations at
        the representative surrounding residences (R1 to R10, refer Figure 1) are
        summarised in Table 1 below.




5
  Narangba Industrial Estate Emission Monitoring Programme May - June 2009 (Golder AWN, October
2009)
6         3            2         2                         3
  350 OU.m /minute/m x 2141m ÷ 60 sec/min = 12489 OU.m /second


                                              5

Page 6

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002



        Table 1:     Model-Predicted 99.5th Percentile Odour Concentrations
                     Cumulative Impact Broiler Farm & Litter Stockpiling

                                         MODEL-PREDICTED
                                                        th
                                         CUMULATIVE 99.5
              RECEPTOR                  PERCENTILE 1 HOUR
                                         AVERAGE ODOUR
                                       CONCENTRATION (OU)

                   R1                             2.4

                   R2                             1.8

                   R3                             1.4

                   R4                             1.1

                   R5                             0.7

                   R6                             0.5

                   R7                             0.8

                   R8                             0.7

                   R9                             0.5

                   R10                            1.0

                Guideline                         2.5



        The results of the modelling indicate that the cumulative impact of the litter
        stockpiling and the proposed eight shed poultry farm can comply with the
        relevant odour amenity criterion subject to the implementation of best-practice
        farm management practices.


   •    The quantitative odour impacts of spreading spent litter across the footprint of the
        existing avocado farm.

        The site has operated as an avocado orchard for over 15 years and prior to
        that as a range of fruit orchards. Fertiliser application is an integral
        component of the existing use and advice from the proponent is the manures
        have previously been applied at the site without generating any significant
        odour nuisance. Imported manure-based fertiliser may continue to be used at
        the site but the primary driver for moving away from the use of manures was
        the relative cost of this fertiliser.




                                              6

Page 7

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002



        A key goal of the proposed poultry farm proposal is to allow for the reuse of
        the spent litter on-site. The reuse minimises waste product generated from
        the poultry farm and integrates the activity with the existing avocado orchard.

        Given the dynamic nature of fertiliser application (i.e. variations in locations
        and sizes of application areas, varying meteorological conditions) it is not
        considered feasible to undertake a reliable quantitative modelling
        assessment. This notwithstanding, it is considered that with the available
        separation distance to sensitive receptors and appropriate application
        methods there is the potential to minimise the risk of odour nuisance.

        The proponent intends to apply litter within 4 to 5 weeks of the clean-out from
        the sheds. Odour emissions from the litter will deplete reasonably quickly
        following application (substantially reduced over several days).           This
        operational program will ensure that odour emissions from the spreading of
        litter do not coincide with peak odour emission periods from the next batch of
        birds in the poultry sheds. There should therefore not be significant
        cumulative impacts from the litter spreading within the orchard and the broiler
        farm.

        The available setback distances from the subject site boundary to sensitive
        receptors is summarised in Table 2 below for the receptor locations shown on
        Figure 1.

        Table 2:      Setback Distances from Nearest Property Boundary to
                      Sensitive Receptors

                                      Distance from
                   Residence         Residence to Site
                                      Boundary (m)

                       1                     415
                       2                     250
                       3                     365
                       4                     610
                       5                     970
                       6                    1450
                       7                     520
                       8                     550
                       9                     825
                      10                     925

        It is recommended that litter not be spread within 50 metres of the southern,
        eastern and northern property boundaries to minimise potential near-field
        odour influences on adjacent properties. On this basis, litter spreading should
        not occur within 300 metres of a sensitive receptor. This provides a
        significant minimum setback distance to allow for odour dilution and
        dispersion.




                                              7

Page 8

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002



        Analysis undertaken by MWA Environmental indicates that winds from the
        northeasterly to southeasterly sector are present in the order of 56% of hours
        between 6am and 6pm. Seasonal and annual wind roses extracted from the
        CALMET meteorological model output for the 6am to 6pm period are included
        as Attachment 3. The wind roses demonstrate that there is ample
        opportunity during all seasons for litter to be spread under wind conditions
        that will not result in odour emissions impacting on sensitive receptors.

        Given the spatial constraints of the orchard terraces, litter is expected to be
        spread using a relatively small ground-driven spreader mounted to a small
        tractor. These spreader systems typically have a fairly short broadcast
        distances and velocity which will minimise potential for excessive dust (and
        associated odorous particles) to be released to the atmosphere. The
        vegetated terrace structures will assist in reducing entrainment of litter in the
        atmosphere during periods of high wind speeds. This notwithstanding, it may
        be necessary to dampen the surface of the litter by irrigation during high wind
        conditions to minimise potential fugitive dust (and odour) emissions.

        Development approvals for poultry farms typically include a condition
        requiring the implementation of a Site-Based Environmental Management
        Plan prior to the commencement of use. This Site-Based Environmental
        Management Plan should include management measures to minimise the risk
        of odour nuisance from the spreading of litter, such as:

                •   Spreading of litter within 4 to 5 weeks of clean-out from the poultry
                    sheds to ensure that odour emissions from the spreading of litter
                    do not coincide with peak odour emission periods from the next
                    batch of birds in the poultry sheds.
                •   Maintaining a minimum setback of 50 metres from the southern,
                    eastern and northern property boundaries to minimise potential
                    near-field odour influences on adjacent properties.
                •   Spreading of litter only when prevailing winds are from the
                    northeasterly to southeasterly sector.
                •   Use of appropriate low velocity spreading equipment to minimise
                    release of dust (and associated odours) into the atmosphere.
                •   Dampening of applied litter during high wind speed periods to
                    minimise potential fugitive dust (and odour) emissions.
                •   Corrective actions in the event of odour nuisance, including:
                           Review of spreading locations, methods and practices to
                            identify measure to reduce impacts; and
                           If necessary, export of litter from site if noted to generate
                            excessive odour emissions.




                                              8

Page 9

Mr David Milligan, W Donald Milligan Pty Ltd                                  11 September 2013
Re: Response to Sunshine Coast Regional Council Outstanding Issues Request – Proposed Poultry
      Growing Sheds, Ridgewood                                                 L18113/BH/12-002



        Based upon the available setback distances to residences, the proposed
        spreading methods and prevailing meteorological conditions, it is considered
        that the reuse of the poultry litter on-site can be managed in accordance with
        a Site-Based Environmental Management Plan to not cause unreasonable
        odour impacts at sensitive receptors.



Yours sincerely

Ben Hyde
Environmental Engineer




                                              9

Page 10

                                                                FIGURES




      Max Winders & Associates Pty Ltd tas MWA Environmental
Level 15, 241 Adelaide St, Brisbane GPO BOX 3137, Brisbane Qld 4001
      P 07 3002 5500 F 07 3002 5588 E [email protected]
                      W www.mwaenviro.com.au
                        ABN 94 010 833 084

Page 11

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                                                                                                          Level 15, 241 Adelaide St, Brisbane. GPO BOX 3137, Brisbane Qld 4001
                                                                                                            P 07 3002 5500 F 07 3002 5588 E [email protected]
                                                                                                                           W www.mwaenviro.com.au
      metres
      metres                                                                                                                      ABN 94 010 833 084

Page 12

                                         ATTACHMENT 1
                                 Callaghan & Toth Plans
                           Showing Litter Stockpile Areas




      Max Winders & Associates Pty Ltd tas MWA Environmental
Level 15, 241 Adelaide St, Brisbane GPO BOX 3137, Brisbane Qld 4001
      P 07 3002 5500 F 07 3002 5588 E [email protected]
                      W www.mwaenviro.com.au
                        ABN 94 010 833 084

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Page 20

                                              ATTACHMENT 2
Predicted 99.5th Percentile 1 Hour Average Odour
                                   Concentrations

Cumulative Operation of Broiler Sheds and Litter
                                    Stockpiling




           Max Winders & Associates Pty Ltd tas MWA Environmental
     Level 15, 241 Adelaide St, Brisbane GPO BOX 3137, Brisbane Qld 4001
           P 07 3002 5500 F 07 3002 5588 E [email protected]
                           W www.mwaenviro.com.au
                             ABN 94 010 833 084

Page 21

                                 Poultry Sheds + Litter Stockpiles
   Figure A2
                   1-hour average 99.5th percentile predicted odour concentration
                      for No Staggered Stocking scenario and Litter Stockpiles


Ridgewood 12-002    Guideline: 2.5 Odour Units              August 2013

Page 22

                                          ATTACHMENT 3
                           CALMET Model
6am to 6pm Seasonal and Annual Wind Roses




       Max Winders & Associates Pty Ltd tas MWA Environmental
 Level 15, 241 Adelaide St, Brisbane GPO BOX 3137, Brisbane Qld 4001
       P 07 3002 5500 F 07 3002 5588 E [email protected]
                       W www.mwaenviro.com.au
                         ABN 94 010 833 084

Page 23

Wind roses for each season between the hours of 6am and 6pm predicted for the Ridgewood site for CALMET 2008

                  Summer                                         Autumn                                           Key




                Calms 0.93%                                    Calms 0.36%
                   Winter                                         Spring                                         Annual




                Calms 1.09%                                    Calms 0.55%                                     Calms 0.73%

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