ENVIRONMENT Comments on additional information

From: Geordie Galvin [[email protected]]
Sent: Monday, 2 December 2013 6:23:23 PM
To: Jack Lewis
Subject: RE: (DWS Doc No 18907363) JL013:JL:MCU12/0184 - 136 Top Forestry Rd, Ridgewood
Jack
 
I refer to the letter and subsequent attachemnts from Max Watterson + Associates (29 November 2013, Ref: JL013:JL:MCU12/0184).
 
In particular I have reviewed air quality (odour and dust) elements in the reports/letters prepared by MWA which were attached to the Max Watterson + Associates document.
 
However, before proceeding further we wish to note that a receptor appears to have been missed in the modelling. This is shown in the figure below.
 
 
Letter : Response to Resolution of Sunshine Coast Regional Council Ordinary Meeting 14 November 2013– Noise, Dust & Odour Issues - Proposed Poultry Growing Sheds, Ridgewood - 26 November 2013
 
This letter specifically dealt with the aforementioned resolution.  
 
Composting
In the Council resolution point 3 noted: composting and stockpiling methodology including data on management of emissions during these processes
 
In their report MWA detailed a number of management measures for litter stockpiling/composting processes.
 
Each of the points detailed by MWA are summarised in the table below.
 
Point
PEL Comment
Litter will be transferred to the stockpile areas by truck and the initial stockpiles formed by tractor, bobcat or backhoe.
Based on composting operations we have seen elsewhere, this is appropriate.
The stockpiles will be covered using polyethylene sheet or similar to minimise fugitive dust and odour emissions during the storage period.
As noted in our previous advice to council an appropriate material should be selected to cover the windrows to avoid anaerobic conditions. Covering windows has been shown to significantly reduce emissions.  
 
Neither of the websites provided by MWA as footnote 1 and 2 indicate which cover materials were used. However a photograph on the website for Ozturners indicates that the cover material may not be polyethylene.
 
However the oz turner machine can turn the windrows without removing the cover. From an odour perspective this would significantly reduce the risk of adverse odour impacts.
A compost turning machine (tow-behind tractor) will be used to manage the composting process and maintain aerobic conditions to minimise odour emissions during the stockpiling period. The compost turning machines produce linear stockpiles approximately 1.5 metres high by 3 metres wide. Available compost turning machines include the ability to pick up and relay the covers over the stockpiles.
Provided the cover material is suitable for placing and removing and subsequently odour control, the use of a turning machine to avoid anaerobic conditions is appropriate. However no mention of how the composting will be managed (moisture content, temperature) has been provided. Alternatively the windrows will simply be manure stockpiles, rather than composting.  
The litter stockpiles will be turned at least weekly but potentially twice per week to maintain aerobic conditions.
This is consistent with turning regimes at other composting operations.
Litter turning should only be undertaken when prevailing winds are:
·        below 10 km/h to minimise fugitive dust and odour emissions; and
·        from the northeasterly to southeasterly sector to ensure that odour emissions are directed away from sensitive receptors.
This seems appropriate. This is discussed further below.
In order to minimise the potential cumulative odour impact from the stockpiling and spreading of the spent litter, the proponent intends to spread all litter 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.
Emissions from chicken sheds are typically most noticeable at week 4 and beyond. Thus, if the manure is spread during the cleanout week and up to week four, this may be appropriate. The spreading methodology is discussed below.
 
The letter goes on to state that the cumulative impact of the sheds and the stockpiling will comply with the Queensland Odour Guideline. Comment on this is provided below.
 
Spreading Management
The spreading management is covered in this section.
 
The points made by MWA are summarised below.
 
Point
PEL Comment
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.
The spreading as proposed is appropriate provided the spreading does not lead to a situation where the Queensland odour guideline is exceeded. We note that modelling has not been provided to prove that the guideline value will be met for the spreading.
Litter from each batch to be spread in a distributed manner across the orchard so as to not concentrate odours to a particular boundary of the site. The applicant has advised that the available litter from the poultry sheds will not be sufficient to spread over all areas of the site in a year i.e. approximately half of
the trees in the orchard will be covered in a year.
We have not been provided any information of the rate of application nor the amount of manure produced each year. However, the spreading of manure in the manner proposed could reduce the risk of adverse offsite odour impacts. If approved this should be a condition.
Maintaining spreading areas at a minimum setback of 50 metres from the southern, eastern and northern property boundaries to minimise potential near-field odour influences on adjacent properties. This will provide a minimum buffer distance of 300 metres from spreading areas to a residential dwelling.
This would reduce the risk of adverse offsite odour impacts. If approved this should be a condition.
Litter should be spread during the 6am to 6pm period only.
We have not checked the atmospheric stability vs time of day data, however this period is generally appropriate.
 
We note that research such as Parker, D. B. et al., 2013. (Odorous VOC emission following land application of swine manure slurry. Atmospheric Environment, Volume 66, pp. 91-100. ) have indicated that 6-8 should be allowed post application for odour emissions to decay to background levels. Whilst their work was on manure slurries, the data does indicate that some form of allowance should be made with regard to emissions decaying post spreading. In simple terms, a better range of time for spreading would be 7am – 2pm. This would allow 4 hours for the emissions to decay post spreading to the proposed cut-off time of 6pm. If approved this should be a condition.
 
Spreading of litter only when prevailing winds are from the northeasterly to southeasterly sector as required to minimise odour transport from the spreading process.
There is not mention of a weather station on site, however selecting spreading times based on wind direction and speed is appropriate. If approved this should be a condition.
Use of appropriate low velocity spreading equipment to minimise release of dust (and associated odours) into the atmosphere.
I checked the website provided by MWA, and could not find any mention of spreading dust control. However, if approved the use of an appropriate spreading should be conditioned.
Dampening of applied litter during high wind speed periods to minimise potential fugitive dust (and odour) emissions.
If approved this should be a condition in particular a suitable water truck or cart should be on site. However the effect of spreading water on the manure may increase 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
If approved this should be a condition.
 
 
We note that although this letter is dated 26 November 2013, it makes reference to the modelling report 29 November 2013 referring to a date in the future. The date on the letter is likely a typographical error with both being dated the same day.
 
Top Forestry Road Dust Modelling
MWA have indicated that they performed dust modelling for the site. The results were not included in the letter. However they indicate that the dust emissions (not impact) are estimated to increase by less than 10% as a result of the proposed development.
 
However the document does not indicate:
1.     Whether the impacts from the existing road (including background dust levels) comply with the EPP Air dust requirements
2.     Whether the change due to the development would see non compliance with the criteria.
 
Letter : Response to Response to Sunshine Coast Regional Council Further Information
Request of 19 November 2013– Noise, Dust & Odour Issues -Proposed Poultry Growing Sheds, Ridgewood
 
This letter detailed further information on odour and dust modelling for the site. Firstly they note that the odour footprint of the site has decreased. This was expected as they had over predicted airflow and thus emissions during the first round of modelling.
 
Representativeness of 2008
MWA have provided a summary of the long term average conditions at the nearest BOM station Tewantin). They have provided a summary of 2000 to 2011 and compared this to all years. It is not clear whether all years is all years for the station or a summary of 2000 to 2001. It is assumed that they:
1.     Used data for the Tewantin RSL park station and not the Tewantin Post office
2.     They compared the 2008 data to the 10 years detailed.
 
We note that good practice for meteorology is typically looking at the last 30 years and one would typically compare a number of years against the longer term data.  
 
The data provided indicates:
1.     The wind direction trends are similar between the years with the exception of 2003
2.     The wind speed data for 2008 is higher than the long term average for 2km/hr to 10 km/hr
3.     The wind roses for all years and 2008 are similar
4.     The percentage of calms for 2000-2011 is higher (~19%) than 2008 (~13%).
5.     The wind speeds under 3m/s (~11  km/hr) are generally consistent between 2008 and 2000-2011)
 
Our experience is that 2008 is typically representative of long term weather conditions for other areas. The data supplied by MWA appear to support this. Whilst the frequency of calms is higher overall compared to 2008, a simple arithmetic mean of winds below 3 m/s (~11 km/hr) based on the graph provided shows that parentage of winds is similar. Whilst there are questions with regard to whether MWA looked at longer term averages or how they processed the data, the data provided to date appears to support the use of the year 2008.
 
Model settings
The comments with regard to the effect of the radius of influence, the vegetation resolution and the use of Teixera algorithm have all been addressed by MWA. We checked the first two points but have not double checked the model files for the second run.
 
With regard to THRESHOL value of 0 being used for the modelling, it was noted by MWA there was an Attachment 4. The attachment was not found in the information provided to us.
 
The use of WSCALM set at 0.5 is appropriate.
 
Based on our discussions with MWA and the information in the report, MWA have remodelled as to account for thermal buoyancy.  MWA have noted that the receptor concentrations have decreased, however, overall the area within the C99.5 1hr contour (red line) has dramatically increased. Notwithstanding this there is compliance at the receptors previously modelled. However as noted above a receptor has not been included in the modelling. Based on a visual inspection of the contours, there is marginal compliance for Figure A and B, and noncompliance for Figures C and D. As data for discrete receptors have not been provided, the actual concentrations at the new and existing receptor are unknown. It would be beneficial if discrete receptor results were provided.
 
Litter stockpiles
We previously noted that there was little data with regard to litter stockpiles. MWA have provided a review of data available to them with regard to emissions from stockpiles. Whilst they have not collected any new data, their data does indicate that the emissions they adopted are similar to the literature values.
 
The further modelling provided by MWA shows that whilst the litter stockpiles have an effect on the odour contours, the contours are dominated by the emissions from the chicken sheds.
 
As noted above, due to the “new receptor” not being considered in the modelling, the conclusion that the site would comply is questionable.
 
However we agree with the proposed condition “A condition could be imposed to the effect that the poultry farm can only operate as long as the adjoining lands are owned and occupied by the operator or an employee of the poultry farm. In the event that the adjoining lands are not owned and occupied by the operator or an employee of the poultry farm, then a condition of approval could require odour limits not to be exceeded at those adjoining lands”.
Cumulative impacts.
The odour modelling provided by MWA considers the cumulative impacts of the shed and stockpiling (assuming good management of both). The modelling does not include impacts associated with spreading. Whilst the spreading was not considered feasible by MWA because the locations and times of spreading vary, we note that the proponent (Mr Lavis) in P&E Court Appeal 129/06 , David & Rosa Lavis T/As D&R Lavis Waste Disposal -V- Mareeba Shire Council & Another relied on modelling of spreading for their appeal. Therefore the modelling of spreading is feasible, albeit uncommon. The modelling of spreading operations (assuming worst case) could lead to a situation where the predicted impacts increase.
 
However, if the recommendation re spreading times above is adopted, this may reduce this risk.
 
Management of spreading
This was covered above.
 
Summary
We have not reviewed the model files used by MWA for the further modelling, but have relied on the information they supplied to us which says that they have.
 
MWA have performed further modelling. In general, this has resulted in a much larger footprint for the chicken farm (comparing figures most recently provided with those in the original report – attachment 17, default stocking scenario). Having said this, the receptors identified by MWA comply with the odour guideline for the shed and stockpile scenarios. However the new receptor identified above, if considered, may not comply.
 
Should the farm be approved we recommend the conditions suggested above be implemented. We also recommend that the farm be conditioned as to comply with the management methods detailed in DAFF, 2012. Queensland Guidelines Meat Chicken Farms, Brisbane: Department of Agriculture, Fisheries and Forestry, State of Queensland.
 
Regards
 
Geordie Galvin
BEng (Env Eng) MEng (Env Eng) MIEAust A.AirQual
 
 
Geordie Galvin
Principal Environmental Engineer
M: +61 429 304 644
E: [email protected]
www.pacific-environment.com
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From: Jack Lewis [mailto:[email protected]]
Sent: Monday, 2 December 2013 9:04 AM
To: Geordie Galvin
Subject: FW: (DWS Doc No 18907363) JL013:JL:MCU12/0184 - 136 Top Forestry Rd, Ridgewood
 
Morning Geordie
 
Could you please review the extra information about odour provided.
 
Thanks,
Jack Lewis | Development Planner
Planning Assessment Branch - North I Tewantin Office
Regional Strategy & Planning I Sunshine Coast Regional Council
Phone: (07) 5449 5183
Email: [email protected]
Mail: Locked Bag 72, Sunshine Coast Mail Centre, Qld 4560
 
From: Max Watterson & Associates [mailto:[email protected]]
Sent: Sunday, 1 December 2013 6:02 PM
To: Internet Mailbox Sunshine Coast Regional Council
Cc: Jack Lewis
Subject: (DWS Doc No 18907363) JL013:JL:MCU12/0184 - 136 Top Forestry Rd, Ridgewood
 
Attention: Jack Lewis
 
Please find attached the response to the issues raised at the Council Ordinary Meeting of the 14th November, 2013.
 
Do not hesitate to contact this office if you have any queries.
 
Regards
Max Watterson
 
Max Watterson & Associates
PO Box 639
COOROY     Q       4563
P (07) 5442 6121       F (07) 5442 5125
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