EPA’s response to
community concerns
1. EPA’s consideration for odour emission and the buffer:
i). Odour emission
EPA considers that overall odour emissions will decrease as a consequence of the proposed
works:
Negligible emission from the rendering plant
It is considered that the proposed rendering plant would cause negligible odour emissions given
the following facts:
 Low volume of rendering capacity (4,070kg/hr).
 Fresh raw material generated from its own premises.
 Best practice odour controls – enclosing the entire rendering building which will be
operated under negative pressure; and fully collecting and treating odourous air from the
building and equipment and treating it in a wet scrubber and biofilter prior to discharging
to atmosphere.
 Installing and operating a dedicated PLC and SCADA system to control the entire
rendering process, with point collection, building ventilation and biofilter system, as
detailed in table 23 of the Application.
Reducing emissions from the existing operation
The existing operation has caused odour reports from the community. Likely sources include the
animal holding yard and wastewater treatment plant (anaerobic and aerobic lagoons).
During the EPA’s site visit on 9 September 2015, EPA’s odour specialist commented that the
highest risk of offensive odour emissions from the existing operation was associated with the
anaerobic lagoons. To minimise odour emissions from the existing operation and in consultation
with EPA, GBP has proposed to undertake a number of actions, as detailed in the Environmental
Improvement Plan (EIP), including the following which have been incorporated as part of works
approval condition WA_W8:
 Extend the screened wastewater pipeline to enable submerged discharge into the
anaerobic lagoon 1 (AnL1).
 Install pipeline to enable submerged discharge from the AnL1 into the anaerobic lagoon 2
(AnL 2).
 Install pipe to direct waste activated sludge from the aerated lagoon to the AnL1.
 Extend the effluent discharge pipeline from the second anaerobic lagoon to below the
surface of the operating level in the wet well of aerobic lagoon inlet pumping station.
Other emission source control:
GBP has put a roof and three walls around the solid waste storage area, per EPA’s requirement,
during the works approval process to minimise odour, prevent rainwater onto and runoff from the
stock pile (refer to page 8 of GBP’s response to s22 notice, dated 25 April 2016).
EPA’s response to community concerns
ii). Buffer requirement:
EPA considers that the existing buffer is sufficient for the proposed rendering plant as explained
below:
 Buffer distances are a tool to manage the potential risk and protect the amenity of
sensitive users under upset conditions when non-routine emissions need to be dispersed.
 The proposed annual production rate of the rendering plant will be 1400t. The
recommended separation distance for a rendering plant with a capacity greater than 200
tonnes/yr is 1000m as specified in EPA publication 1518, Recommended Separation
Distances for Industrial Residual Air Emissions – Guideline.
 The measured buffer between the rendering plant to the closest sensitive receiver is
approximately 460m.
 EPA’s assessment is that the proposed rendering plant is developed for best practice
odour control and hence the risk of frequent upset emissions occurring is substantially
less than that of a traditional rendering plant. Hence the available buffer is assessed to be
adequate to control upset emissions.
 In addition it is a requirement of EPA licensed premises to manage odour within site
boundary.
2. Wastewater treatment plant and effluent reuse scheme
i). Wastewater treatment system
Considering the community concerns and through our assessment, EPA had concerns whether
the existing wastewater treatment would be able to handle the extra volume of wastewater with
the high organic concentration generated from the rendering plant; and whether the effluent
reuse complied with State Environment Protection Policies (Waters of Victoria) and Prevention
and Management of Contaminated Land. For these reasons, EPA issued an s22 notice, mainly
requesting that GBP undertake the wastewater master plan study (Master Plan) and develop an
Environmental Improvement Plan (EIP) for effluent reuse. This is to enable the company to bring
their environmental performances in line with the relevant policies.
In April 2016, GBP provided EPA with the Master Plan and EIP. Based on the report, EPA
considers that the treated effluent for irrigation generally meets Class C standard required under
table 1 of EPA publication 464.2 Guidelines for Environmental Management. Use of Reclaimed
Water. It is expected that the existing wastewater treatment system should be capable of treating
additional rendering wastewater as the anaerobic and aerobic lagoons are all well sized and there
will be a marginal increase in hydraulic loading. The irrigation area will be increased by 23 ha
(40% increase). The expanded irrigation area will be adequate for reusing treated wastewater.
However, the existing wastewater treatment system and reuse scheme have not been managed
well over the years. This has caused a number of issues with the current operations as identified
in the Master Plan. Thus, in consultation with EPA, GBP has provided a summary of what issues
and actions need to be undertaken to address the existing management problems and ensure an
efficient and sustainable operation of the wastewater treatment system and reuse scheme.
Details of action and timelines are specified in the EIP. EPA requires GBP to report the status of
implementation of these actions prior to commissioning the rendering plant (refer to works
approval condition WA_R1).
ii). Irrigation area and winter storage
Based on the water balance calculation, EPA has required GBP to install an additional 13 ML of
winter storage and provide an extra 23 ha of irrigation area for effluent reuse (refer to works
approval condition WA_W8).
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EPA’s response to community concerns
iii. Protecting surface water
Concerns have been raised that the current irrigation practice may have caused contamination of
local creeks due to effluent overflowing from the irrigation areas to the drains connected to the
creeks. A condition of the approval requires GBP to install run-off collection drains to collect the
first flush of recycled water from the irrigation area and coloured posts to mark the 50m buffer
from the relevant water courses (refer to works approval condition WA_W8).
3. Relationship with community and on-going environmental compliance
As required by EPA through the works approval process, GBP has established a community
liaison committee (CLC) with regular meetings and the publication of a newsletter to update the
community regarding status of operational improvements and allow the community to provide
feedback to the company via the CLC members. Representatives from the EPA and local council
are and will attend the on-going CLC meetings.
GBP has been required to report to EPA prior to the commissioning of the rendering plant that
they informed the community through the CLC with the progress regarding the commitments in
the EIP and construction of the rendering plant, together with explanations concerning the issue
resolutions.
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