George Town Seafoods Production Increase Environmental Effects Report
December 2015
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | i
Table of contents 1. Introduction..................................................................................................................................... 1
1.1 Purpose of this report........................................................................................................... 1
2. Part A – Proponent Information ..................................................................................................... 2
2.1 Proponent Details ................................................................................................................ 2
2.2 Background .......................................................................................................................... 2
3. Part B – Project Description ........................................................................................................... 4
3.1 Description of Project ........................................................................................................... 4
3.2 Project Area ....................................................................................................................... 10
3.3 Map and Site Plan .............................................................................................................. 10
3.4 Rational and Alternatives ................................................................................................... 13
4. Part C – Potential Environmental Effects ..................................................................................... 14
4.1 Flora and Fauna ................................................................................................................. 14
4.2 Rivers Creeks, Wetlands and Estuaries ............................................................................ 14
4.3 Significant Areas ................................................................................................................ 15
4.4 Coastal Zone ...................................................................................................................... 15
4.5 Marine Areas ...................................................................................................................... 15
4.6 Air Emissions ..................................................................................................................... 16
4.7 Liquid Effluent .................................................................................................................... 17
4.8 Solid Wastes ...................................................................................................................... 24
4.9 Noise Emissions ................................................................................................................ 25
4.10 Transport Impacts .............................................................................................................. 26
4.11 Other off site Impacts ......................................................................................................... 27
4.12 Hazardous substances and chemicals .............................................................................. 28
4.13 Site contamination ............................................................................................................. 29
4.14 Sustainability and Climate change ..................................................................................... 30
4.15 Cultural Heritage ................................................................................................................ 31
4.16 Sites of Public interest ....................................................................................................... 31
4.17 Rehabilitation ..................................................................................................................... 31
5. Part D – Commitments ................................................................................................................. 32
5.1 Management Commitments ............................................................................................... 32
6. Part E - Public Consultation ......................................................................................................... 33
6.1 Public consultation ............................................................................................................. 33
7. Disclaimer..................................................................................................................................... 34
8. References ................................................................................................................................... 35
Table index
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Table 2-1 Proponent Details .................................................................................................................... 2
Table 3-1 Existing and Proposed George Town Seafoods Fish Processing Quantities ......................... 4
Table 3-2 Water, Chemical and Liquid Waste Estimated Volumes ......................................................... 8
Table 3-3 Project area information (ListMap accessed 07/09/15) ..................................................... 10
Table 4-1 Likely Tradewaste Discharge Rates During Peak Salmon Production .................................. 19
Table 4-2 Tradewaste and Component Volumes ................................................................................... 19
Table 4-3 Existing Tradewaste Quality .................................................................................................. 20
Table 4-4 Sources of Sodium in Tradewaste ........................................................................................ 21
Table 4-5 Annual Chemical Volumes* ................................................................................................... 28
Table 5-1 Management Commitments ................................................................................................... 32
Figure index
Figure 3-1 Current and Proposed Seasonal Production Trend (tonnes) ................................................. 5
Figure 3-2 Proposed Salmon (Hog) Process Flow ................................................................................... 6
Figure 3-3 Site Area Map ....................................................................................................................... 11
Figure 3-4 Site Layout ........................................................................................................................... 12
Figure 4-2 Proposed Improved Efficiencies ........................................................................................... 30
Appendices Appendix A – Draft Biosecurity Management Plan (Tassal September 2015)
Appendix B – Current Containment Areas
Appendix C Biosecurity Permit
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 1
1. Introduction 1.1 Purpose of this report
The purpose of this Environmental Effects Report (EER) is to provide information to support a
development application by George Town Seafoods to the George Town Council for a
production quantity increase.
The EER provides information for the Environmental Protection Authority to consider
environmental aspects of the proposal. The information will be used to determine the conditions
under which approval may be given.
The EER also provides information for interested individuals and groups to gain an
understanding of the proposal.
The EER has been prepared in accordance with the Environmental Effects Report Guidelines
for George Town Seafoods Proprietary Limited, Proposed Increase in Capacity of Fish
Processing Factory 38-42 Franklin Street, George Town, the EPA general guidelines for
preparing Environmental Impact Statements for level 2B activities (EPA April 2013) and the
Draft Aquaculture Farm Biosecurity Plan Guidelines and Plan Template (Australian Government
Department of Agriculture 2015).
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2. Part A – Proponent Information 2.1 Proponent Details
The proponent for the George Town Seafoods Production Increase EER is shown below in
Table 2-1.
Table 2-1 Proponent Details
Proponent Name Managing Director, George Doumouras
George Town Seafoods Pty Ltd
Proponent Address
38 - 44 Franklin Street,
George Town,
TAS 7253
ABN 76 076 219 988
There are no known legal proceedings against the proponent and they are considered capable
of meeting the financial and resource implications of the project.
GHD Pty Ltd (GHD) has provided environmental assistance in preparing this EER on behalf of
the proponent. The GHD contact for the George Town Seafoods Production Increase EER is:
Susan McLeod
Senior Environmental Consultant
GHD Pty Ltd
23 Paterson St
Launceston TAS 7250
Phone: (03) 6332 5531
2.2 Background
George Town Seafoods Pty Ltd is an existing seafood processing and exporting facility located
in the light industrial area of George Town, Tasmania. Established in 1993, George Town
Seafoods was has always been an export accredited facility; regularly audited by AQIS to meet
the strict hygiene requirements for the export of seafood. Currently, George Town Seafoods is
registered under an approved arrangements system with AQIS, and is one of few processing
facilities registered as a preferred processor for the European Union (EU).
The criteria which George Town Seafoods adheres to in order to be EU registered demands
that world regarded best processing practices be utilised throughout all facets of the processing
line. These criteria include fish waste and waste management. The site is also audited by a
third party HACCP (hazard analysis and critical control plan) auditor to maintain HACCP
accreditation.
George Town Seafoods process raw fish (white fish and salmon), scallops, oysters and crayfish
The site operates under an existing EPN issued by the Tasmanian EPA and has a licenced
processing capacity of 5,000 tonnes of product produced per year. Seafood raw products (live,
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chilled or frozen) are processed by filleting, heading, gutting, skinning and boning. The resulting
products are for human consumption and for bait.
The site has been undergoing continuous improvement and upgrade to improve quality,
environmental and biosecurity management. Examples of recent improvements include:
Rearranging the process flow with building modifications to enable;
o better containment of raw fish areas and confinement of areas draining to
tradewaste and sewer;
o Prevention of the cross movement of raw and finished product;
Purchase and installation of low noise air compressor; and
Provision of bunded containment facilities around wastewater tanks and bulk chemical
storage areas.
George Town Seafoods have been issued with a current planning (DA 2015/18), building and
plumbing permit (2015/27) to undertake the following amendments to the existing process
building and setup:
Upgrade and relining of processing rooms to achieve improved segregation,
temperature control and hygiene and allow for fitting and installation of new automated
gutting equipment.
Installing automated salmon processing equipment
Upgrading the salmon tipping station prior to automated processing.
Constructing a roof over the northern unloading and dewatering station area to prevent
rainwater entering the Tradewaste system.
The site operates under the following licences, permits and plans:
EPN 7489-1 Fish Processing
EPN 8836-1 Fish Processing Waste Disposal
Biosecurity Animal Health Act 1995 Permit MH 15-03
AQIS Approved Arrangements REG. EST. NO. 5485
Approval is now being sought for an increase in production capacity from 5,000 tonnes seafood
product produced per year to 10,000 tonnes product produced per year (the focus of this
application).
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3. Part B – Project Description 3.1 Description of Project
3.1.1 Overview
George Town Seafoods are proposing to increase their licenced production capacity from 5,000
tonnes seafood product produced per year to 10,000 tonnes product produced per year. This
proposal relates to the increased production of salmon head on and gutted (HOG) product only.
The proposal does not include any building or site modifications. Table 3-1 below shows the
proposed breakdown of annual raw materials and product expected from the proposed
increased production capacity. The increased capacity will be achieved solely through
increased quantities of farmed Atlantic Salmon (“salmon”). The quantities of other seafood
(“wildfish”) are expected to remain similar to existing quantities processed.
This proposal relates solely to the receival, processing and waste management of salmon on
site at George Town Seafoods facility and does not include production at the fish farm.
Table 3-1 Existing and Proposed George Town Seafoods Fish Processing Quantities
Existing Annual Quantities (taken
from June 2014 – May 2015)
Proposed Annual Quantities
(Jan 2016 –Dec 2017)
Raw Material
(tonnes)
Product (tonnes) Raw Material
(tonnes)
Product (tonnes)
Farmed Atlantic
salmon
6,130 5,394 11,136 9,800
Wild Fish (other
seafood)
324 167 385 200
Total 6,450 5,561 11,521 10,000
3.1.2 Timeframe
George Town Seafoods are seeking to increase production immediately following environmental
and planning approvals, in order to take advantage of peak production periods over months
January – May 2016. An existing planning, building and plumbing permit has already been
issued to George Town Seafoods to allow for the required building modifications which are
currently in the process of being implemented. New equipment proposed for use has been
purchased by George Town Seafoods and is currently being installed. Installation and
commissioning of the new equipment does not depend on the outcomes of this EER for
increased production quantities and is likely to occur prior to December 2015 for use in the
2015/2016 salmon processing season (regardless of the outcomes of this application).
All production on the new equipment will be limited by the requirements of the existing EPN
licence limits, or any interim EPA approvals until necessary approvals for the increased
production quantities are obtained. That is, production quantities will be limited to those in line
with previous years until such time as approval for the higher production quantities are obtained.
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3.1.3 Operating Hours
The proposed production increase will be met within the existing operating hours 5 am - 5.30
pm Monday to Friday and 5 am to 5 pm Saturday and Sunday. The processing facility will
operate 12 months of the year for wild fish production (as per current conditions), whilst salmon
will be processed for approximately 6-7 months of the year (also similar to current). As
observed from Figure 3-1, the proposed seasonal production trends will result in 5-6 months of
the year where minimal quantities of fish (wild fish only) are processed through the facility. The
increased salmon production quantities will be met by running more consistent production days
for 7 days a week with higher output, rather than shorter and variable production days
experienced in previous years.
3.1.4 Seasonal Volumes
Farmed salmon is currently processed in months October through to May, while wild fish is
processed all year round. Peak processing periods for salmon are typically between the months
of February and April and these peak seasonal trends are expected to continue following the
proposed increased salmon production. Figure 3-1 below shows the observed trend of salmon
production volumes in the June 2014- May 2015 season (“existing farmed salmon”) and the
expected trend in salmon production volumes following the increased production (“proposed
farmed salmon”). As illustrated the majority of salmon will continue to be processed over a 3-4
month period starting in late January.
Figure 3-1 Current and Proposed Seasonal Production Trend (tonnes)
3.1.5 Process and Equipment
The increase in salmon production capacity will be primarily achieved by operating automated
equipment for gutting and grading. As described in Section 3.1.2, new automated equipment
proposed for use has already been purchased by George Town Seafoods and is currently being
installed (under approval from Georgetown Council). Commissioning of the new equipment
does not depend on the approval of increased production quantities (as it will be used for
existing production levels regardless of the proposed production increase) and is likely to occur
in October and November 2015. The new equipment currently being installed includes:
Two automatic “Baader” gutting machines;
One automatic-manual gutting station;
One grading and weighing machine;
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Conveyors between receival, gutting and grading machines;
Two new vacuum pumps installed on the roof above the wastewater treatment area;
and
Additional chemical dosing station for fish guts received off two Badder gutting
machines.
All other processing equipment and services (e.g. compressed air, refrigeration, water, chemical
and waste storage facilities) will remain as per the current operations. There are no proposed
changes to the wild fish production processes.
The process that will apply to the proposed increased salmon production is shown in Figure 3-2
and described below. A site layout (Figure 3-4) showing the key process activity areas is
provided in Section 3.3.
Figure 3-2 Proposed Salmon (Hog) Process Flow
Receival There are no proposed changes to the raw material receival processes. The method of salmon
receival will be as per the current unloading arrangements. Volumes of materials received by
the site and frequency of turnover will increase as shown in Table 3-1 (fish raw material), Table
3-2 (chemicals, wastes and water) and described in Section 3.1.6. Salmon processed from the
months of October to December are currently and will continue to be received in 1000 L bins.
There is no proposed change in quantities during these months. The proposed increased
quantities are expected to be received between months of January and April. The additional
raw salmon between January and April are expected to be delivered entirely in bulk tankers.
Raw salmon received on site via bulk tankers will be unloaded in the existing designated
unloading Transvac Station at the north east corner of the factory (refer Figure 3-4). Raw
1. Receival
2. De‐watering and Initial Storage
3. infeed
4. Gutting
5. Grading
6. Packing
7. Storage
8. Dispatch
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salmon received in 1000 L insulated bins with chilled water and ice will continue to be received
at the loading bay at the south end of the factory and moved to the northern end of the factory
for interim storage and processing (refer Figure 3-4).
Chemicals are received in loading bay at the northern end of the site. Unloading of packaging
and other dry goods will continue to occur at the southern loading/unloading zone adjacent to
Thompson Avenue. Dry goods are stored in designated areas within the building as per the
conditions of the Approved Arrangements (George Town Seafoods 19/05/2015), so as to
prevent cross contamination of food products.
De-Watering & Initial Storage
The whole fish from tankers will be de-watered during the unloading process by pumping fish
from the Transvac station to the dewatering station (refer Figure 3-4). Ice water and any blood
drained from the whole fish is directed to the tradewaste system. Salmon will be placed in 1000
L insulated bins with fresh chilled water (dosed with chlorine dioxide) and ice. The salmon will
be kept at a temperature of 0-2 degrees Celsius ready for processing the same day. The
drained blood water from the dewatering station, comprised of blood, salt water and iced water,
will be dosed with sodium hypochlorite in accordance with the site’s current Approved
Biosecurity Management Plan (Appendix A). The blood water will be stored in a 28 kL blood
water tank adjacent to the bulk tanker unloading area, prior to being transferred to the
wastewater tanks and discharged through the tradewaste system.
The de-watering and initial storage process described for bulk transport received salmon will not
change from the current operations. The process area however is being progressively
upgraded as part of the recently issued building permit. The de-watering process area is
currently uncovered and drains to tradewaste, whilst the building upgrades provide for covering
the dewatering and initial storage areas (Figure 3-4).
Process Infeed
Following dewatering, all salmon in the 1000 L insulated bins will be loaded onto a covered
tipping station which will empty the salmon onto a speed controlled infeed belt. Any liquid from
the tipping station will drain to the sites tradewaste system. This tipping station has been
recently upgraded.
Gutting From the infeed conveyor belt the salmon will be processed through one of two automatic
Baader machines which guts and cleans the salmon. Fish not able to be processed through the
Baader machines will be manually gutted in an automatic-manual gutting station. The viscera
(gut) which is removed either by the machines or manually will be sucked or pumped into the
existing 32 kL holding tank. This holding tank is stainless steel and jacketed.
The viscera will be pumped into the 32 kL tank and stored. From the fish viscera storage tank
the waste will be sucked into a tanker which is transported to Triabunna for processing at a
licenced fish waste facility into downstream products. The proposed disposal of fish viscera
follows the same process as the current operations. Volumes of fish viscera waste will increase
however the frequency of collection is expected to be once every 1-2 days compared to the
current frequency of once every 2-3 days during the salmon processing season. Aside from an
increase in frequency all other aspects of the waste collection and disposal will remain
unchanged.
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Grading
Salmon will be graded in quality and weighed with an automatic weighing machine. Based on
the grading, salmon are sent to the appropriate packing line, either premium whole fish or fish
for further processing off-site.
Packing, Chilling and Freezing
Processed premium whole salmon (HOG) will be placed into polystyrene eskies which will be
shipped out the same day. All other salmon (HOG) will be placed into either AFC’s (Austral
Folding Containers) transported interstate or 1000 L insulated bins which will travel via truck to
Margate or Huonville for value add processing (filleting etc.). All containers will include either
ice (AFCs) or ice water (insulated bins) and will be kept refrigerated in cool rooms shown in
Figure 3-4 until departure.
Dispatch
Goods will be removed from storage, and will then be placed into transport vehicles for dispatch.
Product in bins will be dispatched via the southern loading/unloading zone adjacent to
Thompson Avenue. Premium whole fish in eskies will be loaded directly off the processing line
to transport vehicles in the northern loading bay. Quantities for dispatch will increase but the
dispatch process remains unchanged.
3.1.6 Chemicals, Water and Waste
Quantities of water, chemicals used and wastes from the proposed production increase
compared to the existing operation are provided below in Table 3-2. Two types of liquid wastes
will be produced from the increased salmon production 1) Tradewaste containing blood water
and cleaning water and 2) Fish Viscera Waste. Volumes of fish viscera waste are expected to
increase in proportion with the proposed production quantities (x 1.8), whilst the volume of
tradewaste is estimated to increase by approximately 1.3 x the existing volume during salmon
processing. The current processing facility produces a third type of waste (liquid fertiliser) from
the processing of all wild fish waste. Quantities of liquid fertiliser waste are expected to remain
similar to current as this waste stream is generated during the production of wild fish only (which
is not proposed for increase).
Other solid waste general waste (packaging etc.) will be disposed of via secure landfill as per
the current operations, in accordance with the Approved Arrangements (George Town Seafoods
19/05/2015) and the Approved Biosecurity Management Plan (Tassal Nov 2015).
Water use at the site is largely driven by the use of fresh water to produce ice and ice water
which is used in interim storage of fish and also used during packing prior to dispatch. It is
estimated that approximately 50% of the site’s water use ends up being dispatch out with
finished product. The rest of the water used is for cleaning of tankers, bins and processing
equipment as well as in the on-site shop and amenities. Approximately 45% of the current
incoming water is estimated as ending up as tradewaste.
Table 3-2 Water, Chemical and Liquid Waste Estimated Volumes
Volumes Existing per year Volumes proposed per year
Water use* 14,220 kL 19,170 kL
Blood water** 2,034 kL 2,596 kL
Chemicals (sodium
hypochlorite, sanitiser, CIP,
42.9 kL 67.3 kL
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Volumes Existing per year Volumes proposed per year
Topax) ***
Liquid Waste 1. Tradewaste ^ 8,470 kL 11,290 kL
Liquid Waste 2. Fish Viscera
Waste ^^
1,400 kL 2,520 kL
Liquid Waste 3. Liquid
Fertiliser^^^
37.6 kL 37.6 kL (no change)
Solid Waste (general) 15 m3 collected 1-2 x per
week
15 m3 collected 1-2 x per
week
* Existing water use is based on billed water use quantities October 2014 – Sept 2015.
Proposed water use is estimated based on 1.5 x existing water use, during salmon processing
season.
**Existing blood water quantities are based on average percentages of salt water (29%) and ice
(8%) in a typical salmon delivery tanker. Proposed quantities are based on 18% salt water and
8% ice in a typical salmon delivery tanker.
*** Existing chemical volumes based on 12 months purchase records. Proposed volumes
estimated based on 1.5 x existing quantities.
^ Existing tradewaste volume estimated broadly based on 45% of current water use, 100%
chemical use quantities and typical blood water volumes. Proposed tradewaste volumes are
based on the 45% of the proposed water volume, and proposed chemical and blood water
volumes as described above.
^^ Fish viscera waste quantities are based on 20 kL every 3 days of production for 7 months of
the year, assumes 210 days of production per year. Proposed volumes estimated based on 20
kL every 1-2 days during the salmon processing months.
^^^ Existing liquid fertiliser quantities for 12 month period September 2014 – August 2015.
Proposed quantities are the same as current as this is not impacted by salmon production.
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3.2 Project Area
The project area occupies 4327 m2 at 38 - 44 Franklin St, Georgetown. Key information relating
to the project area is summarised in Table 3-3 below.
Table 3-3 Project area information (ListMap accessed 07/09/15)
Street Addresses 38-44 Franklin Street, George Town, TAS 7253
Approximate Grid Coordinates 486188E, 5448726N
General Description of site
The current site occupies 4327 m2 of Lot 1 on Plan 251964 (38-44 Franklin St, George Town). The site is located adjacent to other light industrial sites and is across the road from the South George Town Primary School (approximately 50 m). The nearest residential property is approximately 140 m away. There is vegetation around the boundary of the school (dry eucalypt forest and woodland) and to the north of the facility itself (classed as agricultural, urban and exotic vegetation). The nearest watercourse (York Creek) is over 500 m away and the Tamar Estuary is over 750 m away.
Title Identifiers Title Reference PID
251694/1 6438126
Owner Doumouras Investments Pty Ltd (proponent parent company)
Local Government Area George Town Council
Current and Historic Land Use Fish Processing Facility (historical use unknown)
Future Land Use Light industrial
Land Use Zoning George Town Interim Planning Scheme 2013 - Light Industrial (Zone 24)
Surrounding Land Uses
The immediate area to the north, east and south of the site is zoned light industrial (zone 24) and comprises commercial and light industrial premises. This area includes a commercial garden centre to west of Franklin St. The area immediately to the west is zoned residential (Zone 10) and includes the South George Town Primary School (approximately 50 m). The nearest residential properties are located mostly north of Victoria St (140 m) with some lower density residential properties close to Edgar St (400 m). There are some small areas zoned Open Space (Zone 19) located approximately 200 m to the north of the site.
Geology and Soil
The site sits on tertiary sediments from the Cenozoic era. Soil type is classed as Dalrymple association (Soils developed from Pleistocene littoral sands on gently undulating sand plains).
3.3 Map and Site Plan
© 2015. While GHD has taken care to ensure the accuracy of this product, GHD make no representations or warranties about its accuracy, completeness or suitability for any purpose. GHD cannot accept liability of any kind (whether in contract, tort or otherwise) for any expenses, losses, damages and/or costs(including indirect or consequential damage) which are or may be incurred as a result of the product being inaccurate, incomplete or unsuitable in any way and for any reason.
GHD\Launceston\32\2217760_LTN_01.cdr
Figure 3-3
Job Number
Revision A
32-17760
6 Oct 2015Date
GEORGE TOWN SEAFOODSEER PRODUCTION INCREASE
SITE LOCATION
21 Paterson Street Launceston 7250 61 3 6332 5500 61 3 6332 5555 [email protected] www.ghd.comT F E W
NLEGEND
General residential
Open space
Light industrial
Community purpose
Waterway
Paper size A4
0 100 200
Scale (metres)
PrimarySchoolPrimarySchool
LIGHT INDUSTRIALLIGHT INDUSTRIAL
NEAREST
RESIDENTS
NEAREST
RESIDENTS
CommercialGarden Centre
CommercialGarden Centre
SITE
LOCATION
GEORGE TOWNGEORGE TOWN
Tamar EstuaryTamar Estuary
York CreekYork Creek
© 2015. While GHD has taken care to ensure the accuracy of this product, GHD make no representations or warranties about its accuracy, completeness or suitability for any purpose. GHD cannot accept liability of any kind (whether in contract, tort or otherwise) for any expenses, losses, damagesand/or costs (including indirect or consequential damage) which are or may be incurred as a result of the product being inaccurate, incomplete or unsuitable in any way and for any reason.
GHD\Launceston\32\2217760_LTN_02.cdr
Figure 3-4
Job Number
Revision A
32-17760
6 Oct 2015Date
GEORGE TOWN SEAFOODSEER PRODUCTION INCREASE
SITE LAYOUT
21 Paterson Street Launceston 7250 61 3 6332 5500 61 3 6332 5555 [email protected] www.ghd.comT F E W
NLEGEND
Salmon Processing Area
Loading/unloading
Chemical storage
Waste storage
Wild fish
processing
area
Wild fish
processing
area
Tipping stationTipping station
Unloading of 1KL bins
finished product load out
Unloading of 1KL bins
finished product load out
Bulk tanker unloading bayBulk tanker unloading bay
Dewatering
station
Dewatering
station
Fin
ish
ed
pro
du
ct
load
ou
t
an
d c
hem
ical receiv
al
Fin
ish
ed
pro
du
ct
load
ou
t
an
d c
hem
ical receiv
al
Sodium hypochlorite
dosing
Sodium hypochlorite
dosing
CIP waterCIP water
Chemical dosing
for fresh water
treatment
Chemical dosing
for fresh water
treatment
Fresh water storageFresh water storage
Refrigerated waterRefrigerated water
Temporary
chemical
storage area
Temporary
chemical
storage area
Chemical dosingChemical dosing
Blood water
storage
Blood water
storage
Fish viscera
storage
Fish viscera
storage
Liquid fertiliserLiquid fertiliser
Trade waste
batching and
storage
Trade waste
batching and
storage
Blood waterBlood water
Liquid fertiliserLiquid fertiliser
Salmon processing
and storage
Salmon processing
and storage
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 13
3.4 Rational and Alternatives
The processing of farmed salmon at George Town Seafoods has previously been a manual
process. This manual process has limited the processing capacity of the operation. George
Town Seafoods have recently been issued with a planning and building permit from the George
Town Council to allow for a number of upgrades to the existing processing facility which will
provide the ability to process larger quantities of farmed salmon (development application
2015/18 approval issued 17/04/2015). The upgrades in particular allow for greater levels of
automation during the receival, gutting and grading processes.
The proposed increased production capacity addressed in this EER will result in an increase in
the people employed at the site. The increased salmon quantities will utilise the recent
upgrades to the facility and will therefore be produced with improved levels of hygiene,
biosecurity management and environmental control compared to past salmon production.
Due to the suitable location, space, services, and proven acceptable operation of the existing
site, no alternative sites for increased production capacity were relevant for consideration in this
proposal.
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4. Part C – Potential Environmental Effects 4.1 Flora and Fauna
The current site is fully cleared and free of vegetation. This site consists of concreted hardstand
areas, gravelled driveway and buildings.
As the project does not propose an expansion of the footprint of the current processing facility,
there will be no direct clearance or disturbance of any native vegetation or habitat areas
required.
The proposal does not involve any impacts to flora and fauna values of the site.
4.2 Rivers Creeks, Wetlands and Estuaries
4.2.1 Potential Impacts
As outlined in the EER guidelines, the project will not result in:
Stormwater draining to a river, creek, wetland or estuary;
Filling or excavating a river, creek, wetland or estuary;
Impounding a river, creek, wetland or estuary;
Works within within 200 m of a river, creek, wetland or estuary; or
Clearing of vegetation within 200 m of a river, creek, wetland or estuary.
Stormwater will be managed as per existing sites stormwater drainage system as the site
outdoor infrastructure will not change as a result of the Project. The parts of the facility that are
connected to stormwater runoff drains include downpipes from the building roof areas,
driveways and carpark areas.
Key areas within the site that have potential to leak or spill materials have drains installed to
capture runoff directly to the site’s tradewaste system or sewer (refer to Appendix B for further
information about existing containment areas). Therefore no direct impacts to rivers, creeks,
wetlands or estuaries are likely to occur as a result of the normal operation from the project due
to the drainage systems on site established to collect all contaminated runoff and liquids.
During abnormal conditions, spills of materials in the vicinity of site stormwater drains could
occur. The following two abnormal conditions or equipment failures have been considered for
potential impacts on stormwater.
Power failure
In the event of a power failure all processing will cease. Valves will default to closed positions
(e.g. pumping fish from tanker to dewatering station or pumping of tradewaste). All powered
processing areas are located within areas draining to the tradewaste, valves default to close
and no wastewater will be generated during the outage. Therefore there is no increased risk of
uncontrolled discharge to stormwater during a power outage. All salmon in mid process will be
removed and held in refrigerated storage. Depending on the length of the power outage – some
quantities of salmon may need to be disposed. This would be undertaken in accordance with
the sites biosecurity management plan (Appendix A) and is discussed in Section 0.
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Spills outside bunded areas
The current 28 kL blood water storage tank located adjacent to the bulk tanker and tradewaste
tanks in the wastewater area are located in a tradewaste drainage catchment. In the event of
small-moderate leaks from the tanks or pipework, drainage would be captured by the
tradewaste drainage. In the case of the blood water tank a small to medium spill may fall into
the tanker unloading bay pit which can contain up to 3000 L and directs all liquids to the
tradewaste system. In the event of a significantly larger leak from these tanks e.g. due to tank
rupture, it is possible for blood water or tradewaste to spill out onto the adjacent northern
stormwater drainage area. However the likelihood of a major tank rupture is considered
extremely rare and will not change with the proposed increased production. The existing
pumping stations are protected with bollards to prevent damage from on-site vehicle movement.
Similarly the current storages of fresh water, refrigerated water and CIP water along the eastern
end of containment area 2, although slope towards the tradewaste system do not have a bund
to contain significant leaks spilling out the eastern side. Small to medium leaks and spills
would be contained. The contents are fresh water and even in the result of tank rupture would
not result in any significant environmental impact. There is no traffic movement around these
tanks and regular inspections means that the risk of spills to stormwater from this area does not
increase with the proposed production.
4.2.2 Mitigation Strategies
Power Failure
No additional controls are proposed to mitigate risks to stormwater from power failure. The
existing drainage system and processes are regarded as sufficient to mitigate any impacts on
stormwater.
Spills out side bunded areas
George Town Seafoods plan to seal the northern driveway and install stormwater drainage
points in future (prior to the 2016/2017 salmon processing season). This will enable improved
control in the event of a spill in this area by isolating the stormwater drainage points with drain
covers to prevent any spill leaving the site.
Commitment 1 Implement plan to seal the northern driveway and install stormwater drainage points in future.
4.3 Significant Areas
The project is not located within or adjacent to an existing reserved area and no impacts to any
such areas are expected.
4.4 Coastal Zone
The project is approximately 750 m from the coast of the Tamar Estuary and there are no
impacts to coastal areas anticipated as a result of the project.
4.5 Marine Areas
As the project is restricted to an onshore location there will be no direct impact on sensitive
marine areas, conservation areas, or areas used extensively for recreational or commercial
fishing activities.
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The proposed project does not relate to fishing activities and only includes increased processing
capacity on shore. This application involves increased processing only and excludes any
consideration of increased salmon production at fish farm sites.
4.6 Air Emissions
4.6.1 Potential Impacts
Odour
Areas on the site that may be sources of odour include:
the bulk tanker unloading area;
salmon processing areas; and
the waste storage and processing areas.
The site is located within a light industrial zone. The nearest resident is approximately 140 m to
the north west. The South George Town Primary School property is located opposite the site to
the west approximately 50 m from the George Town Seafoods boundary and 80 m from the
processing area. A commercial garden centre is located in the light industrial zone
approximately 100 m to the north west (refer Figure 3-3). Prevailing wind direction is from the
west, away from the school and general direction of residents (Low Head wind speed and
direction 1998 – 2010 accessed from BOM 09/09/2015).
Owing to the existing facility dealing with fresh produce and waste only remaining onsite for
short periods, odour impacts offsite have not historically been an issue for the facility.
The increased number of salmon bulk truck deliveries in the salmon processing season from 2-3
per day to 4 per day will result in more frequent washing of tankers in the unloading area.
Consistent with the existing operation, due to the frequency of cleaning and the adherence to
the Approved Biosecurity Management Plan there is no additional risk of odours from this area.
Similarly, strict hygiene and disinfection requirements within the salmon processing area,
mitigates the risk of odour.
The most odorous area of the current operation is the liquid fertiliser waste processing area
(refer to Figure 3-4 for location). The liquid fertiliser waste processing facility is not impacted by
the proposed increases of salmon for processing as all wastewater during salmon processing
by-passes the liquid fertiliser plant for discharge to tradewaste. The liquid fertiliser waste
processing facility is influenced only by wildfish volumes, which are not affected by this
proposal.
All wastes generated from the proposed increased production will continue to be managed
strictly in accordance with George Town Seafoods Approved Arrangements for export
(GeorgeTown Seafoods 2015) and the George Town Seafoods Approved Biosecurity
Management Plan (Appendix A) to prevent cross contamination, quality and odour issues. The
requirements of the biosecurity plan and approved arrangements (e.g. disinfection regular
removal, controlled transport and disposal) mitigate any build-up of wastes or storage in
condition that generate odour.
The frequency of waste collection from the site following the proposed production will actually
increase therefore mitigating any risk of odours (refer Section 4.7 and Section 0 for further detail
on waste generation and removal).
In the event of power failure, the processing ceases to operate. All salvageable fish will be
moved to a cool store area until the power is restored. All liquid wastes stored on site will be
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removed daily or once every 1-2 days in the case of fish viscera. Waste holding tanks are
cleaned and disinfected when emptied to minimise the build-up of waste and potential for odour.
The process for disposal of any solid waste from a power failure is described in Section 0.
It is expected the potential for odour issues from the project will remain low, consistent with the
existing process, or may in-fact be lessened due to the increased frequency of cleaning and
waste pickups.
Dust
The unloading area to the North of the processing facility is accessed currently by a gravel
driveway from the Franklin St. There have been no prior issues in regards to dust in this area.
Traffic in this area will increase by up to five vehicles per day (refer Section 4.10 for further
information on proposed traffic changes).
Although the vehicle movements on the northern delivery driveway are expected to increase (by
approximately 4-5 vehicles per day), the speed of vehicle movement is restricted and there is
not expected to be any notable impact from dust due to the slightly increased activity.
4.6.2 Mitigation Strategies
Odour
Odours from processing areas are minimal and will continue to be frequently cleaned in
accordance with the facilities Approved Biosecurity Management Plan, Approved Arrangements
and Good Manufacturing Practice. This includes the regular removal of all wastes and cleaning
and disinfection of waste bins and tanks.
A complaint register will be maintained at site and odour or dust complaints dealt with
accordingly in line with EPA recommendations.
During abnormal conditions or power outage all wastes will continue to be managed in
accordance with site’s Approved Biosecurity Management Plan (Appendix A).
Dust
As part of the continued improvements on the site, George Town Seafoods have future plans to
seal the Northern driveway which will eliminate the risk of dust on site altogether. This action is
planned to occur prior to the second season of increased production (2016/2017).
Commitment 2 A complaint register will be maintained at site and odour, dust and noise complaints dealt with accordingly in line with EPA recommendations
4.7 Liquid Effluent
4.7.1 Proposed Conditions
The facility produces three liquid waste streams:
1. Tradewaste discharged under licence to TasWater;
2. Salmon viscera (guts) transported to Triabunna; and
3. Liquid fertiliser produced from wildfish wastes
Of these waste streams only the first two will be affected by the proposed production increase
as the third (liquid fertiliser) uses only wildfsh wastes which are not proposed for increase.
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A comparison of existing compared to proposed liquid waste volumes is provided in Section
3.1.6 in Table 3-2.
Tradewaste
Additional tradewaste from the salmon processing wash water will be generated and discharged
to TasWater George Town Sewage Treatment Plant (STP) under a tradewaste agreement with
TasWater. All tradewaste from the increased production will be managed by the site’s current
tradewaste management system. This includes preliminary screening on drainage points prior
to batch dosing with sodium hypochlorite and storage in bulk tradewaste tanks.
The current tradewaste is discharged under an existing (transitional) agreement D13/101 with
TasWater (issued 30 September 2015). This interim agreement includes a maximum daily
discharge of 90kL/day and specifies maximum flow rates from 8am – 4pm of 1L/s during
operating hours and up to 2L/s from 4 pm to 8 am.
All potentially contaminated areas of the salmon processing area will be captured and drained
to the site’s tradewaste management system as per the existing site conditions (refer Appendix
B – Current Containment Areas). The drainage systems capture all blood water from the tanker
unloading area, all drainage from the Northern unloading area and all drainage from the
processing areas (i.e. cleaning water) and wastewater management areas. Blood water from
the 28 kL tank in the unloading area is transferred to the 56 kL blood water tank prior to
blending with other factory waste water in the tradewaste storage tanks.
The tradewaste system includes two 22.8 kL tanks and one 20 kL storage tank in a bunded
area. The two 22.8 kL tradewaste storage tanks are batch dosed with sodium hypochlorite to
ensure that all wastewater from salmon processing is treated to control odour and prevent
spread of pathogens off the site. An oxygen reduction potential (ORP)of 400 mv in accordance
with the Approved Biosecurity Management Plan (Appendix A) must be maintained for a
minimum of 30 minutes prior to discharge off site to the George Town Sewage Treatment Plant
(STP).
The total wastewater storage capacity of the site is 149 kL. This is includes 65 kL tradewaste
storage (2x 22.8 kL tanks and 1x 20 kL tank) and two blood water storage tanks (56 kL and 28
kL).
The proposed increased salmon processing capacity is expected to result in an increase of
approximately 2820 kL of tradewaste over the 6-7 months salmon processing season (Table
4-2). This equates to an average volume of 13 kL/day, but may be higher on peak days.
Historically there has not been routine monitoring of tradewaste volumes. Proposed tradewaste
volumes presented in this EER are based on extrapolations from existing metered water usage,
measured chemical use quantities and records of salt water and ice volumes in salmon received
into the facility (as presented in Table 4-2). The current tradewaste estimate is based on a sum
of measured volumes and can be regarded as reasonably accurate.
Volumes of tradewaste as a result of the proposed salmon production increase have been
conservatively estimated based on likely portions of blood water, expected chemical
consumption and expected water use. Assumptions for these estimations are provided with
Table 4-2.
As there has not been regular flow monitoring it is not possible to determine what the maximum
daily discharge rate has been. However based on records of daily water use during peak times
and the assumption that 55% of water used is used in ice or ice water dispatched with product
or used for shop and site amenities, the maximum current discharge rate is likely to be
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approximately 55 kL/day1. The peak daily discharge during salmon processing months from the
proposed increase in salmon quantities is expected to increase and may be up to 80 kL/day
(Table 4-1 Likely Tradewaste Discharge Rates During Peak Salmon Production).
Table 4-1 Likely Tradewaste Discharge Rates During Peak Salmon Production
Volumes Likely maximum rates kL/day
- Current
Likely maximum rates kL/day
- Proposed
Tradewaste – peak 55 kL /day 80 kL/day
Tradewaste from the increased salmon production will not include fish viscera or solids from the
fish process operation. These sources of waste are segregated and managed separately (refer
section on Fish Viscera Waste below).
Table 4-2 Tradewaste and Component Volumes
Tradewaste Volumes Volumes Existing per year Volumes proposed per year
Water use* 14,220 kL 19,170 kL
Blood water (salt water, ice
and blood)**
2,034 kL 2,596 kL
Chemicals (sodium
hypochlorite, sanitiser, CIP,
Topax) ***
37.2 kL 55.8 kL
Total Tradewaste ^ 8,470 kL 11,290 kL
* existing water use is based on billed water use quantities October 2014 – Sept 2015. Proposed water
use is estimated base on 1.5 x existing water use quantities during 6-7 months salmon production.
** existing blood water quantities are based on average percentages of salt water (29%) and ice
(8%) in a typical salmon delivery tanker. Proposed quantities are based on 18% salt water and
8% ice in a typical salmon delivery tanker.
*** Existing chemical volumes based on 12 months purchase records. Proposed volumes estimated based
on 1.5 x existing quantities (i.e. increased in direct proportion to production quantities).
^ existing tradewaste volume estimated broadly based on 45% of current water use, 100%
chemical use quantities and typical blood water volumes. Proposed tradewaste volumes are
based on the 45% of the proposed water volume, and proposed chemical and blood water
volumes as described above.
Although tradewaste composition has not been routinely monitored, a series of analysis was
undertaken over 22 different production days between October 2014 and April 2015. The
average results from this analysis shown in Table 4-3 below show that the wastewater is within
the short term tradewaste limits established for the site. Results from the 2014-2015 analysis
show that sodium, BOD/COD and nitrogen concentrations of the wastewater exceed the
1 The average daily water use from February 2015 – April 2015 was 80 kL/day, peaks are
estimated at maximum 55 kL/day.
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possible TasWater long term limits. Long term limits however have not been finalised and will
be confirmed by TasWater following further analysis of Tradewaste from the 2015/2016 salmon
processing season.
Comparative calculations on sources of sodium (Table 4-4) reveal that the overwhelming source
of sodium in wastewater is likely to be and will continue to be from salt water received with
salmon product due to the volumes involved. The concentration of sodium calculated from
existing inputs (2158 mg/L from Table 4-4) was slightly more than the average actual tested
concentrations from production between October 2014 and April 2015 (1583 mg/L from Table
4-3). The calculated proposed sodium level from inputs should therefore represent a
conservative estimate of sodium concentrations.
The typical quantity of salt water (L) per kg of salmon received is currently 0.29 L/kg (29%).
This is expected to reduce to 18% with the increased salmon quantities processed due to larger
numbers of fish able to be included per bulk tank delivery. Due to the reduced portion of salt
water, the likely concentration of sodium in the wastewater will be lower, however the total
sodium loads are expected to increase from approximately 18.25 to 20.5 tonnes per year (Table
4-4).
Table 4-3 Existing Tradewaste Quality
Parameter
Unit Tradewaste Agreement long term limits
Tradewaste Agreement Short term
limits
Average GTS Tradewaste
Quality (n=22)
Temperature oC <38 <38 n/a
pH 6‐10 6‐10 7.70
BOD mg/ L TBA or 600 1500 756.5
COD mg/L TBA or 1500 6000 3561.9
Total Dissolved Solids (TDS)
mg/L <10,000 <10,000 8390 conductivity µs/cm
Total suspended solids (TSS)
mg/L TBA or 600 1500 446.7
Oil and Grease mg/L TBA or 200 400 126.0
Total Nitrogen mg/L TBA or 200 320 212.0
Total Kjeldahl Nitrogen (TKN)
mg/L TBA or 150 320 211.7
Ammonia mg/L 100 100 6.5
Total Phosphorus mg/L 50 50 15.7
Sulphate mg/L 1500 1500 309.6
Sulphite mg/L 15 15 4.75
Thiosulphate mg/L 300 300 15.2
Sulphide mg/L 1 1 0.26
Cyanide mg/L 1 1 0.06
Sodium mg/L 200 2500 1583
Bold denotes exceedance of the proposed long term tradewaste limits in the transitional TW
agreement.
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Table 4-4 Sources of Sodium in Tradewaste
Sodium Sources Annual volume Annual sodium loads
(tonnes)
Resultant
concentration in
tradewaste during
salmon processing
mg/L
Existing
Salt Water (incoming)
10,800 mg/L Na
1576 kL 17.0 2010 mg/L
10% Sodium
Hypochlorite (NaClO)
solution contains
37,000 mg/L Na
33.7 1.25 148 mg/L
Total 18.25 2158 mg/L
Proposed
Salt Water (incoming)
10,800 mg/L Na
2450 kL 19.0 1687 mg/L
10% Sodium
Hypochlorite (NaClO)
solution contains
37,000 mg/L Na
50.1 kL 1.5 133 mg/L
Total 20.5 1820 mg/L
Fish Viscera Waste
Fish viscera (guts) removed during the processing will be pumped and stored in a covered 28
kL tank as per existing processing conditions. The viscera waste will be stored in the tank prior
to collection via licensed transport to Triabunna in Tasmania for further processing. The
management of this waste source is conducted in compliance with George Town Seafoods EPN
8836/1 and the Approved Biosecurity Management Plan (Appendix A). Any solid waste from
the processing area floor or floor drains will be passed through the manual fish gutting station
for dosing and storage as per fish viscera waste.
The existing fish viscera waste 28 kL storage tank will be sufficient to store at least two days of
waste generated during the peak production time. The expected frequency of viscera waste
collection will therefore increase from once every 2-3 days (current peak production) to once
every 1-2 days (proposed peak production). The current designated transport vehicle can
continue to be used to transport the waste between George Town and Triabunna. As required
in the Approved Biosecurity Management Plan, all waste handling tanks and transport vessels
will be cleaned and sanitised prior to being used again. This is consistent with existing
operations.
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4.7.2 Potential Impacts
Tradewaste Volume
Based on the estimates made in this report, the tradewaste volume during the proposed salmon
peak processing periods is expected to remain within the maximum daily discharge limit of 90
kl/day specified in the existing TasWater Tradewaste Agreement. The estimated peak daily
discharge during salmon processing months based on Tradewaste volumes provided in Table
4-2 may increase to approximately 80 kL/day which is well within the maximum daily discharge
limit.
The proposed daily tradewaste volume is well within the storage and processing capacity of the
existing site (149 kL) and can be fully discharged each day whilst remaining within the maximum
discharge rate in the TW agreement of 1L/s during the day and 2L/s during the night.
Sodium and TDS
The sources of salt water and sodium hypochlorite will increase over the peak salmon
production process period (Table 4-4). Although the relative percentage of salt water per kg fish
received will decrease and concentrations of sodium in wastewater are likely to decrease, the
total annual load of sodium in tradewaste is expected to increase by approximately 14% (Table
4-4). As the Tradewaste is discharged to TasWater’s system via controlled batches, the sodium
concentrations and loads are not expected to vary greatly throughout the day. The seasonable
variability in sodium concentrations is expected to be very similar to what has been received
and accepted by TasWater in the past. The overall 14% increase in load will be due to higher
volumes of slightly lower concentrations during a peak 3 month period.
Nitrogen/BOD/COD
As a result of increased production it is possible that the concentration of blood and therefore
nitrogen and BOD/COD in the trade waste discharge may increase compared to the previous
average analysis (due to greater numbers of fish received per bulk tanker). TasWater have
indicated to George Town Seafoods that organic loading to the George Town STP is generally
received well as it helps balance other inorganic Tradewaste loads from the municipality. The
additional concentrations and/or loads are expected to follow similar trends to previous
Tradewaste accepted by TasWater and are not likely to cause a notable impact compared to the
current operation.
Spills to Trade Waste
Spills of liquid waste to the tradewaste area from the processing area or storage tanks are
unlikely to occur and the risk of spills should not increase with increased production quantities.
The existing bund containment capacity in the waste storage area is regarded as sufficient to
contain large volumes of process or wastewater (description of containment areas provided in
Appendix B. The existing storage capacity of the tradewaste system is 149 kL. This allows for
ample volume to store any spills to the bunded tradewaste drainage area and allow for
controlled discharge to the tradewaste system.
Fish Viscera Waste
The existing storage tank for fish viscera is sufficient to hold two days of the processing
quantities during proposed peak production and the existing bund around the waste tanks is
regarded as sufficient to manage risk of spills. Back up transport and disposal (via deep burial
at Remount Rd Landfill) is available should the existing waste tanker or disposal become
unusable. Therefore there are no adverse environmental impacts expected as a result of the
increased production quantities of salmon viscera waste.
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Biosecurity Risk from liquid waste handling
Potential impacts on biosecurity risks associated with liquid waste handling are discussed in
Section 4.11.
4.7.3 Mitigation Strategies
Tradewaste Volume
The automated salmon processing and bulk delivery, minimises the volumes of water required
for cleaning and processing. Therefore the increase in tradewaste volume will be minimised.
George Town Seafoods propose to maintain compliance with the maximum volume and
discharge rate requirements of their existing interim TasWater Agreement. The Tradewaste
Agreement includes a number of commitments in regards to improving the monitoring and
measurement of Tradewaste and a process to establish appropriate long term targets. This
includes the immediate installation of an in-line flow meter to continuously measure discharge
volumes.
Tradewaste Quality
George Town Seafoods will commit to undertake the required intensive monitoring program of
the salmon processing effluent in February 2016, as included in the Interim Agreement with
TasWater. The monitoring will be undertaken over 4 weeks and will include 3 daily composite
samples for each week. Parameters to be tested are currently being confirmed by TasWater
but are likely include pH, BOD/COD, TDS, TSS, nitrogen, Total Kjeldahl Nitrogen (TKN)
ammonia, sodium and sulphide. The results of this program will be used to determine
appropriate long term TW licence limits.
George Town Seafoods will undertake a regular monthly sampling program in compliance with
their tradewaste agreement with TasWater to confirm the key characteristics of the wastewater
and basis for TasWater charges to be calculated. This program is currently being determined by
George Town Seafoods and TasWater.
George Town Seafoods will continue to work with Tassal to reduce the volume of salt water
included in incoming salmon deliveries. A target maximum of 18% saltwater per bulk tanker will
result in at least a 16% reduction in sodium concentrations in final tradewaste volumes.
George Town Seafoods have recently identified opportunities to reduce the use of sodium
hypochlorite without compromising the biosecurity standards. This may result in further
reduction of TDS and sodium in the final effluent. The dosing and mixing of sodium
hypochlorite is currently manually operated and checked. Although not part of this project
George Town Seafoods have future plans to automate this process to further control the use of
chemicals.
Biosecurity Risk from liquid waste handling
Refer to Section 4.11.3.
Fish Waste
There are no proposed additional mitigation strategies for fish viscera waste as the existing controls are regarded as adequate. The following existing controls will be maintained:
All salmon fish gut and solid salmon waste is to be collected in the designated bunded
gut tank.
Regular daily or once every two day removal, cleaning and disinfection of fish viscera
waste tanks
Fish waste must only be transported off site using a registered and approved transporter.
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The fish waste is only to be delivered to EPA and Chief Veterinary Officer approved sites
such asSeafish Triabunna.
Back-up disposal of deep burial at the Remount Rd Landfill may be implemented (in
accordance with the Approved Biosecurity Management Plan) if all other approved
methods are unavailable.
Spills to Trade Waste
Due to the proposed increased use of the pumps and valves, regular condition inspection of the
pipework, unions, valves and tanks will be undertaken and preventative maintenance checks on
all pumps and valves will be scheduled on an annual basis in order to reduce the risk of a major
pipework leak.
A spill register will be maintained and all spills will be investigated to ensure root causes and
preventative actions are identified.
There are no proposed additional mitigation strategies for spills to tradewaste as the existing controls are regarded as adequate.
Commitment 3 Undertake all monitoring programs and activities in compliance with TasWater Tradewaste Agreement
Commitment 4 Continue to work with Tassal to reduce the volume of salt water included in incoming bulk salmon deliveries.
Commitment 5 Regular condition inspection of the pipework, unions, valves and tanks will be undertaken and preventative maintenance checks on all pumps and valves will be scheduled on an annual basis.
Commitment 6 A spill register will be maintained and all spills will be investigated to ensure root causes and preventative actions are identified.
4.8 Solid Wastes
4.8.1 Potential Impacts
The types of solid wastes generated in the process will be similar to the existing operation.
Sources of solid wastes include consumable items used in the delivery and processing of
salmon (e.g bin liners, gloves, hand towel, packaging etc.) and solid fish waste screened at
tradewaste drainage points in the site.
All non-fish consumable items will continue to be disposed of as required under the existing
Movement (Biosecurity) Permit MH 15-03 and Biosecurity Management Plan (Appendix A).
Consumable items include but are not limited to:
Bin liners for ITR and HOG, labels and cable ties.
Consumable items soiled during product handling and packing.
Hygiene garments, gloves, paper towel, and associated items that have been in contact
with fish or associated with secondary contact.
All consumable wastes will be disposed of in a designated salmon waste bin supplied by an
approved contractor. Management and disposal of the salmon waste bins will be in accordance
with the Biosecurity Permit (MH 15-03) and the Approved Biosecurity Management Plan
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Appendix A which requires use of bin liners and the requirement for all consumable wastes to
undergo deep burial at an EPA approved landfill Remount Road Landfill.
Any solid fish wastes (e.g. salmon waste from factory floor or drainage screens) will be minced
in the factory and added to the “gut” (fish viscera) tank. This will be undertaken at the manual
gutting station in the salmon processing area The waste salmon will then be managed in
accordance with fish viscera waste as described in Section 4.7.
The quantities of consumable items as solid waste are not expected to increase significantly.
This is because the proposed increase in salmon processing quantities will be delivered in the
form of bulk tanker deliveries only and therefore will not result in more bin liners for disposal.
The quantities of other consumables are not expected to increase significantly as the number of
processing days will not be increasing. The existing process controls and infrastructure are
regarded as sufficient to manage the increased quantities of solid wastes expected from the
increased production capacity and any association biosecurity risks.
4.8.2 Mitigation Strategies
The following existing waste management controls will be continued in accordance with the
Approved Biosecurity Management Plan:
Drains to the tradewaste and to the gut tank will continue to be cleaned daily to minimise
the likelihood of the presence of opportunistic vermin
Processing fish wastes will be placed in designated fish waste bins in the processing
factory.
Fish waste bins will be emptied daily, sanitised and reused.
All bins used for salmon and consumables associated with salmon from Macquarie
Harbour will be identified clearly and segregated from all other waste bins at the site.
All solid salmon wastes will be minced and added to the “gut” tank.
All consumable waste will be collected 1-2 times per week by a licenced waste
transporter and disposed of via secure landfill disposal.
Further detail on management of solid wastes for disposal is provided in the Approved
Biosecurity Management Plan (Appendix A).
4.9 Noise Emissions
4.9.1 Potential Impacts
Noise has not previously been a concern at the facility, given its industrial siting and distance to
nearest sensitive receptors (as shown in Figure 3-3) and the generally low noise emission levels
produced by the facility. The only previous potential source of nuisance noise has been limited
to the outdoor compressor for refrigeration and vacuum pumps. As identified in Section 4.6.1,
prevailing wind direction is from the west, away from the school and general direction of
residents (Low Head wind speed and direction 1998 – 2010 accessed from BOM 09/09/2015).
There are no new refrigeration compressors or noise generating plant and equipment proposed
as part of this production increase project. The project will result in increased use of recently
purchased and installed equipment.
The project will utilise additional fixed equipment (approved separately by Council) housed
within the existing facility that will emit noise at a similar level to that which is currently produced
within the facility. The new equipment in the processing area includes the two gutting machines
26 | GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760
and automatic weighing/grading machine. Any noise emitted from this equipment is attenuated
by the processing building walls which have been recently replaced.
Two new 15 kW vacuum pumps are currently being installed on the roof above the waste
processing area (approved separately by Council). These vacuum pumps, required during
operation of the automatic gutting machines, are fitted with mufflers to minimise noise emissions
and are located in a position such that noise from the running of the pumps with prevailing
westerly winds is most likely to travel in a north easterly direction.
The facility will maintain its operational hours to a maximum of 5 am to 5:30 pm during
weekdays and 5:00 am to 5:00 pm on weekends during the peak salmon processing season.
There have been no noise complaints recorded under the previous processing regime and the
majority of new equipment will be housed within the existing facility. The additional use of
processing machinery located at the site is not anticipated to produce peak noise levels
significantly above current operating levels.
4.9.2 Mitigation Strategies
A complaint register will be maintained at site and noise complaints dealt with accordingly in line
with EPA recommendations.
All noise emitting equipment will be regularly maintained. The existing maintenance contract
with local refrigeration mechanics for the maintenance of the aforementioned compressor
system will remain in place.
Should noise complaints be received, additional noise controls e.g. silencers or buffers can be
applied.
4.10 Transport Impacts
4.10.1 Potential Impacts
The Project will result in an estimated additional two tankers delivering salmon to the site during
mornings and conversely up to two additional trucks collecting processed product in the
afternoons.
As described in Section 4.7.1 there will also be additional trucks from current operation to collect
fish viscera waste for delivery to third party recyclers (currently once every 2-3 days and will
become once a day with the proposed production increase).
There is likely to be a small increase in small vehicle movements from the site from employees
and minor deliveries.
All traffic will enter and leave the site using existing transport routes.
The potential impacts from an additional five truck movements and increased small vehicle
movements to the area in any one day are not considered to be significant in terms of impact on
local roadways.
4.10.2 Mitigation Strategies
A complaints register will be maintained on site for any transport related issues that arise from
the Project.
As described in Section 4.6.2, the continuous improvement plans for the site include sealing the
Northern driveway. This action will eliminate the need for further maintenance on the gravel
driveway. This action is planned to occur prior to the second season of increased production.
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4.11 Other off site Impacts
4.11.1 Proposed Conditions
Fish originating from Macquarie Harbour on the west coast are known to carry Aeromonas
salmonicida and the Tasmanian aquabirna virus (pathogens), which are not found in south-east
Tasmanian waters. Therefore salmon product derived from Macquarie Harbour is required to
comply with biosecurity controls to prevent the spread of diseases present in the Macquarie
Harbour area to other locations in Tasmania.
Biosecurity risks associated with transport of salmon from Macquarie Harbour into the George
Town Seafoods processing facility are currently governed by a Movement (Biosecurity) Permit
MH 15-03 issued under the Animal Health Act 1995.
Under the existing biosecurity permit, GTS is approved to process salmon from Macquarie
Harbour into HOG and ship the product to the Tassal Margate and Huonville processing
facilities.
The movement (biosecurity) permit also allows GTS to discharge wastewater to the George
Town Sewage Treatment Plant (GTSTP) under strict disinfection conditions.
A copy of the permit conditions are provided in Appendix C.
George Town Seafoods has an Approved Biosecurity Management Plan provided in Appendix
A, which provides procedural controls and details on how the conditions of the Movement
(biosecurity) Permit will be achieved.
4.11.2 Potential Impacts
Additional sources of salmon received into the George Town Seafoods site have the potential to
impact on biosecurity should the existing controlled processes be insufficient for increased
volumes.
Impacts may occur with:
Movement of fish onto and off the site;
Disposal of plastic liners in transport containers;
Spread of diseases from movement of transport containers between regions; and
Disposal of blood, viscera and other waste.
4.11.3 Mitigation Strategies
Conditions for transport receival and processing of the increased salmon quantities at George
Town Seafoods will continue to be managed in accordance with the existing Movement
(biosecurity) Permit conditions (Appendix C) and the Approved George Town Seafoods
Biosecurity Management Plan (Appendix A).
A full description of the mitigation strategies is included in Approved George Town Seafoods
Biosecurity Management Plan (Appendix A). In summary, these include:
All unloading and loading of 1000 L bins containing salmon to and from transport vehicles
must be conducted on designated containment aprons in containment area 4 (refer
Appendix B).
All transport bins are to be cleaned and disinfected before being returned to areas used
for farming of fish.
All bulk tankers are cleaned and disinfected immediately after unloading prior to be
returned to areas used for farming of fish.
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The harvest tanker trailer must not be used to transport fish from regions other than
Macquarie Harbour unless it has been demonstrated that it has undergone appropriate
decontamination.
Where drains are at significant risk of collecting and releasing potentially contaminated
fish related water or liquid to the environment, the drain must have control measures
(closed valves) to hold the liquid (as described in Biosecurity Management Plan).
The Southern bin receival and HOG dispatch apron is managed during use by a manual
check of the strip drain that collects spillage from the area and manual disinfection and
washdown prior to release of the treated water to sewer. As spillage is rare and
accidental it is managed on a case by case basis by the factory supervisor.
If a spill occurs then any spilt fish are to be placed in a bin and secured, along with
salmon fish waste. All water from the spill and the clean-up water must be directed to
drainage to the tradewaste system and all vehicles and the area involved are to be
thoroughly cleaned and sanitised.
Disinfection of spill areas and drains must be carried out to ensure live pathogens do not
leave the site.
Drains to the tradewaste and to the gut tank are cleaned daily to minimise the likelihood
of the presence of opportunistic vermin.
All solid salmon wastes are to be minced and added to the “gut” tank.
All consumable waste will be bagged and placed in secure bins collected 1-2 times per
week by a licenced waste transporter and disposed of via secure landfill disposal.
A record of chlorine treatments of wastewater and residual levels achieved prior to
discharge is to be retained.
Further description of the drainage controls and management of tradewaste was provided in
Sections 4.2 and Section 4.7.
Commitment 7 Comply with the existing Movement (biosecurity) permit conditions (Appendix C) and the Approved George Town Seafoods Biosecurity Management Plan (Appendix A) at all times
4.12 Hazardous substances and chemicals
4.12.1 Potential Impacts
The site uses the chemicals as listed below in Table 4-5 for both stabilising waste products and
cleaning and sanitising the process and equipment. All chemicals used in cleaning and
sanitation are disposed to the tradewaste stream. A comparison of the chemical volumes used
in the existing operation and those proposed during increased salmon production are shown in
Table 4-5.
Table 4-5 Annual Chemical Volumes*
Chemical Purpose Current Proposed
Cleaning and Sanitising
Sanimaxx Sanitising 2000 L 4000 L
Topax Cleaning 4000 L 8000 L
CIP cleaner Cleaning 3,200 L 4,800 L
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 29
Waste Stabilisation
Sodium hypochlorite XY-12
Treating blood water
33,700 L 50,500 L
Other
Lubes etc. Minor quantities Minor quantities
Gas (storage) 8-16 bottles 8-16 bottles
*volumes of chemical are sourced from 12 months purchase records from March 2014 to April
2015.
The blood water and tradewaste is treated with XY-12 (sodium hypochlorite). The XY-12 is
delivered in 205 L drums (4 to a pallet) and then moved and placed in bunded areas adjacent to
the tradewaste storage tank or adjacent to blood water storage tank for use.
CIP Cleaner is a detergent used to clean out the salmon delivery tankers and the Transvac
System. CIP cleaner is dosed into water from a 5 kL storage tank as shown on Figure 3-4.
Topax is an alkaline chlorine type cleaner used in process area for cleaning machinery also
supplied in 205 L drums. Sanimaxx is an alkaline cleaner used to sanitize the factory equipment
and is supplied in 205 L drums.
All 205 L drums are delivered and temporarily stored on the northern hardstand area, adjacent
to the dewatering station prior to moving to their point of use. As described in Section 4.2, this
hardstand area (containment area 2), drains to tradewaste.
The volume of chemicals stored on site at any one time will remain similar to current, whilst the
frequency of use/ turnover will increase.
There are currently between 8 and 16 forklift gas bottles stored for forklift consumption. These
are stored in a designated area within a designated, approved BOC Gas crate. No change is
proposed to this gas storage.
Proposed delivery and usage volumes of most chemicals will increase, however the storage
volume held on site will remain the same. In the event of a spill all chemicals can be contained
within the tradewaste system. The existing containment and bunding is regarded as sufficient
and the additional chemical volumes are not expected to have any additional impact including
impact as a result of spills. There will be no impact on public health from the increased use of
chemicals on site.
4.12.2 Mitigation Strategies
No additional mitigation strategies are proposed to manage hazardous substances on site.
Existing storage bunds, containment and drainage controls as described in Section 4.7 and
Appendix B will be maintained.
Any chemical spill will be recorded and investigated by George Town to enable preventative
actions to be implemented on site.
4.13 Site contamination
The proposed production increase does not include any disturbance to soil or groundwater that
may have been contaminated in the past, therefore there will be no impact in relation to
contaminated land or groundwater.
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Consideration of impacts associated with liquid waste, spills, chemicals and stormwater are
dealt with separately in the relevant sections of this report.
4.14 Sustainability and Climate change
4.14.1 Potential Impacts
The proposed increase in production quantities will also be met through increased quantities of
fish transported in existing bulk tankers and more frequent deliveries of these tankers. Currently
during the peak processing period there are up to four tankers per day, but mostly two. The
proposed production increase will result in more consistent deliveries of four tankers per day.
There is no proposed change to the volume of 1000 L salmon bins received into the site.
The operational days and hours of the factory will remain the same as the current operation.
The use of automated equipment and recent site upgrades are contributing to the sites overall
improvement in energy and water efficiency.
The proposed increased production will result in increased use of water, chemicals, energy and
fuel; due to the additional transport, volume of fish received into the site, cleaning of tankers and
chemical treatment of tradewaste. However the use of materials, water and transport energy
will all improve per quantity of fish produced (i.e. the efficiency will improve). The water use per
tonne of salmon produced is expected to decrease by approximately 26%, whilst chemical use
per tonne of salmon is likely to decrease by approximately 16%.
The number of transport trips per tonne of salmon (due to the increased numbers of fish per
tanker) is expected to decrease by approximately 8 %.
Figures on total site power use are not available, however are also expected to increase overall,
whilst improving in efficiency (i.e. power use per tonne of salmon).
Emissions of greenhouse gases from the site may increase slightly from the use of bottled gas
on site. Similar to power use the overall efficiency of gas and greenhouse gas emissions per
tonne of salmon are expected to improve.
Figure 4-1 Proposed Improved Efficiencies
Existing Proposed % Reduction
Water Use Efficiency
(kL/tonne salmon)
26.4 19.6 26%
Chemicals Use
Efficiency (L/tonne
salmon)
7.4 6.2 16%
Tradewaste (kL/tonne
of salmon)
1.57 1.14 27%
Transport (number of
trips per 1000 tonnes
of salmon)
1.67 1.53 8 %
4.14.2 Mitigation Strategies
George Town Seafoods are continuing to improve the efficiency of their manufacturing site
through upgrades to the plant and equipment. The proposed increased in salmon processing
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 31
numbers will assist the site in achieving greater efficiency of water, chemicals and energy use
per tonne of product by getting greater utilisation out of equipment and processes.
4.15 Cultural Heritage
Heritage impacts are not applicable as no aspect of the proposed development will impact on
items of European or Aboriginal heritage. There is no planned disturbance on the existing
industrial factory site.
4.16 Sites of Public interest
The project site is located adjacent to the South George Town Primary School.
Potential noise and odour impacts on the South George Town Primary School have been
addressed in Sections 4.6 and 4.9. The project is not likely to cause an increased noise or
odour impact to the George Town Primary School.
Sections 4.6.2 and 4.9.2 identify mitigation measures that relate to potential odour and noise
impacts.
4.17 Rehabilitation
The project does not involve disturbance of land that will require future rehabilitation.
Rehabilitation requirements for the site remain consistent with those required for the existing
operation which is specified in clauses 20 -22 of EPN 7489-1.
George Town Seafoods will comply with their existing EPN 7489-1 in regards to the requirement
to notify the EPA upon permanent cessation of the business and to prepare a decommissioning
and rehabilitation plan which will include:
Removing or mitigating any environmental hazards or land contamination;
Stabilising any land surfaces that may be subject to erosion; and
Decommissioning any equipment that has not been sold.
32 | GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760
5. Part D – Commitments 5.1 Management Commitments
The following commitments shown in Table 5-1 are provided in relation to the proposed
production increase.
Table 5-1 Management Commitments
No Commitment EER
Reference
Completion Date Responsibility
1 Implement plan to seal the
northern driveway and install
stormwater drainage points in
future.
4.6.2 Prior to the
2016/2017 salmon
processing season.
George Town
Seafoods
2 A complaint register will be
maintained at site and odour, dust
and noise complaints dealt with
accordingly in line with EPA
recommendations
4.6.2,
4.9.2
Effective immediately George Town
Seafoods
3 Undertake all monitoring
programs and activities in
compliance with TasWater
Tradewaste Agreement
4.7.3 As per tradewaste
agreement
timeframes agreed
with TasWater
George Town
Seafoods
4 Continue to work with Tassal to
reduce the volume of salt water
included in incoming bulk salmon
deliveries.
4.7.3 Ongoing George Town
Seafoods and
Tassal
5 Regular condition inspection of
the pipework, unions, valves and
tanks will be undertaken and
preventative maintenance checks
on all pumps and valves will be
scheduled on an annual basis.
4.7.3 Effective immediately George Town
Seafoods
6 A spill register will be maintained
and all spills will be investigated
to ensure root causes and
preventative actions are
identified.
4.7.3 Effective immediately George Town
Seafoods
7 Comply with the existing
Movement (biosecurity) permit
conditions (Appendix C) and the
Approved George Town
Seafoods Biosecurity
Management Plan (Appendix A)
at all times
4.11.3 At all times George Town
Seafoods
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6. Part E - Public Consultation 6.1 Public consultation
Consultation in regards to this proposal has been undertaken with George Town Council, EPA,
DPIPWE Animal Biosecurity and Welfare Branch and TasWater.
A joint meeting with EPA and TasWater was held on the 6th August 2015 to confirm the
requirements and guidelines to be addressed in this EER.
A letter from DPIPWE Animal Biosecurity and Welfare Branch was sent to the EPA and passed
to George Town Seafoods on 6th August 2015. This letter detailed the requirement for George
Town Seafoods to submit a Biosecurity Management Plan for approval by the Tasmanian Chief
Veterinary Officer as part of this EER. Approval of the Biosecurity Management Plan for
George Town Seafoods was granted by the Chief Veterinary Officer on 1st December 2015 and
its content has been incorporated into this EER.
A meeting was held between George Town Seafoods and TasWater on 30th September 2015 to
discuss the Interim Tradewaste Agreement and to discuss the likely requirements following the
increased production.
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7. Disclaimer This report: has been prepared by GHD for George Town Seafoods and may only be used and relied on by George Town Seafoods and the EPA for the purpose agreed between GHD and the George Town Seafoods as set out in Section 1 of this report.
GHD otherwise disclaims responsibility to any person other than George Town Seafoods 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.
The opinions, conclusions and any recommendations in this report are based on assumptions made by GHD described in this report. GHD disclaims liability arising from any of the assumptions being incorrect.
GHD has prepared this report on the basis of information provided by George Town Seafoods 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.
The opinions, conclusions and any recommendations in this report are based on information obtained from, and testing undertaken at or in connection with, specific sample points. Site conditions at other parts of the site may be different from the site conditions found at the specific sample points. Investigations undertaken in respect of this report are constrained by the particular site conditions, such as the location of buildings, services and vegetation. As a result, not all relevant site features and conditions may have been identified in this report. Site conditions (including the presence of hazardous substances and/or site contamination) may change after the date of this Report. GHD does not accept responsibility arising from, or in connection with, any change to the site conditions. GHD is also not responsible for updating this report if the site conditions change.
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 35
8. References Australian Government Department of Agriculture (2015), Draft Aquaculture Farm Biosecurity Plan Guidelines and Plan Template.
EPA (2015) Environmental Effects Report Guidelines for George Town Seafoods Proprietary
Limited, Proposed Increase in Capacity of Fish Processing Factory 38-42 Franklin Street,
George Town.
EPA (April 2013) EPA general guidelines for preparing Environmental Impact Statements for
level 2B activities.
George Town Seafoods (02/12/2015) Approved Arrangements - Model Part 1
36 | GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760
Appendices
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 37
Appendix A – Approved Biosecurity Management Plan (Tassal November 2015)
Biosecurity Management Plan
for the Processing of Macquarie Harbour Fish
at the George Town Seafoods Processing Facility
Final
November 2015
Author: Malcolm Cummins
Environmental Coordinator – Processing
Tassal Operations Pty Ltd
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 1
TableofContents1. The George Town Factory ............................................................................................................... 3
Processing at the Facility ................................................................................................................. 3
2. Biosecurity Issue ............................................................................................................................. 3
3. Approvals ........................................................................................................................................ 4
4. Biosecurity Management Issues Identified Under This Plan .......................................................... 5
5. Biosecurity Management ............................................................................................................... 6
5.1. Containment ........................................................................................................................... 6
Issue ................................................................................................................................................ 6
Management ................................................................................................................................... 6
Control Points ................................................................................................................................. 6
5.2. Managing Spillage on Site ....................................................................................................... 7
Issue ................................................................................................................................................ 7
Management ................................................................................................................................... 7
Control Points ................................................................................................................................. 7
5.3. Delivery of MAQ Fish – MAQ Identification and Tracking ...................................................... 8
Issue ................................................................................................................................................ 8
Management ................................................................................................................................... 8
Control Points ................................................................................................................................. 8
5.4. MAQ ITR fish Delivery ............................................................................................................. 9
Issue ................................................................................................................................................ 9
Management ................................................................................................................................... 9
Control Points ................................................................................................................................. 9
5.5. Transport Vehicles – Vehicle Hygiene ................................................................................... 10
Issue .............................................................................................................................................. 10
Management ................................................................................................................................. 10
Control Points ............................................................................................................................... 10
5.6. Hygiene and bin management .............................................................................................. 11
Issue .............................................................................................................................................. 11
Management ................................................................................................................................. 11
Control Points ............................................................................................................................... 11
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 2
5.7. Wastewater Containment within Processing Operations .................................................... 12
Issue .............................................................................................................................................. 12
Management ................................................................................................................................. 12
Control Points ............................................................................................................................... 12
5.8. Management of Wastes for Disposal .................................................................................... 13
Issue .............................................................................................................................................. 13
Management ................................................................................................................................. 13
Control Points ............................................................................................................................... 13
5.9. Management of MAQ Fish Wastes ....................................................................................... 13
Issue .............................................................................................................................................. 13
Management ................................................................................................................................. 14
Control Points ............................................................................................................................... 14
5.10. Collection and Treatment of Contaminated Wastewater ................................................ 14
Issue .............................................................................................................................................. 14
Management ................................................................................................................................. 14
Control Points ............................................................................................................................... 15
6. Treatment of Wastewater ‐ Disinfection for Discharge ............................................................ 15
Issue .............................................................................................................................................. 15
Management ................................................................................................................................. 15
Control Points ............................................................................................................................... 16
7. Communication, Contacts and Review ..................................................................................... 16
7.1. Communication of this biosecurity plan ............................................................................... 16
7.2. Biosecurity contacts .............................................................................................................. 16
7.3. Review and audit................................................................................................................... 17
Attachment 1 – Site Plan ............................................................................................................... 18
Attachment 2 – Permit to move MAQ fish to George Town Seafoods ......................................... 19
Attachment 3 – Monitoring Record Form..................................................................................... 21
Attachment 4 – Daily Tanker Cleaning Protocol and Record Forms ............................................. 23
Attachment 5 Wastewater Treatment ORP Validation for Free Chlorine .................................... 27
Attachment 6 – Biosecurity Contact List ....................................................................................... 31
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 3
1. TheGeorgeTownFactoryThe George Town Seafoods factory (the facility) is located at 38 – 44 Franklin Street George Town.
The facility undertakes the processing of dead harvested Atlantic salmon (Salmo salar) “in the
round” (ITR) fish sourced from Macquarie Harbour (MAQ) into “head on gutted” (HOG) fish on
behalf of Tassal Group Limited, collectively referred to as the fish in this plan. The HOG are
subsequently shipped to markets on the Australian mainland or to a Tassal value add (VA)
processing facilities in Margate or Huonville.
The facility also processes wild caught spiecies for local and interstate markets and direct sale;
however this is managed as a separate activity, generally during times when Atlantic salmon are not
being processed.
ProcessingattheFacilityThe facility is designed to receive ITR in two ways – ITR are delivered to the site in insulated purpose
built road transport tanker units or when necessary in ‘chiller’ bins by road transport from Tassal
farms on Macquarie Harbour. An average of 400kg of fish per bin are delivered with ice and water
(blood water), or more usually fish in a tanker with ice and blood water in 8 tonne loads.
Bins of fish are delivered via the southern side of the facility (also the dispatch area) and moved
directly by forklift to the ITR bin storage area at the northern side of the facility. This arrangement is
only for a brief period at the beginning of the annual processing cycle until the tanker trucks are
brought into service the facility. Tankers unoad at a purpose built fully contained unloading and
dewatering station on the south side of the factory. The fish are then collected in insulated bins and
stockpiled for processing in the same secure area.
A plan of the site (the site plan) is provided in Attachment 1.
The ITR are fed into automated gutting machines that remove the gut under vacuum. The resultant
HOG are subsequently packaged for shipment or placed in ice slurry in a HOG bin for transport to a
VA facility in Tasmania.
2. BiosecurityIssueFish that originate from Macquarie Harbour on the west coast are known to carry Aeromonas
salmonicida and the Tasmanian aquabirna virus (the pathogens), which are not found in south‐east
Tasmanian waters. Macquarie Harbour together with all connecting bays and estuaries, is a
Restricted Area sub ject to a declaration in force under section 35 of the Animal Health Act 1995 (the
AHA). There are also pathogens found in south‐east Tasmanian waters that are not necessarily
endemic to all south‐east Tasmanian waters. Fish feedstock for the facility may carry the pathogens.
Protection of other restricted areas is essential and it is essential that the facility has the necessary
measures in place to ensure that all potentially contaminated wastewater and stormwater from the
facility is contained and managed appropriately.
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 4
The facility and its operation under this plan is within the existing context of Tassal’s “Farm Disease Management & Bio‐security Protocol” (internal document MO‐116), which has been developed to provide high level biosecurity management and to facilitate a coordinated, well informed and timely response to bio‐security risks and issues company‐wide. This is predominantly to ensure that there is no discharge of potentially contaminated waters to the marine environment.
3. ApprovalsGeorge Town Seafoods (GTS) currently operates under Environment Protection Notice 7489/1 (the
EPN), issued to George Town Seafoods Pty Ltd by the Director Environment Protection Authority
under Section 44(1)(d) of the Environmental Management and Pollution Control Act, 1994 (EMPCA),
which contains current conditions for the operation of the facility and permits the processing of up
to 5000t of product per year. A new land use planning permit for the processing of up to 10,000t of
product per year is currently being sought from George Town Council and an application for planning
approval has been submitted.
A permit(the Movement Permit) under Section 37 of the AHA, issued by the Chief Veterinary Officer
(CVO), of Animal Biosecurity & Welfare Branch within Biosecurity Tasmania, DPIPWE, is also in place
to allow the movement of the fish out of MAQ Restricted Area (RA) and into other designated
Restricted Areas. This permit allows the movement of ITR for processing into HOG and for the
movement of HOG to other approved facilities for value add processing.
Under the biosecurity permit, GTS is approved to process MAQ ITR into HOG and ship the product
to the Tassal Margate and Huonville processing facilities. The Movement Permit also allows GTS to
discharge wastewater to the George Town Waste Water Treatment Plant (GTWWTP) under strict
disinfection conditions. A copy of the permit in place at the time of preparation of this plan is
attached (Attachment 2). The facility meets the requirements of the Movement Permit for the
movement of MAQ fish.
The facility is permitted to pretreat it’s wastewater in batches to ensure disinfection and
subsequently discharge the wastewater to the GTWWTP operated by TasWater under a Trade Waste
Agreement (TWA).
This plan also complies with the Tassal Farm Disease Management and Biosecurity Protocol.
The following plan has been prepared for the biosecurity management of the facility in accordance
with any requirements of the Director and the CVO.
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 5
4. BiosecurityManagementIssuesIdentifiedUnderThisPlanThe following key aspects have been identified for operations at the facility addressed by this plan:
All potentially contaminated wastewater from all operations including ITR fish transport
bins, transport tanks, processing, and from cleaning is to be captured and disinfected on site,
in batches in accordance with an approved disinfection protocol.
All wastewater treated is to be comply with the CVO specified disinfection criteria of
maintenance of 1 mg/L free residual chlorine for a minimum of 30 minutes prior to being
discharged to the GTWWTP.
Any spillage during unloading, loading and bin movement at the facility must be captured
(i.e. prevented from entering unsecured stormwater drains) and the area and impacted
drains disinfected;
Any rare spillage captured in secured stormwater drains is to be disinfected with a suitable
chlorine solution and held for 30 min prior to release.
All transport vehicle unloading of MAQ ITR fish bins or dispatch loading of HOG fish bins,
uloading of ITR tankers, and internal handling of HOG fish is to occur in the respective
designated containment area.
Containment areas (contained hardstand aprons, bunds) are to be purpose built to collect,
contain and direct runoff (or facilitate pumping) to the wastewater disinfection system
(WWDS);
All storage of the fish and fish waste is to occur in a designated containment area.
All plastic bins liners and consumable items used in processing are to be segregated, bagged,
and enclosed in a lined skip bin then disposed of to landfill by deep burial;
All bins are to be segregated according to their origin, for cleaning, and for dispatch of
empties to MAQ;
MAQ harvest fish transport tankers are to be disinfected after load delivery and prior to
returning to service. The transport tankers are to be dedicated to the transport of MAQ ITR
fish until the end of the harvest season and they have been disinfected, sanitised and meet
the CVO requirements for service in other RAs;
ITR bins are not to be dispatched to SE Tasmania farms unless fully disinfected and sanitised
and meet the CVO requirements for service in other RAs and approved by Tassal senior
management.
MAQ HOG fish bins must not be reused for fish from another RA (must be dedicated to
movement of fish between GTS and processing premises at Margate and Huonville and not
taken to marine farms) unless fully disinfected and sanitised and meet the CVO
requirements for service in other RAs;
All MAQ HOG and harvest ITR bins must be clearly marked and identifiable;
Bins containing fish and fish waste must be clearly marked and identifiable as containing fish
from Macquarie Harbour; and
Solids from or contaminated with the fish are to be contained and disposed of at an
approved facility.
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 6
5. BiosecurityManagement
5.1. Containment
IssueThe loss of potentially contaminated fish related material or liquids to the off‐site environment must
be prevented.
The handling of the fish must be conducted within fully contained areas to prevent any loss of MAQ
related fish material or liquids to the off‐site environment.
ManagementThe handling, storage and processing of the fish must be conducted within fully contained areas
within the internal areas of the facility to prevent any loss of potentially contaminated fish related
material or liquids to the off‐site environment. These areas report all wastewater or potentially
contaminated stormwater to the facility’s drainage system reporting to the WWDS .
The facility’s designated containment areas, as shown on the site plan, are designed to ensure
contaminated wastewater and potentially contaminated stormwater is contained and treated by the
WWDS or manually disinfected. The containment areas are:
1. All internal processing areas, chillers and freezers of the factory
2. Northern tanker unloading dock and dewartering system, bunds, bin wash area and associated
hardstand.
3. The Waste Water Disinfection System and associated bunds.
4. The Southern receival and HOG dispatch apron.
The Southern bin receival and HOG dispatch apron is the only location that falls outside the facility’s
drainage system reporting to the WWDS.
ControlPoints All activities involving processing of the fish, fish storage, and fish waste management are to
be conducted within the facility in the containment areas and in a manner that ensures all
associated wastewater is captured and reports to the WWDS storage or direct to treatment.
As a minimum requirement containment areas 1, 2, and 4 and fork lifts are to be routinely
cleaned and sanitised when in use.
Vehicles are to be routinely cleaned and sanitised when in use.
Forklift vehicles are to have tyres sanitised prior to exiting the facility building.
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 7
5.2. ManagingSpillageonSite
IssueTo prevent pathogen transmission, any spillage of potentially pathogen contaminated water must be
captured and treated. Cross contamination between ITR bins and HOG bins must be prevented.
ManagementAll handling of MAQ fish, waste products and wastewater is done within designated containment
areas.
All unloading of MAQ ITR from both onsite vehicles and road transport vehicles are conducted on
designated containment areas 2 and 4, and loading of HOG on containment area 4.
Any spillage of potentially pathogen contaminated water is captured and treated in the facility’s
WWDS. All reasonable and practicable precautions are taken and containment measures are in
place to prevent the escape of fish solids and related liquids into the stormwater drains or off site.
The Southern bin receival and HOG dispatch apron is managed during use by a manual check of the
strip drain that collects spillage from the area and manual disinfection and washdown prior to
release of treated water to sewer. As spillage is rare and accidental it is managed on a case by case
basis by the factory supervisor.
If a spill occurs then any spilt fish are to be placed in a bin and secured with MAQ fish waste. All
water from the spill and the clean‐up water must be directed to drainage to the WWDS and all
vehicles and the area involved are to be thoroughly cleaned and sanitised.
Disinfection of spill areas and drains must be carried out to ensure live pathogens do not leave the
site.
ControlPoints All unloading and loading of bins containing MAQ ITR & HOG to and from transport vehicles
must be conducted on designated containment aprons containment areas 2 &4.
All handling of the fish and fish waste is to be done within the designated containment
areas.
Any spilt fish or waste must be collected and returned to a secure container immediately
and segregated with MAQ fish waste. Processing fish waste on the facility floors is to be
cleared as soon as practicably possible.
Any fish solids, fish related water or ice must be prevented from entering any stormwater
drains where it is reasonable and practicably possible to do so and be directed to the WWDS
drainage system.
Where drains are at significant risk of collecting and releasing potentially contaminated fish
related water or liquid to the environment, the drain must have control measures (closed
valves) to hold the liquid.
Spilt fish related water or ice or other liquid entering stormwater drains must be captured,
held in the drains where possible and disinfected.
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 8
Spillage, wash down and sanitising water must be collected and disposed of in the WWDS as
far as practicably possible.
The area is to be cleaned up as soon as possible, and the area sanitised.
5.3. DeliveryofMAQFish–MAQIdentificationandTracking
IssueHOG are to be delivered to the facility clearly identified as MAQ fish, recorded and traceable.
ManagementAll transport containers (insulated plastic with an insulated lid bins or “bins”) used within and
between restricted areas or are dedicated for the purpose and identified clearly and distinctly.
All bins holding fish from the restricted area are specifically and distinctly marked with the following
symbols:
VA MAQ HOG Symbol Macquarie Harbour Harvest (ITR) symbol
Each bin containing MAQ HOG destined for Value Add processing is also clearly marked and
identified by clearly marked bin labels containing details of the fish:
Harvest Date
Processing Date
HOG processing facility
VA facility destination
Records:
Records are to be maintained relating to the movement to and from the facility of MAQ ITR, MAQ
HOG, and by‐products (wastes), including the amount, description, the date of despatch and the
destination.
ControlPoints VA bins must be appropriately marked and labelled as above.
Records are to be maintained for at least two years relating to the movement of MAQ ITR
and HOG to and from the facility, including the amount, description, the date of despatch
and the destination.
Likewise records are to be maintained of all fish by‐products (wastes) disposed of from the
facility.
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5.4. MAQITRfishDelivery
IssueThe loss of potentially contaminated fish related material or liquids to the off‐site environment must
be prevented. The handling of the fish must be conducted in a manner that prevents any loss of
MAQ related fish material or liquids to the off‐site environment. Spillage and leakage presents an
unacceptable biosecurity risk.
ManagementMAQ fish are generally delivered by purpose built tanker. Tanker transport is specially designed to
prevent leakage and keep the fish and liquid contents contained. This is checked prior to
transportation and on arrival at GTS. However, when the tankers are unavailable the fish may be
delivered to the facility in marked bins, containing approximately 400kg of fish with approximately
250kg of ice each. Bin delivery is typically only short term until the close of the SE harvest.
The ITR bin storage is on the northern side of the plant. Bin deliveries use the southern apron for
forklift unloading and direct movement to the northern storage area well before use as dispatch
area. The southern apron is disinfected prior to using the area for bin dispatch.
The bins must be in good condition, have sealed bungs, no leaks or cracks and without spillage for
transport. However, the use of bins may afford an opportunity for leakage during transit if the bin is
damaged. To ensure this is managed, each bin of fish is lined with a plastic liner (bag) and ‘cable tied’
closed before the lid is secured to the bin. The bins are fitted with a lid that recesses into the top of
the bin, which is designed to prevent liquid splashing out of the bin at the bin‐lid interface. The lids
are also fixed down to the bin by cable tie.
Damaged bins must be immediately withdrawn from service, high pressure cleaned, sanitised prior
to repair, or be condemned. Condemned bins must be disposed of or be destroyed to ensure that
they do not enter another restricted area or put to alternative use in fish farming or fish processing.
This applies to bins used for harvested ITR transport and for HOG transport to Tassal VA factories.
ControlPoints Tanker transport is to be checked for leakage prior to transportation and on arrival at GTS.
Bins must be checked prior to each use for leak points and serviceability.
Bins with ITR must be moved directly from the delivery vehicle to the northern storage area.
The southern apron is to be isinfected prior to using the area for bin dispatch
Bins and lids must be fully sanitised prior to use.
Full bins must be plastic lined and the liner cable tied closed prior to dispatch.
Lids are to be properly fitted and cable tied down prior to dispatch.
Damaged bins must be marked or tagged and immediately withdrawn from service, high
pressure washed and sanitised, and segregated.
Condemned bins must be disposed of or destroyed such that they do not enter another
restricted area or be used in farming or processing for alternative use.
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5.5. TransportVehicles–VehicleHygiene
IssueMAQ ITR can at times be transported to the facility in accordance with the AHA permit in curtained
semi‐trailer road transport. Spills may occur during transit, a bin may be damaged and leak or a spill
may occur during unloading.
Transport vehicles carrying the fish are dedicated to the Restricted Area (RA) they service for the
period of the harvest season, unless approved to move between RA following sanitisation. Following
the completion fo the harvest season transport vehicles must be completely sanitised in an
approved manner as the vehicles may service other RAs.
ManagementIf there is a spill of the ITR or liquid during transport the driver is aware of, the driver is to notify the
facility manager whilst in transit if possible otherwise on arrival. The truck is to be parked on arrival
on the factory containment apron and the truck tray and tyres pressure cleaned and sanitised
thoroughly following unloading and before departure from the site.
If there is a spill of liquid or fish feedstock during transport that the driver is aware of, the driver is to
notify the facility manager whilst in transit if possible, otherwise on arrival. The truck is to be parked
on arrival within the facility for full cleaning and sanitisation.
Transport vehicles are dedicated to the RA they service; however, vehicles may service another
region if need be if fully sanitised in accordance with a standard protocol.
The vehicle tray or tank, wheels and wheel wells will be sanitised before loading clean bins to ensure
there is no potential pathogen transference.
Tanker trucks must be cleaned daily in accordance with the George Town Seafoods Standard
Operating Procedures and a record kept (Attachment 4).
End of season cleaning must include additional cleaning that ensures the vehicle is not contaminated
with fish residues.
ControlPoints In the event of any significant leakage or spillage of bins while in transit, the vehicle must be
secured on the southern containment apron and sanitised as soon as possible on arrival.
Spillage and sanitising wash water is to be collected where possible and further treated in
the WWDS.
If there is a spill of liquid or fish during transport or other related issue that may affect
biosecurity that the driver is aware of, the driver is to notify the facility manager or the
Tassal representative whilst in transit if possible, otherwise on arrival.
The truck tray (or tank) and tyres are to be pressure cleaned thoroughly with Hydrofoamer
concentrated detergent.
The truck must not leave the facilitiy’s containment apron until cleared to do so by the
facility manager or delegate.
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Trucks servicing one RA must not be used to service another RA unless cleaned, sanitised
and cleared to do so by the facility manager or delegate or as otherwise approved under this
plan.
GTS Form 59 is to be used to record tanker cleaning details and sign off using GTS Form
60. Records are to be kept with the GTS QA officer.
End of season cleaning must include additional cleaning:
fill tanker with double strength CIP cleaner solution and soal soak for 20 minutes
recirculate through system for 30 minutes
drain
fresh CIP solution is placed in the tanker as per normal CIP routine
tank and system is double rinsed with fresh water
visual inspection of tank
exterior wash and sanitize as per daily routine.
5.6. Hygieneandbinmanagement
IssueAll equipment in contact with the fish can potentially carry pathogens. Bins containing fish may leak.
Opportunity for pathogen transfer directly between RAs must be prevented by restricting the
movement of vehicles and bins that may carry pathogens between RAs.
ManagementAll equipment in contact with the fish must be cleaned and sanitised after use and before being
taken from the facility’s containment areas or off site. This specifically includes empty bins, other
containers, equipment, parts, and structures in possible contact with the fish.
Bins are to be thoroughly sanitised in accordance with Tassal’s current sanitisation protocols with QA
management, cleaned and segregated for transport, and transported on dedicated vehicles. Bins
must be appropriately sanitised and approved for use in a different RA.
Bins (and lids) are dedicated for use by marine operations or VA processing (Margate and Huonville)
and movement is to be restricted between the facility and the RA or VA processing facility of origin;
bins and lids are coded as such.
Bins may leak or spill during transit if the bin is damaged. The bins must be in good serviceable
condition, must have sealed bungs, no leaks or cracks. Damaged bins must be immediately
withdrawn from service, high pressure cleaned, sanitised prior to repair, or be condemned.
Condemned bins must be disposed of or be destroyed to ensure that they do not enter another
restricted area or put to alternative use in fish farming or fish processing.
ControlPointsBin cleaning and sanitising (and other containers, equipment, parts and structures):
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 12
All equipment in contact with the fish must be cleaned and sanitised after use and before being taken outside the facility building or off site.
Bins must be totally empty prior to commencing cleaning and sanitising.
The cleaning is to occur in a designated containment area within the facility and all water is to be collected and directed to the irrigation storage pond.
Bins must be high pressure cleaned and sanitised thoroughly.
Where applicable, clean bin lids must be applied once bins have been cleaned.
Where bins are to be dispatched to a different biosecurity zone, which must be as approved by the CVO, bins must be high pressure cleaned and sanitised following an approved disinfection protocol, and high pressure cleaned again.
All bins must be marked in a recognised manner indicating the RA or VA point of origin.
As a minimum colour coding is to be used for this purpose.
All staff associated with the handling of fish feedstock for the facility must be aware of
the bin colour coding or marking used.
All MAQ marked or colour coded bins are to be segregated following cleaning for
dispatch. These bins are not to be dispatched to SE Tasmania farms unless fully
disinfected and sanitised and meet the CVO requirements for service in other
biosecurity zones and approved by Tassal senior management.
Damaged bins must be immediately withdrawn from service, high pressure cleaned,
sanitised prior to repair, or be condemned.
Condemned bins must be disposed of or be destroyed to ensure that they do not enter
another restricted area or put to alternative use in fish farming or fish processing.
5.7. WastewaterContainmentwithinProcessingOperations
IssueAll potential pathogen contaminated process water is to be prevented from escape to the
environment. Wastewater from within processing operations needs to be captured and directed to
the facility’s WWDS for treatment.
ManagementAll the processing floor area in the factory within Containment Area 1 is fully contained with floor
drains that feed into the WWDS. The adjoining containment aprons also feed into the WWDS
system (one drain to stormwater is securely closed and is subject to regular inspection, cleaning and
disinfection).
ControlPoints All processing and handling of MAQ ITR, HOG and waste must be within a designated
containment areas.
All potentially pathogen contaminated process water from processing must be captured and
directed to the facility’s WWDS.
All drains in designated containment areas must have sufficient capacity to meet flow
demand and be kept clear and functional at all times and be in service.
Foreign objects must not be allowed to enter or be placed in or over the drains.
Fish solid residues must be prevented from entering drains as far as reasonable practicable.
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5.8. ManagementofWastesforDisposal
IssueConsumable items used in the delivery and processing of MAQ HOG, fish products and by‐products
can carry the pathogens. All non‐fish consumable items must be disposed of as required under the
AHA Movement Permit.
Consumable items include but are not limited to:
Bin liners for ITR and HOG, labels and cable ties.
Consumable items soiled during product handling and packing.
Hygiene garments, gloves, paper towel, and associated items that have been in contact with
MAQ fish or associated with secondary contact.
ManagementAll consumable items must be segregated for disposal at designated locations, segregated waste
clearly marked MAQ waste or similar. If it is reasonable and practicable to clean an item free of fish
residue it should be done (such as bin liners). Plastic bin liners are to be well drained, ‘bagged’
securely and placed in a dedicated hook bin for landfill disposal.
All wastes must be disposed of in a designated MAQ waste bin supplied by an approved contractor
(currently Veolia). Management and disposal of the waste in the MAQ waste bin is to be in
accordance with the AHA permit requirement for deep burial at an EPA approved landfill, Remount
Road Landfill.
ControlPoints All MAQ contaminated packaging must be disposed of as MAQ waste for deep burial.
All MAQ contaminated used consumables must be segregated for disposal as MAQ Waste.
If it is reasonable and practicable to clean an item free of fish residue it should be done.
Plastic bin liners are to be drained, ‘bagged’ securely and placed in a dedicated hook bin
located on a designated containment area for disposal by an approved contractor.
Management and disposal of the waste in the MAQ waste hook bin is to be in accordance
with the AHA permit requirement for deep burial at an EPA approved landfill.
5.9. ManagementofMAQFishWastes
IssueMAQ fish wastes are a high risk for carrying pathogens and secure containment is essential. MAQ
fish waste pathogenic risks are principally from:
Vermin, birds and other pathogen transmission vectors carrying the pathogen or pathogen
containing material.
Improper disposal.
Uncontained spillage and leakage.
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 14
ManagementAll solid fish wastes need to be secured in serviceable (i.e.no leaks and significant damage)
designated fish waste bins.
Fish viscera “gut” is pumped directly from the processing line into a bunded “gut” tank.
All fish wastes (i.e. whole fish) are minced in the factory and added to the “gut” tank. This prevents
access from birds or vermin. Drains to the WWDS and to the gut tank are cleaned daily to minimise
the likelihood of the presence of opportunistic vermin. There are no other fish wastes.
All of fish waste, viscera with some minced rejects go to Seafish Tasmania or will go to Tassal
Triabunna rendering plant. In the event that fish waste cannot be processed by these means, it will
be directed to Remount Road Landfill for deep burial with GTS solid wastes.
ControlPoints Processing fish wastes must be placed in designated fish waste bins in the processing
factory.
Fish waste bins must be emptied daily and sanitised.
All solid MAQ fish wastes (i.e. whole fish) are to be minced and added to the “gut” tank.
All MAQ fish gut is to be collected in the designated bunded gut tank where it may be
treated chemically to ameliorate odour and preserve gut quality prior to rendering.
Fish waste must only be transported off site using a registered and approved transporter.
The fish waste is only to be delivered to EPA and CVO approved sites such as Tassal
Triabunna for rendering or Remount Road Landfill for deep burial.
Drains are to be thoroughly cleaned daily to minimise the likelihood of the presence of
opportunistic vermin and other vectors.
5.10. CollectionandTreatmentofContaminatedWastewater
IssueAll potentially pathogen contaminated wastewater and stormwater must not be allowed to
transport pathogens off site and therefore must be captured on site within relevant processing,
loading, unloading, storage, and cleaning areas and directed for treatment to the facility’s WWDS.
ManagementMAQ ITR delivery bin and tanker water, processing wastewater, cleaning wastewater and
stormwater from Containment Areas is directed to the WWDS.
Cleaning of equipment of any nature, bins and vehicles used in the handling of MAQ HOG or
unpackaged fish product must take place on a containment apron with all water directed to the
sewer drains or other designated containment structure that is supported by such drains.
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ControlPoints Processing of MAQ ITR and handling of HOG product must take place within the confines of
the processing factory.
All potentially contaminated wastewater and stormwater must be directed to the WWDS.
Cleaning of equipment of any nature, bins and vehicles used in the handling of MAQ fish
must take place within a designated Containment Area, with all water directed to the
WWDS.
6. TreatmentofWastewater‐DisinfectionforDischarge
IssueAppropriate disinfection is necessary for the pathogens Aeromonas salmonicida and the aquabirna
virus prior to discharge of fully treated effluent into the Tamar Estuary from the George Town Waste
Water Treatment Plant (TasWater WWTP).
It should be noted that the latter pathogen, the aquabirna virus, is difficult to kill; however, any
infection that may be in the fish is likely to be removed with the viscera during gutting of the fish.
All wastewater may carry pathogens and cannot leave the facility site unless treated and disinfected
as approved, or it is to be treated and disposed of by other means approved by the CVO and the
EPA.
The facility treats all wastewater and potentially contaminated stormwater in the site’s wastewater
disinfection system to ensure that the wastewater is sufficiently disinfected prior to discharge to the
TasWater WWTP. The TasWater WWTP provides a second level of disinfection during the biological
treatment of the wastewater by the Plant. The combined process of disinfection is approved by the
CVO.
ManagementSolids in the wastewater and stormwater are captured by appropriate hardstand grates, processing
area floor drain grates, screens and traps or other suitable equipment to minimise fish solids from
entering the WWDS.
The facility wastewater disinfection system (the WWDS) consists of several bunded primary
treatment tanks into which wastewater is pumped and chlorinated by automatic dosing with sodium
hypochlorite. Wastewater is treated in batches and held on site until it qualifies for discharge. The
chlorinated wastewater is recirculated and dosed until such time as a free residual chlorine level of
1mg/L is reached. This level of free residual chlorine is maintained for at least one half hour. This
ensures that sufficient disinfection of the wastewater has been achieved.
Treated wastewater is tested using a Dulcotest DT1B Photometer. Batch testing is conducted by
sampling direct from the recirculation line from the tank and then immediately testing as per the
manufacturer’s instructions. All details are recorded on a monitoring record form (Attachment 3).
Oxidation Reduction Potential (ORP) is also used as a measure of disinfection. By maintaining sufficiently high ORP (mV) the level of disinfection is assured. ORP is the preferred form of
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 16
determining there is sufficient free chlorine (oxidiser) in the wastewater and disinfection potential within the wastewater.
A benefit of ORP as the disinfection level indicator is that ORP does not need to be combined with pH readings and adjusted for pH, and ORP can be relied upon when there is complex water quality such as produced by the George Town facility. ORP readings are also recorded on the disinfection record form.
Attachment 5 contains a comparison report following a study of ORP recordings taken in parallel with Dulcotest DT1B Photometer chlorine readings in January 2013. The report shows that by maintaining 400mV in the treated wastewater a free residual chlorine level of at least 1 mg/L is maintained (range of approximately 1 – 1.5 mg/L).
On approval of this plan, ORP will be the measure of disinfection potential in the wastewater per batch, for a minimum 30 minutes at an ORP level of 400mV prior to release to sewer to the TasWater WWTP. A Dulcotest DT1B Photometer chlorine reading will be taken daily for two weeks on annual commencement of MAQ fish processing, and on a weekly basis thereafter and as a backup.
ControlPoints All potential pathogen contaminated water must pass to the WWDS for treatment.
All containment area drains, processing area drains, associated pipework, are to be clear of
obstruction and fit for purpose.
Solids in the wastewater (including stormwater) must be captured by fit for purpose and
operational screens, traps, or other process prior to entering the WWTP system proper.
ORP is to be used to measure disinfection potential in wastewater batches.
Along with ORP, a Dulcotest DT1B Photometer chlorine reading is to be taken daily for two
weeks on annual commencement of MAQ fish processing, and on a weekly basis thereafter.
ORP readings and Dulcotest readings are to be recorded routinely on the monitoring record form (Attachment 3).
Wastewater and captured stormwater must be treated in batches for a minimum 30
minutes at an ORP level of 400mV prior to release to sewer to the TasWater WWTP.
ORP probes must be cleaned at least once a month and calibrated as necessary in
accordance with the manufacturer’s instructions.
7. Communication,ContactsandReview
7.1. CommunicationofthisbiosecurityplanThis biosecurity plan is to be communicated to staff by the GTS manager and the GTS QA officer,
and to Tassal staff using Tassal “QPulse” electronic document management and communication
system. Relevant standard operating procedures and task breakdowns for staff and contractors
will be developed within six months of approval of the biosecurity plan.
7.2. BiosecuritycontactsA list of contacts for biosecurity management, issues or events in relation to the facility is
provided in Attachment 6.
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7.3. ReviewandauditThe plan will be reviewed every three years to ensure it is current and fit for purpose. Auditing
against the plan will be conducted annually.
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Attachment1–SitePlan
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Attachment2–PermittomoveMAQfishtoGeorgeTownSeafoods
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George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 21
Attachment3–MonitoringRecordForm
Form 48 Waste Water Treatment – George Town Seafoods Reg. Est. 5485
Tank number (A or B):_______________ Date: _____________________
Start up checks
YES / NO If NO, record action taken
Sodium Hypochlorite stocks sufficient (min 2 Drums)
Dosing day tanks are full
Dosers functioning
Discharge valves closed
Infeed valves checked (only one tank valve open)
Supplementary dosing record
Add dosage of hypo before filling begins
YES / NO
Start circulating pump when tank at least 25% full
Controller reading (Mv)when 50% full
Controller and tank level recording (at start up and every 2 hrs. during production)
Production start time:_________________
Time of check Controller readings (Mv) Tank levels (Litres) Comments
Preparation for discharge
Time Tank full
Controller reading (min 320Mv)
Titration result* Manual dose required
30 minute titration***
YES / NO YES** / NO
*If the reading is min. 1ppm, wait 30 mins and titrate again. If reading is below 1ppm manually dose
tank and titrate again in 15 minutes.
**If YES, record the details of dosing in section below.
***If reading has consistently remained above 1ppm for 30 minutes proceed with discharge. If
reading is below 1ppm manually dose tank and titrate again in 15 minutes.
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Manual addition record
Time of addition Quantity added Reason for addition
Discharge record
Discharge NOT to occur until titration confirms min 1ppm has been achieved consistently for 30
mins
Discharge start time
Discharge end time Discharge valve closed
YES / NO
Comments
Completed by name: __________________________ Signature:
______________________________
Checked by QA: ______________________________ Signature:
______________________________
Form 48 – Waste Water Treatment V3 Issue date: 10/1/2013 Last Updated: 20/3/2013
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Attachment4–DailyTankerCleaningProtocolandRecordForms
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George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 25
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 26
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Attachment5WastewaterTreatmentORPValidationforFreeChlorine
George Town Seafoods
Wastewater Treatment ORP Validation for Free Chlorine
Introduction:
George Town Seafoods began processing Tassal’s Macquarie Harbour fish in January 2013. As it is
directly from another biosecurity zone the wastewater from this process must be fully contained and
treated on site prior to release to sewer.
Wastewater Treatment:
Wastewater is treated by dosing with sodium hypochlorite in batches in treatment tanks. The
analogy behind how to treat the wastewater is based on some testing performed at our Dover
facility on fish blood water. Several samples of blood water at differing dilutions were treated with
Hypochlorite with the aim to achieve better than 1mg/L of residual free chlorine after treatment.
1mg/L of residual free chlorine is maintained for at least 30 minutes to ensure full contact with
pathogens.
Measuring residual free chlorine:
Treated wastewater is tested using a Dulcotest DT1B Photometer for free chlorine.
A true free chlorine probe has to be installed in a low pressure (max 1 bar) sample line and has a
membrane which may clog if there are solids, oil or grease in the line. If there is salt water then a
total chlorine probe is used, which has the same, or similar membrane. Both types of probes
measure chlorine only and do not detect other oxidants, including chlorine dioxide, and are a much
better way to measure but must be kept clean. It was decided that the Chlorine Probes were not
suitable for the current application.
Oxidation Reduction Potential (ORP) is also used as a measure of disinfection. By maintaining
sufficiently high ORP (mV) the level of disinfection is assured. ORP is the preferred form of
determining there is sufficient free chlorine (oxidiser) in the wastewater and disinfection potential
within the wastewater. A benefit of ORP as the disinfection level indicator is that ORP does not need
to be combined with pH readings and adjusted for pH, and ORP can be relied upon when there is
complex water quality such as produced by the George Town facility.
The ORP probe monitors all oxidants in the water, one of which will be chlorine, and displays the
result in millivolts. It is not a chlorine probe per se but if chlorine is the major oxidant present then it
will give good control, which is the case. It is used as a low cost chlorine probe and is quite common
in simple water applications like swimming pools. It is also a glass probe and can take pressures of up
to 10 bar so can be installed in line, and is not as susceptible to oil, grease or other coating products.
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Graphed results:
Interpreting the results from the graph: It is concluded that a millivolt reading in the order of 400 Millivolts represents a residual free chlorine level of
between 1.0 – 1.5 ppm.
0
0.5
1
1.5
2
2.5
3
0
50
100
150
200
250
300
350
400
450
500
Date 9‐Feb 10‐Feb 11‐Feb 12‐Feb 13‐Feb 14‐Feb 15‐Feb 16‐Feb 17‐Feb 18‐Feb 19‐Feb 20‐Feb 21‐Feb
Series1 Series2
Millivolts versus ppm Chlorine residual
ppm/Chlorine
DateMillivolts ppm / Chlorine Residual
Millivolts
Dosing and Control:
From start of production in early January 2013 the dosing of hypochlorite into the wastewater has
been regulated and monitored continuously with a view to confirm the correlation between the
millivolt reading of the ORP probe and the Titrated Residual Chlorine required prior to release.
Application to George Town Seafoods chlorine dose monitoring:
The use of ORP as a legitimate alternative to the use of the Dulcotest DT1B Photometer for free
chlorine is considered legitimate in this application as it correlates well with the Photometer and is
reliable under the conditions in which it is used.
It is concluded that a millivolt reading in the order of 400 Millivolts will result in a residual free
chlorine level of between 1.0 – 1.5 ppm having been obtained.
After several months of dosing and control, coupled with significant monitoring, it is concluded that
the Wastewater Treatment System can be reliably run via this dosing control methodology.
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 24
George Town Seafoods Factory Biosecurity Management Plan for the Processing of Macquarie Harbour Fish Page 31
Attachment6–BiosecurityContactList
Contact Organisation Name Contact Number
Head of Supply Chain and
Commercial Services, Logistics
Tassal Operations Pty Ltd Ben Daley 0438 291 224
Manager (Director)
George Town Seafoods Pty Ltd
George Dourmouras 03 6382 3466
Quality Assurance Manager
George Town Seafoods Pty Ltd
Megan Lutz 03 6382 3466
Senior Manager Fish Health
Tassal Operations Pty Ltd Christine Huynh 0400 608 590
Senior Manager Wet Processing
Tassal Operations Pty Ltd Duane Baker 0427 870 867
Environmental Coordinator
Processing
Tassal Operations Pty Ltd Malcolm Cummins 0417 359 861
Senior Environmental Officer
Industrial Operations
EPA Division Department of Primary Industries Parks Water and Environment
Jane Rapkins 0407836203
EPA AH
1800 005 171
Senior Veterinary Officer
Aquatic Health &
Epidemiology
Animal Biosecurity and Welfare Biosecurity Tasmania Division Department of Primary Industries Parks Water and Environment
Kevin Ellard 6165 3260
38 | GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760
Appendix B – Current Containment Areas
From a biosecurity aspect, all areas contaminated with fish product are either treated by the
tradewaste management system or manually disinfected prior to release to the sewage system.
The containment areas are:
1. All internal processing areas, chillers and freezers of the factory (Tradewaste)
2. Northern tanker unloading dock and dewatering system, bunds, bin wash area and
associated hardstand (Tradewaste).
3. The Waste Water Disinfection System and associated bunds (Tradewaste).
4. The Southern receival and HOG dispatch apron (Controlled discharge to Sewer).
Each of the four containment areas have been identified in the figure shown below taken from
the Approved Biosecurity Management Plan (Tassal 2015).
The bulk tanker salmon unloading area (containment area 2) takes place over a large pit which
is capable of containing 3000 L of liquid. This area drains to the site’s tradewaste system and
captures all washdown water whilst cleaning out tankers. There is no risk of spills to stormwater
during normal unloading conditions. The 28 kL blood water storage tank is located adjacent to
the bulk tanker unloading area in a tradewaste drainage area (also in containment area 2). This
area is bunded by a concrete raised edge along the northern side of the concrete hard stand.
The slope of the concreted area is such that all spills flow from west to east and are captured by
a tradewaste drain.
Chemical and waste storages are located in tradewaste drainage areas (containment area 2
and 3). The waste storages and chemicals located in containment area 3 (wastewater
disinfection and bund) are fully bunded to contain liquids in the event of a spill or leak either in
their own stand-alone chemical storage bund (refer in Section 4.12) or the larger bund for the
whole wastewater storage area. Chemicals located in containment area 2 (the bin storage area
near the dewatering station) are either temporarily stored here until placement for use either in
containment area 3 or are placed adjacent to the blood water tank or CIP tank for dosing. As
described above any spills in this area flow east and are captured by the tradewaste drainage
system.
The Southern bin receival and HOG dispatch apron (containment area 4) is the only location
that falls outside the facility’s tradewaste capture system. The majority of this area is covered
(roofed) and drainage in the area is directed to the sewer. The project will not result in any
change to incoming raw salmon into the southern receival area of the factory. Increased
volumes of raw salmon will be received via bulk tanker unloading only. There will be increased
quantities of packaged finished product dispatched from the southern dispatch apron - however
this does not pose an increased risk of spills.
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760 | 39
Spill Containment Areas (Sourced George Town Seafoods Approved Biosecurity Management Plan v3)
GHD | Report for George Town Seafoods - Production Increase Environmental Effects Report, 32/17760
Appendix C Movement (Biosecurity) Permit
GHD
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© GHD 2015
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G:\32\17760\WP\22074.docx
Document Status
Rev No.
Author Reviewer Approved for Issue Name Signature Name Signature Date
0 S McLeod A. Jungalwalla On file A. Jungalwalla
12/10/2015
1 S McLeod D.Elson On file D.Elson On file 03/12/2015
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