ACTA Works Approval Application Response to Submissions 1 ... · ACTA Works Approval Application...

ACTA Works Approval Application

Response to Submissions 1 – 36

5 June 2019

Response to Submission One Issue: Truck Traffic Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,

• Hamilton Highway/Harvey Road/Shelford Road (for trucks travelling from Geelong and Melbourne)

• Midland Highway/English Road

• Midland Highway/Shelford – Bannockburn Road Issue: Odour

Response: Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection.

ACTA can confidently state that odour from its composting activities will not be noticeable to the surrounding community based on the following facts:

• Results from the odour modelling

• Results from the odour monitoring

• Observations undertaken during the 24 months that composting was undertaken at the site as part of the RD&D project

• The volume of feedstock received (5,700m3), and compost produced during the 24 months RD&D project

• The zero odour complaints received during the whole of the RD&D project

Response to Submission 2

Issue: Non Compliance with Rules and Regulations

Response: ACTA takes compliance with EPA and Council rules and regulations seriously.

Since completion of the RD&D project, the only activity currently being undertaken on the

site is the occasional mechanical screening of processed compost. ACTA does not need

permission from the EPA or the Council for this activity.

The claim that ACTA has a history of ‘bending rules’ is wrong. It is impossible to respond to

this claim in the absence of any information to support it.

Issue: Zoning

Response: The land is zoned FZ, i.e., Farming Zone. The Golden Plains Shire has previously considered a planning application to undertake composting activities on the site and its decision was that the proposal generally accords with the provision within the planning scheme and that it will not cause material detriment to any adjoining or surrounding properties.

Issue: Pollution of Waterways

Response: For waterways to be polluted there needs to be a link between the pollution

source and the waterway. All wastewater from composting activities will flow into a clay

lined storage at the composting site. The storage has the capacity to hold all wastewater

produced at the site, thus removing any link between site activities and any local

waterways.

Issue: Odour Nuisance

Response: There are enough examples of composting causing odour issues to surrounding communities for ACTA to realise this is a critical issue within both the community and the EPA. Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection. ACTA can confidently state that odour from its composting activities will not be noticeable

to the surrounding community based on the following facts:






Issue: Attraction to Flies

Response: All feedstock arriving at the site will be immediately mixed with green waste,

poultry manure and activator. The activator has the ability to destroy odour as soon as it is

added to an odour source. This was successfully demonstrated throughout the 24 months

RD&D project. So, the belief that the site will consist of piles of rotting organic matter is

totally wrong.

There is also minimal risk of fly breeding within the compost piles due to internal

temperature within the piles being in the range of 550 – 650C destroying fly larvae. There

was no evidence of fly breeding at the site during the RD&D project.

Issue: Visual Amenity

Response: The site is not visible from the nearby towns of Bannockburn and Teesdale and

other nearby residences. It is also screened from passing traffic by (a) mature trees on the

verge of the Bannockburn – Shelford Road. If the application is approved, further screening

will be provided by constructing a 1.5m high earthen perimeter mound that will be planted

with shrubs and trees.

Composting activities have been undertaken at the site for the past two years without

raising any concerns about visual impact from local communities.

Issue: Composting of Animals Response: The application does not include composting of animals at the site. Issue: Composting of Industrial Waste Response: Many types of organic waste are classified by the EPA as industrial waste. Many people in the community wrongly associate industrial waste with hazardous waste. The commercial viability of a composting business is dependent on the quality of the compost it produces. ACTA has clearly stated the types of organic waste it will accept. All these wastes are recognised by the composting industry as being capable of producing compost that meets the requirements of AS4454 and the EPA.

Issue: Environmental Risk Associated with Waste Transporting Vehicles Response: There are strict rules applying to waste transporting vehicles. All vehicles transporting waste to the site will have to comply with these rules. This includes the requirement for load security. Issue: Increased Traffic Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 truck movements (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,



• Midland Highway/Shelford – Bannockburn Road Issue: Impact on Quiet Rural Lifestyle Response: A major benefit of static pile composting is the fact that it is a relatively passive activity. Turning of windrows produces noise, dust and odour. These are largely absent from the ACTA static pile composting system. Composting activities at the site will certainly not impact on the Bannockburn and Teesdale communities. Issue: Non Compliance with EPA Licence Conditions Response: ACTA has invested over $200,000 undertaking the RD&D project. It has every incentive to protect this investment. It has demonstrated that its composting system produces compost that complies with the requirements of AS4454 and the EPA. The EPA’s

ability to control composting activities is well known to ACTA. Therefore, based on ACTA’s knowledge and experience with its composting system, its investment to date and the need to comply with EPA requirements, the community can be confident that it will be vigilant in complying with its EPA licence conditions.


Issue: Loss of Amenity

Response: The composting site will occupy two hectares on a farming property covering an

area of 316 hectares. The farming property and the surrounding land is zoned for farming.

Composting activities will have a low visual impact due to the compost windrows having a

height of 3 - 4 metres

No trees will be removed, in fact extra trees will be planted around the perimeter of the

site, thereby providing extra wildlife habitat.

Based on the above information, it is difficult to understand how the claim of ‘ruining a

good thing’ can be sustained.

Issue: Wind Impact

Response: ACTA has undertaken composting on the site over a period of 24 months without

experiencing problems with local wind conditions. The physical characteristics of the

feedstock and the compost, and not having to turn the compost means site activities are

relatively impervious to windy weather.

Issue: Odour

Response: There are enough examples of composting causing odour issues to surrounding communities for ACTA to realise this is a critical issue within both the community and the EPA. Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection. ACTA can confidently state that odour from its composting activities will not be noticeable to the surrounding community based on the following facts:



• Observations undertaken during the 24 months that composting was undertaken at

the site as part of the RD&D project




Issue: Health Risk

Response: The health risks associated with grease trap waste, abattoir waste and hatchery

waste are well known and understood by regulators. The EPA requires waste transporters

and persons who receive waste to be licensed. These licences have conditions attached that

are there to protect the environment and the community.

All communities produce a wide variety of waste. This waste has to be picked up and

removed. This occurs everywhere there is human activity. Bannockburn is no exception. This

will not change regardless of the existence of a composting facility.

The RD&D project has proved that the ACTA composting system produces compost that

complies with all the EPA’s health requirements, and that it does so in a manner that does

not create nuisance odours, fly breeding and vermin infestation.

Issue: Offensive Odour







Issue: Traffic Impact

Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 truck movements (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,



• Midland Highway/Shelford – Bannockburn Road

Issue: Traffic Noise

Response: The submission indicates that the writer believes the site will be open to the

general public. This is wrong. Access to the site will be restricted to vehicles authorised by

ACTA.

Based on the number of vehicles accessing the composting site compared with the number

of vehicles using local roads, it is difficult to sustain the case that this small number of

vehicles will result in a noticeable increase in traffic noise.

Issue: Amenity

Response: The composting site will occupy two hectares on a farming property covering an

area of 316 hectares. The farming property and the surrounding land is zoned for farming.

Composting activities will have a low visual impact due to the compost windrows having a

height of 3 - 4 metres

No trees will be removed, in fact extra trees will be planted around the perimeter of the

site, thereby providing extra wildlife habitat.

Based on the above information, it is difficult to understand how the claim of ‘unsightliness’

can be sustained.

Issue: Vermin

Response: The writer is under the impression that incoming waste will be piled up and

allowed to rot. Nothing could be further from the truth.

All waste arriving at the site will be unloaded into a concrete lined bunker and mixed with

green waste, poultry manure and ACTA activator and formed into a windrow. This

combination of waste characteristics, mixing with non-food organics and high temperature

makes the site unattractive to vermin.

Monitoring results from the 24 months RD&D project show that the windrows reach a

temperature of 450 – 550C within 24 hours of the windrow being formed and then rapidly

increase to a temperature of 550 – 650C, resulting in a biologically active compost mass, free

of hydrogen sulphide odour, indicating an absence of anaerobic conditions.


Issue: Fire Risk

Response: The risk of fire is closely linked to material characteristics/fuel and fuel quantity.

ACTA is proposing to compost high moisture content waste, i.e., grease trap waste, abattoir

waste and hatchery waste. All these wastes have a high moisture content. Thus they

represent a low fire risk.

The quantity of waste on site at any one time will be approximately 5,000 - 6,000m3 of

compost windrows, three metres high (the four metre height that is included in the works

approval application refers to compost that has completed the 12 weeks composting cycle

and has been stockpiled waiting to be screened).

The CFA has set its requirements after giving due consideration to these facts. It should also

be noted that there was not even a hint of conditions conducive to the outbreak of fire

during the 24 months of the RD&D project.

Issue: Control of Incoming Feedstock

Response: The only vehicles entering the site will be those authorised by ACTA. The site will

not be open to the general public. ACTA has invested over $200,000 in the RD&D project. It

will safeguard this investment by strictly controlling the quality of incoming feedstock.

Issue: Traffic

Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 truck movements (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. The three routes that can be used to reach the site are:






verge of the Bannockburn – Shelford Road and (b), if the application is approved, further

screening will be provided by constructing a 1.5m high earthen perimeter mound that will

be planted with shrubs and trees.



Issue: ‘Piles of Rotting Material’

Response: Language is capable of painting a variety of word pictures. Language like ‘piles of

rotting material’ paints a word picture of offensive odour, vermin and flies and risk to public

health. ACTA has undertaken a 24 months RD&D project at the site to demonstrate to the

EPA, and the local community, that its composting system produces compost without

creating nuisance odours, without creating a haven for vermin and which complies with the

EPA’s health/disease requirements.

Issue: Odour





• The volume of feedstock received (5,700m3), and compost produced during the 24

months RD&D project


Issue: Methane Pollution

Response: Far from creating methane, the ACTA composting system stops methane being

produced by diverting organic waste from landfill where it would produce methane and

composting it using the ACTA system, which prevents the establishment of anaerobic

conditions, as demonstrated during its 24 months RD&D project.


Issue: Endorsement of the benefits of the ACTA system

Response: If only more people shared the writer’s understanding of what the application is

capable of delivering!


Issue: Objection to the Application

Response: In the absence of any information concerning the application, the only response

ACTA can make is to state that the objection has been noted.


Issue: Odour







Issue: Public Health












Issue: Proximity to Teesdale

Response: ACTA wishes to acknowledge that it should have included the Teesdale

community when considering the impact of its proposed composting facility on surrounding

communities. The issues raised by the writer are addressed below.

Issue: Odour Monitoring

Response: In response to the question who will be monitoring odour from the composting

activities, in the first instance it will be ACTA for the obvious reason that if the application is

approved, by the time the facility becomes operational, ACTA will have invested over

$500,000 in the project. It will be in ACTA’s interest to protect this investment. If it fails to

control odour to the satisfaction of the EPA (and the community), it’s investment will be put

at risk.

Issue: Odour

Response: The short answer to the question of will there be nuisance odour for 10 weeks is

‘no’. The reason for this goes to the heart of the ACTA system, i.e., the ability of the ACTA

activator to destroy odour as soon as it comes into contact with a wide range of odours. This

property was demonstrated during the 24 months Research, Development and

Demonstration project. Further information on the odour performance of the ACTA system

is presented below.

There are enough examples of composting causing odour issues to surrounding communities for ACTA to realise this is a critical issue within both the community and the EPA. Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection. ACTA can confidently state that odour from its composting activities will not be noticeable to the surrounding communities based on the following facts:



• Observations undertaken during the 24 months that composting was undertaken at

the site as part of the RD&D project



Issue: Wastewater Management

Response: The wastewater dam has been designed to accommodate a 1 in 25 year storm

event. Obviously, the dam has to be kept empty so that it can fulfil this purpose. This will be

achieved by pumping water from the dam onto the compost windrows whenever there is

water in the dam. Compost windrow temperature will be in the range of 550 – 650C. These

temperatures are high enough to evaporate any surplus liquid.

Because the dam will be kept empty, or at worst depth of wastewater will be less than

0.5m, there will be insufficient volume for it to produce sufficient odour to be detectable.

Issue: Odour from Screening Activities

Response: The writer is concerned that screening the compost will generate excessive

odour. The reality is that odour is at its lowest level when the compost is ready for

screening. The reason for this is that the activator has the ability to rapidly break down

odour. This was demonstrated to the EPA when they were at the site to witness the mixing

of grease trap waste with green waste, poultry manure and activator. This odour destroying

property remains within the compost regardless of its age.

The 24 months RD&D project was an excellent opportunity to validate the claims that are

made in the above information, as well as validating the information that is contained in the

works approval application.

Issue: Flies and Vermin

Response: Monitoring results from the 24 months RD&D project show that the windrows

reach a temperature of 450 – 550C within 24 hours of the windrow being formed and then

rapidly increase to a temperature of 550 – 650C, resulting in a biologically active compost

mass.

All waste arriving at the site will be unloaded directly into a concrete lined bunker and

mixed with green waste, poultry manure and ACTA activator and formed into a windrow.

This mixing with non-food organics, and the high temperature makes the site unattractive to

flies and vermin. At no stage of the RD&D was there any evidence of fly or vermin

infestation.


Issue: Fire Risk



waste and hatchery waste. All these wastes have a high moisture content. Thus, they









Issue: Traffic

Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) truck movements per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,




Issue: Odour

Response: The writer states that windows in their house had to be closed due to the smell

from the compost site. It is impossible to know the source of the odour that forced the

closing of windows when no complaint is lodged. ACTA can only respond to this claim in the

manner outlined below.

Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection. ACTA can confidently state that odour from its composting activities will not be noticeable to the surrounding community based on the following facts:







Issue: Odour

Response: With regard to solving an odour problem within seven days, the operative word

is ‘within’. An early indicator of an odour problem developing is a drop in temperature. This

is the trigger for corrective action to start. If steps are taken to address the problem, then it

will be dealt with before it becomes an issue. ACTA has invested over $200,000 in the RD&D

project, so it will be vigilant in protecting this investment. Having said that, the ACTA system

is a robust system. It doesn’t depend on compost being turned on a weekly basis, it doesn’t

depend on a forced aeration system. It has been composting on the Bannockburn site for 24

months without causing nuisance odours to nearby residents or to the communities of

Teesdale and Bannockburn.

Issue: Local Flooding

Response: The composting site will have a perimeter embankment that will prevent

stormwater running onto the composting pad. In the event of heavy rain, the only

stormwater draining into the wastewater dam will be from rain falling directly onto the pad.

The wastewater dam has been designed to accommodate a 1 in 25 year storm event.

Obviously, the dam has to be kept empty so that it can fulfil this purpose. This will be


water in the dam.

Issue: Economic Benefits:

Response: Although the compost site will have only one full time employee, it will provide other, indirect benefits. Some of these are:

• Cost savings to local and regional food processors by providing a more cost effective and environmentally beneficial alternative to landfill

• Producing a quality compost that will improve soil health, thereby directly improving crop quality and productivity.

• Reducing the need for chemical fertilisers, thereby reducing on farm costs and reducing the risk of runoff from these fertilisers negatively impacting local water resources

• Providing a better environmental outcome for poultry litter from local growers than stockpiling on farmland

Issue: Impact on Property Values

Response: Composting is accepted as a legitimate activity associated with primary

production. So, there is no reason to believe that the operation of a composting depot that

would be located in a farming zone, and that will have to comply with EPA requirements,

will have a detrimental effect on property values.

Issue: Increased Traffic

Response: As can be seen from the information provided below, the number of truck

movements associated with the proposed composting facility compared with existing

vehicle movements is relatively minor.

ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,



• Midland Highway/Shelford – Bannockburn Road Regarding entry and exit of vehicles from the site, Vic Roads requirements will form part of any planning approval, and ACTA will have to comply with them before an EPA licence can be granted.


Issue: Amenity







raising any concerns from local communities about visual impact, odour, dust and other

issues commonly associated with composting sites.

Issue: Odour







Issue: Traffic

Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering

feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,





Issue: Compost Feedstock

Response: The primary requirement for compost feedstock is that it will produce compost

that meets the requirements of the Australian compost standard, AS4454 and EPA

requirements. EPA requirements include environmental impact, air quality, noise, public

health, etc. These requirements are designed to protect the environment and the public.

The writer refers to the site as being a ‘tip’. Nothing could be further from the truth. This

will be a facility that will have to comply with both strict planning and environmental

conditions, and that will have to produce compost that meets market requirements. ACTA

has so far invested $200,000 in the project. There are sound commercial reasons for it to

comply with the conditions that will control how it operates the site.

Issue: Traffic

Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,





Issue: Odour and Transfer of Bacteria

Response: Half of the organic waste/feedstock that would be delivered to the site will

consist of green waste that has been sorted to remove waste such as plastic bags, and other

foreign matter and then shredded. The other half will be delivered in fully enclosed tankers

or tip trucks. Odour emissions from these vehicles will be minimal.

The wastewater pond will be kept empty so that it can accommodate stormwater runoff

from the compost pad. When runoff occurs, it will be recirculated over the compost

windrows. Internal windrow temperature will be in the range of 550 – 650C, which means

they have the capacity to evaporate surplus water.

Regarding transfer of bacteria from the compost windrows, temperature of 550 – 650C is

sufficient to destroy all harmful bacteria. This was proved during the recent 24 months

RD&D project at the site.

Response Submission 18

Issue: Odour







Issue: Fire Risk



waste and hatchery waste. All these wastes have a high moisture content. Thus they




















Issue: Effect on Local Wildlife

Response: No trees have been removed, no wildlife habitats have been disturbed, so it is

difficult to understand how composting activities on two hectares of land previously used

for cropping and grazing would effect local wildlife.

Issue: Local Amenity









Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year.

Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,




Issue: Vermin




mass.





infestation.


Issue: Future Site Expansion

Response: If an increase in the size of the site was considered sometime in the future, it

would have to go through the same approval process that the current application is going

through, i.e., it would have to satisfy whatever planning and environmental rules applied at

the time.

Issue: Odour Corrective Action

Response: The short answer to the question of what would happen if corrective action

within seven days was ineffective is that ACTA would face the risk of the EPA suspending

composting activities until it was satisfied that the problem had been successfully resolved.

Given that ACTA, over the 24 months of its EPA approved RD&D project, has proved that its

system doesn’t create odour problems, and that it has invested over $200,000 so far in the

project, it is confident that this eventuality will not occur.

Issue: Wastewater Pond Management

Response: The writer is of the understanding that the wastewater dam will contain ‘blood,

guts and grease’. Nothing could be further from the truth! All feedstock is unloaded directly

into a concrete lined bunker, mixed with green waste, poultry manure and activator. It is

then formed into windrows. This means that ‘blood, guts and grease’ is thoroughly mixed

with material that will absorb and bind it, making it impossible for ‘blood, guts and grease’

to be available to flow into the wastewater dam.

Issue: Economic Benefits






Issue: Future Land Use

Response: A major factor in determining land value is its zoning. Currently, the land is zoned

for farming. If this changes to residential sometime in the future, then it is likely that the

compost facility would have to relocate.


Issue: Odour










Issue: Local Flooding







water in the dam.

Issue: Economic Benefits:











Issue: Future Site Expansion




the time.


Response: As can be seen from the information provided below, the number of truck

movements associated with the proposed composting facility compared with existing

vehicle movements is relatively minor.

ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,




Response to Submissions 21, 22, 24 and 27

Submissions 21, 22, 24 and 27 are identical.

Issue: Personal and Family Wellbeing, Loss of Enjoyment of Property

Response: Wellbeing and loss of enjoyment are essentially a matter of personal preference.

If an activity that meets all planning and EPA requirements manages to upset a person’s

wellbeing, and their enjoyment of their property, then it is beyond ACTA to deal with such a

subjective issue.

Issue: Odour







Issue: Pollution of the Natural Environment

Response: Before the EPA grants ACTA a composting licence, ACTA has to satisfy the EPA

that its application will not cause environmental harm. This is an extremely rigorous

process. It has required ACTA to undertake a 24 months Research, Development and Design

project, which included a comprehensive testing program. This was followed by the

comprehensive works approval application process. These measures are in place so that the

EPA can be satisfied that ACTA’s activities will not result in pollution of the natural

environment.

Issue: Traffic

Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,





Issue: Hazardous Waste

Response: It’s difficult to know exactly what the writer means by hazardous waste. ACTA

assumes that the writer believes that grease trap waste, abattoir waste and hatchery waste

is hazardous. The EPA has specific requirements regarding the transport, receipt and

treatment of these wastes. When these requirements are followed, any hazards associated

with these wastes will be managed in the required manner.













Submission 25 is identical to Submission 11. The response to Submission 11 is reproduced

below.

Issue: Proximity to Teesdale

Response: ACTA wishes to acknowledge that it should have included the Teesdale

community when considering the impact of its proposed composting facility on surrounding

communities. The issues raised by the writer are addressed below.

Issue: Odour Monitoring

Response: In response to the question who will be monitoring odour from the composting

activities, in the first instance it will be ACTA for the obvious reason that if the application is

approved, by the time the facility becomes operational, ACTA will have invested over

$500,000 in the project. It will be in ACTA’s interest to protect this investment. If it fails to

control odour to the satisfaction of the EPA (and the community), it’s investment will be put

at risk.

Issue: Odour

Response: The short answer to the question of will there be nuisance odour for 10 weeks is

‘no’. The reason for this goes to the heart of the ACTA system, i.e., the ability of the ACTA

activator to destroy odour as soon as it comes into contact with a wide range of odours. This

property was demonstrated during the 24 months Research, Development and

Demonstration project. Further information on the odour performance of the ACTA system

is presented below.

There are enough examples of composting causing odour issues to surrounding communities for ACTA to realise this is a critical issue within both the community and the EPA. Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection. ACTA can confidently state that odour from its composting activities will not be noticeable to the surrounding communities based on the following facts:






Issue: Wastewater Management




water in the dam. Compost windrow temperature will be in the range of 550 – 650C. These

temperatures are high enough to evaporate any surplus liquid.

Because the dam will be kept empty, or at worst depth of wastewater will be less than

0.5m, there will be insufficient volume for it to produce sufficient odour to be detectable.

Issue: Odour from Screening Activities

Response: The writer is concerned that screening the compost will generate excessive

odour. The reality is that odour is at its lowest level when the compost is ready for

screening. The reason for this is that the activator has the ability to rapidly break down

odour. This was demonstrated to the EPA when they were at the site to witness the mixing

of grease trap waste with green waste, poultry manure and activator. This odour destroying

property remains within the compost regardless of its age.

The 24 months RD&D project was an excellent opportunity to validate the claims that are

made in the above information, as well as validating the information that is contained in the

works approval application.





mass.





infestation.


Issue: Odour








Issue: Non Compliance

Response: The EPA inspection report seems to deliberately present the site in the worst

possible light! The reason for the grease trap waste not being mixed and windrowed is

because the advice that ACTA gave to companies delivering waste to the site that the site

was no longer accepting waste was ignored.

The statement that there was ‘a large quantity of chicken mortalities’ gives the impression

that the mortalities were in a large pile exposed to the elements. This was not the case. The

mortalities had been received several weeks before the inspection, mixed with green waste,

poultry manure and activator and windrowed. The windrow had been remixed and as

remixing wasn’t included in the conditions attached to the Research, Development and

Demonstration approval, the mortalities feedstock had to be omitted from the project.

The statement that there was ‘a large quantity of …….. plastic….’ also creates the impression

that feedstock was contaminated with waste plastic. In fact, the plastic was heavy duty

plastic film on which the compost windrows had been placed. When windrows reached

maturity, they were moved off the plastic. It was this remnant plastic that was observed by

the EPA inspector.

Why the EPA inspector felt the need to state that the compost had not been screened is

unknown. The compost had reached maturity, and there was no immediate need to screen

it.

The statement that ‘The odour from abattoir waste and chicken mortalities; the leaching of liquid waste; the presence of vermin and flies, the unsightly high compost heaps and this at the entrance to our town!’ must be challenged. There was no evidence that odour from abattoir waste and chicken mortalities had migrated from the site. In fact, the odour modelling and monitoring results show that odour from the site was barely noticeable at a distance of 200m from the odour source. There was no evidence of vermin throughout the 24 months of the RD&D project, nor was there any evidence of fly breeding within the compost windrows during this time. The need to refer to stockpiled mature compost as ‘unsightly high compost heaps’ is surprising. The stockpiles had the physical appearance of soil, why this would be offensive in a farming zone is questioned. Issue: Public Health



















Issue: Property Values


production. So, there is no reason to believe that the operation of a composting depot

located in a farming zone, complying with council planning and EPA requirements, will have

a detrimental effect on residential property values.



Response: The facility received and successfully composted grease trap waste over a period

of 24 months. Due to a misunderstanding between ACTA and the company delivering grease

trap waste to the site, an unexpected and unauthorised delivery was received. This was the

extent of the non-compliance.

Issue: Buffer Zone

Response: The odour modelling report clearly shows that the buffer zone is more than

adequate to prevent odour impacting the communities of Teesdale and Bannockburn and

surrounding residences. The following information explains why this is so.








Response: The writer is concerned that the material received at the site ‘is likely to contain product that has a zoonotic disease potential, this includes abattoir waste material and hatchery waste material.’

The NSW Department of Primary Industries offers the following description of zoonotic

diseases:

“Zoonotic diseases are infectious diseases that can pass from animals to humans. Seventy-five per cent of new human diseases are zoonotic. Some zoonotic diseases, such as Hydatids, Anthrax, Hendra virus infection, Avian influenza or Rabies can be very serious in humans and may cause fatalities. It is important that people who handle or treat animals are aware of the risk of zoonotic diseases. It is not possible to eliminate all risks associated with zoonotic diseases. However, people can take steps to reduce the likelihood of getting a zoonotic disease. Examples include: avoid or minimise contact with potentially infective animals, or use personal protective equipment (PPE) when handling infected animals or their products.”

It can be seen from the above, that people who are in contact with animals are at the

greatest risk of infection from zoonotic diseases. There is no direct contact between the

compost facility and live animals, let alone live diseased animals. Hatchery waste, as the

name implies consists of egg waste, dead chicks and washdown water. The risk of infection

from this source is negligible. For abattoir waste to contain zoonotic diseases, it would mean

that the abattoir had bought diseased stock. This is also extremely unlikely due to the strict

health regulations applying to abattoirs.

The claim that zoonotic diseases including a range of viruses are known to be common in poultry and abattoir waste is challenged. No evidence was uncovered that stated abattoir waste was a source of zoonotic diseases. The only link to poultry was through feathers from diseased birds. The risk of day old chicks carrying a zoonotic disease through their downy cover is considered to be negligible. There is no foundation to the suggestion made by the writer that ‘The products proposed to be accepted by the facility have the potential to come from farms that are destocking & decontaminating due to disease outbreaks such as Highly Pathogenic Avian Influenza, Low Pathogenic Avian Influenza, Salmonella, Listeria and Newcastle Disease.” The EPA required ACTA to test feedstock before and after it was composted for pathogens

and viruses. All feedstock and compost passed the tests.

Issue: Feedstock Handling

Response: The writer is concerned that ‘The product being stored on site prior to being used in the composting process, would be open too wild birds and feral animals. This has the potential to spread any disease through their respective populations and exposing local domestic bird populations. Stored product including liquid waste needs to be contained in a manner that cannot be accessed by wild birds and feral animals.’

There will be no stored feedstock on site. This plainly stated in the works approval

application. All waste arriving at the site will be unloaded directly into a concrete lined

bunker and mixed with green waste, poultry manure and ACTA activator and formed into a

windrow.

Issue: Odour

Response: The writer is concerned about odour from stored feedstock. Again, the point is

made there will be no storage of feedstock. It will be unloaded and treated immediately it is

unloaded.

Issue: Testing of Compost

Response: Testing of compost is a commercial matter that will be implemented by ACTA on

an as needs basis. This is standard practice in the composting industry.

Issue: Operating Hours

Response: ACTA has stated its preferred operating hours in its planning application. It is up

to the council to decide whether they are reasonable.

Issue: Composting on Significant Agricultural Land

Response: The writer states that ‘a composting facility is not in line with the protection of the land for the purpose of farming. Nothing could be further from the truth. It is a well known fact amongst agronomists that soil health all over Australia is deteriorating as a result of current farming practices stripping carbon from the soil and overusing chemical fertilisers. Compost is now being recognised as a means to restore soil health by increasing soil carbon, which then allows bacteria and fungi to transform nutrients into a form that can be taken up by the plant. Increased plant vigour then allows the plant to absorb atmospheric carbon (CO2) and atmospheric nitrogen. If all farms used their organic residue to make compost, food production would achieve a much needed boost.


Issue: Odour Corrective Action










Issue: Flood Management







water in the dam. Because internal windrow temperature is in the range of 550 – 650C, the

windrows have the capacity to evaporate surplus water.

Issue: Property Value



would be located in a farming zone, and that will have to comply with council and EPA

requirements, will have a detrimental effect on property values.

Issue: Traffic

Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year.

Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,



• Midland Highway/Shelford – Bannockburn Road Regarding entry and exit of vehicles from the site, Vic Roads requirements will form part of any planning approval, and ACTA will have to comply with them before an EPA licence can be granted. Issue: Future Expansion




the time.

Issue: Impact on Wildlife

Response: The writer is concerned that feedstock received at the site will be eaten by

wildlife and or carried from the site.



The windrow is then covered with a 200mm thick layer of either green waste or mature

compost. This means that any of the feedstock that may attract wildlife is now in a form that

no longer is capable of attracting wildlife to the site. At no stage of the 24 months Research,

Demonstration and Development project was there any evidence that wildlife was being

attracted to the site.
















the EPA inspector.



it.

The statement that ‘The odour from abattoir waste and chicken mortalities; the leaching of liquid waste; the presence of vermin and flies, the unsightly high compost heaps and this at the entrance to our town!’ must be challenged. There was no evidence that odour from abattoir waste and chicken mortalities had migrated from the site. In fact, the odour modelling and monitoring results show that odour from the site was barely noticeable at a distance of 200m from the odour source. There was no evidence of vermin throughout the 24 months of the RD&D project, nor was there any evidence of fly breeding within the compost windrows during this time. The need to refer to stockpiled mature compost as ‘unsightly high compost heaps’ is surprising. The stockpiles had the physical appearance of soil, why this would be offensive in a farming zone is questioned.


Issue: Feedstock Type and Source

Response: The writer is concerned that animal body parts and faeces from all over the state

will be received at the site and therefore introduce disease to the local livestock.

The only feedstock that contains body parts is abattoir waste. It is important to state that

abattoir waste does not include dead animals. It does include hooves, horns and pieces of

skin and flesh. Abattoirs have strict measures in place to prevent the entry of diseased

stock. This means that there is no source for diseases in abattoir waste.

The only animal faeces that will be received at the site is poultry manure. Poultry manure is

currently received and stockpiled on many farms without any form of regulatory control,

which indicates it is considered to represent a low biosecurity risk.

Another important disease control measure is that all waste arriving at the site will be

unloaded directly into a concrete lined bunker and mixed with green waste, poultry manure

and ACTA activator and formed into a windrow. This mixing results in windrows reaching a

temperature of 450 – 550C within 24 hours and then rapidly increasing to a temperature of

550 – 650C, which is accepted as high enough to destroy viruses and pathogens.

Issue: Odour

Response: Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection. ACTA can confidently state that odour from its composting activities will not be noticeable to the surrounding community based on the following facts:






Issue: Odour from the Wastewater Storage Dam




water in the dam. This means that there will be insufficient water in the dam to produce

enough odour to be noticeable off site.

Windrows have the capacity to receive the wastewater because internal windrow

temperature is in the range of 550 – 650C, which results in the evaporation of surplus

moisture.














Issue: Truck Traffic Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport

routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,











Issue: Composting as an Aerobic Process

Response: The writer quotes Section 1.5.5 from AS 4454 as the measure which indicates

whether organic materials are microbiologically transformed under controlled aerobic

conditions to achieve pasteurisation and a specified level of maturity. The writer then goes

on to state ‘The application does not appear to meet this standard as a controlled aerobic process

and the method used does not seem to provide assurance of pasteurisation.’ The EPA was also of this

view, hence its request for ACTA to undertake a Research, Development and Demonstration (RD&D)

project. The results from the RD&D project, which were included in the works approval application,

clearly showed that the ACTA system does provide assurance of pasteurisation.

The writer also states ‘ The time and temperature sequences as demonstrated do not provide a replicable and assurable quality outcome that provides the degree of certainty required that the waste products have been rendered biologically safe for re-use. Pasteurisation is not assured because the thermal layer placed on top of the static piles and its mechanical removal cannot assure the clean removal of the layer and prevent the reinfection of the pile by the machinery used as the unpasteurised cover layer is removed. There is a lot of variation on the depth of the thermal covering in the RD&D and the application with the depth of thermal cover ranging from 200mm, 300mm and 450mm. This indicates a lack of rigorous science in the depth required of the cover and the amount to remove to guarantee compliant pasteurisation of the product underneath.’ The following information has been prepared in response to the above:

• The data and test results from the RD&D project prove that pasteurisation was achieved. The results from the comprehensive temperature monitoring program show that pasteurisation temperature was achieved over a continuous period of greater than 15 days (as required by AS4454). Pathogen and virus test results confirmed that pasteurisation had been successful

• The claim that the ACTA system does not provide ‘a replicable and assurable (assured?) outcome seems to be based on concerns that removal of the thermal layer may result in reinfection of the compost. The thermal layer for the RD&D consisted of shredded green waste. The only risk of reinfection would be from weed seeds within the green waste. Compost propagation test results show that this was not the case. However, the only reason green waste was used as the thermal layer was the absence of pasteurised compost. If the application is approved, pasteurised compost will be available to replace the green waste. The use of pasteurised compost for the thermal layer has both process and financial benefits.

Issue: Use of Process Water to Irrigate Compost Windrows Response: The writer correctly states that the main source of process water is sourced from

the incoming waste, e.g., grease trap waste consists of mainly water. It is important to

understand that process water sourced from incoming waste is absorbed into the compost

mix when the waste is unloaded into the concrete lined bunker and blended with green

waste, poultry manure and activator. If, at a later stage, monitoring of the windrow

indicates that more moisture is required, this additional moisture will consist of mains

water. Trying to add liquid waste to the windrows to increase moisture would cause too

many handling problems.

It also needs to be stated that if additional moisture needs to be added to a windrow, this

would include turning of the windrow to allow moisture to be thoroughly mixed with the

compost. Because this would interrupt the 15 days pasteurisation phase, the 15 days

pasteurisation phase would restart from the date the moisture is added.

The practice of emptying water from the wastewater dam by applying it to compost

windrows also need to be explained. Water from the wastewater dam was tested during the

RD&D project and found to be free of viruses and pathogens. The need to test dam water is

recognised and will be undertaken by ACTA before it is used on windrows.

Issue: Process Failure

Response: The writer asks when do declining moisture levels and low oxygen levels produce

process failure. The simple answer is when pasteurisation requirements have not been

achieved.

An important requirement of the RD&D project was to prove to the EPA that the ACTA static

pile composting system was capable of producing pasteurised compost after being exposed

to temperature greater than 550C for at least 15 days. The only specific requirements that

AS 4454 sets out for composting procedures that do not include turned windrows are:

• The alternative process must guarantee the same level of pathogen reduction as

required by ARMCANZ WTC No 1/95, which shall be confirmed by pathogen testing;

and,

• The elimination of viable plant propagules

RD&D test results show that these requirements were achieved. Another high risk process concern is where it is stated that moisture is critical and the lack of control of moisture has led to process failure through the RD&D yet the main source of process water is contact water or prescribed industrial waste waters with no pasteurisation sequence defined as when waste or contact waters will no longer be applied and still achieve pasteurisation to standard. If prescribed industrial waste waters or contact water are used as irrigation sources, at what point must this addition stop to achieve a compliant pasteurisation sequence? At what point does declining moisture levels and low oxygen levels of the static pile combine to produce process failure before pasteurisation has been achieved?

Issue: Process Reliability

Response: The writer questions the reliability of the ACTA system based on two

pasteurisation failures, i.e., poultry mortalities and abattoir paunch. As explained in the

RD&D report, the poultry mortalities failure was due to a lack of moisture. When water was

added, pasteurisation temperature was re-established. However, the RD&D conditions

didn’t allow for this corrective action and therefore poultry mortalities were withdrawn

from the project.

Monitoring and testing of the abattoir waste showed that it passed all the virus and

pathogen tests, the only test it failed was the weed seed propagation test. Once again, the

restrictions of the RD&D conditions prevented ACTA from including information in the

RD&D report that the problem was resolved by adding moisture and turning the pile. In its

works approval application, ACTA has stipulated that it would not accept abattoir waste that

contained paunch.

Issue: Compost Porosity

Response: The writer is concerned that there will be insufficient porosity within the

shredded green waste to provide the required level of porosity. This observation appears to

be based on the writer’s assumption that the ACTA system is ‘a static aeration system

dependent wholly on the structure provided by the garden organics’. The ACTA system is not

a static aeration system! It is an activator based, static pile composting system. Green waste

is an essential part of the system, and it does provide porosity, but porosity is not critical to

its success. The RD&D project was carried out over 24 months. This demonstrated the

flexibility of the system to cope with a wide range of conditions.

Issue: Best Practice

Response: The writer questions whether the ACTA system represents best practice. EPA

Publication 1517.1 “Demonstrating Best Practice”, defines best practice as:

“the best combination of eco-efficient techniques, methods, processes or technology used

in an industry sector or activity that demonstrably minimises the environmental impact of

a generator of emissions in that industry sector or activity

-- where eco-efficient is defined as: ‘producing more goods with less energy and fewer

natural resources, resulting in less waste and pollution’.”

When compared to enclosed vessel composting, the ACTA process claims best practice based

on the follow facts:

• It is more eco-efficient as energy is not required to operate the enclosed vessel, operate the odour treatment facility or to turn the piles i.e. it ‘producing more goods with less energy and fewer natural resources, resulting in less waste and pollution’

• It easily meets EPA’s buffer requirements and therefore is a suitable site;

• It prevents odours being generated, rather than generating odours and then needing to treat them;

• It complies with the waste hierarchy by not only reducing odour generation (previous dot point), but also producing a lower cost product that will encourage sales and therefore divert more waste from landfill;

• The ACTA process produces less odour using less energy and at lower cost, therefore it uses all practical measure to produce the lowest overall impact. Any additional treatment or controls would not noticeably reduce the impact, which the RD&D has demonstrated is acceptable and would adversely impact on other segments (e.g. CO2 emissions due to

energy consumption), possibly increase odour emissions (e.g. forced air aeration) and increase costs for no observable environmental benefit;

• It achieves better integrated environmental management compared to in vessel composting by reducing energy consumption, noise generation and producing less odour over the product cycle (see analysis above), i.e., it achieves best overall environmental outcomes.

Issue: Claims Against the ACTA System

Response: The writer makes many claims about the shortcomings of the ACTA system.

These are listed below along with responses to the claims.

Claim: It doesn’t represent best practice

Response: This is refuted above.

Claim: Compost windrows are covered with a pseudo biofilter

Response: The primary purpose of the outer layer is purely a precautionary measure to

make sure all compost is subjected to temperature greater than 550C. The fact that it acts as

a biofilter is incidental. The absence of hydrogen sulphide within the pile, and results from

the odour modelling are proof that a biofilter is not required.

Claim: The centre of the pile ….. will be a mixture of aerobic and anaerobic pockets

Response: If this was the case, whenever the pile was opened, there would be a noticeable

smell of hydrogen sulphide. There was no evidence of a hydrogen sulphide smell when the

pile was opened for sampling, much to the surprise of EPA officers who were present during

the sampling event.

Claim: Poor process control

Response: Poor process control would result in low temperatures, anaerobic conditions and

poor quality compost. RD&D monitoring and test results show this not to be the case.

Claim: Long duration of oxygen deprivation as evidenced by immature finished material

Response: Long periods of oxygen deprivation would result in low temperature, production

of hydrogen sulphide and the inability of the compost to pass pasteurisation tests. None of

these outcomes occurred during the 24 months RD&D project.

The fact that the compost was classified as pasteurised is not a black mark against it. Many

primary producers prefer to purchase pasteurised compost in lieu of mature compost

because it is still biologically active. A high level of ammonia is a desirable property because

it is a nitrogen source for soil bacteria.

Claim: Periods where temperature falls below 550C

Response: It’s not surprising that temperature charts show periods when temperature is

less than 550C. This occurs when windrows are first formed and then after about 10 weeks.

The critical period is what happens between the beginning and the end, i.e., does the

windrow achieve temperature greater than 550C for over 15 days. The temperature charts

show this was achieved, and this is supported by the test results.

Claim: Weed infestation

Response: RD&D test results show that there was no significant failure of the ACTA system

to sterilise weed seeds. Information in the works approval application openly discusses the

paunch weed seed problem. Paunch is generally landfilled for this reason. The suggestion

that because paunch failed the propagation test, the ACTA system is incapable of sterilising

weed seeds, plant propagules and plant diseases in green organics is not supported by the

propagation tests on the hatchery waste and the grease trap waste.

Claim: Fire risk comments from the CFA

Response: The CFA comments need to be put in context. It is unlikely that there are any

static pile composting systems in Victoria, certainly none using the ACTA system. This means

that the CFA is basing its requirements on the performance of aerated, open windrow

composting practices. Unfortunately, there have been some large fires in composting

facilities using this technology. ACTA will hold discussions with the CFA to reach a more

realistic understanding of managing the fire risk associated with composting grease trap

waste, hatchery waste and abattoir waste.

Claim: Problems associated with the use of green waste to cover windrows

Response: ACTA wants to make it clear that the use of green waste to cover windrows was

always seen as a transitory measure. During the RD&D project, there was no finished

compost to cover the windrows, hence the use of green waste. Test results show that the

bio-security risks highlighted by the writer did not eventuate during the 24 months of the

RD&D project. Be that as it may, if the application is approved, compost windrows will be

covered with pasteurised compost.

Claim: The ACTA system will undermine finished product standards

Response: The writer’s attention is drawn to the statement from SESL, an organisation that

is well qualified to give an opinion on compost quality. Here is an extract from their

statement, a copy of which is included in the works approval application:

“The findings of the RD&D project have contributed to an improved WA and EMP. Three suggestions for further improvements are: 1. Ensuring the green waste fraction is sufficiently coarse to prevent oxygen levels from dropping to zero and anaerobic conditions occurring. 2. Developing an effective pile irrigation system to avoid the need for turning in the event piles dry out. 3. Some further thought to minimising odour release from the receival/mixing area. Otherwise, we are of the view the process will result in a commercially valuable product, albeit that it will not comply with the mature compost criteria set out in AS 4454 due to its elevated nitrogen level, unless prolonged composting occurs. We acknowledge this is not a commercial or legal requirement.”


Submission 34 was in favour of the application being approved subject to conditions. The incorporation of these conditions in any planning approval will rest with the Golden Plains Shire.


Issue: Claim that the ACTA system is the lowest level of composting technologies

Response: It appears this claim has been made without understanding the extensive

information included in the works approval application. The information supporting the

application clearly shows that the ACTA system meets all EPA requirements and produces

compost that complies with AS4454 requirements.

There are many benefits to static pile composting provided it avoids the problems

associated with anaerobic conditions. Test results from the Research, Development and

Demonstration project prove that simple technology does not equate to poor performance.

Issue: Expectations

Response: The writer is of the opinion that the only way to compost Category 4 waste is via

in-vessel technology. The EPA was also of this opinion and that is why ACTA agreed to

undertake a comprehensive RD&D project. Field observations and test results conclusively

showed that the ACTA system outperforms in vessel composting considering odour levels,

greenhouse gas emissions, energy consumption and cost effectiveness. Information

supporting this claim is contained in the works approval application

Issue: Odour management reliant on buffer zone

Response: It can be seen from the information provided below that the buffer zone

required by the ACTA system to comply with EPA odour requirements is far less than other

forms of composting.





• The volume of feedstock received (5,700m3), and compost produced during the 24

months RD&D project


Issue: Claim that the ACTA system will result in anaerobic conditions within the compost

Response: This is a reasonable concern for anyone not familiar with the ACTA system. As

stated above this was a concern shared by the EPA. It is necessary to refer again to field

observations and test results to reinforce the fact that the ACTA system does not create

anaerobic conditions within the compost windrow, so the problems associated with

anaerobic conditions, i.e., low temperature, hydrogen sulphide and methane are absent

from composting activities using the ACTA system.

Issue: Concern that pathogen destruction will be incomplete

Response: There is a fundamental difference between the ACTA static pile composting

system and other forms of composting. In the ACTA system, temperature greater than 550C

is achieved by the activator. The activator is mixed with the feedstock when the feedstock is

unloaded into a concrete lined bunker. This means that the activator is spread throughout

the windrow. Temperature monitoring results show that covering the windrow with 200mm

of green waste during the RD&D project allowed the activator to keep the surface

temperature of the compost above 550C. It needs to be noted that the green waste layer

will be replaced with pasteurised compost if the works application is approved.

















the EPA inspector.



it.

The statement that ‘The odour from abattoir waste and chicken mortalities; the leaching of liquid waste; the presence of vermin and flies, the unsightly high compost heaps and this at the entrance to our town!’ must be challenged. There was no evidence that odour from abattoir waste and chicken mortalities had migrated from the site. In fact, the odour modelling and monitoring results show that odour from the site was barely noticeable at a distance of 200m from the odour source. There was no evidence of vermin throughout the 24 months of the RD&D project, nor was there any evidence of fly breeding within the compost windrows during this time. The need to refer to stockpiled mature compost as ‘unsightly high compost heaps’ is surprising. The stockpiles had the physical appearance of soil, why this would be offensive in a farming zone is questioned.






Issue: Truck Traffic Response: ACTA is seeking approval to compost up to 50,000m3 of organic waste, half of which will consist of green waste. Based on the carrying capacity of trucks delivering feedstock to the site, this equates to 1, 950 X 2 (in and out) per year. ACTA has indicated that if its application is successful, site operations will be restricted to weekdays and Saturday morning, i.e., 5.5 days, which equates to 286 opening days. 1, 950 X 2 = 3,900 truck movements 3,900 ÷ 286 = 14 truck movements per day Compost leaving the site also needs to be considered. Composting will result in a 30% reduction in the volume of feedstock received at the site, i.e., 35,000m3. Based on truck capacity of 85m3, and 50% of the trucks delivering green waste to the site back loading with compost (equivalent to 17,500m3), this will result in an additional 206 X 2 truck movements per year. Based on the above information, total daily truck movements spread over three transport routes are 15 – 16. It will be up to the Shire and the EPA to decide whether this is reasonable based on traffic movements on these three routes. There are at least three routes that can be used to reach the site, i.e.,




Issue: Odour Response: In reading the information below, it should be noted that odour modelling assumed that the whole of the one hectare site was covered with compost. For this reason, expansion of the site to two hectares will not change the odour modelling results. Most of the expanded site will be used to provide access roadways and storage of pasteurised compost. Concern over the odour impact of the ACTA static pile composting system was a major reason for the EPA recommending that ACTA undertake a Research, Design and Development (RD&D) project to demonstrate the low odour emission from its composting system. Based on this concern, the EPA recommended that the RD&D project be undertaken in two

stages. Stage 1 required ACTA to demonstrate the effectiveness of the ACTA system to compost green waste and poultry manure using ACTA compost activator. This included odour monitoring and odour modelling. The odour modelling results show that odour at the nearest public boundary (Bannockburn – Shelford Road) rarely exceeded 1 odour unit. One odour unit is accepted by the EPA as being the limit of detection. ACTA can confidently state that odour from its composting activities will not be noticeable to the surrounding community based on the following facts:






Issue: Site Closure

Response: The composting facility will only accept feedstock that is capable of being

converted into quality compost, so composting activities will not cause any contamination

issues. Soil under the site will actually have a much richer bacterial regime than soil in

surrounding land.

Issue: Personal and Family Wellbeing, Loss of Enjoyment of Property

Response: Wellbeing and loss of enjoyment are essentially a matter of personal preference.

If an activity that meets all planning and EPA requirements manages to upset a person’s

wellbeing, and their enjoyment of their property, then it is beyond ACTA to deal with such a

subjective issue.












Issue: Waste Disposal

Response: The writer is under the impression that the site will produce waste. The exact

opposite will occur. The site will take in selected organic waste and process it into compost.

The compost will be used by local primary producers to improve soil health which, in turn,

will improve plant health, which will result in increased crop yields and improved pasture.





mass.





infestation.

Issue: Activator Composition

Response: The activator is 100% organic. It has undergone comprehensive laboratory

testing at the request of the EPA. The test results satisfied the EPA that it is not a prescribed

industrial waste. The Research, Development and Demonstration project included a

comprehensive monitoring and testing program. If there was any harmful substance in the

activator it would have shown up in the test results.

Issue: Compliance Oversight

Response: If the application is approved, it will have conditions attached. Compliance with

planning conditions will be the responsibility of council and compliance with environmental

conditions will be the responsibility of the EPA.












Issue: Scale of RD&D Project and Proposed Project

Response: Even though the area of the proposed composting facility has increased from one

hectare to two hectares, the volume of compost on site at any one time will be similar to

the volume that was on site during the RD&D project. The scale of the RD&D project was

deliberately chosen so that it would replicate the full scale conditions.

ACTA Works Approval Application Response to Submissions 1 ... · ACTA Works Approval Application...

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