1

Before Waikato Regional Council Before Waikato District Council

In the Matter of the Resource Management Act 1991 (Act)

And

In the Matter of an application by Mercer Assets Limited for regional and district resource consents to establish and operate a mushroom substrate production facility at 55 Morrison Road Pukekawa

Hearing Reference LUC039919 AUTH1406570101 AUTH1406570201 and AUTH1406570301

Evidence of Dr Terry Brady on behalf of Mercer Assets

Limited Dated 18 September 2019

Jeremy Brabant

Barrister

Level 4 Vulcan Building Chambers

PO Box 1502 Shortland St

Auckland City

021 494 506

2

Qualifications and experience

1 My full name is Terence John Brady I am a Director of Terry Brady

Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of

Philosophy in Chemistry from the University of Canterbury New

Zealand I specialise in air pollution control preparation of

assessments of the effects of discharges to air and other air quality

matters and I have over 36 years direct experience in these fields

2 From 1983 to the end of 1991 I was employed by the Department of

Health as an air pollution scientist responsible for industrial emissions

for the upper half of the South Island under the Clean Air Act From

1991 to 1996 I was employed as an Air Pollution Scientist with

Woodward Clyde (NZ) Ltd (now AECOM) and from 1996 to 1999 as a

Principal I started my own consultancy in January 1999

3 My relevant experience includes assessing the actual and potential

discharges to air from a very large variety of industries throughout

New Zealand including the discharges of odour from composting I

have been involved with many industrial projects that involve the

discharge of odour and I am currently the air quality advisor in the

Audit Group for Watercare Services two wastewater plants at

Mangere and Rosedale

4 I have also designed and commissioned a considerable number of

industrial ventilation systems for air pollution control purposes

5 Some specific projects that I have been involved with that have

relevance to this application include

(a) Measurement modelling and assessment of odour

from Living Earth composting at Pikes Point in

Auckland Technical advice for monitoring programs

(b) Predictive modelling and assessment of odour from

Living Earth composting at Puketutu Island in Auckland

3

including Resource Consent application and the

successful Environment Court appeal

(c) Assessment of odour effects for composting operations

at Living EarthChristchurch City Council operation in

Christchurch

(d) Assessment of potential odour effects for New

Plymouth City Council composting operation

(e) Provided evidence in an Environment Court appeal

involving New Zealand Mushrooms Ltd Morrinsville

(f) Assessment of potential effects of odour dust and bio-

aerosols for the Living Earth Joint Venture in Careys

Gully Wellington

(g) Assessment of effects of a greenwaste composting

operation application by Whakatane District Council

(h) Measurement and assessment and remedial works for

odours from the indoor composting plant at Cresta

Mushrooms Mercer

(i) Assessment of engineering options to control odour

from Te Mata Mushrooms Havelock North (ongoing)

6 In terms of scale composting operations I have been involved with

range from a few thousand tonnes per annum to up to 75000 tonnes

per annum

7 I believe that I am well qualified to provide expert evidence on

matters that have direct relevance to the application that is before

the Independent Hearing Commissioners

8 I have read the Code of Conduct for Expert Witnesses issued as part of

the Environment Court Practice Notes I agree to comply with the

code and am satisfied the matters I address in my evidence are within

my expertise I am not aware of any material facts that I have

4

omitted that might alter or detract from the opinions I express in my

evidence

SCOPE OF EVIDENCE

9 In my evidence I will

(a) Give an overview the application and the key odour

sources as they relate to the odour control systems

proposed

(b) Discuss the basis for the design parameters selected for

odour containment

(c) The scrubber and biofilter odour control system

(d) Assess the odour impacts arising from the proposals

(e) Comment on the submissions received

(f) Comment on the Officers Report

(g) Provide context regarding alternative sites

OVERVIEW

10 The full details of the process are provided in the application technical

document1 and the following represents a short summary

11 The proposal is for the manufacture of mushroom substrate

(compost) in a fully enclosed facility that will operate with full building

air extraction on all parts of the buildings and processes that generate

odour This odour-containing air will be pre-treated in an acid

scrubber to remove ammonia followed by a water scrubber to

remove any acid mist carry over and finally the air will be treated in a

large biofilter to remove all odour

12 Manufacturing will take place in two buildings beginning with the

pre-wetting operation in the CANVACON pre-wet building followed

by transfer to the filling hall in the main composting building that

1 Terry Brady Consulting Ltd Mercer Mushrooms Application for Consent for Discharge to Air

(2) Revised Technical Report 321502R002 12 April 2019

5

contains 12 fermentation tunnels From the filling hall the tunnels are

filled using a specialised cassette filling machine Fermentation is

broadly separated into Phase 1 and Phase 2 stages that are defined by

the temperatures maintained in the fermenting mass

13 After a pasturisation stage (in Phase 2) the substrate is cooled to

ambient temperature and spawned with mushroom mycelium and

held in the tunnels for 14-21 days before removal to the growing

facility

KEY ODOUR SOURCES

14 The main odour sources in process order are

(a) The pre-wetting and turning in the Canvacon

Building

(b) Transfer of pre-wetted material to the filling hall

(c) Phase 1 Fermentation

(d) Phase 1 Turning

(e) Phase 2 Fermentation

(f) Phase 2 Turning

(g) Miscellaneous sources

15 I discuss these below

Pre-Wet

16 In the pre-wet stage straw bales are bought inside to the enclosed

Pre-Wet building with a loader which are then submerged in to a

dedicated lsquobathrsquo that is filled with nitrogen rich process water Once

the bales are fully wetted they are then stacked within the building

for one week days to allow microbial activity to build and de-wax the

straw After soaking period for 1 week the bales are formed into a

pile about 2 to 3m high together with the other raw materials in the

section of the Pre-Wet building marked as Pre-Wet Conditioning in

6

Appendix B To maintain porosity the material is mechanically turned

once in this final week

17 The pre-wet building is maintained under negative pressure at all

times to prevent odour being released to atmosphere

Transfer

18 At the end of the conditioning period the material is loaded into the

mixing line and then conveyed to the tunnel building

19 The conveyor is covered and air is extracted from it into both the

filling hall and the pre-wet building The openings in both the pre-wet

and filling hall were taken into account in the design of the total

amount of ventilation air that is required in both the pre-wet and

filling hall to maintain negative pressure

Phase 1 Fermentation

20 Each of the tunnels is provided with under-floor aeration to maintain

optimum levels of oxygen and temperature in the compost mass

Temperatures vary through the process ranging between 40-80 oC

and are largely controlled using aeration air

21 In this part of the process the aeration and extraction is a fully sealed

system that is balanced to a slight negative pressure

22 All of the air used in the phase 1 tunnels is extracted to the acidwater

scrubbers and the biofilter

Phase 1 Turning

23 Turning involves removing the substrate from one tunnel and placing

it in another via the filling hall The filing hall and the tunnels are

under negative pressure during this operation and the air is extracted

to the scrubber and biofilter

Phase 2 Fermentation

7

24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of

the fermentation but with slightly different aeration and turning

requirements and continues until a critical point called peak heat is

reached From this time on the temperature reduces to the point

when the substrate is finished and cooled At this stage it has only a

very mild potting mix smell to it

Phase 2 Turning

25 This is identical to the phase 1 turning and again the filling hall is

under negative pressure The air is extracted to the scrubber and

biofilter

Phase 3 Spawning

26 Once the substrate is cooled to ambient temperature it is removed

from the tunnels into the filling hall As there is no significant odour

from the substrate at this stage the filling hall is under slight positive

pressure using filtered air to prevent contamination The mushroom

mycelium is added and the substrate is then returned to the tunnels

and left to grow After 14 to 21 days it is removed via the load out

hall and sent to the growing rooms There is no odour from this

stage

Miscellaneous Sources

27 Because the whole composting process will be fully enclosed there

are very few sources outside that could potentially cause odour and

the only ones would include the nutrient tank (goody water tank) and

deliveries of raw materials

28 The nutrient water tank will be vented into the pre-wet building and is

therefore under negative pressure There will be no odour from this

source

29 The only raw material that has any potential for odour is the chicken

manure However this will be delivered in covered trucks and only

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

2

Qualifications and experience

1 My full name is Terence John Brady I am a Director of Terry Brady

Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of

Philosophy in Chemistry from the University of Canterbury New

Zealand I specialise in air pollution control preparation of

assessments of the effects of discharges to air and other air quality

matters and I have over 36 years direct experience in these fields

2 From 1983 to the end of 1991 I was employed by the Department of

Health as an air pollution scientist responsible for industrial emissions

for the upper half of the South Island under the Clean Air Act From

1991 to 1996 I was employed as an Air Pollution Scientist with

Woodward Clyde (NZ) Ltd (now AECOM) and from 1996 to 1999 as a

Principal I started my own consultancy in January 1999

3 My relevant experience includes assessing the actual and potential

discharges to air from a very large variety of industries throughout

New Zealand including the discharges of odour from composting I

have been involved with many industrial projects that involve the

discharge of odour and I am currently the air quality advisor in the

Audit Group for Watercare Services two wastewater plants at

Mangere and Rosedale

4 I have also designed and commissioned a considerable number of

industrial ventilation systems for air pollution control purposes

5 Some specific projects that I have been involved with that have

relevance to this application include

(a) Measurement modelling and assessment of odour

from Living Earth composting at Pikes Point in

Auckland Technical advice for monitoring programs

(b) Predictive modelling and assessment of odour from

Living Earth composting at Puketutu Island in Auckland

3

including Resource Consent application and the

successful Environment Court appeal

(c) Assessment of odour effects for composting operations

at Living EarthChristchurch City Council operation in

Christchurch

(d) Assessment of potential odour effects for New

Plymouth City Council composting operation

(e) Provided evidence in an Environment Court appeal

involving New Zealand Mushrooms Ltd Morrinsville

(f) Assessment of potential effects of odour dust and bio-

aerosols for the Living Earth Joint Venture in Careys

Gully Wellington

(g) Assessment of effects of a greenwaste composting

operation application by Whakatane District Council

(h) Measurement and assessment and remedial works for

odours from the indoor composting plant at Cresta

Mushrooms Mercer

(i) Assessment of engineering options to control odour

from Te Mata Mushrooms Havelock North (ongoing)

6 In terms of scale composting operations I have been involved with

range from a few thousand tonnes per annum to up to 75000 tonnes

per annum

7 I believe that I am well qualified to provide expert evidence on

matters that have direct relevance to the application that is before

the Independent Hearing Commissioners

8 I have read the Code of Conduct for Expert Witnesses issued as part of

the Environment Court Practice Notes I agree to comply with the

code and am satisfied the matters I address in my evidence are within

my expertise I am not aware of any material facts that I have

4

omitted that might alter or detract from the opinions I express in my

evidence

SCOPE OF EVIDENCE

9 In my evidence I will

(a) Give an overview the application and the key odour

sources as they relate to the odour control systems

proposed

(b) Discuss the basis for the design parameters selected for

odour containment

(c) The scrubber and biofilter odour control system

(d) Assess the odour impacts arising from the proposals

(e) Comment on the submissions received

(f) Comment on the Officers Report

(g) Provide context regarding alternative sites

OVERVIEW

10 The full details of the process are provided in the application technical

document1 and the following represents a short summary

11 The proposal is for the manufacture of mushroom substrate

(compost) in a fully enclosed facility that will operate with full building

air extraction on all parts of the buildings and processes that generate

odour This odour-containing air will be pre-treated in an acid

scrubber to remove ammonia followed by a water scrubber to

remove any acid mist carry over and finally the air will be treated in a

large biofilter to remove all odour

12 Manufacturing will take place in two buildings beginning with the

pre-wetting operation in the CANVACON pre-wet building followed

by transfer to the filling hall in the main composting building that

1 Terry Brady Consulting Ltd Mercer Mushrooms Application for Consent for Discharge to Air

(2) Revised Technical Report 321502R002 12 April 2019

5

contains 12 fermentation tunnels From the filling hall the tunnels are

filled using a specialised cassette filling machine Fermentation is

broadly separated into Phase 1 and Phase 2 stages that are defined by

the temperatures maintained in the fermenting mass

13 After a pasturisation stage (in Phase 2) the substrate is cooled to

ambient temperature and spawned with mushroom mycelium and

held in the tunnels for 14-21 days before removal to the growing

facility

KEY ODOUR SOURCES

14 The main odour sources in process order are

(a) The pre-wetting and turning in the Canvacon

Building

(b) Transfer of pre-wetted material to the filling hall

(c) Phase 1 Fermentation

(d) Phase 1 Turning

(e) Phase 2 Fermentation

(f) Phase 2 Turning

(g) Miscellaneous sources

15 I discuss these below

Pre-Wet

16 In the pre-wet stage straw bales are bought inside to the enclosed

Pre-Wet building with a loader which are then submerged in to a

dedicated lsquobathrsquo that is filled with nitrogen rich process water Once

the bales are fully wetted they are then stacked within the building

for one week days to allow microbial activity to build and de-wax the

straw After soaking period for 1 week the bales are formed into a

pile about 2 to 3m high together with the other raw materials in the

section of the Pre-Wet building marked as Pre-Wet Conditioning in

6

Appendix B To maintain porosity the material is mechanically turned

once in this final week

17 The pre-wet building is maintained under negative pressure at all

times to prevent odour being released to atmosphere

Transfer

18 At the end of the conditioning period the material is loaded into the

mixing line and then conveyed to the tunnel building

19 The conveyor is covered and air is extracted from it into both the

filling hall and the pre-wet building The openings in both the pre-wet

and filling hall were taken into account in the design of the total

amount of ventilation air that is required in both the pre-wet and

filling hall to maintain negative pressure

Phase 1 Fermentation

20 Each of the tunnels is provided with under-floor aeration to maintain

optimum levels of oxygen and temperature in the compost mass

Temperatures vary through the process ranging between 40-80 oC

and are largely controlled using aeration air

21 In this part of the process the aeration and extraction is a fully sealed

system that is balanced to a slight negative pressure

22 All of the air used in the phase 1 tunnels is extracted to the acidwater

scrubbers and the biofilter

Phase 1 Turning

23 Turning involves removing the substrate from one tunnel and placing

it in another via the filling hall The filing hall and the tunnels are

under negative pressure during this operation and the air is extracted

to the scrubber and biofilter

Phase 2 Fermentation

7

24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of

the fermentation but with slightly different aeration and turning

requirements and continues until a critical point called peak heat is

reached From this time on the temperature reduces to the point

when the substrate is finished and cooled At this stage it has only a

very mild potting mix smell to it

Phase 2 Turning

25 This is identical to the phase 1 turning and again the filling hall is

under negative pressure The air is extracted to the scrubber and

biofilter

Phase 3 Spawning

26 Once the substrate is cooled to ambient temperature it is removed

from the tunnels into the filling hall As there is no significant odour

from the substrate at this stage the filling hall is under slight positive

pressure using filtered air to prevent contamination The mushroom

mycelium is added and the substrate is then returned to the tunnels

and left to grow After 14 to 21 days it is removed via the load out

hall and sent to the growing rooms There is no odour from this

stage

Miscellaneous Sources

27 Because the whole composting process will be fully enclosed there

are very few sources outside that could potentially cause odour and

the only ones would include the nutrient tank (goody water tank) and

deliveries of raw materials

28 The nutrient water tank will be vented into the pre-wet building and is

therefore under negative pressure There will be no odour from this

source

29 The only raw material that has any potential for odour is the chicken

manure However this will be delivered in covered trucks and only

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

3

including Resource Consent application and the

successful Environment Court appeal

(c) Assessment of odour effects for composting operations

at Living EarthChristchurch City Council operation in

Christchurch

(d) Assessment of potential odour effects for New

Plymouth City Council composting operation

(e) Provided evidence in an Environment Court appeal

involving New Zealand Mushrooms Ltd Morrinsville

(f) Assessment of potential effects of odour dust and bio-

aerosols for the Living Earth Joint Venture in Careys

Gully Wellington

(g) Assessment of effects of a greenwaste composting

operation application by Whakatane District Council

(h) Measurement and assessment and remedial works for

odours from the indoor composting plant at Cresta

Mushrooms Mercer

(i) Assessment of engineering options to control odour

from Te Mata Mushrooms Havelock North (ongoing)

6 In terms of scale composting operations I have been involved with

range from a few thousand tonnes per annum to up to 75000 tonnes

per annum

7 I believe that I am well qualified to provide expert evidence on

matters that have direct relevance to the application that is before

the Independent Hearing Commissioners

8 I have read the Code of Conduct for Expert Witnesses issued as part of

the Environment Court Practice Notes I agree to comply with the

code and am satisfied the matters I address in my evidence are within

my expertise I am not aware of any material facts that I have

4

omitted that might alter or detract from the opinions I express in my

evidence

SCOPE OF EVIDENCE

9 In my evidence I will

(a) Give an overview the application and the key odour

sources as they relate to the odour control systems

proposed

(b) Discuss the basis for the design parameters selected for

odour containment

(c) The scrubber and biofilter odour control system

(d) Assess the odour impacts arising from the proposals

(e) Comment on the submissions received

(f) Comment on the Officers Report

(g) Provide context regarding alternative sites

OVERVIEW

10 The full details of the process are provided in the application technical

document1 and the following represents a short summary

11 The proposal is for the manufacture of mushroom substrate

(compost) in a fully enclosed facility that will operate with full building

air extraction on all parts of the buildings and processes that generate

odour This odour-containing air will be pre-treated in an acid

scrubber to remove ammonia followed by a water scrubber to

remove any acid mist carry over and finally the air will be treated in a

large biofilter to remove all odour

12 Manufacturing will take place in two buildings beginning with the

pre-wetting operation in the CANVACON pre-wet building followed

by transfer to the filling hall in the main composting building that

1 Terry Brady Consulting Ltd Mercer Mushrooms Application for Consent for Discharge to Air

(2) Revised Technical Report 321502R002 12 April 2019

5

contains 12 fermentation tunnels From the filling hall the tunnels are

filled using a specialised cassette filling machine Fermentation is

broadly separated into Phase 1 and Phase 2 stages that are defined by

the temperatures maintained in the fermenting mass

13 After a pasturisation stage (in Phase 2) the substrate is cooled to

ambient temperature and spawned with mushroom mycelium and

held in the tunnels for 14-21 days before removal to the growing

facility

KEY ODOUR SOURCES

14 The main odour sources in process order are

(a) The pre-wetting and turning in the Canvacon

Building

(b) Transfer of pre-wetted material to the filling hall

(c) Phase 1 Fermentation

(d) Phase 1 Turning

(e) Phase 2 Fermentation

(f) Phase 2 Turning

(g) Miscellaneous sources

15 I discuss these below

Pre-Wet

16 In the pre-wet stage straw bales are bought inside to the enclosed

Pre-Wet building with a loader which are then submerged in to a

dedicated lsquobathrsquo that is filled with nitrogen rich process water Once

the bales are fully wetted they are then stacked within the building

for one week days to allow microbial activity to build and de-wax the

straw After soaking period for 1 week the bales are formed into a

pile about 2 to 3m high together with the other raw materials in the

section of the Pre-Wet building marked as Pre-Wet Conditioning in

6

Appendix B To maintain porosity the material is mechanically turned

once in this final week

17 The pre-wet building is maintained under negative pressure at all

times to prevent odour being released to atmosphere

Transfer

18 At the end of the conditioning period the material is loaded into the

mixing line and then conveyed to the tunnel building

19 The conveyor is covered and air is extracted from it into both the

filling hall and the pre-wet building The openings in both the pre-wet

and filling hall were taken into account in the design of the total

amount of ventilation air that is required in both the pre-wet and

filling hall to maintain negative pressure

Phase 1 Fermentation

20 Each of the tunnels is provided with under-floor aeration to maintain

optimum levels of oxygen and temperature in the compost mass

Temperatures vary through the process ranging between 40-80 oC

and are largely controlled using aeration air

21 In this part of the process the aeration and extraction is a fully sealed

system that is balanced to a slight negative pressure

22 All of the air used in the phase 1 tunnels is extracted to the acidwater

scrubbers and the biofilter

Phase 1 Turning

23 Turning involves removing the substrate from one tunnel and placing

it in another via the filling hall The filing hall and the tunnels are

under negative pressure during this operation and the air is extracted

to the scrubber and biofilter

Phase 2 Fermentation

7

24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of

the fermentation but with slightly different aeration and turning

requirements and continues until a critical point called peak heat is

reached From this time on the temperature reduces to the point

when the substrate is finished and cooled At this stage it has only a

very mild potting mix smell to it

Phase 2 Turning

25 This is identical to the phase 1 turning and again the filling hall is

under negative pressure The air is extracted to the scrubber and

biofilter

Phase 3 Spawning

26 Once the substrate is cooled to ambient temperature it is removed

from the tunnels into the filling hall As there is no significant odour

from the substrate at this stage the filling hall is under slight positive

pressure using filtered air to prevent contamination The mushroom

mycelium is added and the substrate is then returned to the tunnels

and left to grow After 14 to 21 days it is removed via the load out

hall and sent to the growing rooms There is no odour from this

stage

Miscellaneous Sources

27 Because the whole composting process will be fully enclosed there

are very few sources outside that could potentially cause odour and

the only ones would include the nutrient tank (goody water tank) and

deliveries of raw materials

28 The nutrient water tank will be vented into the pre-wet building and is

therefore under negative pressure There will be no odour from this

source

29 The only raw material that has any potential for odour is the chicken

manure However this will be delivered in covered trucks and only

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

4

omitted that might alter or detract from the opinions I express in my

evidence

SCOPE OF EVIDENCE

9 In my evidence I will

(a) Give an overview the application and the key odour

sources as they relate to the odour control systems

proposed

(b) Discuss the basis for the design parameters selected for

odour containment

(c) The scrubber and biofilter odour control system

(d) Assess the odour impacts arising from the proposals

(e) Comment on the submissions received

(f) Comment on the Officers Report

(g) Provide context regarding alternative sites

OVERVIEW

10 The full details of the process are provided in the application technical

document1 and the following represents a short summary

11 The proposal is for the manufacture of mushroom substrate

(compost) in a fully enclosed facility that will operate with full building

air extraction on all parts of the buildings and processes that generate

odour This odour-containing air will be pre-treated in an acid

scrubber to remove ammonia followed by a water scrubber to

remove any acid mist carry over and finally the air will be treated in a

large biofilter to remove all odour

12 Manufacturing will take place in two buildings beginning with the

pre-wetting operation in the CANVACON pre-wet building followed

by transfer to the filling hall in the main composting building that

1 Terry Brady Consulting Ltd Mercer Mushrooms Application for Consent for Discharge to Air

(2) Revised Technical Report 321502R002 12 April 2019

5

contains 12 fermentation tunnels From the filling hall the tunnels are

filled using a specialised cassette filling machine Fermentation is

broadly separated into Phase 1 and Phase 2 stages that are defined by

the temperatures maintained in the fermenting mass

13 After a pasturisation stage (in Phase 2) the substrate is cooled to

ambient temperature and spawned with mushroom mycelium and

held in the tunnels for 14-21 days before removal to the growing

facility

KEY ODOUR SOURCES

14 The main odour sources in process order are

(a) The pre-wetting and turning in the Canvacon

Building

(b) Transfer of pre-wetted material to the filling hall

(c) Phase 1 Fermentation

(d) Phase 1 Turning

(e) Phase 2 Fermentation

(f) Phase 2 Turning

(g) Miscellaneous sources

15 I discuss these below

Pre-Wet

16 In the pre-wet stage straw bales are bought inside to the enclosed

Pre-Wet building with a loader which are then submerged in to a

dedicated lsquobathrsquo that is filled with nitrogen rich process water Once

the bales are fully wetted they are then stacked within the building

for one week days to allow microbial activity to build and de-wax the

straw After soaking period for 1 week the bales are formed into a

pile about 2 to 3m high together with the other raw materials in the

section of the Pre-Wet building marked as Pre-Wet Conditioning in

6

Appendix B To maintain porosity the material is mechanically turned

once in this final week

17 The pre-wet building is maintained under negative pressure at all

times to prevent odour being released to atmosphere

Transfer

18 At the end of the conditioning period the material is loaded into the

mixing line and then conveyed to the tunnel building

19 The conveyor is covered and air is extracted from it into both the

filling hall and the pre-wet building The openings in both the pre-wet

and filling hall were taken into account in the design of the total

amount of ventilation air that is required in both the pre-wet and

filling hall to maintain negative pressure

Phase 1 Fermentation

20 Each of the tunnels is provided with under-floor aeration to maintain

optimum levels of oxygen and temperature in the compost mass

Temperatures vary through the process ranging between 40-80 oC

and are largely controlled using aeration air

21 In this part of the process the aeration and extraction is a fully sealed

system that is balanced to a slight negative pressure

22 All of the air used in the phase 1 tunnels is extracted to the acidwater

scrubbers and the biofilter

Phase 1 Turning

23 Turning involves removing the substrate from one tunnel and placing

it in another via the filling hall The filing hall and the tunnels are

under negative pressure during this operation and the air is extracted

to the scrubber and biofilter

Phase 2 Fermentation

7

24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of

the fermentation but with slightly different aeration and turning

requirements and continues until a critical point called peak heat is

reached From this time on the temperature reduces to the point

when the substrate is finished and cooled At this stage it has only a

very mild potting mix smell to it

Phase 2 Turning

25 This is identical to the phase 1 turning and again the filling hall is

under negative pressure The air is extracted to the scrubber and

biofilter

Phase 3 Spawning

26 Once the substrate is cooled to ambient temperature it is removed

from the tunnels into the filling hall As there is no significant odour

from the substrate at this stage the filling hall is under slight positive

pressure using filtered air to prevent contamination The mushroom

mycelium is added and the substrate is then returned to the tunnels

and left to grow After 14 to 21 days it is removed via the load out

hall and sent to the growing rooms There is no odour from this

stage

Miscellaneous Sources

27 Because the whole composting process will be fully enclosed there

are very few sources outside that could potentially cause odour and

the only ones would include the nutrient tank (goody water tank) and

deliveries of raw materials

28 The nutrient water tank will be vented into the pre-wet building and is

therefore under negative pressure There will be no odour from this

source

29 The only raw material that has any potential for odour is the chicken

manure However this will be delivered in covered trucks and only

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

5

contains 12 fermentation tunnels From the filling hall the tunnels are

filled using a specialised cassette filling machine Fermentation is

broadly separated into Phase 1 and Phase 2 stages that are defined by

the temperatures maintained in the fermenting mass

13 After a pasturisation stage (in Phase 2) the substrate is cooled to

ambient temperature and spawned with mushroom mycelium and

held in the tunnels for 14-21 days before removal to the growing

facility

KEY ODOUR SOURCES

14 The main odour sources in process order are

(a) The pre-wetting and turning in the Canvacon

Building

(b) Transfer of pre-wetted material to the filling hall

(c) Phase 1 Fermentation

(d) Phase 1 Turning

(e) Phase 2 Fermentation

(f) Phase 2 Turning

(g) Miscellaneous sources

15 I discuss these below

Pre-Wet

16 In the pre-wet stage straw bales are bought inside to the enclosed

Pre-Wet building with a loader which are then submerged in to a

dedicated lsquobathrsquo that is filled with nitrogen rich process water Once

the bales are fully wetted they are then stacked within the building

for one week days to allow microbial activity to build and de-wax the

straw After soaking period for 1 week the bales are formed into a

pile about 2 to 3m high together with the other raw materials in the

section of the Pre-Wet building marked as Pre-Wet Conditioning in

6

Appendix B To maintain porosity the material is mechanically turned

once in this final week

17 The pre-wet building is maintained under negative pressure at all

times to prevent odour being released to atmosphere

Transfer

18 At the end of the conditioning period the material is loaded into the

mixing line and then conveyed to the tunnel building

19 The conveyor is covered and air is extracted from it into both the

filling hall and the pre-wet building The openings in both the pre-wet

and filling hall were taken into account in the design of the total

amount of ventilation air that is required in both the pre-wet and

filling hall to maintain negative pressure

Phase 1 Fermentation

20 Each of the tunnels is provided with under-floor aeration to maintain

optimum levels of oxygen and temperature in the compost mass

Temperatures vary through the process ranging between 40-80 oC

and are largely controlled using aeration air

21 In this part of the process the aeration and extraction is a fully sealed

system that is balanced to a slight negative pressure

22 All of the air used in the phase 1 tunnels is extracted to the acidwater

scrubbers and the biofilter

Phase 1 Turning

23 Turning involves removing the substrate from one tunnel and placing

it in another via the filling hall The filing hall and the tunnels are

under negative pressure during this operation and the air is extracted

to the scrubber and biofilter

Phase 2 Fermentation

7

24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of

the fermentation but with slightly different aeration and turning

requirements and continues until a critical point called peak heat is

reached From this time on the temperature reduces to the point

when the substrate is finished and cooled At this stage it has only a

very mild potting mix smell to it

Phase 2 Turning

25 This is identical to the phase 1 turning and again the filling hall is

under negative pressure The air is extracted to the scrubber and

biofilter

Phase 3 Spawning

26 Once the substrate is cooled to ambient temperature it is removed

from the tunnels into the filling hall As there is no significant odour

from the substrate at this stage the filling hall is under slight positive

pressure using filtered air to prevent contamination The mushroom

mycelium is added and the substrate is then returned to the tunnels

and left to grow After 14 to 21 days it is removed via the load out

hall and sent to the growing rooms There is no odour from this

stage

Miscellaneous Sources

27 Because the whole composting process will be fully enclosed there

are very few sources outside that could potentially cause odour and

the only ones would include the nutrient tank (goody water tank) and

deliveries of raw materials

28 The nutrient water tank will be vented into the pre-wet building and is

therefore under negative pressure There will be no odour from this

source

29 The only raw material that has any potential for odour is the chicken

manure However this will be delivered in covered trucks and only

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

6

Appendix B To maintain porosity the material is mechanically turned

once in this final week

17 The pre-wet building is maintained under negative pressure at all

times to prevent odour being released to atmosphere

Transfer

18 At the end of the conditioning period the material is loaded into the

mixing line and then conveyed to the tunnel building

19 The conveyor is covered and air is extracted from it into both the

filling hall and the pre-wet building The openings in both the pre-wet

and filling hall were taken into account in the design of the total

amount of ventilation air that is required in both the pre-wet and

filling hall to maintain negative pressure

Phase 1 Fermentation

20 Each of the tunnels is provided with under-floor aeration to maintain

optimum levels of oxygen and temperature in the compost mass

Temperatures vary through the process ranging between 40-80 oC

and are largely controlled using aeration air

21 In this part of the process the aeration and extraction is a fully sealed

system that is balanced to a slight negative pressure

22 All of the air used in the phase 1 tunnels is extracted to the acidwater

scrubbers and the biofilter

Phase 1 Turning

23 Turning involves removing the substrate from one tunnel and placing

it in another via the filling hall The filing hall and the tunnels are

under negative pressure during this operation and the air is extracted

to the scrubber and biofilter

Phase 2 Fermentation

7

24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of

the fermentation but with slightly different aeration and turning

requirements and continues until a critical point called peak heat is

reached From this time on the temperature reduces to the point

when the substrate is finished and cooled At this stage it has only a

very mild potting mix smell to it

Phase 2 Turning

25 This is identical to the phase 1 turning and again the filling hall is

under negative pressure The air is extracted to the scrubber and

biofilter

Phase 3 Spawning

26 Once the substrate is cooled to ambient temperature it is removed

from the tunnels into the filling hall As there is no significant odour

from the substrate at this stage the filling hall is under slight positive

pressure using filtered air to prevent contamination The mushroom

mycelium is added and the substrate is then returned to the tunnels

and left to grow After 14 to 21 days it is removed via the load out

hall and sent to the growing rooms There is no odour from this

stage

Miscellaneous Sources

27 Because the whole composting process will be fully enclosed there

are very few sources outside that could potentially cause odour and

the only ones would include the nutrient tank (goody water tank) and

deliveries of raw materials

28 The nutrient water tank will be vented into the pre-wet building and is

therefore under negative pressure There will be no odour from this

source

29 The only raw material that has any potential for odour is the chicken

manure However this will be delivered in covered trucks and only

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

7

24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of

the fermentation but with slightly different aeration and turning

requirements and continues until a critical point called peak heat is

reached From this time on the temperature reduces to the point

when the substrate is finished and cooled At this stage it has only a

very mild potting mix smell to it

Phase 2 Turning

25 This is identical to the phase 1 turning and again the filling hall is

under negative pressure The air is extracted to the scrubber and

biofilter

Phase 3 Spawning

26 Once the substrate is cooled to ambient temperature it is removed

from the tunnels into the filling hall As there is no significant odour

from the substrate at this stage the filling hall is under slight positive

pressure using filtered air to prevent contamination The mushroom

mycelium is added and the substrate is then returned to the tunnels

and left to grow After 14 to 21 days it is removed via the load out

hall and sent to the growing rooms There is no odour from this

stage

Miscellaneous Sources

27 Because the whole composting process will be fully enclosed there

are very few sources outside that could potentially cause odour and

the only ones would include the nutrient tank (goody water tank) and

deliveries of raw materials

28 The nutrient water tank will be vented into the pre-wet building and is

therefore under negative pressure There will be no odour from this

source

29 The only raw material that has any potential for odour is the chicken

manure However this will be delivered in covered trucks and only

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

8

unloaded inside the pre-wet building Under normal circumstances

chicken manure has very little odour potential when it is in a covered

truck In the event that unsuitable material is bought on site Mercer

will refuse to accept it and the contract for supply will be reviewed if

there are repeat instances This is set out in the air quality

management plan

BASIS FOR THE DESIGN PARAMETERS

30 The standard hierarchy for odour control engineering is prevention

capture at source followed by treatment and finally full building

enclosure with ventilation followed by treatment

31 In the case of compost or mushroom substrate production

preventing odour generation is not possible at this time but capture

at source is used in the phase 1 and 2 operations as the tunnels are

completely sealed and ventilated to the odour control system

However capture at source is not feasible for the pre-wet phase

filling and turning the substrate and odour control for these

operations must rely on full enclosure with building ventilation to the

odour control system as there are no feasible alternatives

32 In my opinion the proposed odor control system represents the Best

Available Control Technology (BACT) that is both more advanced and

effective than the BPO requirements of the RMA It is also the same

system that I recommended to the Environment Court in the New

Zealand Mushrooms2 case when I gave evidence in support of the

residents and more recently in the Te Mata Mushrooms hearing in

Havelock North

33 The building air extraction rates used for the combined pre-wet and

compost buildings were provided by the equipment manufacturer

Christiaens and I have used them to estimate the vacuum that could

2 ENV-2006-WLG-000356 ENV-2006-WLG-000344) and ENV-2006-WLG-000347 ENV-2006-WLG-000351

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

9

be achieved within the buildings A maximum pressure drop

achievable for the CANVACON building is estimated to be better than

about 50 Pa3 and about 40 Pa when the filling hall also contains

odourous material Pressure drop for both buildings will be controlled

down to a useable level of about 15 Pa at all times when there is

odourous material present

34 This operating pressure drop has been based on my 15 years personal

experience with the control of odours from the PVL Proteins Ltd

rendering plant the Living Earth compost facility in Careys Gully in

Wellington and the Glencore Grain store in New Plymouth It has

been found that 5 Pa vacuum (pressure drop) is the bare minimum

that is required to keep most odours inside a building but where

there will be still significant leaks during moderate to strong winds At

a pressure drop of 7 Pa most odours are kept inside and leaks that

occur only during reasonably strong winds (10 to 15m sec-1 or more)

are relatively minor and are only noticeable in the immediate vicinity

of the building

35 At a pressure drop of 10 Pa or more experience shows that there is no

detectable leakage even during very strong winds 15 Pa is the

operating pressure drop that I recommend to give extra security but

for consent conditions purposes a value of 7 Pa represents the

minimum that must be achieved at all times and is more suitable for

compliance purposes than the expected operational value Note that

these pressure drop values are those that are made during calm

conditions and are not the same as those that prevail during

operation under normal daytime (and windy) conditions

36 I note that some submitters have the view that the CANVACON

material is permeable That is incorrect CANVACON is a multilayer

polyethylene woven material sandwiched between outer

3 This is equivalent to a 75 kg wt force on a standard 15m

2 area door

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

10

polyethylene coating layers and for practical purposes it is

impermeable

SCRUBBERS AND BIOFILTER

37 Again these are described in detail in the technical assessment The

main purpose of the acid scrubber is to remove ammonia that has the

potential to interfere with the biomass population in the biofilter

thereby reducing its ability to remove odour The water scrubber is to

remove acid mist carry over into the biofilter for the same reasons

but it will also remove additional ammonia

38 The biofilter is a very standard design using wood chips and bark that

is widely used across New Zealand and is well proven The 2 metre

depth is the standard design used by Christiaens at their other

European installations and the bulk loading ratio of air flow rate to

filter material is the same as is commonly found in New Zealand

39 The proposed consent conditions for the scrubbers and biofilter are

mostly those that I recommend that achieve a balance between being

useful and excessive monitoring for parameters that do not require

frequent measurement

SUBMISSIONS

40 Where an issue is common to most submissions I deal with it as a

single issue rather than addressing each individual submission

Odour General

41 The common theme in relation to this application is that the

submitters in opposition to the application believe that there will be

odour discharges and that they will be offensive and objectionable I

agree that the odour from mushroom substrate production is in

general terms most definitely offensive and historically residents

have been subjected to unreasonable levels of this odour However

in this application all the odour will be contained and treated to the

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

11

extent that there will be no discernible odour at or beyond the

boundary of the site

42 Mr and Mrs Taylor are concerned that the potential reduction in air

extraction from the buildings at night will result in a loss of negative

pressure and therefore cause more odour The first point to note is

that the design of the ventilation system will achieve no odour which

means that there cannot be more odour The second important

point is that any reduction in air flow from the pre-wet or building or

filling hall will still require a minimum of 7 Pa negative pressure to be

maintained that will contain the odour If for some reason this

cannot be achieved at lower air flow rates then there will be no

reduction in air flow during night time hours

43 Amira Thompson is concerned that the odour from opening the pre-

wet door will have an adverse effect on her tenants This issue was

discussed in Section 3222 of the Assessment document but I can

elaborate on why I do not expect significant odour

44 A simple schematic of the pre-wet building is shown in Attachment A

to my evidence that includes a roof-to-floor plastic curtain separating

the pre-wet pile in the annex at the upper right hand corner of the

building that will have a 300 to 500 mm gap underneath to the floor

Most importantly the air extraction point for the building is located in

this annex where most of the odour is generated An inwards velocity

into this annex will be about between 1 to 2 m sec-1 which is two to

four times the typical 05 m sec-1 usually advocated for indoor air

quality control eg for fume or fine dust4

45 This means that most of the odour in the pre-wet building will be

collected in the Annex When the door is opened for 30 to 60 seconds

or so for vehicle access there will still be an inwards air velocity of 1 to

125 m sec-1 air through the main door but more importantly the

4 Industrial Ventilation A Manual of Recommended Practice American Conference of Governmental

Industrial Hygienists 27th Edition 2010 ISBN 1-882417-22-4

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

12

odour will still be confined to the far end near the annex In my

experience in designing large spray booths with similar large openings

and large air flow rates is that very little odour will be released5

providing that the duration of the opening is short In this application

Mercer Assets have estimated that the door will only remain open for

about 30 to 60 seconds

46 K amp J Foley cite the TampT report as stating that there will be adverse

odour effects during strong wind conditions This is incorrect As I

have noted the pre-wet building and the filling hall will be operated

with a design pressure drop of 15 Pa that fully contains the odours

under all conditions TampT actually state that there may be odours if

the doors are left open or the pre-wet building fabric is damaged

That is correct but the consent conditions require that the doors be

closed and that any damage to the fabric is repaired without delay

47 Stuart Harvey is also concerned about odour during strong winds See

above

Submission of John Karena and Marise Taplin

48 John Karena and Marise Taplin have prepared a detailed submission

and I address the issues raised by reference to their paragraph

numbers These issues are also common to many other submitters

so they are commented on here rather than for individual

submissions

49 Paragraph 34 Contingencies Most of the items listed in paragraph

34 are addressed in the draft air quality management plan (AQMP)

which is the appropriate place rather than in the assessment

document since the AQMP will be modified over time (with

agreement from the Regional Council) as procedures become more

efficient and accommodate new methods or control technologies

The AQMP combines the actions to be followed to achieve full

5 As noted in the application document the large air momentum through the door prevents significant

air outwards leakage

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

13

compliance with conditions actions to minimise equipment and

systems failures and procedures to be followed in the event of failure

However fan breakdown warrants special comment

50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are

extremely rare events at all of the industrial complexes that I have

been involved with over 35 years but in the event that one fan is not

operational the remaining fan is still expected to be able to maintain

a pressure drop of 7 Pa in the pre-wet building and the filling hall

which means that there is no additional risk of odour

51 Paragraph 36 Indoor Air Quality As noted in the application

document indoor health and safety issues are controlled under the

New Zealand Health and Safety at Work Act 2015 not the Resource

Management Act and it is administered by Worksafe New Zealand

not by Regional or District Councils The suggestion that doors may

be left open to enhance the indoor working conditions would

constitute a breach of consent in relation to keeping all doors closed

and maintaining negative pressure on the buildings Leaving doors

open is not an option

52 Paragraphs 37 and 38 Fugitive Odours The submitters are

concerned that there will be a loss of containment that could occur at

night During nighttime hours the pre-wet building will remain under

negative pressure but there will be no mechanical activity that could

result in damage The minimum negative pressure of 7 Pa and the

expected pressure of about 15 Pa are equivalent to the pressure

exerted by light winds of between 35 to 5 m sec-1 respectively which

would not be sufficient to cause any tears in the CANVACON material

53 As part of my analysis of the reliability of the CANVACON material I

sought information from the manufacturer regarding its strength and

long term performance A test report is copied in Attachment B In

summary The CANVACON welded seams have a very high shear

strength of 2800 kg per metre of seam and the tensile strength of the

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

14

fabric itself is clearly greater than 2800 kg m-2 Based on this data it is

highly unlikely to spontaneously tear during the evening hours

Finally the manufacturer has provided a response regarding non-

mechanically induced catastrophic failure of the structure that is

copied in Attachment C to my evidence In short this kind of failure is

unheard of by the supplier

54 I have already commented on the fugitive odours from chicken

manure above and it will not be a significant source

55 One point that the submitter makes in paragraph 38 is that conditions

will not be sufficient to control the odour effects My only comment

in this regard is that the design that Mercer Assets has chosen is

designed to contain all the odour irrespective of the constraints

imposed by the conditions

56 A major part of my brief from Mercer Assets was to assure them that

the proposed systems will actually work as promised by the

manufacturer so that there will be no offensive odour discharges

Having analysed the proposal in detail and assessed the expected

performance against similar in-service odour control systems I am

satisfied that provided the system is built and maintained in

accordance with the technical assessment I prepared then there will

be no odour and certainly no offensive odour

57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33

of the report the take-off scrubbing liquor will be piped to a storage

tank at a rate of a few litres per hour The submitters suggest that the

ammonia that has been removed from the air stream will be released

from the scrubber liquor and cause odour That is not possible

When ammonia is removed from the air stream by dilute acid it

forms ammonium sulphate that has no odour in acidic solution There

will be no ammonia released from the scrubbing liquor

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

15

58 Paragraph 40 Odour from the Process Water I understand that

concerns regarding process water odour have been raised by air

quality advisors engaged by the submitters but the specifics of those

concerns are not presented in the submission The details of the

process water were provided in Section 2 of the application technical

report that stated that all the process liquid is contained within the

buildings and piped to the outside storage tank that is vented to the

odour control system There will be no odour from the process water

59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours

There is no unproven technology involved in this application The

substrate preparation itself is a well known technology and not very

different to what has been previously used in the existing facility The

odour control system is not unproven technology Acid scrubbing to

remove ammonia is a very common technology and biofilters are

widespread throughout New Zealand and the rest of the word In

regard to the suggestion that dispersion modeling should have been

used to assess off-site odours there is no odour to model

60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo

meteorological data presented in the application document the 2001

to 2003 data can be compared to the more recent 2018 data for

Pukekohe in Attachment D to this evidence that also includes Ruakura

for the years 2012 - 2013 These more recent roses are consistent

with the original one presented in the application and typical of all the

Waikato and Auckland regions that do not significantly change from

year to year However as noted in the application the wind rose was

only included to give an overall indication of expected winds in the

area it was not used to assess the likely odour

61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL

factors are important when assessing odours However in this

application no FIDOL assessment has been carried out as no odour is

expected to be discharged

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

16

Dust General

62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report

(Notification letter report 24 May 2019) as indicating that there are

likely to be dust problems at their property This is also a recurring

issue raised by other submitters Section 5 of the TampT report does

mention dust at 67 Morrison Rd in relation to coarse dust that could

affect drinking water but the report does not state where they

believe this dust actually comes from I am unable to clarify this any

further as I am unaware of any significant dust sources that could

cause either nuisance or effects on drinking water

63 However TampT do go on to say that the effects of dust will be

negligible and I agree with this statement

64 In relation to the raw materials bales of straw that are still bound

have negligible dust generating capacity and all the rest of the raw

material handling ie gypsum chicken manure etc including bale

break will take place indoors with no dust generation

65 Construction related dust will be controlled with a water cart andor

water sprinklers as and when required

66 Finally the majority of dust generation in the Morrison Rd area will

actually be generated by wind-blown dust and dry soil from activities

on the surrounding horticultural farms A recent satellite photo dated

3rd March 2019 showing of the extent of this in the surrounding area

is shown in Attachment E to my evidence I would expect the

deposition of dust from these sources to generate dust that would be

orders of magnitude greater than what would be expected from the

Mercer Assets site It is also worth noting that this agricultural dust

will also contain large quantities of bio-aerosols that include fungi and

bacteria

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

17

BIO-AEROSOLS

67 Bio-aerosols were addressed in the application document that

included information on bacteria and fungi including Aspergillus

fumigatus (A fumigatus) and Legionella pneumophila (L

Pneumophila) In summary the available literature indicates that

levels of bio-aerosols in the vicinity of composting plants that use

biofilters for odour control are no different to natural background

levels and no adverse effects are expected from the proposed Mercer

Assets plant I note that the Council reviewer from TampT concurs

OFFICERS REPORT

68 I have already addressed the issues contained in the officers report

that I consider relevant in the above comments relating to the

submitters concerns In regard to the proposed conditions of

consent should it be granted they have been prepared in

consultation with the Council and I have advised Mercer Assets that

they are appropriate

ALTERNATIVE SITES

69 I was asked by Mercer Assests to assess two alternative sites for the

preparation of mushroom substrate The first site was in a disused

quarry at Waikaretu that is about 47 to 50km to the south west of the

current site Two options were considered one that involved

discharging the odour via a straw filter and the other through an

elevated stack

70 Odour emission data from the existing Cresta operation projected to

the proposed production rates was used to determine the extent of

odour on neighbouring properties

71 Based on my observation of the terrain I concluded that drainage

wind flows (katabatic) would preclude the use of a simple straw filter

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

18

and a large biofilter would be required together with full enclosure

Modelling was not required to demostrate this outcome as I relied on

my own experience with similar terrain effects on odour For the

option that used at least partial enclosure odour emission rate data

from the existing Cresta operation was extrapolated to the proposed

production rates and modelled for discharge up a tall stack The

predicted odour levels are shown in Attachment F to this evidence

and are orders of magnitude greater than the accepted Ministry for

the Environment guideline of 5 OU They are indicative of significant

odour nuisance for considerable off-site distances Both options

excluded this site unless full enclosure and filtration was used

72 The second alternative site was a remote area between Island Block

(Meremere) and Maramarua Again I concluded that that operations

on that site would cause odour nuisance to residents who were

located down slope from the proposed site due to the gentle

katabatic drainage winds and that full or partial enclosure would be

required

73 The outcome was that the same level of odour control and

infrastructure (ie full enclosure and odour filtering) would be

required at these sites as at the subject site Furthermore I also

advised Mercer Assets that this level of odour control would be

required at virtually any site in the wider Auckland and Waikato

regions because of the lack of suitable sites that are sufficiently

remote to not affect neighbouring properties if a lesser level of odour

control and infrastructure were adopted

74 Having concluded that full enclosure and odour filtering is necessary

whatever location is chosen and the adoption of that method avoids

odour effects there was no basis to pursue other sites further

75 It is also useful to consider that any alternative remote site would

incur significant transportation costs with the concurrent additional

carbon dioxide (CO2) emission For either the Waikaretu or

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

19

Maramarua locations I have calculated the emission to be about 120

tonnes per year My calculations are provided in Attachment F to my

evidence

CONCLUSION

76 The proposed mushroom substrate production and odour control

system adopted by Mercer Assets represents the Best Available

Control Technology anywhere in the world My assessment is that all

odours will be controlled to a very high level such that providing the

system is maintained in accordance with the proposed consent

conditions and the guidance I have provided in the Air Quality

Management Plan there should be no odour detected at the

boundary of the site and it follows therefore that there will likewise

be no offensive or objectionable odour

Terence John Brady

18 September 2019

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

ATTACHMENT A

PRE-WET EXTRACTION DETAILS

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

Pre-Wet fermentation takes place in annex in the upper right corner of the building where the main building extraction is located above the pre-wet material Roof to floor plastic curtains shown by dashed line with 300 to 500mm gap at floor

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 05 m

Area 228 m2

Velocity 11 msec

Phase 1 PreWet Aeration Section Calc for Containment

within the building annex

D 456 m

H 03 m

Area 1368 m2

Velocity 18 msec

A

B

C

E

D

F

extraction

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

ATTACHMENT B

CANVACON STRESS TEST

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

ATTACHMENT C

CANVACON RELIABILITY

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

FromSelf ltterrytbcplnetgt Tocraig Inger ltcraigmercermushroomsconzgt SubjectCanvacon Date sentMon 02 Sep 2019 160223 +1200

Hi Again Can you get any info from the CANVACON people regarding frequency of unexpected tears or

rips that have occurred on any of their installations ie not from mechanical damage but by

wind or faulty fabric

Terry Terry Brady Consulting Ltd PO Box 96 143 Balmoral Auckland 1342 New Zealand Ph 64 9 630 8710 Mobile 64 027 2970 230 Email terrytbcplnet FromMarty McConnell ltmartymercermushroomsconzgt Toterrytbcplnet ltterrytbcplnetgt SubjectFW Canvacon Date sentSun 8 Sep 2019 220132 +0000 From Paul Whitla [mailtopaulcontainerdomescomau] Sent Wednesday 4 September 2019 1116 AM To phillokaracomaultmailtophillokaracomaugt Subject RE Canvacon Hi Phill I can tell you that in the over 300 Container Dome covers we have supplied using Canvacon I have never experienced a case of this In my personal experience I have been using Canvacon in other areas for over 20 years and have also never heard of anything like this in other businesses I have worked for In my experience if the cover has been manufactured 100 correctly there is zero of chance of this being possible In fact if you look at the test one of our suppliers carried out with an engineer earlier this year you can see the fabric is much stronger than what we require it to be from an engineering point of view Paul Whitla Managing Director - Container Domes Australia T +61 7 5445 1032 - T 1300 793 822 - E paulcontainerdomescomaultmailtosalescontainerdomescomaugt - W containerdomescomau [cidimage003png01D56312645438E0]

ATTACHMENT D

WIND ROSES

NORTH

SOUTH

WEST EAST3

6

9

12

15

WIND SPEED

(ms)

gt= 100

50 - 100

30 - 50

20 - 30

10 - 20

05 - 10

Calms 592

Pukekohe 2018 Wind Rose

NORTH

SOUTH

WEST EAST3

6

9

12

15

WIND SPEED

(ms)

gt= 100

50 - 100

30 - 50

20 - 30

10 - 20

05 - 10

Calms 399

Pukekohe 2001 -2003 Wind Rose

NORTH

SOUTH

WEST EAST26

52

78

104

13

WIND SPEED

(ms)

gt= 111

88 - 111

57 - 88

36 - 57

21 - 36

05 - 21

Calms 000

Ruakura 2012 -2013 Wind Rose

ATTACHMENT D

SURROUNDING LAND USE

ATTACHMENT E

WAIKARETU ODOUR MODEL RESULTS

Figure A-E-1 Predicted odour levels (OU m-3) for a single stack option 200 Tonnes per week Production Guideline = 5 OU m-3 Red triangles are dwellings and cafe (rightmost marker)

Figure A-E-2 3D version of Fig A-E-1 Guideline = 5 OU m-3 Dwellings and cafe are mauve squares

ATTACHMENT F

CO2 CALCULATIONS

CO2 From Transport Calculation

Distance Morrison Rd to Waikeretu 47 km Similar dist for both

Round Trip 94 km Locations

Trips Per Week 17

Km Per Week 1598 km

Fuel Consumption 18 kmLitre Ref from Trucking Firm

Diesel Consumption per Week 888 Litres

Weeks Per Year 52 Weeks

Diesel Consumption per Annum 46164 Litres

Diesel CO2 emission factor 263 kg CO2Litre Fuel Ref WINFLUE Software

TOTAL CO2 Per Annum 121 Tonnes

Alternative MfE Calculation Ref MfE Table 18

km per Week 1598 km

km per Annum 83096 km

Diesel CO2 emission factor 136 kgkm gt30 Tonne 2010 to 2015 Fleet

TOTAL CO2 Per Annum 113 Tonnes

Ministry for the Environment 2019 Measuring Emissions A Guide for Organisations 2019 Summary of Emission Factors

• Qualifications and experience
• 1 My full name is Terence John Brady I am a Director of Terry Brady Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of Philosophy in Chemistry from the University of Canterbury New Zealand I specialise in air pollution control prepar
• 2 From 1983 to the end of 1991 I was employed by the Department of Health as an air pollution scientist responsible for industrial emissions for the upper half of the South Island under the Clean Air Act From 1991 to 1996 I was employed as an Air
• 3 My relevant experience includes assessing the actual and potential discharges to air from a very large variety of industries throughout New Zealand including the discharges of odour from composting I have been involved with many industrial projec
• 4 I have also designed and commissioned a considerable number of industrial ventilation systems for air pollution control purposes
• 5 Some specific projects that I have been involved with that have relevance to this application include
• • (a) Measurement modelling and assessment of odour from Living Earth composting at Pikes Point in Auckland Technical advice for monitoring programs
  • (b) Predictive modelling and assessment of odour from Living Earth composting at Puketutu Island in Auckland including Resource Consent application and the successful Environment Court appeal
  • (c) Assessment of odour effects for composting operations at Living EarthChristchurch City Council operation in Christchurch
  • (d) Assessment of potential odour effects for New Plymouth City Council composting operation
  • (e) Provided evidence in an Environment Court appeal involving New Zealand Mushrooms Ltd Morrinsville
  • (f) Assessment of potential effects of odour dust and bio-aerosols for the Living Earth Joint Venture in Careys Gully Wellington
  • (g) Assessment of effects of a greenwaste composting operation application by Whakatane District Council
  • (h) Measurement and assessment and remedial works for odours from the indoor composting plant at Cresta Mushrooms Mercer
  • (i) Assessment of engineering options to control odour from Te Mata Mushrooms Havelock North (ongoing)
  • • 6 In terms of scale composting operations I have been involved with range from a few thousand tonnes per annum to up to 75000 tonnes per annum
    • 7 I believe that I am well qualified to provide expert evidence on matters that have direct relevance to the application that is before the Independent Hearing Commissioners
    • 8 I have read the Code of Conduct for Expert Witnesses issued as part of the Environment Court Practice Notes I agree to comply with the code and am satisfied the matters I address in my evidence are within my expertise I am not aware of any mate
    • 9 In my evidence I will
    • • (a) Give an overview the application and the key odour sources as they relate to the odour control systems proposed
      • (b) Discuss the basis for the design parameters selected for odour containment
      • (c) The scrubber and biofilter odour control system
      • (d) Assess the odour impacts arising from the proposals
      • (e) Comment on the submissions received
      • (f) Comment on the Officers Report
      • (g) Provide context regarding alternative sites
      • • 10 The full details of the process are provided in the application technical document and the following represents a short summary
        • 11 The proposal is for the manufacture of mushroom substrate (compost) in a fully enclosed facility that will operate with full building air extraction on all parts of the buildings and processes that generate odour This odour-containing air will b
        • 12 Manufacturing will take place in two buildings beginning with the pre-wetting operation in the CANVACON pre-wet building followed by transfer to the filling hall in the main composting building that contains 12 fermentation tunnels From the fi
        • 13 After a pasturisation stage (in Phase 2) the substrate is cooled to ambient temperature and spawned with mushroom mycelium and held in the tunnels for 14-21 days before removal to the growing facility
        • KEY ODOUR SOURCES
        • 14 The main odour sources in process order are
        • • (a) The pre-wetting and turning in the Canvacon Building
          • (b) Transfer of pre-wetted material to the filling hall
          • (c) Phase 1 Fermentation
          • (d) Phase 1 Turning
          • (e) Phase 2 Fermentation
          • (f) Phase 2 Turning
          • (g) Miscellaneous sources
          • • 15 I discuss these below
            • Pre-Wet
            • 16 In the pre-wet stage straw bales are bought inside to the enclosed Pre-Wet building with a loader which are then submerged in to a dedicated lsquobathrsquo that is filled with nitrogen rich process water Once the bales are fully wetted they are then s
            • 17 The pre-wet building is maintained under negative pressure at all times to prevent odour being released to atmosphere
            • Transfer
            • 18 At the end of the conditioning period the material is loaded into the mixing line and then conveyed to the tunnel building
            • 19 The conveyor is covered and air is extracted from it into both the filling hall and the pre-wet building The openings in both the pre-wet and filling hall were taken into account in the design of the total amount of ventilation air that is requi
            • Phase 1 Fermentation
            • 20 Each of the tunnels is provided with under-floor aeration to maintain optimum levels of oxygen and temperature in the compost mass Temperatures vary through the process ranging between 40-80 oC and are largely controlled using aeration air
            • 21 In this part of the process the aeration and extraction is a fully sealed system that is balanced to a slight negative pressure
            • 22 All of the air used in the phase 1 tunnels is extracted to the acidwater scrubbers and the biofilter
            • Phase 1 Turning
            • 23 Turning involves removing the substrate from one tunnel and placing it in another via the filling hall The filing hall and the tunnels are under negative pressure during this operation and the air is extracted to the scrubber and biofilter
            • Phase 2 Fermentation
            • 24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of the fermentation but with slightly different aeration and turning requirements and continues until a critical point called peak heat is reached From this time on the tempera
            • Phase 2 Turning
            • 25 This is identical to the phase 1 turning and again the filling hall is under negative pressure The air is extracted to the scrubber and biofilter
            • Phase 3 Spawning
            • 26 Once the substrate is cooled to ambient temperature it is removed from the tunnels into the filling hall As there is no significant odour from the substrate at this stage the filling hall is under slight positive pressure using filtered air to
            • Miscellaneous Sources
            • 27 Because the whole composting process will be fully enclosed there are very few sources outside that could potentially cause odour and the only ones would include the nutrient tank (goody water tank) and deliveries of raw materials
            • 28 The nutrient water tank will be vented into the pre-wet building and is therefore under negative pressure There will be no odour from this source
            • 29 The only raw material that has any potential for odour is the chicken manure However this will be delivered in covered trucks and only unloaded inside the pre-wet building Under normal circumstances chicken manure has very little odour poten
            • 30 The standard hierarchy for odour control engineering is prevention capture at source followed by treatment and finally full building enclosure with ventilation followed by treatment
            • 31 In the case of compost or mushroom substrate production preventing odour generation is not possible at this time but capture at source is used in the phase 1 and 2 operations as the tunnels are completely sealed and ventilated to the odour contr
            • 32 In my opinion the proposed odor control system represents the Best Available Control Technology (BACT) that is both more advanced and effective than the BPO requirements of the RMA It is also the same system that I recommended to the Environment
            • 33 The building air extraction rates used for the combined pre-wet and compost buildings were provided by the equipment manufacturer Christiaens and I have used them to estimate the vacuum that could be achieved within the buildings A maximum press
            • 34 This operating pressure drop has been based on my 15 years personal experience with the control of odours from the PVL Proteins Ltd rendering plant the Living Earth compost facility in Careys Gully in Wellington and the Glencore Grain store in
            • 35 At a pressure drop of 10 Pa or more experience shows that there is no detectable leakage even during very strong winds 15 Pa is the operating pressure drop that I recommend to give extra security but for consent conditions purposes a value of
            • 36 I note that some submitters have the view that the CANVACON material is permeable That is incorrect CANVACON is a multilayer polyethylene woven material sandwiched between outer polyethylene coating layers and for practical purposes it is imp
            • 37 Again these are described in detail in the technical assessment The main purpose of the acid scrubber is to remove ammonia that has the potential to interfere with the biomass population in the biofilter thereby reducing its ability to remove
            • 38 The biofilter is a very standard design using wood chips and bark that is widely used across New Zealand and is well proven The 2 metre depth is the standard design used by Christiaens at their other European installations and the bulk loading
            • 39 The proposed consent conditions for the scrubbers and biofilter are mostly those that I recommend that achieve a balance between being useful and excessive monitoring for parameters that do not require frequent measurement
            • 40 Where an issue is common to most submissions I deal with it as a single issue rather than addressing each individual submission
            • 41 The common theme in relation to this application is that the submitters in opposition to the application believe that there will be odour discharges and that they will be offensive and objectionable I agree that the odour from mushroom substrate
            • 42 Mr and Mrs Taylor are concerned that the potential reduction in air extraction from the buildings at night will result in a loss of negative pressure and therefore cause more odour The first point to note is that the design of the ventilation
            • 43 Amira Thompson is concerned that the odour from opening the pre-wet door will have an adverse effect on her tenants This issue was discussed in Section 3222 of the Assessment document but I can elaborate on why I do not expect significant od
            • 44 A simple schematic of the pre-wet building is shown in Attachment A to my evidence that includes a roof-to-floor plastic curtain separating the pre-wet pile in the annex at the upper right hand corner of the building that will have a 300 to 500 mm
            • 45 This means that most of the odour in the pre-wet building will be collected in the Annex When the door is opened for 30 to 60 seconds or so for vehicle access there will still be an inwards air velocity of 1 to 125 m sec-1 air through the main
            • 46 K amp J Foley cite the TampT report as stating that there will be adverse odour effects during strong wind conditions This is incorrect As I have noted the pre-wet building and the filling hall will be operated with a design pressure drop of 15 P
            • 47 Stuart Harvey is also concerned about odour during strong winds See above
            • Submission of John Karena and Marise Taplin
            • 48 John Karena and Marise Taplin have prepared a detailed submission and I address the issues raised by reference to their paragraph numbers These issues are also common to many other submitters so they are commented on here rather than for indivi
            • 49 Paragraph 34 Contingencies Most of the items listed in paragraph 34 are addressed in the draft air quality management plan (AQMP) which is the appropriate place rather than in the assessment document since the AQMP will be modified over time (
            • 50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are extremely rare events at all of the industrial complexes that I have been involved with over 35 years but in the event that one fan is not operational the remaining fan is still
            • 51 Paragraph 36 Indoor Air Quality As noted in the application document indoor health and safety issues are controlled under the New Zealand Health and Safety at Work Act 2015 not the Resource Management Act and it is administered by Worksafe
            • 52 Paragraphs 37 and 38 Fugitive Odours The submitters are concerned that there will be a loss of containment that could occur at night During nighttime hours the pre-wet building will remain under negative pressure but there will be no mechan
            • 53 As part of my analysis of the reliability of the CANVACON material I sought information from the manufacturer regarding its strength and long term performance A test report is copied in Attachment B In summary The CANVACON welded seams have a
            • 54 I have already commented on the fugitive odours from chicken manure above and it will not be a significant source
            • 55 One point that the submitter makes in paragraph 38 is that conditions will not be sufficient to control the odour effects My only comment in this regard is that the design that Mercer Assets has chosen is designed to contain all the odour irresp
            • 56 A major part of my brief from Mercer Assets was to assure them that the proposed systems will actually work as promised by the manufacturer so that there will be no offensive odour discharges Having analysed the proposal in detail and assessed t
            • 57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33 of the report the take-off scrubbing liquor will be piped to a storage tank at a rate of a few litres per hour The submitters suggest that the ammonia that has been removed f
            • 58 Paragraph 40 Odour from the Process Water I understand that concerns regarding process water odour have been raised by air quality advisors engaged by the submitters but the specifics of those concerns are not presented in the submission Th
            • 59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours There is no unproven technology involved in this application The substrate preparation itself is a well known technology and not very different to what has been previously used
            • 60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo meteorological data presented in the application document the 2001 to 2003 data can be compared to the more recent 2018 data for Pukekohe in Attachment D to this evidence that
            • 61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL factors are important when assessing odours However in this application no FIDOL assessment has been carried out as no odour is expected to be discharged
            • Dust General
            • 62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report (Notification letter report 24 May 2019) as indicating that there are likely to be dust problems at their property This is also a recurring issue raised by other submitters Section 5
            • 63 However TampT do go on to say that the effects of dust will be negligible and I agree with this statement
            • 64 In relation to the raw materials bales of straw that are still bound have negligible dust generating capacity and all the rest of the raw material handling ie gypsum chicken manure etc including bale break will take place indoors with no dus
            • 65 Construction related dust will be controlled with a water cart andor water sprinklers as and when required
            • 66 Finally the majority of dust generation in the Morrison Rd area will actually be generated by wind-blown dust and dry soil from activities on the surrounding horticultural farms A recent satellite photo dated 3rd March 2019 showing of the exten
            • 67 Bio-aerosols were addressed in the application document that included information on bacteria and fungi including Aspergillus fumigatus (A fumigatus) and Legionella pneumophila (L Pneumophila) In summary the available literature indicates tha
            • 68 I have already addressed the issues contained in the officers report that I consider relevant in the above comments relating to the submitters concerns In regard to the proposed conditions of consent should it be granted they have been prepar
            • 69 I was asked by Mercer Assests to assess two alternative sites for the preparation of mushroom substrate The first site was in a disused quarry at Waikaretu that is about 47 to 50km to the south west of the current site Two options were conside
            • 70 Odour emission data from the existing Cresta operation projected to the proposed production rates was used to determine the extent of odour on neighbouring properties
            • 71 Based on my observation of the terrain I concluded that drainage wind flows (katabatic) would preclude the use of a simple straw filter and a large biofilter would be required together with full enclosure Modelling was not required to demostrat
            • 72 The second alternative site was a remote area between Island Block (Meremere) and Maramarua Again I concluded that that operations on that site would cause odour nuisance to residents who were located down slope from the proposed site due to th
            • 73 The outcome was that the same level of odour control and infrastructure (ie full enclosure and odour filtering) would be required at these sites as at the subject site Furthermore I also advised Mercer Assets that this level of odour control
            • 74 Having concluded that full enclosure and odour filtering is necessary whatever location is chosen and the adoption of that method avoids odour effects there was no basis to pursue other sites further
            • 75 It is also useful to consider that any alternative remote site would incur significant transportation costs with the concurrent additional carbon dioxide (CO2) emission For either the Waikaretu or Maramarua locations I have calculated the emissi
            • CONCLUSION
            • 76 The proposed mushroom substrate production and odour control system adopted by Mercer Assets represents the Best Available Control Technology anywhere in the world My assessment is that all odours will be controlled to a very high level such tha

NORTH

SOUTH

WEST EAST3

6

9

12

15

WIND SPEED

(ms)

gt= 100

50 - 100

30 - 50

20 - 30

10 - 20

05 - 10

Calms 592

Pukekohe 2018 Wind Rose

NORTH

SOUTH

WEST EAST3

6

9

12

15

WIND SPEED

(ms)

gt= 100

50 - 100

30 - 50

20 - 30

10 - 20

05 - 10

Calms 399

Pukekohe 2001 -2003 Wind Rose

NORTH

SOUTH

WEST EAST26

52

78

104

13

WIND SPEED

(ms)

gt= 111

88 - 111

57 - 88

36 - 57

21 - 36

05 - 21

Calms 000

Ruakura 2012 -2013 Wind Rose

ATTACHMENT D

SURROUNDING LAND USE

ATTACHMENT E

WAIKARETU ODOUR MODEL RESULTS

Figure A-E-1 Predicted odour levels (OU m-3) for a single stack option 200 Tonnes per week Production Guideline = 5 OU m-3 Red triangles are dwellings and cafe (rightmost marker)

Figure A-E-2 3D version of Fig A-E-1 Guideline = 5 OU m-3 Dwellings and cafe are mauve squares

ATTACHMENT F

CO2 CALCULATIONS

CO2 From Transport Calculation

Distance Morrison Rd to Waikeretu 47 km Similar dist for both

Round Trip 94 km Locations

Trips Per Week 17

Km Per Week 1598 km

Fuel Consumption 18 kmLitre Ref from Trucking Firm

Diesel Consumption per Week 888 Litres

Weeks Per Year 52 Weeks

Diesel Consumption per Annum 46164 Litres

Diesel CO2 emission factor 263 kg CO2Litre Fuel Ref WINFLUE Software

TOTAL CO2 Per Annum 121 Tonnes

Alternative MfE Calculation Ref MfE Table 18

km per Week 1598 km

km per Annum 83096 km

Diesel CO2 emission factor 136 kgkm gt30 Tonne 2010 to 2015 Fleet

TOTAL CO2 Per Annum 113 Tonnes

Ministry for the Environment 2019 Measuring Emissions A Guide for Organisations 2019 Summary of Emission Factors

• Qualifications and experience
• 1 My full name is Terence John Brady I am a Director of Terry Brady Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of Philosophy in Chemistry from the University of Canterbury New Zealand I specialise in air pollution control prepar
• 2 From 1983 to the end of 1991 I was employed by the Department of Health as an air pollution scientist responsible for industrial emissions for the upper half of the South Island under the Clean Air Act From 1991 to 1996 I was employed as an Air
• 3 My relevant experience includes assessing the actual and potential discharges to air from a very large variety of industries throughout New Zealand including the discharges of odour from composting I have been involved with many industrial projec
• 4 I have also designed and commissioned a considerable number of industrial ventilation systems for air pollution control purposes
• 5 Some specific projects that I have been involved with that have relevance to this application include
• • (a) Measurement modelling and assessment of odour from Living Earth composting at Pikes Point in Auckland Technical advice for monitoring programs
  • (b) Predictive modelling and assessment of odour from Living Earth composting at Puketutu Island in Auckland including Resource Consent application and the successful Environment Court appeal
  • (c) Assessment of odour effects for composting operations at Living EarthChristchurch City Council operation in Christchurch
  • (d) Assessment of potential odour effects for New Plymouth City Council composting operation
  • (e) Provided evidence in an Environment Court appeal involving New Zealand Mushrooms Ltd Morrinsville
  • (f) Assessment of potential effects of odour dust and bio-aerosols for the Living Earth Joint Venture in Careys Gully Wellington
  • (g) Assessment of effects of a greenwaste composting operation application by Whakatane District Council
  • (h) Measurement and assessment and remedial works for odours from the indoor composting plant at Cresta Mushrooms Mercer
  • (i) Assessment of engineering options to control odour from Te Mata Mushrooms Havelock North (ongoing)
  • • 6 In terms of scale composting operations I have been involved with range from a few thousand tonnes per annum to up to 75000 tonnes per annum
    • 7 I believe that I am well qualified to provide expert evidence on matters that have direct relevance to the application that is before the Independent Hearing Commissioners
    • 8 I have read the Code of Conduct for Expert Witnesses issued as part of the Environment Court Practice Notes I agree to comply with the code and am satisfied the matters I address in my evidence are within my expertise I am not aware of any mate
    • 9 In my evidence I will
    • • (a) Give an overview the application and the key odour sources as they relate to the odour control systems proposed
      • (b) Discuss the basis for the design parameters selected for odour containment
      • (c) The scrubber and biofilter odour control system
      • (d) Assess the odour impacts arising from the proposals
      • (e) Comment on the submissions received
      • (f) Comment on the Officers Report
      • (g) Provide context regarding alternative sites
      • • 10 The full details of the process are provided in the application technical document and the following represents a short summary
        • 11 The proposal is for the manufacture of mushroom substrate (compost) in a fully enclosed facility that will operate with full building air extraction on all parts of the buildings and processes that generate odour This odour-containing air will b
        • 12 Manufacturing will take place in two buildings beginning with the pre-wetting operation in the CANVACON pre-wet building followed by transfer to the filling hall in the main composting building that contains 12 fermentation tunnels From the fi
        • 13 After a pasturisation stage (in Phase 2) the substrate is cooled to ambient temperature and spawned with mushroom mycelium and held in the tunnels for 14-21 days before removal to the growing facility
        • KEY ODOUR SOURCES
        • 14 The main odour sources in process order are
        • • (a) The pre-wetting and turning in the Canvacon Building
          • (b) Transfer of pre-wetted material to the filling hall
          • (c) Phase 1 Fermentation
          • (d) Phase 1 Turning
          • (e) Phase 2 Fermentation
          • (f) Phase 2 Turning
          • (g) Miscellaneous sources
          • • 15 I discuss these below
            • Pre-Wet
            • 16 In the pre-wet stage straw bales are bought inside to the enclosed Pre-Wet building with a loader which are then submerged in to a dedicated lsquobathrsquo that is filled with nitrogen rich process water Once the bales are fully wetted they are then s
            • 17 The pre-wet building is maintained under negative pressure at all times to prevent odour being released to atmosphere
            • Transfer
            • 18 At the end of the conditioning period the material is loaded into the mixing line and then conveyed to the tunnel building
            • 19 The conveyor is covered and air is extracted from it into both the filling hall and the pre-wet building The openings in both the pre-wet and filling hall were taken into account in the design of the total amount of ventilation air that is requi
            • Phase 1 Fermentation
            • 20 Each of the tunnels is provided with under-floor aeration to maintain optimum levels of oxygen and temperature in the compost mass Temperatures vary through the process ranging between 40-80 oC and are largely controlled using aeration air
            • 21 In this part of the process the aeration and extraction is a fully sealed system that is balanced to a slight negative pressure
            • 22 All of the air used in the phase 1 tunnels is extracted to the acidwater scrubbers and the biofilter
            • Phase 1 Turning
            • 23 Turning involves removing the substrate from one tunnel and placing it in another via the filling hall The filing hall and the tunnels are under negative pressure during this operation and the air is extracted to the scrubber and biofilter
            • Phase 2 Fermentation
            • 24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of the fermentation but with slightly different aeration and turning requirements and continues until a critical point called peak heat is reached From this time on the tempera
            • Phase 2 Turning
            • 25 This is identical to the phase 1 turning and again the filling hall is under negative pressure The air is extracted to the scrubber and biofilter
            • Phase 3 Spawning
            • 26 Once the substrate is cooled to ambient temperature it is removed from the tunnels into the filling hall As there is no significant odour from the substrate at this stage the filling hall is under slight positive pressure using filtered air to
            • Miscellaneous Sources
            • 27 Because the whole composting process will be fully enclosed there are very few sources outside that could potentially cause odour and the only ones would include the nutrient tank (goody water tank) and deliveries of raw materials
            • 28 The nutrient water tank will be vented into the pre-wet building and is therefore under negative pressure There will be no odour from this source
            • 29 The only raw material that has any potential for odour is the chicken manure However this will be delivered in covered trucks and only unloaded inside the pre-wet building Under normal circumstances chicken manure has very little odour poten
            • 30 The standard hierarchy for odour control engineering is prevention capture at source followed by treatment and finally full building enclosure with ventilation followed by treatment
            • 31 In the case of compost or mushroom substrate production preventing odour generation is not possible at this time but capture at source is used in the phase 1 and 2 operations as the tunnels are completely sealed and ventilated to the odour contr
            • 32 In my opinion the proposed odor control system represents the Best Available Control Technology (BACT) that is both more advanced and effective than the BPO requirements of the RMA It is also the same system that I recommended to the Environment
            • 33 The building air extraction rates used for the combined pre-wet and compost buildings were provided by the equipment manufacturer Christiaens and I have used them to estimate the vacuum that could be achieved within the buildings A maximum press
            • 34 This operating pressure drop has been based on my 15 years personal experience with the control of odours from the PVL Proteins Ltd rendering plant the Living Earth compost facility in Careys Gully in Wellington and the Glencore Grain store in
            • 35 At a pressure drop of 10 Pa or more experience shows that there is no detectable leakage even during very strong winds 15 Pa is the operating pressure drop that I recommend to give extra security but for consent conditions purposes a value of
            • 36 I note that some submitters have the view that the CANVACON material is permeable That is incorrect CANVACON is a multilayer polyethylene woven material sandwiched between outer polyethylene coating layers and for practical purposes it is imp
            • 37 Again these are described in detail in the technical assessment The main purpose of the acid scrubber is to remove ammonia that has the potential to interfere with the biomass population in the biofilter thereby reducing its ability to remove
            • 38 The biofilter is a very standard design using wood chips and bark that is widely used across New Zealand and is well proven The 2 metre depth is the standard design used by Christiaens at their other European installations and the bulk loading
            • 39 The proposed consent conditions for the scrubbers and biofilter are mostly those that I recommend that achieve a balance between being useful and excessive monitoring for parameters that do not require frequent measurement
            • 40 Where an issue is common to most submissions I deal with it as a single issue rather than addressing each individual submission
            • 41 The common theme in relation to this application is that the submitters in opposition to the application believe that there will be odour discharges and that they will be offensive and objectionable I agree that the odour from mushroom substrate
            • 42 Mr and Mrs Taylor are concerned that the potential reduction in air extraction from the buildings at night will result in a loss of negative pressure and therefore cause more odour The first point to note is that the design of the ventilation
            • 43 Amira Thompson is concerned that the odour from opening the pre-wet door will have an adverse effect on her tenants This issue was discussed in Section 3222 of the Assessment document but I can elaborate on why I do not expect significant od
            • 44 A simple schematic of the pre-wet building is shown in Attachment A to my evidence that includes a roof-to-floor plastic curtain separating the pre-wet pile in the annex at the upper right hand corner of the building that will have a 300 to 500 mm
            • 45 This means that most of the odour in the pre-wet building will be collected in the Annex When the door is opened for 30 to 60 seconds or so for vehicle access there will still be an inwards air velocity of 1 to 125 m sec-1 air through the main
            • 46 K amp J Foley cite the TampT report as stating that there will be adverse odour effects during strong wind conditions This is incorrect As I have noted the pre-wet building and the filling hall will be operated with a design pressure drop of 15 P
            • 47 Stuart Harvey is also concerned about odour during strong winds See above
            • Submission of John Karena and Marise Taplin
            • 48 John Karena and Marise Taplin have prepared a detailed submission and I address the issues raised by reference to their paragraph numbers These issues are also common to many other submitters so they are commented on here rather than for indivi
            • 49 Paragraph 34 Contingencies Most of the items listed in paragraph 34 are addressed in the draft air quality management plan (AQMP) which is the appropriate place rather than in the assessment document since the AQMP will be modified over time (
            • 50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are extremely rare events at all of the industrial complexes that I have been involved with over 35 years but in the event that one fan is not operational the remaining fan is still
            • 51 Paragraph 36 Indoor Air Quality As noted in the application document indoor health and safety issues are controlled under the New Zealand Health and Safety at Work Act 2015 not the Resource Management Act and it is administered by Worksafe
            • 52 Paragraphs 37 and 38 Fugitive Odours The submitters are concerned that there will be a loss of containment that could occur at night During nighttime hours the pre-wet building will remain under negative pressure but there will be no mechan
            • 53 As part of my analysis of the reliability of the CANVACON material I sought information from the manufacturer regarding its strength and long term performance A test report is copied in Attachment B In summary The CANVACON welded seams have a
            • 54 I have already commented on the fugitive odours from chicken manure above and it will not be a significant source
            • 55 One point that the submitter makes in paragraph 38 is that conditions will not be sufficient to control the odour effects My only comment in this regard is that the design that Mercer Assets has chosen is designed to contain all the odour irresp
            • 56 A major part of my brief from Mercer Assets was to assure them that the proposed systems will actually work as promised by the manufacturer so that there will be no offensive odour discharges Having analysed the proposal in detail and assessed t
            • 57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33 of the report the take-off scrubbing liquor will be piped to a storage tank at a rate of a few litres per hour The submitters suggest that the ammonia that has been removed f
            • 58 Paragraph 40 Odour from the Process Water I understand that concerns regarding process water odour have been raised by air quality advisors engaged by the submitters but the specifics of those concerns are not presented in the submission Th
            • 59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours There is no unproven technology involved in this application The substrate preparation itself is a well known technology and not very different to what has been previously used
            • 60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo meteorological data presented in the application document the 2001 to 2003 data can be compared to the more recent 2018 data for Pukekohe in Attachment D to this evidence that
            • 61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL factors are important when assessing odours However in this application no FIDOL assessment has been carried out as no odour is expected to be discharged
            • Dust General
            • 62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report (Notification letter report 24 May 2019) as indicating that there are likely to be dust problems at their property This is also a recurring issue raised by other submitters Section 5
            • 63 However TampT do go on to say that the effects of dust will be negligible and I agree with this statement
            • 64 In relation to the raw materials bales of straw that are still bound have negligible dust generating capacity and all the rest of the raw material handling ie gypsum chicken manure etc including bale break will take place indoors with no dus
            • 65 Construction related dust will be controlled with a water cart andor water sprinklers as and when required
            • 66 Finally the majority of dust generation in the Morrison Rd area will actually be generated by wind-blown dust and dry soil from activities on the surrounding horticultural farms A recent satellite photo dated 3rd March 2019 showing of the exten
            • 67 Bio-aerosols were addressed in the application document that included information on bacteria and fungi including Aspergillus fumigatus (A fumigatus) and Legionella pneumophila (L Pneumophila) In summary the available literature indicates tha
            • 68 I have already addressed the issues contained in the officers report that I consider relevant in the above comments relating to the submitters concerns In regard to the proposed conditions of consent should it be granted they have been prepar
            • 69 I was asked by Mercer Assests to assess two alternative sites for the preparation of mushroom substrate The first site was in a disused quarry at Waikaretu that is about 47 to 50km to the south west of the current site Two options were conside
            • 70 Odour emission data from the existing Cresta operation projected to the proposed production rates was used to determine the extent of odour on neighbouring properties
            • 71 Based on my observation of the terrain I concluded that drainage wind flows (katabatic) would preclude the use of a simple straw filter and a large biofilter would be required together with full enclosure Modelling was not required to demostrat
            • 72 The second alternative site was a remote area between Island Block (Meremere) and Maramarua Again I concluded that that operations on that site would cause odour nuisance to residents who were located down slope from the proposed site due to th
            • 73 The outcome was that the same level of odour control and infrastructure (ie full enclosure and odour filtering) would be required at these sites as at the subject site Furthermore I also advised Mercer Assets that this level of odour control
            • 74 Having concluded that full enclosure and odour filtering is necessary whatever location is chosen and the adoption of that method avoids odour effects there was no basis to pursue other sites further
            • 75 It is also useful to consider that any alternative remote site would incur significant transportation costs with the concurrent additional carbon dioxide (CO2) emission For either the Waikaretu or Maramarua locations I have calculated the emissi
            • CONCLUSION
            • 76 The proposed mushroom substrate production and odour control system adopted by Mercer Assets represents the Best Available Control Technology anywhere in the world My assessment is that all odours will be controlled to a very high level such tha

ATTACHMENT D

SURROUNDING LAND USE

ATTACHMENT E

WAIKARETU ODOUR MODEL RESULTS

Figure A-E-1 Predicted odour levels (OU m-3) for a single stack option 200 Tonnes per week Production Guideline = 5 OU m-3 Red triangles are dwellings and cafe (rightmost marker)

Figure A-E-2 3D version of Fig A-E-1 Guideline = 5 OU m-3 Dwellings and cafe are mauve squares

ATTACHMENT F

CO2 CALCULATIONS

CO2 From Transport Calculation

Distance Morrison Rd to Waikeretu 47 km Similar dist for both

Round Trip 94 km Locations

Trips Per Week 17

Km Per Week 1598 km

Fuel Consumption 18 kmLitre Ref from Trucking Firm

Diesel Consumption per Week 888 Litres

Weeks Per Year 52 Weeks

Diesel Consumption per Annum 46164 Litres

Diesel CO2 emission factor 263 kg CO2Litre Fuel Ref WINFLUE Software

TOTAL CO2 Per Annum 121 Tonnes

Alternative MfE Calculation Ref MfE Table 18

km per Week 1598 km

km per Annum 83096 km

Diesel CO2 emission factor 136 kgkm gt30 Tonne 2010 to 2015 Fleet

TOTAL CO2 Per Annum 113 Tonnes

Ministry for the Environment 2019 Measuring Emissions A Guide for Organisations 2019 Summary of Emission Factors

• Qualifications and experience
• 1 My full name is Terence John Brady I am a Director of Terry Brady Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of Philosophy in Chemistry from the University of Canterbury New Zealand I specialise in air pollution control prepar
• 2 From 1983 to the end of 1991 I was employed by the Department of Health as an air pollution scientist responsible for industrial emissions for the upper half of the South Island under the Clean Air Act From 1991 to 1996 I was employed as an Air
• 3 My relevant experience includes assessing the actual and potential discharges to air from a very large variety of industries throughout New Zealand including the discharges of odour from composting I have been involved with many industrial projec
• 4 I have also designed and commissioned a considerable number of industrial ventilation systems for air pollution control purposes
• 5 Some specific projects that I have been involved with that have relevance to this application include
• • (a) Measurement modelling and assessment of odour from Living Earth composting at Pikes Point in Auckland Technical advice for monitoring programs
  • (b) Predictive modelling and assessment of odour from Living Earth composting at Puketutu Island in Auckland including Resource Consent application and the successful Environment Court appeal
  • (c) Assessment of odour effects for composting operations at Living EarthChristchurch City Council operation in Christchurch
  • (d) Assessment of potential odour effects for New Plymouth City Council composting operation
  • (e) Provided evidence in an Environment Court appeal involving New Zealand Mushrooms Ltd Morrinsville
  • (f) Assessment of potential effects of odour dust and bio-aerosols for the Living Earth Joint Venture in Careys Gully Wellington
  • (g) Assessment of effects of a greenwaste composting operation application by Whakatane District Council
  • (h) Measurement and assessment and remedial works for odours from the indoor composting plant at Cresta Mushrooms Mercer
  • (i) Assessment of engineering options to control odour from Te Mata Mushrooms Havelock North (ongoing)
  • • 6 In terms of scale composting operations I have been involved with range from a few thousand tonnes per annum to up to 75000 tonnes per annum
    • 7 I believe that I am well qualified to provide expert evidence on matters that have direct relevance to the application that is before the Independent Hearing Commissioners
    • 8 I have read the Code of Conduct for Expert Witnesses issued as part of the Environment Court Practice Notes I agree to comply with the code and am satisfied the matters I address in my evidence are within my expertise I am not aware of any mate
    • 9 In my evidence I will
    • • (a) Give an overview the application and the key odour sources as they relate to the odour control systems proposed
      • (b) Discuss the basis for the design parameters selected for odour containment
      • (c) The scrubber and biofilter odour control system
      • (d) Assess the odour impacts arising from the proposals
      • (e) Comment on the submissions received
      • (f) Comment on the Officers Report
      • (g) Provide context regarding alternative sites
      • • 10 The full details of the process are provided in the application technical document and the following represents a short summary
        • 11 The proposal is for the manufacture of mushroom substrate (compost) in a fully enclosed facility that will operate with full building air extraction on all parts of the buildings and processes that generate odour This odour-containing air will b
        • 12 Manufacturing will take place in two buildings beginning with the pre-wetting operation in the CANVACON pre-wet building followed by transfer to the filling hall in the main composting building that contains 12 fermentation tunnels From the fi
        • 13 After a pasturisation stage (in Phase 2) the substrate is cooled to ambient temperature and spawned with mushroom mycelium and held in the tunnels for 14-21 days before removal to the growing facility
        • KEY ODOUR SOURCES
        • 14 The main odour sources in process order are
        • • (a) The pre-wetting and turning in the Canvacon Building
          • (b) Transfer of pre-wetted material to the filling hall
          • (c) Phase 1 Fermentation
          • (d) Phase 1 Turning
          • (e) Phase 2 Fermentation
          • (f) Phase 2 Turning
          • (g) Miscellaneous sources
          • • 15 I discuss these below
            • Pre-Wet
            • 16 In the pre-wet stage straw bales are bought inside to the enclosed Pre-Wet building with a loader which are then submerged in to a dedicated lsquobathrsquo that is filled with nitrogen rich process water Once the bales are fully wetted they are then s
            • 17 The pre-wet building is maintained under negative pressure at all times to prevent odour being released to atmosphere
            • Transfer
            • 18 At the end of the conditioning period the material is loaded into the mixing line and then conveyed to the tunnel building
            • 19 The conveyor is covered and air is extracted from it into both the filling hall and the pre-wet building The openings in both the pre-wet and filling hall were taken into account in the design of the total amount of ventilation air that is requi
            • Phase 1 Fermentation
            • 20 Each of the tunnels is provided with under-floor aeration to maintain optimum levels of oxygen and temperature in the compost mass Temperatures vary through the process ranging between 40-80 oC and are largely controlled using aeration air
            • 21 In this part of the process the aeration and extraction is a fully sealed system that is balanced to a slight negative pressure
            • 22 All of the air used in the phase 1 tunnels is extracted to the acidwater scrubbers and the biofilter
            • Phase 1 Turning
            • 23 Turning involves removing the substrate from one tunnel and placing it in another via the filling hall The filing hall and the tunnels are under negative pressure during this operation and the air is extracted to the scrubber and biofilter
            • Phase 2 Fermentation
            • 24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of the fermentation but with slightly different aeration and turning requirements and continues until a critical point called peak heat is reached From this time on the tempera
            • Phase 2 Turning
            • 25 This is identical to the phase 1 turning and again the filling hall is under negative pressure The air is extracted to the scrubber and biofilter
            • Phase 3 Spawning
            • 26 Once the substrate is cooled to ambient temperature it is removed from the tunnels into the filling hall As there is no significant odour from the substrate at this stage the filling hall is under slight positive pressure using filtered air to
            • Miscellaneous Sources
            • 27 Because the whole composting process will be fully enclosed there are very few sources outside that could potentially cause odour and the only ones would include the nutrient tank (goody water tank) and deliveries of raw materials
            • 28 The nutrient water tank will be vented into the pre-wet building and is therefore under negative pressure There will be no odour from this source
            • 29 The only raw material that has any potential for odour is the chicken manure However this will be delivered in covered trucks and only unloaded inside the pre-wet building Under normal circumstances chicken manure has very little odour poten
            • 30 The standard hierarchy for odour control engineering is prevention capture at source followed by treatment and finally full building enclosure with ventilation followed by treatment
            • 31 In the case of compost or mushroom substrate production preventing odour generation is not possible at this time but capture at source is used in the phase 1 and 2 operations as the tunnels are completely sealed and ventilated to the odour contr
            • 32 In my opinion the proposed odor control system represents the Best Available Control Technology (BACT) that is both more advanced and effective than the BPO requirements of the RMA It is also the same system that I recommended to the Environment
            • 33 The building air extraction rates used for the combined pre-wet and compost buildings were provided by the equipment manufacturer Christiaens and I have used them to estimate the vacuum that could be achieved within the buildings A maximum press
            • 34 This operating pressure drop has been based on my 15 years personal experience with the control of odours from the PVL Proteins Ltd rendering plant the Living Earth compost facility in Careys Gully in Wellington and the Glencore Grain store in
            • 35 At a pressure drop of 10 Pa or more experience shows that there is no detectable leakage even during very strong winds 15 Pa is the operating pressure drop that I recommend to give extra security but for consent conditions purposes a value of
            • 36 I note that some submitters have the view that the CANVACON material is permeable That is incorrect CANVACON is a multilayer polyethylene woven material sandwiched between outer polyethylene coating layers and for practical purposes it is imp
            • 37 Again these are described in detail in the technical assessment The main purpose of the acid scrubber is to remove ammonia that has the potential to interfere with the biomass population in the biofilter thereby reducing its ability to remove
            • 38 The biofilter is a very standard design using wood chips and bark that is widely used across New Zealand and is well proven The 2 metre depth is the standard design used by Christiaens at their other European installations and the bulk loading
            • 39 The proposed consent conditions for the scrubbers and biofilter are mostly those that I recommend that achieve a balance between being useful and excessive monitoring for parameters that do not require frequent measurement
            • 40 Where an issue is common to most submissions I deal with it as a single issue rather than addressing each individual submission
            • 41 The common theme in relation to this application is that the submitters in opposition to the application believe that there will be odour discharges and that they will be offensive and objectionable I agree that the odour from mushroom substrate
            • 42 Mr and Mrs Taylor are concerned that the potential reduction in air extraction from the buildings at night will result in a loss of negative pressure and therefore cause more odour The first point to note is that the design of the ventilation
            • 43 Amira Thompson is concerned that the odour from opening the pre-wet door will have an adverse effect on her tenants This issue was discussed in Section 3222 of the Assessment document but I can elaborate on why I do not expect significant od
            • 44 A simple schematic of the pre-wet building is shown in Attachment A to my evidence that includes a roof-to-floor plastic curtain separating the pre-wet pile in the annex at the upper right hand corner of the building that will have a 300 to 500 mm
            • 45 This means that most of the odour in the pre-wet building will be collected in the Annex When the door is opened for 30 to 60 seconds or so for vehicle access there will still be an inwards air velocity of 1 to 125 m sec-1 air through the main
            • 46 K amp J Foley cite the TampT report as stating that there will be adverse odour effects during strong wind conditions This is incorrect As I have noted the pre-wet building and the filling hall will be operated with a design pressure drop of 15 P
            • 47 Stuart Harvey is also concerned about odour during strong winds See above
            • Submission of John Karena and Marise Taplin
            • 48 John Karena and Marise Taplin have prepared a detailed submission and I address the issues raised by reference to their paragraph numbers These issues are also common to many other submitters so they are commented on here rather than for indivi
            • 49 Paragraph 34 Contingencies Most of the items listed in paragraph 34 are addressed in the draft air quality management plan (AQMP) which is the appropriate place rather than in the assessment document since the AQMP will be modified over time (
            • 50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are extremely rare events at all of the industrial complexes that I have been involved with over 35 years but in the event that one fan is not operational the remaining fan is still
            • 51 Paragraph 36 Indoor Air Quality As noted in the application document indoor health and safety issues are controlled under the New Zealand Health and Safety at Work Act 2015 not the Resource Management Act and it is administered by Worksafe
            • 52 Paragraphs 37 and 38 Fugitive Odours The submitters are concerned that there will be a loss of containment that could occur at night During nighttime hours the pre-wet building will remain under negative pressure but there will be no mechan
            • 53 As part of my analysis of the reliability of the CANVACON material I sought information from the manufacturer regarding its strength and long term performance A test report is copied in Attachment B In summary The CANVACON welded seams have a
            • 54 I have already commented on the fugitive odours from chicken manure above and it will not be a significant source
            • 55 One point that the submitter makes in paragraph 38 is that conditions will not be sufficient to control the odour effects My only comment in this regard is that the design that Mercer Assets has chosen is designed to contain all the odour irresp
            • 56 A major part of my brief from Mercer Assets was to assure them that the proposed systems will actually work as promised by the manufacturer so that there will be no offensive odour discharges Having analysed the proposal in detail and assessed t
            • 57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33 of the report the take-off scrubbing liquor will be piped to a storage tank at a rate of a few litres per hour The submitters suggest that the ammonia that has been removed f
            • 58 Paragraph 40 Odour from the Process Water I understand that concerns regarding process water odour have been raised by air quality advisors engaged by the submitters but the specifics of those concerns are not presented in the submission Th
            • 59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours There is no unproven technology involved in this application The substrate preparation itself is a well known technology and not very different to what has been previously used
            • 60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo meteorological data presented in the application document the 2001 to 2003 data can be compared to the more recent 2018 data for Pukekohe in Attachment D to this evidence that
            • 61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL factors are important when assessing odours However in this application no FIDOL assessment has been carried out as no odour is expected to be discharged
            • Dust General
            • 62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report (Notification letter report 24 May 2019) as indicating that there are likely to be dust problems at their property This is also a recurring issue raised by other submitters Section 5
            • 63 However TampT do go on to say that the effects of dust will be negligible and I agree with this statement
            • 64 In relation to the raw materials bales of straw that are still bound have negligible dust generating capacity and all the rest of the raw material handling ie gypsum chicken manure etc including bale break will take place indoors with no dus
            • 65 Construction related dust will be controlled with a water cart andor water sprinklers as and when required
            • 66 Finally the majority of dust generation in the Morrison Rd area will actually be generated by wind-blown dust and dry soil from activities on the surrounding horticultural farms A recent satellite photo dated 3rd March 2019 showing of the exten
            • 67 Bio-aerosols were addressed in the application document that included information on bacteria and fungi including Aspergillus fumigatus (A fumigatus) and Legionella pneumophila (L Pneumophila) In summary the available literature indicates tha
            • 68 I have already addressed the issues contained in the officers report that I consider relevant in the above comments relating to the submitters concerns In regard to the proposed conditions of consent should it be granted they have been prepar
            • 69 I was asked by Mercer Assests to assess two alternative sites for the preparation of mushroom substrate The first site was in a disused quarry at Waikaretu that is about 47 to 50km to the south west of the current site Two options were conside
            • 70 Odour emission data from the existing Cresta operation projected to the proposed production rates was used to determine the extent of odour on neighbouring properties
            • 71 Based on my observation of the terrain I concluded that drainage wind flows (katabatic) would preclude the use of a simple straw filter and a large biofilter would be required together with full enclosure Modelling was not required to demostrat
            • 72 The second alternative site was a remote area between Island Block (Meremere) and Maramarua Again I concluded that that operations on that site would cause odour nuisance to residents who were located down slope from the proposed site due to th
            • 73 The outcome was that the same level of odour control and infrastructure (ie full enclosure and odour filtering) would be required at these sites as at the subject site Furthermore I also advised Mercer Assets that this level of odour control
            • 74 Having concluded that full enclosure and odour filtering is necessary whatever location is chosen and the adoption of that method avoids odour effects there was no basis to pursue other sites further
            • 75 It is also useful to consider that any alternative remote site would incur significant transportation costs with the concurrent additional carbon dioxide (CO2) emission For either the Waikaretu or Maramarua locations I have calculated the emissi
            • CONCLUSION
            • 76 The proposed mushroom substrate production and odour control system adopted by Mercer Assets represents the Best Available Control Technology anywhere in the world My assessment is that all odours will be controlled to a very high level such tha

ATTACHMENT E

WAIKARETU ODOUR MODEL RESULTS

Figure A-E-1 Predicted odour levels (OU m-3) for a single stack option 200 Tonnes per week Production Guideline = 5 OU m-3 Red triangles are dwellings and cafe (rightmost marker)

Figure A-E-2 3D version of Fig A-E-1 Guideline = 5 OU m-3 Dwellings and cafe are mauve squares

ATTACHMENT F

CO2 CALCULATIONS

CO2 From Transport Calculation

Distance Morrison Rd to Waikeretu 47 km Similar dist for both

Round Trip 94 km Locations

Trips Per Week 17

Km Per Week 1598 km

Fuel Consumption 18 kmLitre Ref from Trucking Firm

Diesel Consumption per Week 888 Litres

Weeks Per Year 52 Weeks

Diesel Consumption per Annum 46164 Litres

Diesel CO2 emission factor 263 kg CO2Litre Fuel Ref WINFLUE Software

TOTAL CO2 Per Annum 121 Tonnes

Alternative MfE Calculation Ref MfE Table 18

km per Week 1598 km

km per Annum 83096 km

Diesel CO2 emission factor 136 kgkm gt30 Tonne 2010 to 2015 Fleet

TOTAL CO2 Per Annum 113 Tonnes

Ministry for the Environment 2019 Measuring Emissions A Guide for Organisations 2019 Summary of Emission Factors

• Qualifications and experience
• 1 My full name is Terence John Brady I am a Director of Terry Brady Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of Philosophy in Chemistry from the University of Canterbury New Zealand I specialise in air pollution control prepar
• 2 From 1983 to the end of 1991 I was employed by the Department of Health as an air pollution scientist responsible for industrial emissions for the upper half of the South Island under the Clean Air Act From 1991 to 1996 I was employed as an Air
• 3 My relevant experience includes assessing the actual and potential discharges to air from a very large variety of industries throughout New Zealand including the discharges of odour from composting I have been involved with many industrial projec
• 4 I have also designed and commissioned a considerable number of industrial ventilation systems for air pollution control purposes
• 5 Some specific projects that I have been involved with that have relevance to this application include
• • (a) Measurement modelling and assessment of odour from Living Earth composting at Pikes Point in Auckland Technical advice for monitoring programs
  • (b) Predictive modelling and assessment of odour from Living Earth composting at Puketutu Island in Auckland including Resource Consent application and the successful Environment Court appeal
  • (c) Assessment of odour effects for composting operations at Living EarthChristchurch City Council operation in Christchurch
  • (d) Assessment of potential odour effects for New Plymouth City Council composting operation
  • (e) Provided evidence in an Environment Court appeal involving New Zealand Mushrooms Ltd Morrinsville
  • (f) Assessment of potential effects of odour dust and bio-aerosols for the Living Earth Joint Venture in Careys Gully Wellington
  • (g) Assessment of effects of a greenwaste composting operation application by Whakatane District Council
  • (h) Measurement and assessment and remedial works for odours from the indoor composting plant at Cresta Mushrooms Mercer
  • (i) Assessment of engineering options to control odour from Te Mata Mushrooms Havelock North (ongoing)
  • • 6 In terms of scale composting operations I have been involved with range from a few thousand tonnes per annum to up to 75000 tonnes per annum
    • 7 I believe that I am well qualified to provide expert evidence on matters that have direct relevance to the application that is before the Independent Hearing Commissioners
    • 8 I have read the Code of Conduct for Expert Witnesses issued as part of the Environment Court Practice Notes I agree to comply with the code and am satisfied the matters I address in my evidence are within my expertise I am not aware of any mate
    • 9 In my evidence I will
    • • (a) Give an overview the application and the key odour sources as they relate to the odour control systems proposed
      • (b) Discuss the basis for the design parameters selected for odour containment
      • (c) The scrubber and biofilter odour control system
      • (d) Assess the odour impacts arising from the proposals
      • (e) Comment on the submissions received
      • (f) Comment on the Officers Report
      • (g) Provide context regarding alternative sites
      • • 10 The full details of the process are provided in the application technical document and the following represents a short summary
        • 11 The proposal is for the manufacture of mushroom substrate (compost) in a fully enclosed facility that will operate with full building air extraction on all parts of the buildings and processes that generate odour This odour-containing air will b
        • 12 Manufacturing will take place in two buildings beginning with the pre-wetting operation in the CANVACON pre-wet building followed by transfer to the filling hall in the main composting building that contains 12 fermentation tunnels From the fi
        • 13 After a pasturisation stage (in Phase 2) the substrate is cooled to ambient temperature and spawned with mushroom mycelium and held in the tunnels for 14-21 days before removal to the growing facility
        • KEY ODOUR SOURCES
        • 14 The main odour sources in process order are
        • • (a) The pre-wetting and turning in the Canvacon Building
          • (b) Transfer of pre-wetted material to the filling hall
          • (c) Phase 1 Fermentation
          • (d) Phase 1 Turning
          • (e) Phase 2 Fermentation
          • (f) Phase 2 Turning
          • (g) Miscellaneous sources
          • • 15 I discuss these below
            • Pre-Wet
            • 16 In the pre-wet stage straw bales are bought inside to the enclosed Pre-Wet building with a loader which are then submerged in to a dedicated lsquobathrsquo that is filled with nitrogen rich process water Once the bales are fully wetted they are then s
            • 17 The pre-wet building is maintained under negative pressure at all times to prevent odour being released to atmosphere
            • Transfer
            • 18 At the end of the conditioning period the material is loaded into the mixing line and then conveyed to the tunnel building
            • 19 The conveyor is covered and air is extracted from it into both the filling hall and the pre-wet building The openings in both the pre-wet and filling hall were taken into account in the design of the total amount of ventilation air that is requi
            • Phase 1 Fermentation
            • 20 Each of the tunnels is provided with under-floor aeration to maintain optimum levels of oxygen and temperature in the compost mass Temperatures vary through the process ranging between 40-80 oC and are largely controlled using aeration air
            • 21 In this part of the process the aeration and extraction is a fully sealed system that is balanced to a slight negative pressure
            • 22 All of the air used in the phase 1 tunnels is extracted to the acidwater scrubbers and the biofilter
            • Phase 1 Turning
            • 23 Turning involves removing the substrate from one tunnel and placing it in another via the filling hall The filing hall and the tunnels are under negative pressure during this operation and the air is extracted to the scrubber and biofilter
            • Phase 2 Fermentation
            • 24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of the fermentation but with slightly different aeration and turning requirements and continues until a critical point called peak heat is reached From this time on the tempera
            • Phase 2 Turning
            • 25 This is identical to the phase 1 turning and again the filling hall is under negative pressure The air is extracted to the scrubber and biofilter
            • Phase 3 Spawning
            • 26 Once the substrate is cooled to ambient temperature it is removed from the tunnels into the filling hall As there is no significant odour from the substrate at this stage the filling hall is under slight positive pressure using filtered air to
            • Miscellaneous Sources
            • 27 Because the whole composting process will be fully enclosed there are very few sources outside that could potentially cause odour and the only ones would include the nutrient tank (goody water tank) and deliveries of raw materials
            • 28 The nutrient water tank will be vented into the pre-wet building and is therefore under negative pressure There will be no odour from this source
            • 29 The only raw material that has any potential for odour is the chicken manure However this will be delivered in covered trucks and only unloaded inside the pre-wet building Under normal circumstances chicken manure has very little odour poten
            • 30 The standard hierarchy for odour control engineering is prevention capture at source followed by treatment and finally full building enclosure with ventilation followed by treatment
            • 31 In the case of compost or mushroom substrate production preventing odour generation is not possible at this time but capture at source is used in the phase 1 and 2 operations as the tunnels are completely sealed and ventilated to the odour contr
            • 32 In my opinion the proposed odor control system represents the Best Available Control Technology (BACT) that is both more advanced and effective than the BPO requirements of the RMA It is also the same system that I recommended to the Environment
            • 33 The building air extraction rates used for the combined pre-wet and compost buildings were provided by the equipment manufacturer Christiaens and I have used them to estimate the vacuum that could be achieved within the buildings A maximum press
            • 34 This operating pressure drop has been based on my 15 years personal experience with the control of odours from the PVL Proteins Ltd rendering plant the Living Earth compost facility in Careys Gully in Wellington and the Glencore Grain store in
            • 35 At a pressure drop of 10 Pa or more experience shows that there is no detectable leakage even during very strong winds 15 Pa is the operating pressure drop that I recommend to give extra security but for consent conditions purposes a value of
            • 36 I note that some submitters have the view that the CANVACON material is permeable That is incorrect CANVACON is a multilayer polyethylene woven material sandwiched between outer polyethylene coating layers and for practical purposes it is imp
            • 37 Again these are described in detail in the technical assessment The main purpose of the acid scrubber is to remove ammonia that has the potential to interfere with the biomass population in the biofilter thereby reducing its ability to remove
            • 38 The biofilter is a very standard design using wood chips and bark that is widely used across New Zealand and is well proven The 2 metre depth is the standard design used by Christiaens at their other European installations and the bulk loading
            • 39 The proposed consent conditions for the scrubbers and biofilter are mostly those that I recommend that achieve a balance between being useful and excessive monitoring for parameters that do not require frequent measurement
            • 40 Where an issue is common to most submissions I deal with it as a single issue rather than addressing each individual submission
            • 41 The common theme in relation to this application is that the submitters in opposition to the application believe that there will be odour discharges and that they will be offensive and objectionable I agree that the odour from mushroom substrate
            • 42 Mr and Mrs Taylor are concerned that the potential reduction in air extraction from the buildings at night will result in a loss of negative pressure and therefore cause more odour The first point to note is that the design of the ventilation
            • 43 Amira Thompson is concerned that the odour from opening the pre-wet door will have an adverse effect on her tenants This issue was discussed in Section 3222 of the Assessment document but I can elaborate on why I do not expect significant od
            • 44 A simple schematic of the pre-wet building is shown in Attachment A to my evidence that includes a roof-to-floor plastic curtain separating the pre-wet pile in the annex at the upper right hand corner of the building that will have a 300 to 500 mm
            • 45 This means that most of the odour in the pre-wet building will be collected in the Annex When the door is opened for 30 to 60 seconds or so for vehicle access there will still be an inwards air velocity of 1 to 125 m sec-1 air through the main
            • 46 K amp J Foley cite the TampT report as stating that there will be adverse odour effects during strong wind conditions This is incorrect As I have noted the pre-wet building and the filling hall will be operated with a design pressure drop of 15 P
            • 47 Stuart Harvey is also concerned about odour during strong winds See above
            • Submission of John Karena and Marise Taplin
            • 48 John Karena and Marise Taplin have prepared a detailed submission and I address the issues raised by reference to their paragraph numbers These issues are also common to many other submitters so they are commented on here rather than for indivi
            • 49 Paragraph 34 Contingencies Most of the items listed in paragraph 34 are addressed in the draft air quality management plan (AQMP) which is the appropriate place rather than in the assessment document since the AQMP will be modified over time (
            • 50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are extremely rare events at all of the industrial complexes that I have been involved with over 35 years but in the event that one fan is not operational the remaining fan is still
            • 51 Paragraph 36 Indoor Air Quality As noted in the application document indoor health and safety issues are controlled under the New Zealand Health and Safety at Work Act 2015 not the Resource Management Act and it is administered by Worksafe
            • 52 Paragraphs 37 and 38 Fugitive Odours The submitters are concerned that there will be a loss of containment that could occur at night During nighttime hours the pre-wet building will remain under negative pressure but there will be no mechan
            • 53 As part of my analysis of the reliability of the CANVACON material I sought information from the manufacturer regarding its strength and long term performance A test report is copied in Attachment B In summary The CANVACON welded seams have a
            • 54 I have already commented on the fugitive odours from chicken manure above and it will not be a significant source
            • 55 One point that the submitter makes in paragraph 38 is that conditions will not be sufficient to control the odour effects My only comment in this regard is that the design that Mercer Assets has chosen is designed to contain all the odour irresp
            • 56 A major part of my brief from Mercer Assets was to assure them that the proposed systems will actually work as promised by the manufacturer so that there will be no offensive odour discharges Having analysed the proposal in detail and assessed t
            • 57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33 of the report the take-off scrubbing liquor will be piped to a storage tank at a rate of a few litres per hour The submitters suggest that the ammonia that has been removed f
            • 58 Paragraph 40 Odour from the Process Water I understand that concerns regarding process water odour have been raised by air quality advisors engaged by the submitters but the specifics of those concerns are not presented in the submission Th
            • 59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours There is no unproven technology involved in this application The substrate preparation itself is a well known technology and not very different to what has been previously used
            • 60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo meteorological data presented in the application document the 2001 to 2003 data can be compared to the more recent 2018 data for Pukekohe in Attachment D to this evidence that
            • 61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL factors are important when assessing odours However in this application no FIDOL assessment has been carried out as no odour is expected to be discharged
            • Dust General
            • 62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report (Notification letter report 24 May 2019) as indicating that there are likely to be dust problems at their property This is also a recurring issue raised by other submitters Section 5
            • 63 However TampT do go on to say that the effects of dust will be negligible and I agree with this statement
            • 64 In relation to the raw materials bales of straw that are still bound have negligible dust generating capacity and all the rest of the raw material handling ie gypsum chicken manure etc including bale break will take place indoors with no dus
            • 65 Construction related dust will be controlled with a water cart andor water sprinklers as and when required
            • 66 Finally the majority of dust generation in the Morrison Rd area will actually be generated by wind-blown dust and dry soil from activities on the surrounding horticultural farms A recent satellite photo dated 3rd March 2019 showing of the exten
            • 67 Bio-aerosols were addressed in the application document that included information on bacteria and fungi including Aspergillus fumigatus (A fumigatus) and Legionella pneumophila (L Pneumophila) In summary the available literature indicates tha
            • 68 I have already addressed the issues contained in the officers report that I consider relevant in the above comments relating to the submitters concerns In regard to the proposed conditions of consent should it be granted they have been prepar
            • 69 I was asked by Mercer Assests to assess two alternative sites for the preparation of mushroom substrate The first site was in a disused quarry at Waikaretu that is about 47 to 50km to the south west of the current site Two options were conside
            • 70 Odour emission data from the existing Cresta operation projected to the proposed production rates was used to determine the extent of odour on neighbouring properties
            • 71 Based on my observation of the terrain I concluded that drainage wind flows (katabatic) would preclude the use of a simple straw filter and a large biofilter would be required together with full enclosure Modelling was not required to demostrat
            • 72 The second alternative site was a remote area between Island Block (Meremere) and Maramarua Again I concluded that that operations on that site would cause odour nuisance to residents who were located down slope from the proposed site due to th
            • 73 The outcome was that the same level of odour control and infrastructure (ie full enclosure and odour filtering) would be required at these sites as at the subject site Furthermore I also advised Mercer Assets that this level of odour control
            • 74 Having concluded that full enclosure and odour filtering is necessary whatever location is chosen and the adoption of that method avoids odour effects there was no basis to pursue other sites further
            • 75 It is also useful to consider that any alternative remote site would incur significant transportation costs with the concurrent additional carbon dioxide (CO2) emission For either the Waikaretu or Maramarua locations I have calculated the emissi
            • CONCLUSION
            • 76 The proposed mushroom substrate production and odour control system adopted by Mercer Assets represents the Best Available Control Technology anywhere in the world My assessment is that all odours will be controlled to a very high level such tha

Figure A-E-1 Predicted odour levels (OU m-3) for a single stack option 200 Tonnes per week Production Guideline = 5 OU m-3 Red triangles are dwellings and cafe (rightmost marker)

Figure A-E-2 3D version of Fig A-E-1 Guideline = 5 OU m-3 Dwellings and cafe are mauve squares

ATTACHMENT F

CO2 CALCULATIONS

CO2 From Transport Calculation

Distance Morrison Rd to Waikeretu 47 km Similar dist for both

Round Trip 94 km Locations

Trips Per Week 17

Km Per Week 1598 km

Fuel Consumption 18 kmLitre Ref from Trucking Firm

Diesel Consumption per Week 888 Litres

Weeks Per Year 52 Weeks

Diesel Consumption per Annum 46164 Litres

Diesel CO2 emission factor 263 kg CO2Litre Fuel Ref WINFLUE Software

TOTAL CO2 Per Annum 121 Tonnes

Alternative MfE Calculation Ref MfE Table 18

km per Week 1598 km

km per Annum 83096 km

Diesel CO2 emission factor 136 kgkm gt30 Tonne 2010 to 2015 Fleet

TOTAL CO2 Per Annum 113 Tonnes

Ministry for the Environment 2019 Measuring Emissions A Guide for Organisations 2019 Summary of Emission Factors

• Qualifications and experience
• 1 My full name is Terence John Brady I am a Director of Terry Brady Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of Philosophy in Chemistry from the University of Canterbury New Zealand I specialise in air pollution control prepar
• 2 From 1983 to the end of 1991 I was employed by the Department of Health as an air pollution scientist responsible for industrial emissions for the upper half of the South Island under the Clean Air Act From 1991 to 1996 I was employed as an Air
• 3 My relevant experience includes assessing the actual and potential discharges to air from a very large variety of industries throughout New Zealand including the discharges of odour from composting I have been involved with many industrial projec
• 4 I have also designed and commissioned a considerable number of industrial ventilation systems for air pollution control purposes
• 5 Some specific projects that I have been involved with that have relevance to this application include
• • (a) Measurement modelling and assessment of odour from Living Earth composting at Pikes Point in Auckland Technical advice for monitoring programs
  • (b) Predictive modelling and assessment of odour from Living Earth composting at Puketutu Island in Auckland including Resource Consent application and the successful Environment Court appeal
  • (c) Assessment of odour effects for composting operations at Living EarthChristchurch City Council operation in Christchurch
  • (d) Assessment of potential odour effects for New Plymouth City Council composting operation
  • (e) Provided evidence in an Environment Court appeal involving New Zealand Mushrooms Ltd Morrinsville
  • (f) Assessment of potential effects of odour dust and bio-aerosols for the Living Earth Joint Venture in Careys Gully Wellington
  • (g) Assessment of effects of a greenwaste composting operation application by Whakatane District Council
  • (h) Measurement and assessment and remedial works for odours from the indoor composting plant at Cresta Mushrooms Mercer
  • (i) Assessment of engineering options to control odour from Te Mata Mushrooms Havelock North (ongoing)
  • • 6 In terms of scale composting operations I have been involved with range from a few thousand tonnes per annum to up to 75000 tonnes per annum
    • 7 I believe that I am well qualified to provide expert evidence on matters that have direct relevance to the application that is before the Independent Hearing Commissioners
    • 8 I have read the Code of Conduct for Expert Witnesses issued as part of the Environment Court Practice Notes I agree to comply with the code and am satisfied the matters I address in my evidence are within my expertise I am not aware of any mate
    • 9 In my evidence I will
    • • (a) Give an overview the application and the key odour sources as they relate to the odour control systems proposed
      • (b) Discuss the basis for the design parameters selected for odour containment
      • (c) The scrubber and biofilter odour control system
      • (d) Assess the odour impacts arising from the proposals
      • (e) Comment on the submissions received
      • (f) Comment on the Officers Report
      • (g) Provide context regarding alternative sites
      • • 10 The full details of the process are provided in the application technical document and the following represents a short summary
        • 11 The proposal is for the manufacture of mushroom substrate (compost) in a fully enclosed facility that will operate with full building air extraction on all parts of the buildings and processes that generate odour This odour-containing air will b
        • 12 Manufacturing will take place in two buildings beginning with the pre-wetting operation in the CANVACON pre-wet building followed by transfer to the filling hall in the main composting building that contains 12 fermentation tunnels From the fi
        • 13 After a pasturisation stage (in Phase 2) the substrate is cooled to ambient temperature and spawned with mushroom mycelium and held in the tunnels for 14-21 days before removal to the growing facility
        • KEY ODOUR SOURCES
        • 14 The main odour sources in process order are
        • • (a) The pre-wetting and turning in the Canvacon Building
          • (b) Transfer of pre-wetted material to the filling hall
          • (c) Phase 1 Fermentation
          • (d) Phase 1 Turning
          • (e) Phase 2 Fermentation
          • (f) Phase 2 Turning
          • (g) Miscellaneous sources
          • • 15 I discuss these below
            • Pre-Wet
            • 16 In the pre-wet stage straw bales are bought inside to the enclosed Pre-Wet building with a loader which are then submerged in to a dedicated lsquobathrsquo that is filled with nitrogen rich process water Once the bales are fully wetted they are then s
            • 17 The pre-wet building is maintained under negative pressure at all times to prevent odour being released to atmosphere
            • Transfer
            • 18 At the end of the conditioning period the material is loaded into the mixing line and then conveyed to the tunnel building
            • 19 The conveyor is covered and air is extracted from it into both the filling hall and the pre-wet building The openings in both the pre-wet and filling hall were taken into account in the design of the total amount of ventilation air that is requi
            • Phase 1 Fermentation
            • 20 Each of the tunnels is provided with under-floor aeration to maintain optimum levels of oxygen and temperature in the compost mass Temperatures vary through the process ranging between 40-80 oC and are largely controlled using aeration air
            • 21 In this part of the process the aeration and extraction is a fully sealed system that is balanced to a slight negative pressure
            • 22 All of the air used in the phase 1 tunnels is extracted to the acidwater scrubbers and the biofilter
            • Phase 1 Turning
            • 23 Turning involves removing the substrate from one tunnel and placing it in another via the filling hall The filing hall and the tunnels are under negative pressure during this operation and the air is extracted to the scrubber and biofilter
            • Phase 2 Fermentation
            • 24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of the fermentation but with slightly different aeration and turning requirements and continues until a critical point called peak heat is reached From this time on the tempera
            • Phase 2 Turning
            • 25 This is identical to the phase 1 turning and again the filling hall is under negative pressure The air is extracted to the scrubber and biofilter
            • Phase 3 Spawning
            • 26 Once the substrate is cooled to ambient temperature it is removed from the tunnels into the filling hall As there is no significant odour from the substrate at this stage the filling hall is under slight positive pressure using filtered air to
            • Miscellaneous Sources
            • 27 Because the whole composting process will be fully enclosed there are very few sources outside that could potentially cause odour and the only ones would include the nutrient tank (goody water tank) and deliveries of raw materials
            • 28 The nutrient water tank will be vented into the pre-wet building and is therefore under negative pressure There will be no odour from this source
            • 29 The only raw material that has any potential for odour is the chicken manure However this will be delivered in covered trucks and only unloaded inside the pre-wet building Under normal circumstances chicken manure has very little odour poten
            • 30 The standard hierarchy for odour control engineering is prevention capture at source followed by treatment and finally full building enclosure with ventilation followed by treatment
            • 31 In the case of compost or mushroom substrate production preventing odour generation is not possible at this time but capture at source is used in the phase 1 and 2 operations as the tunnels are completely sealed and ventilated to the odour contr
            • 32 In my opinion the proposed odor control system represents the Best Available Control Technology (BACT) that is both more advanced and effective than the BPO requirements of the RMA It is also the same system that I recommended to the Environment
            • 33 The building air extraction rates used for the combined pre-wet and compost buildings were provided by the equipment manufacturer Christiaens and I have used them to estimate the vacuum that could be achieved within the buildings A maximum press
            • 34 This operating pressure drop has been based on my 15 years personal experience with the control of odours from the PVL Proteins Ltd rendering plant the Living Earth compost facility in Careys Gully in Wellington and the Glencore Grain store in
            • 35 At a pressure drop of 10 Pa or more experience shows that there is no detectable leakage even during very strong winds 15 Pa is the operating pressure drop that I recommend to give extra security but for consent conditions purposes a value of
            • 36 I note that some submitters have the view that the CANVACON material is permeable That is incorrect CANVACON is a multilayer polyethylene woven material sandwiched between outer polyethylene coating layers and for practical purposes it is imp
            • 37 Again these are described in detail in the technical assessment The main purpose of the acid scrubber is to remove ammonia that has the potential to interfere with the biomass population in the biofilter thereby reducing its ability to remove
            • 38 The biofilter is a very standard design using wood chips and bark that is widely used across New Zealand and is well proven The 2 metre depth is the standard design used by Christiaens at their other European installations and the bulk loading
            • 39 The proposed consent conditions for the scrubbers and biofilter are mostly those that I recommend that achieve a balance between being useful and excessive monitoring for parameters that do not require frequent measurement
            • 40 Where an issue is common to most submissions I deal with it as a single issue rather than addressing each individual submission
            • 41 The common theme in relation to this application is that the submitters in opposition to the application believe that there will be odour discharges and that they will be offensive and objectionable I agree that the odour from mushroom substrate
            • 42 Mr and Mrs Taylor are concerned that the potential reduction in air extraction from the buildings at night will result in a loss of negative pressure and therefore cause more odour The first point to note is that the design of the ventilation
            • 43 Amira Thompson is concerned that the odour from opening the pre-wet door will have an adverse effect on her tenants This issue was discussed in Section 3222 of the Assessment document but I can elaborate on why I do not expect significant od
            • 44 A simple schematic of the pre-wet building is shown in Attachment A to my evidence that includes a roof-to-floor plastic curtain separating the pre-wet pile in the annex at the upper right hand corner of the building that will have a 300 to 500 mm
            • 45 This means that most of the odour in the pre-wet building will be collected in the Annex When the door is opened for 30 to 60 seconds or so for vehicle access there will still be an inwards air velocity of 1 to 125 m sec-1 air through the main
            • 46 K amp J Foley cite the TampT report as stating that there will be adverse odour effects during strong wind conditions This is incorrect As I have noted the pre-wet building and the filling hall will be operated with a design pressure drop of 15 P
            • 47 Stuart Harvey is also concerned about odour during strong winds See above
            • Submission of John Karena and Marise Taplin
            • 48 John Karena and Marise Taplin have prepared a detailed submission and I address the issues raised by reference to their paragraph numbers These issues are also common to many other submitters so they are commented on here rather than for indivi
            • 49 Paragraph 34 Contingencies Most of the items listed in paragraph 34 are addressed in the draft air quality management plan (AQMP) which is the appropriate place rather than in the assessment document since the AQMP will be modified over time (
            • 50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are extremely rare events at all of the industrial complexes that I have been involved with over 35 years but in the event that one fan is not operational the remaining fan is still
            • 51 Paragraph 36 Indoor Air Quality As noted in the application document indoor health and safety issues are controlled under the New Zealand Health and Safety at Work Act 2015 not the Resource Management Act and it is administered by Worksafe
            • 52 Paragraphs 37 and 38 Fugitive Odours The submitters are concerned that there will be a loss of containment that could occur at night During nighttime hours the pre-wet building will remain under negative pressure but there will be no mechan
            • 53 As part of my analysis of the reliability of the CANVACON material I sought information from the manufacturer regarding its strength and long term performance A test report is copied in Attachment B In summary The CANVACON welded seams have a
            • 54 I have already commented on the fugitive odours from chicken manure above and it will not be a significant source
            • 55 One point that the submitter makes in paragraph 38 is that conditions will not be sufficient to control the odour effects My only comment in this regard is that the design that Mercer Assets has chosen is designed to contain all the odour irresp
            • 56 A major part of my brief from Mercer Assets was to assure them that the proposed systems will actually work as promised by the manufacturer so that there will be no offensive odour discharges Having analysed the proposal in detail and assessed t
            • 57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33 of the report the take-off scrubbing liquor will be piped to a storage tank at a rate of a few litres per hour The submitters suggest that the ammonia that has been removed f
            • 58 Paragraph 40 Odour from the Process Water I understand that concerns regarding process water odour have been raised by air quality advisors engaged by the submitters but the specifics of those concerns are not presented in the submission Th
            • 59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours There is no unproven technology involved in this application The substrate preparation itself is a well known technology and not very different to what has been previously used
            • 60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo meteorological data presented in the application document the 2001 to 2003 data can be compared to the more recent 2018 data for Pukekohe in Attachment D to this evidence that
            • 61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL factors are important when assessing odours However in this application no FIDOL assessment has been carried out as no odour is expected to be discharged
            • Dust General
            • 62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report (Notification letter report 24 May 2019) as indicating that there are likely to be dust problems at their property This is also a recurring issue raised by other submitters Section 5
            • 63 However TampT do go on to say that the effects of dust will be negligible and I agree with this statement
            • 64 In relation to the raw materials bales of straw that are still bound have negligible dust generating capacity and all the rest of the raw material handling ie gypsum chicken manure etc including bale break will take place indoors with no dus
            • 65 Construction related dust will be controlled with a water cart andor water sprinklers as and when required
            • 66 Finally the majority of dust generation in the Morrison Rd area will actually be generated by wind-blown dust and dry soil from activities on the surrounding horticultural farms A recent satellite photo dated 3rd March 2019 showing of the exten
            • 67 Bio-aerosols were addressed in the application document that included information on bacteria and fungi including Aspergillus fumigatus (A fumigatus) and Legionella pneumophila (L Pneumophila) In summary the available literature indicates tha
            • 68 I have already addressed the issues contained in the officers report that I consider relevant in the above comments relating to the submitters concerns In regard to the proposed conditions of consent should it be granted they have been prepar
            • 69 I was asked by Mercer Assests to assess two alternative sites for the preparation of mushroom substrate The first site was in a disused quarry at Waikaretu that is about 47 to 50km to the south west of the current site Two options were conside
            • 70 Odour emission data from the existing Cresta operation projected to the proposed production rates was used to determine the extent of odour on neighbouring properties
            • 71 Based on my observation of the terrain I concluded that drainage wind flows (katabatic) would preclude the use of a simple straw filter and a large biofilter would be required together with full enclosure Modelling was not required to demostrat
            • 72 The second alternative site was a remote area between Island Block (Meremere) and Maramarua Again I concluded that that operations on that site would cause odour nuisance to residents who were located down slope from the proposed site due to th
            • 73 The outcome was that the same level of odour control and infrastructure (ie full enclosure and odour filtering) would be required at these sites as at the subject site Furthermore I also advised Mercer Assets that this level of odour control
            • 74 Having concluded that full enclosure and odour filtering is necessary whatever location is chosen and the adoption of that method avoids odour effects there was no basis to pursue other sites further
            • 75 It is also useful to consider that any alternative remote site would incur significant transportation costs with the concurrent additional carbon dioxide (CO2) emission For either the Waikaretu or Maramarua locations I have calculated the emissi
            • CONCLUSION
            • 76 The proposed mushroom substrate production and odour control system adopted by Mercer Assets represents the Best Available Control Technology anywhere in the world My assessment is that all odours will be controlled to a very high level such tha

ATTACHMENT F

CO2 CALCULATIONS

CO2 From Transport Calculation

Distance Morrison Rd to Waikeretu 47 km Similar dist for both

Round Trip 94 km Locations

Trips Per Week 17

Km Per Week 1598 km

Fuel Consumption 18 kmLitre Ref from Trucking Firm

Diesel Consumption per Week 888 Litres

Weeks Per Year 52 Weeks

Diesel Consumption per Annum 46164 Litres

Diesel CO2 emission factor 263 kg CO2Litre Fuel Ref WINFLUE Software

TOTAL CO2 Per Annum 121 Tonnes

Alternative MfE Calculation Ref MfE Table 18

km per Week 1598 km

km per Annum 83096 km

Diesel CO2 emission factor 136 kgkm gt30 Tonne 2010 to 2015 Fleet

TOTAL CO2 Per Annum 113 Tonnes

Ministry for the Environment 2019 Measuring Emissions A Guide for Organisations 2019 Summary of Emission Factors

• Qualifications and experience
• 1 My full name is Terence John Brady I am a Director of Terry Brady Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of Philosophy in Chemistry from the University of Canterbury New Zealand I specialise in air pollution control prepar
• 2 From 1983 to the end of 1991 I was employed by the Department of Health as an air pollution scientist responsible for industrial emissions for the upper half of the South Island under the Clean Air Act From 1991 to 1996 I was employed as an Air
• 3 My relevant experience includes assessing the actual and potential discharges to air from a very large variety of industries throughout New Zealand including the discharges of odour from composting I have been involved with many industrial projec
• 4 I have also designed and commissioned a considerable number of industrial ventilation systems for air pollution control purposes
• 5 Some specific projects that I have been involved with that have relevance to this application include
• • (a) Measurement modelling and assessment of odour from Living Earth composting at Pikes Point in Auckland Technical advice for monitoring programs
  • (b) Predictive modelling and assessment of odour from Living Earth composting at Puketutu Island in Auckland including Resource Consent application and the successful Environment Court appeal
  • (c) Assessment of odour effects for composting operations at Living EarthChristchurch City Council operation in Christchurch
  • (d) Assessment of potential odour effects for New Plymouth City Council composting operation
  • (e) Provided evidence in an Environment Court appeal involving New Zealand Mushrooms Ltd Morrinsville
  • (f) Assessment of potential effects of odour dust and bio-aerosols for the Living Earth Joint Venture in Careys Gully Wellington
  • (g) Assessment of effects of a greenwaste composting operation application by Whakatane District Council
  • (h) Measurement and assessment and remedial works for odours from the indoor composting plant at Cresta Mushrooms Mercer
  • (i) Assessment of engineering options to control odour from Te Mata Mushrooms Havelock North (ongoing)
  • • 6 In terms of scale composting operations I have been involved with range from a few thousand tonnes per annum to up to 75000 tonnes per annum
    • 7 I believe that I am well qualified to provide expert evidence on matters that have direct relevance to the application that is before the Independent Hearing Commissioners
    • 8 I have read the Code of Conduct for Expert Witnesses issued as part of the Environment Court Practice Notes I agree to comply with the code and am satisfied the matters I address in my evidence are within my expertise I am not aware of any mate
    • 9 In my evidence I will
    • • (a) Give an overview the application and the key odour sources as they relate to the odour control systems proposed
      • (b) Discuss the basis for the design parameters selected for odour containment
      • (c) The scrubber and biofilter odour control system
      • (d) Assess the odour impacts arising from the proposals
      • (e) Comment on the submissions received
      • (f) Comment on the Officers Report
      • (g) Provide context regarding alternative sites
      • • 10 The full details of the process are provided in the application technical document and the following represents a short summary
        • 11 The proposal is for the manufacture of mushroom substrate (compost) in a fully enclosed facility that will operate with full building air extraction on all parts of the buildings and processes that generate odour This odour-containing air will b
        • 12 Manufacturing will take place in two buildings beginning with the pre-wetting operation in the CANVACON pre-wet building followed by transfer to the filling hall in the main composting building that contains 12 fermentation tunnels From the fi
        • 13 After a pasturisation stage (in Phase 2) the substrate is cooled to ambient temperature and spawned with mushroom mycelium and held in the tunnels for 14-21 days before removal to the growing facility
        • KEY ODOUR SOURCES
        • 14 The main odour sources in process order are
        • • (a) The pre-wetting and turning in the Canvacon Building
          • (b) Transfer of pre-wetted material to the filling hall
          • (c) Phase 1 Fermentation
          • (d) Phase 1 Turning
          • (e) Phase 2 Fermentation
          • (f) Phase 2 Turning
          • (g) Miscellaneous sources
          • • 15 I discuss these below
            • Pre-Wet
            • 16 In the pre-wet stage straw bales are bought inside to the enclosed Pre-Wet building with a loader which are then submerged in to a dedicated lsquobathrsquo that is filled with nitrogen rich process water Once the bales are fully wetted they are then s
            • 17 The pre-wet building is maintained under negative pressure at all times to prevent odour being released to atmosphere
            • Transfer
            • 18 At the end of the conditioning period the material is loaded into the mixing line and then conveyed to the tunnel building
            • 19 The conveyor is covered and air is extracted from it into both the filling hall and the pre-wet building The openings in both the pre-wet and filling hall were taken into account in the design of the total amount of ventilation air that is requi
            • Phase 1 Fermentation
            • 20 Each of the tunnels is provided with under-floor aeration to maintain optimum levels of oxygen and temperature in the compost mass Temperatures vary through the process ranging between 40-80 oC and are largely controlled using aeration air
            • 21 In this part of the process the aeration and extraction is a fully sealed system that is balanced to a slight negative pressure
            • 22 All of the air used in the phase 1 tunnels is extracted to the acidwater scrubbers and the biofilter
            • Phase 1 Turning
            • 23 Turning involves removing the substrate from one tunnel and placing it in another via the filling hall The filing hall and the tunnels are under negative pressure during this operation and the air is extracted to the scrubber and biofilter
            • Phase 2 Fermentation
            • 24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of the fermentation but with slightly different aeration and turning requirements and continues until a critical point called peak heat is reached From this time on the tempera
            • Phase 2 Turning
            • 25 This is identical to the phase 1 turning and again the filling hall is under negative pressure The air is extracted to the scrubber and biofilter
            • Phase 3 Spawning
            • 26 Once the substrate is cooled to ambient temperature it is removed from the tunnels into the filling hall As there is no significant odour from the substrate at this stage the filling hall is under slight positive pressure using filtered air to
            • Miscellaneous Sources
            • 27 Because the whole composting process will be fully enclosed there are very few sources outside that could potentially cause odour and the only ones would include the nutrient tank (goody water tank) and deliveries of raw materials
            • 28 The nutrient water tank will be vented into the pre-wet building and is therefore under negative pressure There will be no odour from this source
            • 29 The only raw material that has any potential for odour is the chicken manure However this will be delivered in covered trucks and only unloaded inside the pre-wet building Under normal circumstances chicken manure has very little odour poten
            • 30 The standard hierarchy for odour control engineering is prevention capture at source followed by treatment and finally full building enclosure with ventilation followed by treatment
            • 31 In the case of compost or mushroom substrate production preventing odour generation is not possible at this time but capture at source is used in the phase 1 and 2 operations as the tunnels are completely sealed and ventilated to the odour contr
            • 32 In my opinion the proposed odor control system represents the Best Available Control Technology (BACT) that is both more advanced and effective than the BPO requirements of the RMA It is also the same system that I recommended to the Environment
            • 33 The building air extraction rates used for the combined pre-wet and compost buildings were provided by the equipment manufacturer Christiaens and I have used them to estimate the vacuum that could be achieved within the buildings A maximum press
            • 34 This operating pressure drop has been based on my 15 years personal experience with the control of odours from the PVL Proteins Ltd rendering plant the Living Earth compost facility in Careys Gully in Wellington and the Glencore Grain store in
            • 35 At a pressure drop of 10 Pa or more experience shows that there is no detectable leakage even during very strong winds 15 Pa is the operating pressure drop that I recommend to give extra security but for consent conditions purposes a value of
            • 36 I note that some submitters have the view that the CANVACON material is permeable That is incorrect CANVACON is a multilayer polyethylene woven material sandwiched between outer polyethylene coating layers and for practical purposes it is imp
            • 37 Again these are described in detail in the technical assessment The main purpose of the acid scrubber is to remove ammonia that has the potential to interfere with the biomass population in the biofilter thereby reducing its ability to remove
            • 38 The biofilter is a very standard design using wood chips and bark that is widely used across New Zealand and is well proven The 2 metre depth is the standard design used by Christiaens at their other European installations and the bulk loading
            • 39 The proposed consent conditions for the scrubbers and biofilter are mostly those that I recommend that achieve a balance between being useful and excessive monitoring for parameters that do not require frequent measurement
            • 40 Where an issue is common to most submissions I deal with it as a single issue rather than addressing each individual submission
            • 41 The common theme in relation to this application is that the submitters in opposition to the application believe that there will be odour discharges and that they will be offensive and objectionable I agree that the odour from mushroom substrate
            • 42 Mr and Mrs Taylor are concerned that the potential reduction in air extraction from the buildings at night will result in a loss of negative pressure and therefore cause more odour The first point to note is that the design of the ventilation
            • 43 Amira Thompson is concerned that the odour from opening the pre-wet door will have an adverse effect on her tenants This issue was discussed in Section 3222 of the Assessment document but I can elaborate on why I do not expect significant od
            • 44 A simple schematic of the pre-wet building is shown in Attachment A to my evidence that includes a roof-to-floor plastic curtain separating the pre-wet pile in the annex at the upper right hand corner of the building that will have a 300 to 500 mm
            • 45 This means that most of the odour in the pre-wet building will be collected in the Annex When the door is opened for 30 to 60 seconds or so for vehicle access there will still be an inwards air velocity of 1 to 125 m sec-1 air through the main
            • 46 K amp J Foley cite the TampT report as stating that there will be adverse odour effects during strong wind conditions This is incorrect As I have noted the pre-wet building and the filling hall will be operated with a design pressure drop of 15 P
            • 47 Stuart Harvey is also concerned about odour during strong winds See above
            • Submission of John Karena and Marise Taplin
            • 48 John Karena and Marise Taplin have prepared a detailed submission and I address the issues raised by reference to their paragraph numbers These issues are also common to many other submitters so they are commented on here rather than for indivi
            • 49 Paragraph 34 Contingencies Most of the items listed in paragraph 34 are addressed in the draft air quality management plan (AQMP) which is the appropriate place rather than in the assessment document since the AQMP will be modified over time (
            • 50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are extremely rare events at all of the industrial complexes that I have been involved with over 35 years but in the event that one fan is not operational the remaining fan is still
            • 51 Paragraph 36 Indoor Air Quality As noted in the application document indoor health and safety issues are controlled under the New Zealand Health and Safety at Work Act 2015 not the Resource Management Act and it is administered by Worksafe
            • 52 Paragraphs 37 and 38 Fugitive Odours The submitters are concerned that there will be a loss of containment that could occur at night During nighttime hours the pre-wet building will remain under negative pressure but there will be no mechan
            • 53 As part of my analysis of the reliability of the CANVACON material I sought information from the manufacturer regarding its strength and long term performance A test report is copied in Attachment B In summary The CANVACON welded seams have a
            • 54 I have already commented on the fugitive odours from chicken manure above and it will not be a significant source
            • 55 One point that the submitter makes in paragraph 38 is that conditions will not be sufficient to control the odour effects My only comment in this regard is that the design that Mercer Assets has chosen is designed to contain all the odour irresp
            • 56 A major part of my brief from Mercer Assets was to assure them that the proposed systems will actually work as promised by the manufacturer so that there will be no offensive odour discharges Having analysed the proposal in detail and assessed t
            • 57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33 of the report the take-off scrubbing liquor will be piped to a storage tank at a rate of a few litres per hour The submitters suggest that the ammonia that has been removed f
            • 58 Paragraph 40 Odour from the Process Water I understand that concerns regarding process water odour have been raised by air quality advisors engaged by the submitters but the specifics of those concerns are not presented in the submission Th
            • 59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours There is no unproven technology involved in this application The substrate preparation itself is a well known technology and not very different to what has been previously used
            • 60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo meteorological data presented in the application document the 2001 to 2003 data can be compared to the more recent 2018 data for Pukekohe in Attachment D to this evidence that
            • 61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL factors are important when assessing odours However in this application no FIDOL assessment has been carried out as no odour is expected to be discharged
            • Dust General
            • 62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report (Notification letter report 24 May 2019) as indicating that there are likely to be dust problems at their property This is also a recurring issue raised by other submitters Section 5
            • 63 However TampT do go on to say that the effects of dust will be negligible and I agree with this statement
            • 64 In relation to the raw materials bales of straw that are still bound have negligible dust generating capacity and all the rest of the raw material handling ie gypsum chicken manure etc including bale break will take place indoors with no dus
            • 65 Construction related dust will be controlled with a water cart andor water sprinklers as and when required
            • 66 Finally the majority of dust generation in the Morrison Rd area will actually be generated by wind-blown dust and dry soil from activities on the surrounding horticultural farms A recent satellite photo dated 3rd March 2019 showing of the exten
            • 67 Bio-aerosols were addressed in the application document that included information on bacteria and fungi including Aspergillus fumigatus (A fumigatus) and Legionella pneumophila (L Pneumophila) In summary the available literature indicates tha
            • 68 I have already addressed the issues contained in the officers report that I consider relevant in the above comments relating to the submitters concerns In regard to the proposed conditions of consent should it be granted they have been prepar
            • 69 I was asked by Mercer Assests to assess two alternative sites for the preparation of mushroom substrate The first site was in a disused quarry at Waikaretu that is about 47 to 50km to the south west of the current site Two options were conside
            • 70 Odour emission data from the existing Cresta operation projected to the proposed production rates was used to determine the extent of odour on neighbouring properties
            • 71 Based on my observation of the terrain I concluded that drainage wind flows (katabatic) would preclude the use of a simple straw filter and a large biofilter would be required together with full enclosure Modelling was not required to demostrat
            • 72 The second alternative site was a remote area between Island Block (Meremere) and Maramarua Again I concluded that that operations on that site would cause odour nuisance to residents who were located down slope from the proposed site due to th
            • 73 The outcome was that the same level of odour control and infrastructure (ie full enclosure and odour filtering) would be required at these sites as at the subject site Furthermore I also advised Mercer Assets that this level of odour control
            • 74 Having concluded that full enclosure and odour filtering is necessary whatever location is chosen and the adoption of that method avoids odour effects there was no basis to pursue other sites further
            • 75 It is also useful to consider that any alternative remote site would incur significant transportation costs with the concurrent additional carbon dioxide (CO2) emission For either the Waikaretu or Maramarua locations I have calculated the emissi
            • CONCLUSION
            • 76 The proposed mushroom substrate production and odour control system adopted by Mercer Assets represents the Best Available Control Technology anywhere in the world My assessment is that all odours will be controlled to a very high level such tha

CO2 From Transport Calculation

Distance Morrison Rd to Waikeretu 47 km Similar dist for both

Round Trip 94 km Locations

Trips Per Week 17

Km Per Week 1598 km

Fuel Consumption 18 kmLitre Ref from Trucking Firm

Diesel Consumption per Week 888 Litres

Weeks Per Year 52 Weeks

Diesel Consumption per Annum 46164 Litres

Diesel CO2 emission factor 263 kg CO2Litre Fuel Ref WINFLUE Software

TOTAL CO2 Per Annum 121 Tonnes

Alternative MfE Calculation Ref MfE Table 18

km per Week 1598 km

km per Annum 83096 km

Diesel CO2 emission factor 136 kgkm gt30 Tonne 2010 to 2015 Fleet

TOTAL CO2 Per Annum 113 Tonnes

Ministry for the Environment 2019 Measuring Emissions A Guide for Organisations 2019 Summary of Emission Factors

• Qualifications and experience
• 1 My full name is Terence John Brady I am a Director of Terry Brady Consulting Ltd I hold the degrees of BSc(Hons) and Doctor of Philosophy in Chemistry from the University of Canterbury New Zealand I specialise in air pollution control prepar
• 2 From 1983 to the end of 1991 I was employed by the Department of Health as an air pollution scientist responsible for industrial emissions for the upper half of the South Island under the Clean Air Act From 1991 to 1996 I was employed as an Air
• 3 My relevant experience includes assessing the actual and potential discharges to air from a very large variety of industries throughout New Zealand including the discharges of odour from composting I have been involved with many industrial projec
• 4 I have also designed and commissioned a considerable number of industrial ventilation systems for air pollution control purposes
• 5 Some specific projects that I have been involved with that have relevance to this application include
• • (a) Measurement modelling and assessment of odour from Living Earth composting at Pikes Point in Auckland Technical advice for monitoring programs
  • (b) Predictive modelling and assessment of odour from Living Earth composting at Puketutu Island in Auckland including Resource Consent application and the successful Environment Court appeal
  • (c) Assessment of odour effects for composting operations at Living EarthChristchurch City Council operation in Christchurch
  • (d) Assessment of potential odour effects for New Plymouth City Council composting operation
  • (e) Provided evidence in an Environment Court appeal involving New Zealand Mushrooms Ltd Morrinsville
  • (f) Assessment of potential effects of odour dust and bio-aerosols for the Living Earth Joint Venture in Careys Gully Wellington
  • (g) Assessment of effects of a greenwaste composting operation application by Whakatane District Council
  • (h) Measurement and assessment and remedial works for odours from the indoor composting plant at Cresta Mushrooms Mercer
  • (i) Assessment of engineering options to control odour from Te Mata Mushrooms Havelock North (ongoing)
  • • 6 In terms of scale composting operations I have been involved with range from a few thousand tonnes per annum to up to 75000 tonnes per annum
    • 7 I believe that I am well qualified to provide expert evidence on matters that have direct relevance to the application that is before the Independent Hearing Commissioners
    • 8 I have read the Code of Conduct for Expert Witnesses issued as part of the Environment Court Practice Notes I agree to comply with the code and am satisfied the matters I address in my evidence are within my expertise I am not aware of any mate
    • 9 In my evidence I will
    • • (a) Give an overview the application and the key odour sources as they relate to the odour control systems proposed
      • (b) Discuss the basis for the design parameters selected for odour containment
      • (c) The scrubber and biofilter odour control system
      • (d) Assess the odour impacts arising from the proposals
      • (e) Comment on the submissions received
      • (f) Comment on the Officers Report
      • (g) Provide context regarding alternative sites
      • • 10 The full details of the process are provided in the application technical document and the following represents a short summary
        • 11 The proposal is for the manufacture of mushroom substrate (compost) in a fully enclosed facility that will operate with full building air extraction on all parts of the buildings and processes that generate odour This odour-containing air will b
        • 12 Manufacturing will take place in two buildings beginning with the pre-wetting operation in the CANVACON pre-wet building followed by transfer to the filling hall in the main composting building that contains 12 fermentation tunnels From the fi
        • 13 After a pasturisation stage (in Phase 2) the substrate is cooled to ambient temperature and spawned with mushroom mycelium and held in the tunnels for 14-21 days before removal to the growing facility
        • KEY ODOUR SOURCES
        • 14 The main odour sources in process order are
        • • (a) The pre-wetting and turning in the Canvacon Building
          • (b) Transfer of pre-wetted material to the filling hall
          • (c) Phase 1 Fermentation
          • (d) Phase 1 Turning
          • (e) Phase 2 Fermentation
          • (f) Phase 2 Turning
          • (g) Miscellaneous sources
          • • 15 I discuss these below
            • Pre-Wet
            • 16 In the pre-wet stage straw bales are bought inside to the enclosed Pre-Wet building with a loader which are then submerged in to a dedicated lsquobathrsquo that is filled with nitrogen rich process water Once the bales are fully wetted they are then s
            • 17 The pre-wet building is maintained under negative pressure at all times to prevent odour being released to atmosphere
            • Transfer
            • 18 At the end of the conditioning period the material is loaded into the mixing line and then conveyed to the tunnel building
            • 19 The conveyor is covered and air is extracted from it into both the filling hall and the pre-wet building The openings in both the pre-wet and filling hall were taken into account in the design of the total amount of ventilation air that is requi
            • Phase 1 Fermentation
            • 20 Each of the tunnels is provided with under-floor aeration to maintain optimum levels of oxygen and temperature in the compost mass Temperatures vary through the process ranging between 40-80 oC and are largely controlled using aeration air
            • 21 In this part of the process the aeration and extraction is a fully sealed system that is balanced to a slight negative pressure
            • 22 All of the air used in the phase 1 tunnels is extracted to the acidwater scrubbers and the biofilter
            • Phase 1 Turning
            • 23 Turning involves removing the substrate from one tunnel and placing it in another via the filling hall The filing hall and the tunnels are under negative pressure during this operation and the air is extracted to the scrubber and biofilter
            • Phase 2 Fermentation
            • 24 The Phase 2 fermentation is similar to the Phase 1 stage in terms of the fermentation but with slightly different aeration and turning requirements and continues until a critical point called peak heat is reached From this time on the tempera
            • Phase 2 Turning
            • 25 This is identical to the phase 1 turning and again the filling hall is under negative pressure The air is extracted to the scrubber and biofilter
            • Phase 3 Spawning
            • 26 Once the substrate is cooled to ambient temperature it is removed from the tunnels into the filling hall As there is no significant odour from the substrate at this stage the filling hall is under slight positive pressure using filtered air to
            • Miscellaneous Sources
            • 27 Because the whole composting process will be fully enclosed there are very few sources outside that could potentially cause odour and the only ones would include the nutrient tank (goody water tank) and deliveries of raw materials
            • 28 The nutrient water tank will be vented into the pre-wet building and is therefore under negative pressure There will be no odour from this source
            • 29 The only raw material that has any potential for odour is the chicken manure However this will be delivered in covered trucks and only unloaded inside the pre-wet building Under normal circumstances chicken manure has very little odour poten
            • 30 The standard hierarchy for odour control engineering is prevention capture at source followed by treatment and finally full building enclosure with ventilation followed by treatment
            • 31 In the case of compost or mushroom substrate production preventing odour generation is not possible at this time but capture at source is used in the phase 1 and 2 operations as the tunnels are completely sealed and ventilated to the odour contr
            • 32 In my opinion the proposed odor control system represents the Best Available Control Technology (BACT) that is both more advanced and effective than the BPO requirements of the RMA It is also the same system that I recommended to the Environment
            • 33 The building air extraction rates used for the combined pre-wet and compost buildings were provided by the equipment manufacturer Christiaens and I have used them to estimate the vacuum that could be achieved within the buildings A maximum press
            • 34 This operating pressure drop has been based on my 15 years personal experience with the control of odours from the PVL Proteins Ltd rendering plant the Living Earth compost facility in Careys Gully in Wellington and the Glencore Grain store in
            • 35 At a pressure drop of 10 Pa or more experience shows that there is no detectable leakage even during very strong winds 15 Pa is the operating pressure drop that I recommend to give extra security but for consent conditions purposes a value of
            • 36 I note that some submitters have the view that the CANVACON material is permeable That is incorrect CANVACON is a multilayer polyethylene woven material sandwiched between outer polyethylene coating layers and for practical purposes it is imp
            • 37 Again these are described in detail in the technical assessment The main purpose of the acid scrubber is to remove ammonia that has the potential to interfere with the biomass population in the biofilter thereby reducing its ability to remove
            • 38 The biofilter is a very standard design using wood chips and bark that is widely used across New Zealand and is well proven The 2 metre depth is the standard design used by Christiaens at their other European installations and the bulk loading
            • 39 The proposed consent conditions for the scrubbers and biofilter are mostly those that I recommend that achieve a balance between being useful and excessive monitoring for parameters that do not require frequent measurement
            • 40 Where an issue is common to most submissions I deal with it as a single issue rather than addressing each individual submission
            • 41 The common theme in relation to this application is that the submitters in opposition to the application believe that there will be odour discharges and that they will be offensive and objectionable I agree that the odour from mushroom substrate
            • 42 Mr and Mrs Taylor are concerned that the potential reduction in air extraction from the buildings at night will result in a loss of negative pressure and therefore cause more odour The first point to note is that the design of the ventilation
            • 43 Amira Thompson is concerned that the odour from opening the pre-wet door will have an adverse effect on her tenants This issue was discussed in Section 3222 of the Assessment document but I can elaborate on why I do not expect significant od
            • 44 A simple schematic of the pre-wet building is shown in Attachment A to my evidence that includes a roof-to-floor plastic curtain separating the pre-wet pile in the annex at the upper right hand corner of the building that will have a 300 to 500 mm
            • 45 This means that most of the odour in the pre-wet building will be collected in the Annex When the door is opened for 30 to 60 seconds or so for vehicle access there will still be an inwards air velocity of 1 to 125 m sec-1 air through the main
            • 46 K amp J Foley cite the TampT report as stating that there will be adverse odour effects during strong wind conditions This is incorrect As I have noted the pre-wet building and the filling hall will be operated with a design pressure drop of 15 P
            • 47 Stuart Harvey is also concerned about odour during strong winds See above
            • Submission of John Karena and Marise Taplin
            • 48 John Karena and Marise Taplin have prepared a detailed submission and I address the issues raised by reference to their paragraph numbers These issues are also common to many other submitters so they are commented on here rather than for indivi
            • 49 Paragraph 34 Contingencies Most of the items listed in paragraph 34 are addressed in the draft air quality management plan (AQMP) which is the appropriate place rather than in the assessment document since the AQMP will be modified over time (
            • 50 Paragraph 34 (c) Fan Breakdown In my experience fan failures are extremely rare events at all of the industrial complexes that I have been involved with over 35 years but in the event that one fan is not operational the remaining fan is still
            • 51 Paragraph 36 Indoor Air Quality As noted in the application document indoor health and safety issues are controlled under the New Zealand Health and Safety at Work Act 2015 not the Resource Management Act and it is administered by Worksafe
            • 52 Paragraphs 37 and 38 Fugitive Odours The submitters are concerned that there will be a loss of containment that could occur at night During nighttime hours the pre-wet building will remain under negative pressure but there will be no mechan
            • 53 As part of my analysis of the reliability of the CANVACON material I sought information from the manufacturer regarding its strength and long term performance A test report is copied in Attachment B In summary The CANVACON welded seams have a
            • 54 I have already commented on the fugitive odours from chicken manure above and it will not be a significant source
            • 55 One point that the submitter makes in paragraph 38 is that conditions will not be sufficient to control the odour effects My only comment in this regard is that the design that Mercer Assets has chosen is designed to contain all the odour irresp
            • 56 A major part of my brief from Mercer Assets was to assure them that the proposed systems will actually work as promised by the manufacturer so that there will be no offensive odour discharges Having analysed the proposal in detail and assessed t
            • 57 Paragraph 39 Odour from Scrubbing Liquor As stated in Section 33 of the report the take-off scrubbing liquor will be piped to a storage tank at a rate of a few litres per hour The submitters suggest that the ammonia that has been removed f
            • 58 Paragraph 40 Odour from the Process Water I understand that concerns regarding process water odour have been raised by air quality advisors engaged by the submitters but the specifics of those concerns are not presented in the submission Th
            • 59 Paragraph 41 to 44 Unproven New Technology and Off-site Odours There is no unproven technology involved in this application The substrate preparation itself is a well known technology and not very different to what has been previously used
            • 60 Paragraph 45 Meteorological Data In relation to the ldquoout of daterdquo meteorological data presented in the application document the 2001 to 2003 data can be compared to the more recent 2018 data for Pukekohe in Attachment D to this evidence that
            • 61 Paragraph 46 FIDOL factors It is correctly noted that the FIDOL factors are important when assessing odours However in this application no FIDOL assessment has been carried out as no odour is expected to be discharged
            • Dust General
            • 62 Mr and Mrs Taylor cite the Tonkin and Taylor (TampT) report (Notification letter report 24 May 2019) as indicating that there are likely to be dust problems at their property This is also a recurring issue raised by other submitters Section 5
            • 63 However TampT do go on to say that the effects of dust will be negligible and I agree with this statement
            • 64 In relation to the raw materials bales of straw that are still bound have negligible dust generating capacity and all the rest of the raw material handling ie gypsum chicken manure etc including bale break will take place indoors with no dus
            • 65 Construction related dust will be controlled with a water cart andor water sprinklers as and when required
            • 66 Finally the majority of dust generation in the Morrison Rd area will actually be generated by wind-blown dust and dry soil from activities on the surrounding horticultural farms A recent satellite photo dated 3rd March 2019 showing of the exten
            • 67 Bio-aerosols were addressed in the application document that included information on bacteria and fungi including Aspergillus fumigatus (A fumigatus) and Legionella pneumophila (L Pneumophila) In summary the available literature indicates tha
            • 68 I have already addressed the issues contained in the officers report that I consider relevant in the above comments relating to the submitters concerns In regard to the proposed conditions of consent should it be granted they have been prepar
            • 69 I was asked by Mercer Assests to assess two alternative sites for the preparation of mushroom substrate The first site was in a disused quarry at Waikaretu that is about 47 to 50km to the south west of the current site Two options were conside
            • 70 Odour emission data from the existing Cresta operation projected to the proposed production rates was used to determine the extent of odour on neighbouring properties
            • 71 Based on my observation of the terrain I concluded that drainage wind flows (katabatic) would preclude the use of a simple straw filter and a large biofilter would be required together with full enclosure Modelling was not required to demostrat
            • 72 The second alternative site was a remote area between Island Block (Meremere) and Maramarua Again I concluded that that operations on that site would cause odour nuisance to residents who were located down slope from the proposed site due to th
            • 73 The outcome was that the same level of odour control and infrastructure (ie full enclosure and odour filtering) would be required at these sites as at the subject site Furthermore I also advised Mercer Assets that this level of odour control
            • 74 Having concluded that full enclosure and odour filtering is necessary whatever location is chosen and the adoption of that method avoids odour effects there was no basis to pursue other sites further
            • 75 It is also useful to consider that any alternative remote site would incur significant transportation costs with the concurrent additional carbon dioxide (CO2) emission For either the Waikaretu or Maramarua locations I have calculated the emissi
            • CONCLUSION
            • 76 The proposed mushroom substrate production and odour control system adopted by Mercer Assets represents the Best Available Control Technology anywhere in the world My assessment is that all odours will be controlled to a very high level such tha