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By NCI Packaging (New Zealand) Limited, to Discharge Contaminants to Air Associated with the Operation of a Can Manufacturing and Painting Plant

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By NCI Packaging (New Zealand) Limited, to Discharge Contaminants to Air Associated with the Operation of a Can Manufacturing and Painting Plant NCI Packaging Limited Report to the Hearing Committee on a limited notified resource consent application Summary of application Activity: To discharge contaminants to air associated with the operation of a steel and aluminium can manufacturing and painting plant. File Reference: WGN110219 Applicant: NCI Packaging (NZ) Limited 80 Mount Wellington Highway Panmure Auckland 1060 For: Stuart Shepherd Consent Sought: [30888]: Discretionary activity Discharge permit to discharge contaminants to air associated with the operation of steel and aluminium can manufacturing and painting plant. Location: 60-66 Montgomery Crescent, Clouston Park, Upper Hutt Map Reference: At or about map reference NZTM 1775130.5445749 Legal Description: Lot 1 DP 30717 and Lot 1 DP 28552 Background: The application was limited notified on 3 April 2012. Recommendation: I recommend that the above consents be granted for the reasons outlined in this report, subject to conditions in Appendix 1. Consent duration: [30888]: 6 years Subject to conditions: Attachment 1 Report prepared Hugh Dixon- Resource Advisor, 25/06/13 by: Paver Environmental Regulation Report peer Ashlee Farrow Resource Advisor, 25/06/13 reviewed by: Environmental Regulation Report reviewed Jeremy Team Leader, 25/06/13 by: Rusbatch Environmental Regulation Report approved Alistair Cross Manager, 25/06/13 by: Environmental Regulation Qualifications of reporting officer My name is Hugh George Leonard Dixon-Paver. I have held the role of Resource Advisor at Greater Wellington Regional Council since July 2008. In this role I have been responsible for processing applications for resource consents, mainly discharge consents to water, land and air. Prior to this role I was employed by the South African Department of Water Affairs for 25 years, involved in all aspects of water quality management. My primary functions were in a regulatory role over mines, industries, municipal wastewater treatment plants and municipal landfills, and their discharges to the environment. I hold a Bachelor of Science degree in Environmental Biology and Cellular Biology (University of Kwa-Zulu Natal, South Africa, 1982), a Bachelor of Science (Honours) degree in Cellular Biology and Plant Growth and Development (University of Kwa- Zulu Natal, South Africa, 1986), and a Bachelor of Science (Honours) degree in Water Utilisation (University of Pretoria, South Africa, 2006). The latter degree was specifically focussed on water treatment plant design and operation, including domestic and industrial wastewater treatment and disposal. In addition to the above, I have over time attended various water quality related training courses at graduate and post graduate level, including physical, chemical and biological effects on the receiving environment. Since coming to New Zealand I have also attended similar training courses, including air quality management. Contents 1. Purpose 1 2. Background 1 2.1 General 1 2.2 Site history 1 2.3 Residential areas 2 3. Location 2 3.1 NCI packaging plant 2 4. Consent application documentation 3 4.1 Consent application 3 4.2 Peer review process 3 5. Proposal/description of activities 4 5.1 Overall concept of NCI Packaging plant 4 5.1.1 Forming steel paint cans 4 5.1.2 Drawing aluminium cans 4 5.1.3 Printing and lacquering of the formed aluminium cans 4 5.2 Discharges to atmosphere 5 5.2.1 Stack discharge characteristics at the time of submission of the application 6 5.2.2 Changes to stack discharge characteristics 6 6. Notification and submissions 6 6.1 Notification 6 6.2 Submissions 7 6.3 Issues raised by submissions 7 6.3.1 Issues raised by submissions in support 7 6.3.2 Issues raised by neutral submissions 7 6.3.3 Issues raised by submissions in opposition 8 7. Further information, reports, reviews and pre-hearing meeting 8 7.1 Reports and reviews 8 7.1.1 Technical Reports 8 7.1.2 URS 2011a report dated 31 January 2011 8 7.1.3 GOLDER 2011a report dated 19 May 2011 8 7.1.4 URS 2011b report dated 9 August 2011 9 7.1.5 GOLDER 2011b report dated 2 November 2011 9 7.2 Changes to discharge stacks implemented by NCI by 16 April 2012 9 7.3 Pre-hearing meeting 9 7.4 Further reports and reviews 10 7.4.1 Technical review by Regional Public Health (RPH) report AQM 2012 dated 10 October 2012 10 7.4.2 URS 2013a report dated 11 January 2013 10 7.4.3 GOLDER 2013 report dated 5 March 2013 10 7.4.4 URS 2013d report dated 22 January 2013 10 7.4.5 AQM 2013 dated 31 May 2013 10 7.5 Changes to discharge stacks implemented by NCI on 26 April 2013 10 7.6 Summary 11 8. Resource consents required 11 8.1 Resource Management Act 1991 11 8.2 Regional Plan Rules 12 9. Statutory reasons for requiring resource consent 12 9.1 Planning instruments and other matters 13 10. Assessment of actual and potential effects 104(1)(a) 13 10.1 Existing environment 13 10.2 Environmental effects of the discharge 14 10.3 Technical peer review 15 10.4 Basis for discussion 15 10.5 Nature of the discharge and potential effects of contaminants 15 10.6 Dispersion modelling 15 10.7 Particulate matter (PM10) 16 10.8 Other products of combustion: Oxides of Nitrogen and Carbon Monoxide 17 10.9 Volatile Organic Compounds (VOCs) 19 10.10 Odour 20 10.11 Adaptive Management Odour Plan (AMOP) 25 10.12 Summary 27 11. Recommended conditions 28 12. Objective and policies of the relevant planning instruments 104(1)(b) 29 12.1 National planning instruments 29 12.2 Regional planning instruments 30 12.2.1 Regional Policy Statement (RPS) 30 12.2.2 Regional Air Quality Management Plan for the Wellington Region 30 13. Matters relating to the grant of discharge permits 32 13.1 Section 105 of the Act 32 13.1.1 Ultraviolet (UV) treatment of stack gas 33 13.1.2 Installation and operation of an afterburner 33 13.1.3 Stack configuration changes 33 13.1.4 Consideration of alternatives 33 14. Part 2 of the Act 34 14.1 Section 6 – Matters of National Importance 34 14.2 Section 7 – Other Matters 34 14.3 Section 8 – Principles of the Treaty of Waitangi 34 14.4 Section 5 – Purpose and Principles 35 14.4.1 Odour 36 14.4.2 Submitter concerns 36 14.4.3 Consideration of health effects 36 14.4.4 Commitment by the applicant to address problems 36 14.4.5 Uncertainty 37 14.4.6 Consideration 38 15. Conclusions 38 16. Recommendation and duration of consent 39 Application WGN110219 [30888] by NCI Packaging (New Zealand) Limited, to discharge contaminants to air associated with the operation of a can manufacturing and painting plant 1. Purpose This report provides an analysis of the resource management issues in respect of an application by NCI Packaging (New Zealand) Limited (NCI, the applicant) for resource consent to discharge contaminants to air associated with the operation of a packaging plant. The assessment and recommendations contained in this report are not binding on the Hearing Panel. This report has been prepared without knowledge of the content of any evidence or submissions that will be made at the hearing; consequently it cannot be assumed that the Hearing Panel hearing the application will reach the same conclusions as those provided in this report. 2. Background 2.1 General NCI has applied to the Greater Wellington Regional Council (GWRC) for resource consent to discharge contaminants to air associated with the operation of a steel and aluminium can manufacturing plant at Clouston Park, Upper Hutt. 2.2 Site history NCI has operated a manufacturing plant in at this location for over 20 years, as well as another, similar but larger, plant in Auckland. The plant produces a range of steel and aluminium cans, and in 2006 NCI acquired Impact Manufacturing and transferred machinery and processes from Lower Hutt to the NCI plant. The applicant states that at that time a due diligence study was undertaken, which found that resource consent was not required. From early 2010 GWRC’s Environmental Protection Team have received notifications of offensive and objectionable odour from residential areas, particularly Mountbatten Grove (north of the NCI site), and Fergusson Drive (northwest of the NCI site). Investigations into the odour source(s) were unable to conclusively identify the source of the odour. As part of the investigation process, GWRC identified that NCI required resource consent as production had increased relative to 2006 levels such that the permitted activity rules (specifically rules 13 and 15) in the Regional Air Quality Management Plan (RAQMP) no longer applied (see Section 8 (Resource consents required) of this report). Several other industries have also been identified as requiring resource consent, which are the subject of other resource consent applications. 1224986-V1 PAGE 1 OF 39 2.3 Residential areas Immediately north and northwest of the NCI plant are residences along Mountbatten Grove. Further to the northwest is Fergusson Drive, a main access road through Upper Hutt. As noted in Section 2.2 (Site history) of this report, notifications of odour have been received from residents in these areas. GWRC Environment Protection Duty Officers have historically experienced difficulty in confirming NCI as the source of a particular odour. This is due to the delay in reaching the site, number of potential sources of odour in the area, intermittent nature of the odour experienced at the residences, and the local meteorological microclimate. Residents and GWRC enforcement officers report that the odour generated by NCI is characteristic, and different in nature to other industrial odours which may be present in the area. 3.
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