South Pacific Meats Limited - CRC156662 - Wastewater Discharge Application for a change of conditions March 2021 - Wastewater Discharge ...
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South Pacific Meats Limited
CRC156662 - Wastewater Discharge
Application for a change of conditions
March 2021
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | i
Table of contents
1. Introduction .................................................................................................................................... 6
1.1 Purpose of this document .................................................................................................... 6
1.2 Background .......................................................................................................................... 6
1.3 Section 127 .......................................................................................................................... 7
1.4 Scope and limitations ........................................................................................................... 8
2. Existing environment ...................................................................................................................... 9
2.1 Site location and description ................................................................................................9
2.2 Processing Plant ................................................................................................................ 10
2.3 Soils ................................................................................................................................... 10
2.4 Surface water bodies .........................................................................................................11
2.5 Hydrogeology ..................................................................................................................... 11
3. Proposed change of conditions .................................................................................................... 12
3.1 Reasons for change of conditions ..................................................................................... 12
3.2 Changes to conditions sought ........................................................................................... 13
4. Assessment of effects .................................................................................................................. 14
4.1 Change in effects on soil quality ........................................................................................ 14
4.2 Change in effects on groundwater quality ......................................................................... 15
4.3 Change in the allocation of the catchment load limit ......................................................... 15
4.4 Change in effects on Tangata Whenua Values ................................................................. 16
4.5 Summary ............................................................................................................................ 16
5. Statutory assessment................................................................................................................... 17
5.1 Part 2 of the RMA – Purpose and Principles ..................................................................... 17
5.2 National Policy Statement for Freshwater Management 2020 .......................................... 18
5.3 Canterbury Regional Policy Statement .............................................................................. 18
5.4 Canterbury Land and Water Regional Plan ....................................................................... 19
5.5 Plan Change 7 of the Canterbury Land and Water Regional Plan .................................... 19
5.6 Mahaanui Iwi Management Plan ....................................................................................... 19
5.7 Resource Management Act 1991 ...................................................................................... 20
6. Notification and consultation ........................................................................................................ 21
6.1 Public Notification .............................................................................................................. 21
6.2 Limited Notification............................................................................................................. 22
6.3 Consultation ....................................................................................................................... 23
7. Conclusion ................................................................................................................................... 24
ii | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/
Table index
Table 1: Site details .................................................................................................................................. 9
Table 2: Land and Water Regional Plan ................................................................................................ 18
Table 3. Public notification assessment ................................................................................................. 21
Table 4: Limited notification assessment ............................................................................................... 22
Figure index
Figure 2-1 Site Location and discharge area ......................................................................................... 10
Figure 3-1 Nitrogen concentrations in SPM wastewater ........................................................................ 13
Appendices
Appendix A – Copy of CRC156662
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | iii
Form 10
APPLICATION FOR RESOURCE CONSENT
UNDER SECTION 88 OF THE
RESOURCE MANAGEMENT ACT 1991
TO: Canterbury Regional Council
1. South Pacific Meats Limited apply for a change of a condition of a resource consent.
2. THE NAMES AND ADDRESSES of the owners and occupiers of any land to which the
application relates are as follows:
Owner of the land: South Pacific Meats Limited
Occupier of the land: South Pacific Meats Limited
3. THE LOCATION to which this application relates is:
Physical Location: 1002 Two Chain Road, Burnham
Legal Description: Lot 2 DP 339707
Certificate of Title: 163301 (refer to Appendix A)
4. THE APPLICATION relates to the following resource consent:
CRC156662 - to discharge contaminants onto land and into air
5. THE APPLICATION relates to the following specific conditions of the resource consents:
Conditions 1 - The discharge shall be only meat works processing wastewater, and stormwater from
animal handling areas of the meat works, and shall be discharged via spray irrigation at a rate not
exceeding 30 litres per second or 1000 cubic metres per day at Two Chain Road, Burnham, at or
about map reference NZTopo50 BX22:3932-7053 within the properties denoted “Applicant’s Site” on
Plan CRC156662A, which forms part of this consent.
6. THE PROPOSED change is as follows:
To increase the daily volume of wastewater able to be discharged from 1000 cubic metres per day to
1500 cubic metres per day.
7. There are no other activities that are part of the proposal to which this application relates.
8. WE ATTACH an assessment of the site in terms of its effects on the environment that—
(a) includes the information required by clause 6 of Schedule 4 of the Resource
Management Act 1991; and
(b) addresses the matters specified in clause 7 of Schedule 4 of the Resource Management
Act 1991; and
(c) includes such detail as corresponds with the scale and significance of the effects that the
activity may have on the environment.
9. WE ATTACH an assessment of the proposed change against the matters set out in Part 2 of
the Resource Management Act 1991.
10. WE ATTACH an assessment of the proposed change against any relevant provisions of a
document referred to in section 104(1)(b) of the Resource Management Act 1991, including the
information required by clause 2(2) of Schedule 4 of that Act.
4 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/
Dated 10 March 2021
Signed on behalf of Applicant
Address for Service
Company: GHD Limited
Attention: Sean Mooney
Telephone: 03 363 0840
Email: Sean.Mooney@ghd.com
All remaining Council process fees:
Company: South Pacific Meats Limited
Attention: Dean Burgess
Telephone: 021589874
Email: Dean.Burgess@affco.co.nz
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 5
1. Introduction
1.1 Purpose of this document
South Pacific Meats Limited (SPM or the applicant) are currently authorised to discharge
wastewater from a meat works processing facility to land under resource consent CRC156662.
SPM seeks to increase their daily volume from 1000 cubic metres per day (m3/day) to 1,500
m3/day.
While SPM are requesting an increase in the maximum daily volume discharged to land, they
are not requesting any changes to their total nitrogen loading limits (gross or net), irrigation
application rate (35 mm) or maximum instantenous rate (30 L/s). Rather, SPM are treating their
wastewater to a higher standard that decreases the concentration of contaminants in their waste
stream.
Given the improved treatment being achieved onsite, SPM seeks to increase the daily volume of
wastewater that is able to be discharged while still complying with all other restrictions placed on
the discharge. The requested change of conditions is not considered to result in a change in the
level of potential effects of the receiving environment.
A copy of the consent is included in Appendix A.
This assessment of effects on the environment (AEE) has been prepared to accompany a s127
application to change conditions of CRC156662 to increase the daily volume of wastewater
being discharged.
1.2 Background
SPM was first granted a discharge consent by Environment Canterbury (ECan) in May 1992 for
the discharge of 200 cubic metres per day of screened wastewater to land.
In 2006 a replacement discharge consent was obtained that also increased the volume of
wastewater to 1000 m3/day over an area of 91 hectares. A variation was sought in May 2014 to
increase the land application area to 119 hectares.
In 2015 SPM applied for a further change of condition to increase the discharge area to 126
hectares. This change of the condition included the re-arrangement of the existing authorised
discharge area and the further use of the available land on the adjacent property.
It is noted that under Condition 2 of the consent, SPM are required to irrigate to not less than 91
hectares of the total land. Having a minimum irrigation area requires SPM to spread the
wastewater over a large area to assist in the management of the receiving environment and to
allow potential effects to be spread over a larger area. There are currently 116 hectares within
the active irrigation area.
SPM have exceeded their daily volume discharge limit on a number of occasions. The
exceedance in the daily wastewater volume has been due to a number of factors, this has
included an increase in cleaning requirements, changes in the operating systems and an
increase in the plant output.
As a result of these non-compliances, SPM has developed a Solutions Strategy Activities (SSA)
to work towards becoming fully compliant with the resource consent, which included a large
number of improvements and financial investment onsite since 2019.
On the 16th of April 2019, Environment Canterbury issued SPM with an abatement notice due to
breaches of consent conditions. The abatement notice required some immediate remedial
6 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/measures to be undertaken by SPM and further mitigation measures employed to comply with
the notice.
As part of the SSA, SPM has undertaken a number of upgrades and modification to the site’s
wastewater management and treatment plant to reduce the concentration of nitrogen within the
discharge. As a result of these changes, SPM has seen a substantial reduction in the nitrogen
concentrations within their wastewater, and have been able to reduce their gross nitrogen
loading below the limit of 350 Kg/N/Ha/yr.
However, while SPM has managed to reduce their nitrogen concentrations within wastewater to
historical lows, on days of high production, they continue to produce volumes of wastewater that
exceed their current daily limit of 1,000 m3/day. Excess wastewater is currently stored in the
onsite storage tank and irrigated on days of lower production to maintain compliance with the
daily discharge limit, or removed from the site by Robson Environmental Services Ltd at a
significant ongoing cost to SPM.
As a result of this, SPM is seeking to increase their maximum daily discharge volume to more
appropriately manage the volume of wastewater produced from the site throughout the year.
No changes are sought to the other consent conditions. While the change of condition is
seeking to increase the volume of wastewater discharge, it is intended to manage this additional
volume to the same level of environmental effects that have been authorised by the original
consent application.
1.3 Section 127
Section 127 provides for conditions of consent to be changed or cancelled.
In accordance with s127(3), the provisions of sections 88 to 121 apply as if:
(3) Section 99 to 121 apply, with all necessary modifications, as if –
a. the application to change or cancel conditions were an application for a
resource consent for a discretionary activity; and
b. the references to a resource consent and to the activity were references only
to the change or cancellation of a condition and the effects of the change or
cancellation respectively; and
(4) In determining who is adversely affected by the change or cancellation of conditions, the
local authority must consider every person who –
a. submitted on the original application, and
b. may be affected by the change or cancellation.
As provided for by section 127(3)(a), this application to change a condition of consent is
assessed as a discretionary activity.
The assessment in this report addresses the effects of the proposed condition change only and
not the effects of the activity itself, as per section 127(3)(b).
The scope of what can be considered under section 127 was confirmed in the High Court
decision on Body Corporate 97010 v Auckland City Council [2000], which found that an
application for a change of conditions may be appropriate where the variation does not result in
‘a fundamentally different activity or one having materially different adverse effects’ compared to
the activity in its original form
While SPM seeks a change of conditions to increase the volume of daily wastewater
discharged, they are not seeking a change of condition in relation to the nitrogen loading from
the wastewater discharge. Rather, from an increase in wastewater treatment, SPM are able to
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 7increase their daily discharge volume while still managing the activity to the same level of
environmental effects.
Furthermore, Condition 2 of CRC156662 requires the discharge to occur over an area of at least
91 hectares. This condition requires SPM to ensure the discharge is spread over a minimal
area to mitigate loading of nitrogen on smaller paddocks. There are no requested changes to
this condition.
1.4 Scope and limitations
This report has been prepared by GHD for South Pacific Meats Limited and may only be used
and relied on by South Pacific Meats Limited the purpose agreed between GHD and the South
Pacific Meats Limited as set out in Section 1 of this report.
GHD otherwise disclaims responsibility to any person other than South Pacific Meats Limited
arising in connection with this report. GHD also excludes implied warranties and conditions, to
the extent legally permissible.
The services undertaken by GHD in connection with preparing this report were limited to those
specifically detailed in the report and are subject to the scope limitations set out in the report.
The opinions, conclusions and any recommendations in this Report are based on conditions
encountered and information reviewed at the date of preparation of the Report. GHD has no
responsibility or obligation to update this Report to account for events or changes occurring
subsequent to the date that the Report was prepared. Specifically, this Report does not take
into account the effects, implications and consequences of or responses to COVID-19, which is
a highly dynamic situation and rapidly changing. These effects, implications, consequences of
and responses to COVID-19 may have a material effect on the opinions, conclusions,
recommendations, assumptions, qualifications and limitations in this Report, and the entire
Report must be re-examined and revisited in light of COVID-19. Where this Report is relied on
or used without obtaining this further advice from GHD, to the maximum extent permitted by
law, GHD disclaims all liability and responsibility to any person in connection with, arising from
or in respect of this Report whether such liability arises in contract, tort (including negligence) or
under statute.
GHD has prepared this report on the basis of information provided by South Pacific Meats
Limited and others who provided information to GHD (including Government authorities), which
GHD has not independently verified or checked beyond the agreed scope of work. GHD does
not accept liability in connection with such unverified information, including errors and omissions
in the report which were caused by errors or omissions in that information.
The opinions, conclusions and any recommendations in this report are based on assumptions
made by GHD described in this report section 1. GHD disclaims liability arising from any of the
assumptions being incorrect
8 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/2. Existing environment
2.1 Site location and description
The SPM processing plant is located at 1044 Two Chain Road in Burnham, approximately 34
kilometres south-west of Christchurch City. It is legally described as Lot 2 DP 339707, Lot 2 DP
370579 and Lot 1 DP 379137 and is contained within Certificates of Title 163301 and 317651.
The site is situated approximately 1.3 km east of the Two Chain and Telegraph Road
intersection and approximately 4.2 km north of the Selwyn/ Waikirikiri River.
The site is located within Selwyn District and is zoned Outer Plains in the Operative Selwyn
District Plan. The site itself is flat and is located on the Canterbury Plains. An overview of the
site details is provided in Table 1 below and a site location plan is shown in Figure 2-1 below:
Table 1: Site details
Address 1044 Two Chain Road, Burnham, Canterbury, 7675
Land Owner South Pacific Meats Limited
Legal Description Lot 2 DP 339707, Lot 2 DP 370579, Lot 1 DP 379137
Site Area 150 Hectares
Co-ordinates (NZTM2000) 1539102 E 5171000 N (centre of property)
Selwyn District Council Rural – Outer Plains
District and Regional Plan Selwyn-Waimakariri Combined Surface and
Zoning Additional Limitations Groundwater Allocation Zone;
Semi-confined or unconfined aquifer
Depth to groundwater greater than 6 metres
The site is not located within a community drinking
water protection zone
Cultural Significance The site is not located within a silent file area nor a
Statutory Acknowledgement Area.
The site is located within the Te Waihora Co-
Governance Area
The Waikirikiri River (Selwyn River) is identified as a
Runanga Sensitive Area for Wähi Taonga and
Mahinga kai
Listed land use register Parts of the site are identified on the LLUR as
containing the following HAIL activities:
C2 – Gun clubs or rifle ranges; and
G5 – Waste Disposal to land
However, none of the identified HAIL activities are
occurring with the site’s irrigation area authorised by
CRC156662
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 9The surrounding area is largely a rural setting, with all of the land immediately surrounding the
processing plant used for pastoral and arable farming practices. Under the Canterbury Land and
Water Regional Plan (LWRP), the site is located within the Selwyn-Te Waihora sub-region,
which includes a diverse range of farming, industrial and township based activities.
The sub-region is of significant economic, social and cultural importance to the wider
Canterbury region, particularly for food production.
Figure 2-1 Site Location and discharge area
2.2 Processing Plant
The site’s processing plant is located over an area of approximately 5 hectares. The plant is
fully integrated, encompassing slaughter and processing operations, the production of edible
by-products, cold storage (chilling and freezing), and an on-site wastewater treatment facility.
2.3 Soils
The site is located on Lismore soils, and is classified in the New Zealand Soil Classification
System as a Pallic Orthic Brown Soil. Lismore soils are formed from gravelly glacial outwash
plain with a silty loess topsoil and a stony silt loam subsoil. The soil is well drained and has
moderate to rapid permeability. It is the most extensive soil occupying the Canterbury Plains.
S-Maps splits the irrigation field over two sub-types of Lismore soils, Lism_2a.1 covering the
northern and central area of the irrigation field and Lism_1a.1 covering the southern portion of
the irrigation field. Both soils have been identified as having a Profile of Available Water
(PAW100) of at least 100 mm.
10 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/2.4 Surface water bodies
The site is located within the Selwyn/Waimakariri Plains surface water catchment. This
catchment contains of a large number of water races and modified watercourses (drains). The
catchment’s land cover is primarily high producing exotic grassland.
With regards to nearby surface water bodies, there are identified drains located on the eastern
and western boundary of the site. These drains are connected to a roadside drain on Grange
Road on the northern end of the site.
The Selwyn River is also located 3 km south-east of the plant.
2.5 Hydrogeology
Glacial and interglacial outwash sediments in the Waimakariri and Rakaia Rivers have built up a
succession of large fans that coalesce and have formed the Central Plains over the last two
million years (North Canterbury Catchment Board, 1983). The fans are composed
predominantly of gravels derived from the Southern Alps and contain water-bearing aquifers.
The finer sediments act as confining layers (aquitards) between the ground surface and
successive gravel aquifers. Aquitards can confine groundwater under considerable pressure. It
is important to note that there can be flow between these aquifers where the aquitards are
discontinuous. The groundwater flow direction is generally west to east, with groundwater
discharging through the ocean floor, or emerging as springs.
The groundwater underneath the site is unconfined in gravel aquifers, below the plains. The
groundwater depth beneath the site is between 17.3 and 24.9 metres below ground level
(mbgl), with the groundwater flowing in a south-easterly direction.
The use of the groundwater downgradient of the site are for irrigation, stock and domestic use
and for the Burnham military camp drinking water supply (cross-gradient to the site).
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 113. Proposed change of conditions
3.1 Reasons for change of conditions
As detailed in Section 1.3 above, SPM have on occasion exceeded their daily volume discharge
limit and nitrogen loading specified in the consent conditions.
As a result of the non-compliance SPM have undertaken a number of measures on-site with the
goal of becoming consent compliant by 2021. These measures have included significant
investment by SPM. This includes the following timeline:
Development of the SSA in 2019 to roadmap the stages required for SPM to achieve
full wastewater compliance.
An expanded testing regime across the site to identify key nitrogen source areas.
Installation of a second contrashear on the stockyards to capture solid waste early in
the waste stream.
Improved blood capture measures.
Implementation of water saving technology across the plant including
– Recycling belly wash water
– More efficient sterilisers and water cut off valves
– Reducing wash water used in stockyards
– Changing wash hoses to high pressure items to reduce water consumption
Trial of a wastewater treatment system by Envirowaste in early 2020.
Refinement of the wastewater treatment process throughout 2020 (ongoing).
As a result of undertaking these actions taken by SPM, they have reduced the nitrogen content
within their wastewater stream by half between 2017 (average of 182 g/m3) and 2020 (average
of 90 g/m3), which is shown in Figure 3-1. Furthermore, this has resulted in the gross annual
nitrogen loading changing from 502 kilograms per hectare (kgN/ha) in 2017 to approximately
244 kgN/ha in 2020/ 2021 consent reporting period..
SPM are continuing to improve their treatment processes and in December 2020 and January
2021 averaged 70 g/m3 total nitrogen in the wastewater discharged to land (see Figure 3-1 for
graphical representation).
12 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/SPM Total Nitrogen Result
300
250
200
Mg/l
150
100
50
0
Mar‐17 Sep‐17 Apr‐18 Oct‐18 May‐19 Dec‐19 Jun‐20 Jan‐21 Jul‐21
Date
Figure 3-1 Nitrogen concentrations in SPM wastewater
With regard to wastewater volume, SPM has seen some improvements in the daily volumes
discharged as a result of additional measures such as the installation of a 2,000 m3 buffer tank
and the water use improvements implemented onsite. The number of days that discharge
volumes exceeded 1,000 m3 has reduced from 209 days during the 2017/2018 consent period
(March – February) to 6 in the 2019/2020 reporting period.
While there have been some improvements in the daily discharge volumes being produced
onsite via the improvement measures discussed above, SPM are still unlikely to achieve
compliance with this daily volume limit without offsite removal. Therefore, SPM are seeking a
change of conditions to reflect the current maximum volumes of wastewater produced onsite.
While the change of conditions seeks an increase in the maximum daily volume of wastewater
being discharged, given the significant reduction in the concentration of nitrogen since 2017, the
increase in the discharge volume alone will not result in a change in environmental effects from
what is already authorised. Furthermore, the level of effect authorised by the consent will still be
controlled by the other parameters set out within the remaining consent conditions.
3.2 Changes to conditions sought
The proposed changes to Condition 1 provided below with additions underlined and deletions
in strikethrough.
Condition 1:
The discharge shall be only meat works processing wastewater, and stormwater from animal
handling areas of the meat works, and shall be discharged via spray irrigation at a rate not
exceeding 30 litres per second or 1000 1500 cubic metres per day at Two Chain Road,
Burnham, at or about map reference NZTopo50 BX22:3932-7053 within the properties
denoted “Applicant’s Site” on Plan CRC156662A, which forms part of this consent.
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 134. Assessment of effects
In accordance with section 127 of the RMA, the following assessment identifies and assesses
the types of effects that may arise from the proposed condition changes and cancellations only,
and not the effects of the activity itself.
Actual and potential effects on the environment have been identified as:
Change in effects on soil quality.
Change in effects on groundwater quality.
Change in the allocation of the catchment load limit.
Change in effects on Tangata Whenua Values.
4.1 Change in effects on soil quality
The requested change of condition will result in an increase in the daily volume of wastewater
that is discharged to land. However, this is not expected to result in a change of effects on the
soil quality of the irrigation field.
The land treatment area is typically sown in pasture, although crops may be grown at certain
times to further increase nutrient uptake. The land treatment area is utilised as a cut and carry
operation. The regular harvesting of this area removes ryegrass pasture-based grasses as
bailage and thereby nitrogen from the land treatment area (approximately 295 kgN/ha was
removed in 2020).
Condition 4 of the consent limits the nitrogen loading of the discharge to 350 kgN/ha/yr and
Condition 8 restricts the mass nitrogen loading to 150 kgN/ha/yr. While the change of condition
will see an increase in daily volume, SPM will still be able to comply with these limits due the
substantial improvement in wastewater quality achieved since 2017.
Furthermore, Condition 5 limits the maximum application rate of 35 millimetres per run, with the
period between runs being a minimum of 14 days. Again there are no changes sought to this
condition. This application rate is less than half the water holding capacity of the soils (described
by the PAW) within the irrigation field, showing the soil has the ability to manage the rate of
discharge over the field.
The soil within the current land application area was tested annually between October 2017 -
2020 as required by the resource consent. The soil test results show that the soil on the land
application area is in good condition and the application of wastewater to land is not adversely
affecting the soil health. For example, the results of the testing indicate that the levels of
phosphorus in the soil have reduced since 2017 and are now within the optimal range for
sedimentary soils (i.e. between 20-30 g/m3). The soil organic matter is low, suggesting that the
disposal of wastewater is only likely to improve soil productivity.
As SPM will be continuing to discharge wastewater in line with the parameters detailed above,
the increase in volume is not expected to result in the degradation of the soil profile.
Nevertheless, annual soil composite samples will continue to be undertaken to monitor the
ongoing health of the soils.
Given the above, the request to increase the daily volume of wastewater is not considered to
result in a change in effect on soil quality. This is largely due to SPM’s recent upgrades in
wastewater treatment onsite, which has resulted in the concentration of nitrogen substantially
decreasing in the wastewater. As a result, SPM are able to discharge a higher daily volume will
still complying with the environmental limits specified in the consent conditions.
14 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/4.2 Change in effects on groundwater quality
The increase in the daily volume of wastewater discharged is not considered to result in an
increase in effect on groundwater quality. This is due to the wastewater that is discharged is
still able to be managed in line with the same level of environmental effects that is controlled by
the remaing consent conditions.
The potential effects on groundwater quality associated with wastewater irrigation is associated
with the leaching of nitruients (mainly oxidised forms of nitrogen) through the root zone.
As detailed above, there are no recommended changes to the existing nitrogen loading and net
nitrogen budget in the consent. While SPM seeks an increase in the maximum volume that can
be discharged to land on a daily basis, given SPM’s improvements in wastewater treatment
onsite, it is considered that they will be able to manage the discharged wastewater in line with
these controls.
The soil and vadose zone provides a very good protection for groundwater against the entry of
pathogens. As there is a reasonably thick vadose zone (i.e.depth to groundwater > 15 m),
pathogens within the wastewater can be attenuated through desiccation, irradiation filtration,
adsorption, and natural attrition. As detailed above, the requested change of condition is
considered to not result in a change of effects on soil quality. Given this, it is not considered that
the increase in discharge volume will result in an increased risk of pathogens entering
groundwater.
Under conditions 21 – 27, SPM are required to undertake quarterly groundwater monitoring
upgradient and downgradient of the site to assess the effects of the activity on local
groundwater quality and trends. There are no proposed changes to this requirement. In
addition, the previous four years of monitoring data have shown that nitrogen concentrations are
typically higher on the sites upgradient boundary and reduce as groundwater passes beneath
the site.
Since accurate herbage data has been collected in 2019 and 2020, the net nitrogen loading has
reduced to below 76 kgN/ha in 2019/2020 (consent limit 150 kgN/ha) and is negative in
2020/2021, indicating a net nitrogen deficient across the wastewater discharge area of negative
50 kgN/ha. The two year rolling average for the discharge area to the end of February 2021 is
negative 13 kgN/ha.
Given that increases in daily discharge volume can be managed to continue to comply with the
current nitrogen loading rate and net nitrogen budget, it is considered that the proposed change
of condition will not result in an adverse change in groundwater quality.
4.3 Change in the allocation of the catchment load limit
Section 11 of the Land and Water Regional Plan (LWRP) contains specific environmental
management issues related to the Selwyn Te Waihora sub-region of Canterbury. Table 11(i) of
this section sets out the sub-regional target limits for nitrogen losses from farming activities,
community sewerage systems and industrial or trade processes. For industrial or trade
processes this sets a nitrogen load limit of 152.4 tonnes/ year.
SPM’s current allocation of this limit is managed by the gross loading rate of nitrate-nitrogen
applied to land and the net loading rate of the irrigation area (accounting for all inputs and
outputs).
As there are no proposed changes to these parameters, the change of conditions will not result
in a greater portion of this allocation being used by SPM.
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 154.4 Change in effects on Tangata Whenua Values
The Mahaanui Iwi Management Plan 2013 (Mahaanui IMP) provides the policy framework for
the protection and enhancement of Ngai Tahu Values and for achieving outcomes that provide
for the relationship of Ngāi Tahu with natural resources across Ngā Pākihi Whakatekateka o
Waitaha and Te Pātaka o Rākaihautū.
Issue P8 (Discharges to Land) of the Mahaanui IMP is of relevance to the requested change of
condition. Tāngata whenua traditionally support the discharge to land as an alternative to
discharge to water, given the natural ability of Papatūānuku to cleanse and filter contaminants
from waste. However, the discharge must be managed appropriately so that does not
contaminate water resources.
As discussed above, the requested change of conditions is not considered to result in a change
in effect on soil and groundwater quality, SPM is still intending to use the land as an effective
wastewater management method with the existing consent conditions providing for the ongoing
monitoring and protection of soil and groundwater quality.
Given this, it is not considered that the proposed change of condition will result in a change in
effects on Tangata Whenua Values.
4.5 Summary
While SPM are seeking a change of condition to increase their maximum daily volume of
wastewater discharged to land, the change in conditions is not expected to result in a change of
effects from what is currently authorised for the following reasons:
Through significant upgrades onsite, the concentration of contaminants in the
wastewater stream has substantially reduced allowing for less nitrogen loading per
irrigation run.
There are no requested changes to the irrigation rate or application depth.
SPM will comply with the nitrogen loading rate and net loading rate of the discharge
area.
The existing monitoring programme will continue to assess the ongoing effects on soil
health and groundwater quality from the discharge. There are no proposed changes to
this programme.
16 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/5. Statutory assessment
Sections 104(1)(b) and 104(1)(c)of the RMA allows the Council to take into account the provisions
of any relevant statutory document, such as district plans, regional plans, national environmental
standards and national policy statements and any other matter the authority considers relevant
and necessary to determine the application. The operative documents relevant to this proposed
change of condition include:
National Policy Statement for Freshwater Management;
Canterbury Regional Policy Statement;
Canterbury Land and Water Regional Plan
Plan Change 7 of the Canterbury Land and Water Regional Plan; and
Mahaanui Iwi Management Plan.
There are no proposed statutory documents or additional proposed plan changes to the above
documents applicable to the proposed works that would require consideration.
In accordance with Schedule 4 of the RMA, all applications for resource consent must include
an assessment of the proposed activity against the objectives and policies of any relevant
statutory document including National and Regional Policy Statements, as well as Regional and
District Plans. An assessment against those documents relevant to the proposed works is
provided below.
5.1 Part 2 of the RMA – Purpose and Principles
Part 2 of the RMA sets out the overall purpose of the Act and defines the RMA’s purpose and
principles. The purpose of the RMA as set out in Section 5 is to promote the sustainable
management of natural and physical resources. The proposed change of consent conditions is to
increase SPM’s daily wastewater volume limit, however, due to significant wastewater upgrades
onsite, SPM are still able to manage the increase in discharge volume to the same level of
environmental effects authorised under the existing consent. Being able to increase the maximum
daily volume removes a significant cost to remove the additional wastewater offsite or risk a
potential non-compliance in the consent conditions, while also allowing SPM to effectively
manage the wastewater discharge and will meet the sustainable management purpose of the
RMA. It is considered that there will be no change in the potential effects on the environment
associated with the requested change of condition.
Section 6 of the RMA sets out the matters of national importance which must be recognised and
provided for. There are no matters of specific relevance to these works.
Section 7 of the RMA provides a list of further matters that particular regard must be given to. Of
relevance to this proposal are
(f) maintenance and enhancement of the quality of the environment
The proposed change of conditions will not result in additional effects on the environment, the
remaining monitoring requirements will provide for the continued maintenance of the discharge
and environment.
Section 8 of the RMA relates to the principles of the Treaty of Waitangi. The site is not recognised
as a culturally significant site, and there are no culturally significant sites within close proximity.
Overall the proposal is considered to be consistent with the principles of the Treaty of Waitangi.
Overall, it is considered that the proposed change of conditions meets the purpose and principles
of the RMA.
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 175.2 National Policy Statement for Freshwater Management 2020
An assessment against the relevant objective and policies of the National Policy Statement for
Freshwater Management 2020 (NPS-F) is provided in the table below.
Table 2: Land and Water Regional Plan
Objective Policy Comment
The objective of this Policy 1: Freshwater is The proposal is considered to give
National Policy managed in a way that gives effect to Te Mana o te Wai.
Statement is to ensure effect to Te Mana o te Wai
The requested change of conditions is
that natural and
not considered to result in additional
physical resources are
effects on freshwater (groundwater)
managed in a way that
and the discharge has other existing
prioritises:
limits and management requirements
(a) first, the health and that will continue to provide a
well-being of water safeguard on the existing water
bodies and freshwater source.
ecosystems
While there is existing potable
(b) second, the health groundwater users within the
needs of people (such surrounding area, the depth to
as drinking water) groundwater is over 15 mbgl.
Furthermore, over the previous year
(c) third, the ability of
SPM have been able to manage the
people and
net nitrogen loading in the negatives
communities to provide
(more nitrogen is removed than
for their social,
added).
economic, and cultural
well-being, now and in Policy 3: Freshwater is The management of nitrogen loading
the future managed in an integrated way is managed through the allocation
that considers the effects of the defined in Table 11(j) of the LWRP.
use and development of land The proposed change is not
on a whole-of-catchment basis, considered to result in a change to the
including the effects on allocation assigned to SPM.
receiving environments
Policy 13: The condition of As detailed above, SPM are required
water bodies and freshwater to monitor groundwater quality
ecosystems is systematically beneath the site. Recent monitoring
monitored over time, and action has shown an increase in groundwater
is taken where freshwater is quality that flows beneath the site.
degraded, and to reverse Annual soil quality testing is also
deteriorating trends. undertaken.
The proposed activity is considered to be consistent with the NPS-F.
5.3 Canterbury Regional Policy Statement
The following objectives are of direct relevance to the consent application:
Chapter 7: Fresh water
Objective 7.2.1 (Sustainable management of fresh water)
Objective 7.2.4 (Integrated management of fresh water resources)
It is considered that the proposal is consistent with the relevant provisions of Chapter 7 of the
RPS. While there is an increase in the volume of wastewater discharged, the activity can still be
managed to the same level of effects to that authorised by the current consent conditions. As
the proposed change is considered to not result in a change in effects on groundwater quality,
the proposed activity will continue to manage the effects on freshwater to the same level and
continued protection of groundwater quality.
18 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/5.4 Canterbury Land and Water Regional Plan
The following objective and policies of the Canterbury Land and Water Regional Plan (LWRP)
are of relevance to the change of conditions:
Objectives:
3.24: All activities operate at good environmental practice or better to optimise efficient
resource use and protect the region’s fresh water resources from quality and quantity
degradation;
Polices:
4.1: Water bodies meet regional freshwater outcomes;
4.4: Sets limits for both quantity and quality to maintain existing aquifers and protect the
water contained in the aquifer from contamination.
4.14: Discharge of contaminants onto land where it may enter groundwater will not
exceed the natural capacity of the soil to treat or remove the contaminant.
As detailed in the AEE, SPM has been able to substantially improve the quality of the
wastewater stream through significant investment and improvement in industry good practice.
As a result of this increased treatment, they will be able to continue to manage the activity in
accordance with the required environmental standards and outcomes set out in the conditions.
The discharge will still be managed to meet these environmental standards and outcomes,
including the requirement to not exceed the natural capacity of the soil.
The proposed change of conditions is considered consistent with the objectives and policies of
the LWRP.
5.5 Plan Change 7 of the Canterbury Land and Water Regional
Plan
Plan Change 7 of the LWRP has been reviewed and does not include any changes to the
objective and policies above.
5.6 Mahaanui Iwi Management Plan
The key policies from the Mahaanui Iwi Management Plan 2013 (Mahaanui IMP) are identified
as the following:
WM6.11 Consented discharge to land activities must be subject to appropriate consent
conditions to protect ground and surface water, including but not limited to: (a) Application rates
that avoid over saturation and nutrient loading; (b) Set backs or buffers from waterways,
wetlands and springs; (c) Use of native plant species to absorb and filter contaminants;
including riparian and wetland establishment and the use of planted swales; and (d) Monitoring
requirements to enable assessment of the effects of the activity
The existing consent conditions already include the matters specified in WM6.11 with the
exception of (c). SPM are not requesting changes to these conditions, nor will the proposed
change of conditions result in SPM becoming non-compliant with these conditions.
WM6.16 To require, in the first instance, that all potential contaminants that may enter water
(e.g. nutrients, sediments and chemicals) are managed on site and at source rather than
discharged off site. This applies to both rural and urban activities
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 19SPM manage and treat all wastewater onsite prior to being discharge to land, there are no direct
discharge to water.
Overall, it is considered that the proposed change of condition is consistent with the framework
of the Mahaanui IMP.
5.7 Resource Management Act 1991
5.7.1 Section 105
Section 105(1) of the RMA sets out the matters that a consent authority must have regard to when
considering a resource consent application for a discharge permit. In particular, consideration
needs to be given to the nature of the discharge and the sensitivity of the receiving environment,
as well as any possible alternative methods of discharge, including discharge into any receiving
environment.
The nature of the discharge and the sensitivity of the receiving environment in discussed earlier
in the report.
As the discharge is an existing authorised activity, discharging into a new receiving environment
would require a new resource consent and would increase the area of the receiving environment.
While SPM are seeking an increase in volume, they have undertaken significant upgrades onsite
to reduce their discharge concentration in the first instance. The requested increase in volume is
after SPM has undertaken alternative methods first, these upgrades also enable the requested to
change to not result in a change in the level of environmental effects permitted by the consent.
5.7.2 Section 107
Section 107 of the RMA places a restriction on the granting of discharge permits to water if,
after reasonable mixing, the contaminant or water discharged is likely to give rise to all or any of
the following effects in the receiving waters:
a. The production of any conspicuous films, scums or foams, or floatable or suspended
materials;
b. Any conspicuous change in the colour or visual clarity;
c. Any emissions of objectionable odour;
d. The rendering of freshwater unsuitable for consumption by farm animals;
e. Any significant adverse effects on aquatic life.
As the change of condition is not expected to result in a change in effects on the environment, it
is not considered that the proposed change will give rise to any of the effects listed above.
20 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/6. Notification and consultation
6.1 Public Notification
Section 95A of the RMA sets out four steps to be taken by the consent authority in deciding
whether to publicly notify an application. An assessment of the proposed works against these
steps is provided in Table 3 below:
Table 3. Public notification assessment
Step 1: A consent authority must notify an application if:
Public notification is required under Section None of these matters are triggered by
95C; the application. As the applicant does
not request public notification, no
The applicant requests public notification; or
outstanding or refused requests for
The application has been made jointly with an further information and the application
application to exchange recreation reserve does not include any exchange of
land. recreation reserved land.
Step 2: If not required by step 1, public notification is precluded if:
A rule or national environmental standard None of these matters are triggered by
precludes public notification of the application; the application. Step 3 applies.
The application is for one or more of the
following, but no other activity:
– The activity is a controlled activity;
– The activity is a restricted discretionary or
discretionary activity, but only if the activity
is a subdivision of land or a residential
activity;
– The activity is a restricted discretionary,
discretionary, or non-complying activity, but
only if the activity is a boundary activity; or
– The activity is a prescribed activity.
Step 3 and Step 4: Therefore, public notification is only required if:
A rule or national environmental standard that The overall change in effects on the
requires public notification; environment has been assessed as no
change in section 5 of this report.
The consent authority decides, in accordance
There are no special circumstances
with section 95D, that the activity will have or is
that exist to justify the public
likely to have adverse effects on the
notification of this application.
environment that are more than minor; or
Special circumstances apply.
Having undertaken the s95A public notification tests, the following conclusions are reached:
Under step 1, public notification is not mandatory.
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 21 Under step 2, there is no rule or NES that specifically precludes public notification of the
activities, and the application is for an activity other than those specified in s95A(5)(b).
Under step 3, public notification is not required as it is considered that none of the matters
under s95A(8) apply.
Under step 4, there are no special circumstances or more than minor effects that warrant
the application being publically notified.
It is, therefore, requested that this application be processed without public notification.
6.2 Limited Notification
Section 95B relates to limited notification of a consent application and sets out the steps to be
taken by the consent authority in deciding whether to notify an application on a limited basis. As
detailed in Table 4 below, limited notification is not required because the adverse effects on third
parties will be less than minor.
Table 4: Limited notification assessment
Step 1: A consent authority must give limited notification if:
There are any affected customary rights There are no protected customary rights
groups; or groups or customary marine title groups
affected by the works subject to this
There are any affected marine
application. The land is not subject to a
customary title groups.
statutory acknowledgement.
Step 2: If not precluded by step 1, limited notification is precluded if:
The activity is for 1 or more activities and None of these matters apply to this
each activity is subject to a rule or application.
national environmental a standard which
precludes limited notification;
The activity is a controlled activity; or
The activity is a prescribed activity.
Step 3: If not precluded by step 2, a consent authority must give limited notification if:
There are any certain affected persons There are no affected parties in accordance
including parties affected by: with section 95E of the RMA.
- A boundary activity; or
- A prescribed activity.
Step 4: Therefore, a consent authority must give limited notification if:
There are any special circumstances where There is nothing exceptional or unusual
any other persons are eligible for limited about the application, and the proposal is
notification. nothing out of the ordinary. Therefore, there
are no special circumstances and limited
notification need not occur.
Having undertaken the s95B limited notification tests, the following conclusions are reached:
Under step 1, limited notification is not mandatory.
22 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ Under step 2, there is no rule or NES that specifically precludes limited notification of the
activities, and the application is for an activity other than those specified in s95B(6)(b).
Under step 3, limited notification is not required as it is considered that the activity will not
result in any adversely affected persons.
Under step 4, there are no special circumstances that warrant the application being
limited notified to any persons.
It is, therefore, requested that this application be processed without limited notification.
6.3 Consultation
No consultation was undertaken in relation to this application and none is considered
necessary.
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 237. Conclusion
This application is seeking a change of consent conditions to SPM wastewater discharge permit
CRC156662. The application relates to the increase in the maximum daily volume of
wastewater from 1000m3 to 1500m3. While SPM are seeking an increase in discharge volume,
they intend to be able to continue to manage the activity to the same level of effect authorised
by the consent, this has been largely achieved by the increase in wastewater treatment onsite to
near historical lows.
SPM has made significant investment onsite to achieve this reduction and with the goal of
becoming fully compliant with the consent conditions. This change of condition will enable SPM
to achieve compliance while still effectively managing the site’s wastewater discharge and
irrigation field in a sustainable way.
In terms of Section 104(1)(a) it is considered that there are no changes in the effects on the
environment as such it is considered there are no potentially affected parties.
In terms of Section 104(1)(b), it is considered the proposal is consistent with the objectives and
policies of the NES-F, Regional Policy Statement and regional plans, and with Part 2 of the
RMA.
It is therefore concluded that the proposal will continue to promote the sustainable management
of natural and physical resources while avoiding, remedying or mitigating adverse effects on the
environment.
It is considered that this change of conditions application can be granted on a non-notified
basis.
24 | GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 25
Appendices GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/
Appendix A – Copy of CRC156662
Content
GHD | Report for South Pacific Meats Limited - CRC156662 - Wastewater Discharge, /12546840/ | 27RESOURCE CONSENT CRC156662
Pursuant to Section 104 of the Resource Management Act 1991
The Canterbury Regional Council (known as Environment Canterbury)
GRANTS TO: South Pacific Meats Limited
A DISCHARGE PERMIT: To discharge contaminants onto land and into air.
CHANGE TAKES EFFECT 18 May 2015
DATE:
EXPIRY DATE: 27 Oct 2037
LOCATION: Two Chain Road, BURNHAM
SUBJECT TO THE FOLLOWING CONDITIONS:
Limits
1 The discharge shall be only meat works processing wastewater, and stormwater from
animal handling areas of the meat works, and shall be discharged via spray irrigation at a
rate not exceeding 30 litres per second or 1000 cubic metres per day at Two Chain Road,
Burnham, at or about map reference NZTopo50 BX22:3932-7053 within the properties
denoted “Applicant’s Site” on Plan CRC156662A, which forms part of this consent.
2 The area of land available for the discharge, “Extent of Area Available for Wastewater”,
shall not be less than 91 hectares, as shown on Plan CRC156662B, which forms part of
this consent.
3 The discharge shall not occur;
a. within 20 metres of any water race, surface drain or other surface water, or property
boundary;
b. within 30 metres in any direction of any well;
c. in any other place, or in such a manner that wastewater is likely to discharge or
percolate into surface water or onto any neighbouring property.
d. after the 21st anniversary of the commencement of this consent.
4 The loading rate of nitrogen applied to any part of the discharge area shall not exceed 350
kilograms of Nitrogen per hectare per year. The nitrogen loading rate shall be calculated
using the most recent sample results taken in the previous two monthly samples in
condition 14.
5 Wastewater shall be applied on a rotational basis to ensure that the discharge occurs over
the discharge area as evenly as is practicable. The maximum application rate shall not
exceed 35 millimetres and the period between applications to the same land area shall not
be less than 14 days.
6 There shall be no ponding of effluent on the ground.
7 There shall be no livestock on the land available for discharge shown on Plan
CRC156662B.You can also read
