Rushes Creek SSD 7704 Mod 3 Submissions Report v2

Rushes Creek
Poultry Production Farm

SSD 7704
Modification 3 -
Submissions Report
Prepared for:
ProTen Tamworth Pty Limited
May 2022
Prepared by:
Rushes Creek Poultry Production Farm, SSD 7004
Modification 3 – Submissions Report May 2022
RUSHES CREEK POULTRY PRODUCTION FARM, SSD 7704
Modification 3 – Submissions Report
PREPARED BY
Name: Eryn Bath
Principal Consultant
Qualifications: Bachelor of Environmental Science
Graduate Diploma of Environmental Engineering
Company: EME Advisory
Address: 17 Carlotta Street, Greenwich NSW 2065
APPLICANT
Company: ProTen Tamworth Pty Limited
Address: PO Box 1746, North Sydney NSW 2060
APPROVED DEVELOPMENT
Development Consent: SSD 7704
Description: Rushes Creek Poultry Production Farm
Address: Rushes Creek Road, Rushes Creek NSW
LGA: Tamworth Regional
PROPOSED MODIFICATION
Approval Pathway: Section 4.55(1A) of the Environmental Planning and Assessment Act 1979
Description: Modification 3 relates to Stage 1 only (i.e. Farm 2 and associated ancillaries) and, in
summary, comprises development optimisations and early commencement of
operations using diesel generators for power for up to 12 months.
DECLARATION
We confirm that we have prepared the contents of this document and to the best of our knowledge:
 It contains all available information that is relevant to the environmental, social and economic impact
assessment of the proposal; and
 It is true in all material particulars and does not, by its presentation or omission of information, materially
mislead.
EME Advisory

Eryn Bath
23 May 2022

Page ii
TABLE OF CONTENTS
1 INTRODUCTION ..................................................................................................................... 1
1.1 Background ....................................................................................................................... 1
1.2 Document Purpose ........................................................................................................... 1
1.3 Additional Consultation .................................................................................................... 2
2 MODIFICATION 3 ................................................................................................................... 3
2.1 Overview ........................................................................................................................... 3
2.2 Minor Amendments to Modification Proposal ................................................................. 4
2.2.1 Realignment of Driveway ..................................................................................... 4
2.2.2 Removing Diesel Storage Tank ............................................................................. 4
2.2.3 Updated Concurrent Construction and Operations Timing ................................. 6
2.2.4 Diesel Generator Operations – Extended Timeframe .......................................... 7
2.2.5 Diesel Generator Operations – NOx Emissions Treatment .................................. 8
3 SUMMARY OF SUBMISSIONS ............................................................................................... 13
4 RESPONSE TO SUBMISSIONS ................................................................................................ 14
4.1 Strategic Context and Contingencies .............................................................................. 14
4.2 Water Licensing ............................................................................................................... 15
4.3 Updated Concurrent Construction and Operations Timing ............................................ 16
4.4 Diesel Storage ................................................................................................................. 16
4.4.1 Water Pump Diesel Storage ............................................................................... 16
4.4.2 Bunding .............................................................................................................. 17
4.5 Generators ...................................................................................................................... 17
4.6 Dead Bird Freezers .......................................................................................................... 18
4.7 Air Quality ....................................................................................................................... 18
4.8 Noise ............................................................................................................................... 19
4.9 Community Consultation ................................................................................................ 21
4.10 Management Plans ......................................................................................................... 21
5 CONCLUSION ....................................................................................................................... 22
6 REFERENCES ........................................................................................................................ 23
7 ABBREVIATIONS .................................................................................................................. 24

TABLES
Table 1 Additional Consultation ............................................................................................................... 2
Table 2 Modification 3 Description Summary.......................................................................................... 3
Table 3 Updated Development Staging ................................................................................................... 6
Table 4 Updated Indicative Timing for Stage 1 Construction and Operations ........................................ 6
Table 5 Summary of Submissions .......................................................................................................... 13
Table 6 Background Air Quality Data 2019 ............................................................................................ 18

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FIGURES
Figure 1 Approved and Proposed Farm 2 Layout ...................................................................................... 5
Figure 2 Proposed Farm 2 Layout with SCR Units and Urea Storage ...................................................... 10
Figure 3 Conceptual Design – SCR Units for the 440 kVA Generators .................................................... 11
Figure 4 Conceptual Design ‐ SCR Unit for the 45 kVA Generator .......................................................... 12

APPENDICES
Appendix A Information for SCR Units and Urea Storage
Appendix B Response to Traffic Matters (SLR Consulting Australia 2022)
Appendix C Response to Noise Matters (Global Acoustics 2022)
Appendix D Response to Fiore/Hazard Matters (GHD 2022)
Appendix E Essential Energy Services Agreement Extension

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1 INTRODUCTION
1.1 Background
ProTen Tamworth Pty Limited (ProTen) was granted Development Consent SSD 7704 from the
Department of Planning, Industry and Environment (now Department of Planning and Environment [DPE])
(as delegate for the Minister for Planning and Public Spaces) on 16 April 2020 to construct and operate an
intensive poultry broiler production farm within a rural area known as Rushes Creek in the Tamworth
Regional local government area. In summary, the approved Rushes Creek poultry production farm (the
“Development”) comprises four individual poultry production units (PPUs), identified as Farms 1 to 4, each
containing between 10 and 18 poultry sheds and various items of ancillary infrastructure. Combined,
these four PPUs comprise a total of 54 poultry sheds and have the capacity to house up to 3,051,000
broiler birds.
The development consent has subsequently been modified on two occasions:
(1) Modification 1 approved on 15 June 2021 allowing (a) an alternative remediation strategy for an
area near Farm 2 containing arsenic impacted soils; and (b) removal of condition B33(e) requiring
the excavation of an Aboriginal hearth; and
(2) Modification 2 approved on 2 September 2021 to amend condition B53(a) to correct the timing for
the requirement to establish vegetation screens from pre‐construction to pre‐operation.
The following should be referred to for a detailed description of the approved Development:
 Environmental Impact Statement, Intensive Livestock Agriculture, Rushes Creek Poultry Production
Farm, SSD 7704 (SLR Consulting Australia [SLR] 2018) (EIS), including appendices;
 Rushes Creek Poultry Production Farm, SSD 7704, Response to Submissions (EME Advisory [EME]
2019a) (RTS), including appendices;
 Rushes Creek Poultry Production Farm, SSD 7704, Supplementary Response to Submissions (EME
2019b) (Supplementary RTS), including appendices;
 Rushes Creek Poultry Production Farm, SSD 7704, Section 4.55(1A) Modification Report (EME 2021a)
(Modification 1), including appendices; and
 Rushes Creek Poultry Production Farm SSD 7704, Modification Report – Condition B53(a) (EME
2021b) (Modification 2).
The poultry farm is planned to be established over two separate stages, with Stage 1 comprising the
construction and operation of Farm 2 and associated ancillaries, and Stage 2 comprising the construction
and operation of Farms 1, 3 and 4 and associated ancillaries. Construction of Stage 1 commenced in
August 2021 and is anticipated to be completed in late 2022. Stage 2 timeframes are currently unknown.
1.2 Document Purpose
ProTen submitted an application to further modify the approved Rushes Creek poultry farm development
under section 4.55(1A) of the Environmental Planning and Assessment Act 1979 (EP&A Act) in January
2022 (Modification 3). The Modification 3 ‐ Modification Report (EME 2022) that accompanied the
application has been assessed by DPE and other relevant government agencies.
This Submissions Report has been prepared to respond to the issues raised by DPE and other consulted
government agencies in response to Modification 3. A summary of these submissions is provided in
Section 3.
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1.3 Additional Consultation
Additional consultation has been undertaken with DPE and the Environment Protection Authority (EPA)
in relation to some of the issues raised in response to Modification 3. Table 1 provides a summary of the
consultation activities undertaken and the key issues raised and/or outcomes.
Table 1 Additional Consultation
Date Stakeholder Method Purpose / Outcome
 Query possibility of an exemption/allowance for the generators to
exceed the nitrogen oxides (NOx) emission limit under the Protection
of the Environment Operations (Clean Air) Regulation 2021 for the
initial 12 month period; and
 Query possibility of extending the initial period of generator power
28 Feb Email and from 10 months to 18 months.
EPA
2022 Phone EPA advised the following:
 The generator emissions query will be referred to the EPA’s technical
air quality unit for consideration; and
 No notable concerns with extending the period of generator power to
18 months. As per Section 2.2.4, ProTen has opted to extent the
period to 12 months (not 18 months).
Advising that the NOx emission limit is not currently achievable by current
“off the shelf” technology and that fully‐engineered selective catalytic
reduction (SCR) units will be required. ProTen again appealed to the EPA to
provide an exemption to the NOx limit based on the significant expense,
2 Mar along with the assessment modelling predicting compliance well‐clear of
EPA Email
2022 the criteria and the generators reverting to standby emergency generators
after the initial 12 month period.
The EPA responded via email on 15 March advising that the EPA is unable to
give an exemption to the NOx limit given that technology is available to
enable compliance.
Outline the issues faced by ProTen in meeting the NOx limit for the
temporary generators and query the following:
 Is the EPA able to provide any information of a facility in Australia that
has installed and commissioned diesel generators of similar sizes to
meet the Group 6 NOx limit?
 Will the EPA reconsider its stance on an exemption from the NOx limit
for the short‐term 12 month period?
 Can DPE and EPA advise of any additional impact assessment
requirements for the SCR units if they are to be installed?
DPE/EPA advised the following:
31 Mar Video  Snowy Hydro 2.0 Project is proposing temporary generators and are
DPE and EPA
2022 conference being required to meet the Group 6 NOx limit.
 No allowance or exemption in relation to the NOx limit for the
temporary generators.
 A manufacturer’s guarantee is all that is required to demonstrate that
the SCR units will meet the NOx limit – see Section 2.2.5 and Appendix
A.
 Urea is not a dangerous good and no additional hazard analysis is
required.
 Advice in relation to noise emissions, water input and waste
generation is required for the SCR units ‐ see Section 2.2.5 and
Appendix A.
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2 MODIFICATION 3
2.1 Overview
ProTen is proposing to modify the approved Rushes Creek poultry farm development (SSD 7704). This
modification relates to Stage 1 only (i.e. Farm 2 and associated ancillaries) and, in summary, comprises
development optimisations and early commencement of operations relying on diesel generators for
power while an alternative renewable power solution (subject to a separate modification) is finalised,
approved and commissioned. The Modification Report titled Rushes Creek Poultry Production Farm,
Development Consent SSD 7704, Modification 3 ‐ Modification Report (EME 2022) should be referred to
for a detailed description of Modification 3.
Modification 3 remains as described in the Modification Report, with the exception of some minor
amendments in response to delays to the construction timeline, delays to the design of the future
renewable power solution, and issues/requests raised by consulted government agencies. These minor
amendments are noted in Table 2 and described in Section 2.2.
Table 2 Modification 3 Description Summary
Description (as per original modification application) Minor Amendment
 Realigning the driveway to the
farm managers’ houses – see
Minor amendments to the positioning of some of the ancillary Section 2.2.1.
infrastructure items at Farm 2, including the site office and  Addition of selective catalytic
workshop, water storage tanks, emergency standby reduction (SCR) units and
(a)
generators, diesel storage and dead bird freezer. These associated urea storage to treat
optimisations will provide efficiencies and benefits for the emissions of NOx from the
initial site establishment and long‐term farm operations. generators that will operate for
more than 200 hours per year –
see Section 2.2.5.
Additional emergency standby diesel generator capacity at
Farm 2 comprising four 440 kilovolt amp (kVA) generators (in
place of the currently approved three 390 kVA generators) to
(b) ensure adequate backup for the rare occasion when the ‐
primary operational power supply is lost. There would only
ever be two of the proposed 440 kVA generators operating at
any one time.
Addition of a 45 kVA emergency standby diesel generator and
2,000 litre (L) bunded diesel storage tank at the water supply No longer proposing the 2,000 L diesel
(c)
pump near the Namoi River to provide backup for the rare storage tank – see Section 2.2.2.
occasion when the primary operational power supply is lost.
Concurrent construction and operation at Farm 2 for up to 10 No change, however the timing has
(d)
months to enable partial farm operations to commence earlier. been delayed – see Section 2.2.3.
 Increasing the proposed
Reliance on the proposed 440 kVA diesel generators to operate timeframe from 10 months to up
Farm 2 (only ever two operating at any one time) and the to 12 months – see Section 2.2.4.
(e) proposed 45 kVA diesel generator to operate the water supply  Addition of SCR units and
pump for up to 10 months while the alternative renewable associated urea storage to treat
power option is finalised, approved and commissioned. NOx emissions from the
generators – see Section 2.2.5.
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2.2 Minor Amendments to Modification Proposal
ProTen is seeking the agreement of the consent authority (DPE) to the minor amendments to the
modification proposal, as listed in Table 2, pursuant to clause 55AA of the Environmental Planning and
Assessment Regulation 2000 and the State Significant Development Guidelines (Department of Planning,
Industry and Environment [DPIE] 2021). Clause 55AA advises:
A development application for State significant development may, with the agreement of the
consent authority, be amended or varied by the applicant at any time before the application is
determined.
The State Significant Development Guidelines (DPIE 2021) confirms that this applies to development
applications for consent as well as applications seeking to modify a development consent.
As outlined in the below sub‐sections, the proposed changes to the modification are considered relatively
minor and they do not pose any material environmental impacts. Some of the amendments will in fact
deliver positive environmental outcomes (in comparison to the original scope of the modification).
2.2.1 Realignment of Driveway
The original modification proposal included realigning the driveway to the farm managers’ houses to
enable the light vehicle traffic generated by the managers and their families to exit the main farm access
road earlier and reduce the potential for interaction with operational heavy vehicle traffic. However,
further site survey and detailed design has identified that the proposed alignment was not ideal in terms
of the existing terrain and required earthworks and construction. As such, and as shown on Figure 1, the
driveway has been realigned to a more position that is preferable in terms of driveway construction
requirements and site operations.
The new driveway alignment is relatively close to the original approved alignment (see Figure 1). While
it is outside of the existing disturbance footprint, it is within an area of non‐native groundcover and will
not increase the overall disturbance area for Farm 2.
2.2.2 Removing Diesel Storage Tank
Responding to the concerns raised by consult government agencies, the proposed modification no longer
includes the 2,000 L bunded diesel storage tank at the water supply pump near the Namoi River. As
suggested by WaterNSW, ProTen will instead cart diesel from the approved storage at Farm 2 using a fuel
trailer towed by a light vehicle (for example, ute or four‐wheel drive) to refill the diesel generator at the
Namoi River water supply pump as required.
During the initial period of up to 12 months when Farm 2 and the water supply pump are proposed to be
powered using diesel generators, it is anticipated that the water supply pump generator will require
refuelling in peak times (for example, in hot conditions with all shed ventilation/cooling systems running)
every 1 to 2 days. SLR’s Modification 3 Traffic Assessment (2021a), which was prepared as part of the
original Modification Report (EME 2022), conservatively assessed up to two light vehicle movements daily
between Farm 2 and the river water pump site. On this basis, and as confirmed in SLR’s response report
in Appendix B, the impacts of this proposed change to the scope of Modification 3 have already been
assessed and no further assessment is warranted.

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SHED 1
H:\Projects-SLR\610-SrvSYD\610-SYD\610.17991 Rushes Creek Draft EIS QA\06 SLR Data\01 CADGIS\CAD\Workings\SLR61017991_F1_Appr v Prop_A3_05.dwg
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SHED 6 SHED 6 Petrol Tank Outer Batter
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LPG Tanks SW LPG Tanks SW
SHED 10 Wheel Wash SHED 10

Site Office and Workshop Dead Bird Freezer
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SHED 11 Water Storage Tanks SHED 11 Primary Emergency Generators (x2), Diesel Tank,
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SW SW Perimeter Drain
Surface Water Diversion Surface Water Diversion
APPROVED FARM 2 LAYOUT PROPOSED FARM 2 LAYOUT

Note: Layout is conceptual. Symbols have been used to represent ancillaries. Note: Layout is conceptual. Symbols have been used to represent ancillaries.
0.0 125 250 Scale: 1:4000 09.05.2022
m (GDA94) MGA Zone XX 610.17991
APPROVED V PROPOSED
Sheet Size: A3
FARM 2 LAYOUTS
www.slrconsulting.com PH: 02 4037 3200 FIGURE 2

2.2.3 Updated Concurrent Construction and Operations Timing
As detailed in the Modification Report, the modification seeks to allow concurrent construction and
operation at Farm 2 for up to 10 months. Due to unforeseen delays to the construction program
associated with on‐going wet weather and Covid‐19 restrictions/cases within the construction workforce,
the timing for construction and operational activities has been delayed.
The updated overall development staging is summarised in Table 3, and the updated indicative timing for
Stage 1 (i.e. Farm 2 and associated ancillaries) construction and operational activities is summarised in
Table 4. While Table 4 indicates construction works and partial operations will occur concurrently for
around 7 months, an additional 3 months has been included to allow for any further unforeseen
construction delays.
Table 3 Updated Development Staging
Estimated Anticipated
Construction
Stage Key Aspects Construction Construction
Commencement
Duration Completion
 Northern site access from Rushes Creek Road.
August 2021
1  Farm 2 ‐ 18 poultry sheds and associated 12 to 16 months
(commenced)
Late 2022
ancillaries and servicing.
2A ‐ southern site access from Rushes Creek Road.
2B ‐ Farm 4 ‐ 16 sheds and associated ancillaries 12 to 15 months
and servicing.
2 2C ‐ Farm 3 ‐ 10 poultry sheds and associated TBC TBC
10 months
2D ‐ Farm 1 ‐ 10 poultry sheds and associated
10 months
Table 4 Updated Indicative Timing for Stage 1 Construction and Operations
Anticipated
Anticipated Completion of
Stage 1 Key Activities Commencement of
Construction
Operations
Earthworks, including construction of the May 2022 (i.e. prior to any
1A ‐
northern site access road and internal roads operational activities)
Construction of Sheds 1‐8 (8 sheds) and
1B June / July 2022 July 2022
ancillary infrastructure
1C Construction of Sheds 9‐12 (4 sheds) August / September 2022 September 2022
1D Construction of Sheds 13‐16 (4 sheds) October / November 2022 November 2022
1E Construction of Sheds 17‐18 (2 sheds) December 2022 / January 2023 January 2023
Farm 2 earthworks and construction of Sheds 1 to 8 are well‐underway and will be completed prior to any
operational activities commencing. ProTen is working towards constructing four to eight poultry sheds at
a time and commissioning them while construction of the remaining sheds is on‐going until all 18 sheds
are completed and commissioned.
Page 6
It is anticipated that construction of the first eight sheds will be completed and commissioned in July 2022
(originally scheduled for February 2022), which is when the proposed concurrent construction and
operation period would commence. Note that the commencement of operations may be brought forward
a few weeks or may be delayed depending on the construction program, weather conditions, installation
of the SCR units (see Section 2.2.5) and other variables.
There are no implications in relation to site access or traffic associated with the delayed construction

program and delayed commencement of operations at Farm 2. The change is merely delayed timing.
SLR’s response report in Appendix B confirms that the proposed delay to concurrent construction and
operation activities at Farm 2 is not significant from a traffic engineering perspective and will not result in
any new traffic impacts beyond that previously assessed. Furthermore, Global Acoustics’ response report
in Appendix C advises that this amendment is not significant in terms of predicted construction, operation
and road traffic noise impacts.
2.2.4 Diesel Generator Operations – Extended Timeframe
As detailed in the Modification Report, the modification originally proposed a period of up to 10 months
for Stage 1 operations (i.e. Farm 2 and associated ancillaries) to be powered using diesel generators while
the alternative renewable power solution (i.e. off‐grid solar, battery and generator solution) is designed,
approved and commissioned. Specifically, the proposed 440 kVA generators would be used to operate
Farm 2 (only ever two operating at any one time) and the proposed 45 kVA generator would be used the
operate the water supply pump at the Namoi River.
There have been delays in finalising the renewable power solution, in terms of selecting the most suitable
solar panels for the poultry farm, and, in particular, optimising the battery and generator components.
These aspects are critical in terms of ensuring sufficient and cost‐effective solar power and battery
storage, and reducing generator requirements. There is also a significant lead time for required
components, particularly the solar panels and battery.
To allow enough time to optimise the design and subsequently progress through the impact assessment
and approval process, and finally install and commission the off‐grid system, ProTen seeks to increase the
period of time relying on the diesel generators to power Farm 2 and associated ancillaries from the
originally proposed 10 months to up 12 months. After this time, the generators will revert to their
intended purpose of standby emergency generators.
As advised in Section 2.2.3, it is anticipated that the first eight poultry sheds will be commissioned in July
2022, which is when the 12 month period of generator use would commence. Note that this
commencement may be brought forward a few weeks or may be delayed depending on the construction
program, weather conditions, installation of the SCR units (see Section 2.2.5) and other variables. If the
first sheds are commissioned in July 2022, the 12 month period will end in July 2023. Contingencies in the
event that the off‐grid power system is not approved or not approved in a timeframe that allows
installation and commissioning prior to the end of the 12 month period are discussed in Section 4.1.
As a result of the increased usage of the diesel generators, additional diesel deliveries to Farm 2 will be
required for up to 12 months. It is anticipated that up to one diesel delivery per day in a rigid tanker from
Tamworth will be required during peak times over the 12 month period. A fuel trailer towed by a light
vehicle will be used to transfer diesel from Farm 2 to refill the diesel generator at the Namoi River water
pump as required (every 1 to 2 days during peak times).
Potential traffic, noise and fire safety/hazard implications of this amendment have been considered by
the respective specialist consultants and addressed in their response reports in Appendices B, C and D,
respectively. In summary:
Page 7
 SLR concluded that the proposed extension of diesel generator use is not considered to be
significant from a traffic engineering perspective and will not result in any new traffic impacts
beyond that previously assessed.
 Global Acoustics concluded that the amendment is not significant in terms of predicted
construction, operation and road traffic noise impacts.
 GHD concluded no impact on findings to date in relation to fire safety/hazards.
Note that Astute’s Air Quality Assessment (2021), which was prepared as part of the original Modification
Report (EME 2022), conservatively assessed the two 440 kVA diesel generators and the 45 kVA water
pump diesel generator operating at full capacity continuously for 12 months and, as such, no further
assessment is warranted.
2.2.5 Diesel Generator Operations – NOx Emissions Treatment
The EPA noted the following in its submissions in relation to Modification 3:
 The primary concern with diesel generators is the emission of nitrogen oxides (NOx); and
 The predicted ground level NOx concentrations are all below the limits specified in the Protection
of the Environment Operations (Clean Air) Regulation 2021 (Clean Air Regulation) and criteria
specified in the Approved Methods for the Modelling and Assessment of Air Pollutants in NSW (EPA
2016) (Approved Methods).
Regardless, given that the proposed generators will operate for more than 200 hours per year over the
initial 12 month period, the NOx concentration limits in Schedule 4 of the Clean Air Regulation will apply.
As such, the EPA recommended the following condition in relation to the proposed 12 months of
generator power:
Any diesel generator that operates for 200 hours or more per year must comply with the NOx
emission limits specified in Schedule 4 of the POEO (Clean Air) Regulation 2021.
The generators proposed at Rushes Creek are classed as “stationary reciprocating internal combustion
engines” and, pursuant to sub‐clause 33(1)(f) of the Clean Air Regulation, they belong to Group 6. As such,
the applicable NOx concentration limit is 450 milligrams per normal cubic metre (mg/Nm3).
The only options that ProTen has been able to identify to meet this NOx emission limit for the proposed
generators are (a) expensive retrofitting of fully‐engineered emissions reduction technology; or (b)
purchasing USEPA Tier 4 compliant generators. Given ProTen has been unable to find any evidence of
USEPA Tier 4 compliant generators in Australia, ProTen has commissioned Exhaust Control Industries
Australia (ECI) to design and manufacture specific SCR units for two of the 440 kVA generators and the 45
kVA generator (i.e. one SCR unit for each generator that will operate more than 200 hours per year in the
initial 12 month operational period) to meet the 450 mg/Nm3 NOx limit over the proposed 12 month
period.
ECI is very experienced in the design and manufacture of SCR NOx abatement systems in Australia
(including the Snowy Hydro 2.0 project) and around the world. As per the letter of guarantee in Appendix
A, ECI has committed to meeting the 450 mg/Nm3 target for NOx emissions for both the 440 kVA
generators and 45 kVA generator. Simply put, these custom‐built SCR units will selectively reduce NOx by
combining liquid urea and oxygen, with NOx in the generator exhaust gas, in the presence of a catalyst to
form molecular nitrogen and water vapour.
Page 8
The urea solution (Ausblue) is 40 percent (%) urea by weight and 60% demineralised water by weight. As
per the Safety Data Sheet (SDS) in Appendix A, it is not classified as a hazardous chemical or a dangerous
good. It will be delivered from Brisbane to Farm 2 in tankers up to B‐double size, with a maximum of one
delivery per month over the 12 month period, and be stored at Farm 2 in a 10,000 L double‐bunded tank
dedicated and design for urea. The SCR unit for the 45 kVA water pump generator will have a small 35 L
urea storage tank attached to it, which will be topped up from the Farm 2 storage tank as required using
the same fuel trailer as the diesel deliveries from Farm 2. Each time the river pump generator is refuelled,
a small amount of urea will be carted to top up the 35 L urea storage.
Figures 1 and 2 show the proposed Farm 2 layout with the addition of the two SCR units and urea storage,
and Figures 3 and 4 show the conceptual designs for the SCR units proposed to treat the emissions from
the two 440 kVA generators (each generator will have its own SCR unit) and the 45 kVA generator,
respectively. While the SCR units required for the 440 kVA generators will be stand‐alone units, the SCR
units required for the 45 kVA water pump generator is much smaller and will be installed on a frame over
the generator.
Some additional key details advised by ECI in relation to the proposed SCR units include:
 The SCR units provide some level of exhaust noise silencing, with an average attenuation/ reduction
of around 15 dB(A).
 There is no water supply to the SCR units (only the urea solution) and no wastewater generation as
the urea solution is vaporised.
 The only waste generation will be from maintenance activities, which ECI will complete and remove
all waste materials off‐site for suitable disposal, reuse or recycling.
The information provided by ECI in Appendix A should be referred to for further information.
Potential traffic and fire safety/hazard implications of the proposed SCR units and urea deliveries and

storage have been considered by the respective specialist consultants and addressed in their response
reports in Appendices B and D, respectively. In summary:
 SLR concluded that the monthly deliveries of Ausblue using tankers up to B‐double size will not be
significant from a traffic engineering perspective and will not result in any new traffic impacts
beyond that previously assessed.
 GHD advised that urea is classified as a non‐hazardous, non‐dangerous good chemical, and it is not
flammable. GHD further advised that the urea storage on‐site at Farm 2, including in proximity to
the diesel storage, is not expected to impact findings to date in relation to fire safety/hazards.

Page 9
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1 : 2000 @ A1 ISSUED FOR COMMENT
0 20m 40m 60m 80m 100m 200m PROTEN / AGRIBIZ
SCALE 1:2000
DOCUMENTATION IN PROGRESS AGRIBIZ NEW POULTRY FARM RUSHES CREEK
NOT TO BE USED FOR CONSTRUCTION PURPOSES
RUSHES CREEK RD. RUSHES CREEK NSW 2346 DATE: 05/05/2022 21-166 A100
Figure 3 Conceptual Design – SCR Units for the 440 kVA Generators
Page 11
Figure 4 Conceptual Design ‐ SCR Unit for the 45 kVA Generator
Page 12
3 SUMMARY OF SUBMISSIONS
Submissions in relation to Modification 3 at the Rushes Creek poultry farm were received from the
following government agencies:
 DPE;
 EPA;
 Transport for NSW (TfNSW);
 DPE Water;
 WaterNSW;
 Tamworth Regional Council (Council); and
 Gunnedah Shire Council (GSC).
These submissions are listed and summarised in Table 5. None of the submissions objected to the
proposed modification, but rather raised concerns/issues and made requests in terms of additional
information, amendments and/or approval conditions.
Table 5 Summary of Submissions
Issue / Request
Operation Schedule
Management Plans
and Contingencies
Dead Bird Freezer
Strategic Context
Water Licensing
Construction /
Diesel Storage
Consultation
Community
Generators
Air Quality
Submission
Noise
Source
DPE X X X X X X
EPA X X X X
TfNSW X
DPE Water X X
WaterNSW X X
Council X X
GSC X X
TOTAL 3 1 1 5 1 1 2 2 1 2
The most common issues raised are in relation to diesel storage, the strategic context and contingencies
for the modification, air quality, noise, and construction/operational management plans.
The matters raised in the submissions have been grouped and addressed in this Submissions Report by
“issue” (rather than on an individual stakeholder/agency basis) to minimise repetition. Where similar
issues were raised by more than one agency, the responding information has been consolidated to allow
a single all‐encompassing response in‐line with the State Significant Development Guidelines (DPIE 2021).
The responses provided in this Submissions Report were prepared by ProTen and EME, with input and
additional assessment from specialist consultants in relation to traffic, noise and fire safety/hazards.
Page 13
4 RESPONSE TO SUBMISSIONS
4.1 Strategic Context and Contingencies
DPE recommended that Modification 3 be amended to also include the off‐grid power solution so the
assessment to modify the farm’s operational power requirements can be assessed holistically.
Alternatively, DPE requested that further justification be provided on how Modification 3 promotes
orderly development in accordance with the EP&A Act and further details be provided on proposed
contingencies in the event that the assessment process for the off‐grid power solution takes longer than
anticipated and/or approval of the off‐grid power option is not granted at all.
Council expressed the preference for the future off‐grid power option to form part of Modification 3 or
a concurrent application given that there has not been information provided on the timeframe for the
off‐grid option or contingency if the off‐grid option is not approved. Council recommended a consent
condition for Modification 3 limiting the use of the generators as the primary power source to a period
of no more than 12 months.
GSC requested that the modification include details of how electrical services will be provided to Farm
2 and the water supply pump upon cessation of the period of generator power. GSC also advised that
the assessment “should not consider the provision of power as the electrical power sources as this
should be subject to a separate development consent and there is no certainty that the development
consent will be granted and construction undertaken”.
The EIS (2018) was prepared based on all operational power requirements being met by solar panels and
connection to Essential Energy’s reticulated electricity supply network, which would require extension of
Essential Energy’s overhead supply infrastructure approximately 17 kilometres (km) from Manilla.
However, given the substantial energy demands of a large‐scale poultry farm and the costs and emissions
associated with reticulated non‐renewable electricity, ProTen commenced investigating the viability of
taking the development completely off‐grid and powering it with a renewable power system comprising
solar panels and battery storage. These investigations took longer than anticipated with several solar
companies putting forward different design options and cost models. ProTen is now working with the
selected solar company to optimise and finalise the renewable power solution. Optimising the design is
critical in terms of ensuring sufficient and cost‐effective solar power, sufficient battery storage, and
reduced generator requirements (for example, during overcast/rain days and overnight in peak periods).
While combining Modification 3 with the off‐grid renewable power solution would have been preferred,
it was not possible given the protracted time it is taking to optimise and finalise the system design and
ProTen’s contractual obligation with Baiada to commence bird production. There is also a significant lead
time for required components, particularly the solar panels and battery. As such, Modification 3 has been
put forward in order to:
 Allow development optimisations that will deliver long‐term operational efficiencies and benefits
at Farm 2;
 Enable early commencement of operations at Farm 2 while construction is on‐going to meet supply
contracts and market demand; and
 Enable operational power requirements of Farm 2 to be met via diesel generators for up to 12
months while the off‐grid renewable power solution is finalised, approved and commissioned.
ProTen endeavours to reduce energy consumption at all their poultry operations. As research and
development identifies areas where energy efficiency can be improved, ProTen implements appropriate
upgrades/changes where practicable.
Page 14
Modification 3 will provide additional time for ProTen to secure the off‐grid solar solution in terms of
design, approval, materials supply, installation and commissioning. If this occurs, the poultry farm will be
powered by renewable energy, which will deliver notable environmental benefits associated with:
 Avoiding the need to extend Essential Energy’s overhead supply infrastructure approximately 17
km from Manilla to the Development Site through various privately‐owned properties and public
lands to the Development Site;
 Reducing reliance on non‐renewable electricity sourced from coal‐fired power stations; and
 Reducing greenhouse gas emissions and associated impacts.
There are two primary contingencies in the event that the off‐grid solar power system is not approved or
not approved in a timeframe that allows installation and commissioning prior to the end of the 12 month
period:
(a) Proceed with the originally planned reticulated electricity supply via the extension of Essential
Energy’s overhead infrastructure from Manilla to the Development Site. ProTen is continuing to
engage with Essential Energy and undertake the necessary activities to ensure this option remains
available. In accordance with the letter in Appendix E, Essential Energy has confirmed that the
connection agreement has been extended until October 2023.
(b) ProTen would completely destock and not place another batch until:
(i) The solar system had been approved, installed and commissioned; OR
(ii) The originally planned reticulated electricity supply (as per (a) above) had been installed and
commissioned.
DPE has the ability to manage any perceived risk via the ability to impose conditions on the modification
proposal. However, given the maximum 12 month period of generator power proposed, the minimal
environmental impacts predicted, the addition of fully‐engineered SCR NOx abatement systems, and the
above contingencies, the potential impacts/risks associated with Modification 3 will be short‐term and
minor in comparison to what has previously been assessed and approved.
Modification 3 will provide additional time for ProTen to secure a long‐term renewable power supply for
the poultry farm, which will in turn reduce reliance on coal‐fired power stations and deliver notable
environmental benefits, while also enabling commencement of operations to fulfill supply contracts and
assist in meeting the current and foreseeable strong demand for poultry meat in the Australian market.
On this basis, Modification 3 does promote the “orderly and economic use and development of land” and
appears justified on environmental, economic and social grounds.
4.2 Water Licensing
DPE Water requested that the relevant nomination of work dealing applications for water access
licences proposed to account for water take by the poultry farm have been completed prior to the water
take occurring.
This is not directly related to the scope of Modification 3, however it is noted.
The dealings issued by WaterNSW under section 71W of the Water Management Act 2000 for ProTen’s
water access licences (WAL 37794 and WAL 41834) were registered by NSW Land Registry Services on 2
February 2022. The dealings nominate the water supply work (i.e. pump) covered by the miscellaneous
works number (90MW833079) issued by the Natural Resources Access Regulator (NRAR) for water
extraction.
Page 15
4.3 Updated Concurrent Construction and Operations Timing
DPE requested an updated construction/operation schedule as part of the Submissions Report
As detailed in the Modification Report, the modification seeks to allow concurrent construction and
operation at Farm 2 for up to 10 months. Due to unforeseen delays to the construction program
associated with on‐going wet weather and Covid‐19 restrictions/cases within the construction workforce,
the timing for construction and operational activities has been delayed.
The updated overall development staging and the updated indicative timing for Stage 1 (i.e. Farm 2 and
associated ancillaries) construction and operational activities are provided in Section 2.2.3. A period of
up to 10 months is still proposed for concurrent construction and operations at Farm 2, and this period is
anticipated to commence in July 2022.
There are no implications in relation to site access or traffic associated with the delayed construction

program and delayed commencement of operations at Farm 2. The change is merely delayed timing.
SLR’s response report in Appendix B confirms that the proposed delay to concurrent construction and
operation activities at Farm 2 is not significant from a traffic engineering perspective and will not result in
any new traffic impacts beyond that previously assessed. Furthermore, Global Acoustics’ response report
in Appendix C advises that this amendment is not significant in terms of predicted construction, operation
and road traffic noise impacts.
4.4 Diesel Storage
4.4.1 Water Pump Diesel Storage
WaterNSW does not support the proposed diesel storage tank at the Namoi River water pump site and
notes that refuelling of the generator is possible using diesel delivered to and stored at Farm 2 instead.
DPE raised concerns in relation to the location of the diesel storage tank in relation to flooding levels
and also the nearby area mapped as containing White Box ‐ White Cypress Pine ‐ Silver‐leaved Ironbark
grassy woodland.
Council and GSC noted that the diesel tank should be located outside of any flood prone land.
Responding to these concerns, and as advised in Section 2.2.2, the proposed modification no longer
includes the 2,000 L bunded diesel storage tank at the water supply pump near the Namoi River. As
suggested by WaterNSW, ProTen will instead cart diesel from the approved storage at Farm 2 using a fuel
trailer towed by a light vehicle (for example, ute or four‐wheel drive) to refill the diesel generator at the
Namoi River water supply pump as required.
During the initial period of up to 12 months when Farm 2 and the water supply pump are proposed to be
powered using diesel generators, it is anticipated that the water supply pump generator will require
refuelling in peak times (for example, in hot conditions with all shed ventilation/cooling systems running)
every 1 to 2 days. SLR’s Modification 3 Traffic Assessment (2021a), which was prepared as part of the
Modification Report (EME 2022), conservatively assessed up to two light vehicle movement daily between
Farm 2 and the river water pump site. On this basis, and as confirmed in SLR’s response report in
Appendix B, the impacts of this proposed change to the scope of Modification 3 have already been
assessed and no further assessment is warranted.

Page 16
4.4.2 Bunding
EPA recommended the following additional EPL condition –
All above ground storage facilities containing flammable and combustible liquids must be bunded in
accordance with the specifications of the relevant Australian Standard and legislative requirements.
Noted. The approved Summary of Commitments for the poultry farm development lists the specific
commitments for chemical and fuel storages, including diesel.
4.5 Generators
EPA recommended the following additional EPL condition –
The licensee must not operate more than two 440 kVA diesel generators at Farm 2 at any one time.
Noted. The Modification Report clearly states that there will only ever be two of the proposed 440 kVA
generators operating at any one time at Farm 2.
EPA noted that the primary concern with diesel generators is the emission of NOX. EPA further noted
that the predicted ground level NOX concentrations are all below the limits specified in the Clean Air
Regulation and criteria specified in the Approved Methods.
initial 12 month period, the NOX limits in Schedule 4 of the Clean Air Regulation will apply. As such, the
EPA recommended the following additional EPL condition ‐ Any diesel generator that operates for 200
hours or more per year must comply with the NOX emission limits specified in Schedule 4 of the POEO
(Clean Air) Regulation 2021.
The generators proposed at Rushes Creek are classed as “stationary reciprocating internal combustion
engines” and, pursuant to sub‐clause 33(1)(f) of the Clean Air Regulation, they belong to Group 6. As such,
the applicable NOx concentration limit is 450 mg/Nm3.
As detailed in Section 2.2.5, ProTen has commissioned ECI to design and manufacture specific SCR units
for two of the 440 kVA generators and the 45 kVA generator (i.e. one SCR unit for each generator that will
operate more than 200 hours per year in the initial 12 month operational period) to meet the 450 mg/Nm3
NOx limit over the proposed 12 month period (after this time the generators will revert to their intended
purpose of standby emergency generators and, pursuant to clause 59 of the Regulation, will be exempt
from the NOX concentration limits in Schedule 4 as they will operate not more than 200 hours per year).
The information provided in Section 2.2.5 and Appendix A should be referred to for further information.

Page 17
4.6 Dead Bird Freezers
WaterNSW requested that bunding of the relocated dead bird freezers be considered given it is outside
of the diversion swale and any contaminated runoff occurring in the event of power loss and thawing
of contents would not be collected in the detention dam.
The proposed modification includes relocating the dead bird freezers from the front of the Development
Site adjacent to Rushes Creek Road to closer to Farm 2 to achieve electrical design efficiencies and reduce
initial establishment costs. ProTen does not believe that bunding of the freezers is warranted and
requests that it not be imposed as a condition of the modification. The following should be noted:
 There was no previous requirement to bund the freezers or provide emergency back‐up power to
the freezers in their currently approved position adjacent to Rushes Creek Road. The relocation of
the freezers closer to Farm 2 does not bring any additional risk for freezer operations.
 Relocating the freezers closer to Farm 2 and connecting the freezers to the Farm 2 power supply
system will ensure that they have emergency back‐up power via the Farm 2 diesel generators – two
primary backup generators and two secondary backup generators. This will reduce the risk for
freezer operations.
 The dead bird freezers are used for short‐term storage only, with the dead birds being collected
and transported off‐site to Baiada’s Oakburn rendering plant every 1 to 2 days.
4.7 Air Quality
DPE believes that Astute’s conclusion that the air quality emissions are predicted to comply with the
relevant air quality criteria is inconsistent with sections 5.2 and 5.3 of Astute’s report which state that
the predicted annual average concentrations for PM2.5 and PM10, including background (cumulative),
are predicted to be in non‐compliance with the criteria at all sensitive receptors due to the elevated
background concentrations being above the EPA’s criteria. DPE requested justification as to why these
non‐compliances are considered acceptable.
The specialist air quality assessment (Astute 2021) for the modification proposal and the Modification
Report (EME 2022) explained this very clearly. To reiterate ‐ air quality during 2019 (i.e. the selected
“representative year”) was affected by intense drought conditions and widespread bushfires. However,
as this year was selected as the most appropriate year for meteorological data in accordance with the
Approved Methods (EPA 2016), the influence of the drought and bushfire conditions on background air
quality was unavoidable. It is obvious from the statistical summary for 2019 in Table 6 that the recorded
background values for PM10 and PM2.5 are at or well above the EPA’s respective assessment criterion.
Table 6 Background Air Quality Data 2019
Monitoring Data Averaging Value Assessment
Pollutant Statistic
Site Availability Period (μg/m3) Criteria (μg/m3)
24‐hour Maximum 205.2 50
PM10 Gunnedah 92%
Annual Average 24.9 25
24‐hour Maximum 94.1 25
PM2.5 Gunnedah 95%
Annual Average 11.4 8
Page 18
While the 2019 background concentrations are unrealistic, in that they are higher than under normal
years/conditions due to the intense drought conditions and widespread bushfires, Astute (2021) was
required to use them in accordance with the Approved Methods (EPA 2016). So, background PM10 and
PM2.5 values were exceeding the assessment criteria even before including the additional emissions
associated with the approved Rushes Creek poultry farm development and the proposed Modification 3.
As such, Astute’s (2021) assessment focused on no additional exceedances of the criteria, and this was
readily demonstrated by Astute. Notably, the EPA did not query this approach or Astute’s modelling
results and conclusions.
EPA noted that the primary concern with diesel generators is the emission of NOX. EPA further noted
that the predicted ground level NOX concentrations are all below the limits specified in the Clean Air
Regulation and criteria specified in the Approved Methods.
initial 12 month period, the NOX limits in Schedule 4 of the Clean Air Regulation will apply. As such, the
EPA recommended the following additional EPL condition ‐ Any diesel generator that operates for 200
hours or more per year must comply with the NOX emission limits specified in Schedule 4 of the POEO
(Clean Air) Regulation 2021.
See Sections 2.2.5 and 4.5, and Appendix A.
4.8 Noise
DPE noted that Global Acoustics’ noise assessment for Modification 3 did not include an assessment of
sleep disturbance and requested that this be addressed in the Submission Report.
Global Acoustics’ response report (2022) in Appendix C advises that the only significant change to
operation noise as a result of Modification 3 is the use of diesel generators for a period of up to 12 months.
These diesel generators were added to the worst‐case operational noise scenario and modelled for
neutral and enhancing atmospheric conditions, with the results included in Global Acoustics’ original
assessment report for Modification 3 (2021). While the generators did result in minor increases to
predicted operational noise levels, all levels complied with the night period criterion of 35 dB. It is worth
noting that this scenario is conservative given it includes the noise sources from Farms 1 to 4, even though
Farms 1, 3 and 4 will not be operational over the 12 month period of proposed generator power.
Given that operational noise levels, including the diesel generators, are predicted to comply with the night
period criterion of LAeq 35 dB, and there are no other proposed changes to night‐time operations and
activities, sleep disturbance impacts are also predicted to comply with the sleep disturbance criterion of
LAmax 45 dB (Global Acoustics 2022).
DPE noted that the criterion adopted by Global Acoustics for the concurrent construction and
operational scenario is the construction criterion of LAeq15min 40 dB. DPE requested that a
justification be provided for using the construction criterion to assess compliance for this scenario as
opposed to the more stringent operational criterion of LAeq15min 35 dB.
Firstly, it is important to note that construction activities will occur during standard construction hours
(i.e. day period). Global Acoustics’ response report (2022) in Appendix C advises that construction noise
was assessed against the minimum noise affected management level of 40 dBA, with no predicted
exceedances, and whole farm operations were assessed against the minimum night period intrusiveness
criterion of 35 dBA, with no predicted exceedances.
Page 19
Commencement of operations while construction is on‐going allows a small number of poultry sheds at
Farm 2 to be productive while other areas of Farm 2 are still under construction. Global Acoustics’
cumulative assessment showed that the predicted noise levels from full farm operation combined with
construction activities are lower than the minimum construction noise affected management level of 40
dBA.
Outside of standard construction hours, Global Acoustics’ predicted that operational noise levels will
comply with the minimum night period intrusiveness criterion of 35 dBA, with no predicted
exceedances. This has not changed as a result of Modification 3.
It is important to note the following conservatisms within Global Acoustics’ assessment:
 Modification 3 relates to approximately one third of the development (i.e. Stage 1 – Farm 2),
whereas the noise modelling included the noise sources from the entire development (i.e. Stages 1
and 2 – Farms 1 to 4) even through Farms 1, 3 and 4 will not be constructed or operational for some
time (certainly not within the proposed 10 month period of concurrent construction and operation,
and not within the proposed 12 month period of generator power). As such, the combined noise
levels are expected to be significantly lower than the predictions provided in the noise assessment.
 The minimum day period intrusiveness criterion in accordance with the EPA’s Noise Policy for
Industry (2017) is 40 dBA. The 35 dBA criterion adopted by Global Acoustics for day period
operations stems from their original assessment prepared for the EIS under the now superseded
Industrial Noise Policy (2000).
EPA recommended the following additional EPL condition:
M8 Requirement to Monitor Noise
M8.1 Attended noise monitoring must be undertaken in accordance with Condition 3.4 and must:
a) occur at receptors R24 and R25 as identified in Figure 3 of ‘Rushes Creek Poultry Production Farm –
SSD 7704 – Modification 3 – Modification Report’ (EME Advisory, January 2022) and
b) occur within 10 days of operations commencing at Farm 2 and
c) occur while concurrently operating two 440 kVA generators at Farm 2 and
d) occur during the night period as defined in the Noise Policy for Industry for a minimum of 1 hour
during the night.
The following two points are raised in relation to the EPA’s requested attended noise monitoring:
(1) There will likely only be 8 poultry sheds operating during the first 10 days of operation and, as such,
only one of the 440 kVA generators operating.
(2) Global Acoustics has verbally advised that noise intrusiveness is assessed over a 15 minute period (as
opposed to a 1 hour period) in accordance with the EPA’s Noise Policy for Industry (2017) and diesel
generators are a continuous noise source. If attended monitoring is specifically required to assess
noise impacts associated with the diesel generators, a 15 minute measurement at the two receptor
locations is sufficient. ProTen requests that the monitoring requirement be amended to a minimum
of 15 minutes during the night.

Page 20
4.9 Community Consultation
DPE noted that the Community Newsletter dated October 2021 had not been uploaded to the ProTen
Rushes Creek development webpage and reminded ProTen to ensure all documentation required by
the development consent is made available to the public on the webpage.
ProTen apologises for this oversight and confirms that the Community Newsletter dated October 2021
was uploaded to the Rushes Creek development webpage on 7 February 2022. There have not been any
further feedback/queries received by ProTen in response to the newsletter, including current construction
activities and the proposed modification.
An additional Community Newsletter will shortly be distributed to surrounding residents and recreation
facilities and uploaded on ProTen’s development webpage providing a development update, including the
status of Modification 3 and the updated construction and operations scheduling.
4.10 Management Plans
TfNSW noted that the development consent includes appropriate conditions to manage access and
driver behaviour and requested that the approved management plans be updated where relevant to
address the modification.
The Assessment of Traffic Matters (SLR 2021) concluded that the traffic engineering implications of
Modification 3 will be minor and only for a short‐term period. Regardless, relevant management plans,
including the Construction Traffic Management Plan (SLR 2021b) and Operational Driver Code of Conduct
(SLR 2021c), will be reviewed and, if necessary, updated to cover Modification 3.
DPE Water requested that the Construction Environmental Management Plan (CEMP) and the
Operational Environmental Management Plan (OEMP) be updated to address the modification.
The previously approved CEMP (EME 2021c) will be reviewed and, if necessary, updated to cover
Modification 3.
The OEMP is currently being prepared and will be submitted to DPE for approval prior to commencing any
operational activities. The OEMP will cover Modification 3.

Page 21
5 CONCLUSION
Submissions from seven State and local government agencies were received following assessment of the
Modification Report (EME 2022) for the latest modification proposal to the Rushes Creek poultry
production farm development (Modification 3). None of the submissions objected to the proposed
modification, but rather raised concerns/issues and made requests in terms of additional information,
amendments and/or approval conditions. The most common issues raised were in relation to diesel
storage, the strategic context and contingencies for the modification, air quality, noise, and
construction/operational management plans.
This Submission Report responds to the issues raised within these submissions. The responses provided
were prepared by ProTen and EME, with input and additional assessment work from specialist consultants
in relation to traffic, noise and fire safety/hazards.
Modification 3 remains as described in the Modification Report (EME 2022), with the exception of some
minor amendments in response to delays to the construction timeline, delays to the design of the future
renewable power solution, and issues/requests raised by consulted government agencies. These minor
amendments, which are described in Section 2.2, do not pose any material environmental impacts. Some
of the amendments will in fact deliver positive environmental outcomes (in comparison to the original
scope of the modification) associated with removing the originally proposed diesel storage tank at the
Namoi River and treating NOx emissions from diesel generators via specifically designed SCR units.
The detailed information presented in the Modification Report (EME 2022) and this Submissions Report
demonstrates that Modification 3 poses a low risk to the local environment and surrounding populace.
While there will be some implications for air emissions, noise emissions and traffic generation, these will
be short‐term and are predicted to be minor in comparison to what has previously been assessed and
approved.

Page 22
6 REFERENCES
Astute Environmental Consulting (2021) Rushes Creek – Modification 3 Diesel Generator Air Quality Assessment
EME Advisory (2019a) Rushes Creek Poultry Production Farm, SSD 7704, Response to Submissions
EME Advisory (2019b) Rushes Creek Poultry Production Farm, SSD 7704, Supplementary Response to
Submissions
EME Advisory (2021a) Rushes Creek Poultry Production Farm, SSD 7704, Section 4.55(1A) Modification Report
EME Advisory (2021b) Rushes Creek Poultry Production Farm SSD 7704, Modification Report – Condition B53(a)
EME Advisory (2021c) Rushes Creek Poultry Production Farm, Development Consent SSD 7704, Stage 1
Construction Environmental Management Plan
EME Advisory (2022) Rushes Creek Poultry Production Farm, Development Consent SSD 7704, Modification 3 ‐
Modification Report
Environment Protection Authority (2016) Approved Methods for the Modelling and Assessment of Air
Pollutants in NSW
Environment Protection Authority (2017) Noise Policy for Industry
GHD (2022) CAN03: Addendum to Fire Safety Study, Rushes Creek Poultry Production Farm
Global Acoustics (2021) Rushes Creek Poultry Production Complex, Modification 3 to Development Consent SSD
7704
Global Acoustics (2022) ProTen Rushes Poultry Production Complex, Modification 3 to Development Consent
SSD 7704 submissions response
Department of Planning, Industry and Environment (2021) State Significant Development Guidelines
SLR Consulting Australia (2018) Rushes Creek Poultry Production Farm, SSD 7704, Environmental Impact
Statement
SLR Consulting Australia (2021a) Rushes Creek Poultry Production Farm, Modification 3 Traffic Assessment
SLR Consulting Australia (2021b) Construction Traffic Management Plan, Rushes Creek Poultry Production Farm
SLR Consulting Australia (2021c) Operational Driver Code of Conduct, Rushes Creek Poultry Production Farm
SLR Consulting Australia (2022) Rushes Creek Poultry Production Farm, Modification 3 Scope Changes,
Assessment of Traffic Engineering Matters

Page 23
7 ABBREVIATIONS
Approved Methods Approved Methods for the Modelling and Assessment of Air Pollutants in NSW
Astute ` Astute Environmental Consulting
CEMP Construction Environmental Management Plan
Clean Air Regulation Protection of the Environment Operations (Clean Air) Regulation 2021
Council Tamworth Regional Council
dB decibel
DPE Department of Planning and Environment
DPIE (former) Department of Planning, Industry and Environment
ECI Exhaust Control Industries Australia
EIS Environmental Impact Statement
EME EME Advisory
EPA Environment Protection Authority
EPL Environment Protection Licence
EP&A Act Environmental Planning and Assessment Act 1979
GSC Gunnedah Shire Council
km kilometre
kVA kilovolt amp
L litre
LAeq A‐weighted equivalent/average noise level
LAmax A‐weighted maximum noise level
3
mg/Nm milligrams per normal cubic metre
NOx nitrogen oxides
OEMP Operational Environmental Management Plan
PM2.5 particulate matter less than 2.5 microns in diameter
PM10 particulate matter less than 10 microns in diameter
POEO Act Protection of the Environment Operations Act 1997
PPU poultry production unit
ProTen ProTen Tamworth Pty Limited
RTS Response to Submissions
SCR Selective catalytic reduction
SLR SLR Consulting Australia
SSD State significant development
TfNSW Transport for NSW
μg/m3
Micrograms per cubic metre
USEPA United States Environmental Protection Agency
WAL water access licence

Page 24
Appendix A
Information for SCR

Units and Urea Storage
Leading the way in
SCR NOx abatement
Exhaust Control Industries Air and noise pollution control specialists
Exhaust Control Industries
The leading SCR experts
Over the past 20 years, ECI has led the way in Selective Catalytic
Reduction (SCR) NOx Abatement Systems in Australia and around
the world.
Current and future Co-generation and Tri-generation building projects that
feature the ECI Selective Catalytic Reduction (SCR) System and Oxidation
Catalyst continue to set the industry benchmark for both business and
environmental sustainability. ECI’s constant testing, research and development
ensures cutting-edge design and maximum reduction in harmful pollutants
into the lower atmosphere, thus reducing smog.

Co-generation and Tri-generation
power for energy efficiency
Co-generation (or CHP - Combined Heat With the ever-increasing need for power
and Power) is the use of an engine or power generation, coupled with stringent air policy
station to simultaneously generate electricity regulations, the SCR system for NOx abatement is
and useful heat. Tri-generation (or CCHP - widely used in large power stations and process
Combined Cooling, Heat and Power) refers to the plant applications around the world.
simultaneous generation of electricity and useful
The ECI SCR System
heating and cooling.
SCR is a post-combustion control technology
Co-generation is a thermodynamically efficient
capable of reducing NOx emissions by 80-95+
use of fuel. In separate production of electricity,
percent. The ECI SCR system selectively reduces
some energy must be discarded as waste heat,
NOx by combining liquid Urea/Ammonia (NH3)
but in Co-generation this thermal energy is put
and Oxygen (02), with NOx in the exhaust gas,
to use. All thermal power plants emit heat during
in the presence of a catalyst to form molecular
electricity generation, which can be released into
nitrogen (N2) and water (H20).
the natural environment through cooling towers,
flue gas, or by other means. SCR, in conjunction with various oxidation catalyst
options, produces beneficial and accountable
Emissions (NOx) Treatment NOx, CO (Carbon Monoxide), VOC (Volatile
The emissions from these power stations or Organic Compounds) and PM (Particulate Matter)
engines typically contain NOx. NOx is a generic emission reductions.
term for mono-nitrogen oxides NO and NO2
ECI SCR System Components
(nitric oxide and nitrogen dioxide). They are
produced from the reaction of nitrogen and A typical SCR system is composed of
oxygen gases in the air during combustion, • Reactor housing with catalyst material for
especially at high temperatures. NOx reduction
In the lower atmosphere, NOx combines with • Optional Oxidation Catalyst / Predator
reactive organic gases in the presence of sunlight Particulate Catalyst (diesel engines)
to form ground-level ozone, which is the primary • Injection and mixing unit
component of urban smog. In addition, nitric
• Urea metering unit
oxide and nitrogen dioxide are components of
• Continuous Emission Monitoring System
acid rain, which is a significant problem in the
(CEMS); OR
northern hemisphere.
• Predictive Emission Monitoring System
The ECI Australia SCR for NOx Abatement System
(PEMS) option
is capable of reducing NOx emissions by over
95 percent. Over the past 40 years, the fitting of • Urea storage tank and accessories.
this post-combustion NOx control system on both In addition, the system can be integrated with a
diesel and gas fired engines and turbines has BMS via a modbus port and offer 24 hour remote
resulted in major reductions in NOx in our urban access and data logging.
environments.
ECI Oxidation Catalyst
The addition of an Oxidation Catalyst onto an SCR

Benefits of Selective Catalytic Reduction
NOx Abatement System will further reduce levels
• Long catalyst life
of CO (Carbon Monoxide), hydrocarbon and VOC
(Volatile Organic Compounds) emissions by up • System design flexibility for marine, rail and
to 80-90 percent. plant applications
Time of fuel dispensation, peak pressures, • Broad temperature range from 285ºC to
combustion and exhaust temperatures all affect 520ºC
NOx formation. Typically there is an inverse • Compatible with various fuel types, which
relationship between the formation of NOx and includes contaminated fuels with up to 3.5%
CO. Higher combustion temperature and sulphur
pressure levels, which are often conducive to • Process guarantees
NOx formation, tend to be out of the range of ideal
• Ongoing maintenance and emissions
CO forming conditions.
testing services
If the temperature conditions within the exhaust
• Urea supply
system cool (i.e. with the use of a Chiller),
• Remote access to PLC controls
NOx emissions come down slightly, but CO,
hydrocarbons and VOCs may rise. Therefore, to • Technical training & engineering manuals.
concurrently meet BACT (Best Available Control
Technology) emission levels for CO, hydrocarbons
and VOCs, the utilisation of an Oxidation Catalyst
is required.
Further treatment can be applied by diesel
fuel applications, that is, with the addition of
Particulate Filters that provide particulate matter
(i.e. soot) reductions of up to 95 percent. These
Particulate Filters oxidize the particulate matter
to offer an environmentally sustainable option for
diesel fuel applications.
Why use the SCR NOx Abatement System
and Oxidation Catalyst?
In June 2012, the International Agency for
Research on Cancer (part of the World Health
Organisation) updated diesel engine exhaust
to the classification ‘carcinogenic to humans
(Group 1)’. This is the highest classification and
indicates that diesel exhaust damages the DNA,
or genetic material in body cells in a way that
leads to cancer. The Group 1 classification places
diesel exhaust alongside toxins such as asbestos,
benzene, formaldehyde and arsenic.
Exposure to diesel exhaust can have immediate
harmful health effects. Those most vulnerable
are children whose lungs are still developing and Green Square North Tower, Gas Powered Generator, Brisbane
the elderly who may have other existing health
problems.
ECI customise emissions treatment
The following substances are present in solutions for all types of applications
diesel exhaust: including:
• Ozone (precursors, NOx and VOC) • Heavy transport
Effects: eye and respiratory irritants, asthma
• Food and beverage
exacerbation, bronchitis and irreversible lung
• Data and communication centres
damage.
• Industrial
• Oxides of nitrogen
Effects: respiratory irritant, immunosuppressant • Health
and asthma exacerbation. • Construction
• Carbon monoxide • Mining
Effects: headaches, irritability, impaired • Power generation, including:
judgement and memory, breathlessness, – Standby power
aggravation of angina and other cardiovascular – Emergency power, and
diseases, developmental toxicity and death. – Community power.
• Particulate matter (i.e. soot)
Effects: Respiratory irritant with higher levels ECI can help provide a safer workplace
associated with increased incidence of for your employees and a cleaner world
cardiovascular and lung failure. for us all.
Pictured Green Square North Tower project, Brisbane Australia.
ECI worked with Leighton Contactors to achieve a 6 Star Green Star rating. ECI’s customised design
met plant room requirements as well as stringent Brisbane City Council air policy regulations.
Exhaust Control Industries

Air and noise pollution control specialists
ECI is the leader in Co-generation and SCR technology in Australia.

Our air and noise pollution control products include Silencers, Diesel Particulate Filters,
Diesel Particulate Catalysts, Catalytic Purifiers, Waste Heat Recovery Systems and
Acoustic Enclosure Products.
ORIGINATION CRM ECI 114 0814
Exhaust Control Industries Pty Ltd Air and noise pollution control specialists
31-33 Fonceca Street, Mordialloc, Victoria, 3195 Australia
Ph 1800 730 158 +61 3 9588 2233 Fax +61 3 9588 2567 www.exhaustcontrol.com.au ABN 60 606757724
M e l b o u r n e • S y d n e y • B r i s b a n e • A s i a P a c i f i c
SCR 40
AUSblue Pty Ltd Chemwatch Hazard Alert Code: 1
Chemwatch: 4886-46 Issue Date: 15/11/2016

Version No: 3.1.1.1 Print Date: 16/11/2016
Safety Data Sheet according to WHS and ADG requirements S.GHS.AUS.EN
SECTION 1 IDENTIFICATION OF THE SUBSTANCE / MIXTURE AND OF THE COMPANY / UNDERTAKING
Product Identifier
Product name SCR 40
Other means of
Not Available
identification
Relevant identified uses of the substance or mixture and uses advised against
Relevant identified Use according to manufacturer's directions.
uses Used for NOx reduction in exhaust gases from vehicles with diesel engines.
Details of the supplier of the safety data sheet

Registered company
AUSblue Pty Ltd
name
Address PO Box 5386 Brassall QLD 4306 Australia
Telephone 1300 AUS BLUE (1300 287 258)
SECTION 2 HAZARDS IDENTIFICATION
Classification of the substance or mixture
NON-HAZARDOUS CHEMICAL. NON-DANGEROUS GOODS. According to the WHS Regulations and the ADG Code.
Poisons Schedule Not Applicable
Classification Not Applicable
Label elements
GHS label elements Not Applicable
SIGNAL WORD NOT APPLICABLE
Hazard statement(s)
Continued...
Chemwatch: 4886-46 Page 2 of 9 Issue Date: 15/11/2016
SCR 40
Not Applicable
Precautionary statement(s) Prevention

Not Applicable
Precautionary statement(s) Response

Not Applicable
Precautionary statement(s) Storage

Not Applicable
Precautionary statement(s) Disposal

Not Applicable
SECTION 3 COMPOSITION / INFORMATION ON INGREDIENTS
Substances
See section below for composition of Mixtures
Mixtures
CAS No %[weight] Name
57-13-6 40 urea
7732-18-5 60 water
SECTION 4 FIRST AID MEASURES
Description of first aid measures

If this product comes in contact with eyes:
Wash out immediately with water.
Eye Contact
If irritation continues, seek medical attention.
Removal of contact lenses after an eye injury should only be undertaken by skilled personnel.
If skin contact occurs:
Immediately remove all contaminated clothing, including footwear.
Skin Contact
Flush skin and hair with running water (and soap if available).
Seek medical attention in event of irritation.
If fumes, aerosols or combustion products are inhaled remove from contaminated area.
Inhalation
Other measures are usually unnecessary.
Immediately give a glass of water.

Ingestion
First aid is not generally required. If in doubt, contact a Poisons Information Centre or a doctor.
Indication of any immediate medical attention and special treatment needed

Treat symptomatically.
SECTION 5 FIREFIGHTING MEASURES
Extinguishing media
The product contains a substantial proportion of water, therefore there are no restrictions on the type of extinguishing media which may be used. Choice
of extinguishing media should take into account surrounding areas.
Though the material is non-combustible, evaporation of water from the mixture, caused by the heat of nearby fire, may produce floating layers of
combustible substances.
In such an event consider:
foam.
dry chemical powder.
carbon dioxide.
Special hazards arising from the substrate or mixture

Fire Incompatibility None known.
Advice for firefighters

Alert Fire Brigade and tell them location and nature of hazard.
Wear breathing apparatus plus protective gloves in the event of a fire.
Fire Fighting Prevent, by any means available, spillage from entering drains or water courses.
Use fire fighting procedures suitable for surrounding area.
DO NOT approach containers suspected to be hot.
Continued...
SCR 40
Cool fire exposed containers with water spray from a protected location.
If safe to do so, remove containers from path of fire.
Equipment should be thoroughly decontaminated after use.
,,,
Non combustible.
Not considered to be a significant fire risk.
Expansion or decomposition on heating may lead to violent rupture of containers.
Decomposes on heating and may produce toxic fumes of carbon monoxide (CO).
Fire/Explosion Hazard
May emit acrid smoke.
Decomposition may produce toxic fumes of:
carbon dioxide (CO2)
nitrogen oxides (NOx)
other pyrolysis products typical of burning organic material.
HAZCHEM Not Applicable
SECTION 6 ACCIDENTAL RELEASE MEASURES
Personal precautions, protective equipment and emergency procedures

See section 8
Environmental precautions
See section 12
Methods and material for containment and cleaning up

Clean up all spills immediately.
Avoid breathing vapours and contact with skin and eyes.
Control personal contact with the substance, by using protective equipment.
Minor Spills
Contain and absorb spill with sand, earth, inert material or vermiculite.
Wipe up.
Place in a suitable, labelled container for waste disposal.
Minor hazard.
Clear area of personnel.
Alert Fire Brigade and tell them location and nature of hazard.
Control personal contact with the substance, by using protective equipment as required.
Prevent spillage from entering drains or water ways.
Major Spills
Contain spill with sand, earth or vermiculite.
Collect recoverable product into labelled containers for recycling.
Absorb remaining product with sand, earth or vermiculite and place in appropriate containers for disposal.
Wash area and prevent runoff into drains or waterways.
If contamination of drains or waterways occurs, advise emergency services.
Personal Protective Equipment advice is contained in Section 8 of the SDS.
SECTION 7 HANDLING AND STORAGE
Precautions for safe handling

Limit all unnecessary personal contact.
Wear protective clothing when risk of exposure occurs.
Use in a well-ventilated area.
When handling DO NOT eat, drink or smoke.
Safe handling Always wash hands with soap and water after handling.
Avoid physical damage to containers.
Use good occupational work practice.
Observe manufacturer's storage and handling recommendations contained within this SDS.
DO NOT allow clothing wet with material to stay in contact with skin
Store in original containers.
Keep containers securely sealed.
Store in a cool, dry, well-ventilated area.
Other information
Store away from incompatible materials and foodstuff containers.
Protect containers against physical damage and check regularly for leaks.
Observe manufacturer's storage and handling recommendations contained within this SDS.
Conditions for safe storage, including any incompatibilities

Polyethylene or polypropylene container.
Suitable container Packing as recommended by manufacturer.
Continued...
SCR 40
Check all containers are clearly labelled and free from leaks.
Storage Avoid reaction with oxidising agents
incompatibility Avoid strong acids, acid chlorides, acid anhydrides and chloroformates.
SECTION 8 EXPOSURE CONTROLS / PERSONAL PROTECTION
Control parameters
OCCUPATIONAL EXPOSURE LIMITS (OEL)
INGREDIENT DATA
Not Available
EMERGENCY LIMITS
Ingredient Material name TEEL-1 TEEL-2 TEEL-3

urea Urea 10 mg/m3 10 mg/m3 1700 mg/m3
Ingredient Original IDLH Revised IDLH

urea Not Available Not Available
water Not Available Not Available
Exposure controls
Appropriate
General exhaust is adequate under normal operating conditions.
engineering controls
Personal protection
Safety glasses with side shields.

Chemical goggles.
Contact lenses may pose a special hazard; soft contact lenses may absorb and concentrate irritants. A written policy
document, describing the wearing of lenses or restrictions on use, should be created for each workplace or task. This should
Eye and face include a review of lens absorption and adsorption for the class of chemicals in use and an account of injury experience.
protection Medical and first-aid personnel should be trained in their removal and suitable equipment should be readily available. In the
event of chemical exposure, begin eye irrigation immediately and remove contact lens as soon as practicable. Lens should
be removed at the first signs of eye redness or irritation - lens should be removed in a clean environment only after
workers have washed hands thoroughly. [CDC NIOSH Current Intelligence Bulletin 59], [AS/NZS 1336 or national
equivalent]
Skin protection See Hand protection below

The selection of suitable gloves does not only depend on the material, but also on further marks of quality which vary from
manufacturer to manufacturer. Where the chemical is a preparation of several substances, the resistance of the glove
material can not be calculated in advance and has therefore to be checked prior to the application.
The exact break through time for substances has to be obtained from the manufacturer of the protective gloves and.has to
be observed when making a final choice.
Personal hygiene is a key element of effective hand care. Gloves must only be worn on clean hands. After using gloves,
hands should be washed and dried thoroughly. Application of a non-perfumed moisturizer is recommended.
Suitability and durability of glove type is dependent on usage. Important factors in the selection of gloves include:
· frequency and duration of contact,
· chemical resistance of glove material,
· glove thickness and
· dexterity
Select gloves tested to a relevant standard (e.g. Europe EN 374, US F739, AS/NZS 2161.1 or national equivalent).
Hands/feet protection · When prolonged or frequently repeated contact may occur, a glove with a protection class of 5 or higher
(breakthrough time greater than 240 minutes according to EN 374, AS/NZS 2161.10.1 or national equivalent) is
recommended.
· When only brief contact is expected, a glove with a protection class of 3 or higher (breakthrough time greater
than 60 minutes according to EN 374, AS/NZS 2161.10.1 or national equivalent) is recommended.
· Some glove polymer types are less affected by movement and this should be taken into account when
considering gloves for long-term use.
· Contaminated gloves should be replaced.
For general applications, gloves with a thickness typically greater than 0.35 mm, are recommended.
It should be emphasised that glove thickness is not necessarily a good predictor of glove resistance to a specific chemical,
as the permeation efficiency of the glove will be dependent on the exact composition of the glove material. Therefore, glove
selection should also be based on consideration of the task requirements and knowledge of breakthrough times.
Glove thickness may also vary depending on the glove manufacturer, the glove type and the glove model. Therefore, the
manufacturers’ technical data should always be taken into account to ensure selection of the most appropriate glove for the
Continued...
SCR 40
task.
Note: Depending on the activity being conducted, gloves of varying thickness may be required for specific tasks. For
example:
· Thinner gloves (down to 0.1 mm or less) may be required where a high degree of manual dexterity is needed.
However, these gloves are only likely to give short duration protection and would normally be just for single use
applications, then disposed of.
· Thicker gloves (up to 3 mm or more) may be required where there is a mechanical (as well as a chemical) risk
i.e. where there is abrasion or puncture potential
Gloves must only be worn on clean hands. After using gloves, hands should be washed and dried thoroughly. Application of a
non-perfumed moisturiser is recommended.
Wear chemical protective gloves, e.g. PVC.
Wear safety footwear or safety gumboots, e.g. Rubber
Body protection See Other protection below
Overalls.
P.V.C. apron.
Other protection Barrier cream.
Skin cleansing cream.
Eye wash unit.
Thermal hazards Not Available
Respiratory protection
Particulate. (AS/NZS 1716 & 1715, EN 143:000 & 149:001, ANSI Z88 or national equivalent)
SECTION 9 PHYSICAL AND CHEMICAL PROPERTIES
Information on basic physical and chemical properties

Appearance Clear liquid with a slightly ammoniacal odour; mixes with water.
Relative density
Physical state Liquid 1.09@20C
(Water = 1)
Partition coefficient
Odour Not Available Not Available
n-octanol / water
Auto-ignition
Odour threshold Not Available Not Available
temperature (°C)
Decomposition
pH (as supplied) Not Available 100
temperature
Melting point /
-11.5 Viscosity (cSt) Not Available
freezing point (°C)
Initial boiling point Molecular weight
100 Not Applicable
and boiling range (°C) (g/mol)
Flash point (°C) Not Applicable Taste Not Available
Evaporation rate Not Available Explosive properties Not Available
Flammability Not Applicable Oxidising properties Not Available
Upper Explosive Limit Surface Tension

Not Applicable Not Available
(%) (dyn/cm or mN/m)
Lower Explosive Limit Volatile Component
Not Applicable Not Available
(%) (%vol)
Vapour pressure (kPa) 6.4@40C Gas group Not Available
Solubility in water
Miscible pH as a solution (1%) 9.8-10 (10%)
(g/L)
Vapour density (Air =
Not Available VOC g/L Not Applicable
1)
SECTION 10 STABILITY AND REACTIVITY
Reactivity See section 7

Unstable in the presence of incompatible materials.
Chemical stability Product is considered stable.
Hazardous polymerisation will not occur.
Possibility of
See section 7
hazardous reactions
Continued...
SCR 40
Conditions to avoid See section 7
Incompatible materials See section 7
Hazardous
decomposition See section 5
products
SECTION 11 TOXICOLOGICAL INFORMATION
Information on toxicological effects

Not normally a hazard due to non-volatile nature of product
The material is not thought to produce adverse health effects or irritation of the respiratory tract (as classified by EC
Inhaled
Directives using animal models). Nevertheless, good hygiene practice requires that exposure be kept to a minimum and that
suitable control measures be used in an occupational setting.
The material has NOT been classified by EC Directives or other classification systems as "harmful by ingestion". This is
Ingestion
because of the lack of corroborating animal or human evidence.
The material may cause skin irritation after prolonged or repeated exposure and may produce on contact skin redness,
Skin Contact
swelling, the production of vesicles, scaling and thickening of the skin.
Eye The liquid may produce eye discomfort causing smarting, pain and redness.
Long-term exposure to the product is not thought to produce chronic effects adverse to the health (as classified by EC
Directives using animal models); nevertheless exposure by all routes should be minimised as a matter of course.
Chronic
As with any chemical product, contact with unprotected bare skin; inhalation of vapour, mist or dust in work place
atmosphere; or ingestion in any form, should be avoided by observing good occupational work practice.
TOXICITY IRRITATION
SCR 40
Not Available Not Available
TOXICITY IRRITATION
urea [2]
Oral (rat) LD50: 8471 mg/kg Skin (human): 22 mg/3 d (I)- mild
TOXICITY IRRITATION
water [2]
Oral (rat) LD50: >90000 mg/kg Not Available
Legend: 1. Value obtained from Europe ECHA Registered Substances - Acute toxicity 2.* Value obtained from manufacturer's SDS.
Unless otherwise specified data extracted from RTECS - Register of Toxic Effect of chemical Substances
Asthma-like symptoms may continue for months or even years after exposure to the material ceases. This may be due to a
non-allergenic condition known as reactive airways dysfunction syndrome (RADS) which can occur following exposure to high
levels of highly irritating compound. Key criteria for the diagnosis of RADS include the absence of preceding respiratory
disease, in a non-atopic individual, with abrupt onset of persistent asthma-like symptoms within minutes to hours of a
documented exposure to the irritant. A reversible airflow pattern, on spirometry, with the presence of moderate to severe
bronchial hyperreactivity on methacholine challenge testing and the lack of minimal lymphocytic inflammation, without
eosinophilia, have also been included in the criteria for diagnosis of RADS. RADS (or asthma) following an irritating inhalation
is an infrequent disorder with rates related to the concentration of and duration of exposure to the irritating substance.
Industrial bronchitis, on the other hand, is a disorder that occurs as result of exposure due to high concentrations of irritating
substance (often particulate in nature) and is completely reversible after exposure ceases. The disorder is characterised by
dyspnea, cough and mucus production.
The material may cause skin irritation after prolonged or repeated exposure and may produce on contact skin redness,
swelling, the production of vesicles, scaling and thickening of the skin.
For urea:
UREA
There is little data that relates urea to human health other than its use in dermatology and some more limited applications in
clinical medicine. The use of urea (at 10% concentration or less) in ointments and creams to treat dry skin has been
widespread, and long term follow-up studies have indicated that the substance is nonallergenic and virtually free from side
effects. Among other clinical therapeutic uses, the treatment of inappropriate secretion of antidiuretic hormone (SIADH)
should be noted, because its chronic form has involved long term oral administration of large amounts of urea. Most patients
have tolerated urea well, although diarrhoea is sometimes reported after ingestion of 60-90 g/day. The possibility exists that
infection of H. pylori in human stomach may aggravate local effects by urea because of ammonia generation.
Acute toxicity: The acute toxicity by urea is well delineated by the oral route. Toxicity is low in mammals other than
ruminants, especially cattle, and sheep, in which the rumen micro-organisms contain urease activity and metabolise urea to
ammonia at a high rate. In mice and rats, urea is of low toxicity even by the subcutaneous and intravenous route.
Repeated dose toxicity: No well-conducted repeated dose toxicity studies on urea were located. Chronic toxicity and
carcinogenicity screening studies in mice and rats fed with 4500, 9000 or 45000 ppm in diet (up to about 6750 mg/kg body
weight/day for mice and about 2250 mg/kg body weight/day for rats) did not uncover any treatment-related toxic syndromes
in the various organs studied. Neither was any weight depression noted at terminal necropsy for animals of either sex or
Continued...
SCR 40
species at any dose levels. Thus the NOAELs were about 6750 mg/kg body weight/day for mice and about 2250 mg/kg body
weight/day for rats.
Repeated dose toxicity studies with rats by skin application over 4 weeks and 25 weeks were conducted using urea ointment
at 10%, 20% and 40% concentrations, and no consistent treatment-related toxic effects were found. The ointments were
applied on a 20 cm2 area of the back skin; it is concluded that the repeated dose toxicity of urea by dermal route is low.
Reproductive/developmental toxicity: The studies cited under repeated dose toxicity did not indicate any toxic effects on
the reproductive organs of mice and rats. No adequate teratogenicity/developmental toxicity studies of urea with mammals
were located. According to one rat study, 50 g/kg body weight/day administered by gavage in two doses 12 hours apart for an
average of 14 days did not cause outstanding (external) teratogenicity; the mean birthweight of the newborn was lower but the
litter size greater. Injection of urea into the air sack of eggs shows that urea is toxic to the development of chick embryo.
No NOAEL can be given for the reproductive/developmental toxicity of urea because appropriate studies are lacking.
Genetic toxicity: Urea has been negative in several appropriately conducted bacterial mutagenicity tests. Urea caused DNA
single strand breaks in mammalian cells in vitro and was clastogenic for mammalian cells in vitro and in vivo but only at
concentrations much beyond the physiological range (about 50-100 higher concentrations than found in human blood). The
mechanism of genotoxicity is probably non-specific (e.g. difference in osmotic pressure across the cell membrane).
NOTE: Substance has been shown to be mutagenic in at least one assay, or belongs to a family of chemicals producing
damage or change to cellular DNA.
Altered sleep time, change in motor activity, antipsychosis, dyspnea, methaemoglobinaemia, convulsions, lymphomas
recorded. Carcinogenic by RTECS criteria.
WATER No significant acute toxicological data identified in literature search.
Acute Toxicity Carcinogenicity

Skin
Reproductivity
Irritation/Corrosion
Serious Eye STOT - Single
Damage/Irritation Exposure
Respiratory or Skin STOT - Repeated
sensitisation Exposure
Mutagenicity Aspiration Hazard
Legend: – Data available but does not fill the criteria for classification
– Data required to make classification available
– Data Not Available to make classification
SECTION 12 ECOLOGICAL INFORMATION
Toxicity
Ingredient Endpoint Test Duration (hr) Species Value Source
urea LC50 96 Fish 5mg/L 4
urea EC50 48 Crustacea 3910mg/L 4
urea EC50 96 Algae or other aquatic plants 42184.758mg/L 3
urea BCF 24 Algae or other aquatic plants 0.05mg/L 4
urea EC50 384 Crustacea 894.861mg/L 3
urea NOEC 96 Crustacea 1000mg/L 4

Extracted from 1. IUCLID Toxicity Data 2. Europe ECHA Registered Substances - Ecotoxicological Information - Aquatic Toxicity
3. EPIWIN Suite V3.12 - Aquatic Toxicity Data (Estimated) 4. US EPA, Ecotox database - Aquatic Toxicity Data 5. ECETOC
Legend:
Aquatic Hazard Assessment Data 6. NITE (Japan) - Bioconcentration Data 7. METI (Japan) - Bioconcentration Data 8. Vendor
Data
For Urea: log Kow: -2.97 to -2.26; Henry's Law Constant: 4.4E-8 atm m3/mol. Urea is essentially non-volatile in solid form.
Atmospheric Fate: Urea will not evaporate from water to the atmosphere and is expected to be readily degraded by reactions with photochemically
produced hydroxyl radicals; half-life is expected to be less than 1 day. Degradation of urea to ammonia causes NH3-emissions to the air.
Terrestrial Fate: The highest environmental exposure for urea is via fertilizer when 85 - 90% of urea is incorporated into the soil. Urea will hydrolyze into
ammonium in a matter of days to several weeks. Urea is relatively leachable from the soil into surface water and groundwater especially if the soil
surface is saturated with water.
Aquatic Fate: Urea is very soluble in water and may rapidly biodegrade to a moderate extent. Urea is not expected to evaporate significantly. Urea can
be leached relatively easily into the surface water and the groundwater. Degradation products (e.g. nitrate, nitrite and ammonium) can be measured after
urea has undergone biodegradation.
Ecotoxicity: Urea is not likely to undergo bioaccumulation and generally has low acute ecotoxicity to organisms. The degradation product of urea,
ammonia, is known to be toxic to all vertebrates; however, in neutral and acidic conditions, ammonia exists in the form of the ammonium ion. Urea may
directly influence eutrophication in the environment and there is a pollution risk to groundwater when urea is used as a fertilizer, and a deicing agent at
airports. Ecosystems may be affected following long-term use of urea in the control of soil acidification and by ammonia emissions to air.
DO NOT discharge into sewer or waterways.
Persistence and degradability
Continued...
SCR 40
Ingredient Persistence: Water/Soil Persistence: Air

urea LOW LOW
water LOW LOW
Bioaccumulative potential
Ingredient Bioaccumulation
urea LOW (BCF = 10)
water LOW (LogKOW = -1.38)
Mobility in soil
Ingredient Mobility
urea LOW (KOC = 4.191)
water LOW (KOC = 14.3)
SECTION 13 DISPOSAL CONSIDERATIONS
Waste treatment methods

Recycle wherever possible.
Consult manufacturer for recycling options or consult local or regional waste management authority for disposal if no
Product / Packaging suitable treatment or disposal facility can be identified.
disposal Dispose of by: burial in a land-fill specifically licenced to accept chemical and / or pharmaceutical wastes or incineration in
a licenced apparatus (after admixture with suitable combustible material).
Decontaminate empty containers. Observe all label safeguards until containers are cleaned and destroyed.
SECTION 14 TRANSPORT INFORMATION
Labels Required
Marine Pollutant NO
HAZCHEM Not Applicable
Land transport (ADG): NOT REGULATED FOR TRANSPORT OF DANGEROUS GOODS
Air transport (ICAO-IATA / DGR): NOT REGULATED FOR TRANSPORT OF DANGEROUS GOODS
Sea transport (IMDG-Code / GGVSee): NOT REGULATED FOR TRANSPORT OF DANGEROUS GOODS
Transport in bulk according to Annex II of MARPOL and the IBC code

Source Product name Pollution Category Ship Type
IMO MARPOL (Annex II)
- List of Noxious Liquid
Urea solution Z 3
Substances Carried in
Bulk
SECTION 15 REGULATORY INFORMATION
Safety, health and environmental regulations / legislation specific for the substance or mixture
UREA(57-13-6) IS FOUND ON THE FOLLOWING REGULATORY LISTS

Australia Inventory of Chemical Substances (AICS)
WATER(7732-18-5) IS FOUND ON THE FOLLOWING REGULATORY LISTS

Australia Inventory of Chemical Substances (AICS)
National Inventory Status

Australia - AICS Y
Canada - DSL Y
Canada - NDSL N (urea; water)
China - IECSC Y
Continued...
SCR 40
Europe - EINEC /
Y
ELINCS / NLP
Japan - ENCS N (water)
Korea - KECI Y
New Zealand - NZIoC Y
Philippines - PICCS Y
USA - TSCA Y
Y = All ingredients are on the inventory

Legend: N = Not determined or one or more ingredients are not on the inventory and are not exempt from listing(see specific ingredients
in brackets)
SECTION 16 OTHER INFORMATION
Other information
Classification of the preparation and its individual components has drawn on official and authoritative sources as well as independent review by the
Chemwatch Classification committee using available literature references.
A list of reference resources used to assist the committee may be found at:
www.chemwatch.net
The SDS is a Hazard Communication tool and should be used to assist in the Risk Assessment. Many factors determine whether the reported Hazards are
Risks in the workplace or other settings. Risks may be determined by reference to Exposures Scenarios. Scale of use, frequency of use and current or
available engineering controls must be considered.
This document is copyright.

Apart from any fair dealing for the purposes of private study, research, review or criticism, as permitted under the Copyright Act, no part may be
reproduced by any process without written permission from CHEMWATCH.
TEL (+61 3) 9572 4700.
end of SDS
Installation &
Operation Guide industrial
Bluemaster®
Station
AdBlue® Storage and
Dispensing Above Ground
Bunded Polyethylene Tanks
• Depot
• Express
• Terminal
• Customised Fit-Outs
Thank you for purchasing

a Bluemaster® Station!
This installation guide effective from
1st March 2016
Australian
Owned and Made
• industrial.polymaster.com.au
• 1300 062 064
Contents Company Proﬁle
1. Company Profile About Polymaster
2. Introduction Polymaster are manufacturers of an
extensive range if quality products for
3. Bluemaster® Brief
industrial, residential and agricultural
4. Safety Guide applications. Over the last two decades,
Polymaster has been at the forefront of
5. Transport & Storage industry endorsed, product certified
6. Installation & Handling designs that have advanced the life-span
and functional capabilities of process
7. Service and Maintenance vessels, bulk storage, rainwater tanks and
8. Components animal care products. As an Australian
owned, quality assured company.
9. Guarantee Card Polymaster delivers every product to
specification with confidence through our
10. Warranty
growing network of distributors.
Environmental Management
Polymaster’s manufacturing methods embrace
environmental considerations as a central
philosophy. We implement recycled heat
technology; minimizing on the LPG required to
manufacture each product, reducing operating
costs and most importantly, our C02 emissions.
Excess materials are fully recycled and water
re-use programs help to lessen our impact on
Australia’s natural resources.
Quality Assurance
As a quality certified company, Polymaster’s
quality assurance regimen is internationally
recognised and certified to ISO9001 standards.
Our exclusive use of UV stabillzed premium
resins to AS/NZS 4766 standards, combined
with FEA testing and engineering for every
mould design assures quality in the manufac-
ture of every Polymaster product. Every tank
is independently certified to SAI Global’s AS/
NZS 4766:2006 standard and labelled to dis-
play manufacturing details and serial number
for complete traceability.
2 l industrial.polymaster.com.au
Introduction Safety Guide
Congratulations for purchasing one Read operation manual in detail

of Polymaster’s quality Bluemaster® before use & comply with all
Stations. Ensure this product is cor- instructions herein.
rectly installed, operated and regularly Operation manual should be kept
with the equipment at all times.
maintained and it should give you
trouble free service for year to come.
A. Installation and use of this product
Correct tank installation is the sole should only be carried out by properly
responsibility of the purchaser. trained and approved personnel.
The following content is a guide only. B. This manual contains important informa-
Any vehicle/machinery affected tion concerning the safe installation and use
negatively or positively is not covered of this product. Read the manual carefully
before installation and use. Pay attention to
by the Bluemaster® Station guarantee.
all safety warnings.
C. Users of this product are responsible for

the safe and correct use of this product.
Bluemaster® Brief D. Any changes to this product, which have
been done without consulting the manu-
This Bluemaster® Station is only to be facturer, will invalidate all warranties and
used for the static storage and dispensing of guarantees.
AdBlue. The range is designed and engi-
neered to suit the needs of a vast coverage E. The manufacturer will not be responsible
of industrial, commercial and public require- for any accidents or damages caused by
ments from nationwide fleets to local users. incorrect installation or use of this product.
The station enables safe chemical storage F. This product is only suitable for storage
outdoors, at a safe distance from building and dispensing of Adblue® SCR urea.
and hazard zoned areas. High resistance
against mechanical impact and protection G. The control board contains electrical
against heat due to the bunding system devices which are not suited for use in
(tank in tank) construction. The high area’s where there may be risks of explosion.
standard that your Bluemaster Station has
H. The components must not be altered
been made to ensure optimum safely and
or tampered with due to potential risks to
functionally.
personnel.
N.B. For customised BMS’s the following material may
not apply. For all customised bluemaster stations,
polymaster takes no responsibility for operation, rec-
ommendations or maintenance and safety guidance.
FREECALL 1300 062 064 l 3

Transport & Storage
A. DO NOT TRANSPORT WITH LIQUID directly on a level, secure and non-com-
INSIDE. bustible base.
B. The Bluemaster Station must be pro- • Determine if station needs to be secured

tected against mechanical damage during in place in exposed conditions. Do not
transport and storage. drill holes in the tank.
• Bluemaster tanks are supplied with an

C. Loading and off-loading must be carried electronic contents gauge and alarms as
out using only professional equipment, e.g. a standard.
forklift with extended forks. The covers, sock-
ets or other protruding elements, which are • Prior to installing inspect for damage, if
not designed for lifting or moving the station damaged do not install.
must not be used to lift or move the station. • The guarantee card in this booklet
should be returned to the supplier at
D. The Bluemaster Station must never
161 Karinie St, Swan Hill Vic. 3585 or
be pushed or rolled.
[email protected]
E. During transport and storage, the door
• The tank serial number must be record-
must be tightly closed and secured. The dis-
ed on the guarantee card to validate
pensing nozzle must be placed in its holster
warranty. This number is usually located
and the control box shut.
on outside tank by the access hole.
F. Loading and transport areas must be • THE STATION MUST NOT BE FILLED AT
smooth and free of sharp edges. During A RATE EXCEEDING 250 LITRES PER
transportation, the tank must be secured to MINUTE.
prevent the tank from moving.
• For further advice, contact the
BlueMaster helpline on 1300 062 064
After installation, please ensure that this

instruction booklet is left with the end user
for future reference.
Installation & Handling Ensure the entire base of the tank is
These instructions should be read in their supported with a non-combustible base
entirety before commencing installation (minimum 45mm in thickness) extending
of the Bluemaster Station. 300mm on all sides.
• For all tank installation and maintenance,

please take into consideration Health & Bluemaster Station is guaranteed for 2 years
Safety/Local Building Regulations. from the date of purchase against faulty
• A concrete/level solid base is recom- materials or manufacture of the tanks. The
mended for installation. If this is not equipment and accessories are guaranteed
possible the station should be installed for 1 year from purchase.
• The guarantee excludes ancillary fittings 1. Filling bluemaster® tank
such as contents measuring gauges or
During the first fill of the tank the level
mechanical pumps. indicator may show less volume than that
filled. The level indicator minimum read point
Provided that the following criteria are ad- is placed at the base of the tank. The safe fill
hered to (applicable to all models): level must NOT be exceeded.
NOTE: As level gauges can take some time to
• The enclosed guarantee card is returned calibrate, the liquid level must be physically
to Polymaster with evidence of the checked during initial filling.
purchase date.
A. Filling should be performed only under
• The tank is installed and commissioned constant supervision of an authorized person.
in accordance with the instructions out-
lined in the Installation and User Manual. B. This tank can only be filled by a tanker
equipped with a female dry-break coupling.
• The tank is installed and commissioned
by a suitably qualified engineer. C. Ensure dispensing nozzle is in the holster.
• The tank has not been subject to misuse, d. Fit delivery hose to dry-break coupling. Do
careless handling, faulty installation, or not fill the internal tank by other means.
any repairs have not been attempted
or carried out other than by authorized, e. Stop filling when desired amount has been
dispensed into tank or when overfill alarm
qualified service staff.
is activated.
• The tank has been purchased by the
f. Disconnect delivery hose from coupling.
end user and is not for hire purposes.
• The tank is installed above ground. 2. Dispensing from Bluemaster® Stations.
• The tank is inspected every 6 months or A. If the unit is a terminal station, please read
every 50,000 litres dispensed, depend- the MC Box manual entirely before use, and
ing on which occurs first, by a suitably ensure any users are fully instructed.
qualified service engineer. Immediately
B. Lift dispensing nozzle from holster.
upon discovery of any defect in the tank
Ensure the nozzle is clean.
steps are taken to mitigate loss by con-
tacting the Adblue supplier and if neces-
sary arrange for tank to be drained. C. Turn the pump on and start pumping
immediately.
• Immediately upon discovery of any
defect you contact the Guarantor and D. Dispense contents into appropriate tank
allow a representative to inspect the
tank and its surroundings and where E. When vehicle is full, turn off pump
necessary carry our any repairs (before immediately, ensure the dispensing nozzle
any attempts are made to move the is clean before placing back in holster.
tank).
• Standard and ancillary fittings, repairs

and maintenance are to be carried out
by your nominated agent
FREECALL 1300 062 064 l 5

Service & Maintenance Warranty
A. Keep all station equipment in good, This guarantee is not valid for the following
clean working condition. defects:
B. Bluemaster® Station should only be

• Mechanical damaged caused by the
serviced by approved qualified personnel.
Please contact a local service agent for this. user, dealer or improper maintenance.
• Faults, damage or premature wear
C. Spare parts must comply with the caused by improper use.
requirements of the manufacturer. • Damage caused by third parties.
• Repairs carried out by unauthorised
D. A daily check should be carried out in
service personnel.
the visual condition of the station, devices
and power supply.
Within the warranty period, Polymaster will
E. Any faults or alarms should be reported repair or replace, at their discretion, any tank
to the station supplier immediately. found faulty due to incorrect material or
workmanship.
F. Protect against unauthorised access.
Polymaster products are guaranteed against
G. Bluemaster® Station should be serviced
material or manufacturing defect and have
every 6 months or every 50,000 litres dis-
pensed, depending on which occurs first. the following guarantee period commencing
from the date of the invoice:
H. Transport and store the station so as not
to damage the tank walls. • For polyethylene tanks: 5 year
• For accessories/components: 1 year
K. Ensure no foreign material is entering
the Bluemaster® Station at all times.
L. If the station has not been used for an

extended period, run contents through
the dispenser for at least 10 seconds and
dispose of appropriately.
Components
Special Features 10. Lockable Door
1. 400mm Vented Access Lid 11. Inner Tank
2. Digital Level Indicator(ole) 12. Bund Enclosure
3. Tank Management System (optional)
4. 35 LPM Diaphragm Pump
5. Nozzle Holder Please note: Equipment shown in diagram is

not standard on all tanks. Positioning of equip-
6. S/Steel Automatic Nozzle ment may vary depending on model of your
Bluemaster® station.
7. 50mm Dry Break Coupling
For further information please refer to ad-
8. Retractable Hose Reel ditional manuals.
9. Weather-proof Dispensing Cabinet
3 4 5
6
10
7
11
12
8
9
PICTORIAL VIEW
(Terminal MODEL SHOWN)
FREECALL 1300 062 064 l 7

Warranty Card
industrial
Please register online at warranty.polymaster.com.au

to activate your warranty.
If you are unable to access this page online you can complete the
below fields and return this form to Polymaster: Attn: Warranty Dept.
Locked Bag 4001 Swan Hill VIC 3585
PRODUCT CODE : ___________________________________
COLOUR: _________________________________________
SERIAL NUMBER :___________________________________
FULL NAME:_______________________________________
ADDRESS (LOCATION OF TANK) :________________________
DAYTIME TELEPHONE NO._____________________________
EMAIL ADDRESS____________________________________
DATE OF PURCHASE:_________________________________
(Please ensure all fields are completed to ensure validity)
Appendix B
Response to
Traffic Matters
(SLR Consulting Australia 2022)
2 May 2022
620.30288-L03-v2.0 Modification 3 Traffic Matters 20220502.docx
ProTen Tamworth Pty Ltd

PO Box 1746
North Sydney NSW 2060
Attention: Bill Williams
Dear Bill
Rushes Creek Poultry Production Farm

Modification 3 Scope Changes
1 Introduction
1.1 Context
SLR Consulting Australia Pty Ltd (SLR) has been engaged by ProTen Tamworth Pty Ltd (ProTen) to provide traffic
engineering advice in relation to a proposed modification to an existing Development Consent (Modification 3)
for the Rushes Creek Poultry Production Farm development (Rushes Creek PPF or the development). For
reference, an assessment of the traffic engineering matters associated with Modification 3 has previously been
undertaken by SLR and is documented in the Modification 3 Traffic Assessment dated 20 December 2021 (SLR
M3TA).
This letter has been prepared to document an assessment of the traffic engineering implications of proposed
changes to the scope of Modification 3 for consideration by the NSW Government Department of Planning,
Industry and Environment (DPIE) and relevant road authorities, including Transport for NSW (TfNSW) and
Tamworth Regional Council (TRC).
2 Proposed Modification 3 Scope Changes
The proposed changes to the scope of Modification 3 are described below and compared to that previously
assessed within the SLR M3TA:
• ProTen now seek approval for reliance on diesel generators to operate Farm 2 and the Namoi River
water supply pump for up to 12 months. The SLR M3TA considered diesel generator use at the above
locations for up to 10 months, including daily diesel deliveries by Heavy Rigid Vehicle (HRV) tankers to
Farm 2 and daily transfers of diesel between Farm 2 and the Namoi River water supply pump using a
light vehicle (e.g. 4WD or ute) towing a 2,500L fuel trailer.
• In response to issues raised by WaterNSW and Gunnedah Council, ProTen has agreed not to position
an ancillary diesel storage tank at the Namoi River water supply pump site, and instead transfer diesel
from storage tanks located on Farm 2 as required. As indicated above, the SLR M3TA contemplated
daily transfers of diesel between Farm 2 and the Namoi River water supply pump.
SLR Consulting Australia Pty Ltd Level 16, 175 Eagle Street Brisbane QLD 4000 Australia (PO Box 26 Spring Hill QLD 4004)
T: +61 7 3858 4800 E: [email protected]
www.slrconsulting.com ABN 29 001 584 612
ProTen Tamworth Pty Ltd SLR Ref: 620.30288-L03-v2.0 Modification 3 Traffic
Rushes Creek Poultry Production Farm Matters 20220502.docx
Modification 3 Scope Changes Date: 2 May 2022
• Responding to the Environmental Protection Authority’s (EPA’s) requirement for any generator
operating for greater that 200 hours per year to comply with the NOx limits in Schedule 4 of POEO
(Clean Air) Regulation 2021, ProTen will install Selective Catalytic Reduction (SCR) units for two of the
440 kVA generators at Farm 2 and the 45 kVA generator at the Namoi River water supply pump. These
units use a urea solution, Ausblue, which will be stored in a 10,000L double bunded tank at Farm
2. Ausblue will be delivered from Brisbane in tankers up to 25m B-Double size, with a maximum of one
(1) delivery per month anticipated for the 12 month period for which diesel generators will be
utilised. The SCR unit for the small 45 kVA Namoi River generator has a 35 L Ausblue storage tank
attached to it, which will be topped up from the Farm 2 storage tank as required using the same fuel
trailer as the diesel deliveries from Farm 2. Each time the river pump generator is refuelled, a small
amount of Ausblue will be carted using the fuel trailer to top up the 35L Ausblue storage tank.
• The proposed timing for concurrent site operation and construction activities on Farm 2 has now
changed. The SLR M3TA considered up to 10 months of concurrent construction and operations
commencing in February 2022. The proposed duration of concurrent site construction and operations
is still up to 10 months; however, this is now planned to commence in May 2022 (i.e. a three month
delay compared to that previously proposed).
The traffic engineering implications of the above changes to the Modification 3 scope are assessed below.
3 Assessment of Traffic Engineering Matters
3.1 Proposed Extension of Diesel Generator Use
The following of relevance from a traffic engineering perspective is noted with regard to the proposed extension
of diesel generator use at Farm 2 and the Namoi River water supply pump for up to 12 months:
• The SLR M3TA indicated that the use of diesel generators would generate up to four (4) vehicle
movements per day, consisting of two (2) heavy vehicle movements associated with diesel deliveries
to Farm 2, and two (2) light vehicle movements between Farm 2 and the Namoi River water supply
pump site for fuel transfer.
• The proposed extension of diesel generator use from 10 to 12 months will not increase development
peak hour or daily traffic demands beyond that previously assessed in the SLR M3TA, albeit, that the
additional trips associated with fuel deliveries and transfers will now occur for up to 12 months.
• Importantly, the SLR M3TA indicated that the proposed site accesses and external intersections have
sufficient capacity to accommodate the additional traffic movements generated by diesel deliveries
and fuel transfers, and that no specific safety measures were considered necessary to accommodate
these vehicle movements.
Reflective of the above, the proposed extension of diesel generator use is not considered to be significant from
a traffic engineering perspective and will not result in any new traffic impacts beyond that previously assessed.
Page 2
3.2 Ausblue deliveries to Farm 2
As previously indicated, Ausblue will be delivered to a 10,000L storage tank located on Farm 2 using tankers up
to 25m B-Double size, with up to one (1) delivery per month anticipated for the 12 month period for which diesel
generators will be utilised.
The following is noted with respect to the traffic engineering implications of Ausblue deliveries to Farm 2:
• The northern site access and Farm 2 internal circulation roads have been designed to accommodate
vehicles up to 25m B-Double size for the operational phase of the development, as summarised in the
SLR M3TA. The use of 25m B-Doubles for monthly Ausblue deliveries is therefore considered to be
reasonable, and will not introduce any additional safety impacts compared with those previously
assessed;
• Ausblue deliveries are expected to create up two (2) additional heavy vehicle movements per month,
consisting of one (1) inbound and one (1) outbound movement, both of which are anticipated to occur
outside of network peak hour periods. This level of additional traffic demand is not considered to be
significant from an operational perspective.
Reflective of the above, monthly deliveries of Ausblue using tankers up to 25m B-Double size for a period of up
to 12 months is not considered to be significant from a traffic engineering perspective and will not result in any
new traffic impacts beyond that previously assessed.
3.3 Fuel and Ausblue Transfer to the Namoi River water supply pump generator
With regard to fuel transfers between Farm 2 and the Namoi River water supply pump, daily transfers of diesel
(up to two (2) light vehicle movements daily) have already conservatively been contemplated and assessed in
the SLR M3TA. Furthermore, Ausblue will be transferred between Farm 2 and the Namoi River water supply
pump using the same fuel trailer as diesel transfers, and accordingly, will not generate any new vehicle trips
beyond that previously contemplated. On this basis, the impacts of this proposed change to the scope of
Modification 3 have already been assessed, and no further assessment is considered warranted.
3.4 Timing of Concurrent Site Construction and Operation
The following is noted in relation to the proposed timing of concurrent site operation and construction activities
on Farm 2:
• The traffic impacts of concurrent site operation and construction activities on Farm 2 were previously
assessed within the SLR M3TA, which indicated that the proposed site accesses and external
intersections have sufficient capacity to accommodate the combination of operational and
construction traffic movements, and that no specific safety measures were considered necessary to
accommodate these vehicle movements.
• Importantly, the proposed changes will not materially increase development peak hour or daily traffic
demands beyond that previously assessed in the SLR M3TA.
• The delay in commencement of concurrent site operation and construction activities on Farm 2 is not
considered to be material from a traffic engineering perspective.
Reflective of the above, the proposed delay to concurrent site operation and construction activities on Farm 2
is not considered to be significant from a traffic engineering perspective and will not result in any new traffic
impacts beyond that previously assessed.
Page 3
4 Summary
SLR has been engaged by ProTen to provide traffic engineering advice in relation to Modification 3 for the Rushes
Creek Poultry Production Farm development. Based on the commentary provided herein, the proposed changes
to the scope of Modification 3 will not result in any new or changed impacts from a traffic engineering
perspective compared with that previously assessed in the SLR M3TA.
Should you have any queries in relation to the information contained herein, please do not hesitate to contact
the undersigned.
Yours sincerely
CHRIS LAWLOR
Principal - Transport Advisory
Page 4
Appendix C
Response to
Noise Matters
(Global Acoustics 2022)
20 May 2022
EME Advisory Pty Ltd

Greenwich NSW 2085
Attention: Eryn Bath
Dear Eryn ,
Regarding: ProTen Rushes Creek Poultry Production Complex, Modification 3 to

Development Consent SSD 7704 submissions response.
1 INTRODUCTION
On 16 April 2020 Development Consent SSD 7704 was granted by the NSW Department of Planning, Industry
and Environment (DPIE) to construct and operate an intensive poultry broiler production farm at Rushes
Creek in the Tamworth Regional Local Government Area. ProTen are seeking to undertake a third
modification to SSD 7704 (Modification 3) which relates only to Farm 2.
Key elements of Modification 3 that relate to noise include:
• operation of Farm 2 using diesel generators for a period of up to 12 months;
• operation of the water supply pump at the Namoi River using diesel generators for a period of up to
12 months;
• concurrent construction and operation of Farm 2 for a period of up to 10 months; and
• increase to the number of diesel deliveries by rigid tankers and urea deliveries by vehicles up to B-
double size, for a period of up to 12 months.
Global Acoustics provided a letter of advice regarding potential noise impact associated with Modification 3
(file reference 21250_L02.pdf). This letter provides additional advice addressing minor amendments to
Modification 3 and agency submissions.
2 MODIFICATION 3 SLEEP DISTURBANCE IMPACTS

21250_L03 Page2
DPIE have sought clarification on sleep disturbance impacts related to Modification 3. The only significant
changes to operation noise source in Modification 3 are the use of diesel generators for a period of up to 12
months. Diesel generators were added to the operational noise model with updated results provided in Table
2.2 of Global Acoustics letter 21250_L02. With diesel generators included there were minor increases to
predicted operational noise levels with results remaining in compliance with the night period criterion of LAeq
35 dB.
A Noise Impact Assessment (NIA) was undertaken by Global Acoustics as part of the Environmental Impact
Statement (EIS). Sleep disturbance impacts for the development were assessed with impacts predicted to be
less than LAmax 40 dB at all receivers with an LAmax criterion of 45 dB.
While all operational noise sources were included in the sleep disturbance assessment, bird collection activities
including trucks and forklifts are the primary generators of maximum levels.
As operational noise levels, including operation of the diesel generators comply with the night period criterion
of LAeq 35 dB, and there are no proposed changes to bird collection, sleep disturbance impacts are predicted
to comply with the sleep disturbance criterion LAmax 45 dB.
3 CRITERIA FOR CONCURRENT CONSTRUCTION AND OPERATION
The NSW Department of Planning have sought justification for the use of the construction noise criterion of
LAeq 40 dB to be used for assessment of concurrent construction and operational activities instead of the more
stringent operational criterion of LAeq 35 dB.
Construction activities will occur during standard construction hours (Day period). We have assessed
construction noise against the minimum noise affected management level of LAeq 40dB with no predicted
exceedances. We have assessed the whole farm operations against the minimum night period intrusiveness
criterion of LAeq 35 dB with no predicted exceedances.
Commencement of operations while construction is ongoing allows a small number of sheds to be productive
while other areas of the site are still under construction. The combined assessment shows that with full farm
operation combined with construction activities, cumulative noise levels are predicted to be lower than the
minimum construction noise affected management level of LAeq 40dB. Note that Mod 3 relates to
approximately one third of the total farm operations so combined noise levels are expected to be significantly
lower than the predictions provided.
Outside of standard construction hours we have predicted that noise levels from operations will comply with
the minimum night period intrusiveness criterion of LAeq. This has not changed as a result of Mod 3. Any
cumulative impact of construction and operations outside of standard construction hours would be required
to be assessed against a criterion of LAeq 35dBA.
It should also be noted that the minimum day period intrusiveness criterion in accordance with the Noise
Policy For Industry is LAeq 40 dB. The LAeq 35 dB criterion adopted for day period operational criterion in
the EA NIA was from the Industrial Noise Policy.
21250_L03 Page3
4 MODIFICATION AMENDMENTS
ProTen have advised that since the previous letter discussing noise impacts associated with Modification 3
(file reference 21250_L02.pdf) was provided there have been some minor amendments to the proposed
modification. These changes include the following:
• An increase in the period of reliance on diesel generators from 10 months to 12 months;
• The proposed timeline for construction has changed, although the duration of concurrent construction
and operations remains the same;
• Daily diesel deliveries and monthly urea deliveries for a period of up to 12 months.
None of the proposed amendments to the modification are significant in terms of predicted construction,
operation or road traffic noise impact.
It should also be noted that the EIS NIA and modelling for Modification 3 have assessed worst-case
construction and operation impacts for Stage 1 and 2 of the development (Farms 1 – 4). Modification 3 relates
only to Stage 1 (Farm 2) which encompasses 18 of the proposed 54 total sheds. The farms operate in a modular
way so during Stage 1 where only one farm is operating only approximately one third of the total noise sources
(ventilation fans, vehicle movements etc) assessed in the EIS NIA will be operating. As such, the noise results
presented in 21250_L02 and further discussed in this response should be considered conservative and no
exceedance of criteria is predicted.
21250_L03 Page4
5 CONCLUSION
Results presented in this letter report show that the changes associated with the proposed Modification 3
should not materially change site noise emission levels from those predicted for the EIS NIA and 21250_L02.
Continued compliance is predicted for all receptors.
I trust this information meets your requirements. If you have any questions or need further details please
contact me.
Prepared: Ryan Bruniges QA Review: Tony Welbourne

Consultant Director
Appendix D
Response to Fire
Safety/Hazard Matters
(GHD 2022)
Level 15, 133 Castlereagh Street
Sydney, NSW 2000
Australia
www.ghd.com
Our ref: 12545704

Revision: 1
2 May 2022
ProTen Tamworth Pty Ltd

Suite 1103, Level 11
99 Mount Street
North Sydney NSW 2060.
Re: CAN03: Addendum to Fire Safety Study

Project: Rushes Creek Poultry Production Farm
Background
The purpose of this Consultant Advice Note (CAN) is to assess the additional Stage 1 modification works to
Rushes Creek Poultry Production Farm, and whether the modifications impact the findings and
requirements of the following documents:
x Fire Safety Study (FSS) undertaken by GHD Pty Ltd (Reference #: 12545704, Revision 0, dated 29
June 2021); and
x Final Hazard Analysis (FHA) undertaken by GHD Pty Ltd (Reference #: 12545704-CAN01,
Revision 0, dated 30 June 2021.
x Addendum to Fire Safety Study (Reference # 1254704-CAN02, Revision 2, dated 3 December

2021.
This CAN shall be read in conjunction with all the referenced documents above.
Proposed Modification Works

Following feedback received from the Department of Planning Industry and Environment (DPIE) and other
respective agencies, the following modifications are proposed;
x Concurrent construction and operation at Farm 2 for up to 10 months (Same duration as reviewed
under CAN02. Noted on a shift in the proposed period to: April 2022 – January 2023)
x Reliance on diesel generators to operate Farm 2 and the river water supply pump for up to 12
months (Previously 10 months under CAN02)
x Diesel storage tank is no longer proposed to be located at the Namoi River water pump site and
instead, diesel to be carted using a light vehicle and fuel trailer from Farm 2 storage as required
(likely one trip per day in peak periods).
x Selective Catalytic Reduction (SCR) units powered by urea solution (Adblue) to be installed,
serving the two (2) 440 kV generators at Farm 2 and 45 kV generator by the river. Urea is noted to
be stored in a double bunded tank located at Farm 2 (capacity of 10,000 L) and at the generator
The Power of Commitment

located by the river (35 L storage tank attached to the generator). The urea storage tank is located
approximately 6 m from the 4000 L diesel storage tank at Farm 2.
Assessment
The proposed modifications detailed above have been reviewed against the referenced documents and the
findings are summarised in Table 1.
Table 1: Assessment of proposed modifications against Fire Safety Study
Modification Impact on Fire Safety Study Findings
Concurrent construction and operation at Farm 2 No impact on findings to date.

for up to 10 months (April 2022 – January 2023).
Fire hydrants are to be commissioned and
operational prior to any operation of Farm 2.
Reliance on diesel generators to operate Farm 2 No impact on findings to date.

and the river water supply pump for up to 12
Water storage tanks at each farm is provided with
months (Previously 10 months under CAN02)
an alarm which sounds when water levels drop to
2/3 full, therefore reliance on diesel generators to
operate the river water supply pump to fill the tanks
is not expected to impact the FSS and FHA
findings.
The low-level alarms shall be implemented and
operational during the operational period.
Diesel storage tank is no longer proposed to be No impact on findings to date.

located at the Namoi River water pump site and
instead, diesel to be carted using a light vehicle
and fuel trailer from Farm 2 storage as required
(likely one trip per day in peak periods).
Selective Catalytic Reduction (SCR) units powered Urea solution is classified as a non-hazardous,
by urea solution (Adblue) to be installed, serving non-DG chemical. It is not flammable.
the two (2) 440 kV generators at Farm 2 and 45 kV
The urea storage tank is to be located in close
generator by the river. Urea is noted to be stored in
proximity to other DGs such as the proposed
a double bunded tank located at Farm 2 (capacity
4,000 L diesel storage tank located at farm 2, but is
of 10,000 L) and at the generator located by the
not expected to impact findings to date.
river (35 L storage tank attached to the generator).
The urea storage tank is located approximately 6
m from the 4000 L diesel storage tank at Farm 2.
Based on the review of the modifications proposed, there is no material impact to the referenced Fire
Safety Study and Final Hazard Analysis.
It is however recommended that the following to be adopted during the concurrent construction and
operation of Farm 2 to ensure adequate firefighting provisions are provided:
x Fire hydrants shall be operational during this period; and
x Water storage tanks filled via the diesel generator water pumps shall be provided with a low level
alarm to sound when tanks reach a capacity of two-thirds full (as detailed in the fire safety study
requirements).
We trust this addendum provides insight with respect to the proposed modifications at Rushes Creek
Poultry Production Farm. If you have any further queries, see contact details below.
Documented By Technical Review By Approved By
Mark Tsai Colin Thomson Colin Thomson

Fire Engineer Chartered Fire Safety Engineer – Chartered Fire Safety Engineer –
[email protected] Engineers Australia Engineers Australia
Technical Director – Fire Engineering Certifier (Fire Safety) – BDC04754
[email protected] Technical Director – Fire
Engineering
[email protected]
Appendix E
Essential Energy Services

Agreement Extension
Ref: fC110111
7/04/2022
Att: Mark McDonald

ProTen Holdings Pty Ltd
2/66 Berry Street, NORTH SYDNEY NSW 2060
Dear Mark,
499144 ‐ Rushes Creek Poultry Services Agreement Extension
Essential Energy and ProTen Holdings Pty Ltd are parties to the Connection Investigation Services
Agreement (CISA) for Rushes Creek Poultrywhich commenced on 20/04/2017.
In accordance with clause 16(1)(a)(i) of the CISA, Essential Energy wishes to place a further 18 months
on to the previous extension of time such that the date to which the term of the CISA is extended
under clause 16(1)(a) is 20/10/2023.
The terms and conditions of the CISA will remain in full force and effect for the duration of the term.

Yours sincerely
Michael Logan
Major Network Connections Manager
PO Box 5730 Port Macquarie NSW 2444 | ABN 37 428 185 226
Telephone: (02) 6589 8318 | Interpreter Services 13 14 50 | essentialenergy.com.au

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Rushes Creek

Poultry Production Farm

SHED 10 Wheel Wash SHED 10

SHED 13 SHED 13 Panels

SHED 15 SHED 15 Secondary Emergency Generator (x1)

SHED 18 SHED 18 Outer Batter

Surface Water Diversion Surface Water Diversion

APPROVED FARM 2 LAYOUT PROPOSED FARM 2 LAYOUT

www.slrconsulting.com PH: 02 4037 3200 FIGURE 2

1D Construction of Sheds 13‐16 (4 sheds) October / November 2022 November 2022

1E Construction of Sheds 17‐18 (2 sheds) December 2022 / January 2023 January 2023

There are no implications in relation to site access or traffic associated with the delayed construction

Potential traffic and fire safety/hazard implications of the proposed SCR units and urea deliveries and

PROPOSED DETENTION DAM

GENERATOR SHEDS & MSB ,55,*$7,21$5($

BIO SECURITY GATE & WHEEL WASH )$5006%

PART SITE PLAN

PROPOSED SITE PLAN RUSHES CREEK ROAD

There are no implications in relation to site access or traffic associated with the delayed construction

Information for SCR

Reduction (SCR) NOx Abatement Systems in Australia and around

Current and future Co-generation and Tri-generation building projects that

environmental sustainability. ECI’s constant testing, research and development

ensures cutting-edge design and maximum reduction in harmful pollutants

into the lower atmosphere, thus reducing smog.

The addition of an Oxidation Catalyst onto an SCR

Exhaust Control Industries

ECI is the leader in Co-generation and SCR technology in Australia.

Chemwatch: 4886-46 Issue Date: 15/11/2016

SECTION 1 IDENTIFICATION OF THE SUBSTANCE / MIXTURE AND OF THE COMPANY / UNDERTAKING

Details of the supplier of the safety data sheet

Telephone 1300 AUS BLUE (1300 287 258)

SECTION 2 HAZARDS IDENTIFICATION

Classification of the substance or mixture

Poisons Schedule Not Applicable

Classification Not Applicable

GHS label elements Not Applicable

SIGNAL WORD NOT APPLICABLE

Precautionary statement(s) Prevention

Precautionary statement(s) Response

Precautionary statement(s) Storage

Precautionary statement(s) Disposal

SECTION 3 COMPOSITION / INFORMATION ON INGREDIENTS

SECTION 4 FIRST AID MEASURES

Description of first aid measures

Immediately give a glass of water.

Indication of any immediate medical attention and special treatment needed

SECTION 5 FIREFIGHTING MEASURES

Special hazards arising from the substrate or mixture

Advice for firefighters

HAZCHEM Not Applicable

SECTION 6 ACCIDENTAL RELEASE MEASURES

Personal precautions, protective equipment and emergency procedures

Methods and material for containment and cleaning up

Personal Protective Equipment advice is contained in Section 8 of the SDS.

SECTION 7 HANDLING AND STORAGE

Precautions for safe handling

Conditions for safe storage, including any incompatibilities

SECTION 8 EXPOSURE CONTROLS / PERSONAL PROTECTION

OCCUPATIONAL EXPOSURE LIMITS (OEL)