Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
415924
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
24-May-2023
Time of Inspection:
12:00 a.m.
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Not Assessed
Comments / Actions Required :
Consent not exercised no site audit required.
Visited the site few weeks ago the plant is not ready yet.
Kasjan Paciuszkiewicz
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
422432
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
23-Jun-2023
Time of Inspection:
7:42 a.m.
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Not Assessed
Comments / Actions Required :
Update Email received from Garreth Strawbridge;
The setup of the pyrolysis plant is still happening, site is waiting on arrival of final parts to complete the assembly.
Currently no discharges as the equipment is being built. No requirement for site visit yet.
Will organize a visit once notification for start of works arrives.
Kasjan Paciuszkiewicz
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
431138
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
05-Jul-2023
Time of Inspection:
12:00 a.m.
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Complying
Comments / Actions Required :
Desktop audit assessing compliance with resource consents RM22-0076 & RM22-0128 and the requirement of Site
Management Plans.
RM22-0076 - The purpose of this resource consent is to authorise and set conditions for the temporary discharge of
contaminants to air from an Anaerobic-Thermal-Reduction (ATR) Pyrolysis Trial.
RM22-0128 - The purpose of this resource consent is to authorise and set conditions for the discharge of contaminants to
air from the use of an Industrial Shredder and Destoner Cleaning Plant.
In accordance with consent condition 5.1 of RM22-0128 No later than 20 working days prior to the commencement of
activities authorised by this resource consent, the consent holder must submit a final Shredder Activities Site Management
Plan (SASMP) to the Bay of Plenty Regional Council (BOPRC) for certification that it has been prepared in accordance
with Condition 5.2 of this consent. The purpose of the SASMP is to detail the management, operation, sampling and
monitoring procedures, methodologies and contingency plans necessary to comply with the conditions of this consent.
And condition 5.1 of RM22-0076 No later than 20 working days prior to the commencement of activities authorised by this
resource consent, the consent holder must submit a final ATR Plant Site Management Plan (APSMP) to the BOPRC for
certification that it has been prepared in accordance with Condition 5.2 of this consent. The purpose of the APSMP is to
detail the management, operation, sampling and monitoring procedures, methodologies and contingency plans necessary
to comply with the conditions of this consent.
EMERGENCY MANAGEMENT PLAN Operation of Anaerobic Thermal Reduction (Pyrolysis) Processing Plant Rainbow
Mountain Resource Recovery Centre SITE MANAGEMENT PLAN Operation of Anaerobic Thermal Reduction (Pyrolysis)
Processing Plant Rainbow Mountain Resource Recovery Centre.
Were submitted to BOPRC on 30-05-2023 for review, these documents were externally reviewed by Airmatters.
Airmatters raised few questions and required some amendments to the SMPs.
The responses to the Questions raised by airmatters were provided 04-07-2023. No further issues raised.
The purpose of this audit report is to certify the two management plans.
Please ensure compliance with consent condition 5.4 The consent holder must ensure that a copy of the certified SASMP
(as required by Condition 5.1 of this consent), including any approved amendments, is kept on-site at all times, that only
activities authorised by this consent are being undertaken, and the on-site copy of the certified SASMP shall be updated
Report ID: BRCCOMRP001
Report Date: 5 July 2023
Page: 1 of 2
within 5 working days of any amendments being certified.
Kasjan Paciuszkiewicz
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
431284
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
18-Jan-2024
Time of Inspection:
4:29 pm
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Not Assessed
Comments / Actions Required :
Plant still under construction
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
449944
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
27-Mar-2024
Time of Inspection:
10:33 am
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Complying
Comments / Actions Required :
Site inspection to assess compliance with Resource consent RM22-0076. The purpose of this resource consent is to
authorise and set conditions for the temporary discharge of contaminants to air from an Anaerobic-Thermal-Reduction
(ATR) Pyrolysis Trial.
Currently running two reactor trials, one was running while I was onsite. Initial product results look good, mixed ASR being
used as a feed stock which is cracking around 330 degrees C. Only a minimal amount of PVC content. Also to trial some
HDPE from Fonterra, but potential issues with wax generation.
No visible stack emissions while onsite, stack testing report still to come.
Site contact signage was missing but this has now been reinstalled on the gate
Scrubbers are currently running one with water only and second with NaOH Caustic soda, observed bunded storage
shipping container for NaOH. NaCl is still to be shipped from Australia
ASR is stored under cover so not generating any leachate
A Copy of the APSMP plan is kept on site
Commented to Garreth that some of the secondhand vessels on site had incorrect HSNO signage on them.
.
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
449944
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
27-Mar-2024
Time of Inspection:
10:33 am
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Complying
Comments / Actions Required :
Site inspection to assess compliance with Resource consent RM22-0076. The purpose of this resource consent is to
authorise and set conditions for the temporary discharge of contaminants to air from an Anaerobic-Thermal-Reduction
(ATR) Pyrolysis Trial.
Currently running two reactor trials, one was running while I was onsite. Initial product results look good, mixed ASR being
used as a feed stock which is cracking around 330 degrees C. Only a minimal amount of PVC content. Also to trial some
HDPE from Fonterra, but potential issues with wax generation.
No visible stack emissions while onsite, stack testing report still to come.
Site contact signage was missing but this has now been reinstalled on the gate
Scrubbers are currently running one with water only and second with NaOH Caustic soda, observed bunded storage
shipping container for NaOH. NaCl is still to be shipped from Australia
ASR is stored under cover so not generating any leachate
A Copy of the APSMP plan is kept on site
Commented to Garreth that some of the secondhand vessels on site had incorrect HSNO signage on them.
Small heat up single reactor runs occurred in Feb. Official 6 month trial date to begin from 1st of March 2024
No actions required, Please continue to comply with consent conditions.
.
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
449944
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
12-Apr-2024
Time of Inspection:
10:33 am
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Complying
Comments / Actions Required :
Site inspection to assess compliance with Resource consent RM22-0076. The purpose of this resource consent is to
authorise and set conditions for the temporary discharge of contaminants to air from an Anaerobic-Thermal-Reduction
(ATR) Pyrolysis Trial.
Currently running two reactor trials, one was running while I was onsite. Initial product results look good, mixed ASR being
used as a feed stock which is cracking around 330 degrees C. Only a minimal amount of PVC content. Also to trial some
HDPE from Fonterra, but potential issues with wax generation.
No visible stack emissions while onsite, stack testing report still to come.
Site contact signage was missing but this has now been reinstalled on the gate
Scrubbers are currently running one with water only and second with NaOH Caustic soda, observed bunded storage
shipping container for NaOH. NaCl is still to be shipped from Australia
ASR is stored under cover so not generating any leachate
A Copy of the APSMP plan is kept on site
Commented to Garreth that some of the secondhand vessels on site had incorrect HSNO signage on them.
.
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
457845
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
30-May-2024
Time of Inspection:
11:40 am
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Complying - Follow Up
Comments / Actions Required :
Site inspection to assess compliance with Resource Consent RM22-0076 was carried out on 30-05-2024 in conjunction
with a site visit for Stormwater Consent 65172, see inspection #372187
At the time of my inspection the plant was shut down for maintenance repairs so no emission testing was able to be
observed.
We discussed proposed plans for installation of oil & grit seperator for drainage in addition to the existing bunding which
has over-capacity to hold liquids
Some contouring work has been done to the pad to reduce runoff
Some emissions testing has already been carried out but results have not yet been received - compliant with Condition 7.1
No emissions limit exceedances recorded to date - compliant with Condition 7.6
No odour assessments yet recorded by consent holder. I reminded Gareth that records of FIDOL assessments are
required - as per condition 10.4
I observed during wider site inspection some overflow of stored ASR material outside the south-eastern corner of the
storage shed, where corrosion of roofing Iron at the end corner of the shed allows rainfall to infiltrate, this presents a risk of
discharge of contaminants to storm water from rainfall events. - contamination has not been identified in any recent
stormwater sampling.
RMA s15 1(b) No person may discharge any — contaminant onto or into land in circumstances which may result in that
contaminant (or any other contaminant emanating as a result of natural processes from that contaminant) entering water;
or unless the discharge is expressly allowed by a national environmental standard or other regulations, a rule in a regional
plan as well as a rule in a proposed regional plan for the same region (if there is one), or a resource consent.
Required actions:
1) Provide appropriate overhead rainfall cover to Eastern end of ASR storage shed or cease using this section for ASR
storage. Actions required by 11/07/2024 - required actions also outlined in inspection #372187
Consent conditions:
7.1 Emission tests shall be conducted on emission points identified and following methodology listed in the final ATR Plant
– Sampling and Monitoring Plan (S&MP), to determine compliance with Condition 7.3. These tests shall:
Report ID: BRCCOMRP001
Report Date: 16 September 2024
Page: 1 of 2
1. Be conducted at least three times across the duration of this consent.
2. Be conducted during process conditions that will give rise to maximum normal emissions.
3. Record and describe in lay terms the process conditions that give rise to the emissions.
4. Comprise not less than three separate samples with results corrected to 0 (zero) degrees Celsius, 1 (one) atmosphere
pressure, 11% oxygen and a dry gas basis.
5. Be carried out by an International Accreditation New Zealand-accredited stack testing company using accredited
methods.
7.6 (a) At any point during the exercise of this consent, should the discharge from the ATR Plant exceed any of the
Emissions Limits for any of the parameters identified in Appendix A, the consent holder shall;
1. Complete the trial in progress and then cease operation of the ATR Pyrolysis Plant until the following steps have been
taken; and
2. Advise the Bay of Plenty Regional Council as soon as practicable that there has been an exceedance of the Emissions
Limit(s) including details of the parameter(s) exceeded; and
3. Undertake a review of the process, the plant operation, the material being thermally reduced and the management
plans to understand and remedy the issues causing or contributing to the exceedances of the consented limits; and
4. Identify measures to be undertaken to ensure Emissions Limits will be complied with in subsequent trials;
5. Submit the updated management plan for certification by the Bay of Plenty Regional Council where required as a result
of points (1)-(4) being undertaken; and
6. Advise the Bay of Plenty Regional Council of the outcome of the review process (point 3) and the measures taken to
avoid further exceedances (point 4).
(b) The purpose of the certification process is to review and provide feedback on the proposed changes to ensure the
emissions limits are not exceeded in the future.
(c) Further trials shall not commence until the measures identified in 7.6(a)(1) - (6) have been undertaken and certification
by the Bay of Plenty Regional Council has been received.
10.4 (1) The consent holder shall keep a record of;
1. All FIDOL Assessments undertaken and
2. Measures taken to reduce the frequency, intensity, the duration, offensiveness and/or location of the odour
(2) A record of this information shall be kept for the duration of the consent and shall be provided to the Bay of Plenty
Regional Council within 48 hours of it being requested.
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
440631
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
12-Jun-2024
Time of Inspection:
11:03 am
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Not Assessed
Comments / Actions Required :
Plant still under construction
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
476810
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
09-Sep-2024
Time of Inspection:
1:45 pm
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Complying
Comments / Actions Required :
Follow-up for inspection #457845
Required actions:
1) Provide appropriate overhead rainfall cover to Eastern end of ASR storage shed or cease using this section for ASR
storage. Actions required by 11/07/2024 - required actions also outlined in inspection #372187
Result:
Inspected storage shed 09/09/2024, the area of concern had been cleared and ASR material removed. Consent holder
plans to repair roof with new roofing iron so it is watertight.
Assessed as complying
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
476810
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
16-Sep-2024
Time of Inspection:
1:45 pm
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Complying
Comments / Actions Required :
Follow-up for inspection #457845
Required actions:
1) Provide appropriate overhead rainfall cover to Eastern end of ASR storage shed or cease using this section for ASR
storage. Actions required by 11/07/2024 - required actions also outlined in inspection #372187
Result:
Inspected storage shed, the area of concern had been cleared and ASR material removed. Consent holder plans to repair
roof with new roofing iron so it is watertight.
Assessed as complying
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
467423
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
16-Sep-2024
Time of Inspection:
2:00 pm
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Low Risk Non- Compliance
Comments / Actions Required :
Site inspection to assess compliance with Resource consent RM22-0076. The purpose of this resource consent is to
authorise and set conditions for the temporary discharge of contaminants to air from an Anaerobic-Thermal-Reduction
(ATR) Pyrolysis Trial.
Final on site inspection was conducted on 09/09/2024 to close off the Pyrolysis Trial. I met onsite with Gareth Strawbridge.
- The LDPE trial had proved to produce too much WAX for the plant setup, wax will be reprocessed
- ASR floc and Tyre rubber ran well as seperate feedstocks
- Some teething issues with rollers and gearbox with required maintenance downtime, affected/delayed timelines for trial
runs
Testing
- Ran a few no-load tests but was not great for the reactor
- Dioxin testing was run in the final week of trials
- Halogen & Chloride tests came back with low levels. Results due this week.
- Some profile testing of Syngas came back as 98% methane. Used as recycled fuel for boilers.
- Plans to install filters to improve oil quailty
- Looking into improving quality of carbon black by-product
Scrubbers:
1&2 ran with water, gareth informed me from stack testing results this was sufficient to knock out NOX, sodium chloride
was not used
3 ran with caustic soda to knock out Sulphites
Scrubber residue salts will be removed and tested for content
Stack testing:
Sweet of tests were run over 3 separate days - all required testing said to be completed - compliant with condition 7.1
On 09/09/02024 I requested all test result data received and FIDOL records be forwarded to BOPRC.
As at 16/09/2024
No test results have been received to date by BOPRC - Non-Compliant with condition 7.2
- Results must be submitted to BOPRC within 10 days of receiving results
No records of FIDOLs have been provided to date - Non-Compliant with condition 10.4
Report ID: BRCCOMRP001
Report Date: 16 September 2024
Page: 1 of 2
-Record of information shall be provided BOPRC within 48 hours of request
Required Actions:
- Provide raw test results and records received to date, FIDOL records, and record of relevant operating parameters as per
condition 7.2 and 10.2 by Monday 23/09/2024
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
467423
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
16-Sep-2024
Time of Inspection:
2:00 pm
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Low Risk Non- Compliance
Comments / Actions Required :
Site inspection to assess compliance with Resource consent RM22-0076. The purpose of this resource consent is to
authorise and set conditions for the temporary discharge of contaminants to air from an Anaerobic-Thermal-Reduction
(ATR) Pyrolysis Trial.
Final on site inspection was conducted on 09/09/2024 to close off the Pyrolysis Trial. I met onsite with Gareth Strawbridge.
Feedstock:
- The LDPE trial had proved to produce too much WAX for the plant setup, wax will be reprocessed
- ASR floc and Tyre rubber ran well as seperate feedstocks
- Some teething issues with rollers and gearbox with required maintenance downtime, affected/delayed timelines for trial
runs
Scrubbers:
1&2 ran with water, gareth informed me from stack testing results this was sufficient to knock out NOX, sodium chloride
was not used
3 ran with caustic soda to knock out Sulphites
Scrubber residue salts will be removed and tested for content
Testing:
- Ran a few no-load tests but was not great for the reactor
- Dioxin testing was run in the final week of trials
- Halogen & Chloride tests came back with low levels. Results due this week.
- Some profile testing of Syngas came back as 98% methane. Used as recycled fuel for boilers.
- Plans to install filters to improve oil quailty
- Looking into improving quality of carbon black by-product
- Sweet of Stack tests were run over 3 separate days - all required testing said to be completed - compliant with condition
7.1
On 09/09/02024 I requested all test result data received and FIDOL records be forwarded to BOPRC.
As at 16/09/2024
No test results have been received to date by BOPRC - Non-Compliant with condition 7.2. Results must be submitted to
BOPRC within 10 days of receiving results
No records of FIDOLs have been provided to date - Non-Compliant with condition 10.4. Record of information shall be
provided BOPRC within 48 hours of request
Report ID: BRCCOMRP001
Report Date: 16 September 2024
Page: 1 of 2
Required Actions:
- Provide raw test results and records received to date, FIDOL records, and record of relevant operating parameters as per
condition 7.2 and 10.2 by Monday 23/09/2024
Consent Conditions:
Condition 7.2
The results of all tests, including a record of all relevant operating parameters, raw data, calculations, assumptions, and an
interpretation of the results, shall be submitted to the Bay of Plenty Regional Council within 10 working days of the sample
results being received.
Condition 10.4
(1) The consent holder shall keep a record of; 1. All FIDOL Assessments undertaken and 2. Measures taken to reduce the
frequency, intensity, the duration, offensiveness and/or location of the odour
(2) A record of this information shall be kept for the duration of the consent and shall be provided to the Bay of Plenty
Regional Council within 48 hours of it being requested.
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Compliance Audit
Rainbow Mountain Renewable Energy Limited
Consent Number:
RM22-0076-DC.01
Inspection Number:
467423
PO Box 4067
Expiry Date:
30-Oct-2024
Mount Maunganui South
Mount Maunganui 3149
Date of Inspection:
16-Sep-2024
Time of Inspection:
2:00 pm
Consent Holder(s):
Rainbow Mountain Renewable Energy Limited
Site Address(es) :
216 State Highway 38
Purpose : temporary discharge of contaminants to air from an ATR Pyrolysis Trial
Contact Person During Inspection :
Position:
Reason for Inspection :
Level of Compliance :
Moderate Non-Compliance
Comments / Actions Required :
Site inspection to assess compliance with Resource consent RM22-0076. The purpose of this resource consent is to
authorise and set conditions for the temporary discharge of contaminants to air from an Anaerobic-Thermal-Reduction
(ATR) Pyrolysis Trial.
Final on site inspection was conducted on 09/09/2024 to close off the Pyrolysis Trial. I met onsite with Gareth Strawbridge.
Feedstock:
- The LDPE trial had proved to produce too much WAX for the plant setup, wax will be reprocessed
- ASR floc and Tyre rubber ran well as seperate feedstocks
- Some teething issues with rollers and gearbox with required maintenance downtime, affected/delayed timelines for trial
runs
Scrubbers:
1&2 ran with water, gareth informed me from stack testing results this was sufficient to knock out NOX, sodium chloride
was not used
3 ran with caustic soda to knock out Sulphites
Scrubber residue salts will be removed and tested for content
Testing:
- Ran a few no-load tests but was not great for the reactor
- Dioxin testing was run in the final week of trials
- Halogen & Chloride tests came back with low levels. Results due this week.
- Some profile testing of Syngas came back as 98% methane. Used as recycled fuel for boilers.
- Plans to install filters to improve oil quailty
- Looking into improving quality of carbon black by-product
- Sweet of Stack tests were run over 3 separate days - all required testing said to be completed - compliant with condition
7.1
On 09/09/02024 I requested all test result data received to date and FIDOL records be forwarded to BOPRC.
As at 16/09/2024
No test results have been received to date by BOPRC - Non-Compliant with condition 7.2. Results must be submitted to
BOPRC within 10 days of receiving results
No records of FIDOLs have been provided to date - Non-Compliant with condition 10.4. Record of information shall be
provided BOPRC within 48 hours of request
Report ID: BRCCOMRP001
Report Date: 17 September 2024
Page: 1 of 2
Required Actions:
- Provide raw test results and records received to date, FIDOL records, and record of relevant operating parameters as per
condition 7.2 and 10.2 by Wednseday 25/09/2024
If compliance with the required actions are not met, further enforcement action may be taken.
Consent Conditions:
Condition 7.2
The results of all tests, including a record of all relevant operating parameters, raw data, calculations, assumptions, and an
interpretation of the results, shall be submitted to the Bay of Plenty Regional Council within 10 working days of the sample
results being received.
Condition 10.4
(1) The consent holder shall keep a record of; 1. All FIDOL Assessments undertaken and 2. Measures taken to reduce the
frequency, intensity, the duration, offensiveness and/or location of the odour
(2) A record of this information shall be kept for the duration of the consent and shall be provided to the Bay of Plenty
Regional Council within 48 hours of it being requested.
Hayden Graham
Compliance Officer
Disclaimer: This report is not intended to be a full review of all compliance issues associated with this consent, nor is it intended to supersede or nullify any
conditions of the relevant consent(s)
Bay of Plenty Regional Council has a policy of recovering costs associated with resolving non-compliance issues.
These costs may include staff time, mileage, analytical fees and any other material expenses.
Document Outline