Review of Sweco Report by Professor Andrew Wadsley
This is a review of the report “Assessment of the Gunns Limited Bell Bay Pulp Mill
against the Environment Emission Limit Guidelines” by SWECO PIC Oy and
associated documentation. This review is limited, in the main, to factors affecting
pulp mill effluent and emissions. Download Professor Wadsley's full report from below.
The main findings are:
1. SWECO PIC make false and misleading statements, and omit significant issues
required for assessment under the Pulp Mill Assessment Act 2007.
2. The report confirms the “deficiencies” identified by the RPDC in Gunns’ draft
IIS and supplementary material.
3. The report and associated references support calculations, reported previously,
demonstrating the likelihood of extensive pollution of the coastal and marine
environment near the outfall of the proposed mill.
4. With respect to dioxin pollution, the Premier publicly stated that “this is a
matter that SWECO PIC is looking at” (7.30 Report, 5th June 2007); the impact
of dioxin is not addressed in the report.
5. SWECO PIC do not assess environmental impacts as required under the Pulp
Mill Assessment Act 2007. In particular, they do not assess or qualify their
assessment of the following sections of the Guidelines:
• D.1.1 for emissions to the marine environment, emission limits will be set at
levels that can be achieved by using AMT, unless lower limits are required to
protect recognised water quality objectives;
• D.1.2 more stringent standards may be required to mitigate any deleterious
environmental impacts identified during the environmental impact assessment
for the proposed mill;
• D.1.3 general measures for best practice environmental management;
• D.1.10(a) the discharge limits must be set at levels which will not prejudice
the achievement of water quality objectives;
• D.1.11 depending on the circumstances and characteristics of the receiving
waters there may be justification for setting limits on other wastewater
discharge parameters e.g. nutrients, pH, temperature and possibly flow;
Page 1 of 10
Review of SWECO PIC Pulp Mill Assessment, 11 July 2007
• D.3.10 to retain a reserve capacity for airsheds, no point source activity
should be permitted to emit a pollutant in a manner or quantity that, allowing
for other reasonable emissions to the relevant airshed, would prejudice
compliance with the National Environment Protection Measure for Air
Quality (National Environment Protection Council 1998).
6. The capacity of the Tamar Valley airshed to cope with the increased pollution
load from the mill is critical to determining the impact of the mill on human
health and mortality. SWECO PIC do not say whether the mill complies with
Section D.3.10. On the basis of this omission alone the report fails to meet the
requirements of the Pulp Mill Assessment Act 2007.
7. The report is deficient in that it does not address technical issues which would
have been addressed under the RPDC assessment. In particular, it does not
include an assessment of noise emissions, impacts on surface or estuarine
waters, effects on flora and fauna, transport implications, construction impacts,
and does not include impacts from off-site infrastructure developments such as
the raw water supply pipeline or effluent pipeline.
8. SWECO PIC abrogates its responsibility with respect to the impact of emissions
on human health, society and the environment. This is in breach of its
obligations under the Code of Ethics of FIDIC (The International Federation of
Consulting Engineers) and the Swedish Partnership for Global Responsibility
(Globalt Ansvar) to which SWECO AB, the parent company, is a signatory.
9. Their report states: “SWECO PIC has limited its work to checking the validity of
the individual statements and data (numbers) in the DIIS [draft integrated
impact statement] that have been identified as requiring special emphasis”. In
my opinion, based on the outcome of this review, SWECO PIC have been
improperly selective with respect to the data they have reviewed and they have
been negligent in checking and certifying the validity of critical assertions of the
Red Light for Pulp Mill: Report Predicts significant Pollution problems.
A report released by the National Toxics Network (NTN) 16th August concludes that the Gunn?s proposed pulp mill fails to meet 58% of the requirements set down by the Resource Planning and Development Commission in relation to emissions. This is in stark contrast to the findings of the SWECO PIC report which assessed the pulp mill as failing only 8% of requirements. Our report exposes major flaws in both the SWECO report and Gunns pulp mill proposal.
SWECO PIC, are pulp mill industry consultants from Finland commissioned by the Tasmanian Government to examine compliance of the proposed pulp mill prior to a Parliamentary approval process. NTN found that the SWECO report had not correctly assessed many of the factors against existing scientific literature and international experience of pulp mill pollution.
NTN spokesperson Lee Bell said, 'The SWECO PIC consultants were given extremely restrictive criteria against which to assess the compliance of the proposed pulp mill. As a result they relied heavily on pulp industry literature and studies that skew the pollution levels associated with modern pulp mills. They also took Gunns claims on pollution at face level which is a major mistake. NTN considered a wide range of literature and expert evidence and has found that the pulp mill does not comply with 58% of its requirements. The SWECO report glosses over many important issues, ignoring the flow-on impacts of non-compliant criterion (such as chlorine and bromine contamination in the bleach) through the pulp mill process which render other factors such as dioxin control in effluent and air emissions non-compliant'.
'Expert information that has come forward late in the process from Dr Stuart Godfrey (effluent movement) and Dr Andrew Wadsley (dioxin contamination) has not been given due consideration due to the Parliamentary fast-tracking of the pulp mill approval' said Mr Bell. These experts conclude that pulp mill effluent is likely to cause coastal contamination as a result of effluent drift and that dioxin levels in sediment of Bass Strait are likely to tip some fish dioxin levels over Australian limits? warns Mr Bell.
Relying on the SWECO report alone to make a decision would be a mistake. NTN urges decision-makers to ensure they hear other voices and assessments of the controversial pulp mill proposal? Mr Bell concluded.
Download the full report 'National Toxics Network analysis of SWECO report.pdf'
Contact: Mr Lee Bell 0417 1966 04 or Dr Mariann Lloyd Smith 0413 621 557
Pulp Mill Effluent to Blow Back to Tamar
Dr Stuart Godfrey, Oceanographer
Effluent from Gunns’ pulp mill will almost certainly be blown back to the shore and sometimes up to the mouth of the Tamar estuary, according to a former CSIRO oceanographer.
Dr Stuart Godfrey, who worked at the CSIRO Marine and Atmospheric Research for over 38 years, believes that Gunns’ failure to take account of two processes that create layering in the ocean has undermined the company’s assurances about the behaviour of the mill’s effluent.
“Oil spills move downwind at 3% of the wind speed; sunny days can turn the top few meters of the ocean into a layer that moves like an oil spill. Depending on wind direction, effluent can travel to the shore, or into Commonwealth-controlled waters, within a few hours; or to the Tamar estuary within less than one day of its discharge into Bass Strait,” said Dr Godfrey.
Dr Godfrey illustrates his point with an aerial photograph of the plume of effluent from a pulp mill in Oregon, USA, in which the plume is clearly blown back to the shore on days of light winds.
Dr Godfrey also warned that potentially toxic substances in the effluent – including bacteria and dioxins – could attach themselves to an ultra-thin layer of oil on the surface of the ocean, and thereby concentrate in foam that blows back to the shore.
Dr Godfrey has drawn his conclusions after detailed analysis of Gunns’ Impacts Statement, the Sweco Pic Report, and Gunns’ responses to submissions that were part of the federal government’s assessment of the proposed pulp mill.
Using a basic modelling program and meteorological data from a week in January 2005, Dr Godfrey carried out a desk-top ‘trial’ to predict where particles from the effluent would have travelled on the days in question – even when the surface flow is assumed to be fully compensated by an equal and opposite flow beneath. Some plumes travelled 20 kilometers in a day, easily enough to take it onto the beach, or into Commonwealth waters, or to the Tamar mouth, depending on wind direction.
The Sweco Pic report identified the absence of adequate data as one of the areas where Gunns had failed to comply with the state’s Emission Guidelines. The Scandinavian company’s report said that Gunns had failed to comply with Guidelines D.3.14, 3.15 and 3.17 because it had not adequately considered the issue of ‘stratification’, or layering, of the ocean as a result of warming. Sweco Pic recommended that these deficiencies be addressed through permit conditions.
Dr Godfrey finds that their failure is so comprehensive that none of their observations were used to validate their choice of modelling parameters; nor could they have been so used.
“Gunns’ prediction that effluent will not reach the shore is due to the combined effects of several modelling errors, that disallowed ocean layering”, Dr. Godfrey said. “This should be a wake-up call to both Governments, and the fishing and tourism industries.”
He will recommend to Tasmanian Parliamentarians and to the Federal Minister for the Environment that Gunns Ltd failure to meet Tasmanian Government Guidelines is so extensive, and augurs so poorly for Gunns meeting any Commonwealth Guidelines, that they should not grant a permit for the Mill to proceed.
Inquiries: Dr Stuart Godfrey (03) 6223 1546
Download the full report Inadequacies of Gunns hydrodynamic modelling.pdf from below.
Dioxin study by Prof Wadsley
Professor Andrew Wadsley has replied to Gunns’ response to submissions under the Commonwealth EPBC Act re dioxin levels in Bass Strait. ‘The likely impact on the Tasmanian coastal and Commonwealth marine environments will be sufficient to pose a significant risk to marine life, to commercial and recreational fisheries, and to human health.’ Download Professor Wadsley's reply to Gunns below.
Poor flushing of Bass Strait
Paul Sandery of Flinders University shows that Bass Strait flushes poorly particularly in the area where the pulp mill effluent pipe will be located. It takes at least 160 days to flush where the effluent is to be released.
Go to the Gallery images to see the age of different parts of the Bass Strait water body in summer and winter. Blue parts flush relatively quickly whilst orange to red parts flush very slowly.
Since the intended scale of the development is large and be a long-term source of contaminants and pollutants for the marine environment, further investigation should be carried out to understand long-term impacts.
Gunns Ltd IIS has not addressed uncertainty associated with long-term environmental impacts to the marine environment from:
• accumulation of pollutants, particularly dioxins and furans, in sediments and biota over time in Bass Strait and the Tamar Estuary.
• potential long-term impact on Tamar Estuary nurseries, Bass Straight marine cosystems and South East Fishery.
In addition, climate scientists suggest the westerly wind belt will move further south due to climate change, implying that the currents in Bass Strait will probably weaken and the flushing times increase.
Bass Strait flushing time video clip
Sandery has produced a short video clip showing flushing times of Bass Strait over a 12 month period. The red areas are slow flushing waters (around 160 days) and blue areas a relatively fast flushing waters. A Shockwave Flash file of 1.4MB "Sandery Tasmania Currents Flash Animation" is available below for downloading. Note; Flash Media is required to view the video clip and it takes a minute or more to load.
Go to Paul Sandery Research Project to download animation video clips of Bass Strait flushing. Three animations of between 3MB and 32 MB can be downloaded from the bottom of the page.
Download Paul Sandery's submission to the RPDC No 32 Paul Sandery from below.
Impact of effluent on the fishing industry
Tasmanian Fishing Industry Council (TFIC) is the peak body representing the seafood industry. The IIS studies of effluent from the pulp mill are not helpful in predicting the impact on Bass Straight fisheries of 73000 tonnes per day of effluent for the next 30 years. Download No 267 Tasmanian Fishing Industry Council from below 159Kb.
Tasmanian Fishing Industry Council Submission to Federal Dept of Environment and Water re EPBC Act
The TFIC submission to federal Minister Malcom Turnbull highlights serious shortcomings in Gunns' methodology for assessing the impact of its effluent on the marine ecosystem of Bass Straight. Download TFIC submission to Turnbull from below 48Kb.
|32 Paul Sandery.pdf||112.55 KB|
|267 Tasmanian Fishing Industry Council.pdf||158.8 KB|
|TFIC submission to Turnbull.pdf||48.32 KB|
|Inadequacies of Gunns hydrodynamic modelling.pdf||615.66 KB|
|Sandery Tasmania Currents Flash Animation.swf||1.38 MB|
|National Toxics Network analysis of SWECO report.pdf||200.77 KB|
|Prof Andrew Wadsleys reply to Gunns re dioxin.pdf||12.19 KB|
|Review of Sweco Pic Report Prof Andrew Wadsley.pdf||230.89 KB|