TAP submissions re Environment Protection Conservation and Biodiversity Act

Tasmanians Against the Pulp Mill have made several submissions to the Commonwealth under the Environment Protection Conservation and Biodiversity Act.

The main concerns are: pollution impacts on Bass Strait, no risk assessment, persistent organic pollutants eg dioxin, poor flushing of Bass Strait and inadequate hydrodynamic modelling.


31 AUGUST 2007

TAP Submission re EPBC assessment of Gunns’ Tamar valley pulp mill
Referral number 2007/3385



TAP Inc. (Tasmanians Against the Pulp Mill)
TAP spokesperson: Robert McMahon
ph 03 6394 4225, mobile 0448 547 290
email bob@orielstudio.com.au
31 August 2007

We are writing in response to the invitation for public comment on the extended assessment of Gunns Ltd Bleached Kraft Pulp Mill, Bell Bay Tasmania (EPBC 2007/3385)

1. Risks of getting the assessment wrong
No formal Risk Management assessment of the proposal in accordance with Australian Standard AS/NZS 4360 (2004), has been completed. Any risk assessment should at it simplest, include an analysis of the hazard and the probability of its impact over the duration of the risk.

Given that pulp mills can last 100 years, the Commonwealth should view the assessment of Gunns’ proposal as a decision that will impact Australia at least until the next century.

Independent reports from Professor Andrew Wadsley and Dr Stuart Godfrey show that Gunns’ claims about ecotoxicological assessments in their referral seriously understate the impact of the pulp mill effluent.

Slow flushing rates in Bass Strait and bioaccumulation properties of persistent organochlorines such as dioxin from pulp mill effluent poses a serious long term risk to marine species in Commonwealth waters.

Dioxin contamination also poses significant risk to the Tasmania’s fishing industry that utilises Commonwealth waters. The industry was worth $472 million in 2004/05 in direct and downstream processing and involved 7000 jobs (Tasmanian Fisheries Industry Council’s “Fisheries Industry Scorecard” 2004/05).

2. Pollution impacts on Bass Strait
Dioxin calculation errors
Professor Andrew Wadsley Adjunct Associate Professor of Petroleum Technology at Curtin University of Technology (WA) has revealed that Gunns' consultant Toxicos had made a clear cut error in their calculations on Dioxin levels. Toxicos incorrectly set a key calculation as 'dioxin concentrations in the water column' when in fact the calculation should have been 'concentration of dioxin in the water column and sediment’.
The result of this and other miscalculations is that now:

  • Dioxin levels quoted in the Human Health Risk Assessment are 1390 times higher, more than twice the Australian action levels of 6000 pg/kg;
  • Dioxin levels in offshore sediments are 338 times higher;
  • Marine Impact Assessment levels are 90 times higher;
  • Correct background levels of 670 pg/kg for dioxin were not included in the Toxicos assessment on toxicity.

The miscalculations effectively invalidate all of Gunns ecotoxilogical risk assessments and this has grave implications not just for marine ecosystems and human health but also for the Bass Strait fishing industry. Threatened marine species including cetaceans and sharks, as well as the Australian fur seal colony at Tenth Island, are likely to be affected by long-term impacts of effluent discharge and bioaccumulation in the food chain.

Unknown risks re manufacturing of chemicals on site
According to ex RPDC pulp & paper scientist Dr Warwick Raverty (http://www.news.com.au/mercury/story/0,22884,21441712-921,00.html March 25, 2007), Gunns proposes a chemical factory on site manufacturing toxic chemicals to be used in the Integrated Chlorine-Dioxide Process. This particular process to manufacture chlorine dioxide for bleaching is likely to create excess dioxins.

This is a process which Beca AMEC reviewed and said was not accepted modern technology. It appears that the process is not used in a pulp mill anywhere else in the world and actual dioxin emissions from such a process are unknown. This contravenes the requirements of the Stockholm Convention to avoid production of persistent organic pollutants where-ever possible.
This possibility alone should be sufficient to cause the Commonwealth to rule out the proposal.

Dioxin sources inadequately assessed
According to Professor Wadsley, Gunns have also failed to adequately consider:

  • Air borne dioxin emissions which may be produced in greater volume than those in the mill effluent;
  • The leakage into the Tamar Estuary from hazardous landfill;
  • Dioxin released from sediment during construction of the wharf facility.

The likely impact of dioxin contamination on State coastal and Commonwealth marine environments will be sufficient to pose a risk to marine life, to commercial and recreational fisheries, and to human health. (Wadsley A. W. (2007) A Reply to Gunns Limited: Response to Submissions, Appendix A Response on submission citing dioxin calculation concerns Australian Risk Audit. p.22).

Threat of pollutant accumulation through limited flushing of Bass Strait
The threat to Bass Strait can be best understood by reviewing Paul Sandery’s models (Submission number 32 RPDC website www.rpdc.tas.gov.au) that demonstrate the extremely long ‘flush’ times for the shallow Bass Strait, which will allow pollutants to build up and threaten marine life in much of the Strait.

Hydrodynamic modelling
A recent report by Dr Stuart Godfrey (former Chief Research Scientist at CSIRO Marine and Atmospheric Research) examined site-specific hydrodynamic modelling of marine stratification and other factors affecting effluent transport at the proposed discharge site for Gunns’ pulp mill.

Dr Godfrey has identified seriously deficient aspects of hydrodynamic modelling conducted by Gunns viz. model limitations, dilution and fate of effluent discharges and non-compliance with requirements.

His report found that water polluted with effluent from the pulp mill will certainly be washed up on beaches near the outfall at relatively high concentrations and under certain conditions will be drawn to the mouth of the Tamar River. The Tamar River provides a nursery environment for a number of species.

3. Conclusion
For the reasons outlined above, we contend that the proposal should be rejected.

Yours sincerely,
Bob McMahon
Spokesman, TAP Inc.




6 JULY 2007

Federal legislation (Environmental Protection and Biodiversity Conservation Act)

Under the EPBC Act, there is a two step assessment. The first step was completed when the proposal was assessed as a "controlled" action. This has triggered a second step, an asssessment of its environmental and biodiversity impacts. The results are due to be released in August 2007. Download the file EPBC pulp mill assessment process for an explanation.

Available below is the TAP submission on the evironmental and biodiversity impacts of Gunns pulp mill. Conclusions are -

1) For the reasons outlined above, we contend that the proposal should be rejected until all the independent studies are completed, and risks are fully described and independently reviewed to allow a proper assessment by the Commonwealth.

2) At a minimum, risks must be well quantified and the Commonwealth satisfied with the level of risk. However, even the best advice from dedicated safety experts and an almost unlimited budget was not enough to stop the space shuttle Challenger disaster. Because of the multifarious impacts of the pulp mill and the large number of individuals and industries potentially at risk, we ask the Commonwealth to include permit conditions that guarantee:

a) compensation for those affected;

b) clean up costs for environmental damage; and

c) shut down clauses that remain in effect till the causes are remedied.



17 APRIL 2007

Also below is the submission from TAP arguing that the proposal should be considered a 'controlled' action and therefore be fully assessed. See EPBC referral submission from TAP.




State legislation (Pulp Mill Assessment Act 2007)

Click on the link Pulp Mill Assessment Act 2007 to see the legal details.


EPBC pulp mill assessment process.pdf12.55 KB
TAP submission re EPBC assessment of Gunns pulp mill.pdf25.08 KB
EPBC referral submission from TAP.pdf22.43 KB