Effluent

Effluent

EFFLUENT TO BASS STRAIT
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The Tamar enters Bass Strait at Low Head. Will chemicals from the mill get sucked into the estuary by the tides?

Gunns Ltd: 'Huge advances have been achieved in minimising effluent from modern pulp mills. In fact, 70% less effluent is released from mills compared to those built 15 years ago'.

Gunns Ltd: ' No effluent will be discharged into the Tamar River.'

Proposal: 'The mill will discharge 30 billion litres of effluent a year'

Comment: 30% still remains, in fact, as this mill is larger, the percentage of effluent will probably be quite a bit higher compared to the proposed Wesley Vale output. A closed loop mill has no effluent discharge but more solid waste.

Gunns Ltd: 'All effluent passes through primary and secondary treatment plants before being released to the ocean to ensure that it is environmentally safe'.

Comment: As far as can be ascertained, the primary and secondary treatment plants consist of two settling ponds where the effluent will be treated by bacteria and an aeration ponds . The settling ponds will be just across the river from a family farm. No doubt more information will be available in the IIS.

Gunns Ltd: 'This treated effluent will be released into the ocean up to 4 kms offshore which is common practice for many mills around the World located on pristine rivers, oceans and lakes'.

Comment: Pulp mills tend to be located well away from inhabited areas because of the smell.

Gunns proposal to RPDC: ' The mill will require a diffuser section at the outfall located in a good ocean dispersion area. Satisfactory mixing is likely to be achieved at the 15-25 metre depth contour and up to 4 kms into Bass Strait.'

Comment: Please note, Bass Strait is not an ocean but a shallow sea that takes up to 180 days to flush. Parts of the Tamar River are deeper than Bass Strait. It looks as though the outfall will be where the depth reaches between 15-25 metres.

A survey in Canada has demonstrated that damage to marine life occurs up to 25kms from the outfall from a pulp mill. Severe degredation occurs up to 10kms away. And please note that tides and currents around British Columbia are far more vigorous than Bass Strait although it has to be said that most Canadian mills are older ones (but their effluent treatment is updated from time to time). If marine plants die, so do the animals that feed on them and so on up the food chain.

Marine survey in Canada

Lets have a look at another angle: This scientific survey from Finland shows that pulp mill effluents disturb the natural male/female ratio around the outfall - this is known as endocrine disruption. The chemical that actually causes the effect has yet to be established which is a bit of a worry.

Effects of pulp mill effluent

Surveys have shown that the area in Bass Strait around the proposed outfall takes 160 days to flush. The penguin colony at Low Head is less than 10kms from the proposed outfall at 5 mile bluff as is the mouth of the Tamar. Tides will almost certainly suck up these chemicals into the Tamar - a 53 km long tidal estuary. The Tamar contains a fish farm, a shark hatchery, a marine park, Sea Horse World and a water bird haven. It is a favourite spot for recreational fishermen. A considerable amount of money and effort has gone into cleaning up the estuary and installing pontoons along its length.

The following CSIRO study shows Bass Strait flushes 1% a day.

CSIRO study on Bass Strait

Paul Sandery's survey shows very clearly that the effluent pipe will be in the worst possible place.

This animated map shows how Bass Strait flushes day by day.

This survey shows without any doubt whatsoever that the area in Bass Strait around the proposed outfall takes at least 160 days to flush. There are unique soft Corals and Sponges living on reefs off Low Head. When seaweed dies because of the effluent it can turn black and wash up on beaches causing an unsightly smelly mess.

This is the area at Five Mile Bluff where the pipe will discharge:

At Five Mile Bluff there is a tesselated pavement rock formation and rock pools bursting with marine organisms:

Gunns Ltd: 'The treated effluent contains naturally occuring inorganic salts (found in oceans) and organic wood constituents.'

Comment: In the Examiner on 3/12/2005, Gunns Ltd announced that their tests on the effluent of a similar pulp mill in Thailand showed that there would be no short term acute effects on a range of marine organisms. Whilst that is encouraging, unfortunately it does not mean that there will be no long term effects as chemicals can bio-accumulate to the point where damage starts to occur. Inorganic salts can be harmful, it all depends on the concentration. It also does nothing to address the problem of endocrine disruption. In fact the RPDC agree: .

RPDC final scope: ' Potential impacts must include the potential for persistent organic pollutants or any other pollutants to bio-accumulate and bio-magnify in marine organisms and the marine food chain with special reference to any threat to human health or the commercial acceptance of marine products .'

Gunns Ltd: the IIS will describe the existing environmental conditions around the marine outfall.'

RPDC final project scope: 'Oceanic dispersion characteristics including currents, tides, flushing ability, residence time, wave energy and temperature within the proposed mixing zone and zone of influence must be detailed .'

Comment: The RPDC final scope also suggests a 4 month survey of sediments around the outfall. All in all, this section of the IIS should make interesting reading.

The Northern Tasmanian Development Group study tour reported that they considered pumping the effluent four kms out to sea will be safe. Locals were happy to drink untreated the water from a lake in Sweden where pulp mills discharged and where the water was only totally flushed once every seven years. No mention was made of possible bio-accumulation, endocrine disruption or colouration (which in pristine turquoise Bass Strait could become an issue) nor the fact that Tasmania has a Scallop and Abalone industry or that the lake water would be cold, fresh water. (Not exactly a valid comparison but better than nothing.)

WHY DOES IT MAKE A DIFFERENCE IF IT'S SALT WATER? The reason is that salt water acts as a flocculant so that suspended solids stick together and, depending on their density, rise to the surface or sink to the sea bed. If they float they could wash up on the beach. If they sink a large area of gunk will accumulate and spread out from around the effluent pipe. The effect of salt water on suspended solids can be seen at the head of the Tamar where fresh water from the North and South Esk rivers mix with the salty Tamar and mud flats have formed.
IIS: identifies that the area of discharge has a high level of environmental health and the Tamar estuary as having critical conservation values. The effluent will contain 1.3 tonnes a day of suspended solids. These will be buoyant (they will float) and so will therefore spread along the coast. The IIS claims that this amount is insignificant. According to the IIS there will be 70,000,000 litres of effluent per day. The effluent will come in under the guidelines. An emminent toxocologist has indicated that there is little chance that damage will occur beyond the mixing zone or that bio-accumulation will occur. The effluent will contain many dozens of other compounds that are foreign to sea water but only in very small quantities. The IIS also accepts that endocrine disruption can occur with pulp mill effluent. The colour content will also came in under the guidelines but no comment has been made on whether this will be visible.
IIS: The marine biological and pollutant survey found that existing levels of copper and zinc exceeded the guidelines for 99% of species. The levels of aluminium, iron and zinc exceeded the guideline values for aquaculture and seafood consumption. Boron pollution is six times the guidelines for recreational water quality.
Comment: So is it wise to add more pollutants into this area?
IIS: The effluent will be bouyant in sea water and will rise quickly to the surface. There is a tidal current flowing parallel to the shore running at 0.8m/s. It reverses with the tide.
Comment: 0.8m/s is about 2.8kms/hr. So in a 6 hour period the effluent could travel 17kms. The mouth of the Tamar is only 8kms away. Opponents will find it hard to accept that pouring this huge amount of effluent into a pristine area that is relatively stagnant in terms of water movement will not affect the local beaches in some way or colour the water. Sometimes perception is more powerful than reality and just the knowledge that the effluent outfall is there will deter some people from either living, holidaying or participating in recreational activites in the area.
In the Mercury on 26th July 2006, the Tasmanian Conservation Trust points out that that the statement in the IIS that 'dioxins are not significantly bioaccumulated' is at odds with a Federal Government report that 'organochlorines bioaccumulate in fish and marine mammals'.
IIS: These are the actual figures as provided in the IIS:

The mill will produce up to 3140 Adt (air dried tonnes) of pulp a day.
Pollutant Kgs/Adt Per day Per year Total dissolved solids 38.5 120tonnes 42,300tonnes Total suspended solids 0.41 1.3tonnes 450tonnes Colour 10 31.4tonnes 10,990tonnes
The National Toxins Network have said that the dump site will leak 10,000 litres a year containing dioxins, furans and heavy metals into the groundwater just 1.5kms from the Tamar and it's only a question of time until they reach the river. Opponents have also suggested that the production of resin acids and sterols has not been adequately dealt with. These have caused fish abnormalities and endocrine disruption.
Paul Sandery has said that the IIS does not take into account the lack of flushing as demonstrated by his survey.

Paul Sandery's submission
The Tasmanian Conservation Trust has said that the IIS does not contain any provisions for monitoring the effects of the effluent from the mill.
In an extraordinary blunder, Gunns Ltd have announced that there has been a mistake in their toxicology report and that the level of DIOXINS in the effluent is 45 times higher than previously stated although they will still come in under the guidelines. The mistake was discovered in August but has only just come to light which has led to accusations that Gunns Ltd, which posted the mistake on their web site but made no announcement, were hoping nobody would notice. On the radio on 20/9/06, Bob Gordon (head of the pulp mill task force) said that the first they knew about it was when they saw it on the Gunns website. Opponents now want more time to send in submissions to incorporate this new information. Submissions must be in by September 25th. However, the RPDC have refused saying that there will be public hearings at which these issues can be discussed.
This is an excerpt from the marine and wildlife section of the Tasmanian Department of Primary Industries and Water printed in the Mercury on 24/9/2006:

Toxicos fails to conclude or describe the risk to seals of bioaccumulating dioxins from exposure to pulp mill effluent. Evidence exists that the effect of exposure is significant, "therefore the Toxicos implication is misleading and their conclusion false". Toxicos states that dioxins are not significantly bioaccumulated by fish. This statement is profoundly inaccurate, misleading and directly contradictory to references cited by Toxicos and Toxicos statements. The method used to determine the risk of bioaccumulation in fish is inappropriate. The assessment using effluent concentration by Toxicos is invalid and misleading and all conclusions based on this information are unsubstantiated. Toxicos demonstrates a complete lack of understanding of the meaning of biomagnification.
The Australian on 9/8/2006 reports that a Californian study on frogs has found that while one chemical alone may do no harm in low doses, in conjunction with others, even in doses that are individually safe, it can do serious harm. The US Geological Service notes 'the potential effects of contaminant mixtures on people, aquatic life and fish-eating wildlife are still poorly understood'.
The Beca AMEC peer review is not happy with Gunns' IIS. It says there are many deficiences including no tests to see if the Chlorates in the effluent have a long term effect on Brown Algae. Chlorates are used by gardeners as weed killers. Brown Algae are at the bottom of the food chain so their demise could affect other animals up the food chain. The review also thinks that fish will be attracted to the outfall and feeding seals as well. Sharks around Tenth Island then eat the seals. Another critisism is that the outfall is situated on a colony of the endangered Gunns Screw Shell.
In the Mercury on 10/10/06 it is reported that the operator of the fish farm in Longreach has said in his submission that the fish may suffer because of disturbance of sediment during construction. He is also worried about the effect the noise and dust will have on the 30 employees who work at the fish farm.
Professor Eduardo Jaramillo of the Universidad Austral de Chile has visited Tasmania and given lectures on the cause of the environmental disaster near Valdivia. In early 2004, an ECF Kraft pulp mill with a capacity of 550,000 tonnes was started up. By the end of 2004 the resident Black-necked swans started dying or flying off, the plants in the river died and the river turned brown. Professor Jaramillo was asked to head an investigation into the causes. A comprehensive scientific study was conducted and the conclusions were:
* The swans died either of starvation because their plant food died or from heavy metal poisoning * The plants died because of high concentrations of heavy metals - Iron, Magnesium and Aluminium * The source of the heavy metals was the Kraft pulp mill (the same type as proposed at Longreach) * All other possible causes were investigated and rejected
In Chile, by law, the company building the mill had to conduct comprehensive baseline studies of the local environment. This enabled Professor Jaramillo to be able to pinpoint the cause of the problems. The company will now have to pay to restore the environment. Professor Jaramillo has recommended that comprehensive baseline studies are carried out before the Longreach mill is built or else it will be difficult to remedy problems that occur after.
So it is now apparent that the mill effluent has potential environmental consequences (and is not harmless as Gunns IIS has claimed- the inorganic salts can contain heavy metals). The effluent will be discharged 3kms offshore. In 1995, a ship hit Hebe Reef which is 3kms offshore. The resulting oil spill was washed onto the beaches, up the Tamar and all over the Fairy Penguins at Low Head. It was not washed away by currents and tides. What will happen to Gunns' effluent containing 120 tonnes a day of dissolved solids, 31 tonnes of colouring and 1.3 tonnes of suspended solids?
Supplementary IIS: There is a huge amount of analysis in the supplementary information supplied by Gunns Ltd which deals with concerns about penguins, seals, dolphins, birds and other creatures. More modelling has been done on the effluent plume and more tests using similar effluent on various plants and animals. These all come to the conclusion that there is insignificant risk to the marine habitat.
Comment: Others disagree with the conclusions and it has been noted that no further on-site monitoring has been undertaken. Criticisms include: The on-site monitoring has been inadequate. There have been no long term toxicology tests. The Toxicos report completely ignores the Sandery and CSIRO reports on lack of flushing. The probability of contamination of the Tamar estuary has been dismissed with no evidence and no on-site testing. Here are a couple of links to documents prepared by qualified scientists who find the Toxicos report to be incomplete:

29/5/2007: DIOXIN RISK UNDERESTIMATED BY 1400 TIMES - PROFESSOR
In a press release, Professor Andrew Wadsley said today that errors had been made in Gunns' IIS that could mean the dioxins in the receiving waters of Bass Strait could have been underestimated by a factor of 1400. He says that in his opinion, the effluent will breach the EPBC act. Toxikos, the firm responsible for Gunns' report, say they stand by their calculations.
Press release
10/6/2007: PENGUINS AT RISK FROM PULPMILL - Birds Tasmania
Birds Tasmania have said in their submission under the EPBC Act that the penguin colony at Low Head could be at risk from the pulpmill effluent. The number of penguins at the colony has decreased in recent years and the area where the effluent pipe discharges is part of their foraging zone. In 1995 an iron-ore carrier hit Hebe Reef 3kms out to sea. The resulting oil discharge covered many of the penguins in oil and washed right up the Tamar. To the credit of the local people who mounted a huge rescue effort, not one rescued penguin was lost. The effluent pipeline will discharge 2.7kms offshore.

Report prepared for fishing council

Stuart Godfey's letter to politicians and newspapers

19/7/2007: MALCOLM TURNBULL HAS A MAJOR PROBLEM
Federal Environment Minister has got himself into a bit of a mess. His website admits that he wrote to Gunns in March inviting a submission under the EPBC Act. In the recent Federal court case in Hobart it has come out that in April he asked for an assessment of possible damage to protected species from the effluent and the report came back that it was likely. So now how can any Minister with any integrity pass the mill? Mr.Turnbull will be wishing that he had done his homework before he rushed in and offered to help Gunns. Mr.Turnbull has a battle on his hands to hold on to his seat of Wentworth in the Federal election and his opponent will be waiting to see if he makes any mistakes and a decision against the advice of his own department could be fatal. So Mr.Turnbull has been looking for a third way - a desalinisation plant to remove harmful compounds from the effluent. But unfortunately for him there are problems there as well:
* First of all, the plant is likely to cost $250m. The Government would find it hard to justify spending that on a project in just one constituency that will be electorally unpopular with an election looming. * Second - it will cost a lot to run - perhaps $15m. a year. Who will pay? * Third - The process would result in nearly a hundred tonnes a day of toxic chemicals most of which dissolve in water. How do you get rid of those? * Finally - no large pulp mill in the World uses this option which suggests that it not an option and also means that it is not accepted technology and therefore would not be within the guidelines.
It could be that Mr.Turnbull is praying that the court case takes the decision out of his hands!

7/8/2007: PULP MILL EFFLUENT WILL POLLUTE TAMAR - CSIRO OCEANOGRAPHER
Retired CSIRO oceanographer Stuart Godfrey says that pollution from the pulp mill will be blown up the Tamar estuary by winds and that Gunns' calculations do not take in to account ocean stratification and are therefore hopelessly deficient. The SWECO report points this out but says it can be dealt with by using permits. But what if the work is done and unacceptable pollution is predicted? Will the mill construction be halted? It obviously needs to be sorted out before construction commences.

Dr.Stuart Godfrey

Gunns Ltd original submission to federal minister: While Gunns will undertake mitigation measures to avoid or minimise impacts, due to the scale of the project the possibility of impacts to threatened species and Commonwealth marine areas as a result of this project cannot be discounted at this stage.'

VERDICT: So Gunns have said that it could damage the environment in their federal submission but now say their tests say that this is unlikely. However, Professor Jarimillo's evidence is that there is the potential for damage and Dr Stuart Godfrey says that it will be blown right up the Tamar estuary.

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