VISY PULP AND PAPER PTY LTD
ENVIRONMENTAL ASSESSMENT FOR A MAJOR PROJECT
TUMUT MILL EXPANSION
436 Gadara Road, Tumut, New South Wales
January 2007
H:\Environmental\VPP9 Stage 2\Stage 2\FINAL EA SUBMISSION\Main Report\Visy Tumut Final Env Assessment Main Report.doc
Environmental Assessment Submission Under Part 3A of the Environmental Planning and
Assessment Act 1979
Statement by Authors
Environmental Assessment Prepared By:
Name
Ms Leanne Hayes
Company
Visy Pulp and Paper Pty Ltd
Position
Project Environmental Engineer
Qualifications
BSc Environmental Biology
Address
436 Gadara Road, Tumut, New South Wales, 2720
Co-authored and Reviewed By:
Name
Ms Alison McRae
Company
Peter J Ramsay and Associates Pty Ltd
Position
Associate
Qualifications
Bachelor of Engineering (Environmental), Bachelor of
Commerce
Address
3/538 Gardeners Road, Alexandria, New South Wales,
2015
Project Under Part 3A:
Application Number
06_0195
Development
Visy Pulp and Paper Tumut, Mill Expansion
Development Location
436 Gadara Road, Tumut, New South Wales, 2720
Proponent
Visy Pulp and Paper Pty Ltd
PO Box 98
Tumut, New South Wales, 2720
Certification:
I certify that I have prepared this Environmental
Assessment report and that to the best of my knowledge: it has been prepared in accordance with Part 3A of the Environmental Planning and Assessment Act and
Regulations; and the information contained in the report is neither false nor misleading.
Signature:
_________________
_________________
Name:
_________________
_________________
Date:
_________________
_________________
TABLE OF CONTENTS
Page
1. INTRODUCTION
1
1.1
Background and History of Project
1
1.2
Project Proponent
1
1.3
Project Rationale
2
1.4
Overview of Mill Expansion Proposal
4
1.5
Environmental Objectives of the Proposal
5
1.6
The Planning Context and Approval Process
7
1.7
Environmental Assessment Scope and Requirements
8
2. STRATEGIC ASSESSMENT
9
2.1
Project Need and Alternatives
9
2.2
Scale, Scope and Location
11
2.2.1 Raw Materials
12
2.2.2 Existing Infrastructure
12
2.2.3 Environmental Capacity of the Site
12
2.2.4 Waste Management Objectives
13
2.3
Environmental Performance of the Existing Mill
13
2.4
Accommodation of the Expansion
14
2.4.1 Physical Site Constraints
14
2.4.2 Existing Air Quality
15
2.4.3 Existing Traffic
15
2.4.4 Existing Odour Performance
15
2.4.5 Catchment for Wood and Wastepaper Supply
15
2.5
Project Implementation
16
2.6
Ecologically Sustainable Development Principles
16
2.7
Consequences of Not Proceeding
17
3. STATUTORY REQUIREMENTS
18
3.1
State Legislation
18
3.1.1 Environmental Planning and Assessment Act 1979
18
3.1.2 Environmental Planning and Assessment Regulation 2000
19
3.1.3 Protection of the Environment Operations Act 1997
19
3.1.4 Protection of the Environment Operations (Clean Air) Regulation 2002
19
3.1.5 Visy Mill Facilitation Act 1997
19
3.2
State Environmental Planning Policies
20
3.2.1 State Environmental Planning Policy (Major Projects) 2005
20
3.2.2 State Environmental Planning Policy No. 11 – Traffic Generating Developments
20
3.2.3 State Environmental Planning Policy No. 33 – Hazardous and Offensive Development 21
3.2.4 State Environmental Planning Policy No. 34 – Major Employment – Generating Industrial
Development
21
3.2.5 State Environmental Planning Policy No. 55 – Remediation of Land
21
3.3
Regional Environmental Plans
21
3.4
Local Environmental Plans
22
3.4.1 Tumut Local Environmental Plan 1990
22
3.5
Development Control Plans
22
3.5.1 Tumut Shire Council Development Control Plan No. 3 Car Parking
22
3.5.2 Tumut Shire Council Development Control Plan No. 6 Industrial Development
23
3.6
Commonwealth Legislation
23
4. CONSULTATION
25
4.1
NSW Department of Environment and Conservation
26
4.2
NSW Department of Health
26
4.3
NSW Roads and Traffic Authority
26
4.4
Tumut Shire Council
27
4.5
Visy Community Consultative Committee
27
4.6
Local Community
28
4.7
Other Stakeholders
28
4.8
Director-General’s Requirements
29
5. THE KRAFT PULP PROCESS
6. DESCRIPTION OF EXISTING MILL OPERATIONS
6.1
Existing Mill and Operations Summary
6.1.1 Location Setting
6.1.2 Existing Plant and Equipment
6.1.3 Production
6.1.4 Freshwater Use
6.1.5 Wastewater Generation and Irrigation
6.1.6 Power Generation and Consumption
6.2
Environmental Management
6.2.1 Compliance with Statutory Requirements
6.2.2 Environmental Management System
6.2.3 Complaints Management
6.2.4 Community Consultation and Involvement
6.2.5 Investment for Continuous Improvement
6.3
Environmental Monitoring
6.3.1 Wastewater Irrigation System Monitoring
6.3.1.1 Evaluation of the Existing Irrigation System
6.3.2 Air Emissions Monitoring
6.3.3 Ambient Air Monitoring
6.3.4 Odour Management
6.3.5 Noise Management
6.3.6 Waste Management
6.3.6.1 Solid Residue and Waste Management
6.3.6.2 Liquid Residue and Waste Management
6.3.7 Traffic and Transport
6.3.8 Cultural Heritage
6.3.9 Native Vegetation
7. DESCRIPTION OF MILL EXPANSION
7.1
Phased Installation
7.1.1 Phase 1 of Mill Expansion
7.1.2 Phase 2 of Mill Expansion
7.2
Fibre Supply and Storage
7.2.1 Sawmill Residues
7.2.2 Pulp Logs
7.2.3 White Pulp
7.2.4 Wastepaper
7.3
Wood Yard
7.4
Recycled Fibre Plant
7.5
Purchased White Pulp Processing Plant
7.6
De-inking Plant
7.7
Digester
7.8
Fibreline
7.9
Evaporation
7.10
Recovery Boiler
7.11
Recrystallisation Plant
7.12
Recausticising Process and Lime Kiln
7.13
Paper Machine
7.14
Gas Fired Boiler
7.15
Multi Fuel Boiler
7.15.1 Technology Selection
7.15.2 Fuel Sources
7.15.3 Quality Assurance and Quality Control Procedures
7.15.4 Fuel Preparation
7.15.5 Gasification and Combustion
7.15.6 Steam and Electricity Generation
7.15.7 Mass Balance Using Non-Standard Fuels
7.16
Natural Gas Turbine
7.17
Air Emission Control Technologies
7.17.1 Odorous Compounds
7.17.2 New Recovery Boiler
7.17.3 New Lime Kiln
7.17.4 New Multi Fuel Boiler
7.18
Chemical Storage and Usage
7.19
Water Supply
7.19.1 Water Treatment
7.20
Wastewater Generation, Treatment and Irrigation
7.21
Stormwater Management
7.21.1 Diversion of Up-gradient Stormwater
7.21.2 Uncontaminated Stormwater Drainage
7.21.3 Wood Yard Stormwater Drainage
7.22
Site Infrastructure
7.22.1 Site Layout and Access
7.22.2 Buildings and External Plant
BEST AVAILABLE TECHNIQUES
8.1
Best Available Techniques for Kraft Pulp Mills
8.2
Best Practice for Multi Fuel Boiler
8.3
Conclusions
ENVIRONMENTAL RISK ASSESSMENT
9.1
High Environmental Risks
9.2
Medium Environmental Risks
9.3
Low Environmental Risks
WATER SUPPLY AND MANAGEMENT
10.1
Water Supply and Management Summary
10.2
Water Availability and Acquisition
10.3
Impact of Additional Supply on Tumut River Flows
10.4
Comparison to BAT
WASTEWATER MANAGEMENT AND IRRIGATION
11.1
Wastewater Management
11.1.1 Upgrades to Wastewater Treatment Plant
11.1.2 Proposed Wastewater Quality
11.2
Comparison to BAT
11.3
Irrigation
11.3.1 Proposed Irrigation Strategy
11.3.3 Soil Investigation Survey
11.3.4 Impact Assessment/Evaluation of New Irrigation Strategy
11.4
Conclusions
AIR QUALITY
12.1
Statutory Requirements
12.2
Emissions to Atmosphere
12.2.1 Sources of Emissions
12.2.2 Existing Sources
12.2.2.1 Existing Recovery Boiler, Lime Kiln and Power Boiler
12.2.3 Proposed Sources – Phase 1 of Mill Expansion
12.2.3.1 New Recovery Boiler and Lime Kiln
12.2.3.2 Natural Gas Boiler
12.2.3.3 Stack 2 – Combined Emissions
12.2.4 Proposed Sources – Phase 2 of Mill Expansion
12.2.4.1 New Recovery Boiler and Lime Kiln
12.2.4.2 Multi Fuel Boiler
12.2.4.3 Stack 2 Combined Emissions
12.2.4.4 Gas Turbine
12.3
Comparison with Regulatory Limits
12.3.1 New Recovery Boiler and Lime Kiln
12.3.2 Natural Gas Boiler
12.3.3 Multi Fuel Boiler
12.3.4 Gas Turbine
12.4
Comparison to BAT
12.5
Multi Fuel Boiler Mass Balance
26.3.11 Winter Storage Dam Monitoring
26.3.12 Solid Waste Quality Monitoring
26.4
Summary of Mitigation Measures
26.4.1 Emissions to Air
26.4.2 Odorous Emissions
26.4.3 Noise Emission Control
26.4.4 Traffic Management
26.4.5 Irrigation Management
26.4.6 Chemical Hazards
26.4.7 Safety and Hazards
26.4.8 Fire Prevention
26.4.9 Solid Waste Generation
26.4.10 Construction Phase
26.4.11 Community Consultative Committee
26.5
Licensing and Approval Requirements
26.5.1 Principal Development Consent
26.5.2 NSW Department of Environment and Conservation
26.5.3 NSW Department of Natural Resources
26.5.4 Visy Facilitation Act 1997
26.5.5 Commonwealth Legislation
26.5.6 Local Government Law
27. DRAFT STATEMENT OF COMMITMENTS
27.1
Environmental Mitigation, Management and Monitoring
28. GLOSSARY
29. REFERENCES
Comparison to Regulatory Limits – New Recovery Boiler
156
Table 44
Comparison to Regulatory Limits – New Lime Kiln
156
Table 45
Comparison to Regulatory Limits – Stack 2
156
Table 46
Comparison to Regulatory Limits – Natural Gas Boiler
158
Table 47
Comparison to Regulatory Limits – Multi Fuel Boiler
159
Table 48
Comparison to Regulatory Limits – Gas Turbine
160
Table 49
Main Stack Emissions Compared to European BAT Standards
161
Table 50
Multi Fuel Boiler Emissions Compared to European Standards
162
Table 51
Partial Mill Shut Down Activities that can result in Odorous or other Air Emissions above the Normal Operating Level
164
Table 52
Annual Mill Shut Down Activities that may result in Odorous or other Air Emissions above the Normal Operating Level
Table 53
165
Process Upsets that can result in Odorous or other Air Emissions above the Normal
Operating Level
166
Table 54
Air Quality Impact Assessment Criteria
168
Table 55
Expected Emissions of Other Organic Species and Impact Assessment Criteria
169
Table 56
Maximum Ground Level Concentrations - Mill Expansion Phase 1
170
Table 57
Maximum Ground Level Concentrations - Mill Expansion Phase 2
172
Table 58
Potential Sources of Odorous Emissions
179
Table 59
Scenario 1 - Odorous Emission Sources and Odour Strength during Steady-state
Operations – Existing Mill (Based on 2006 Monitoring Data)
Table 60
180
Scenario 2 - Odorous Emission Sources and Odour Strength during Steady-state
Operations – Existing + Expanded Mill (Based on Projected Improvements to Condensate
System)
181
Table 61
DEC Odour Assessment Criteria Versus Population Density
184
Table 62
Predicted Odour Levels at the Nearest Residences
186
Table 63
Paper Machine Residue Composition (Including De-inking Sludge)
199
Table 64
Solid Waste Management for Expanded Mill Operations
200
Table 65
Solid Waste Quantities
201
Table 66
Liquid Waste Management for Existing and Expanded Mill Operations
203
Table 67
Comparison of Power Consumption with European BAT Standards
212
Table 68
Heavy Vehicle (“HV”) Traffic Increases and Level of Service after Phase 2 Expansion
214
Table 69
List of Chemicals to be Stored and Used at the Expanded Mill
220
Table 70
Employment by Industry Sector 1996 and 2001
227
Table 71
Level of Education by Non-school Qualification 1996-2001
234
Table 72
Potential Residual Environmental Risks Following Implementation of Control Measures for the Proposed Mill Expansion
255
Table 73
Proposed Monitoring for Stack 2 (Phase 1 and 2)
264
Table 74
Proposed Monitoring for Gas Turbine (Stack 3 in Phase 2 only)
264
Table 75
Proposed Source Monitoring for Recovery Boiler (Duct Point)
265
Table 76
Proposed Source Monitoring for Lime Kiln (Duct Point)
265
Table 77
Proposed Source Monitoring for Gas Fired Boiler (Phase 1) (Duct Point)
265
Table 78
Proposed Source Monitoring for Multi Fuel Boiler (Phase 2) (Duct Point)
266
Table 79
Testing Regime for Non-Standard Fuels Characterisation
269
Table 80
Proposed Monitoring of Combined Fuel for Multi Fuel Boiler
272
Table 81
Treated Wastewater Quality Monitoring
273
Table 82
Surface Water Monitoring Requirements and Frequency
274
Table 83
Proposed Frequency of Groundwater Level Monitoring
275
Table 84
Proposed Parameters and Frequency for Groundwater Quality
275
Table 85
Soil Monitoring Parameters and Frequency
276
Table 86
Proposed Monitoring for Dregs, Grits and Lime Mud for Land Application Purposes
277
Table 87
Proposed Monitoring of Multi Fuel Boiler Ash Streams
277
Table 88
Draft Statement of Commitments
287
LIST OF FIGURES
Figure 1
Visy Recycling – NSW Performance
Figure 2
Main Inputs and Outputs at a Typical Kraft Pulp Mill
Figure 3
3
32
3
Average Annual Freshwater Usage per Tonne of Paper Produced (m /tonne of paper produced) 2001 – 2006
Figure 4
37
3
Average Wastewater Generation per Tonne of Paper Produced (m /tonne of paper) from
2001-2006
37
Figure 5
Imported, Generated and Consumed Power Per Year 2001- 2006 (MW Ave)
39
Figure 6
Total Odour Complaints per Year 2001 - 2006
41
Figure 7
Total Number of Odour Complaints by Distance from the Mill June 2003 – June 2006
42
Figure 8
Winter Storage Dam Expansion Options
Figure 9
Mill Power Demand, Onsite Generation, Imported Power and Exported Power for Existing
126
Mill, Phase 1 and Phase 2 of Mill Expansion
206
Figure 10
Gas Usage for Existing Mill, Phase 1 and Phase 2 of Mill Expansion
206
Figure 11
Unit Processes for Life Cycle Analysis of Tumut Mill Expansion
207
Figure 12
GHG Emissions from Existing Mill Operations and Following Phase 1 and Phase 2 of Mill
Expansion
Figure 13
GHG Emissions from Manufacture of Kraft Liner at Tumut Mill for Existing Operations and
Following Phase 1 and Phase 2 of Mill Expansion
Figure 14
209
210
GHG Emissions from all Steps in Box Production Life Cycle from Paper Produced at
Tumut Mill from Existing Operations, Phase 1 and Phase 2 of Mill Expansion
211
Figure 15
Share of Income Generated by the South West Slopes Forest Industries 2002/2003
229
Figure 16
Average Annual Change in Population of Different Local Government Areas in the South
West Slopes, 1991 – 2001
233
Figure 17
Number of Approvals for New Residences 1999 – 2005
236
Figure F1
Visy Tumut’s Role in Visy’s Fibre and Energy Closed Loop
Figure F2
Mill Expansion Layout
Figure F3
Mill Location
Figure F4
Property Boundary
Figure F5
Mill Title Lots
Figure F6
Existing Site Layout
Figure F7
Existing Environmental Monitoring Locations
Figure F8
Air Emission Monitoring Points – Existing and Expansion
Figure F9
Inputs and Outputs of Expanded Mill
Figure F10 Water, Liquor and Wastewater Cycle – Mill Expansion
Figure F11 Stormwater Drainage from Existing Mill Site
Figure F12 Proposed Stormwater Layout – General Mill Area
Figure F13 Proposed Stormwater Layout – Wood Yard Area
Figure F14 Existing and Proposed Irrigation Areas
Figure F15 Proposed Areas for Irrigation
Figure F16 Soil Types and Suitability for Irrigation
Figure F17 Proposed Irrigation Layout based on Soil Suitability
Figure F18 Indicative Mass Balance for Proposed Multi Fuel Boiler Based on Combined Weighted
Average Fuel Composition
Figure F19 Location of Neighbouring Properties in Relation to Mill Site
Figure F20 Traffic Noise Monitoring Locations
Figure F21 Existing and Proposed View of Mill from Front Looking Towards Northeast
Figure F22 Existing and Proposed View of Wood Yard from Front
Figure F23 Photographs of Existing Mill from Snowy Mountains Highway and Batlow Road
Figure F24 Existing and Proposed View of Site from the East
Figure F25 Existing and Proposed View Looking West into Wood Yard
Figure F26 Existing and Proposed View of Site from the West
Figure F27 Proposed Mill Expansion Layout with Gas Pipeline
APPENDICES
VOLUME 1
Appendix A
Director General’s Requirements
Appendix B
Evaluation of Existing Irrigation System Operations
Appendix C
Ambient Air and Source Emissions Monitoring Summary – Existing Operations
Appendix D
Non-Standard Fuels Assessment Information
Appendix E
VEP-001- Environmental Aspects and Impacts Procedure
VOLUME 2
Appendix F
Soil Survey
Appendix G
Evaluation of Proposed Expansion of Irrigation System
VOLUME 3
Appendix H
Estimates of Species Emitted to Air
Appendix I
Multi Fuel Boiler Mass Balance
Appendix J
Start up, Shut Down and Process Upset Scenarios
Appendix K
Air Impact Assessment
Appendix L
Measurements of Lower Boundary Layer Structure
Appendix M
Odour Impact Assessment
VOLUME 4
Appendix N
Noise Impact Assessment
Appendix O
Truck Noise Impact Assessment
Appendix P
Greenhouse Gas Life Cycle Assessment
Appendix Q
Traffic Assessment
Appendix R
Preliminary Hazard Assessment
VOLUME 5
Appendix S
Health Risk Assessment
Appendix T
Re-assessment of Possible Aboriginal Scarred Tree
i
EXECUTIVE SUMMARY
Visy Pulp and Paper Pty Ltd (Visy), a division of Visy Industries Pty Ltd, obtained Development
Consent from the Minister for Urban Affairs and Planning (now Minister for Planning) on
29 November 1998, for the staged development of the Visy Kraft Pulp and Paper Mill at 436
Gadara Road, Tumut, NSW. The consent was issued for the existing operations with capacity of up to 300,000 tonnes per year (tpy) and an increase up to 450,000 tpy for the future mill expansion. Construction of the existing mill commenced in January 2000 and was completed in May 2001.
The official Commissioning period ended on 15 May 2002 and the mill has now been operating for over five years. Visy seeks to increase paper production from the currently approved
300,000 tpy to 700,000 tpy. While the existing Development Consent permits an increase in paper production to 450,000 tpy, a new approval is required to increase paper production to
700,000 tpy. Visy is therefore seeking approval for the proposed expansion of the mill, and has prepared this Environmental Assessment (EA).
On 24 July 2006, the Minister for Planning authorised Visy to submit a Concept Plan for the expansion of the existing pulp mill to increase production of Kraft liner to 700,000 tpy. The expansion will be phased, as determined by production requirements, and will include the installation of an additional paper machine and pulping capacity. This EA has been prepared to satisfy the requirements for the concurrent assessment and granting of a Concept Approval and of an Approval for the project described in this report to commence immediately upon granting of the approval. The approval granted for the project will apply to all aspects of the project except for the use of non-standard fuels in the multi fuel boiler. For the purposes of this EA, Visy is seeking Concept Approval only for this aspect of the project, and will seek full approval at a later date.
During Phase 1 of the expansion, an additional paper machine will be installed to allow immediate increase in production to 700,000 tpy. The pulp mill components will effectively be duplicated and it is expected that this phase of the expansion will be operational by 2009. The timing and extent of Phase 2 of the expansion will be determined by production requirements.
The estimated cost of the phased expansion of the mill is $375 million. This amount will bring the overall investment in the plant to over $750 million, and see a further 50 direct jobs created at the mill and a further 350 flow-on jobs in supply and service activities. Construction of the initial phase of the mill is expected to generate up to 500 jobs at its peak.
ii
Project Proponent
Visy Industries is the world’s largest privately owned packaging and recycling company with its headquarters in Melbourne, Australia. Visy operates from approximately 130 sites and employs approximately 5,500 staff across Australia, New Zealand and South East Asia. The company manufactures packaging products from paper, plastic, steel and aluminium and operates
Australia’s most extensive network of recycling facilities, collecting and reprocessing more than
1.5 million tonnes of used materials a year. There are also more than 60 paper and board manufacturing sites in the USA employing a further 2,000 personnel.
Visy Pulp and Paper (Visy) is the proponent for the expansion of the Tumut mill.
Project Rationale and Objectives
Visy is committed to sustainable development. The company seeks to continue to grow its packaging manufacturing and recycling operations in a manner that enhances the community and the environment. Further development of Visy Tumut will support community and
Government goals by expanding the domestic market for waste paper, will provide economic development in the region through export opportunities and will achieve clean-production and manufacturing excellence.
Visy’s over-riding corporate philosophy is a commitment to recycle and re-utilise all products and energy that can feasibly be utilised in its paper and packaging manufacturing business.
The primary objective of the development is to expand the existing integrated plantation softwood based pulp and paper mill in Tumut, so that Visy can continue to recycle paper in
Australia without the need to import Kraft liner. The mill will further supply Visy Board with Kraft liner for its corrugated packaging plants in Australia, and will also export Kraft liner thereby further improving Australia’s balance of trade in the Kraft liner market.
The Planning Context
The Environmental Planning and Assessment Act 1979 (the EPA Act) is the key planning legislation in NSW, and defines the mechanism by which to obtain development consent for a project. The State Environment Planning Policy (SEPP) (Major Projects) 2005 defines developments that are considered to be Major Projects and for which Part 3A of the EPA Act applies. iii
As indicated earlier, the mill expansion will have a capital investment of more than $30 million for the purposes of the manufacture of paper pulp, and also involves paper recycling. The expansion is therefore captured under Schedule 1, Group 1, Section 4 (b) of the SEPP (Major
Projects) 2005 as a Major Project. In view of this, Part 3A of the EPA Act applies.
In May 2006 Visy sought approval from the Minister of Planning to submit a Concept Plan for the mill expansion. Authorisation of the submission of a Concept Plan under Section 75M(1) of the EPA Act was given by the Minister on 24 July 2006. Approval of the Concept Plan will allow
Visy to commence specified aspects of the development on receipt of the approval. An Approval for the project as described in this EA is also sought, with the exception of the use of nonstandard fuels in the multi fuel boiler. Visy is seeking Concept Approval only for the use of these fuels and will seek full approval at a later date.
Consultation
Visy’s consultation with stakeholders including regulatory agencies and the local community has been on-going since the earliest days of project development for the existing mill, and included the prospect of an expansion of the project. The consultation process has included the regular monthly meetings of the Visy Community Consultative Committee, and also frequent meetings with regulatory agencies such as the Department of Environment and Conservation.
Consultation and/or briefings were undertaken with the following parties during the preparation of this EA:
•
NSW Premier’s Department;
•
NSW Department of State and Regional Development;
•
NSW Department of Environment and Conservation;
•
NSW Department of Health;
•
NSW Department of Energy Utilities and Sustainability;
•
Commonwealth Department of Industry, Tourism and Resources;
•
Roads and Traffic Authority;
•
Tumut Shire Council;
•
Visy Community Consultative Committee;
•
Brungle Tumut Local Aboriginal Land Council; and
•
The local community.
iv
Existing Mill Operations
The existing mill operations in Tumut commenced in 2002 (post commissioning) and the mill was designed to incorporate Best Available Techniques (BAT) for all environmental aspects of operation including air emissions, energy and water use. The mill operates under some of the most stringent environmental limits in NSW in the Protection of the Environment Operations
(POEO) Licence issued by the NSW DEC for the site and Development Consent Conditions issued by NSW Department of Planning. The mill has proven to meet these limits with some exceptions due to process upsets, however none of these have adversely impacted upon the health of the local community and environment.
The mill generates 70% of its own energy from renewable resources and is highly water efficient, irrigating all treated effluent onto dedicated and managed pastures. It has received numerous awards for exemplary performance during its years of operation. Ongoing environmental monitoring and management is a key component of the mill operations, in addition to local community consultation.
Mill Expansion
Visy will expand the existing facility at Tumut by installing a second paper machine and associated pulping capacity. The expanded plant will produce Kraft liner board of various grades and white top liner. A phased approach is planned for the mill expansion which will enable some plant components to be installed immediately, with others being progressively installed over time to allow flexibility of product output to match projected market demand. The phasing will not however affect the timing of achievement of the 700,000 tpy paper production which is expected to be met within five years of commissioning of the expansion.
The exact phasing of the proposal in terms of the combination and timing of the installation of the components at each phase will be determined by production requirements. Therefore, prospects for Phase 2 may be brought forward to Phase 1.
Visy will initially install a new paper machine and pulp production line in Phase 1. The wood yard will be expanded to allow for the increased tonnage of pulpwood, sawmill chips and boiler fuel. The mill will continue to operate 24 hours per day, 7 days per week with provision for chipping and debarking operations in the wood yard to also occur continuously 24 hours per day, 7 days per week.
v
In Phase 2, Visy will install a number of additional components to meet product output requirements. These comprise a multi fuel boiler, natural gas turbine, de-inking plant and digester. All other operating parameters will not change from Phase 1 of the expansion. These include mill production, type of fibre resources utilised, water consumption and wastewater generation. The expanded mill operations will incorporate BAT to minimise environmental impacts and optimise performance.
The proposed multi fuel boiler will be fuelled with non-standard fuels, comprising paper residues and urban wood residues. As Visy is seeking Concept Approval only for the multi-fuel boiler, a separate assessment of the proposed non standard fuels will be conducted in accordance with the DEC Guidance Note for the Assessment of Non-standard Fuels (DEC 2005a) at a later date when full approval is sought.
Key Environmental Issues
Air
An air quality assessment, including dispersion modelling of the emissions to air from the proposed expansion, has been performed for the EA. The assessment has demonstrated that emissions to air from the new sources at the expanded plant will be in compliance with the
POEO (Clean Air) Regulation, and the cumulative impact of the existing and expanded operations will meet the NSW impact assessment criteria for air emissions at ground level.
Odour
The odour impact assessment demonstrates that odour control measures proposed for the expanded mill are expected to maintain or improve odour impacts compared to current levels.
Visy commits to continued vigilance in odour management for the expanded mill operations.
Improvement in the control of odorous emissions will occur as a result of new processes and technology which are proposed for the mill expansion such as Vapour Compression
Evaporation. This will assist in reducing odorous compounds in the clean condensate thereby reducing odours from areas of the mill which use clean condensate such as the cooling towers, paper machine and cooling ponds.
Odours may however be experienced from the mill for short periods during start up, shut downs and process upsets, however Visy will adopt control measures similar to those that have been developed for the existing operations to reduce the impacts from these events.
vi
Noise
The results of the noise assessment performed for the EA have shown that the expanded mill will require higher day and night time noise limits to be incorporated into the POEO licence and reflected in the development consent conditions. The reason for the required higher noise limits is to accommodate night time operation of the chipping and debarking systems in the wood yard, increased on-site traffic, including mobile equipment, and also the effect of enhanced meteorological conditions. Specific engineering controls will be implemented to minimise noise impacts and ensure compliance with the new proposed limits.
The potential impact of truck noise resulting from the mill expansion is not considered to be extensive or excessive. Any impacts at other locations than currently impacted, where the additional traffic generated by the mill expansion may cause disturbance can be mitigated using a truck management plan.
Water and Wastewater
Additional water will be required for the mill expansion, and Visy will seek to secure, on the existing water market, additional high security water entitlements of up to 1,076 ML per annum, to be attached to the existing high security water licence. There may also be opportunities to secure additional general security water entitlements as a contingency measure. The proportion of the river flow that will be removed from the Tumut River to meet the demands of the expanded mill will increase from the current 0.11% of average annual flows to 0.19% of average annual flows. This change is considered to be an insignificant amount on the overall River’s flows. The expansion of the wastewater irrigation system will not have any adverse impacts on soil, groundwater or surface waters of the Pratt Pastoral farm. The assessment of impacts indicates that the employment of best management practices will ensure the long term sustainability of the irrigation system under various climate conditions. Continual monitoring will ensure, should there be any impacts detected, that irrigation practices will be modified. Additional contingency areas will also be considered to ensure long term sustainability of the system.
vii
Waste Management
The Kraft process involves a high level of residue reuse including recycling of pulping chemicals, energy production from process byproducts and water recycling. Nevertheless there is a considerable remaining stream of solid waste that will require disposal to landfill in the absence of alternative uses. There will be an increase in solid waste production as a result of the mill expansion, however the rate of solid waste generation per tonne of paper will not increase and may decline marginally. Visy will continue to investigate beneficial reuse opportunities for all residues and wastes from the mill.
Traffic and Transport
The assessment of traffic and transport impacts associated with the mill expansion has shown that there will be an increase in heavy vehicles on local and regional roads. However, the increase can be accommodated without any significant change to the Level of Service of these roads, which will remain acceptable after the fully expanded mill is commissioned. The overall impact on these main roads is considered to be in line with growth in the region. Visy will continue to collaborate with other regional industries and authorities to achieve general road upgrades and maintenance improvements within the Tumut Shire and adjoining areas.
Hazard
Based on the hazardous materials inventory and preliminary risk screening, the proposed expansion of the Tumut mill is classified as a potentially hazardous and/or potentially offensive development under the SEPP No. 33 – Hazardous and Offensive Development (SEPP 33). A
PHA was therefore required to assess the hazards associated with the proposed development.
The PHA identified a number of scenarios with high or moderate risk of on-site or off-site impacts but determined that the proposed expansion would not pose an unacceptable risk of fatality, injury and/or damage to any of the adjacent land uses.
One scenario was identified with an extreme risk of on-site fatality or injury during the construction phase of the mill expansion due to the isolation of emergency systems. The analysis also identified a number of high risk scenarios with the potential for fatality or injuring during construction, commissioning, start up and shut down of the mill expansion. Several risk management and mitigation strategies have been recommended to minimise this risk. Visy will incorporate the recommended strategies into management of the construction, commissioning and operational phases of the proposed mill expansion to reduce the potential risks identified.
viii
Health Risk Assessment
The results of the Human Health Risk Assessment performed for the EA indicate that there is minimal likelihood of either acute or chronic exposures to the emissions from the existing mill, or to emissions from the proposed expansions, causing direct health effects.
Environmental Management and Monitoring
Visy proposes a detailed environmental management and monitoring program for the expanded mill, covering all environmental aspects including air, water and noise. Further, the health risk assessment will be reviewed and updated following the gathering of data during the operation of the expanded mill to validate the assessment undertaken as part of the EA.
ix
LIST OF ABBREVIATIONS
AD
Air Dried
ARI
Average Recurrence Interval
BAT
Best Available Techniques
BFB
Bubbling Fluidised Bed
BLS
Black Liquor Solids
BOD
Biological Oxygen Demand
BTLALC
Brungle Tumut Local Aboriginal Land Council
CAPER
Clean Air (Plant and Equipment) Regulation 1997
CCA
Copper Chromium Arsenic
CEMP
Construction Environmental Management Plan
CEMS
Continuous Emissions Monitoring System
CLBAR
Contaminant Limited Biosolids Application Rate
CMR
Compost Manufacturing Residues
COD
Chemical Oxygen Demand
CP
Centre Pivot
CSU
Charles Sturt University
DA
Development Application
dB(A)
Decibel (A weighted)
DCP
Development Control Plan
DEC
NSW Department of Environment and Conservation
DO
Dissolved Oxygen
DoP
NSW Department of Planning
DTW
Depth to Water
EA
Environmental Assessment
EC
Electrical Conductivity
EET
Emissions Estimation Technique
EF
Emissions Factor
x
EIA
Environmental Impact Assessment
EIS
Environmental Impact Statement
EMS
Environmental Management System
EPA
Environment Protection Authority
EPA Act
Environmental Planning and Assessment Act 1979
EPA Regulation
Environmental Planning and Assessment Regulation 2000
EPBC Act
Environment Protection and Biodiversity Conservation Act 1999
ESD
Ecologically Sustainable Development
ESP
Electrostatic Precipitator
EU
European Union
GCL
Geosynthetic Clay Liner
GGAS
Greenhouse Gas Abatement Scheme
GHG
Greenhouse Gas
GLC
Ground Level Concentration
ha
Hectares
HCl
Hydrogen Chloride
HF
Hydrogen Fluoride
HHRA
Human Health Risk Assessment
HRSG
Heat Recovery Steam Generator
HI
Hazard Index
HQ
Hazard Quotient
HV
Heavy Vehicle
HVLC
High Volume Low Concentration
ID
Induced Draft
IPPC
Integrated Pollution Prevention and Control
kL
Kilolitre
kWh
Kilowatt Hours
LCA
Life Cycle Assessment
LEP
Local Environmental Plan
xi
LGA
Local Government Area
LoS
Level of Service
LVHC
Low Volume High Concentration
MC
Medium Consistency
MEE
Multiple Effect Evaporator
ML
Megalitre
MRET
Mandatory Renewable Energy Target
MW
Megawatt
NCG
Non-Condensable Gas
NMHC
Non Methane Hydrocarbons
NO2
Nitrogen Dioxide
NOx
Oxides of Nitrogen
NPI
National Pollutant Inventory
OEMP
Operational Environmental Management Plan
ORER
NSW Office of Renewable Energy Regulator
PAH
Polyaromatic Hydrocarbons
PHA
Preliminary Hazard Analysis
PJ
Petjoules
PM
Particulate Matter
POEO Act
Protection of the Environment Operations Act 1997
POEO (Clean Air) Regulation
Protection
of
Regulation 2002
PVC
Polyvinyl Chloride
QA/QC
Quality Assurance/Quality Control
REP
Regional Environment Plan
RTA
Roads and Traffic Authority
SBR
Sequencing Batch Reactor
SBT
Sludge Balancing Tank
SEPP
State Environment Planning Policy
the
Environment
Operations
(Clean
Air)
xii
SHT
Soft Hose Traveller
SNCR
Selective Non Catalytic Reduction
SO2
Sulfur Dioxide
SOx
Sulfur Oxides
SWS
South West Slopes
TDS
Total Dissolved Solids
THC
Total Hydrocarbons
TJ
Terrajoules
tpy
Tonnes per Year
TRS
Total Reduced Sulfides
TSP
Total Solid Particles
TSS
Total Suspended Solids
UWR
Urban Wood Residues
Visy
Visy Pulp and Paper Pty Ltd
VCCC
Visy Community Consultative Committee
VCE
Vapour Compression Evaporator
VOC
Volatile Organic Compounds
VP3
Visy Pulp and Paper Smithfield NSW (paper machine 1)
VP4
Visy Pulp and Paper, Coolaroo VIC (paper machine 1)
VP5
Visy Pulp and Paper, Coolaroo VIC (paper machine 2)
VP6
Visy Pulp and Paper Smithfield, NSW (paper machine 2)
VP9
Visy Pulp and Paper Tumut (existing paper machine)
VP10
Visy Pulp and Paper Tumut (proposed paper machine)
WaSim
Water Simulation Model
WSAC
Wet Surface Air Condenser
WWTP
Wastewater Treatment Plant
1
1.
INTRODUCTION
1.1
Background and History of Project
Visy Pulp and Paper Pty Ltd (Visy), a division of Visy Industries Pty Ltd, obtained Development
Consent from the Minister for Urban Affairs and Planning (now Minister for Planning) on
29 November 1998, for the staged development of the Visy Kraft Pulp and Paper Mill at 436 Gadara
Road, Tumut, NSW.
The Minister for Urban Affairs and Planning determined the Development Application (DA) under
Sections 91 and 91AB of the Environmental Planning and Assessment Act 1979 (the EPA Act). The consent was issued for the existing operations with capacity of up to 300,000 tonnes per year (tpy) and an increase up to 450,000 tpy for the future mill expansion.
Construction of the existing mill commenced in January 2000 and was completed in May 2001. This was followed by the commissioning phase during which balancing of the mill process was undertaken. Each section of the mill had to be commissioned sequentially so that it could provide the necessary inputs to the subsequent section of the process. The commissioning phase presented challenges primarily in the area of odour management. Upgrades to the process have been in the order of >$8 million to date in order to achieve the odour performance committed to by
Visy. The official Commissioning period ended on 15 May 2002 and the mill has now been operating for over five years. An outline of the existing operations is provided in Section 6.
Visy seeks to increase paper production from the currently approved 300,000 tpy to 700,000 tpy as a result of the mill expansion. While the existing Development Consent permits an increase of paper production to 450,000 tpy, a new approval is required to increase paper production to
700,000 tpy. A brief description of the mill expansion is provided in Section 1.4.
For the purposes of this document, the expressions “paper”, “Kraft paper”, “Kraft liner” and
“paperboard” are essentially interchangeable, as they all refer to the industrial grade paper produced by this mill.
1.2
Project Proponent
Visy Industries is the world’s largest privately owned packaging and recycling company with its headquarters in Melbourne, Australia.
2
Visy operates from about 130 sites and employs about 5,500 staff across Australia, New Zealand and South East Asia. The company manufactures packaging products from paper, plastic, steel and aluminium and operates Australia’s most extensive network of recycling facilities, collecting and reprocessing more than 1.5 million tpy of used materials. There are also more than 60 paper and board manufacturing sites in the USA employing a further 2,000 personnel. The following divisions make up Visy:
•
Visy Recycling: collects, sorts, and reprocesses recyclable materials to form raw materials for new end products.
•
Visy Pulp and Paper: produces virgin Kraft and recycled paper for the packaging and building industries. •
Visy Board: manufactures corrugated cardboard boxes from recycled and virgin Kraft paper
•
Visy Specialities: produces point of sale displays, specialty cartons and heavy duty industrial packaging and paper products.
•
Visy Beverage: produces a range of paper, plastic and aluminium containers mainly for the beverage industry.
•
Visy Food: produces steel cans and lightweight plastic containers for the food industry.
Visy Pulp and Paper Pty Ltd (Visy) is the proponent for the development.
1.3
Project Rationale
Visy’s Corporate Strategy – A Genuine “Closed Loop”
Visy is committed to sustainable development. The company seeks to continue to grow its packaging manufacturing and recycling operations in a manner that enhances the community and the environment. Further development of Visy Tumut will support community and Government goals by expanding the domestic market for waste paper, will provide economic development in the region through export opportunities and will achieve clean-production and manufacturing excellence. Visy’s over-riding corporate philosophy is a commitment to recycle and re-utilise all products and energy that can feasibly be utilised in its paper and packaging manufacturing business. For example, Visy Recycling currently operates to recycle over 94% of all materials collected from the
Sydney waste stream through the various types of infrastructure designed to capture such materials
(refer to Figure 1).
3
There are major opportunities for additional investment in resource recovery and recycling in areas such as wood residue, waste paper, plastics, mill residues, glass and metals. Visy has a large capacity for undertaking new recycling/manufacturing investment within NSW if it can ensure a stable supply of feedstock from the waste stream.
In addition, and consistent with its closed-loop philosophy, Visy is committed to being as energyefficient and water-efficient as possible. This includes, where feasible, installing new capacity to generate energy from materials otherwise consigned to landfill or other non-use fates.
Waste to other recycling means or landfill
(3,350,000 tpa)
Domestic and commercial users
(4,000,000 tpa waste)
Visy Board, Visy Pak
Our contribution to fiber recycling
Packaging manufacturing Wood
Residues
Figure 1
Visy Recycling/Visy Paper
Re-cycle paper and packaging Visy Recycling
Visy
Recycles
~94% of its
NSW
Collections
Local
Manufacture
78%
Tumut’s Role in the Strategy
The original stimulus for the Tumut pulp and paper mill was the ready supply of a sustainable fibre resource (plantation pines, and sawmill residues) and the need to inject virgin paper fibre into the
Australian paper manufacturing sector.
Since its commissioning in 2001, Visy Tumut has successfully stimulated the Australian and regional plantation-based economy by providing:
a) Over 1000 new jobs, many of which are regionally-based;
4
b) Markets for plantation and sawmill residues otherwise wasted;
c) The replacement of approximately 300,000 tpy of imported Kraft paper with domestic production; d) Linkage with city-based paper recycling mills for feedstock and residue management;
e) New investment in plantation expansion both through Forests NSW and private growers; and
f)
Utilisation of urban wood residues (UWR) for energy production, leading to landfill avoidance and green energy supply.
The scope for the Tumut plant to meet a number of major Government environmental objectives is demonstrated by the flow chart shown in Figure F1. These include:
a) Waste reduction;
b) Landfill avoidance;
c) Renewable energy production;
d) Greenhouse gas abatement;
e) Sustainable regional development;
f)
Plantation timber development;
g) New manufacturing investment; and
h)
1.4
Domestic manufacturing of previously imported goods.
Overview of Mill Expansion Proposal
On 24 July 2006, the Minister for Planning authorised Visy to submit a Concept Plan for the expansion of the existing pulp mill at Tumut, NSW, to increase production of Kraft liner to
700,000 tpy, for both the local and overseas markets. The expansion will be phased, as determined by production requirements, and will include the installation of an additional paper machine and pulping capacity. This Environmental Assessment (EA) has been prepared to satisfy the requirements for the concurrent assessment and granting of a Concept Approval and of an
Approval for the project described in this report to commence immediately upon granting of the approval. The approval granted for the project will apply to all aspects of the project except for the use of non-standard fuels in the multi fuel boiler. For the purposes of this EA, Visy is seeking
Concept Approval only for this aspect of the project, and will seek full approval at a later date.
During Phase 1 of the expansion, an additional paper machine will be installed to allow immediate increase in production to 700,000 tpy. The current pulp mill components will effectively be duplicated to allow for the increase in pulp production. It is expected that this phase of the expansion will be operational by 2009.
5
The timing and extent of the future phase of the expansion (Phase 2) will be determined by production requirements. While production of 700,000 tpy of Kraft liner will continue during this phase, the proportion of wastepaper in the fibre mix will be increased so that a portion can be deinked to produce white pulp for white liner production.
The estimated cost of both phases of the mill expansion is $375 million. This amount will bring the overall investment in the plant to over $700 million, and see a further 50 direct jobs created at the mill and a further 350 flow-on jobs in supply and service activities. Construction of the initial phase of the mill is expected to generate up to 500 jobs at its peak.
A detailed description of the mill expansion is provided in Section 7.
1.5
Environmental Objectives of the Proposal
The primary objective of the development is to expand the existing integrated plantation softwood based pulp and paper mill in Tumut, so that Visy can continue to recycle paper in Australia without the need to import Kraft liner. The mill will further supply Visy Board with Kraft liner for its corrugated packaging plants in Australia, and will also export Kraft liner thereby further improving Australia’s balance of trade in the Kraft liner market.
6
The above primary objective would be achieved while also considering the following environmental, economic and social objectives.
Environmental Objectives
Continue to maintain a high level of environmental standards at the Tumut mill with particular regard to the effects upon the surrounding land and community.
Visy has demonstrated this while operating the existing mill through commitment to continual improvements to the process and plant design. In order to achieve this environmental objective the following would occur:
•
Continue to minimise water use through a high level of water recycling within the process;
•
Minimise the impacts of air and noise emissions on the immediate community through appropriate operations management and engineering controls;
•
Continue to investigate waste minimisation, recycling and reuse options for the process by-products produced by the mill;
•
Continue to limit any adverse impact on the biological environment including terrestrial and aquatic flora and fauna; and
•
Minimise adverse impact on the visual environment.
Economic Objectives
•
To continue producing an internationally competitive product and maintain and enhance Visy’s position in the international pulp and paper market.
•
Continue to produce a virgin fibre dominated product to enable Visy to continue to recycle paper in
Australia.
Social Objectives
Limit any adverse impacts on adjoining land uses and provide additional employment opportunities within the region.
In order to achieve this social objective, the following would occur:
•
Continue to develop employment and training opportunities particularly for the local community;
•
Minimise adverse impact from mill operations on neighbouring properties in terms of air, odour and noise emissions; and
•
Minimise adverse impact of traffic on the local community and road network.
7
1.6
The Planning Context and Approval Process
The EPA Act is the key planning legislation in NSW, and defines the mechanism by which to obtain development consent for a project. The State Environment Planning Policy (SEPP) (Major Projects)
2005 defines developments that are considered to be Major Projects and for which Part 3A of the
EPA Act applies.
As indicated earlier, the mill expansion will have a capital investment of more than $30 million for the purposes of the manufacture of paper pulp, and also involves paper recycling. The expansion is therefore captured under Schedule 1, Group 1, Section 4(b) of the SEPP (Major Projects) 2005 as a
Major Project. In view of this, Part 3A of the EPA Act applies.
In May 2006 Visy sought approval from the Minister of Planning to submit a Concept Plan for the mill expansion. Authorisation of the submission of a Concept Plan under Section 75M(1) of the EPA
Act was given by the Minister on 24 July 2006. Approval of the Concept Plan will allow Visy to commence specified aspects of the development on receipt of the approval. An Approval for the project as described in this EA is also sought, with the exception of the use of non-standard fuels in the multi fuel boiler. Visy is seeking Concept Approval only for the use of these fuels and will seek full approval at a later date.
The Concept Approval approach is required for Visy Tumut’s future expansion as it is necessary to have up-front certainty for this project as it develops over time. The facility itself is a complex one, which also exists within a complex wider framework. For example, the plant is exposed to changes in the relative availability of recycled paper fibre and virgin fibre, respectively. In addition, important factors such as transport, which are external to the facility itself but which have a major bearing on long-term cost competitiveness and regional impacts, need to be taken into account during the project’s medium to longer term development.
The Director-General on behalf of the Minister prepared environmental assessment requirements for the proposal (Director-General’s Requirements), and these were received on 6 July 2006 (refer to Section 4.8). Visy subsequently prepared this EA report, including a statement of the commitments that Visy is prepared to make for environmental management and mitigation measures at the site. Visy has been able to thoroughly assess the potential environmental impacts of the mill expansion.
8
Once the EA has been accepted by the Director-General, it is to be made publicly available during which time members of the public may make written submissions regarding the project. The
Director-General is to provide a report to the Minister for consideration of Visy’s application for approval for the mill expansion. The Minister may then approve or reject the proposal.
1.7
Environmental Assessment Scope and Requirements
The Environmental Impact Statement (EIS) for the existing mill dealt with a number of key environmental aspects for the mill development. For example, a 50% increase in traffic generation, energy and steam demand, water consumption and mill effluent production was predicted for the mill expansion compared to the existing operations. The mill expansion was assumed at that time to bring the total site production of paper up to 450,000 tpy. Subsequent to the original EIS, research into market requirements indicates a greater demand for virgin Kraft liner in the export market. As such, the mill expansion aims to bring the total site paper production to 700,000 tpy.
This EA report includes a description of the mill expansion, a review of existing mill operations and an assessment of the main impacts associated with the proposed expansion.
Assessment of the following key impacts has been conducted in association with the increased production capacity:
•
Air and odour emissions - due to an increase in emissions as a result of increased production;
•
Noise emissions - due to the addition of plant and equipment;
•
Traffic - due to increased input and output tonnages associated with increased production;
•
Groundwater, surface water and soil – due to increase in volume of effluent produced and additional area required for irrigation; and
•
Hazards – due to additional plant, equipment and services on the site.
It is important to note that the original EIS assessed the potential impacts on a greenfield site. This included heritage and flora and fauna, and therefore these areas do not require further assessment because the mill expansion will be within the area assessed for the original mill development including the area set aside for irrigation of the additional effluent quantity on the southern side of the Snowy Mountains Highway.
9
2.
STRATEGIC ASSESSMENT
2.1
Project Need and Alternatives
The potential for future expansion of the Tumut facility was part of Visy’s strategic purpose when it commenced development of the original project in 1998.
The initial Environmental Impact Statement included the following statement:
“…Visy proposes to build an integrated pulp and paper mill at Tumut to produce Kraft paper for both local and overseas markets. The mill will be constructed in two stages, commencing with the establishment of a fully operational 300,000 tonne/yr facility by the end of the Year 2000. …. the timing of the second stage of the development is dependent upon several factors including the availability of additional secure supply sources and access to suitable markets….” (Nolan-ITU 1998)
At that time it was considered that because a high proportion of Australia’s manufactured paperbased packaging materials were being made from recycled feedstock, there was a need to introduce virgin fibre into the paper packaging product stream. This was to ensure the strength of packaging was maintained. Also, because a significant proportion of waste paper still finds its way into landfills rather than recycling streams. This situation has not changed significantly since 1998
(Productivity Commission 2006).
However, as well as satisfying part of Australia’s domestic market for paper packaging material, the expanded mill will have an increased export focus, taking advantage of growing overseas market opportunities for competitively-priced Kraft paper.
By far the major use for Tumut’s Kraft paper is in the manufacture of corrugated boxes. Other uses are in plasterboard sheet and other liners. There is a clear and growing demand for Kraft paper on the world market. For example, Visy has recently begun supplying Kraft paper from its existing
Tumut paper mill into the growing export markets of Asia, Africa, Europe and North America. In financial year 2005-2006, the volume of Kraft paper sold by Visy on export markets was
125,000 tonnes, representing more than 42 percent of the Tumut mill’s production. From this direct market exposure, Visy has established firm market relationships with box-manufacturing companies for long-term supply of large volumes of Kraft paper in all these markets.
10
In addition to direct market experience, Visy has commissioned expert market analyses on the current and future trends in demand for Kraft paper in key world markets. These market analyses include Global Packaging Trend Analysis, Pöyry Forest Industry, November 2006, and Linerboard
Cost Competitiveness, Pöyry Forest Industry, November 2006. Both reports form part of the input into the commercial and market feasibility analysis for the project and are commercial-in-confidence to
Visy Pulp & Paper. Conclusions from these analyses relevant to the question of justification of the scale of the project in terms of the long term market demand include:
•
Asia’s total usage of Kraft liner board is in excess of 1.2 million tpy, and in the key markets that
Visy have identified the total usage including Asia is in excess of 10.5 million tonnes.
•
Growth in corrugated board production in China grew by 14 per cent per annum between 2000
(when the Tumut mill was commissioned) and 2005. The second highest annual growth was around 8 per cent in Thailand.
•
During the five years to 2005, European corrugated board production rose by around 1 per cent per annum in Western Europe and by almost 12 per cent per annum in Eastern Europe.
•
In most countries (except the US) the unit weight of corrugated board is declining due to a demand for greater cost competitiveness and greater ‘fitness for purpose’ in engineered solutions. This will provide a significant additional market opportunity for the second Tumut paper machine’s production of multi-grade Kraft liner.
•
There is a growing trend – particularly in Europe but also in other regions - towards a market preference (and demand) for Kraft products sourced from sustainably managed feedstock and from facilities that promote greenhouse-friendly technologies. Both of these criteria are prominent in the present Tumut mill and in the proposed expansion. This places Visy in a strong competitive position for the future.
As a result of direct market participation, further analysis and indicated long-term sales arrangements, the estimated annual volumes and proportions of production from the expanded
Tumut mill that will be sold in each of the key export regions are shown in Table 1.
11
Table 1
Expanded Tumut Mill Exports
Export Destination (Region)
Tonnes Kraft Paper per Year
Percentage of Total Mill
Production
Asia
175,000
40,000
US West Coast
Total
21
60,000
Europe
6
150,000
Africa
25
8
425,000
60
Alternatives to proceeding with the planned expansion of the Tumut facility are:
a) To import packaging material from elsewhere to satisfy Visy Tumut’s Australian customers
(which include other Visy Pulp & Paper mills);
b) To utilise imported semi-processed pulp for on-shore paper manufacture at the Tumut site or elsewhere; c) To forgo export market opportunities and remain a fully domestic-focused supplier; and/or
d) Build or purchase a mill offshore and import Kraft paper from this facility.
Visy does not believe that these are feasible alternatives to the proposed expansion. Further discussion of these alternatives is provided in Section 24.
2.2
Scale, Scope and Location
The choice of the existing Tumut site for the plant expansion conforms to the proponent’s original decision to implement a staged development on the site.
As originally conceived, the “Stage 2” of the Tumut plant outlined in the 1998 EIS was intended to produce up to 150,000 tonne per year of additional Kraft paper, bringing the total site to a maximum production level of 450,000 tonne per year. Had this remained the case, the expansion would have been possible without the need for a further DA.
However a number of factors have since led the proponent to consider the current proposal for an expanded facility. These factors include:
a) Visy having secured expanded market opportunities for manufactured Kraft product – both in
Australia and overseas;
12
b) Increased production efficiencies at the existing plant, enabling higher unit production than originally envisaged before the commencement of the existing operations; and
c) The availability of additional supplies of plantation softwood and waste paper feedstock to allow the higher production of Kraft paper.
Nevertheless, while the scale of paper production has increased since the original mill was envisaged, the physical scope of the expanded mill and the location of the components of the expansion have not altered materially since that time. That is, the project will deliver higher production within the same general physical footprint as originally envisaged for “Stage 2”. While the increased production will be at the same or better environmental efficiency rates, such higher production will entail a larger total volume of environmental impacts. These impacts will principally be in relation to traffic, air emissions, water consumption and wastewater generation. These impacts are described and assessed elsewhere in this report (refer to Sections 10 to 22).
2.2.1
Raw Materials
Fibre supply for the expanded mill will consist of pulp logs sourced from State Forests and private plantations, sawmill residues, purchased white pulp and waste paper. The main catchment for wood fibre is the Hume region, with supplementation from the Macquarie and Monaro regions.
Wastepaper will be sourced principally from Sydney and Melbourne. Further detail on raw material supply is provided in Sections 2.4.5 and 7.2.
2.2.2
Existing Infrastructure
The original pulp mill development provides the essential infrastructure and services required for the expanded plant. These comprise, in particular, electricity, gas, water, communications and transport networks.
2.2.3
Environmental Capacity of the Site
The 1998 approval for the existing mill facility anticipated a Stage 2 expansion, therefore most of the key environmental considerations pertaining to an expanded plant were contemplated and provided for at that time. In particular, the location of a future second paper machine was identified, to be incorporated into the existing plant footprint. Other production components will be located within the existing mill precinct. Figure F2 shows the elements of the expansion which will extend generally beyond the current operational site, but will remain generally within the current site’s perimeter roadway. These are:
13
•
The expanded mill wood yard;
•
The expanded reel store;
•
The new recausticising plant;
•
The new waste paper storage area; and
•
The new boiler fuel storage area.
Outside the immediate production site precinct, the expanded irrigation area lies to the south of the
Snowy Mountains Highway. This area was approved for irrigation operations as part of the initial consent which at the time involved the irrigation of a larger quantity of treated wastewater.
Subsequently a Statement of Environmental Effects was submitted in 2000 for the reduction in treated wastewater production and as such this area to the south of the Snowy Mountains Highway was not required for irrigation of wastewater from the existing operations. This area will now be utilised for the expanded development under the existing consent.
In view of the above considerations, the site has the required capacity to accommodate the environmental impacts associated with the expansion. Those impacts are detailed and assessed in this report.
2.2.4
Waste Management Objectives
This project utilises materials that would otherwise be considered waste by other processors. In particular, pine forest thinnings are removed to encourage the growth of remaining saw logs in the forest, and sawmill residues would otherwise be landfilled or burnt were it not for the market provided by the Visy facility. The facility will also utilise energy sources such as UWR and harvest resides which would otherwise be left to decompose in the forest or in landfill. Finally, the Kraft process is essentially a closed loop one with a high degree of water recycling and recovery of chemicals and process by-products within the mill process.
2.3
Environmental Performance of the Existing Mill
The current mill facility operates under a comprehensive approval and licensing regime as required and administered by the NSW Government.
14
More than 100 conditions are attached to the development consent, and the licence issued by the then NSW Environment Protection Authority (EPA) (now NSW Department of Environment and
Conservation (DEC)), covers discharge conditions relating to air, water, noise, waste and boiler fuel. The existing facility is widely acknowledged as exhibiting world’s best environmental performance with respect to the common performance indicators: water use, wastewater management, odour and air emissions.
Independent compliance audits indicate that Visy has complied with these conditions during the operation of the existing facility, except for some non-compliances which have been reported mainly due to commissioning, start-up and shut-down phases and early operation of the mill’s continuous emissions monitoring system.
Visy has adopted a continuous improvement philosophy during the operational development of the existing mill, and the facility is now operating at a level of consistency expected by the relevant regulatory authorities.
Section 6.2 of this report provides further detail on the environmental management performance of the existing mill facility.
2.4
2.4.1
Accommodation of the Expansion
Physical Site Constraints
The physical location of the expansion elements is shown in Figure F2. As can be seen from this layout, the accommodation of the expansion has been planned as part of the overall staged development of the facility. There are no constraints which pose logistical or other impacts that cannot be managed as part of the established mill’s operational systems.
15
2.4.2
Existing Air Quality
The current mill operates at well below the DEC Licence limits with respect to emissions to air as well as the impact assessment criteria specified in DEC guidelines (DEC 2005c). The air environment can easily accommodate the expanded mill operations despite the addition of new emission sources. This has been demonstrated by the air dispersion modelling presented in
Section 12.
2.4.3
Existing Traffic
The current mill is operating with a traffic movement profile significantly lighter than that predicted for the original approved development. This is due to enhanced backloading and use of B-double trucks. Consistent with the findings of a traffic study conducted as part of this EA (see Section 17), the expansion can be accommodated within the current road traffic system. Existing on-site parking and site traffic routes have been designed and constructed to cater for the expansion.
2.4.4
Existing Odour Performance
During commissioning and early operation of the current mill a number of odour issues were encountered. These have been reported as part of the ongoing environmental reporting and auditing procedures for the plant. Visy has responded to these odour issues by implementing a detailed odour-reduction program. As a result, odour complaints have now dropped to a very low level. The operating procedures designed to successfully manage odour will be applied to the expanded plant, and it is expected that the expanded plant will operate well within the currently accepted odour performance for the facility.
2.4.5
Catchment for Wood and Wastepaper Supply
Visy holds a long-term Timber Supply Agreement with the NSW Government for plantation-based pulpwood to supply the Tumut plant. The company also holds contracts for additional supply from private plantation owners and sawmills.
For the expansion, while the greater proportion of the required wood feedstock is already contracted, there is a logistical and timing mismatch between the required flow of additional wood fibre to feed the second paper machine, and production from new plantations within the mill’s current economic supply zone. This will require the initial sourcing of wood from more distant sources than would otherwise be contemplated for this development.
16
Accordingly, Visy has identified and contracted additional supplies of softwood in Macquarie and
Monaro Regions which will serve to fill any deficit in fibre supply while new plantations are being established and grown to “first thinning” stage within the mill’s economic supply zone.
Visy will continue to source wastepaper as a supplementary feedstock for the expanded mill’s production principally from Sydney and Melbourne, utilising backloading transport wherever feasible. The traffic impacts of transporting this additional wood and wastepaper feedstock has been assessed as part of this report (refer to Section 17).
2.5
Project Implementation
A phased approach is planned for the mill expansion. This will enable some plant components to be installed immediately, with others being progressively installed over time to meet the project’s expected production milestones. A description of the nature and scope of the project’s implementation is provided in Section 7.1.
2.6
Ecologically Sustainable Development Principles
Visy supports and pursues the principles of Ecologically Sustainable Development (ESD). They are:
•
Integrating economic and environmental goals in policies and activities;
•
Ensuring that environmental assets are properly valued;
•
Providing for equity within and between generations;
•
Dealing cautiously with risk and irreversibility; and
•
Recognising the global dimension.
Visy has a number of systems enabling integration of these principles in planning and management as well as having extensive internal and external assessment and measurement to track performance against the principles. Samples can be provided if required.
17
2.7
Consequences of Not Proceeding
The consequences of not proceeding with the planned expansion of the Tumut facility include the requirement to import packaging material to satisfy Visy’s Australian customers, utilising imported semi-processed pulp for on-shore paper manufacture at the Tumut site, and forgoing export market opportunities. 18
3.
STATUTORY REQUIREMENTS
Visy’s proposed expansion of the existing pulp and paper mill at Tumut requires planning approval in accordance with NSW planning legislation. The EPA Act which is administered by the NSW
Department of Planning (DoP) is the key legislation. Planning approval is also required to take into consideration any applicable SEPPs, and the development cannot be prohibited by any applicable regional environmental plan (REP) or local environmental plan (LEP). In addition to state planning and environmental legislation, Visy’s approval will have to comply with applicable commonwealth environmental legislation.
Environmental protection in NSW is dealt with by the Protection of the Environment Operations
Act 1997 (the POEO Act), which is administered by the DEC. The proposed expansion must also be considered with regard to this Act.
3.1
State Legislation
The key NSW legislation for Visy’s proposal is the EPA Act and subordinate regulations, as well as the Visy Mill Facilitation Act 1997.
3.1.1
Environmental Planning and Assessment Act 1979
Visy’s proposed expansion is a Major Project because the proposed expansion of the pulp and paper mill has a capital investment greater than $30 million ($375 million). Therefore Part 3A of the
EPA Act will apply which specifies that the Minister for Planning will be the consent authority for the proposed expansion. This is discussed further in Section 3.2.1.
Under Part 3A of the EPA Act an application for Concept Approval of a Major Project is to be lodged with the Director-General (Section 75O). This lodgement is to include an EA for which requirements are to be requested from, and provided by, the Director-General.
In addition, Part 3A of the EPA Act provides that the development and environmental assessment processes under Part 4 and Part 5 of the Act do not apply in respect of an approved project.
Further, under Part 3A environmental planning instruments (other than SEPPs) do not apply to an approved project. However, the project cannot be approved if the development is prohibited under any environmental planning instrument.
19
3.1.2
Environmental Planning and Assessment Regulation 2000
The EPA Regulation provides further detail on the process to obtain Concept Approval for a Major
Project. This includes statutory timeframes, information to be made available to the public and applicable fees and charges. As the proposed expansion is subject to the provisions of the EPA
Act, the EPA Regulation applies.
3.1.3
Protection of the Environment Operations Act 1997
The POEO Act is the key piece of environmental protection legislation administered by the DEC.
Visy has an existing Environment Protection Licence under the POEO Act to authorise the carrying out of a scheduled activity at the Tumut premises. Visy’s operation is considered to be a scheduled activity under Schedule 1, Paper, pulp or pulp products industries (1), being:
“Schedule 1
Schedule of EPA – licensed activities
Paper, pulp or pulp products industries that manufacture paper, paper pulp or pulp products and that have an intended production capacity of more than:
(1) 30,000 tonnes per year.
The existing Licence would require amendment for the proposed expanded mill operations.
3.1.4
Protection of the Environment Operations (Clean Air) Regulation 2002
The facility is classified as a Pulp and Paper Mill under Schedule 3 of the POEO (Clean Air)
Regulation. The existing operations comply with Group 5 emission limits under Schedule 3 and the expanded plant will be required to meet Group 6 emission limits under the same Schedule.
3.1.5
Visy Mill Facilitation Act 1997
The Visy Mill Facilitation Act 1997 was enacted to facilitate the development and approval of the existing mill facility, which at the time, as now, was envisaged as a staged development comprising two stages. Hence this Act applies to the current proposed development works, and the proposed expansion constitutes the second stage for the purposes of this legislation. The Act provides that the State and its agencies will “…act to promote the principal purpose of this Act, and in particular will use their best endeavours to assist the Company and any other persons to obtain any approvals that are necessary for or relevant to any of the designated activities, and to ensure that, within the applicable legislative structures, any such approvals will be granted….”.
20
3.2
State Environmental Planning Policies
SEPPs are legislative environmental planning instruments administered under the EPA Act. SEPPs deal with issues considered to be significant to the state and people of NSW. The SEPPs applicable to Visy’s proposed expansion include:
•
•
SEPP No. 33 – Hazardous and Offensive Development (SEPP 33);
•
SEPP No. 34 - Major Employment - Generating Industrial Development (SEPP 34); and
•
3.2.1
SEPP (Major Projects) 2005;
SEPP No. 55 – Remediation of Land (SEPP 55).
State Environmental Planning Policy (Major Projects) 2005
The SEPP (Major Projects) 2005 defines developments that are considered to be Major Projects and for which Part 3A of the EPA Act applies. Visy’s proposed expansion of the pulp and paper mill having a capital investment greater than $30 million. The facility is therefore captured under
Schedule 1, Group 1 of the SEPP (Major Projects) 2005, being:
“Schedule 1
Part 3A projects – classes of development
Group 1
Agriculture, timber, food and related industries
Part 4
Timber milling, timber processing, paper or pulp processing
Development that employs 100 or more people or has a capital investment value of more than $30 million for the purpose of:
(b)
3.2.2
Manufacture of paper, pulp, cardboard or newsprint.”
State Environmental Planning Policy No. 11 – Traffic Generating Developments
This policy is directed at ensuring the NSW Roads & Traffic Authority (RTA) is made aware of, and is given an opportunity to make representations in respect of proposed developments that meet certain threshold criteria. Visy's proposed expansion meets at least one of the specified criteria, namely “…the erection of a building for the purposes of industry where the gross floor area is or exceeds 20,000 square metres, or its extension is or exceeds 20,000 square metres…”.
Accordingly, Visy has consulted with RTA during the preparation of the EA.
21
3.2.3
State Environmental Planning Policy No. 33 – Hazardous and Offensive Development
SEPP 33 provides definitions for hazardous and offensive industries and hazardous and offensive storage establishments. SEPP 33 also defines proposals that are potentially hazardous and potentially offensive and requires specific matters to be considered in the proposal. This includes the requirement to conduct a preliminary hazard analysis (PHA) to support the development and to advertise the development for public comment.
Guidelines published by the DoP provide guidance on PHA, and in particular the DoP 1994
Applying SEPP 33, Hazardous and Offensive Development Application Guidelines outlines the risk screening method to determine if a PHA is required. This risk screening and preparation of a PHA as required has been undertaken for Visy’s proposed expansion. Refer to Section 18.
3.2.4
State Environmental Planning Policy No. 34 – Major Employment – Generating Industrial
Development
The key criterion of this Policy which brings the Visy expansion under its direction is that the development has a capital investment value of $20 million or more (excluding land).
3.2.5
State Environmental Planning Policy No. 55 – Remediation of Land
The SEPP 55 states that land must not be developed if it is unsuitable for a proposed use due to contamination. The Tumut site was rural/pastoral land prior to development of the existing facility.
Independent environmental audits of current operations confirm that all relevant conditions of consent have been met since commissioning. The site is therefore suitable for an ongoing industrial/commercial land use.
3.3
Regional Environmental Plans
REPs are legislative environmental planning instruments made under the EPA Act. REPs deal with issues such as urban growth, commercial centres, extractive industries, recreational needs, rural lands and heritage and conservation. REPs do not apply to a project approved under Part 3A of the
EPA Act. However, a project cannot be approved under Part 3A of the EPA Act if the development is prohibited by an applicable REP. There are no REPs applicable to Visy’s proposed expansion.
22
3.4
Local Environmental Plans
LEPs are legislative environmental planning instruments administered under the EPA Act. LEPs are prepared by local Councils and guide planning decisions for local government areas (LGAs).
Similarly to the REPs, LEPs do not apply to a project approved under Part 3A of the EPA Act.
However, a project cannot be approved under Part 3A of the EPA Act if the development is prohibited by an applicable LEP. Visy’s existing pulp and paper mill is located within Tumut Shire
Council LGA. The applicable LEP is the Tumut Local Environmental Plan 1990.
3.4.1
Tumut Local Environmental Plan 1990
The Tumut LEP 1990 has been developed to encourage the proper management, development and conservation of natural and man-made resources as well as facilitating growth and development within the Shire of Tumut. The Tumut LEP outlines the objectives and relevant development controls of each Zone of land. The existing mill is located within Zone 1(a) (Rural Zone) and it is permissible in the Zone with consent.
3.5
Development Control Plans
Local Councils also prepare development control plans (DCPs) that provide more specific and comprehensive guidelines for development proposals. DCPs do not apply to a project approved under Part 3A of the EPA Act. However Visy recognises DCPs reflect local concerns and issues and accordingly has reviewed the proposed development in the light of two particular DCPs viz:
•
Tumut Shire Council Development Control Plan No. 3 Car Parking; and
•
Tumut Shire Council Development Control Plan No. 6 Industrial Development.
3.5.1
Tumut Shire Council Development Control Plan No. 3 Car Parking
The purpose of the TSC Car Parking DCP is to ensure development proposals provide adequate on and off-street parking and delivery vehicle facilities. The DCP requires car parking to be designed as follows:
•
Access to and from the site shall be located where it causes the least interference to vehicular and pedestrian traffic on a public road;
•
Pedestrian safety must be considered;
•
The car park must be designed to achieve ease of manoeuvrability and appropriate sight lines into, from and with the site;
23
•
Parking is to be provided for persons with a disability in appropriate locations to meet demand;
•
Parking spaces for vehicles other than cars;
•
Landscaping must be provided to ensure that car park construction and use does not have a detrimental impact on the surrounding environment;
•
For car parks used at night, adequate lighting is required to facilitate safety and encourage use;
•
Must be designed to minimise the opportunity for crime to be committed;
•
Provide signage to allow users to easily navigate into, out of and through the car park;
•
Incorporate an adequate drainage system;
•
Provision must be made for delivery vehicles; and
•
Specific parking schedule.
The traffic assessment undertaken for the expansion (see Section 17) indicates that demand for additional spaces as a result of the expansion can be met within the current site carpark.
3.5.2
Tumut Shire Council Development Control Plan No. 6 Industrial Development
The TSC DCP No. 6 industrial Development aims to encourage economic growth and job creation through sustainable industrial development. The DCP provides guidance on sustainable development, setbacks, parking, landscaping, building design, fencing and advertising signs. The performance of industrial developments with the Rural (1a) Zone are:
•
To preserve quality agricultural land for agricultural purposes;
•
To preserve the rural areas from industrial creep; and
•
To support agricultural industry in Rural (1a) Zones.
The DCP has been considered in the preparation of this EA.
3.6
Commonwealth Legislation
The relevant commonwealth planning and environmental legislation includes:
•
Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).
24
There are three triggers under the EPBC Act whereby a Commonwealth Environmental Impact
Assessment (EIA) may be required. These include actions that would or are likely to have a significant impact on matters of national environmental significance, actions that would or are likely to have a significant impact on commonwealth land and actions by the commonwealth or its agencies that would or are likely to have a significant impact on the environment inside or outside
Australia. Matters of national environmental significance include World Heritage properties,
RAMSAR wetlands, threatened species or ecological communities listed in the EPBC Act, migratory species listed in the EPBC Act, the environment in a Commonwealth marine area and nuclear actions. Visy’s proposed expansion of the existing pulp and paper mill at Tumut does not fall into any category that would require an EIA. Therefore, the statutory requirements outlined in EPBC Act have not been considered further.
Other Commonwealth law applying to the operation of the existing and expanded plant includes that dealing with the National Pollutant Inventory and Energy Efficiency and Greenhouse Gas abatement. The Commonwealth recently introduced the Energy Efficiency Opportunities Act 2006.
This requires a company (measured as an ownership group) to register for energy efficiency management and reporting purposes if its annual energy use exceeds 0.5 petajoules (PJ). On this basis, Visy may be required to register for the purposes of this Act.
25
4.
CONSULTATION
Visy’s consultation with stakeholders including regulatory agencies and the local community has been on-going since the earliest days of project development for the existing mill, and included the prospect of an expansion of the project. Having commenced well before the construction of the mill itself, meetings with the Visy Community Consultative Committee (VCCC) continue today on a monthly basis. The meetings provide an opportunity for two way communications – where Visy can learn about issues raised by the broader community and where community representatives are informed of the mill’s operation and performance. Similarly, meetings with regulatory agencies such as the DEC also continue on a regular basis.
The Director-General’s Requirements issued to Visy for the mill expansion at Tumut specify that
Visy must undertake consultation with the following parties in the preparation of the EA:
•
DEC;
•
NSW Department of Health;
•
RTA;
•
Tumut Shire Council;
•
VCCC;
•
The local community; and
•
The local aboriginal community
The specific liaison undertaken with the above parties is described further in the following sections.
In addition Visy held briefings with representatives of other government agencies including:
•
NSW Premier’s Department;
•
NSW Department of State and Regional Development;
•
NSW Department of Energy Utilities and Sustainability; and
•
Commonwealth Department of Industry, Tourism and Resources.
26
4.1
NSW Department of Environment and Conservation
Visy held meetings with the DEC in November 2005, June 2006 and September 2006, to discuss the mill expansion at Tumut. DEC also provided a letter to the DoP dated 20 June 2006 outlining their recommendations for the conduct of the assessment, which have been included in the
Director-General’s Requirements outlined in Section 4.8. An additional assessment was required in relation to the removal of a potential aboriginal scarred tree in the area designated for the expansion of the irrigation system on the Visy owned property, south of the Snowy Mountains
Highway. This assessment including consultation with the local aboriginal community is discussed in Section 23.
4.2
NSW Department of Health
Visy consulted with the NSW Department of Health on their requirements for the assessment.
These requirements, and the Sections of the EA in which they are discussed are outlined in Table
2.
Table 2
NSW Health Requirements
Requirements
EA Section
22
•
Health risk assessment
•
Additional monitoring of air toxics emissions
•
Odour assessment
13
•
Noise assessment
14
4.3
26.3.1
NSW Roads and Traffic Authority
The RTA requested prior review of the Draft Traffic Assessment Report during the EA process and indicated its acceptance of the methodology and conclusions. A final copy of the Traffic
Assessment Report is provided in Appendix Q and discussed in Section 17.
27
4.4
Tumut Shire Council
Two formal presentations and a number of informal meetings were held at Tumut Council chambers to consult on the Visy Tumut mill expansion proposal. The General Manager and all Councillors were provided with a full copy of the “Project Summary and Environmental Issues” document submitted to DoP and a newsletter which was later featured in the local newspaper. Comments from Tumut Shire Council regarding the proposed expansion were mainly in relation to the increase in traffic as a result of the expansion. The mill expansion proposal received positive feedback in relation to economic and employment opportunities for the area. The aspects of the proposal that were of interest to the Council are shown in Table 3.
Table 3
Tumut Shire Council – Aspects of Interest
Aspect of Interest
EA Section
•
Traffic impacts
17
•
Economic impact and employment, including housing
20
4.5
Visy Community Consultative Committee
As outlined earlier, meetings with the VCCC occur on a monthly basis. At each meeting the VCCC are given updates on the progress of the mill expansion plans. In June 2006 the group was provided with a project summary document outlining the mill expansion proposal and also received a newsletter to the same effect which also outlined the approvals process. The main comments that have been raised by the VCCC are in relation to increase in traffic as a result of the mill expansion, odour and air emissions due to additional sources and noise impacts for immediate neighbours.
The VCCC were positive towards the economic and employment opportunities that the expansion proposal provided for the area.
Table 4
VCCC – Aspects of Interest
Aspect of Interest
EA Section
•
Traffic impacts
17
•
Economic impact and employment
20
•
Odour impacts
13
•
Air emission impacts
12
•
Noise impacts
14
28
4.6
Local Community
In June 2006 Visy distributed a newsletter to all neighbours of the Tumut mill outlining Visy’s plans for expansion of the Tumut mill. The newsletter was also later featured on the front page of the local newspaper. Visy’s close relationship with the Gilmore Progress Association has also ensured that the expansion plans have been included in the local area newsletter to all Gilmore Valley residents.
In all forms of communication to the local community contact names and numbers of Visy representatives were provided so that any community member could call and ask about any aspect of the expansion. Few calls were received and these were mainly in relation to potential employment prospects for future mill operations. In order to gauge the views of the close neighbours of the mill, one on one consultation meetings were offered via phone and letter.
Table 5 outlines the main aspects of interest raised by the neighbours consulted either in person or on the phone.
Table 5
Local Community – Aspects of Interest
Aspect of Interest
EA Section
17
•
Traffic impacts
•
Traffic noise impacts
•
Odour impacts
13
•
Air emission impacts
12
•
Health impacts
22
•
Noise impacts
14
•
Economic impacts and employment
20
•
Expansion of the wastewater reuse system
11
4.7
14.2
Other Stakeholders
Representatives of Visy have met on a number of occasions with representatives of peak environment groups in NSW and nationally, representatives of Timber Communities Australia (a rural community support network), and a large number of tour groups and service organisations.
These provided opportunities for Visy to detail the proposed expansion and to seek comments from these groups.
29
4.8
Director-General’s Requirements
The Director-General’s requirements for the mill expansion and the sections of the EA in which they are discussed are outlined in Table 6. The Director-General’s requirements are provided in
Appendix A.
Table 6
Director General’s Requirements
Requirements
•
Executive Summary
EA Section
Executive
Summary
•
Project description, including construction, operation and staging
•
Assessment of environmental impacts with particular focus on the key
7
10 to 23
assessment requirements
•
Justification for undertaking the proposal
2
•
Draft Statement of Commitments
27
•
A signed statement from the author of the EA
•
Strategic assessment of the project
2
•
Air quality
12
•
Demonstration of consistency with DEC Guidance Note, Assessment of
Start of EA
8 and 12
Non-Standard Fuels (DEC 2005a) including a demonstration of best practice •
Mass balance of the combustion of any fuel other than natural gas or
12.5
liquefied petroleum gas
•
Demonstration of compliance with Protection of the Environment
12.3
Operations (Clean Air) Regulation 2002
•
Demonstration that air emissions will not exceed acceptable human
22
health standards
13
•
Assessment of odour impacts
•
Assessment of noise impacts during construction and operation
•
Details of noise mitigation measures
•
Assessment of water quality impacts, including a water balance
7.20, 10 and 11
•
Demonstration of water efficient practises and technologies on site
6.1.4, 6.1.5, 7.20
•
Assessment of the long term sustainability of effluent re-use
•
Assessment for potential groundwater and surface water contamination from the current and expanded irrigation of effluent
14 & 21.2
26.4.3
11.3.4
6.3.1.1 and
11.3.4
30
Requirements
EA Section
15
•
Details of waste streams and process by-products
•
Assessment of the use of non-standard fuels including information on
Appendix D
fuel ratios and compositions
Appendix D
•
Details of recovered paper input specifications
•
Hazard and risk analysis
•
Site map showing the location of existing plant, new plant, current and
18
Figure F27
additional gas supply and metering infrastructure
•
•
The operation of a Kraft pulp mill at the Visy Tumut site was approved by the Minister for Planning in 1998 (reference S96/00598). The EIS that was prepared for the then-proposed mill includes a detailed description of the on-site operations, including the Kraft pulp process. The previous EIS should be referenced for full details and information regarding the existing operations. The general
Kraft pulp process is described in the following section.
The Kraft process is used to produce 80% of the pulp manufactured around the world. The pulp that is manufactured by the Kraft process is then used as the key input to paper production. The process was first commercially used in Sweden in 1885. The term “Kraft” comes from the
German/Swedish word “kraftig”, meaning strong.
The Kraft pulp process is relatively simple in terms of the processes used to convert woodchips to pulp. However, additional operations are used to efficiently recover the chemicals required for the manufacture of the pulp. Extensive heat recovery stages are also incorporated into the Kraft process. The Kraft pulp process is therefore an efficient cyclic process involving:
•
Cooking of woodchips to produce pulp;
•
Washing of the pulp;
•
Recovery and re-use of chemicals used in the cooking process; and
•
Recovery and re-use of heat in the pulping process.
The key elements of the Kraft process are outlined in Table 7. Figure 2 shows the main inputs and outputs, including the fibre and chemical flows, for a typical modern Kraft mill. However the extent of chemical reuse and recovery may vary between mills.
32
Wood Waste
Steam
Power Boiler
Lime
Logs
Bark
Wood Yard
White Liquor
Woodchips
Lime Kiln
Recausticising
Lime Mud
Green Liquor
Digester
Wash Liquor
Cooked Chips
Recovery Boiler
Heavy Black Liquor
Weak
Black
Fibreline
Evaporators
Paper Machine
Water
Figure 2
Main Inputs and Outputs at a Typical Kraft Pulp Mill
Table 7
Paper
Key Elements of Kraft Pulp Process
Element
Digester
Description
The woodchips are cooked using steam and chemicals (white liquor), to produce soft but still structured chips. The used chemicals are known as weak black liquor.
Fibre line
The cooked chips are mechanically treated to reduce the chips to pulp, and washed to remove the cooking chemicals.
Evaporators
The weak black liquor from the digester is concentrated to heavy black liquor via extraction of water. The resultant heavy black liquor is kept in molten form for firing in the recovery boiler.
Recovery boiler
The heavy black liquor is combusted, and the inorganic components from the liquor are recovered and dissolved in a water solution to form green liquor.
Recausticising
Sodium hydroxide is recovered from the green liquor to produce white liquor, which is then used back in the digester. Lime is used in this process, and lime mud is generated as a by-product.
33
Element
Lime kiln
Description
Thermal decomposition is used to convert the lime mud to lime, which is then used in the recausticising process.
The three types of liquor mentioned in Table 7 form the basis of the Kraft chemical recovery cycle.
These are described below in further detail.
White Liquor
White liquor contains the cooking chemicals sodium hydroxide and sodium sulfide. It is the product of adding lime (calcium oxide) to green liquor and its name is derived from its milky white appearance before it undergoes filtration.
Black Liquor
Weak black liquor is the by-product of cooking woodchips in white liquor. The sodium hydroxide and sodium sulfide in the white liquor break down and dissolve the lignin in the wood, which frees the wood fibres. The result is organic sodium salts and organic sulfur compounds.
Green Liquor
Green liquor contains predominantly sodium carbonate and sodium sufide. It is the product of dissolving the smelt (molten salt) formed from burning black liquor in the recovery boiler. The name is derived from the green compounds formed by non-process elements such as iron and manganese. The Kraft process produces odorous reduced sulfur compounds such as hydrogen sulfide and mercaptans. The Tumut mill has a system in place which captures these odorous compounds and destroys them in the recovery boiler.
Section 6 provides further details on the existing mill operations at the Visy Tumut site. The expansion of the Tumut mill is described in Section 7.
34
6.
DESCRIPTION OF EXISTING MILL OPERATIONS
This section of the EA provides an overview of the existing mill operations and its environmental performance. Input for this section has been taken from audit reports, Visy’s Annual Compliance and Monitoring Reports, DEC Annual Returns and a review of the environmental monitoring records. The mill was designed to meet some of the most the stringent emissions limits in NSW which has been written into the site’s Protection of the Environment Operations (POEO) Licence issued by the
NSW DEC and Development Consent Conditions issued by the DoP. The mill has proven to meet these limits with some exceptions as described in this section.
Design of the mill incorporates Best Available Techniques (BAT) for all environmental aspects of operation including air emissions, energy and water use. The mill generates 70% of its own energy from renewable resources and is highly water efficient, irrigating all treated effluent onto dedicated and managed pastures. Awards for exemplary performance of the mill have included:
•
Winner – United Nations Association of Australia Excellence in Water Management Award –
Visy Pulp and Paper Pty Ltd;
•
Winner – Institution of Engineers Australia, Sydney Division – Engineering Excellence Awards
2002, Products, Manufacturing and Control Systems;
•
AA rated, first company for Environmental Reputation (E1 rating) – Reputex survey of
Australia’s top 100 companies (fifth year in a row);
•
Winner – Banksia Environment Foundation - Gold Banksia Award 2004;
•
Winner – Banksia Environment Foundation Award – Business Environmental Responsibility and
Leadership;
•
Highly Commended – SEDA - Biomass Cogeneration Plant, Visy Pulp & Paper, for a large generation project that reduces greenhouse gas emissions; and
•
Banksia Environment Foundation - Finalist: Corporate Responsibility and Sustainability - Visy
Pulp and Paper, Tumut.
Certification of the mill’s environmental management system to ISO 14001 was also achieved in
2003. Certification to 14001:2004 was achieved in 2005 and further accreditation for the combined safety, environment and quality system was achieved in 2006.
35
As outlined in Section 4, Visy’s consultation with the local community has been on-going since the earliest days of project development. Having commenced well before the construction of the mill itself, meetings with the VCCC continue today on a monthly basis. Visy has been actively involved in broader community projects, and has undertaken various studies to understand its broader impacts/contribution to the community. This is discussed further in Section 20.
However, operation of the mill to date has not been without its challenges. Odour management has been at the forefront of these challenges since commissioning in 2001. Visy’s dedication to addressing odour issues has seen a number of improvements to the mill design. Although significant reduction in odours has been achieved this commitment continues every day through vigilant management of odour sources.
The following section includes an overview of compliance with statutory requirements including a summary of environmental management and environmental monitoring results.
6.1
Existing Mill and Operations Summary
6.1.1
Location Setting
The existing Visy property occupies an area of approximately 1,400 ha and is located in the Gilmore
Valley, approximately 8 km directly west of Tumut on both sides of the Snowy Mountains Highway.
It is bound to the north by the Tabletop Mountain range, to the west by Deep Creek, to the south by
Windowie and Electro properties and to the east by Gilmore Creek. Sandy Creek flows through the
Visy property from west to east. Figure F3 depicts the mill location in reference to Tumut and the surrounding towns. Figure F4 shows the boundary of the Visy property, and Figure F5 show the lots which comprise the property.
The mill site occupies some 53 ha, which is approximately 3.8% of the total Visy owned property.
The existing irrigation area occupies approximately 110 ha which is 7.9% of the total property area.
6.1.2
Existing Plant and Equipment
The existing mill consists of the following main facility infrastructure elements:
•
Wood yard;
•
Recycled fibre plant;
•
Kraft pulp mill;
36
•
Recovery island (evaporation plant, recovery boiler and recausticising plant);
•
Power boiler;
•
Ancillary mill infrastructure;
•
Kraft liner paper mill;
•
Water management and recycling system;
•
Water supply pipeline from the Tumut River to the mill;
•
Electricity supply line to the mill; and
•
Natural gas supply pipeline to the mill.
A plan of the existing site is shown in Figure F6. The 1998 EIS provided a detailed description of the existing mill operations.
6.1.3
Production
Visy commenced operation of the existing mill in May 2001 to produce up to 300,000 tpy of unbleached Kraft liner for both the local and overseas markets. Table 8 outlines the gradual rise in annual production to reach the anticipated production goal of 300,000 tpy.
Table 8
Production Rates
Financial Year
2002-2003
2003-2004
242,530
274,040
2004-2005
281,759
2005-2006
6.1.4
Production (tpy)
295,401
Freshwater Use
Freshwater is primarily used in the process in boilers for the generation of steam, for mechanical sealing, cooling water in heat exchangers and as emergency make up water for the cooling towers.
A large proportion of the water used in the process is derived from the water entering with the woodchips which is extracted during the digestion process and then evaporated to recover cooking chemicals. The condensate produced by evaporation is cleaned and reused in various parts of the mill including the paper machine as a substitute for freshwater. The average freshwater usage per tonne of paper produced since 2001 is shown in Figure 3.
37
3
Figure 3
Average Annual Freshwater Usage per Tonne of Paper Produced (m /tonne of paper
produced) 2001 – 2006
7
6.07
Production (tonnes)
300,000
274,040
281,759
295,401
6
242,530
250,000
200,000
5.75
5
4.38
3.85
175,700
3.66
4
150,000
3
100,000
2
50,000
1
0
0
2001-2002
2002-2003
2003-2004
2004-2005
2005-2006
Wastewater Generation and Irrigation
Since the existing mill is an efficient user of water by world standards, the generation of wastewater is also very low. Approximately 1.18 m3 of wastewater is produced per air dry tonne of paper manufactured. Figure 4
3
Average Wastewater Generation per Tonne of Paper Produced (m /tonne of paper)
from 2001-2006
2.37
274,040
295,401
2
3
242,530
250,000
200,000
281,759
1.69
1.5
175,700
1.43
1.41
150,000
1.18
1
100,000
0.5
50,000
0
0
2001-2002
2002-2003
2003-2004
2004-2005
2005-2006
Wastewater Generation (m
300,000
2.5
/tonne)
350,000
Production (tonnes)
6.1.5
Freshwater Usage (m 3/tonne)
350,000
38
Visy’s low freshwater usage and wastewater generation is achieved by:
•
Careful design of process water loops to maximise the re-use of process water streams (i.e. condensates) and minimise the use of freshwater for certain functions (make up water only);
•
Reuse of all paper machine effluent in the fibreline for pulp washing, countercurrent to flow of pulp; and
•
Collecting and processing all process water through the evaporators to recover pulping chemicals and avoid the flow of sulfur and other process materials to other parts of the water circuit. Treated wastewater is delivered to the winter storage dam which has a storage capacity of 480 ML.
During the irrigation season the treated effluent is applied through five centre pivot (CP) irrigators and a soft hose traveller (SHT) irrigator to approximately 110 hectares (ha) of land on the Visy property, currently dedicated for irrigation of treated wastewater from the existing operations. In the winter months when irrigation is not possible due to high rainfall, the treated wastewater is stored in the winter storage dam.
Irrigation scheduling is based on continuous monitoring of weather and soil moisture data. A series of dams collect runoff from the irrigation areas. The runoff is primarily generated during rain events, and is pumped back to the winter storage dam for re-use.
Crops that have been grown under the existing irrigation areas include oats, maize, sorghum and pasture for silage and hay production, which feed Visy’s 1,600 head of cattle.
6.1.6
Power Generation and Consumption
Visy meets the requirements of being an electricity generator from renewable energy resources under both the Commonwealth Mandatory Renewable Energy Target (MRET) and the NSW
Greenhouse Abatement Scheme (GGAS). Approximately 90% thermal energy and 70% of the mill’s electricity requirements are generated on site from renewable ecologically sustainable resources as a replacement to traditional fossil fuels. The power boiler utilises wood residues as its primary fuel, sourced from bark from the on site debarking process and sawmill residues. Visy also has approval to utilise UWR and compost manufacturing residues (CMR) diverted from landfill as fuel. Figure 5 illustrates the power imported, generated and consumed per year from 2001-2005.
39
Figure 5
Imported, Generated and Consumed Power Per Year 2001- 2006 (MW Ave)
30.0
25.0
MW Ave
20.0
15.0
10.0
5.0
FY 2001/02
FY 2002/03
FY 2003/04
Year
6.2
6.2.1
FY 2004/05
FY 2005/06
Import
Generated
Total Consumed
Environmental Management
Compliance with Statutory Requirements
The current mill operates under a Development Consent with over 100 Conditions of Consent issued by the DoP (then Department of Urban Affairs and Planning) and a POEO Licence administered by the DEC (then NSW EPA) covering discharge conditions relating to air, water, noise and waste.
Each year an independent compliance audit is carried out to monitor compliance with POEO
Licence and Development Consent Conditions. Visy has demonstrated a high level of compliance with these conditions and limits. Non-compliances occurred mainly during the commissioning phase of the current mill. Non-compliances associated with the operational phase have been in relation to air emissions a result of non steady state operating conditions, and the Adelong transport curfew imposed by the conditions of consent.
40
6.2.2
Environmental Management System
The mill has in place a comprehensive Environmental Management System (EMS), accredited to
ISO 14001. Environmental issues are discussed on a day to day basis, and complaints and incidents are managed and reported in accordance with the requirements of the site’s EMS.
Training is conducted for site personnel for an array of skills from environmental awareness through to fire fighting and emergency preparedness. Records of training are documented and kept on site.
All activities relating to environmental management of the mill are reported annually in the Annual
Compliance and Monitoring Report which is submitted to government and the VCCC.
6.2.3
Complaints Management
The site maintains a 24 hour free complaints hotline where all complaints, notifications or comments are logged and electronically entered into the Visy E Alert system. Visy follows up and visits the complainant where possible (and if the complainant agrees) and advises them of the results of the investigations. Additionally Visy personnel carry out regular visits to nearby neighbours to ensure that any concerns or issues raised have been satisfactorily addressed. Management of odours has been a continual focus for mill management since commencement of operations in 2001, and the majority of complaints received relate to this issue. Operational staff has developed a checklist of potential odour sources and routine inspections of these items are undertaken.
Figure 6 illustrates the total number of odour complaints received per year from the public from
2001 through to June 2006.
41
Figure 6
Total Odour Complaints per Year 2001 - 2006
450
350,000
400
295,401
274,040
281,759
300,000
350
250,000
300
250
200,000
175,700
200
150,000
150
Production (tonnes)
Number of Complaints
242,530
100,000
100
50,000
50
0
0
2001-2002
2002-2003
2003-2004
Year (Jul-Jun)
2004-2005
2005-2006
Production (tonnes)
Total Complaints Per Year (Jul-Jun)
The above figure demonstrates notable reduction in the number of complaints received in 2006.
This has been due to the implementation of odour improvement works through the years since
2001. These odour improvement works are outlined in Section 6.3.4.
While there has been an overall decrease in odour complaints, continuous vigilance and attention is maintained to prevent odour issues arising. A further analysis shows historically that the majority of complaints regarding odour have been made by residents within a 5 km radius from the mill. An overall decreasing trend in the number of complaints from all areas is evident over the last 4 years
(refer to Figure 7).
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Figure 7
Total Number of Odour Complaints by Distance from the Mill June 2003 – June 2006
